Adventist Review editor Bill Knott recently sat down with Karnik Doukmetzian, chief legal counsel for the General Conference of Seventh-day Adventists, to discuss the ethical behaviors church members may expect of leaders.

Many conversations about ethics in faith-based organizations get stranded in the clouds at a theoretical level of nuance that seems far removed from the realities of where believers live and move. I’m going to ask you to respond to a plausible scenario that might land on your desk in the Office of General Counsel (OGC) for the General Conference. It’s not a real situation: it’s a composite story formed from fragments of many such stories. Here it is:

An ADRA (Adventist Development and Relief Agency) country director in country X happens to be the brother of a union treasurer in the same territory. Concerns are expressed by several ADRA employees who have questions about what’s happening to the finances of aid money donated by national governments or aid organizations to ADRA for certain projects. In the process of looking into the matter, ADRA concludes that there is need for an audit to track their funds and accurately report to donors and their organizations. The audit reveals that ADRA funds had been comingled with those of the union, and there’s now a sum equivalent to US$70,000 that is unaccounted for.

If those were the facts that arrived on your desk as the Seventh-day Adventist Church’s chief legal counsel, what processes would you think about initiating to bring clarity and resolution?

I know it’s not good form to argue with the interviewer’s question, but if this was an actual situation, those involved would have encountered a robust ADRA system to protect against such abuses, as well as a full investigative process if something inappropriate still occurred.

But your scenario is really about appropriate process. First, we would need to recognize that there are several different entities involved that must all be considered. We have ADRA in that local territory: it could be a separate legal organization, or it could be part of the church organization. We could have ADRA International involved. We could have the foreign government that provided the funding involved, because they hold every organization that receives their funds accountable. And if you don’t provide accurate documentation, that government has the right to reclaim what it has given. And then, of course, there are the established church structures in the region—in this case a union conference.

Assessing all the parties involved in the situation is a key to developing an ethical process?

If such a situation were presented, our office follows a two-step process—one with ADRA, and one within the church. That would include using ADRA’s internal auditors initially, and, if necessary, external auditors to go in, investigate, and then provide a report. It could also involve the General Conference Auditing Service.

If somebody is doing wrong, we need to stop that behavior. If somebody is abusing a child or abusing a church member, there’s no room for that.

It’s heartening to hear that there are robust investigative options.

Depending on the findings, appropriate actions would be taken. But we have to remember that as separate organizations, we may have very little input or control over what the local organizations do. We may provide guidance, counseling, and advice, but the General Conference isn’t unilaterally able to remove someone from office, even when there’s evidence of wrongdoing. We can provide guidance, but ultimately that decision has to be made by the local governing body responsible for those individuals.

Are there sometimes competing claims or structural matters that restrict the world headquarters from dealing with a situation in the way it would wish to?

Yes, there are. Ultimately, the governing body is responsible, but if they fail to take action, it does have an impact on the church as a whole. There may be an impact on additional funding for an organization like ADRA, or for other projects that may be happening. There’s, of course, the impact on the reputation of the church, both in the specific country and internationally. That reputation impacts the trust level of church members and their giving patterns.

Many church members may not differentiate between one entity of the church, like ADRA, and the rest of the mission that is operated through local structures. They may see these as somehow all under one governance.

For most Seventh-day Adventists the church is the church. Members don’t differentiate between one level and another, between one organization and another. As long as it has Adventist branding on it, we’re all assumed to be operating together—and in a time of crisis or misappropriation of money, we can all be tarred with the same brush.

With this scenario you’ve responded to, what steps could have been taken before it occurred to make it less likely to happen?

Two things come to mind. One, both leaders and members need to understand what a “conflict of interest” is, and how it can be protected against. Putting my relative in a position over which I may have some authority places me in a potential conflict of interest.

Second, leaders at every level have to understand they have fiduciary responsibilities. They are there to protect the interests of the individuals who put them in authority, or in position. That could well be the constituency of the organization. It could be the board that oversees that entity. Ultimately, each leader is accountable to that group or organization that has put us in positions of decision-making and authority, because we’re charged with protecting their interests. Overlooking the wrongs of a family member puts us in a severe conflict of interest, and doesn’t allow us to carry out our fiduciary responsibilities.

