A. Regarding the first point of the Draft Decision, the Title of the Program and especially in the point “I. Its purpose and principles, we think that it would be appropriate to define who these other actors are that are charged with electoral duties or involved in the elections.
The clear definition of the target of this decision from the beginning, we consider that it gives due importance to its content, the equality in the importance of the responsibilities and tasks that must be fulfilled by all the actors charged according to the law, as well as the organization with a more thorough care and due attention to the foreseen program.
B. In the heading “V. Procedures for the application of candidates for election administration trainers” provide forecasts for the monitoring target of long-term and short-term trainers, and specifically through its points 4 and 5:
“… 4. The long-term trainer engages with the training of
a) the election administration
b) the employees of the local government administration
c) the election campaign monitors
d) the candidates of the political entities
e) the monitoring of the election administration
5. The short-term trainer engages with the training of :
a) electoral administration
b) candidates of political entities
c) monitoring of the electoral administration. …”.
It is noted that in its entire content, the program more clearly defines the Electoral Administration as a category to be trained, along with all other necessary adjustments and provisions. It has even attached to the Program a planning for the realization of the foreseen trainings.
Such a thing is missing for the other categories that are expected to be trained through this Program and specifically for the employees of the local government administration, monitors election campaign candidates of political subjects.
In the various points of the Program, the provision is simply made that:
“VIII.4.a. The training of the election campaign monitors and the training of the public administration of the local government will be carried out at the district level. The calendar, place, schedule and organization of the training of election campaign monitors, public administration of local government will be carried out by the CEC, respectively by the Directorate of Electoral Subjects, Supervision, Financing and Monitoring (DSZMFM).”
“VIII.4.b. In the training of political party candidates, the trainers recruited for a short term period, after having previously been trained by the CEC, will be included. The calendar, place, schedule and organization of the training will be carried out by the CEC, respectively by (DSZMFM).”
“IX.8. The trainer is also paid for carrying out other trainings with the administration of the central or local government, candidates of political entities or election campaign monitors according to the program drawn up by the directorates that cover these issues and approved by the CEC.”
“IX. 11. The fulfillment of the trainers’ obligations for the training of election campaign monitors, candidates, local government administration and the calculation of the financial aspects of these trainings is followed and analyzed by DSZMFM.”
“XII. Training calendar.
… The planning of other trainings is done by DSZMFM.”
KRIIK is of the opinion and suggests that in this Program, which are the categories to be trained, the scope of their responsibilities and the connection with the relevant regulatory acts, if any, as well as the fields of training, or the main modules, should be clearly foreseen.
This especially applies to the employees of the public administration of the local government, which of them will be trained and for what they will be trained.
The same for the candidates of the political entities for what they will be trained for.
Also, KRIIK suggests that it is necessary to establish time limits as well as other main necessary elements, such as related to monitoring or financial costs or even how this work will be organized by DSZMFM.
These forecasts will outline the orientation framework within which the DSZMFM will operate and it will be easier for it to do the entire organization of the training, monitoring and evaluation process.
C. Regarding the training modules that will be used. KRIIK considers that it is necessary that in the design of the training methodology and relevant curriculataken into consideration and the violations observed by the post-election audit process for the examination of election materials either for the Parliamentary Elections 2021 or for the Partial Elections areLocal 2022.
Therefore, it is suggested that this forecast becomes part of the program text, as a separate point or as a supplement to point IX.2. and IX.8.
The same applies and should be done for the design of the training methodology and relevant curricula for the training of election campaign monitors, public administration of local government and candidates of political subjects.
In their drafting, all the findings of the analysis made by the CEC administration itself, the cases of administrative investigation or complaints reviewed by the CEC, as well as the findings or recommendations made in the relevant observation reports by international observers should be taken into consideration. and local, including the recommendations from the discussion tables and meetings where the CEC has been a part, and where the above actors and their sphere of responsibility have been the subject matter, directly or indirectly.