General Report of the CPT, 2011-2012 Types of NPMs and key requirements 31. From the observation of NPMs already operating within Europe, three main models can be identified: • Ombudsman/Ombudsman plus: in countries following this approach (e.g. Albania, Estonia, Georgia, Spain), the pre-existing functions of the Ombudsman institution are extended to encompass the NPM mandate. In certain countries (e.g. Republic of Moldova, Slovenia), the NPM mandate is carried out by the Ombudsman office together with civil society actors (NGOs). • Stand-alone single body model: that is the establishment of a specific body exclusively devoted to carrying out the NPM mandate. Examples of this approach are the mechanisms established in France, Liechtenstein and Switzerland. • Multi-body model: in certain countries (e.g., the Netherlands and the United Kingdom), several existing inspectorates and/or specialised independent institutions have been jointly designated as the NPM, with one institution having a coordinating role. 32. NPM structures inevitably reflect the specific characteristics of each country, which no doubt explains why they are often quite different in terms of organisational make-up, budgetary means, and even powers and competences. It is certainly not for the CPT to promote one particular model over another. 33. However, the Committee is attentive to whether a given mechanism, what­ ever its form, meets the key requirements as laid down in the OPCAT and subsequently elaborated upon by the SPT in its Guidelines on NPMs. Those requirements include the functional independence of the mechanism and of its personnel, adequate resources, experienced and diversified membership, as well as a mandate and powers which are in accordance with the OPCAT (Articles 19 and 20) and clearly set out in a constitutional or legislative text. It should be noted in this regard that the degree of interaction between the CPT and a given NPM will inevitably depend to a large extent on the Committee’s perception of that mechanism’s real level of independence. 34. When the CPT encounters situations in which the above-mentioned require­ ments do not appear to be met, it will raise the matter with the national author­ ities. For example, the Committee has commented in several visit reports on the apparent inadequacy of the resources placed at the disposal of the NPM in the country concerned. Similarly, in one report the CPT highlighted a specific case in which an NPM did not enjoy ready access to police holding facilities and/or custody registers (in clear contravention of Article 20 of the OPCAT), and made recommendations designed to avoid any repetition of such a situation. By acting in this way the CPT hopes to provide concrete support to NPMs, many of which are still at an early stage of their development and trying to make their mark. 16