OSCE/ODIHR Opinion on the Draft Amendments to the Act on Establishment of the Slovak National Centre for Human Rights increase the workload of the committee and of the applicant and it is recommended to formulate this provision not in a mandatory manner so that the committee “can” consider to request a statement of the applicant regarding a reservation. The possibility of anonymous reservations being made is also of concern. If this provision is to be kept, more precision is required to clarify how it will operate in practice, and how it is in keeping with the Paris Principles requirements of independence. Any reservations voiced against candidates should not be made anonymously. 76. The mere fact of making the interview viewable by the public is unlikely to meet the Paris Principles requirements for a consultative process. While the lawmakers should ensure transparency of the process, the Paris Principles do not require an interview to be viewable to public. According to General Observation 1.8, the process of appointment/election of the head of the NHRI should be based on broad consultations and/or participation in the application, screening, selection and appointment process. This may be achieved through various methods allowing representatives of civil society organization and media to observe the process. One element of public scrutiny could also be the vetting of successful candidates by a Parliamentary Committee prior to being appointed. 77. Pluralism should also be taken into account in the criteria for selection of the Executive Director by the Board. The SCA previously recommended to the Centre “to ensure that its membership and staff complement is representative of the diverse segments of society”.101 Reconsideration of the provisions in § 3 ba, of the Draft Amedments should be given, particularly as to the precise nature and purpose of the ‘reservations’, bearing in mind the requirements for independence of the Centre. Pluralism should be included as a requirement for selection of candidates in § 3 bb of the Draft Amendments. 5. Lawmaking Process 78. The SNCHR, pursuant to the SCA’s periodic review process for NHRIs, is due for reaccreditation in 2019.102 The stated aim of the Draft Amendments is for the SNCHR to fully comply with the Paris Principle and obtain A-Status. The upcoming review might be one motivating factor for the timing of the Draft Amendments. However, the Draft suggests the new act would enter into force by 1 May 2019. The draft further seems to suggest that the current executive director’s term of office will expire on 30 April 2018, and that of the Board on 30 June 2019. It is unclear whether transitional arrangements are in place before the new Director and Board are appointed under the revised legislation. This move may breach the Paris Principles’ requirements that the executive should not be able to remove NHRI leadership or board members from office and should be seriously considered by the drafters. 79. Further, given the importance of the proposed amendments, the haste with which this law is proposed to be enacted may require reconsideration. OSCE commitments require States to adopt legislation as “as the result of an open process reflecting the will of the people, either directly or through their elected representatives”. 103 At the same time, a 101 Op. cit. fn 7, p. 9 (2014 ICC Sub-Committee on Accreditation Report). Periodic re-accreditation is mandated by Article 15 of the GANHRI Statute. 103 See par 18.1 of the Moscow Document (1991), available at http://www.osce.org/fr/odihr/elections/14310 102 25