16 CDL-AD(2013)019 enhance awareness of the work of the Higher Committee if the Law would require the National Assembly or Parliament to conduct a parliamentary debate on this report26. 65. Under Article 12, the Higher Committee may issue press releases, which is a welcome attempt at ensuring transparency of this body’s work. However, this transparency could go even further – it would be preferable if all reports and opinions issued by the Committee would be published, to raise awareness of human rights issues across the country, and ensure accountability of the government. The Paris Principles specify that “public opinion [shall be addressed] directly, or through any press organ, particularly in order to publicize [a national institution’s] opinions and recommendations”. This principle should also be outlined in the Law. 66. As mentioned earlier, the Committee gives itself its own rules of organization and rules of procedure (internal regulation), which then need to be approved by decree of the President. Also amendments to these rules need to be approved by presidential decree. Such requirement to have internal regulations approved by the executive should not compromise the Higher Committee’s independence and efficiency, and should, if at all, constitute a mere formality.27 It is recommended to consider deleting this requirement from Article 10 of the Law, or otherwise specify the functional nature of such decree, which should not be a legal requirement for the validity and applicability of internal rules and regulations of the Higher Committee. Generally, to ensure the largest possible autonomy of such institution in shaping its internal organization and procedures, the Law should be limited to regulating merely the fundamental and general legal framework. Only the Committee itself should be allowed to regulate its own detailed work procedures and organization, and this should be unambiguously reflected in the Law. 67. According to Article 3 of the Rules of Organization, the Higher Committee shall meet at least every three months, and each time the need arises to take decisions and issue opinions. General meetings may be called on an exceptional basis following a written request of at least one-third of those members with voting rights to the Chairman, outlining the subject to be discussed. 68. Currently, the Higher Committee has two permanent sub-committees dealing with requests and complaints, and general reports respectively (Article 4 of the Rules of Organization), and special working groups or commissions may be constituted to deal with issues submitted to the Higher Committee, as needed. Any member of the Higher Committee may take part in all commissions and working groups. In relation to the sub-committee responsible for dealing with requests and complaints, the ability for ministry representatives to participate also in these sub-committee’s meetings should be revisited, to avoid a potential conflict of interest. Even if the latter are not able to vote when decisions are taken, their presence could compromise the confidentiality thus effectiveness of the proceedings in cases involving individual complaints. 69. As stated earlier, it would be advisable to include the main aspects of complaints proceedings in the Law, so that potential complainants will be aware of the procedures for processing complaints (see par. 24 supra). Generally, everyone (including designated legal representatives) should be able to have easy access to the Higher Committee, to complain about his/her grievances. 70. According to Articles 5 and 8 of the Rules of Organization, the allowances granted to Committee members and staff shall be fixed “in accordance with the legislative and regulatory provisions in force”. At least the level of remuneration for Committee members and staff should be fixed in the Law. Especially in the case of full-time staff members, such remuneration should be at a competitive level, and should reflect the special human rights oversight nature of the Higher Committee; it could, e.g., correspond to the salaries of higher court staff. 26 Ibid., par 16. See the Reports and Recommendations from the Session of the ICC Sub-Committee on Accreditation of 19-23 November 2012, Chapter 2, Specific Recommendations, p. 14. See, on a more general note, the General Observations of the ICC Sub-Committee on Accreditation, par 2.10. 27