1.1 Visits to social care institutions (residential homes for the elderly) Complaint procedures The most common way residents and their loved ones make complaints is orally. If possible, homes solve these oral complaints as they come, and some are logged into a complaint book. Written complaints may be submitted to the home’s competent persons, registered into the complaint book, or placed in the complaint box which is found in the ward. Homes already have internal acts in place to process and resolve internal complaints. The procedures for external complaints and objections are usually recorded in house rules, in information which residents and their loved ones receive upon admission into the home, and in agreements on providing institutional health-care services which the resident or their legal representative concludes with the home. Especially regarding the installation of complaint boxes in secure wards we discovered varying practices among homes. In visiting some secure wards which the residents cannot leave by themselves, we discovered that access to complaint boxes was insufficient so as to enable residents to anonymously submit their complaints, compliments, or suggestions. The NPM accordingly recommends that complaint boxes be installed in those wards, regardless of the consideration that a majority of residents in these wards can no longer form written complaints. We recommended that such boxes be installed at the Bor HE, Jesenice RH, and at the Olmo Home. Bor HE replied that they had already installed one. Olmo Home similarly reported having installed a box, but on our visit we discovered that this was not the case. The complaint box at the Olmo Home was still only installed outside of the ward, thus inaccessible for residents of the secure ward. We also recommended that Škofja Loka Centre install a complaint box at the high-level supervision ward, as the access of residents from this ward to the complaint box can be, according to the NPM’s findings, limited. In its reply, Škofja Loka Centre stated that its complaint box is in the direct vicinity of the doors leading away from the ward, wherefore they are of the opinion that its location does not present any obstacles for residents or their guardians. Nonetheless, Škofja Loka Centre promised to study the spatial possibilities of installing a box in the ward itself. We recommended that the Hmelina Home slightly modify its complaint box, as they had been using for it a nicely decorated piece of fabric with a pocket sewn into it, where residents could submit their complaints. Since anyone could remove an already submitted complaint from this pocket and read it and, either on purpose of by accident, throw it away, as there were even empty forms in the pocket meant for residents to write their comments and complaints down, we recommended that the home make modifications so that only employees could access the content. They accepted the NPM’s recommendation, and rectified their procedure for submitting complaints accordingly. On our visits, we discovered that some homes ensure good traceability of the complaint resolution procedure, e.g. Trnovo CE. Meanwhile, the level of traceability in other homes was lower. We recommended, for example, that the Trebnje HE, which otherwise records all oral comments and complaints (which should be commended) and depending on their nature submits them to the appropriate individual service, improve the traceability of their complaint resolution procedure. It replied that as part of ISO standards, it adopted the organizational regulation Customer Complaint Resolution, which regulates complaint resolution in depth. This organizational regulation ensures the traceability of complaints. We made a similar recommendation to the Jesenice RH, which had a complaint box in place, but did not record when and how it handled a resident’s submission (complaint, compliment), what measures were adopted on its basis, and whether or not the resident was informed of the resolution. IMPLEMENTATION OF THE DUTIES AND POWERS OF THE NPM IN 2013 NATIONAL PREVENTIVE MECHANISM UNDER THE OPTIONAL PROTOCOL TO THE UN CONVENTION AGAINST TORTURE AND OTHER CRUEL, INHUMAN OR DEGRADING TREATMENT OR PUNISHMENT 39