OSCE ODIHR Comments on the draft Law on the Protector of Human Rights and Freedoms of Montenegro alleged victims of discrimination, conduct independent surveys concerning discrimination and public independent reports and recommendations on discrimination issues. 13. In addition to its role as a non-discrimination body, the Human Rights Protector is also responsible under Article 1 of the draft Law to take measures “to prevent torture and other forms of inhuman and degrading treatment and punishment”. This signifies that the Human Rights Protector is also a national preventive mechanism under the OPCAT. According to Part IV of the OPCAT, preventive mechanisms shall prevent torture at a domestic level. Minimum powers granted to national preventive mechanisms under Article 19 of the OPCAT include the regular examination of the treatment of persons deprived of their liberty in any places under state jurisdiction and control where persons are or may be deprived of their liberty, with a view to strengthening, if necessary, their protection against torture and other cruel, inhuman or degrading treatment or punishment. Article 19 of the OPCAT also provides national preventive mechanisms with the power to make recommendations to relevant authorities with the aim of improving treatment of persons deprived of their liberty, and to prevent torture and cruel, inhuman and degrading treatment or punishment, and also to submit proposals and observations concerning existing or draft legislation. 14. Under Article 20 of the OPCAT, States Parties to this Protocol undertake to provide national preventive mechanisms with access to information concerning the number of persons deprived of their liberty and their treatment and conditions of detention, as well as the number of places of detention and their location. State Parties are also obliged to provide access to all places of detention, their installations and facilities, and the opportunity for private interviews with persons deprived of their liberty without witnesses, either personally or with a translator if deemed necessary, as well as with any other person who the national preventive mechanism believes may supply relevant information. Further rights granted to national preventive mechanisms include the liberty to choose the places to visit and the persons to interview and the right to have contacts with the OPCAT Subcommittee on Prevention. Article 21 forbids any sanctions against persons or organizations for having communicated information to the national preventive mechanism. 15. The ensuing Comments will be based on certain principles expounded in the Paris Principles, international anti-discrimination instruments and relevant provisions of the OPCAT. Furthermore, they will be grounded on basic rule of law principles on legality, transparency and foreseeability of laws. 4.2. General Comments on the draft Law 16. Overall, the draft Law reflects international standards with regard to national human rights institutions. In particular the financial independence of the Human Rights Protector (Article 5 of the draft Law), the authorities’ obligation to support the Human Rights Protector (Article 43 of the draft Law), the Protector’s accountability towards the public (Article 50 of the draft Law) and the overall procedure for complaints before this body are positive features of the draft Law that strengthen the institution as such. 9