CAT/OP/BRA/2 (a) whether, and if so how (eg. when, means of communication, and specifically to whom, etc), the SPT’s visit Report was disseminated to the relevant local State authorities, detaining institutions, and all other relevant bodies and authorities, (b) if the Report was disseminated, whether the Central authorities took steps to confirm receipt of it by the relevant entities, and what was done to follow up with the States and institutions to insist upon and to monitor compliance, (c) if the Report was not disseminated to all relevant States and to all detention institutions of the same type reflected in the SPT’s visit, which authorities or institutions did not receive or were not otherwise made aware of it, and reasons why not, (d) whether Ombudsmen, judges, local NGOs and other relevant entities such as the regional preventive mechanisms were also notified and sent copies of the Report, and if so, to whom and how was this information sent or disseminated. 20. In addition, in order to ensure compliance with its international undertakings, the SPT recommends that the State review the way that information is passed down through the different levels of government, and that it consider and put in place new mechanisms that would both raise local level awareness of obligations, support and facilitate their implementation at the local level, and monitor the fact of their implementation. The SPT makes this recommendation purely for the impact it will have on the implementation of its own recommendations, though the advantages that such action would carry across the board are evident. 21. The SPT wishes to highlight that having an effective, fully independent and properly resourced NPM could greatly contribute to efforts in this respect. Through its reports, the NPM would be able to provide a reliable indication to the Central authorities of whether, (and if not, why not), recommendations and indeed Brazil’s own legal safeguards are being implemented. The same advantages are carried with the creation of regional preventive mechanisms. (See para. 32 below). B. Disconnect between law an practice 22. The SPT emphasized in its visit Report that the legal framework in Brazil to prevent torture is largely adequate (Report, para. 22). The SPT wishes to reiterate, with emphasis, that that protections and safeguards provided in law very often do not match the reality on the ground. In the case of Brazil, the legal and policy framework in place to prevent torture and other ill-treatment simply does not match the reality and practice seen in places of detention. Accordingly, it is somewhat disappointing that in its Reply, Brazil has lent so much of its focus to protections at the legal and policy level, with very little attention paid to the implementation of these laws and policies. It is the implementation of laws and safeguards which will have an impact in preventing torture and other ill-treatment. It is the SPT’s overriding concern that in Brazil, it is the implementation of relevant laws and safeguards which is, at this point, unsatisfactory. 23. In view of this disconnect between law and practice, the SPT urges the authorities to take urgent steps to address this. The SPT recommends that this can be addressed via a number of complimentary approaches, including; (a) a zero-tolerance approach to torture and all other forms of ill-treatment which is reflected in practice by allegations of torture or other ill-treatment being taken seriously, subject to prompt and independent investigation with the person making the allegations and any witnesses being removed from danger of intimidation 6