IR & Politics

Comparative analysis of Human Resource Management in Turkey and some European Countries

Depending on the nature of the public services offered by the state to its citizens, the status of the personnel providing the service varies. There may be staff employed in market conditions (workers working under private law provisions, public company workers, etc.), as well as civil servants (teachers, police officers, religious officials, etc.) working in an area different from private sector employment which regulated by their own detailed rules. Therefore, the definition of “human resources in public” does not imply a singular, uniform and/or homogeneous structure. The differences in the status of those working in the public service are closely related to the political, social and economic conditions. While legal public employment based on job security is accepted under welfare state conditions, under open competition conditions based on the free market, it may be more preferable to employ public personnel according to the provisions of private law. In this case, as in other developed countries around the world it is also true example for Turkey. Referring briefly to the historical transformation of public employment in Turkey (1), it will become more apparent differentiation, which is described above.

The Civil Servants Law, enacted in 1926, can be described as the founding document of the public personnel regime. While determining the status of public personnel with institutional arrangements (Property, Foreign Affairs, education etc.) instead of general regulations during the Ottoman Empire, a general regulation was made for the first time with the Civil Servant Law and the framework of the civil service regime was drawn. In the new case, the civil service regime rises on a dual structure: civil servants employed under the status law and employees under the provisions of private law. This dual structure has not been able to meet the needs of the growing state over time, and with many different forms of employment (D-staff, R-staff, S-table staff, N-ruler staff, casual technical staff, contractors, etc.) has appeared.

In the 1950s, it is seen that the public personnel regime formed a multi-part structure with the spread of different forms of employment. Great differences have emerged among the employees not only in terms of employment styles but also in terms of personal rights (salary, social security, retirement, etc.). Growing problems have accelerated reform initiatives in this area. The reform reports prepared by foreign experts within the framework of international aid agreements have determined the direction of the reform efforts to be carried out. The Civil Servants Law (DMK) numbered 657, which came into force in 1965, is the product of the preparatory work for reforms that continued throughout the 1950s. The Law in question initially attempts to establish a public personnel regime based on the US-type classification system such that class regulations have been referenced in more than thirty locations. According to the law, hiring civil servants, rising positions, competitions and proficiency exams, economic and social rights will be arranged in detail in the regulations to be prepared for each class. Class regulations are also prepared by negotiating with hundreds of unions established with the opportunity provided by the Law on State Personnel Unions, which were put into effect almost simultaneously with the Civil Servants Law (DMK). Class preparations took five years, and during this time, the DMK could not be put into effect.

The 1980s, mainly by making itself felt for decades of a free-market economy in Turkey. With the influence of the new public management thought flow, it has been frequently mentioned that the employment of the staff working in public institutions decreases the effectiveness and decreases the quality of service in the provision of public services. In this climate of thought, similar to the trends in the world, the widespread adoption of private sector employment in conditions outside the legal status of the public sector in Turkey has gained weight of public opinion will make administration more efficient. After this process, which reflects the transition from status law to flexibility, a substantial transformation has occurred in the public personnel regime. The civil servants and Civil Servants Law, which constitute the most crowded group of this field comes to mind when it comes to public resources, human resources or public personnel regime. However, the area in question is wider to include academic and military personnel, contracted personnel, judges and prosecutors, and personnel in the status of the worker.

  1. General Situation in Turkey and Europe

Public debts increased, and resources decreased with the economic crises experienced at the global level since the 1970s, and the area of public services started to be discussed. Although the crises show local differences in the countries experienced, it is accepted that it is crucial to activating public administration. In addition to these developments, the concepts of localization, governance, e-government, transparency, flexibility, performance management, and state-citizen relations have come to the fore.

Civil Servants in the UK

Table 1. Public Personnel in the UK with Task Areas (2017) (2)

The distribution of the personnel is presented in the table above. As can be seen from the table, the vast majority of public personnel in England are in central government and local government institutions. The number of public servants working in local government is very high compared with Turkey. It is important to note that for the UK, civil service work in a dual structure in the form of civil servants and public employees.

