ADDENDUM AGREEK ORTHODOX ARCHDIOCESE OF AMERICA
CONFLICTS AND RELATED PARTY TRANSACTIONSDISCLOSURE POLICY ("Policy")
FOR OFFICERS, KEY EMPLOYEES, AND MEMBERS OF THE
ARCHDIOCESAN, METROPOLIS AND PARISH COUNCILS
Officers, Key Employees1, and Members of the Archdiocesan Council, the Direct
Archdiocesan District/Metropolis (collectively, "Local" or "Metropolis ") Councils andthe Parish Councils, herein referred to collectively as "Related Party or Related Parties"
are entrusted with sacred responsibilities which affect the whole of the Archdiocese2. Allsuch individuals shall honor that trust with honesty, competence, and care, in managing
the affairs of the Archdiocese and shall always act in the best interests of theArchdiocese.
The purpose of this Policy is to set forth procedures for properly disclosing andaddressing conflicts of interest and related party transactions.
A "Conflict" exists when the financial or any other interest of a Related Party, or amember of his/her immediate family, compete or conflict with the interests of theArchdiocese, Metropolis, or Parish. For example, this includes situations in which anindividual's judgment is or may be influenced by considerations of personal gain orbenefit to that individual, or his/her immediate family, or when participation in a decision
creates the appearance of a conflict of interest, whether or not such a conflict actuallyexists. A Related Party Transaction means any transaction, agreement, or any otherarrangement in which a Related Party has a substantial financial interest, and in which theArchdiocese, any Metropolis or any Parish is a participant. Other examples of conflicts ofinterest or related party transactions are myriad and may take place in a number ofdifferent contexts. Conflicts or Related Party Transactions may arise in connection withinvestment of Church funds, in the providing of professional services, or in the sellingbusiness goods.
Prior to or at the commencement of a new term of the Archdiocesan, Metropolis
and Parish Council, and annually thereafter , each Member of a Council shall be given a
copy of this Conflicts Disclosure Policy and shall sign the applicable Conflicts DisclosureStatement (as attached hereto as Addenda A 1-A3). The Council Member shall disclose,to the best of his or her knowledge, any entity of which the Council Member is a officer,director, trustee, member, owner (either as a sole proprietor or partner), or employee, that

1 A "Key Employee" means any person who is in a position to exercise substantial influence over theaffairs of the Archdiocese, Metropolis, or local Parish, as applicable.
2 "Archdiocese" as used herein includes the Archdiocese, the Direct Archdiocesan District /Metropolises and the Parishes.

