WHISTLEBLOWER POLICY (the "Policy")
I. PURPOSEThe Greek Orthodox Archdiocese of America (the "Archdiocese"), to the extent consistent with
its status as a religious corporation, is committed to compliance with applicable state and Federallaw. In addition, the Archdiocese recognizes that it is in the best interests of the Church topromote transparency and high standards of conduct and ethics with respect to Archdiocesan
administrative and financial activities and practices.
The Archdiocese will receive complaints, investigate, and take action it deems appropriate inmatters including, but not limited to, instances of suspected: (1) fraud, waste and/or abuse of its
resources; (2) theft and/or other related misconduct; (3) violation of its Regulations, guidelines
and/or policies, including, but not limited to, its Conflicts and Related Party Transactions
Disclosure Policy; and (4) harassment or retaliation and/or other misconduct, by clergy or lay
employees, officers, directors, contractors, volunteers, or Archdiocesan Council, Metropolis
Council and Parish Council members, (collectively, "Violations"). The Faithful and otheraffected individuals are encouraged to report potential Violations pursuant to the procedures set
forth below.
This Policy applies to the entire Greek Orthodox Archdiocese of America, including
metropolises and parishes.
II. PROCEDURES
A. Administration of Policy
The Chancellor of the Archdiocese (the "Chancellor"), and the General Counsel of theArchdiocese (or in the absence of a General Counsel, the Chair of the Legal Committee of theArchdiocese) ("Legal Counsel") are designated to administer the Policy and to report to theExecutive Committee of the Archdiocese any material Violations, as well as significant actions
taken under this Policy.
B. Reporting of Complaints
Complaints under this Policy shall be submitted through a third party hosted website
https://goarch.ethicspoint.com/ established by the Archdiocese to receive all "whistleblower"
complaints (the "Reporting Mechanism"). Notwithstanding anything to the contrary in thisPolicy, any individuals who are alleged to have committed a Violation shall recuse themselvesfrom the administration of the investigation into that Violation. Any questions or concerns in thisregard shall be referred to Legal Counsel.
This Policy shall not be deemed to limit or restrict, in any way, the Archdiocese's Spiritual
Court Guidelines and other Canonical rules. In addition, notwithstanding anything to thecontrary herein, any complaints regarding sexual misconduct shall be handled inaccordance with the Archdiocese's applicable sexual misconduct policies.

C. Confidentiality
With the exception of the notifications set forth below, complaints under the Policy will
generally be kept confidential unless confidentiality would impede the investigation of thecomplaint. In addition, confidentiality may not be possible where disclosure or reporting isrequired pursuant to any applicable law or regulation, ordered by a court, ordered by a SpiritualCourt, required by the Holy Tradition and Holy Canons of the Church, or required so that theArchdiocese or any appropriate governmental entity may conduct an adequate or appropriate
investigation of the matter.
Following the Initial Inquiry, as defined below, the Archdiocesan Chancellor and Archdiocesan
General Counsel shall provide, to the extent feasible and appropriate, immediate notice ofallegations of complaints with Reasonable Basis, as defined below, as follows:
For Complaints involving:
Archdiocese
DAD
Metropolises / parishes /monasteries
Archdiocese Affiliates

Notice to:Archbishop and Vice President of the Archdiocesan Council
Archbishop and Vice President of the DAD Council
Applicable Metropolitan and Vice President of theMetropolis Council and highest-ranking clergy and lay
person at each location
Archbishop and chairperson of the Board of Directors