Some might say, in response to this scenario, that we’re just applying Western and legal contexts to a cultural setting in which family is the basic unit.

Family is important—vital—and we need to take care of our family members. But at the same time we have to remember that we can’t give them preference or allow them to continue with their wrongdoing. We don’t give them the right to do what is wrong. We must hold them accountable. If our family member is stealing, that shouldn’t stop us from reporting it or taking care of the problem.

So there’s a biblical imperative that is transcultural?

Yes, absolutely. Ethics, morality, legality—they’re all interwoven, and they apply across the board, regardless of what country you’re in.

Are there other steps that could have been taken procedurally to prevent the embarrassing situation that emerged in this scenario?

Church organizations always have the ability to investigate, and not just after a problem is discovered. Because of the family situation, it would be crucial to have independent investigation. Whether that’s someone from a higher organization or completely external, there must be a competent investigation. Those perceived to be involved, or related to those involved, must be isolated from the process, to prevent the potential conflict of interest, and allow the investigation to take place.

What steps is the church taking to bring this ethical awareness to the persons we elect to lead church structures or auxiliary church structures?

First and foremost—education. Many people don’t understand the concept of conflict of interest and exactly what that means. They need to be educated. How do I handle a conflict of interest? When I have an issue, whom do I need to disclose it to? Do I withdraw from any decision-making involving that situation or those individuals? Ethics education is vitally important as persons take on leadership roles. As individuals who act in fiduciary responsibilities, they have an obligation to others.

A newly elected officer in a given region wouldn’t necessarily have been exposed to that ethical training at their previous level of employment. How does the church go about providing that? Do we automatically train new officers, or do we sort of trust that there is field training in their region?

Different organizations handle things differently. In North America all newly elected conference or union officers come in for extensive training within a few months of being elected. That training covers the whole gamut of responsibilities that they have assumed, including organizational ethics, administration, governance, conducting constituency meetings, and helping with issues at local church boards. An entire range of issues is addressed.

Are there church organizations that have a well-developed training sequence to orient new officers to things they might not have known through their previous church experience?

Yes, there are—and good ones too. It’s very important that officers be trained in how to carry out their functions. If they’ve been elected to leadership from a local pastorate, they may not have had to make final decisions on these kinds of things, including employment matters, personnel issues, contracts. These aren’t things you normally deal with in a local church setting, and you need that legal and ethical training to be able to function effectively.

If you were speaking to a group of elected church leaders about a mind-set they ought to take to these kinds of ethical issues, what are the points you’d want to highlight? How do you take an organization that wasn’t intended to do investigations of money or conduct—but was supposed to focus on mission and ministry—and also make sure that it’s scrupulous about these ethical concerns?

We had an individual who filed a complaint that the receptionist in their office wore such strong perfume that the smell caused them problems.

Leaders have to understand that they have an obligation not only to the constituency and to the general public, but to God. They’ve undertaken responsibilities to abide by certain processes and procedures that they need to follow. If they don’t, their leadership is going to be called into question. If the law says you ought to be doing A, and you’re doing B, do you want to get challenged in court? So we expose ourselves to litigation, liability, and public embarrassment when we don’t adhere to standards that we are expected to follow.

We’re all painfully aware of a developing trend of frustrated persons who believe themselves to be aggrieved by some church process going to a media outlet—or going to social media—to broadcast their concerns. What options are there for a person who has a grievance with the ethical conduct of a leader or an organization? Are there responsible steps they can take to make sure their concerns are heard and investigated?

A number of years ago the global Adventist Church began participating in a whistleblower reporting system that allows for individuals to report matters of fraud, sexual misconduct, financial improprieties, and other such concerns anonymously. Their reporting allows a genuine investigation to take place, and for the matter to be dealt with. It’s called SilentWhistle^®, and it can be accessed through a website called www.Adventist.silentwhistle.com.

