Section three Strengthing the NPM information to the general public (Q 1.52). • Members continued to report the lowest levels of compliance for questions relating to sanctions, including: whether they had developed a strategy for the prevention of reprisals or threats against people interviewed during visits and people who provide information during visits (Q 1.36); whether they had a policy setting out the types of information that can be collected in group interviews and the types of information that should only be collected in private interviews (Q 1.37); and if they seek to ensure that a disciplinary or criminal investigation is initiated in cases of alleged reprisals (Q 1.42). • As in previous years, a significant number of NPM members ( just over two-thirds of those completing the self-assessment) remained only partially compliant in the area of gender balance and representation of ethnic and minority groups in visiting teams (Q 1.17). • Organisations based in England were the most positive about their compliance, reporting 93.1% full compliance, compared with members working in both England and Wales who reported the lowest level of full compliance at 75.3%. • Professional bodies reported a higher level of full compliance (87.6%) than lay bodies (76.6%). Conclusion The findings of the self-assessment are presented to the NPM membership at the business meeting following the completion of the analysis. In light of the lowest levels of reported compliance continuing to be in areas relating to sanctions and equality and diversity, members agreed that a focus on these two issues be included in the 2018–19 NPM business plan. In addition, the thematic work that the NPM will undertake on ill-treatment (see section 2) will consider issues relating to sanctions. We therefore hope to report increased compliance in these areas in coming years. Developing the NPM Throughout the year, the NPM continued to work for greater recognition and independence of the NPM and for the OPCAT-related work of the NPM itself and each of its individual members to be placed on a legislative footing. The NPM’s view, supported by the United Nations Subcommittee on Prevention of Torture and other Cruel, Inhuman or Degrading Treatment or Punishment (SPT) is that the NPM must be placed on a statutory footing through legislation which recognises its independence and reflects the powers it has pursuant to OPCAT. As noted in last year’s annual report, the NPM Chair wrote to the Director of Judicial, Rights and International Policy at the Ministry of Justice (MoJ) in January 2017 to express his concern about the lack of legislation setting out the mandate of the NPM and its constituent bodies, and the lack of statutory guarantees of independence for the NPM or its members.43 In addition, the NPM recommended that a statutory basis for the NPM be introduced into the Prisons and Courts Bill that was then before Parliament.44 43 Eighth Annual Report of the United Kingdom’s National Preventive Mechanism 1 April 2016 – 31 March 2017, available at https://s3-eu-west-2.amazonaws.com/npm-prod-storage-19n0nag2nk8xk/uploads/2018/02/6.4122_NPM_AR201617_v4_web.pdf, accessed 19 July 2018. 44 Public Bill Committee, Written evidence submitted by John Wadham, Chair of the UK National Preventive Mechanism (PCB 08). 37