Election Investigations Guidebook In General Comment No. 32, the Human Rights Committee recognizes that it is necessary to protect judges against conflicts of interest in order to safeguard their independence.481 Extending this principle to elections, the European Court of Human Rights similarly concludes: “One of the guarantees of election commissions’ independence is that persons who could be involved in an inherent conflict of interest should not be allowed to be appointed to electoral commissions….”482 Like all electoral standards and procedures,483 states should clarify conflicts of interest in their electoral laws, regulations, and policies. The relevant authorities should provide clear, realistic descriptions of the circumstances and relationships that can lead to conflicts of interest. They should ensure that investigators fully understand their duty to identify, declare, and manage conflicts of interest.484 States can address conflicts of interest among election investigators in various ways. Most broadly, they can include conflict of interest provisions into general administrative laws that apply to all public servants, including election investigators. In Ukraine, for example, the Code of Conduct for Public Officials obliges investigators to “use exhaustive measures” to avoid conflicts of interest and “not allow actions or inaction that may cause a conflict or create an impression of one.”485 Likewise, in Pakistan, the Government Servants (Conduct) Rules of 1964 and the Government Servants (Efficiency and Discipline) Rules of 1974 apply to electoral commission officials.486 Alternatively, states can include conflict of interest provisions into their electoral laws or regulations, as in South Africa. Finally, states can also include provisions about conflicts of interest into the electoral codes of conduct.487 481 General Comment No. 32, supra note 374, ¶ 19. 482 Georgian Labour Party v. Georgia, App. 9103/04 Eur. Ct. H.R. ¶ 68 (2008) (reviewing conflict of interest provisions in the electoral laws of Belgium, Bosnia and Herzegovina, the Czech Republic, Germany, Hungary, Moldova, Portugal, Serbia, Spain, and the United Kingdom). 483 See generally GUARDE, supra note 1, at 24–37 (describing the necessity for a clearly defined regimen of electoral standards and procedures). 484 See generally OECD Guidelines for Managing Conflict of Interest in Public Service §§ 1.1–1.2, in Managing Conflict of Interest in the Public Sector: A Toolkit, supra note 481, at 95. 485 Code of Conduct for State Officials, No. 4722-VI (Ukr.), http://zakon4.rada.gov.ua/laws/anot/en/4722-17. 486 Internal survey response from IFES legal team in Pakistan (Jun. 18, 2013) (on file with IFES). 487 See generally Wall et al., supra note 366, at 73 (noting that the avoidance of conflicts of interest is a basic issue often included in electoral codes of conduct). 134