OSCE/ODIHR Opinion on the Draft Law Amending and Supplementing the Ombudsman Act of Bulgaria boards and councils, networks and/or public forums. 52 Article 15 of the Rules of Procedure of the Ombudsman Institution provides for the possibility of setting up advisory councils. The decision to do so, as well as the modalities and composition of these councils continues to lie, however, with the Ombudsman. To enhance pluralist decision-making, the Ombudsman is encouraged to set up and consult with advisory councils regularly, in order to obtain more information and expertise in key areas. Additionally, the composition of the advisory councils should ensure the representation of civil society, relevant experts and affected groups. In this context, the inclusion of women and members of ethnic, linguistic, religious, sexual or other minority groups is particularly encouraged. 6. Adequate Funding of the Institution 6.1. General Remarks 31. Adequate funding is crucial for the financial autonomy of any NHRI and, as such, for its ability to efficiently fulfill its mandate pursuant to Section B.2 of the Paris Principles. Article 47 par 1 of the Rules of Procedure spells out that the work of the Ombudsman and his or her administration “shall be financed by the national budget and other sources”. The justification to General Observation 1.10 clarifies that national law should always indicate the budget allocation for an NHRI, and shall ensure that funds are released in a timely manner. In light of this justification, it should be ensured that the funding for the Ombudsman is allocated in a transparent manner and funds for the NHRI should be allocated in a separate budget line.53 It is recommended to supplement the Draft Amendments accordingly. 32. Additionally, adequate funding, pursuant to General Observation 1.10, includes an appropriate level of salaries and benefits for an NHRI’s staff, comparable to civil servants performing similar tasks in other independent institutions of the State. The status and remuneration of the Ombudsman and the Deputy Ombudsman should equal that of other positions of high rank within the State structure.54 These resources should also be used to ensure that the Ombudsman Office’s premises are accessible to the wider community, including persons with disabilities, and should fund the establishment of well-functioning communications systems including telephone and internet. 33. Funding for an NHRI should also be secure, meaning it should not be arbitrarily altered for the period for which it was approved.55 Additionally, if budget cuts are inevitable, the cuts should not target NHRIs disproportionately. The reduction of funds should not be out of proportion to that of other core areas, in particular in the area 52 53 54 55 UNDP-OHCHR Toolkit, op. cit. footnote 4, page 162. See General Observation 1.10; see also op. cit. footnote 39, par 74 (OSCE/ODIHR NHRI Opinion Iceland). In this regard, practice greatly varies within the OSCE area. See e.g., Article 10 (5) of the Ombudsman Act (1995) of Malta referring to remuneration equivalent to that of the judges of superior courts; Section 8 of the Law on the Public Defender of Rights (1999, as amended 2009) of the Czech Republic, which refers to the salary, severance pay, reimbursement of expenses and benefits in kind equal to that of the President of the Supreme Audit Office; Article 12 of the Law on Establishment of a Mediator of Luxembourg (2003), referring to the specific upper salary scale applicable in the public service; all are available at http://www.legislationline.org/topics/topic/82; see also op. cit. footnote 12 Section 4.1.1 on Rank and Salary (2016 Venice Commission’s Compilation of Opinions concerning the Ombudsman Institution). UNDP-OHCHR Toolkit, op. cit. footnote 4, page 254. 13