Civil Servants in France

In terms of the status of civil servants in France it is comparable to Turkey. In terms of numerical distribution, central government officials and local government officials are close to each other. So, the share of public employees of local government officials is very high compared to Turkey. Analogously to Turkey, statutaire situation is a structure in question. The public personnel regime was regulated statistically with four separate laws, namely the General Civil Servants Law, the State Public Servants Law, the Local Government Officials Law and the Health Service Law.

Table 2. Public Personnel in France with Task Areas (2015)(3)

Civil Servants in Germany

Table 3. Public Personnel in Germany with Task Areas (2016) (4)

The civil servant regime in Germany shows many similarities with Turkey. In Germany, the principle of “civil service until death” applies. Those who are civil servants once cannot be easily removed from civil service. From the point of view of numerical distribution, it is seen that public employees work predominantly in states and local administrations. In Germany, public servants are employed in three different statuses: civil servants, contract staff and workers. Civil servants can work not only at the federal level but also at the state level. The duties and responsibilities, the rights and obligations of civil servants, have been organized with a special law, as in Turkey and France. Contracted staff work according to the provisions of private law.

  1. Public Personnel Reform Initiatives in Europe

In a summary report based on a research on public resources and trends in the European Union member countries, the following findings were made (5):

In Austria, public personnel reform has been accelerated along with the public administration reform. The basic approach is to reduce the state budget, reduce costs and significantly cut the number of public personnel. On the other hand, horizontal hierarchy has been preferred to the organizations that are based on classical vertical hierarchy, and delegation of power has been reformed from the centre to the local.

The Ministry responsible for public personnel reform in Belgium has prepared a reform strategy covering the years 2007-2011. The prepared reform strategy plan is built on three main objectives: citizens to be seen as customers; creating an accountable, efficient and result oriented public administration; to create an innovative, creative, open-minded, dynamic public personnel group.

There are public administration and public personnel reform efforts that have been carried out regularly in Finland since 2003. The main goal of the reform effort is to transfer the duties on Helsinki to local or regional government bodies as much as possible. Concretely, it is the transfer of 4000 to 8000 different jobs to local governments, which were carried out by the capital until 2015. The aim is to enrich local and regional manpower resources while employing fewer staff in the centre, thereby ensuring regional and balanced development.

The most important aim of public reforms carried out in France is to balance public employment. For this purpose, the principle of recruiting only one officer to replace both civil servants who will retire as of 2009 has been adopted, thus reducing the number of civil servants. Apart from this, the objectives of restructuring ministries to provide more effective services, strengthening regional governments and developing new public human resources strategy across the country have been determined. Another main objective is to develop the opportunity of “zero formality/bureaucracy-zero red tape” in the provision of public services.

There are several categories of public sector employees in Hungary, each governed by a specific law.

Law no. 1992 XXIII identifies the status of 105,000 civil servants. It determines working conditions, wages and progress and mobility conditions. Law no. 1992 XXXIII describes the state of public employees. Hungarian public sector employees have the right to pursue a career in public service and education and have a paid leave. Law no. VII of 1989 gives administrative staff the right to strike (except judicial bodies and police officers). Employees must abide by the principle of hierarchical obedience, are responsible in case of damage, and some employees must declare their interests. Recruitment conditions vary depending on the status of the employee. It is defined in the laws regulating the status of each group. In most cases, positions must be announced and recruiting must take place after a competition procedure. The recruitment system is decentralized, defines the needs of each ministry or department and selects its staff. A central competitive examination system for civil servants is implemented in 1 January 2009. Continuing education is provided by the State Administration and Human Resources Services Centre, which opened on January 1, 2007 and it offers training in many fields. The salary of public sector employees includes a basic salary calculated at the position of the civil servant and additional wages for some employees (central government, national assembly, constitutional court). The basic salary level is determined by the parliament every year, following negotiations with management and union representatives. This level cannot be lower than the previous year. Moving to a different level depends on seniority and merit. If the officers meet the conditions determined by their superiors, it is possible to pass the exam to a higher class as required by law and when deemed appropriate. Hungarian senior civil servants are subject to special provisions on salaries and leaves. They must also declare all property rights. Senior civil servants have had to take special training courses since 2006. Disciplinary action is imposed if he refuses to continue. Some senior civil servants do not have the right to strike.

