Dear MM,

What you have raised here is a very pertinent “Corporate Governance” issue. What is being proposed is a definitely a deviation from the current structure. But what is needed is just to make it a bit more clear, how it is to function. Probably we just need to address ourselves to a few questions, for example: What will be the top management structure of ICCK like? Is there need to have a kind of Board to oversee the management of ICCK?  The roles of Commission Chairman and fellow Commissioners and the Director General and his/her team of fellow Directors (the Staff) should to be clearly definite and demarcated.  This should be clearly articulated in the Bill/Act to avoid any confusion.  If the commissioners are fulltime engaged in the daily running of ICCK, whether developing strategies or in whatever roles, then there could be conflict in roles with that of the DG, but only if the DG has a similar or same power of authority as the Commissioners.  The way the Draft Bill is at the moment, the role of the DG is being reduced to a lower level (not necessarily a line manager position), and the commissioners are to play the role of top management team of the organization. This will of course subdue the role of Director General, to a lower level as the DG will be reporting to the Commission Chairman and his/her team who will be responsible for the daily running of the ICCK affairs.  There could be a conflict of roles here; however the position of the DG is reduced, if the chairman of the Commission takes over the daily management functions of ICCK.  There could be a body to oversee the activities of the Commission whose role is not daily management of the ICCK. But on the other hand, this kind of a structure is what is to be abolished to give birth to a body with a teeth to bite; a body with authority to make decisions, without political and other forms of interference from the environment; an independent regulatory authority whose activities is governed and directed by the rule of the laws and the regulations, “not by a board of directors” with political lineages.   

Regards

Vitalis