has either has a relationship with the Archdiocese, Metropolis or any Parish or any
transaction between the Archdiocese, Metropolis, or Parish and the Council Member,whereby the Council Member has a conflicting interest or Related Party Transaction.
If, at any time thereafter, an Archdiocesan Council or Local Council member
discovers that he /she may have a conflicting interest or is involved in a Related PartyTransaction, he/ she shall immediately report it to the President, Vice President andSecretary of the Council. If at any time thereafter, a Parish Council Member discovers
that he/she may have a conflicting interest or involved in a Related Party Transaction,then he/she shall immediately report it to the Parish Priest, as well as to the President andSecretary of the Parish Council. In all cases, the existence and resolution of any conflictof interest or Related Party Transaction shall be documented in the appropriate Council's
minutes, including the minutes of any meeting at which the conflict was discussed orvoted upon.
The determination of whether a conflict of interest exists shall be made, in thecase of an Archdiocesan Council Member or Local Council Member, by the President,
Vice President and Secretary. In the case of a Parish Council Member, the determination
shall be made by the Priest, Parish Council President and Parish Council Secretary andtheir determination shall be disclosed to the Parish Council at its next meeting. The
minutes of the meeting shall reflect when the conflict of interest was disclosed and thefinal determination on the matter. At any time, the Priest or any member of the Parish
Council may request a review by the respective Hierarch, whose determination shall befinal.
The Archdiocese, Metropolis, or any Parish shall not enter into any Related Party
Transaction unless the transaction is determined by, in the case of an ArchdiocesanCouncil Member or Metropolis Council Member, by the President, Vice President andSecretary or in the case of a Parish Council Member, by the Priest, Parish CouncilPresident and Parish Council Secretary, to be fair, reasonable, and in the best interests of
the Archdiocese, Metropolis, or Parish, as applicable. The minutes of the meeting shallreflect when the Related Party Transaction was disclosed and the final determination on
the matter. Prior to entering into any Related Party Transaction, the Council or authorizedcommittee shall (1) consider alternative transactions to the extent available, (2) approve
the transaction by not less than a majority vote of the Council members or committee
members present at the meeting, and (3) contemporaneously document in writing thebasis for the approval , including consideration of any alternative transactions. In the caseof the Archdiocese, the Archbishop shall make the final determination of fairness,reasonableness, and best interest. At the Metropolis and Parish level, the Metropolitan
shall make this final determination.
All Related Parties have the ongoing duty to disclose conflicts of interests andrelated party transactions to appropriate Council or authorized committee at the earliestmoment possible. The disclosure shall be made in good faith and shall include allmaterial facts of the conflict of interest or Related Party Transaction. No Key Employee,officer, or Member of any Council may participate in deliberations or voting related toconsideration of the conflict of interest or related party transaction. Further, no Related
Party shall attempt to improperly influence the deliberation or voting related to theconsideration of the particular conflict of interest or Related Party Transaction. However,the foregoing shall not preclude the Related Party from providing information at theCouncil or committee's request prior to the commencement of deliberations or voting. Inno event shall the affected Related Party be present or participate in any deliberations on
the matter or be present when the vote on the matter is taken.
A lay employee of: a) the Archdiocese, shall not serve as a member of the ArchdiocesanCouncil; b) the Metropolis, shall not serve as a member of the Metropolis Council; or c) a
Parish, shall not serve as a member of the Parish Council.

ADDENDUM A-1
GREEK ORTHODOX ARCHDIOCESE OF AMERICAConflicts and Related Party Transactions Disclosure Policy Statement -- ArchdiocesanCouncil
For Officers, Key Employees1 and Members of the Archdiocesan Council of the Greek
Orthodox Archdiocese of America2 (“Council”):
I, _________________________, understand and agree that my role as an Archdiocesan Council
member is one of sacred honor, trust and responsibility. As such, I will, with honesty,competence and care, act at all times in the best interests of the Greek Orthodox Archdiocese ofAmerica.
I have received and read a copy of the Conflicts and Related Party Transactions DisclosurePolicy of the Greek Orthodox Archdiocese of America. I agree to fully abide by the Policy. Iaffirm that, to the best of my knowledge, I am not engaged in any activity or business, or haveany other association that would pose a financial or other conflict with the best interests of theGreek Orthodox Archdiocese of America, or engaged in any Related Party Transaction except as
has been disclosed, in writing, to the President, Vice President and Secretary of theArchdiocesan Council as follows:______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
I further state I have disclosed above, and to the individuals specified above, the identity of any
entity (“my entity”) of which I am an officer, director, trustee, member, owner (either as a sole
proprietor or partner), or employee, that either has a relationship with the Archdiocese,Metropolis or any Parish, or a transaction between the Greek Orthodox Archdiocese of America
and myself (or my entity), whereby I have a conflicting interest or a Related Party Transaction.
If I become aware of any conflicting interest or Related Party Transaction that arises after thedate of this affirmation, I will immediately disclose that conflict or transaction, in writing, to theindividuals specified above.
Date:__________________

Signature:________________________________

Printed Name: ________________________________

Archdiocesan Council Conflicts and Related Party Transactions Disclosure Policy Statement. Rev.10.20.2017
1A “Key Employee” means any person who is in a position to exercise substantial influence over the affairs of theArchdiocese, Metropolis, or local Parish, as applicable.
2The “Greek Orthodox Archdiocese of America” includes the Archdiocese, the Direct Archdiocesan District/Metropolises (“Local” or “Metropolis”) and the Parishes.

