CAT/OP/HUN/2/Add.1 26. The NPM conducts its visits following pre-defined, standard operational and procedural rules, in accordance with the recommendation made in Clause 32 of the Subcommittee’s report.39 During the meeting on 11 April 2018, in order to solidify and further develop uniform rules of procedure, the NPM also discussed its working methods with the participants. 27. In accordance with the recommendation made in Clause 33 of the Subcommittee’s report, the more experienced members of the NPM team hold regular training sessions on interviewing techniques to the new colleagues. The NPM’s colleagues regularly participate in domestic and international training sessions discussing technical issues related to certain types of institutions. On 12–13 March 2018, one of them attended a training session on monitoring homes for the elderly, organized by the Council of Europe, held with the cooperation of the German and the Austrian NPMs; the program also included practical issues related to interviewing techniques. The NPM will do everything, in the future as well, to use the most efficient interviewing techniques in the course of its investigations ensuring the detection of signs of ill-treatment. II. Recommendations on visit methodology A. Working plan, reporting, and follow-up 28. A preventive monitoring visit by the NPM, by necessity, also means a practiceoriented review of the legal regulations relevant to the operation of a given place of detention. In accordance with the recommendation in Clause 35 of the Subcommittee’s report, when planning a visit, the NPM, in addition to the type and geographical location of the place of detention, the categories of detainees held there, and the thematic objectives of the visit, automatically identifies and reviews the legal regulations determining the operation of the suggested site. The NPM “may make proposals for the amendment or making of legal rules affecting fundamental rights and/or the expression of consent to be bound by an international treaty”.40 Through publishing its conclusions and impressions regarding the visits, and making legislative recommendations based on the critical assessment thereof, the NPM facilitates domestic legislation.41 29. The NPM has no legislative powers; however, it shall give an opinion on the draft legal rules and legal concepts affecting its tasks and competences. 42 When reviewing a draft legal regulation, the NPM pays special attention to determining if the text suggested as a result of its legislative recommendation is suitable for remedying and preventing the problematic treatment. In the case of legislative concepts and draft bills relative to the application of which it has no investigative experience, the NPM draws the attention of those responsible for the codification to the risks of ill-treatment and to the measures required for the prevention thereof.43 When reviewing draft legislation, the NPM, depending on its future visits and the conclusions of its future investigations, reserves the right to initiate the amendment or annulment of regulations which will have in the meantime entered into force. 30. The critical analysis of the NPM’s activities, using the assessment tool mentioned in Clause 36 of the Subcommittee’s report, has been completed. The areas that are not properly covered are detailed in Paragraphs 2 through 4. 31. In accordance with Article 23 of the OPCAT and the recommendation made in Clause 40 of the Subcommittee’s report, it is a constitutional obligation of the 39 40 41 42 43 See the relevant provisions of the Ombudsman Act, and Chapter X (Tasks related to the OPCAT National Preventive Mechanism) of Normative Instruction 3/2015. (XI. 30.) AJB of the Commissioner for Fundamental Rights on the professional rules and methods of his/her inquiries. Section 2(2) of the Ombudsman Act. In its reports published in 2017, the NPM made altogether 17 legislative recommendations. Section 2(2) of the Ombudsman Act. In his capacity as NPM, the Commissioner for Fundamental Rights reviewed 212 draft bills in 2016, and 219 in 2017. 7