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Discussion Papers

To spark debate and thinking on addressing issues confronting Bhutan's public service

An initiative of the Anti-Corruption Commission, the Royal Audit Authority, the Royal Civil Service Commission and the Transformation Office

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This discussion paper intends to define accountability in the public sector. Case studies from Estonia, Singapore and New Zealand are presented alongside relatable cases from Bhutan to illustrate how accountability is enforced in these countries, and to see if there are lessons for Bhutan. 


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"Accountability is the obligation or willingness to accept responsibility for one's actions"

Webster's Dictionary

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Accountability in the Public Sector

Accountability in the public sector is discussed in terms of the relationship between public service agencies as service providers and citizens as beneficiaries, with agencies being answerable for their actions and decisions. Because public agencies use public money and make decisions that impact the people, they must be held responsible for their actions.

Situating accountability under such a relationship however, does not mean that citizens are viewed simply as passive beneficiaries. In fact, in many countries, demand for greater accountability has led to a seismic shift away from “government knows best” to a more citizen-centric, citizen engagement approach.

Accountability enhances efficiency and productivity and fosters public trust. It is an important aspect of good governance. Accountability has tangible benefits for public servants themselves by empowering and incentivizing them to drive results, promoting ownership and providing greater clarity of roles and responsibilities. Generally, accountability systems are driven by public demand to account for the public resources used to meet defined expectations and targets. Oversight bodies for public grievances, audit and anti corruption are instituted at the national level to make public agencies accountable for their decisions and service delivery. At the agency level, feedback systems, performance management systems and monitoring practices including evaluation exercises are instituted to drive accountability.  

An effective accountability framework must be backed by a clear and measurable set of goals, expectations and standards for enforcement, along with incentives and penalties that are actually implemented. Accountability deficits in agencies because of lack of performance evidence, inactive interaction between agents and principal, and rewards/punishment not aligned to performance negatively influence agency performance.

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Three dimensions of accountability to consider

Performance Accountability
Compliance Accountability
Operational Accountability

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Case Studies




€3 million worth of vaccines held in the Estonian Health Board’s cold storage was damaged in late June 2021 because of the rise in temperature of the cold storage rooms. Investigations by a committee led by the State Secretary carried out in July 2021 concluded that design and construction flaws had led to the malfunctioning of the cold storage, which had been constructed between 2016-17.

The Director General of the Health Board, Mr. Ullar Lanno, submitted his resignation in September 2021 taking responsibility for the crisis.

While the deficits in the construction were already existent when Mr. Lanno took office in October 2020, the Health Minister stated that the current management’s fault was failing to identify the issues and taking corrective and preventive actions. The Minister also stated that Mr. Lanno will not receive his severance pay. 


Thimphu Thromde in partnership with KCR Private Limited undertook the construction of two multilevel car parks (MLCPs) in Thimphu, under Public-Private Partnership model starting in 2014. The construction was expected to be completed in 2017.

Construction did not progress as planned and completion was delayed until 2019, attributed to change in design and scope of work. The delay cost Thromde revenue losses of Nu.8.2 million, with applicable liquidated damages amounting close to Nu. 0.8 million (Kuensel story dated March 12, 2021). The Royal Audit Authority pointed out that there were performance lapses (Audit Report 2019, page 171).

The MLCP initiative did not feature in Thimphu Thromde’s APAs. There were no success indicators on the MLCP construction or revenue projection. Thromde was rated “very good” with APA ratings above 90% between 2016 and 2018. 

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​An investigation was carried out by the Corrupt Practices Investigation Bureau (CPIB) of Singapore on Mr. Norezwan Bin Em, who was at that time, a Senior Investigation Officer in the Employment Inspectorate of the Ministry of Manpower (MOM). The department focuses on illegal employment, illegal deployment and other violations of MOM’s foreign manpower regulations.

Norezwan had issued a Special Pass to a female Chinese national who was assisting MOM with an investigation. With the special pass, she was allowed to stay in Singapore legally. The CPIB's investigation, which started in November 2012 revealed that Norezwan had continued to contact her in his personal capacity and had obtained sexual favours from her on three occasions as an inducement for the extension of her stay.

The investigation was started based on information received on 8 November 2012. On 19 September 2013, Norezwan Bin Em was convicted for corruptly obtaining gratification in the form of sexual favours. He was sentenced to 8 months’ jail for corruption in October 2013, within a span of 11 months after the information was received. 


Bhutan’s former head of Chancery in Bangkok, Mr. Chenda Tobgay, was charged for misappropriation and embezzlement of public funds meant for treating Bhutanese patients in Bangkok. The mismanagement of funds surfaced in 2011 because of the accumulation of huge outstanding bills, amounting to Nu. 8.4 million, with some hospitals in Bangkok despite the funds having been released from Bhutan. The hospitals threatened the Embassy of Bhutan in Bangkok with legal action. The government had to pay Nu.18 million to avoid legal action.

