both accomplish primarily by setting quotas. Zimbabwe’s Constitution appears to be more progressive, since its gender equity clause states that: (b) “the State must take all measures, including legislative measures, needed to ensure that— (i) both genders are equally represented in all institutions and agencies of government at every level; and (ii) women constitute at least half the membership of all Commissions and other elective and appointed governmental bodies established by or under this Constitution or any Act of Parliament….”26 In contrast, the Kenyan Constitution directs the State to “take legislative and other measures to implement the principle that not more than two-thirds of the members of elective or appointive bodies shall be of the same gender.”27 Of course, under Kenya’s provision, it is possible for women to make up 75% of a government body, whereas Zimbabwe would limit their number at 50%, although neither has yet been achieved. Both Zimbabwe and Kenya include the equality of women and men in their values and principles of public service.28 Similarly, both instruct that a chairperson and vice or deputy chairperson of a committee cannot be of the same gender.29 As of March 2016, the most recent date for which information could be found, this requirement was followed by almost all constitutional commissions in Zimbabwe, but only some of the commissions in Kenya.30 26 Zimbabwe Constitution, Ch. 2, § 17(b). Kenya Constitution, Ch. 4, § 27(8). 28 Compare Zimbabwe Constitution, Ch. 9, § 194 with Kenya Constitution, Ch. 13, § 232. 29 Compare Zimbabwe Constitution. Ch. 18, § 320 with Kenya Constitution, Ch. 15, § 250(11). 30 As of March 2016, this requirement was followed by almost all constitutional commissions of Zimbabwe: the Gender Commission, the Human Rights Commission, the Media Commission, and the Anti Corruption Commission. The Electoral Commission violated this requirement because both its chairperson and deputy chairperson are female. The National Peace and Reconciliation Commission constituents are not yet selected. See Cyril Zenda, Zimbabwe struggles with gender parity, The Financial Gazette (March 24, 2016), http://www.financialgazette.co.zw/zimbabwe-struggles-withgender-parity/. Similarly, this requirement is followed by some Kenyan constitutional commissions, such as the Law Reform Commission, the Parliamentary Service Commission, the Salaries and Renumeration Commission, the National Land Commission, the Commission on Human Rights, and the Public Service Commission. See Commissioners, Kenya Law Reform Commission, http://www.klrc.go.ke/index.php/management/commissioners; Parliamentary Service Commission, Parliament of Kenya, http://www.parliament.go.ke/parliamentary-service-commission; Steve Nguru, Salaries and Remuneration Commission SRC, Constitutions of Kenya (Sep. 2015), http://www.ustawi.info.ke/index.php/government/commissions-and-independent-offices/salaries-andremuneration-commission-src?hitcount=0; Commissioners, National Land Commission, http://www.landcommission.go.ke/about-nlc/commissioners; Current Commissioners, Kenya National Commission on Human Rights, http://www.knchr.org/Aboutus/Structrure/Commissioners/CurrentCommissioners.aspx; Commissioners, The Public Service Commission, http://www.publicservice.go.ke/index.php/aboutpsc/governance-structure/commissioners. 27 7