  1. Conclusion and General Evaluation

About 3.5 million civil servants serve in Turkey and civil servants make up the majority of this staff. From civil servants hiring, candidates, salary, leave, social rights, discipline, etc. issues are regulated in detail by Law No. 657. The Law was prepared in 1965, taking into account the public employment conditions of that period and put into effect. Today, although there have been important changes in the fulfilment of public office, in Turkey and in the world, there has not been a substantial change in public employment conditions.

The most important feature that distinguishes civil service from other forms of employment is that its status is regulated by a special law and is a form of employment that provides “job security” with broad social rights (especially the right to leave). Job security means that the officer behaves impartially and respects the public interest in performing his duties; to ensure that it is closed to political or private external influences. Job security or broad social rights in the execution of public office should positively affect the work motivation of the officer and should not lead to a decrease in work efficiency. The balance between secured and statutory employment and productivity in civil service needs to be established very well.

The most important tool for effective management of manpower in the public sector is the use of a functional evaluation system. After removal of the registration system in Turkey in 2011, a new evaluation system has not been established. It is inevitable to develop an evaluation system in line with the changing public administration and public personnel management approach, which measures not only individual competencies but also the way the officer performs his/her duty.

Turkey is undergoing a rapid process of transformation and change. Within the framework of the 2023 targets, the entire form of public administration and government will be reshaped, and in this framework, no change in the public personnel regime is unthinkable. The new public personnel regime should be regulated with an understanding that will make the Presidential Government System work most effectively. A system should be established to allow rapid decision making in new human resources management. Mechanisms should be developed to enable managers to take more initiative.

Turkey has a very important geopolitical position. It is a transition country in terms of energy and security. When viewed strategically, it is an example for countries seeking change with a stable state structure and strong public personnel in a geography where the fastest changes are experienced in the world. In order to maintain a strong and stable state structure, the main target in the next fifteen years is directing change, dynamic, high mobility, flexible decision making, can be implemented immediately; it should be ensured that a public personnel order is established to allow effective and proactive bureaucracy in which the distance between managers and practitioners is shortened.


1)As for the historical transformation of the general public personnel regime in Turkey: : Hasan Şükrü Adal, Kamu Personel İdaresi, Ahmet Sait Matbaası, İstanbul,1968; Onur Ender Aslan, Kamu Personel Rejimi: Statü Hukukundan Esnekliğe, TODAİE Yayını, Ankara 2005; Tayfun Akgüner, Kamu Personel Yönetimi, Der Yayınları, İstanbul, 2001; Birgül Ayman Güler, Kamu Personeli Sistem ve Yönetim, İmge Kitabevi, Ankara, 2005; Süha Oğuz Albayrak, Kariyer Uzmanlık Sistemi, TODAİE Yayını, Ankara, 2016.


3)L’emploi dans la fonction publique au 31 décembre 2015(premiers résultats) En 2015, l’emploi dans la fonction publique se stabilise


5)Administration and the Civil Service in the EU 27 Member States (Ministère Du Budget, Des Comptes Publics Et De La Fonction Publique)


  • Administration and the Civil Service in the EU 27 Member States (Ministère Du Budget, Des Comptes Publics Et De La Fonction Publique)


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Erhan Aygün

Erhan Aygun is PhD candidate at National University of Public Service in Budapest. His main research fields concern on migration, public administration, security studies, international theories and political science. He studied international relations in his master at Pécs University and bachelor degree at Çağ University.
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