42 | Zimbabwe Rule of Law Journal of promoting and facilitating the independence and accountability of the judiciary and the efficient, effective and transparent administration of justice in Zimbabwe, as prescribed in Section 190 of the new Constitution. In much the same light, the Judicial Service (Code of Ethics) Regulations were passed in 2012, and similarly predate the 2013 Constitution. However, it is one of the key achievements of the JSC to date due to the establishment of a comprehensive framework on procedures for appointment and recruitment of judicial members, performance, resignation, termination of employment and salaries. Generally, under the Regulations, in order to promote efficiency and effectiveness, the JSC is required to recruit members with knowledge and ability about the task, relevant experience and requisite qualifications and qualities.23 Therefore, recruitment is based on merit.24 On disciplinary issues and procedures,25 the important aspect is what constitutes acts of misconduct. Some of the acts of misconduct include absence from duty, failure to perform duties, negligence, inefficiency or incompetence, sexual harassment and corruption or dishonesty.26 These Regulations clearly indicate that the JSC has made significant efforts, at least from a legislative perspective, to contribute to judicial independence, impartiality and integrity. The language used in the “code of ethics” is also in accord with international soft law principles and guidelines on judicial service commissions and judicial independence.27 2. Contribution of JSC to judicial independence: theory and practice 2.1 Conceptual meaning and scope of judicial independence A conceptual analysis of judicial independence is important at this point in order to fully assess how the JSC has contributed to judicial independence. The independence of the judiciary is pivotal to the protection of human rights28 and instrumental in the pursuit of constitutional values and the 23 Section 3 24 Section 3 (2) 25 Section 45 -46 26 Third Schedule to Section 45 27 Bangalore Principles op cit note 17; Latimer House Guidelines op cit note 11 28 L.Chiduza “Towards the Protection of Human Rights. Do the new Zimbabwean Constitutional Provisions on Judicial