I'd like to say a bit more on that, if I may.
That is why we think third parties should be able to make complaints. We are witnesses to that culture, or the ongoing problems, whereas it may not always be in the client's best interest to report what happened because it could affect their claim. This is something that could help bring about culture change on a broader level.
It's also important to keep in mind that the client is a newcomer, someone who is vulnerable. They are seeking refugee protection, so they don't want a complaint to impact their claim. They have to find housing and social assistance. They have their family to worry about. From their standpoint, a complaint in relation to the conduct may be the least of their worries. Their lawyer, however, could pursue the matter and take on the additional burden that the client has no intention of dealing with. The lawyer could deal with the matter so as not to add to all the problems the client already has to overcome, not to mention the distress they suffer. The reason we are recommending these things is precisely to change the culture.