45. We are contacting you in order to request clarifications regarding the eligibility criteria for applicants for the “Open accommodation centers for vulnerable asylum seekers in Greece” call, as described in par. 4.1 and 4.3. Our organization is run by a 5 member Steering Committee elected by the Holy Synod of the Church of Greece, which is the organization’s sole shareholder, monitoring and approving annual financial balance sheets and activity reports. The provision of services is mainly externally funded, apart from a 5.000 euros annual contribution by the Church of Greece. All projects are implemented in accordance with our organization’s certified internal procedures as well as the administrative framework set by funding authorities in compliance with national and European legislation and are audited by certified public accountants. We would further like to mention that the organisation’s mission, as documented in its statutes, is not in any way related with religious matters. Given the abovementioned we attach our Statutes (in Greek) and we would appreciate your response regarding our eligibility to submit a proposal.

EEA Grants conditions indicate that an entity in order to be considered an NGO has to comply with the following:
“A “non-governmental organisation” (NGO) is eligible for support within the Programme if it meets the following definition: it is a non-profit, voluntary organisation established as a legal entity, having a non-commercial purpose, independent of local, regional and central government, public entities, political parties and commercial organisations. Religious institutions and political parties are not considered NGOs. It is recognised that the registration of NGOs, and therefore their establishment as legal entities, differs from country to country. Eligible applicants for funding shall nonetheless be entities usually meeting the following principles:
• Are non-profit, being organisations that have not been created nor operate to generate personal profit. Although they may have paid staff and may engage in revenue-generating activities, they do not distribute profits to their members nor to their board. Where revenue generating activities are undertaken, these should not represent the purpose of the NGO, but should be a means to support its mission and values
• Have members who do not have any direct commercial interest in the outcome of the work of the organisation or of its commercial activities and should not pursue the commercial or professional interests of their members. This requirement therefore excludes trade- and professional associations, where the aims and purposes of the association is to further the specific interests of its members only
• Are voluntary in nature, formed voluntarily by groups or individuals and usually involving an element of voluntary participation in the organisation
• Act in the public arena and for the public good on concerns and issues related to the wellbeing of people, groups or society as a whole
• Have some degree of formal or institutional existence, unlike informal or ad hoc groups, involving formal statutes or other governing document(s) defining their mission, objectives and scope
• Have transparent structures and elected chair/board, and are accountable to their members and donors
• Are independent of local, regional and national government and other public authorities
• Are independent of political parties and commercial organisations Political parties, religious institutions, social partners or profit-distributing cooperatives are not considered NGOs. Foundations and the national Red Cross societies are considered eligible NGOs if they fulfil the above principles.
Faith-based organisations are eligible if they meet the principles identified above and if the funded activities do not directly or indirectly promote a religious doctrine, mission or proselytism related to the beliefs of a particular faith (beyond basic religious/cultural awareness raising).”

An organisation run by a 5-member Steering Committee elected by the Holy Synod of the Church of Greece, which is the organisation’s sole shareholder, monitoring and approving annual financial balance sheets and activity reports, cannot fall under the meaning of the term “NGO”, according to the above mentioned provisions as it lacks the necessary independence. Given that the Church appoints all members of the steering committee and is the Organisation’s sole shareholder, this negates the flexibility and independence of an NGO.  To that end your Organisation cannot fall under the EEA Grants definition of NGOs, which requires strict independence from public entities and religious institutions, and thus it cannot be considered as an eligible lead applicant or partner.