closed institutions). These institutions are not mentioned when enumerating the establishments which the Commissioner should be given an access to without hindrance and prior notification, etc. as specified in Article 12.2.1 of the Constitutional Law. It has therefore been suggested to amend the norm accordingly and make other necessary changes in line with the requirements of Article 20 of the OPCAT. As regards Article 20 subparagraph “f” of the OPCAT, it should be mentioned that the Commissioner establishes relationships and collaborates with various international organizations in line with the directions of her activity. The Commissioner has become a member of the European Ombudsman Institute, the International Ombudsman Institute, and the Asian Ombudsman Association and successfully functions within those institutions. The accreditation of the Commissioner with the highest “A” status has resulted in the expansion of international relations and entitled her to independently participate in the activities of the UN Human Rights Council and make recommendations, express her opinion in respect of reports prepared by the government for submitting to the UN treaty bodies, prepare parallel reports and monitor the implementation of treaties. Taking into consideration the importance of the organization of collaboration with international organizations in the field of torture prevention, as well as experience sharing with the NPMs of foreign countries at a high level, it is planned to entrust this work to the department to be established in the Office. Notwithstanding the above mentioned, it should be noted that the Constitutional Law does not contain any provisions requiring the Commissioner to establish international relationships, which makes it necessary to amend the law accordingly, so the relevant proposal has been submitted. Article 21 of the OPCAT specifies: 1. No authority or official shall order, apply, permit or tolerate any sanction against any person or organization for having communicated to the NPM any information, whether true or 25

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