iii. The absence of an independent, effective and accessible complaints mechanism with powers to receive, investigate and take appropriate action on allegations of torture or ill-treatment; and iv. The non-establishment of the centres for victims of human trafficking, stipulated under the Anti-Human Trafficking Act. Police, prisons and conditions of detention 43. The Commission is concerned about: i. The lack of an independent institution mandated to conduct unannounced visits to prisons and other places of detention; ii. The absence of an independent police oversight mechanism; and iii. The lack of facilities to cater for prisoners with disabilities. Access to and administration of justice 44. The Commission is concerned about the absence of institutionalized training conducted for judges and judicial officers. Freedom of expression and access to information 45. The Commission is concerned about: i. The provisions of the Cybercrime and Related Crimes Act, which may impose restrictions on freedom of expression; ii. The provisions in Sections 90, 91, 93 and 192 to 199 of the Penal Code covering ‘insult’ laws and criminal defamation, which can have the effect of curtailing the right of freedom of expression; iii. The absence of provisions on Community broadcasting in the Botswana Communication Regulatory Authority Act; iv. The absence of provisions regulating the State broadcaster in the Botswana Communication Regulatory Authority Act; and v. The delay in enacting legislation on the right of access to information. Freedom of association and assembly 46. The Commission is concerned about the absence of specific legislation or policy to ensure promotion and protection of the rights of Human Rights Defenders. The right to participate in the conduct of public affairs 47. The Commission is concerned about the absence of legislation or policy aimed at encouraging the political participation of women, persons with disabilities and ethnic minorities. 13