their beneficiaries from circumventing this, the law must prohibit donations through third parties. Also, to ensure a relatively even political playing field, especially with regard to the financial disparity between bigger and smaller political parties, reasonable limits must be placed on election expenditures of parties and candidates. These limits can be determined from time to time by Parliament, upon recommendation by an independent electoral commission following consultations with political parties and other stakeholders. V. In the light of the immediate above, it is desirable that political parties must be required to maintain records of all donations received from private sources, together with proper books of accounts, subject to audit in the manner already suggested above with regard to public funding. Care must be taken, however, to ensure that the maintenance of such records and books of accounts is strictly for transparency and accountability purposes only, in the public interest, and not for ulterior purposes especially by the party in power. The information must not be used to ‘flush out’ who the donors of the opposition are and to impede their support for parties of their choice. The result of such a requirement must not be to imperil the donors. It is especially important that this is borne in mind when considering the timing of such a requirement, more so in view of how vindictive ZANU (PF) can be. VI. While foreign donations to political parties are prohibited, there is no law which prevents the government from receiving foreign donations, however they are channelled, for the purpose of supporting the electoral process e.g. voter registration, printing of ballot papers, making ballot boxes, public awareness campaigns and general support to the body responsible for running elections. Where such donations are received, this must be done in a transparent and accountable manner, so that individual parties, especially the governing party, should not benefit directly from the donation. Ideally, such donations must be managed and utilised by an independent electoral commission. VII. The Minister of Justice should not be involved in determining who qualifies for public funding and in allocating the funds to political parties because there is a clear conflict of interest and lack of transparency and accountability. An interested party should not determine how and when political parties should access funding, and administer the funds. That responsibility should rest with an independent and impartial body, presumably an independent electoral commission as is the case with other countries. Further, the budgetary allocation for political parties should not be administered as part of the Ministry of Justice vote but it 32