ANNUAL REPORT 2019-OMBUDSMANNATIONAL PREVENTIVE MECHANISM have been forwarded to the immediate superior and the director, and on their part the use of coercive means has been assessed as justified. Also, in cases when means of coercion are used, the Penitentiary-Correctional Institution submits a notification to the Directorate for Execution of Sanctions. Officials said the binding did not apply to sick, elderly, frail, disabled or pregnant women. During the escorts, it was concluded that the tying of persons is almost always done “by default”, as a security measure which is stated in the order for official escort and security, due to which it is recommended not to use tying means during the escorts routinely in all cases, but such means to be used exclusively on the basis of a previously performed individual risk assessment and the need to use tying means - handcuffs. During 2018, coercive means were also used in 6 cases, of which in 4 cases convicts were separated, while in 2 cases tying means - handcuffs were used. From the inspection of the records for the used means of coercion, it was concluded that in only one of the cases the means of using coercion was assessed as unjustified. It is about the use of tying means - handcuffs on one of the convicts serving a prison sentence in the Institution. From the conversations with the officials from the Institution, the NPM team was informed that in order to reduce the risk of possible pressure against the person against whom the means of coercion were used, during the distribution of work tasks to the members of the Prison Police, care should be taken that the contacts between the official and the specific convicted person should be kept to a minimum, and also the NPM team was informed that regarding the specific occurrence, inspectors from the Ministry of Interior, after examining the case, initiated an appropriate court procedure. 3.1.5. Complaints system During the visit, it was concluded that the Institution has special forms for submitting requests for exercising the right, legal interest or filing a complaint, as well as for filing an appeal to the notification upon the submitted request for exercising the right, legal interest or filed complaint. The forms themselves explain the procedure for filing a complaint and deciding thereupon. Such forms were placed on the bulletin boards in each of the special units within the Prison. However, from the conversation with the convicts it was concluded that they were placed shortly before the visit by the NPM team, and some of the convicts were not even familiar with their content. For those who are illiterate, the officials pointed out that there is a lawyer in the Institution who helps them if they want to submit this type or any other type of a request for exercising their right, legal interest or to file a complaint. From the conversation with the officials, it was also concluded that they are really newly developed forms and that special records are kept for such requests, that is complaints, but that so far no request has been submitted in such a form. 112