OSCE/ODIHR Opinion on the Draft Act on the Independent National Human Rights Institution of Iceland institutions should nevertheless benefit from certain flexibility with respect to public service rules on recruitment and career advancement.93 In any case, the Draft Act should clarify the employment status of the NHRI’s staff. 70. Regarding staff salaries and benefits, General Observation 1.10 provides that they should be “comparable” to those of civil servants performing similar tasks in other state independent institutions. In many countries though, public sector salaries may not always be adequate or appropriate and it is recognized that so-called “comparable” salaries should only be a minimum criterion.94 A good practice in that respect is to provide salaries that are more at the upper end of the public sector’s salary scale, particularly for professional expert staff, while taking into account similar levels of responsibilities and experience. This is useful not only to attract and retain competent staff,95 but also to ensure their independence from the executive when carrying out their work. The Draft Act should be supplemented accordingly, while ensuring that the NHRI has some flexibility to set the levels of wages and benefit packages for its staff, especially professional expert staff, which may differ from those of the public service in general;96 similar comments apply regarding rules on career advancement and human resources management.97 71. As stated in General Observation 1.7, a “diverse […] staff body facilitates the NHRI’s appreciation of, and capacity to engage on, all human rights issues affecting the society in which it operates, and promotes the accessibility of the NHRIs for all citizens”. As in the case of the Board of Directors (see pars 45-47 supra), the staff of an NHRI should reflect pluralism in terms of gender, ethnicity or minority status98 so as to represent all segments of society within NHRI staff at all levels of responsibility, including senior level positions.99 This can help strengthen the visibility of an NHRI’s commitment to inclusiveness and diversity, could positively influence the institution’s overall credibility and effectiveness, and may serve as model for other public bodies.100 Thus, it is recommended to supplement the Draft Act by adding provisions clearly stating that qualification requirements and selection criteria and modalities, and employment conditions, for NHRI staff, should ensure gender balance and diversity at all staff levels.101 93 94 95 96 97 98 99 100 101 ibid. page 156 (2010 OHCHR Handbook on NHRIs). See also op. cit. footnote 14, pages 173-174 (2010 UNDP-OHCHR Toolkit for Collaboration with National Human Rights Institutions). Op. cit. footnote 92, page 156 (2010 OHCHR Handbook on NHRIs); and op. cit. footnote 14, page 174 (2010 UNDP-OHCHR Toolkit for Collaboration with National Human Rights Institutions). ibid. pages 123 and 152 (2010 UNDP-OHCHR Toolkit for Collaboration with National Human Rights Institutions). ibid. page 152 (2010 UNDP-OHCHR Toolkit for Collaboration with National Human Rights Institutions). ibid. page 174 (2010 UNDP-OHCHR Toolkit for Collaboration with National Human Rights Institutions). ibid. page 20, General Observation 1.7 (General Observations). See also e.g., op. cit. footnote 29, page 9 on the Staffing of the Commissioner for Administration and Human Rights (CAHR) of Cyprus (SCA Report and Recommendations of November 2015). Op. cit. footnote 16, pages 9 and 78 (2012 OSCE/ODIHR Handbook for NHRIs on Women’s Rights and Gender Equality). See also op. cit. footnote 92, page 157 (2010 OHCHR Handbook on NHRIs). ibid. pages 39 and 173 (2010 OHCHR Handbook on NHRIs). See also e.g., Amnesty International, National Human Rights Institutions: Amnesty International’ Recommendations for Effective Protection and Promotion of Human Rights (2001), page 10, Recommendation 2.4, available at https://www.amnesty.org/en/documents/ior40/007/2001/en/. See e.g., op. cit. footnote 16, pages 9, 78 and 80 (2012 OSCE/ODIHR Handbook for NHRIs on Women’s Rights and Gender Equality); and Sub-Committee on Accreditation, Report and Recommendations of the Session (March 2015), page 23 on the Staffing of the Protector of Citizens (PCRS) of Serbia, available at http://nhri.ohchr.org/EN/AboutUs/ICCAccreditation/Documents/SCA%20MARCH%202015%20FINAL%20REPORT%20%20ENGLISH.pdf; and Sub-Committee on Accreditation, Report and Recommendations of the Session (March 2012), pages 8 and 10 on the Staffing of the Commissioner for Human Rights of Kazakhstan and of the Ombudsperson (Akyikatchy) of the Kyrgyz Republic (OKR), available at http://nhri.ohchr.org/EN/AboutUs/ICCAccreditation/Documents/SCA%20MARCH%202012%20FINAL%20REPORT%20ENG%20WI TH%20ANNEXURES.pdf. 22