• This new Section 40F is an important provision, requiring that all foreign funding (described as “foreign contribution or donation”) for the purposes of voter education must only be made to the Commission. The Commission “may” then allocate such funding to any person referred to in section 40B (3) or section 40C (1). • This is essentially a ban against direct foreign funding to persons or organisations that provide voter education. From a foreign policy point of view, this may be seen as a measure to control foreign interference in the election process. However, the scarcity of local funding due to the economic challenges and limited culture of philanthropy, the reality is that most organisations are almost entirely dependent on foreign contributions and donations. It will therefore mean logistically, funding would have to be channelled through the Commission for onward passage to the relevant organisations. This will depend on the Commission’s efficiency and fairness otherwise delays and bureaucracy could effectively hamper the activities of voter education providers who have to rely on foreign donations. • Further, it is not entirely clear from the provision that the Commission has the discretion to refuse any foreign funds for onward passage to the local organisations. If it does have such discretion, the hope is that it will be used reasonably in favour of the primary goal of enabling the provision of voter education. • In addition, it is not entirely clear that the funding that it receives will be passed on intact to the relevant organisation or whether the Commission will have the discretion to allocate it to other organisations. It is important to clarify that the funding will not be used in this broad way and that essentially the Commission is a receiving agent for the specific organisation that applied for funding. The last option is that organisations may wish to reorganise their finances and funding streams more creatively in order to avoid having to go through what may be a lengthy and bureaucratic process. • The key point for any provider of voter education is that they must satisfy their “Zimbabwean” character, be prepared to provide material for the provision of voter education and that this 20