CAT/OP/PAN/1 Nations Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules). The Subcommittee is concerned that access to means of making complaints to prison authorities, judicial officials, the Ombudsman’s Office or other authorities is not ensured. In any case, it observed that persons deprived of their liberty fear reprisals. 45. The Subcommittee urges the State party to ensure that all persons deprived of their liberty have the opportunity to make requests or complaints to the prison superintendent or the prison staff member authorized to represent him or her. The State party should also ensure that persons deprived of their liberty are able to speak freely and in full confidentiality and that they are not punished or otherwise prejudiced for having submitted a complaint or provided information. Shortage of sentence enforcement judges 46. The Subcommittee was informed of the limited number of sentence enforcement judges (there are 28 nationwide, but in the first judicial district, which has the country’s largest prison population, there are only 8). There is a critical need for a State policy that strengthens the role of sentence enforcement judges as an additional mechanism for the prevention of torture. 47. The Subcommittee urges the State party to introduce a policy on increasing the number of sentence enforcement judges and to ensure that they receive the training they need in order to perform effectively. The Subcommittee recommends that sentence enforcement judges work proactively, maintaining direct contact with persons deprived of their liberty and ensuring that their rights are respected. 48. During its visit, the Subcommittee was invited to participate in a training course for judges, prosecutors and public defenders organized by the judicial authorities and noted with appreciation that the course included modules on the topic of torture. 49. The Subcommittee recommends the further development of current training programmes for judges, prosecutors and public defenders, including in connection with the Manual on the Effective Investigation and Documentation of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (Istanbul Protocol). Small footprint of the Ombudsman’s Office 50. The Subcommittee noted that the Ombudsman’s Office has a unit that should conduct regular prison visits, as it is responsible for monitoring the exercise of human rights by persons deprived of their liberty. The Subcommittee also noted, however, that the unit has only two staff members. This situation severely limits the unit’s ability to monitor detention centres, police stations and even holding facilities for migrants, and thus contributes to the invisibility of torture and ill-treatment. 51. The Subcommittee recommends that the Ombudsman’s Office increase its presence in detention centres throughout the country with a view to detecting cases of torture and ill-treatment. 52. The Subcommittee took note of an incident that occurred on 9 August in Nueva Joya Prison, which resulted in injuries to both prison staff and persons deprived of their liberty. It is surprised that, despite the seriousness of the incident, the Ombudsman’s Office has not commented on it. 53. The Subcommittee wishes to stress that the establishment of the national preventive mechanism as part of the Ombudsman’s Office does not supplant the ongoing work of the unit responsible for monitoring the exercise of human rights by persons deprived of their liberty. Both the Optional Protocol and the Subcommittee’s guidelines allow for the operation of two different structures that have different mandates and maintain a degree of independence. 54. The Subcommittee reiterates that, to increase the efficiency of the national preventive mechanism, it is important to ensure that all stakeholders, in particular the authorities and persons deprived of their liberty, are aware that the mechanism’s core mandate is to prevent torture. 8 GE.18-12640