CAT/OP/NLD/1 12. Moreover, the Subcommittee draws the State party’s attention to the Special Fund established in accordance with Article 26 of the OPCAT. Recommendations contained in Subcommittee visits reports that have been made public can form the basis of an application for funding of specific projects through the Fund. 1 13. In addition, in accordance with its mandate, as set forth in article 11 (b), subparagraphs (ii) and (iii), the SPT will address a separate confidential report to the NPM of the Netherlands. II. The national preventive mechanism 14. The Netherlands ratified the Optional Protocol on 28 September 2010. In December 2011, the Netherlands Ministry of Security and Justice formally designated, by letter, six established institutions as its NPM, including three national inspectorates: the Public Order and Safety Inspectorate (IOOV), the Health Care Inspectorate (IGZ), and the Inspectorate for Youth Care (IJZ), as well as the Supervisory Commission on Repatriation (CITT), the Council for the Administration of Criminal Justice and Protection of Juveniles (RSJ), and the Inspectorate for Implementation of Sanctions (ISt). 15. In January 2012, the Ist merged with the IOOV to create the Inspectorate of Security and Justice (IVenJ), which acts as NPM coordinator. In 2014, the tasks of the CITT also merged with those of the IVEnJ. There is now a network structure with four NPM members (IVenJ, IGZ, IJZ and RSJ) and several observer associates. 16. At the time of the NPM’s designation, four associate observers were appointed: the Commission of Oversight for Penitentiaries, the Commission of Oversight for Police Cells, the Commission of Oversight for Military Detention and the National Ombudsman. Each commission is an umbrella organization representing committees of citizens who monitor conditions and the treatment of persons deprived of liberty in specific places of detention around the country. The State party intended that these associates would complement the work of the NPM, ensuring wide coverage of places of detention. While not officially holding NPM status, these observers were given the mandate to participate in NPM meetings and to communicate concerns to the NPM. 17. However, the National Ombudsman, which is an independent body mandated to investigate allegations of wrongful government practices, withdrew from the NPM network in 2014. In a letter dated 24 September 2014, the Ombudsman identified three main concerns leading to this withdrawal: (1) the structure of the NPM network and the lack of cooperation among its constituent organizations, (2) the limited independence and initiative of the inspectorates from the national authorities with which they are associated, and (3) the NPM’s lack of vision.2 While it did not itself resign from the NPM network, the RSJ, an NPM member, also expressed concerns with respect to the autonomy and functioning of the NPM.3 Legal basis 18. Until now, there is no single legislative instrument which designates the NPM and regulates its activities. Rather, the inspectorates operate in reference to the Netherlands General Administrative Law Act, which provides the legal mandate for supervisory bodies, 1 2 3 4 See http://www.ohchr.org/EN/HRBodies/OPCAT/Pages/SpecialFund.aspx. Letter from National Ombudsman to Head of the Inspectorate of Security and Justice, 24 September 2014. Open letter to organisations involved in the Netherlands NPM, 10 November 2014.