Election Investigations Guidebook of the offense, penalties for improper, wrongful, or negligent conduct may include transfer, suspension, termination, fine, and prosecution.386 The Philippines provides a good example of a comprehensive procedure for disciplinary action and associated penalties. According to the election law, if an election officer is found guilty of misconduct following a procedure that protects the officer’s due process rights, the authority with jurisdiction over the matter can order suspension, removal from office, and fines.387 The Anti-Graft and Corrupt Practices Act provides for further penalties, including imprisonment, fines, removal or dismissal from public office, permanent disqualification from public office, and confiscation or forfeiture of assets.388 In addition, the Congress is empowered to impeach members of the Election Commission for a culpable violation of the Constitution, such as treason or corruption.389 386 See, e.g., Kingdom of Bhutan, Election Act of the Kingdom of Bhutan § 324 (2008); Republic of Georgia, Law of Georgia on Public Service No. 45, arts. 78, 79 (1997). 387 Omnibus Election Code, B.P.Blg. 881, art. VII, sec. 52 (Phil.) (“[A]s any public official or employee, regardless of whether or not he holds office or employment in a casual, temporary, holdover, permanent or regular capacity, committing any violation of this Act shall be punished with a fine not exceeding the equivalent of six (6) months’ salary or suspension not exceeding one (1) year, or removal depending on the gravity of the offense after due notice and hearing by the appropriate body or agency. If the violation is punishable by a heavier penalty under another law, he shall be prosecuted under the latter statute. Violations of Sections 7, 8 or 9 of this Act shall be punishable with imprisonment not exceeding five (5) years, or a fine not exceeding five thousand pesos (P5,000), or both, and, in the discretion of the court of competent jurisdiction, disqualification to hold public office.”) 388 Anti-Graft and Corrupt Practices Act, Rep. Act No. 3019, § 9 (1960) (Phil.). 389 Const. (1987), art. XI, sec. 2 (Phil.) (“The President, the Vice-President, the Members of the Supreme Court, the Members of the Constitutional Commissions, and the Ombudsman may be removed from office on impeachment for, and conviction of, culpable violation of the Constitution, treason, bribery, graft and corruption, other high crimes, or betrayal of public trust. All other public officers and employees may be removed from office as provided by law, but not by impeachment.”). 114

Select target paragraph3