Who do civil servants talk to?

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Article 3.3 of the Bhutan Civil Service Rules and Regulations, would not have come out in the limelight at the rate it did in the last month, so much so that civil servants are reputedly unwilling to speak about anything not just to the media, but between friends, too. “A civil servant shall not criticise publicly the policies, programmes, and actions of the Royal Government and his own Agency...” section 3.2.7.2, says. 
Section 3.2.5.1 says a civil servant shall “openly communicate and provide feedback if what his superiors/ colleagues/ subordinates do or say is professionally or morally unacceptable; and iii. Provide forthright and impartial advice in a constructive manner that facilitates the achievement of Agency objectives.” In doing so a civil servant shall not “fear consequences for being honest and sincere in his duties..”
While these beautifully scripted clauses are there, there are hardly any platform in government agencies, where one lower ranking civil servant “can openly communicate and provide feedback if what his superiors/ colleagues/ subordinates do or say is professionally or morally unacceptable.” And there would be very few civil servants who would not fear consequences. In such a scenario, what can civil servants do? Who do they speak to when their superiors make a mistake? 
Though the dozens of meetings held could be one forum, a civil servant said that in the last three years of his service, there wasn’t even one meeting where the agenda was to discuss about “what is wrong in the agency?” “During meetings, seniors ask if we have any comments and if we point out mistakes and errors, we are either brushed aside or ‘marked,’” he said. When asked if there are any grievance cell or a feedback box, he said apart from surveys being done sometimes, there are no avenues to convey to those in charge of respective agencies, what is not right. “This could be the reasons why civil servants speak to people outside, which is dubbed ‘public.’ he said. 
Similarly, another civil servant said there are no ways to tell “their bosses that something is going wrong.” When asked about complaint box or grievance cells, she said no one would make use of it, unless anonymity is retained and ensured. “If we have to sign or write something, we will be caught. I would not say that I would be penalized, but the possibility of me being penalized indirectly or in different forms is there,” she said. “And even if one does not sign, leaders could go to the extent of checking whose handwritings those are,” she added. 
However, a senior civil servant said though there are no meetings as such to comment on each other, opportunities are provided during meetings to junior civil servants. “Most of the time there are no comments,” he said. When questioned if there are avenues provided to speak about a leader’s flaws, he said there are no “formal avenues.” “And I understand that most would not complain because of fear,” he said. 
Meanwhile, certain sections of the society say that the code which bars civil servants from criticizing publicly the policies, programmes, and actions of the Royal Government and agencies are ways to ensure that errors made, powers abused and others are kept “within the camp.” “Section 3.2.7.2, does not say a civil servant should not speak; it says that they cannot criticize, meaning they can blow the trumpets of the agencies and governments but refrain from saying anything bad,” Sonam Tashi, who is self-employed said. “If there are no formal mechanisms to lodge complaints against superiors or policies, the ground for corruption is laid,” he said, adding that if Section 3.2.7.2 of the BCSR is removed or modified, corruption cases will decline. “Only family members know what is happening in a house. I am definite corruption cases will decline as civil servants could speak about it publicly.” 
Meanwhile, civil servants are pinning their hopes on the reforms carried out. “The RCSC and selected excellent executives are engaged in the reform. We hope that apart from ‘managing out,’ merging and others, they come with measures that will fill in the vacuums like those mentioned above,” a civil servant said.