observed. A concrete measure that may usefully be taken in this context is to adopt a rule prohibiting the management and staf of establishments from recording the names of persons interviewed by the Committee. Moreover, places identifed as presenting a higher risk of intimidation or retaliatory action must be the subject of increased attention and more frequent independent monitoring. Where appropriate, the reassignment of members of staf to other duties or the transfer of potential victims of reprisals, with their consent, to other establishments where their safety would be better guaranteed, should also be considered. In addition, decisive action must be taken to ensure that all staf working in places of detention understand that any form of intimidation against a detained person with a view to preventing him or her from communicating, or any retaliatory action for having communicated with the CPT (or any other monitoring bodies active in preventing and combating torture) will be severely punished. The range of penalties at the disposal of the competent authorities should be as broad as possible. The introduction of specifc ofences in law might also be a useful tool. In this connection, the Committee noted with interest the adoption in France of a new law introducing specifc penalties (i.e. heavy fnes and imprisonment) for hampering the work of the NPM by using threats or other means (such as sanctioning a person on the sole ground of having entered into contact with the NPM or of having provided information to the latter) and monitoring confdential communications between detained persons and the NPM.6 In particular in countries where the phenomena of intimidation and reprisals have been recurrent, as demonstrated in the Committee’s reports, the adoption of similar legal provisions that are applicable both to the NPM and to international monitoring bodies (such as the CPT) should be considered. Finally, in order for penalties and other measures to have a strong deterrent efect, appropriate complaints procedures must be in place. The competent authorities must also be – and be seen to be – determined to carry out an efective investigation into every potential case of intimidation or reprisal against a detained person. Everything possible should be done, in the context of such investigations, to counter the risk of further intimidation and protect witnesses and “whistle-blowers”. 6. See Law No. 2014-528 of 26 May 2014 amending Law No. 2007-1545 of 30 October 2007 establishing the General Controller of Places of Deprivation of Liberty. The phenomena of intimidation and reprisals: a major challenge for the CPT’s work ► Page 23