122. The SPT recommends that the right of detainees to lodge a complaint is clearly established in law and that detainees are fully informed about this right by the police officers and/or staff working in the police detention facilities. In this connection the SPT wishes to emphasize the duty of the Maldivian authorities to ensure that there are no reprisals as a result of lodging a complaint. 123. Furthermore, the SPT recommends that the authorities ensure that the detainees have the possibility to lodge a complaint in practice, and that the principle of confidentiality of complaints is duly respected. Police officers or staff working in detention centres should not interfere with the complaints process, filter the co mplaints addressed to competent au thorities or have access to the con tent of the complaints. The SPT recommends drawing up rules for use by the police officers regarding handling of complaints, which should include modalities concerning referral of the complaint to the competent authorities, the obligation to respect the anonymity of the complainant, and the duty to make available writing materials and envelopes for detainees wishing to lodge a complaint. 124.As there are currently several authorities in the Maldives vested with the power to examine complaints, it is important to have an overview of the type of the complaints lodged and the outcome of the investigations and possible sanctions imposed. This information systematically compiled would be an effective tool in prevention of ill-treatment as it would give the authorities an overview of compliance by police officers with their duties toward detainees, and the possibility to identify and analyze gaps in the existing safeguards and the need for training, legislative changes or other targeted measures to eradicate ill-treatment. The SPT recommends that the Maldivian authorities examine the possibility to establish such an information system. 125.The SPT also wishes to emphasize that the mere existence of complaints mechanisms is not enough; they must be, and must be seen to be, independent and impartial, and should offer guarantees of effectiveness, promptness and expeditiousness. 11. Access to monitoring bodies as a safeguard against ill-treatment 126.As noted above in Chapter I, section B 1, it remained unclear to the SPT whether the HRCM has a mandate to monitor places of deprivation of liberty operated by or under the responsibility of the police. 127.With the designation of the HRCM as the National Preventive Mechanism (NPM), the SPT looks forward to the development of a proactive and regular programme of visits to police stations and other police custodial facilities. Regular visits, including unannounced visits, to police facilities should also include interviews with detainees in private. 128.As noted in Chapter I section B 5 above, the new Constitution also vested in the Prosecutor General the power to monitor and review the circumstances and conditions under which any person is arrested, detained or otherwise deprived of freedom prior to trial. 12. Training and supervision of police officers 129.The SPT notes with concern that the police officers working at the Dhoonidhoo Detention Centre stated that they had not received any training for their work at the detention centre. The SPT recommends that the police officers and other staff members working in the police stations and police detention facilities are provided with adequate training for work in custodial settings. 130.During the visit, the delegation paid particular attention to the oversight and supervision exercised by officers in charge and other senior police officials over the work of police officers. The delegation observed that, in practice and in particular on the more remote atolls, the police officers in charge seemed to experience very little supervision by more senior officers. For example, in the Ha. Dhidhdoo Police Station the delegation was informed that an inspector from Malé police came only once in 6-8 months, and that no other internal mechanisms of superior control existed. 131.The SPT considers that proper supervision and oversight of subordinates is an essential safeguard against illtreatment. The SPT believes that the absence of effective oversight by senior officials of the treatment of detainees by the police officers, and possibly even their silent approval of the methods used, may lead some police officers to resort to ill-treatment. Whereas the delegation does not assume that the alleged ill-treatment is the result of direct orders, the lack of oversight and supervision does not absolve senior officers from their responsibility to ensure that ill-treatment does not occur. The SPT recommends that the authorities ensure effective oversight and supervision of the work of police officers by senior officials and superior authorities. 132.Furthermore, the SPT wishes to underline that those exercising superior authority cannot avoid accountability or escape criminal responsibility for torture or ill-treatment committed by subordinates where they knew or should have known that such impermissible conduct was occurring, or was likely to occur, and where they failed to take reasonable and necessary preventive measures. The SPT recommends that the relevant authorities ensure that the responsibility of any superior officials, whether for direct instigation or encouragement of torture or ill - treatment or for consent or acquiescence therein, be fully investigated through competent, independent and impartial prosecutorial and judicial authorities. 133.The SPT welcomes the information provided by senior police officers on measures being taken in the Police to ensure better oversight of Police to prevent the occurrence of ill-treatment. These measures would include, among others, preparation of an integrity code, “Statement of values”, covering issues such as how the police should act toward detainees, how to carry out interrogations and the audio-video recording of interrogations. The SPT wishes to be kept informed of any developments to this effect. The SPT recommends that, as a means of preventing cases of torture and ill-treatment, interrogation rules, instructions, methods and practices as well as arrangements for the custody and treatment of persons subjected to any form of arrest or detention should be kept under systematic review.