Principle 4: independent and Impartial Investigators is often not transparent to the public because transparency conflicts with its duty to secure confidentiality in the investigative context.459 The UNDP Guidelines for Investigations assert that confidentiality is necessary during the investigation process—so much so that the “requirement for confidentiality extends equally to investigators, management, staff members and other personnel, investigation participants, and investigation subjects.”460 Accordingly, the Uniform Guidelines for Investigations instruct investigative authorities to “take reasonable measures to protect as confidential any non-public information associated with an investigation, including the identity of the parties that are the subject of the investigation and of parties providing testimony and evidence.”461 Many states have enacted statutory provisions that ensure confiden- “Independence” embraces two different tiality in the course of an electoral concepts: (1) structural independence investigation. Indonesian regula- from the government; and (2) “fearless tions, for example, plainly state that independence”—not bending to an investigation is “confidential in governmental, political or other partisan nature, as long as there are no deci- influences on decisions. sions made by a plenary.” 462 In Bhu- tan, the Election Dispute Settlement Rules and Regulations specify: “The decision-making authorities shall Excerpt from the ACE Electoral Knowledge Network: http://aceproject.org/ace-en/ topics/em/default ensure that the confidentiality of the name of complainant, if necessary, shall be upheld and witness protection, if requested, provided as per the laws of the Kingdom of Bhutan.”463 The Australian Electoral Commission also guarantees confidentiality in the management of a complaint and refers back to the commission’s privacy policy.464 In Hong Kong, the regulations of 459 Steve Bickerstaff, Contesting the Outcome of Elections, in International Election Principles: Democracy & the Rule of Law 307–346, 312 (John Hardin Young, ed., 2009) (distinguishing between an election contest and the independent investigation of alleged electoral irregularities). 460 UNDP Investigation Guidelines 2012, supra note 6, ¶ 3. 461 Uniform Guidelines 2009, supra note 25, ¶ 12. 462 Bawaslu Regulation No. 14/2012, supra note 173, art. 14(3). 463 Bhutan Election Dispute Settlement Rules and Regulations, supra note 28, ¶ 9.5. 464 Australian Election Complaints Management Policy, supra note 8. 129