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From the Ministerial code:
1.2 Ministers should be professional in all their dealings
and treat all those with whom they come into contact with
consideration and respect. Working relationships,
including with civil servants, ministerial and parliamentary
colleagues and parliamentary staff should be proper and
appropriate. Harassing, bullying or other inappropriate or
discriminating behaviour wherever it takes place is not
consistent with the Ministerial Code and will not be
tolerated.
From The Guardian:
Sir Alex Allan’s findings based on the cabinet office investigation concluded that Patel’s approach “amounted to behaviour that can be described as bullying” – noting instances of shouting and swearing – and that she had breached the ministerial code, although her actions may have been “unintentional”.
Doesn't seem particulartly subjective to me.... But I'm not a Tory trying to justify shouting and swearing at staff