ADAM Tolley KC conducted 66 interviews, including four with Dominic Raab over two and half days, during his five month investigation into alleged bullying by the Deputy PM.

Mr Tolley examined eight complaints in total - one about Mr Raab’s time as Brexit Secretary, one as Foreign Secretary, and the rest related to his first period as Justice Secretary. 

The Ministry of Justice complaints were in the form of a “group” complaint, which kickstarted the inquiry, and four additional ones. 

Mr Raab described his style to Mr Tolley as “inquisitorial, direct, impatient and fastidious”.

He typically worked from 730am to 10pm Monday to Thursday on ministerial work, including in the car between home and Westminster, then more at the weekend in his constituency.

Mr Tolley did not conclude Mr Raab was a bully, a shouter or a swearer, but he did find his behaviour towards civil servants could be abrasive, intimidating, aggressive, and insulting.

He also rejected some of Mr Raab’s denials and defences, preferring the evidence of others.

While the report says Mr Raab is intelligent ,driven and demands high standards from staff, it also paints him as someone who lacked empathy and self-awareness.

Once formal complaints were made in November, Mr Raab changed his conduct and was less abrasive, behaving in a way that could have avoided complaints being made.

Mr Raab was Secretary of State for Exiting the EU from July to November 2018

In relation to the complaint about this period, Mr Tolley concluded Mr Raab’s conduct “cannot be characterised as offensive, malicious or insulting”.  

However he went on: “It was experienced as intimidating, in the sense of excessively demanding. I could not make a finding as to whether it was in fact intimidating in this sense.

“There was no evidence to suggest any abuse or misuse of power.

“The DPM did not intend any adverse effect on others.  

“No-one drew to the DPM’s attention that his conduct was in any way problematic.  

“He did not know and could not reasonably have been aware of what is said to have been the impact of his conduct on certain individuals.”

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Mr Raab was later Foreign Secretary from July 2019 to September 2021.

The complaint about this period is about Mr Raab’s being dissatisfied with how civil servants had acted in relation to a particular project.

Mr Tolley found Mr Raab “made a legitimate management choice, on the basis of his genuine, adverse view about the work of others”.

In doing so “he acted in a way which was  intimidating, in the sense of unreasonably and persistently aggressive conduct in the context of a work meeting.  

“It also involved an abuse or misuse of power in a way that undermines or humiliates.  

“He introduced an unwarranted punitive  element.   

“His conduct was experienced as undermining or humiliating by the affected individual, which was inevitable.  

“It is to be inferred that the DPM was aware that this would be the effect of his conduct; at the very least, he should have been aware.”

Mr Raab also referred to the Civil Service Code in a way that suggested staff had broken it, having a “significant adverse effect on a particular individual who took it seriously”.

Mr Tolley said: “The DPM’s conduct was a form of intimidating behaviour, in the sense of conveying a threat of unspecified disciplinary action, and was experienced as such.  

“He did not target any individual, nor intend to threaten anyone with disciplinary action. 

“However, he ought to have realised that his reference to the Civil Service Code could well have been understood as a threat.”

Mr Tolley said the Foreign Office Permanent Secretary Sir Philip Barton told Mr Raab “in a private and informal meeting that he should not threaten officials with reference to the Civil Service Code”, but Mr Raab later “disputed any such conversation had occurred”. 

Mr Tolley said: “On this point, I prefer the evidence of Sir Philip. He had no reason to make up such a conversation with a view to protecting himself.”

Finally, the Ministry of Justice complaints relate to Mr Raab’s first time as Justice Secretary from September 2021 to September 2022.

Mr Tolley said the officials behind the initial group complaint “deserve credit for their courage in coming forward”, but the collaborative nature of the text meant it could not be used as the basis for any findings about Mr Raab’s conduct.

However Mr Tolley did find that in relation to other Ministry of Justice (MoJ) complaints Mr Raab acted on a number of occasions “in a manner which was intimidating, in the sense of going further than was necessary or appropriate in delivering critical  feedback, and also insulting, in the sense of making unconstructive critical comments about the quality of work done (whether or not as a matter of substance any criticism was justified).  

“By way of example, he complained about the absence of what he referred to as ‘basic information’ or ‘the basics’, about ‘obstructiveness’ on the part of officials whom he perceived to be resistant to his policies, and described some work as ‘utterly useless’ and ‘woeful’.”

Mr Tolley said Mr Raab did not intend to upset or humiliate, not target anyone.

His habit of interrupting people who were telling him what he already knew was not in itself intimidating or insulating, although multiple interruptions could be taken as criticism.

“The combination of unconstructive critical feedback and regular interruption is likely to be experienced as intimidating, in the sense of being unreasonably difficult to deal with, and plainly was so experienced by some individuals.”

Mr Raab was not aware of the impact of his behaviour on others, including on their health.

Mr Tolley said some of the MoJ complainers suffered “stress and anxiety, the taking of special unpaid leave, and in one case a period of stress-related sick leave”. 

However there was not enough evidence to conclude Mr Raab directly caused this. 

In March, July and October 2022, the MoJ Permanent Secretary Antonia Romeo drew Mr Raab’s attention to concerns about his tone and behaviour with civil servants.

“Ms Romeo produced notes of these conversations, which I was satisfied were derived from  her  contemporaneous  records.    

“The DPM sought to challenge the reliability of these notes on various grounds. 

“ I was not convinced by those challenges and did not consider that Ms Romeo would have had any reason to manufacture or manipulate the content of these notes.

“It is not suggested that Ms Romeo told the DPM that any complaints about him were well-founded or conveyed any specific allegation. 

“Nor is it suggested that the DPM was told that his conduct was or might amount to bullying. 

“The relevance… is that the DPM had been told on 9 March 2022, and reminded on 14 July 2022, that he should regulate his behaviour by not communicating frustration directly to individual  civil servants in the context of particular meetings.

"In addition, and in view of the DPM’s dispute as to whether these conversations occurred, I infer that he did not accept that there was any legitimate basis for such regulation of his behaviour.” 

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Mr Tolley said Mr Raab had not apologised over his conduct at the MoJ, as he did not accept he had done anything wrong.

But he had expressed regret for his impact on individuals.

Overall, Mr Tolley concluded Mr Raab’s behaviour at the MoJ was on occasion “abrasive, in the sense of a personal style which is and feels intimidating and insulting to the individual, but is not intended to be so”. Nor was it targeted at specific individuals.

Mr Raab had also been “able to regulate this level of ‘abrasiveness’ since the announcement of the investigation. He should have altered his approach earlier.

"Since the investigation was  announced, there has not been any valid ground for criticism of the DPM’s conduct.”