III. INVESTIGATON
1. All complaints shall be subject to an initial inquiry (the “Initial Inquiry”) by the Archdiocesan
Chancellor and Archdiocesan General Counsel to determine whether a reasonable basis exists for
conducting additional investigation (“Reasonable Basis”). No Reasonable Basis shall exist whenthe Initial Inquiry determines that the complaint is manifestly false, baseless, or frivolous.
2. Following the determination of a Reasonable Basis, complaints will be investigated by theGeneral Counsel or an investigator retained by the Archdiocese to conduct an investigation (the“Investigation”).
3. The Investigation should be completed in a timely and expeditious manner, unless doing sowould be deemed by the Chancellor or the Archdiocesan General Counsel to interfere with any
parallel criminal or regulatory proceedings.
4. It is the obligation of all Clergy and lay persons who have or may have information regarding
the complaint to cooperate fully and completely with the Investigation.
5. The investigators shall report the results of the Investigation as they are reached to theArchdiocesan Chancellor and Archdiocesan General Counsel
6. Upon receipt of the results of the Independent Investigation, the Archdiocesan Chancellor andArchdiocesan General Counsel shall provide a Final Report to the Archdiocesan Executive
Committee that consists of the following:

a. The Complainant’s formal complaint and any amendments thereto;b. A summary of the findings from the Investigation;c. A statement of any conclusions reached by the Archdiocesan Chancellor and the ArchdiocesanGeneral Counsel; andd. Disclosure of disciplinary action as determined by the Archdiocesan Chancellor and theArchdiocesan General Counsel. In the event that the Archdiocesan General Counsel and theArchdiocesan Chancellor either decline to impose disciplinary action or are unable to agree
regarding disciplinary action for the Respondent, then the Archdiocesan Executive Committee
shall meet to determine the appropriate disciplinary action, if any. In addition, at any point in theprocess, the Archdiocesan Executive Committee reserves the right to report the Complaint to therelevant authorities.
A Final Report shall also be provided as follows:
For Complaints involving:
Archdiocese
DAD
Metropolises / parishes /monasteries
Archdiocese Affiliates

Notice to:Archbishop and Vice President of the Archdiocesan Council
Archbishop and Vice President of the DAD Council
Applicable Metropolitan and Vice President of theMetropolis Council and highest-ranking clergy and lay
person at each location
Archbishop and chairperson of the Board of Directors

7. This policy is not intended to replace or change any legal reporting obligations. Therefore,
conduct required by law to be reported by the Complainant to local, county, state, federal orother law enforcement, social services, or other outside agencies shall be reported, as applicable.
Legally required reporting does not obviate the other required reporting in this section; nor does
reporting to the Archdiocese satisfy a person’s mandated reporting obligation required by law.
IV. NO RETALIATION
No individual who in good faith reports any Violation shall suffer intimidation, harassment,
discrimination or retaliation, and with respect to any employee, any retaliation that results in anadverse employment consequence. Any individual entitled to this protection who believes he orshe has been the subject of intimidation, harassment, discrimination or retaliation for submittinga whistleblower complaint should immediately report the same as a Violation of this Policy.
V. PUBLICATION AND DISTRIBUTION
This Policy shall be distributed to the Faithful, as well as to all officers, directors, employees,and volunteers of the Archdiocese, through the inclusion of this Policy as an Addendum to theRegulations of the Greek Orthodox Archdiocese of America, and distributed electronically toclergy and laity, by posting on the Archdiocesan website. Information regarding the Reporting
Mechanism referred to in this Policy shall be included, periodically, in the Orthodox Observer.

VI. LIMITATIONS TO SCOPE OF POLICYThis Policy describes the general approach that the Archdiocese should follow with respect toreports of whistleblower complaints. However, as a religious organization, it may not be possible
or appropriate for the Archdiocese to follow this approach in every case. Accordingly, each andevery provision of the above Policy, including the provisions regarding confidentiality andprotection from retaliation, are expressly subordinate to our Faith, Holy Tradition, and Holy
Canons of the Church. Further, the Archdiocese reserves all protections accorded to it by theUnited States Constitution as well as by applicable federal and state law. Nothing in this Policy
shall work in derogation of, or be construed as an abdication by the Archdiocese of the Church'sconstitutionally protected freedom from governmental interference, and this Policy is notintended to diminish these freedoms in any respect or to create any legal rights or responsibilities
upon the Archdiocese or any of its representatives.