CAT/OP/UKR/3 Subcommittee has been informed that, in some SIZOs, only submissions sent to the court are sealed whereas general complaints must be passed from guards on duty to the administration in open form, which again has the effect of deterring detainees from reporting concerns. 71. Moreover, the Subcommittee remains concerned about the multiplicity of roles exercised by public prosecutors, who are tasked both with conducting criminal investigations and prosecutions and with overseeing the legality and rights compliance of those same processes (see CAT/OP/UKR/1, paras. 25-27). That inherent conflict of interest may prevent the conduct of speedy and thorough investigations into claims of torture and ill-treatment. For example, during its visit the Subcommittee saw documentation from a case of alleged ill-treatment that had been summarily dismissed by a prosecutor’s office with no accompanying rationale given, which implies that no investigation had taken place. 72. The Subcommittee recommends that the State party guarantee the right to submit complaints, both in law and in practice (see CAT/OP/UKR/1, paras. 18-20). It also recommends that detainees be empowered to submit complaints directly and confidentially to administrators in places of detention, to higher-level authorities, as necessary, and to authorities with remedial powers. The Subcommittee encourages the State party to bolster its monitoring and complaints mechanisms by giving such mechanisms the power to grant effective remedies. 73. The State party is urged to protect complainants from reprisals and any other form of prejudice. 74. Finally, the Subcommittee reiterates its recommendation that the multiple roles of public prosecution be revised in order to enhance the independence and effectiveness of investigations into allegations of torture and ill-treatment (see CAT/OP/UKR/1, para. 55). B. Specific concerns Detainees accused of crimes in connection with the armed conflict in eastern Ukraine 75. During its visit, the Subcommittee was alarmed to discover that fundamental safeguards were not being applied to detainees accused of crimes in connection with the armed conflict in eastern Ukraine, who claimed, as a pattern, to have been deprived of liberty first in secret places of detention, where they were interrogated for up to several days before being transferred to State-recognized institutions. It was only after they were taken to State-recognized detention centres that their detention was registered, albeit under a misreported time of arrest. It is worrying that detainees were apparently held incommunicado and not afforded a medical examination nor given access to a lawyer at the onset of their detention, official or otherwise. 76. As mentioned above, the Subcommittee has received consistent allegations of torture and ill-treatment in this process (see para. 35). 77. The Subcommittee is further concerned about the fact that, according to article 176 (5) of the Criminal Code, custody is the only measure of restraint for those accused of crimes in connection with the conflict, given the restrictions placed on pretrial detainees and the tendency of their cases to last several months. With courts universally extending detention to the maximum legal limits and frequently postponing hearings, detainees accused of crimes in connection with the armed conflict in eastern Ukraine are held under a regime that greatly restricts occupational activities, outside contacts and access to fresh air for periods exceeding 18 months. 78. The Subcommittee recommends that the State party ensure that fundamental safeguards, including the right to a lawyer, notification of custody and contact with the outside world, are applicable to all detainees, regardless of the reason for or the place of detention. 79. Given the heightened risk of torture and ill-treatment in undisclosed places of detention, the Subcommittee recommends that the State party cease its use of such places. 13