New Zealand Human Rights Commission Submission to the CAT in relation to NZ’s 6th periodic review 6. The Commission recommends that the Government commit to amending its BORA reporting process to require section 7 reports - in the modified form referred to above at paragraph 41 – on substantive SOPs. 7. The Commission recommends that:  the requirement set out in section 7.60 of the Cabinet Manual be more explicit in requiring identification of implications in relation to international human rights commitments and extended to apply to all policy and legislation (both primary and secondary); and  Ministers and officials be directed to strictly adhere to current and extended Cabinet Manual requirements. 8. The Commission urges the Committee to encourage New Zealand to continue to mainstream human rights by inter alia developing and implementing capacitybuilding programmes for parliamentarians and senior civil servants. 9. The Commission recommends that funding levels should be increased without delay to cover the actual costs of OPCAT work of NPMs, where the appropriation for OPCAT work is less than the actual costs of that work, and to enable NPMs to carry out more site visits and to establish a coordinated mechanism to engage the services of experts to assist with those visits. 10. The Commission urges the Government to prioritise reviewing the scope of the OPCAT mandate in New Zealand with a view to identifying ways to address the gaps in monitoring all places where people are deprived of their liberty. Any increase in scope would need to be properly funded. Violence 11. The Commission recommends that the Government commit through the Social Sector CEO Group – or another appropriate forum – to:  develop in consultation with civil society an agreed definition of sexual and family violence and appropriate minimum data set of indicators; and 76