A nonprofit’s whistleblower policy first enacted after an at-will employee had begun his employment does not create a barrier to his termination, an appellate court in New York has held. According to the complaint, a business office supervisor and officer of a biological research institute complained to the CFO about a failure to timely file certain financial documents during a four month period in 2010. At the end of the period he was terminated on the ground that he repeatedly engaged in disrespectful and insubordinate conduct towards her in violation of the Institute’s Code of Conduct. The employee sued for breach of an implied employment contract in the whistleblower policy. A trial...