3.5 Considering the volume of transfer-related complaints received by the Committee, we concur with the JICS' assessment that the transfer processes appear to be irregularly applied. The 'punitive' and 'preventative' application of the process described in the report subverts rehabilitation and reintegration efforts, and those responsible should be held to account. The Committee supports the JICS recommendation that the policies governing transfers, particularly those related to the turnaround time for the consideration of such requests, should be strictly adhered to.