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Monsoons Book Club’s advertisement campaign is a legitimate commercial activity

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By Stephen Chang
I am curious to read that the Media Development Authority (MDA) of the Singapore government has demanded that The Opinion Collaborative Limited (TOC Limited) should return money received from the Monsoons Book Club Limited (MBC), a social enterprise registered and based in the UK, for sponsoring an essay competition publicised by The On-line Citizen which at the material time was managed by TOC Limited. As part of the arrangement between the two social enterprises, The Online Citizen will advertise the logo of MBC as one of the sponsors of the essay competition.
In a letter dated 4 March 2016 to TOC Limited, Ms Yuvarani Thangavelu (Director, Licencing Division of MDA) wrote, to quote, “The MDA has determined that TOC Limited had received funds from a foreign source but not for bona fide commercial purposes.  Accordingly, TOC Limited is to return the funds to MBC Ltd…”
I would like to pose the following question to the MDA.
If a social enterprise, say in the nature of an educational establishment (such as a school or university), registered and based in the UK as a non-commercial and non-trading company or a charitable trust, advertises in a private social media like The Online Citizen in return for publicity to attract Singapore students, would the MDA prevent TOC Limited from receiving the advertising money because the money received was not for bona fide commercial purpose?

Monsoons-Book-Club-logo
MBC’s logo, published by TOC as part of the “My Singapore, My Future” essay contest jointly organised with TOC Ltd.

Such an educational establishment does not have shareholders and invests all its surplus income over its expenditure (profit) in improving the school/university and providing scholarships. The MBC, a social enterprise registered and based in the UK, is similar to such an educational establishment.  While an educational establishment would advertise to attract Singapore students, MBC uses the advertisement to publicise the Book Club as the venue for intellectual discussions.
MBC’s objectives as set out in its constitution (Articles of Association) registered with the UK authorities are:

  1. Promote the reading of books which offer challenging ideas for social change.
  2. Encourage discussions and critical thinking about social, political and economic progress in the South East Asian Region.
  3. Provide a platform for people from all walks of life, including writers, intellectuals, artists, researchers, and politicians to inform, share their thoughts, challenge conventional views, and be challenged.
  4. Publish and disseminate reports and recordings of events set out in objectives 2 and 3 above to a wider audience through written, audio and video media.

The MDA in its media release said, “TOC Ltd has undertaken not to receive funding from foreign sources for the provision, management and/or operation of the website, The Online Citizen, except for bona fide commercial purposes.  This is to ensure that foreign entities do not engage in domestic politics and to uphold the principle that domestic politics must remain a matter for Singapore and Singaporeans alone.”
Firstly, the sponsoring by MBC of an essay competition promoted by TOC Limited in return for advertising MBC on TOC is a bona fide commercial activity as explained above.
Secondly, I do not see any of MBC’s objectives as set out above to be engaging in Singapore domestic politics or to be sinister.  I classify them to be educational. I would have thought that all democratic countries would welcome participation by their citizens in activities promoted by MBC.
The writer is a retired Chartered Accountant

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