Election Investigations Guidebook any judgment or remark which is prejudicial in nature.”443 This guidance highlights the importance that the notion of impartiality can play in developing perceptions of fairness in the investigation process. Several other countries have incorporated notions of fairness in their policies. The Australian Electoral Commission’s Complaint Management Policy, for example, provides that investigators should be guided by an adherence to the principle of fairness, which is defined as a management of complaints fairly and with integrity but also includes impartiality and respect for all complainants.444 Objectivity Objectivity refers to impartiality in carrying out public duties.445 Furthermore, there are two aspects of objectivity that must be considered when developing effective investigation regimes: institutional objectivity and individual investigator objectivity.446 It is also important for investigators to consider both real and perceived impartiality, given the influence that public perceptions can have on the acceptance of investigation and adjudication outcomes. 443 Bhutan Election Dispute Settlement Manual, supra note 27, ¶ 6.11. 444 Australia, Complaints Management Policy ¶ 4. 445 See Gilman, supra note 364; cf. OHCHR Manual, supra note 374, at 139 (similarly equating objectivity and impartiality by stating that the “notion of impartiality of the judiciary . . . means that all the judges involved must act objectively.”). 446 See Valente v. The Queen, [1985] 2 S.C.R. 673 (Can.); Office of the High Comm’r for Human Rights, Independence and Impartiality of Judges, Prosecutors and Lawyers, in Human Rights in the Administration of Justice: A Manual on Human Rights for Judges, Prosecutors and Lawyers 119 (2003) (In a passage from the prominent Valente v. The Queen decision, the Canadian Supreme Court summarizes the general understanding of objectivity or impartiality under both Canadian constitutional law and international human rights law. Commenting on the right to an independent and impartial judiciary, the Court states that this notion “connotes not only a state of mind but also a status or relationship to others . . . rest[ing] on objective conditions or guarantees.” It “involves both individual and institutional relationships: the individual independence of a judge . . . and the institutional independence of the court.”); General Comment No. 32, supra note 374, ¶ 21 (the Human Rights Committee affirms that the “requirement of impartiality has two aspects,” both an individual and a structural dimension: “First, judges must not allow their judgment to be influenced by personal bias or prejudice, nor harbor preconceptions about the particular case before them, nor acts in ways that improperly promote the interests of one of the parties to the detriment of the other. Second, the tribunal must also appear to a reasonable observer to be impartial.”); El-Masri v. Former Yugoslav Republic of Macedonia, App. No. 39630/09, 2012-VI Eur. Ct. H.R. 263, ¶ 184 (The Court suggests that objectivity is not only the absence of a hierarchical or institutional connection, but also independence in practical terms.”); See also Volkov v. Ukraine, App. No. 21722/11 Eur. Ct. H.R. ¶ 104 (2013) (Reaffirming its decision in El-Masri v. Former Yugoslav Republic of Macedonia, the Court stated that any analysis of the objectivity of an election investigation must contemplate “whether the tribunal itself . . . offer[s] sufficient guarantees” of its independence and if the “personal conviction and behavior” of the individual investigator holds “any personal prejudice or bias in a given case.”). 126