In drafting a corporate compliance policy, one concern is the extent to which a corporation’s policy will be assumed to set a legal standard for corporate conduct. In Hitesman v. Bridgeway, Inc., 93 A.3d 306 (N.J. 2014), the plaintiff was a nurse employed by a nursing home. He was terminated after raising concerns internally, to regulatory agencies and to the media about infection control at the facility. He filed suit under New Jersey’s Conscientious Employee Protection Act, which bars retaliation against a health professional who reports on activity reasonably believed to constitute “improper quality of patient care” or to be “incompatible with a clear mandate of public policy concerning the public health.” N.J.S.A. 34:19-3. Plaintiff prevailed after a jury trial, but the appellate court reversed, and the New Jersey Supreme Court affirmed the reversal. Under either prong of the statute, plaintiff needed to identify a source of law or other authority constituting an expression of public policy that set a governing standard for the employer’s conduct about which the plaintiff had complained. Among other things, plaintiff relied on the employer’s Employee Handbook Code of Conduct and on the employer’s Statement of Resident Rights. Neither document, however, had any governing standard regarding infection control, and plaintiff thus failed to establish a source of public policy to support his claim. The court did not, however, expressly consider whether an employer’s internal codes could constitute expressions of public policy that could support the plaintiff’s claim; rather, it implicitly assumed the answer to that question to be yes, and instead examined whether the contents of those codes matched up with the conduct to which the plaintiff objected resulting in his termination.