CAT/OP/NLD/1 25. The SPT has also notes the NPM’s primary focus on monitoring functions while other NPM functions, such as advocacy, awareness raising, commenting on legislation and capacity building are underdeveloped. This may also result from the lack of specific NPM legislation providing the NPM with such authority and with the corresponding human resources for carrying out outward-facing NPM functions, in addition to the visiting mandate. 26. While the institutional format of the NPM is left to the State Party’s discretion, it is imperative that the State party enact NPM legislation which guarantees an NPM in full compliance with OPCAT and the NPM Guidelines. Indeed, the SPT deems the adoption of a separate NPM law as a crucial step to guaranteeing this compliance, though the enactment of such legislation will be beneficial only after the articulation of a vision for the prevention of torture and identification of the appropriate NPM model for the Netherlands. 27. The SPT wishes to emphasize the importance that the NPM be granted, by means of this legislation, core NPM functions, including the power to regularly examine the treatment of persons deprived of their liberty in all places of detention, as defined in Article 4 of the OPCAT, to issue recommendations to the relevant authorities, and to submit proposals and observations on existing and draft legislation. The NPM’s legal framework should also require a separate budget line in the State budget for the funding of the NPM, in order to ensure its continuous financial and operational autonomy. Moreover, it should outline privileges and immunities of NPM members and those who contribute to the NPM, including experts and civil society, while guaranteeing protection for persons who provide information to the NPM. Visibility and cooperation 28. The Subcommittee has observed that the inspectorates within the NPM are well regarded and influential when providing recommendations to their respective ministries. In discussions with the SPT, the authorities confirmed that the work of the inspectorates is appreciated. The SPT also notes that the inspectorates utilize established visiting protocols and have the trust of the authorities that they are carrying out quality inspections. Moreover, the community-based approach of the Commissions of Oversight and the committees they represent are valuable additions to the NPM network, as is the counsel provided by the RSJ. 29. However, the Subcommittee notes that the NPM on the whole is largely invisible. Without a separate legislative mandate, specified NPM tasks, specially allocated resources and systematic cooperation with other national and international stakeholders, it is difficult to perceive the NPM as its own entity. 30. At the time of its visit, the Subcommittee observed that the NPM did not produce documents — other than the NPM Annual Report — under the auspices of the NPM itself. Personnel of institutions in the NPM identify themselves by their respective institutional affiliations and continue to carry out the work they conducted before institutional appointment to the NPM. Moreover, the SPT has received feedback that the authorities do not proactively discuss NPM reports. As a result, the NPM is not well known by government stakeholders, civil society and the public. 31. Moreover, while the inspectorates conduct joint visits and collaborate in reporting on incidents, such as deaths in custody, the Subcommittee has observed that additional interaction and cooperation between different NPM institutions — and between NPM members and associates — depends largely on the readiness and availability of these institutions to work together. The SPT notes that not all components of the NPM participate equally in the activities of the NPM. Observers to the NPM do not participate in visits, for 6