CAT/OP/NLD/1/Add.1 memorandum on the approval of the OPCAT (Parliamentary Papers 31797 (R 1871), nr. 1/A). B. Comments and recommendations — visibility and collaboration 11. The Subcommittee notes in its report that the Dutch NPM focuses on monitoring places of detention and that its other functions such as advocacy, capacity building, commenting on legislation and awareness-raising are underdeveloped. It also states that the NPM is largely invisible and, with the exception of the NPM Annual Report, publishes no documents. According to the Subcommittee, the collaboration between the NPM’s members depends on their readiness and availability to work together. The Subcommittee therefore recommends articulating a unified vision of how to prevent inhuman or degrading treatment or punishment, 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. The Netherlands should also clarify the status of the NPM-associated observers and consider giving them a more prominent role in relation to the NPM. Furthermore, the visibility of the Dutch NPM should be raised by coordinating public awareness campaigns, producing materials in various languages for detention personnel, detainees and civil society, and by informing the organisations concerned. 12. The Government endorses the Subcommittee’s finding that there is further scope for improving collaboration within the NPM and that — in addition to monitoring places of detention — the NPM could put greater emphasis on preventing inhuman or degrading treatment or punishment by providing information and organising public awareness campaigns. The Government has already described above how the Netherlands wishes to shape collaboration within the NPM in the future. The Government trusts that the changes being made will further clarify the roles of the participating organisations and any collaboration between them. 13. It should also be noted that the NPM system is becoming embedded in the fabric of society. As far as visibility is concerned, it is up to the NPM members, as independent institutions, to develop their own vision on this. The Government has called on them to do so. Involving civil society actors (such as the National Ombudsman and the Netherlands Institute for Human Rights) and external stakeholders is a matter for the NPM members. In the Government’s opinion, the new structure provides sufficient scope for this. The NPM Annual Report is submitted to the House of Representatives of the States General each year. It is then up to the House to decide whether substantive debates should be held on the investigations and recommendations contained in that report. C. Comments and recommendation — independence 14. The Subcommittee states in its report that the independence of the various NPM members is inadequately guaranteed. It therefore recommends creating a separate mandate for the NPM. According to the Subcommittee, legislation is also necessary for this purpose. 15. All NPM members and observers are independent in functional and operational terms. For example, the national inspectorates have the scope, on the basis of their programme of work and their professional expertise, to gather information and form an opinion, report and advise on it. Similarly, the RSJ, in its capacity as an adviser, is completely independent of any organisation in the criminal justice system, and the supervisory committees in each branch operate independently of the Ministry of Security and Justice, the custodial institutions, the police and the Defence organisation. The Ministry of Security and Justice does not have any substantive input in the NPM Annual Report, 4