CAT/OP/DEU/1/Add.1 The Commission shall issue its own rules of procedure. It shall be free in determining its strategies and modi operandi. 29. Furthermore, the Joint Commission of the Länder for the Prevention of Torture has issued its own rules of procedure, which, in section 8 on the conduct of inspection visits, provide the following in subsection (1): “Visits may take place both announced and unannounced”. 30. The Federal Government would like to emphasise that the Joint Commission and Federal Agency for the Prevention of Torture are not under any obligation to announce or obtain prior permission for their visits. 31. The Optional Protocol to the UN Convention against Torture includes an obligation for all States Parties to grant the NPM “access to all information referring to the treatment of those persons as well as their conditions of detention” (Article 20 b). Domestic ratifying legislation has implemented this obligation in German law. 32. Germany’s Länder are aware of the CPT Standards, which include pointers on written records/maintaining files. Furthermore, when they visit Germany (e.g. in 2010 and 2013), delegations of the CPT regularly examine how prisoner and medical records are kept and issue recommendations accordingly. The affected authorities of all Länder are informed of these recommendations. 33. With reference to the recommendation of the SPT contained in paragraph 36 of the SPT visit report (CAT/OP/DEU/1), pursuant to Article 19 c) the national preventive mechanisms shall be granted, at a minimum, “the power to submit proposals and observations concerning existing or draft legislation". The ratifying legislation has implemented this power in German law as well. 34. With reference to the recommendation of the SPT contained in paragraph 48 of the SPT visit report (CAT/OP/DEU/1), the Federal Agency already has POCs at the Federal Ministry of Justice and Consumer Protection who can be contacted in all matters. The Conference of German Justice Ministers is responsible for matters pertaining to the Joint Commission. 35. Finally, Germany would like to reiterate that it embraces the SPT’s offer of constructive dialogue. The Federal Government is aware that the measures described are only the beginning. Germany will maintain contact with the SPT and provide information on further developments. 5