Part II: Tools for an effective follow-up and implementation discussions. There are however exceptions, such as the Green Paper on Detention, where the CPT was involved. As noted earlier in relation to NPMs, the expertise and the reports (where public) of the CPT, as well as the NPMs and SPT, could be useful for the EU to monitor the respect of fundamental rights at national level, especially within the implementation of EU law. Moreover, at the final conference of this Project it was suggested that the EU should consider taking CPT or NPM recommendations more into account when granting funds both to EU member states and third countries, e.g. the member states of the European Investment Fund. For example, as recently highlighted by the EU Court of Auditor in respect of Greece, citing a report by the CPT, the EU should avoid funding detention centres for migrants where detention conditions are said to be in violation of the ‘principle of respectful treatment and dignity’.242 Similarly, it would be important, if EU finances for example the construction of prisons in accession countries, that these at least do not contradict existing recommendations by torture monitoring bodies. 3. Publicity A strategic approach to communications, including not only the publishing of NPM reports but also public relations, is seen as a crucial element in the work of a NPM. Publicity also has a useful role in follow-up and promoting implementation, e.g. pressure on the authorities to comply can be exerted by the publication of visit and/or annual reports detailing information on progress made in the implementation of recommendations. The great majority of NPMs in the EU publish their annual reports and most also their visiting reports. Many also present annual reports or thematic reports in Parliament. These are sometimes followed up by press releases to better engage with the media. In order to allow for a more timely engagement with the media — not awaiting the often-lengthy process of finalisation of a report — some NPMs publish urgent recommendations or press releases directly after a visit. Beyond the publication of a report, a few NPMs also have the possibility to issue public warnings or appeals for non-implementation of recommendations. Overall, only very few NPMs have contacts with media beyond the dissemination of a report. Many are concerned as to the unfavourable public opinion towards criminal detainees and the risk of being misrepresented in the media or a media story damaging the reputation of the NPM as an objective and neutral actor for the protection of the rights of persons in detention. To mitigate these risks, some recommended conducting a stakeholder analysis and thus identifying journalists ‘friendly’ to the NPM and its topic as well as being proactive in public and media relations and dedicating specific resources for public relations work. Moreover it was also suggested that it would be useful to develop an NPM communication and public relations strategy with a specific focus on promoting the implementation of recommendations. There are several ways in which NPMs use publicity to follow-up their recommendations and promote their implementation. The most common one is the publication of and dissemination of annual and visit reports. While the publication and dissemination of the annual reports is an obligation for states parties under article 23 OPCAT, the SPT states that ‘[v]isit reports, including recommendations, should be published, if the NPM considers it appropriate to do so.’243 However, in any case the SPT recommends that NPMs should establish ‘a policy for publicising reports, or parts of reports including the main findings 242 243 See EU Court of Auditor ‘The External Borders Fund has fostered financial solidarity but requires better measurement of results and needs to provide further EU added value’ (Special report 2014) n 15, 33, where the Court criticised the support and subsequent funding (through the External Borders Fund) of a temporary detention centre for migrants in Greece. SPT, UN Doc CAT/OP/1, para 22. - 81 -