It was reported that the head of chancery not only caused huge financial losses to the government but also tainted the country’s image.

The Ministry of Foreign Affairs forwarded the case to the Anti Corruption Commission (ACC) in November 2011. The investigation took four years and was forwarded to the Office of the Attorney General in March 2015.

In April 2021, ten years after the case first surfaced, Chenda Tobgay was sentenced by the Supreme Court to nine years in prison. The Supreme Court passed the verdict to uphold the decision of the High Court. 

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New Zealand

New Zealand's Office of the Auditor-General consults closely with its auditees as part of its quality control objective and measures its impact by the number of recommendations accepted.

Each of the auditees reviews the auditor's recommendations, clause by clause based on significance, for incorporation into their plan for improvement.

For instance, based on resource implications, the Ministry of Agriculture and Forestry reviewed and adopted 73% of the recommendations related to managing biosecurity risks associated with high-risk sea containers. Similarly, the Department of Conservation reviewed and adopted 5 out of 9 recommendations related to planning for and managing publicly owned land. The remaining recommendations were not adopted since resolving these did not require additional actions and the reasons were also discussed with the Office of the Auditor-General.

This practice was embedded into New Zealand's performance auditing in response to public demand for better performance and greater accountability. It is expected to address issues concerning inefficiencies in the public sector. 


As per the 2018 Annual Audit Report, the total unresolved irregularities increased from Nu.405 million in 2017 to Nu.604 million in 2018. The highest amount was reported with the MOAF at Nu.80 million, followed by the MOIC with Nu.53 million and the MoWHS with Nu.52 million.

The highest amount was on account of mismanagement such as under-utilization of structures of the Tibetan Mastiff Conservation project at Gasa and the non operational Chupathang lift irrigation scheme in Samtse, which had remained defunct for two planting seasons because of breakdown of the pumping system.

The highest irregularities in the MoAF were attributed to payment made without completion of nursery work, payment without execution of work for the creation of heritage forest, payment without supporting documents, and wasteful expenditure in the construction of market sheds. Shortfalls, lapses, and deficiencies on payment exceeding the actual work done due to non-recovery of advances from the running account bills and grant of inadmissible advances, outstanding advances, and payment made without adequate supporting documents were also identified.

The APA assessment report for FY 2018-19 for the MOAF, MOIC, and MOWHS were 97.4%, 98.8%, and 99.1%, respectively. 

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Accountability is important for public sector performance. It ensures responsibility, competency, and transparency in decision-making and service delivery processes. An effective accountability framework requires the swift enforcement of consequences, without fear or favour.

The case studies provide useful insights and lessons for Bhutan in enforcing accountability. For example, leadership in Estonia had to take responsibility for the failure to identify and put in place corrective actions. While the work was carried out under the tenure of the predecessor, the successor came under public pressure and took responsibility for his failure to take corrective measures during his one year in office. 

In the Singapore case study, the Corrupt Practices Investigation Bureau of Singapore had the perpetrator convicted of corruption within 11 months.

New Zealand’s Office of the Auditor-General put in place a system to incentivise the implementation of audit recommendations through strong collaboration with the auditees themselves. In addition, measuring their own impact by the number of recommendations accepted also created the right incentives for the auditors to work closely with the auditees. 

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The case studies provide insights and lessons for Bhutan in enforcing accountability.

An effective accountability framework requires the swift enforcement of consequences, without fear or favour.

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Corrupt Practices Investigation Bureau. (n.d.). Authority – You Will Lose It If You Abuse It. CPIB. 

Dolkar, D. (2021, June 26). MoWHS tops the list of ministries with highest fraud and corruption cases – Business Bhutan. Business Bhutan.  

Han, Y. (2019). The impact of accountability deficit on agency performance: performance-accountability regime. Public Management Review, 22(6), 927–948. 

Han, Y., & Hong, S. (2016). The Impact of Accountability on Organizational Performance in the U.S. Federal Government: The Moderating Role of Autonomy. Review of Public Personnel Administration, 39(1), 3–23. 

Manaf, N. A. A. (2010). The impact of performance audit: The New Zealand experience. Victoria University of Wellington.  

Royal Audit Authority. (2020, April). Annual Audit Report 2019. RAA.  

Wangchuk, R. (2015, March 6). Bangkok referral fund ball in OAG court. Kuensel Online. 

Wangmo, C. (2020, March 12). Thromde’s massive parking buildings underutilised. Kuensel Online. 

World Health Organization. (2015). WHO accountability framework. WHO. 

Wright, H. (2021, August 18). Health Board’s cold storage malfunction due to construction error. ERR. 

Zam, T. (2021, April 27). Supreme Court upholds High Court’s judgment sentencing former Head of Chancery of the Bhutanese Embassy in Bangkok to over nine years in prison. BBS. 

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