ADDENDUM A-2
GREEK ORTHODOX ARCHDIOCESE OF AMERICA
Conflicts and Related Party Transactions Disclosure Policy Statement – Metropolis/LocalCouncil
For Officers, Key Employees1 and Members of the Metropolis/Local Council of the Greek
Orthodox Archdiocese of America2 (“Council”):
I, _________________________, understand and agree that my role as a Metropolis/Local
Council member is one of sacred honor, trust and responsibility. As such, I will, with honesty,
competence and care, act at all times in the best interests of the Greek Orthodox Archdiocese ofAmerica.
I have received and read a copy of the Conflicts and Related Party Transactions Disclosure
Policy of the Greek Orthodox Archdiocese of America. I agree to fully abide by the Policy. Iaffirm that, to the best of my knowledge, I am not engaged in any activity or business, or haveany other association that would pose a financial or other conflict with the best interests of theGreek Orthodox Archdiocese of America, or engaged in any Related Party Transaction except as
has been disclosed, in writing, to the President, Vice President and Secretary of theMetropolis/Local Council as follows:______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________I further state I have disclosed above, and to the individuals specified above, the identity of anyentity (“my entity”) of which I am an officer, director, trustee, member, owner (either as a sole
proprietor or partner), or employee, that either has a relationship with the Archdiocese,Metropolis or any Parish, or a transaction between the Greek Orthodox Archdiocese of America
and myself (or my entity), whereby I have a conflicting interest or a Related Party Transaction.
If I become aware of any conflicting interest or Related Party Transaction that arises after thedate of this affirmation, I will immediately disclose that conflict or transaction, in writing, to theindividuals specified above.
Date:__________________

Signature:________________________________

Printed Name: ________________________________

Metropolis/Local Council Conflicts and Related Party Transactions Disclosure Policy Statement. Rev.10.20.2017
1

A “Key Employee” means any person who is in a position to exercise substantial influence over the affairs of theArchdiocese, Metropolis, or local Parish, as applicable.
2The “Greek Orthodox Archdiocese of America” includes the Archdiocese, the Direct Archdiocesan District/Metropolises (“Local” or “Metropolis”) and the Parishes.

ADDENDUM A-3
GREEK ORTHODOX ARCHDIOCESE OF AMERICA
Conflicts and Related Party Transactions Disclosure Policy Statement – Parish Council
For Officers, Key Employees1 and Members of the Parish Council of the Greek Orthodox
Archdiocese of America2 (“Council”):
I, _________________________, understand and agree that my role as a Parish Council member
is one of sacred honor, trust and responsibility. As such, I will, with honesty, competence andcare, act at all times in the best interests of the Greek Orthodox Archdiocese of America.
I have received and read a copy of the Conflicts and Related Party Transactions Disclosure
Policy of the Greek Orthodox Archdiocese of America. I agree to fully abide by the Policy. I
affirm that, to the best of my knowledge, I am not engaged in any activity or business, or haveany other association that would pose a financial or other conflict with the best interests of theGreek Orthodox Archdiocese of America, or engaged in any Related Party Transaction except as
has been disclosed, in writing, to the Priest, President and Secretary of the Parish Council
as follows:______________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
I further state I have disclosed above, and to the individuals specified above, the identity of any
entity (“my entity”) of which I am an officer, director, trustee, member, owner (either as a sole
proprietor or partner), or employee, that either has a relationship with the Archdiocese,Metropolis or any Parish, or a transaction between the Greek Orthodox Archdiocese of America
and myself (or my entity), whereby I have a conflicting interest or a Related Party Transaction.
If I become aware of any conflicting interest or Related Party Transaction that arises after thedate of this affirmation, I will immediately disclose that conflict or transaction, in writing, to theindividuals specified above.

Date:__________________

Signature:________________________________

Printed Name: ________________________________

Parish Council Conflicts and Related Party Transactions Disclosure Policy Statement. Rev.10.20.2017
1

A “Key Employee” means any person who is in a position to exercise substantial influence over the affairs of theArchdiocese, Metropolis, or local Parish, as applicable.
2
The “Greek Orthodox Archdiocese of America” includes the Archdiocese, the Direct Archdiocesan District/Metropolises (“Local” or “Metropolis”) and the Parishes.