Commission has the discretion to refuse any foreign funds for onward passage to the local organisations. If it does have such discretion, ZESN urges that it should be used reasonably in favour of the primary goal of enabling the provision of voter education. 13.2 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. 14. Accreditation 14.1 ZESN notes that the Observers’ Accreditation Committee (“OAC”) which is responsible for the accreditation of both local and foreign election observers is comprised of a high number of political nominees. If the aim was to reduce political interference in the accreditation of observers, this is not fully achieved given the domination of political nominees. ZESN recommends that the composition of the OAC be the exclusive decision of the body charged with running elections, i.e. the Commission. Ministers, who are usually also contestants in an election, should have no role in the accreditation of observers since all other candidates in an election who are not Ministers do not have the same facility. Likewise, it is not necessary to give power to the Ministers of Government to invite persons to apply for accreditation to observe elections. Indeed, on the same basis, Ministers’ right of objection against certain observers is not justified given that other contestants or parties with an interest in an election do not have the same facility of objection. All this should be the exclusive domain of the Commission. 14.2 ZESN is also concerned that there is at present no provision for the applicants who would have been rejected for accreditation to seek recourse against the decision of the OAC. It is necessary to put in place an expedited procedure to deal with any appeals. 52

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