CAT/OP/UKR/3 networks that have enabled the mechanism to increase its capacity, the Subcommittee is concerned that the mechanism’s autonomy may be compromised if it must rely on international donors in order to be fully functioning. 17. The Subcommittee notes approvingly that the national preventive mechanism has conducted hundreds of visits to places of detention, many of them unannounced. In addition, the Subcommittee notes that the mechanism has a strong relationship with civil society, regularly involving civil society actors in its visits and consultations, as well as in its core structure. Nevertheless, the Subcommittee is concerned that the mechanism is not able, in practice, to visit every place of deprivation of liberty given that it has limited access to State Security Service premises, where people may be held for investigative purposes. 18. The Subcommittee considers that the mechanism’s preventive activities could be strengthened. In particular, it notes that the mechanism suffers from not being perceived as an entity separate from the Ombudsman’s Office. The Subcommittee also notes that much of the mechanism’s work is in fact undertaken in response to individual complaints. Moreover, the Subcommittee understands that there is no established procedure through which the State will consider the implementation of the mechanism’s recommendations. 19. Recalling that article 18 (3) of the Optional Protocol obliges States parties to provide national preventive mechanisms with the resources necessary to undertake their work, the Subcommittee recommends that the national preventive mechanism of Ukraine be provided with a budget that is sufficient to enable it to accomplish all mandated tasks. The Subcommittee recommends that such funding be provided through a separate line in the national annual budget referring specifically to the national preventive mechanism (see CAT/C/57/4, annex, paras. 11-12). It also recommends that sufficient funds be allocated to allow the mechanism to carry out its visiting programme, to engage outside experts as and when appropriate, to increase its staffing and to regularly benefit from training, in accordance with its workplan. 20. In determining what constitutes a place of deprivation of liberty, the Subcommittee recommends that the State party adopt an approach that maximizes the preventive impact of the mechanism (see CAT/C/57/4, annex, paras. 1-3). In addition, the Subcommittee recommends that the State party ensure that the mechanism has the legal authority and practical capacity to access any place where it, the mechanism, believes that people are or may be deprived of their liberty, in accordance with article 4 of the Optional Protocol. 21. Furthermore, the Subcommittee recommends that the State party assist the mechanism in increasing its public profile so that its mandate and work are more widely recognized and known. This might include, for example, coordinating public awareness campaigns, distributing materials on the mandate and activities of the mechanism in various languages to detention personnel, detainees and civil society, and informing associations of service users, lawyers and the judiciary of the mechanism’s mandate. The Subcommittee also recommends that the State party establish an institutional means to systematically consider and discuss, with the mechanism, the implementation of the mechanism’s recommendations and annual report. III. Overarching issues A. Legal framework Positive developments 22. A number of positive legal developments have taken place in Ukraine since the Subcommittee’s 2011 visit. In particular, the revision of the Criminal Procedure that allows greater use of non-custodial measures during criminal proceedings has resulted in a noticeable reduction in the number of pretrial detainees (see CAT/OP/UKR/1, paras. 59-60, 65-66 and 97-98). This has reduced overcrowding and contributed to improving the provision of services. In addition, the 2011 Law on Free Civil Legal Aid has significantly improved the legal aid system in the State party (see CAT/OP/UKR/1, paras. 28-29), while 5