CAT/OP/NLD/1 example, and have less of a role in the quarterly NPM meetings. In addition, the RSJ comments on draft legislation, but does not have a mandate to provide policy advice on all types of institutions. Meanwhile, divergent powers among the various institutions result in unequal access to information, such as medical records, further necessitating their close collaboration. As a result, the torture prevention mandate is of an irregular nature, lacking an overall strategy, systematized follow up and mutual cooperation. 32. The SPT also notes that several stakeholders, including civil society, have requested that a sustainable and more participatory approach inform the NPM structure. As it stands, the NPM does not actively involve civil society actors in its work and the NPM does not fully benefit from the expertise of other institutions sharing a human rights mandate, such as the Netherlands Institute for Human Rights and the National Ombudsman. 33. The SPT therefore deems it crucial that the State party first articulate a unified vision of its work of torture prevention, a vision that takes into account the best practices and other experiences accumulated by all national mechanisms that monitor human rights and places of detention. This mapping exercise should provide a roadmap for how all such stakeholders can contribute to the work of torture prevention in the country, together with the NPM. In addition, in consideration of the contribution they make, the State party should clarify the status of the associated observers and consider increasing their role in the NPM. 34. The SPT recommends that the State party ensure its NPM is recognised as a key component in the country’s system for prevention of torture and ill-treatment. In this regard, it is recommended that the NPM’s outward-facing role be increased, including its engagement with civil society and with institutions having related human rights mandates, such as the National Ombudsman and the Netherlands Institute for Human Rights. The SPT further recommends that the State Party take steps to assist the NPM in increasing its visibility, so that its mandate and work are well known to other national stakeholders and the general public. The State party may contribute to making the work of the NPM more visible by, for example, coordinating public awareness campaigns, producing and distributing materials on the mandate and activities of the NPM in various languages to detention personnel, detainees and civil society, and by informing associations of service users, lawyers and the judiciary on the mandate of the NPM. 35. The SPT further encourages the State party to introduce, together with the NPM, an institutional forum for the discussion and follow up to NPM reports, bearing in mind Article 23 of the Optional Protocol and paragraph 29 of the NPM Guidelines, both of which relate to the obligation of States parties to publish and widely disseminate NPM Annual Reports. Independence 36. The issue of independence, while a sensitive one, is a fundamental concern for the Subcommittee. The proximity of the inspectorates to the ministries, both in their establishment and their functioning, threatens the NPM’s credibility. For example, inspectorates are housed with their respective ministries and are connected to them financially, logistically and in terms of supervision. Work plans are proposed or approved by ministers, and visit reports are sent to ministers for review before being publicized. Moreover, limited public consultation on the establishment of the NPM has caused scepticism among civil society, with whom the NPM should smoothly collaborate. 37. Inspectorates which serve as members of the NPM have stated that they are able, in practice, to carry out their work without interference. Nevertheless, these accounts are overshadowed by the appearance of partiality, an appearance that is exacerbated by the lack 7

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