Individuals—members and employees—can anonymously report the issue, which is then processed, sent to the organization ultimately responsible, and dealt with at that point. After the initial anonymous intake, the processing is done by this office—the Office of General Counsel—and directed to the individual ultimately responsible.

For example, if the issue is of a local conference nature and involves personnel or policies, then it would likely be directed to the president of that organization. If the matter involves the president, it would be directed to the next-higher organization, and so on. If it’s learned that an organization isn’t dealing with the issue or the complaint, working policy does allow for the next-higher organization to begin their own investigation, and to deal with the matter, taking it to the executive committee for ultimate handling.

What assurances does a caller to SilentWhistle^® have that the ethical concern they are reporting won’t just disappear?

Well, first of all, the information that comes in is completely anonymous.

At both ends?

Both ends. Now, once that is received, then the investigation commences, and when additional information is required, it is anonymously communicated to the individual.

So there’s a loop back to the initial reporter.

Once the matter is investigated, and action taken, that’s also reported back to the individual who filed the complaint so that they are aware that their complaint was taken seriously.

How many of these reports emerge in a typical year?

It’s hard to say in any given year, but probably 20 to 30. They are all looked at and processed. At one end we had an individual who filed a complaint that the receptionist in their office wore such strong perfume that the smell caused them problems. That one was forwarded to the HR director of the organization. The other extreme is financial mismanagement or outright theft being reported. In those cases, auditors were dispatched to investigate, and appropriate actions were taken. We need to have the lowest and most immediate level of church organization deal with the problem wherever possible.

So there’s an attempt to avoid having the General Conference, or the Office of General Counsel, ever override existing processes. There are times, though, when local organizations ask the OGC or the General Conference Auditing Service to assist them, but the request does come from that lower organization to help them. We won’t step in on our own initiative, but we will assist where requested.

Many church members may assume that the foremost organization can take action from its position over any other component organization. You’re saying that the church deliberately focuses on trying to solve it at the lowest level possible.

Remember that most organizations are separate legal organizations. Whether it’s a conference, a union, or the General Conference—they’re all separate. Our institutions are all separately governed. So their governing bodies, their constituencies, are the ones that oversee and control those. For the General Conference to step over all those other organizations and instruct a local conference, “You must do this or you must not do this,” is not only improper, it’s something we as a church cannot do. We have constituencies in place that oversee these organizations, and ultimate responsibility rests with them.

There’s an assumption that the highest named organization can take executive action to adjust policy, personnel, and situations at every other level.

(Laughs) Which is why all the complaint letters come to the president’s office at the General Conference, believing that he can act directly. It would actually be timelier and more effective if they would actually work through the relevant local organization, or the one above it.

You’ve watched many difficult situations come and go. What key ideas do you want to lodge in the minds of leaders and members about how we deal with the inevitable clay feet of human beings?

Every action we take must be held to the highest standards, whether those are legal standards, moral standards, or ethical standards. If somebody is doing wrong, we need to stop that behavior. If somebody is abusing a child or abusing a church member, there’s absolutely no room for that. It’s not enough to say, “Sorry, I won’t do it again,” and move them on to another position. They must be terminated, and terminated immediately, and not be passed on or hired by another denominational organization.

In some cases the law of the land dictates outcomes we can’t avoid.

Absolutely. We have an obligation to protect the assets of the church, and if that means removing that individual, so be it. We have an obligation to follow the law: if the law says we have to pay our employees A, B, and C, we have to do that. We can’t say, “Well, no, we think better than the law.” We’re not above the law, and the law will find us, and we will pay a price as a church. Our reputation and the reputation of the denomination are at stake.

We have an obligation to God to do right. We have an obligation to our constituency and to the community as a whole. And as a religious body, we’re really held to a higher standard. People expect us to be better, and when we make mistakes that could have been avoided with proper regard for ethics, it doesn’t reflect well on the church.

Church members and the wider public have the right to expect that faith leaders at all levels will act in harmony with the principles of Scripture. It’s part of the job of every leader to increase confidence in the trustworthiness and ethical decision-making of the organization they lead. When that happens, our witness within—and our witness without—bring glory to the God of truth.