OSCE/ODIHR Opinion on the Draft Law on Amendments to the Law on the Protector of Human Rights and Freedoms of Montenegro - Article 25c (fifth indent) should provide the possibility for the Human Rights Protector or his/her representatives to be accompanied by a translator if deemed necessary. 35. It should also be noted that the Draft Law currently does not include a legal guarantee that persons who have cooperated with the office of the Protector (e.g. detainees, their families and friends, lawyers, former detainees, staff of places of detention, and any other person or organization wishing to complain or convey information to the Protector) shall not suffer any retaliation or sanction (as per Article 21 par 1 of the OPCAT). Such legal guarantee is distinct from the protective measures mentioned under Article 29 of the Human Rights Protector Law regarding the investigation of complaints, but could be added to this provision. It is recommended that the Draft Law is amended accordingly. 36. Given that the introduction of the new Article 25c renders the current Article 24 of the Law somewhat redundant, it is unclear why the Draft Law does not also foresee the deletion of Article 24. The current wording of Article 24 is also not fully consistent with the newly introduced provisions, e.g. with regard to the categories of persons permitted access to premises where persons are deprived of their liberty, which do not include the members of the working group established under the Law. Consequently, to avoid any confusion, it is recommended that, instead of amending Article 24 of the Human Rights Protector Law, Article 8 of the Draft Law should provide for the deletion of this provision. 4.3 Competences as an Anti-Discrimination and Equality Body 37. It is noted that Article 11 of the Draft Law (amending Article 27 of the Human Rights Protector Law) will delete the reference to the Protector as an institutional mechanism for the protection from discrimination (Article 27 par 1) and the possibility to initiate or to intervene in court proceedings dealing with anti-discrimination issues (Article 27 par 3, on this aspect see also par 39 infra). As already mentioned in par 19 supra, the Human Rights Protector has been designated as the anti-discrimination and equality body under Article 21 of the Anti-Discrimination Law (and proposed draft amendments) and it is important that Article 2 of the Human Rights Protector Law clearly states this additional competence of the Protector, with an express reference to the Law on Prohibition of Discrimination. This will help ensure consistency between the Human Rights Protector Law and the Draft Amendments to the AntiDiscrimination Law. 38. According to the EU Equality Directives, anti-discrimination and equality bodies mainly focus on the promotion of equal treatment, but also on the analysis, monitoring and support of equal treatment, and should provide independent assistance to alleged victims of discrimination, conduct independent surveys concerning discrimination and issue public independent reports and recommendations on discrimination issues.42 It is recommended to supplement, as appropriate, the general competences listed under Chapter III of the Human Rights Protector Law to expressly mention such roles and competences. 42 While EU Racial Equality Directive focuses only on the promotion of equality, the EU Gender Equality Directives also include analysis, monitoring and support of equal treatment in the competences of the equality bodies. 15