Senator Cory Bernardi, the conservative warrior who led the charge against Senator Sam Dastyari, is himself involved with a fundraising entity that inhabits a grey area in the political donations system and permits gifts from foreign donors.

Founded by the hard-right senator in 2009, the Conservative Leadership Foundation, based in Adelaide, solicits public donations, runs networking events and trains “future political and business leaders”.

But unlike other fundraising entities linked to senior Liberals, it has never made a disclosure to the Australian Electoral Commission as an associated entity, nor disclosed any political expenditure. The foundation is not named as a donor in Liberal Party returns.

Associated entities are defined in the Commonwealth Electoral Act as operating “wholly or to a significant extent for the benefit of one or more registered political party”.

The foundation did not respond to emailed questions this week, but in June, a spokesperson denied the organisation made political donations, or was even a political organisation.

“[The CLF] is an educational and leadership development organisation for young conservatives,” the spokesperson told Fairfax Media. “It has never contributed financially to any political party or any political candidate [and] our charter expressly prohibits such involvement.”

But as well as a platform for the views of its chairman, Senator Bernardi, on political issues such as the repeal of Section 18C of the Racial Discrimination Act, the foundation’s website and Facebook page boast of the success of CLF alumnus James Paterson in his surprise Liberal preselection for the Senate in March.