"The policy defines bullying as a misuse of power that can make people feel vulnerable, upset, humiliated, undermined or threatened. It says harassment is unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating someone else’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them."

ICR were playing by the letter of the law - as they ought to - and sound properly contrite. There must have been a lot of substance.