In a matter of days or hours, it’s likely we’ll finally learn the conclusions of a report into the conduct of one Dominic Raab.

The Prime Minister appointed Adam Tolley KC to investigate a number of formal complaints, reportedly alleging behaviour akin to ‘bullying’. Raab himself has apparently asserted he has behaved ‘professionally’ at all times, which perhaps calls into question whether indeed his actions and expectations of staff were indeed ‘bullying’ or were simply reflective of his ‘high standards’.

Therein lies one of the biggest issues for any employer or HR professional to consider – what exactly is deemed to be workplace bullying?

ACAS states that while there isn’t one precise legal definition of bullying, it can be described as unwanted behaviour from a person(s) which is:

  • Offensive, malicious, intimidating or insulting


  • An abuse or misuse of power that undermines, humiliates or causes physical or emotional harm

You should note that to be termed ‘bullying’ it isn’t necessary that the behaviour is a regular pattern. In fact, it can also be a one-off incident. It might be that the behaviour is in person, or that it is via social media or other online communication. It might happen in or at work, but also in other ‘work-related’ situations.

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Perhaps as important – if not more so – as understanding the definition of what might constitute workplace bullying, is knowing how your business can seek to prevent and tackle matters of bullying.

This is where the concept of ‘culture’ within your organisation becomes so important.

Time and again we have heard criticism that Raab and others have not been removed from their positions of responsibility at the outset of any enquiry or investigation. This in turn leads to questions being levied in the direction of the leadership.

If the right policies are in place (and employees are all aware of them), and the surrounding culture is clear and embedded, it is indeed less likely that matters perceived to be of a bullying nature would either arise or escalate.

As a leader, some of the tactics and cultural factors you might want to begin to explore, are:

  • Implementing a strong anti-bullying (or even ‘zero tolerance’) policy, which all existing staff are encouraged to observe and even to endorse
  • Raising the matter of your anti-bullying policies and expected practices at the point of onboarding new staff
  • Encouraging a 360 performance review structure which allows employer and employee to give valuable feedback on every aspect of their work experience
  • Having a robust procedural approach to any allegation of bullying, such that all staff know that any affected party will be heard and treated fairly
  • Utilising external expert help on matters pertaining to bullying, if you feel there is any danger at all, that the system of judgment might be undermined or compromised
  • Introducing training or occasional ‘learning opportunities’ with key speakers, who might share with your staff the importance of conducting ourselves well in the workplace, and being able to speak out on matters which feel akin to bullying
  • At every opportunity, ensure your staff feel able to speak up, that they know to whom they can refer concerns, and that they feel they are working within a culture which is inclusive and supportive.

It is to be remembered that in the event of anyone being found to have bullied in a workplace, or breached a code of conduct on matters of unfairness or harassment of any nature, it is not just how the business manager or HR lead deals with the particular incident.

It is more how the entire business and its culture is subsequently revised, reconsidered or assessed, in light of what has been learnt.

We wait now, to find what it is that the Downing Street culture will have cause to learn in the days and weeks ahead – and whether there is significant changes in the way its ‘workplace’ is perceived by the wider world.

If you’re looking to explore the creation of an anti-bullying policy, or you want to discuss an individual matter of concern, please do reach out to the MAD-HR team.