CAT/OP/DEU/2/Add.1 operative guidelines should, in the view of the National Agency, be sufficiently flexible to maintain the ability to react to unforeseen circumstances. 15. With reference to the recommendation of the SPT contained in paragraph 33 of the SPT visit report, the State Treaty and the decree of the Federal Ministry of Justice both include references to the National Agency’s rights under articles 19 and 20 of the Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment. Its task is hence known to the authorities concerned. On several occasions, the National Agency has been asked for its opinion on draft legislation. It has hitherto though not been able to submit opinions due to lack of capacity. Under the current circumstances and where required, its strategy is to include into its visit reports, comments on legislative shortcomings. Abstract comments on draft or existing legislation may result from background research undertaken by the National Agency on different issues. 16. A modification in particular of the State Treaty would require an agreement of the 16 Länder Ministries of Justice and approval by all 16 Länder Parliaments. Taking into account that there are more straightforward ways to ensure better implementation of the National Agency in legislative processes, amendments to the basic texts do not appear practical at this stage. 17. With reference to the recommendation of the SPT contained in paragraph 35 of the SPT visit report, the general public can provide the National Agency with information through a variety of channels such as postal mail, telephone, fax, e-mail as well as the anonymous contact form on its homepage. The Agency frequently receives information from many sources; among them, mainly detainees and their family members but also journalists or interest groups. It, furthermore, proactively establishes contacts with many public agencies and non-governmental organizations and participates in conferences and meetings of different interest groups. 18. The National Agency has identified that publishing its visit reports only in its Annual Reports is a major limiting element to its public visibility. Due to the fact that up to a year may pass before a report is published, many visits go unnoticed by the press. So as to ensure a more timely notification, beginning 2014 the Agency will increase its public visibility mainly by making visit reports available to the public on its website together with the comments of the subject ministry. 19. The National Agency’s corporate identity is currently being designed in cooperation with the University of Applied Sciences and Arts Hanover. Only through this innovative approach was the National Agency able to finance its new corporate design. The scope of this process will include the annual report, the website and information leaflets. There will be a version for detainees that will be translated into the most pertinent languages. 20. Annual reports are published in German and English and are sent to some 50 interest groups in Germany and abroad. The reports are also available through the National Agency’s website. All past reports have been sent to the SPT in German and English. The National Agency is thus already complying with article 23 of the Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment. 21. The National Agency maintains contacts with the relevant Federal and Länder Ministries and regularly meets their representatives. To improve implementation of its recommendations, it immediately informs the head of department about the provisional findings. Contacts are also maintained with other European NPMs through the Council of Europe’s NPM network. Furthermore, the National Agency, with financial and operative support by the Federal Ministry of Justice, is organizing a first meeting of Germanlanguage NPMs to take place in Berlin in April 2014. 4

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