main activity of the NPM is to carry out regular visits to such places, and as a result of the discussions held in the Office after the designation of the Commissioner as an NPM, the generalization of the proposals received from different governmental bodies, as well as international organizations, and the study and analysis of best practices in this field, it has been suggested that a special structural unit is established under the Office to organize the activity aimed at revealing, investigating and preventing torture. For this purpose, the regulations of the Torture Prevention Affairs Department of the Office, as well as its structure, the staff vacancies suggested to be added to the staff lists of the Office and regional centres, as well as the estimate of expenditures and action plan have been drafted and sent to the Cabinet of Ministers of the Republic of Azerbaijan, taking into account that the Cabinet of Ministers of the Republic of Azerbaijan has been entrusted by the country president’s known order for ensuring the implementation of the OPCAT to undertake necessary actions for the implementation of the OPCAT, and the Ministry of Finance of the Republic of Azerbaijan. It should be emphasized that in the context of the fact that the staff members of the Office do not possess relevant powers, the scope and importance of the NPM activity, and the conglomerate – number of the places of detention and their location in different parts of the country make it necessary that this activity is carried out by the National Preventive Group (NPG) that will be established by the Commissioner on the basis of transparent procedures and will include members to be selected among persons who will satisfy specific requirements. By including NGO representatives in the composition of the NPG it is possible to ensure the close participation of civil society in the work of the NPM. Though the guarantees for the independence of the Commissioner have been specified in the legislation, no special instructions have been provided for the independence of his/her staff. To the point, it should be mentioned that the staff members have to receive special permission to conduct a visit to this or other closed establishments. The employees of the Commissioner’s Office and regional centres are civil servants and their rights and duties, as well as guarantees are governed by the Law of the Republic of Azerbaijan “On Civil Service” and that law does not provide for any privileges or immunities. 19