MEMORANDUM OPINION AND ORDER
Plaintiff Jonathon Myers brings this action against Alutiiq International Solutions, LLC (“Alutiiq”), a contractor with the U.S. Department of State, and two of its employees, Gregory Dodge and Eric Boyle, for wrongful termination, breach of implied contract, and promissory estoppel. He alleges that he was fired for engaging in whistleblowing activities. Defendants have moved to dismiss the complaint for failure to state a claim upon which relief can be granted. For the reasons stated below, the Court will grant defendants’ motion in part and deny it in part.
I. Background
Plaintiff alleges that he was hired in 2003 by George Bailey, the Contracting Officer’s Representative (“COR”) for the U.S. Department of State, under a government contract held by Anteon and General Dynamics. Compl. ¶ 14. In 2005, he was promoted to the position of on-site program manager for Anteon and General Dynamics at the Department of State, where he was responsible for managing all of the contract personnel who worked within his organization. Id. ¶ 17. That same year, Bailey directed plaintiff to hire an individual named Lori Strickland, and plaintiff complied despite his concerns about her qualifications. Id. ¶¶ 21-22. Although Strickland was supposed to be under plaintiffs supervision, and plaintiff observed that she did little substantive work, Bailey objected when plaintiff attempted to critique or manage her performance. Id. ¶ 22.
In March 2006, Bailey directed plaintiff to hire Strickland’s daughter, Erika. He told plaintiff that he was not interested in any other candidates for the position even though the standard practice was to interviеw several qualified applicants. Id. ¶ 23. The next year, Bailey also directed plaintiff to hire one of the Stricklands’ friends, and he again stated that he was not interested in any other candidates. Id. During that time, Bailey also recommended another friend of the Stricklands to fill yet another position. Id.
In early 2007, defendant Alutiiq won a contract with the Department of State and effectively took over the role previously performed by Anteon and General Dynamics. Id. ¶¶ 18, 24. Alutiiq retained all the employees in the contracts office, including plaintiff and his supervisors, defendants Dodge and Boyle. Id. ¶¶ 10-11, 18. Plaintiff alleges that when he began working for Alutiiq, “he received and reviewed an Employee Handbook and Code of Ethics and Business Conduct.” Id. ¶ 19. He also asserts that Dodge “instructed” him at that time about Alutiiq’s progressive discipline policy, which plaintiff was required to employ with his subordinates. Id. ¶ 19.
Plaintiff states that he began hearing complaints from other Alutiiq employees about Lori Strickland’s close personal relationship with Bailey. Id. ¶ 24. In April 2007, plaintiff counseled Strickland to refrain from involvement in a social relationship with Bailey to avoid violating government contracting regulations. Id. ¶25. In response to plaintiffs admonition of Strickland, Bailey removed her from plaintiffs direct supervision and placed her under his sole supervision, an action that plaintiff alleges was in violation of government contracting regulations. Id. ¶ 26. Plaintiff alleges that as a result of the close relationship, and at Bailey’s insistence, Lori Strickland received several unmеrited raises and promotions over plain *264 tiffs objections. Id. ¶¶ 28. Plaintiff notes that Strickland’s salary exceeded that of more qualified Alutiiq employees. Id.
Plaintiff repeatedly asked Dodge and Boyle to address the situation created by the inappropriate relationship between Bailey and Strickland. Id. ¶ 30. He asserts that they declined to do so because they did not want to anger Bailey and jeopardize Alutiiq’s government contract. Id. ¶ 31. Not satisfied with their response, in September 2009, plaintiff reported his concerns to Bailey’s supervisor, Martin Kraus. Id. ¶ 32.
After Kraus performed an informal investigation, he forwarded the information to the Department of State Office of Inspector General (“OIG”), which initiated a formal investigation in 2009. Id. ¶¶ 33-34. Plaintiff cooperated with the OIG investigation thrоugh multiple interviews and by providing e-mails to support his allegations. Id. ¶ 34. The OIG concluded that three out of four serious allegations against Bailey were well-founded and substantiated by evidence provided by plaintiff and by other evidence gathered during the investigation. Id. ¶ 35. Bailey was then removed as the COR on the contract at issue, and Lori Strickland was terminated — at OIG’s direction — on May 14, 2010. Id.
After the OIG completed its investigation, but before Lori Strickland was terminated, plaintiff directed a new receptionist, Louise Jefferson, to limit the amount of time she spent socializing with Lori and Erika Strickland at her desk. Id. ¶ 36. He told her that the government was paying close attention to the level of professionalism in the office, but did not mention anyone’s name or the OIG investigation. Id. Dodge then instruсted plaintiff to “drop” the issue with Jefferson. Id. ¶ 37. On May 12, 2012, Jefferson sent an e-mail to plaintiff, Dodge, Boyle, and Bailey complaining about “office politics” and the “hostile work environment” created by plaintiffs discussion with her about the socializing. Id. ¶¶ 37-38. According to plaintiff, “[h]is experience as a Program Manager, coupled with the tone and content of Ms. Jefferson’s e-mail, gave [plaintiff] the impression that she had been instructed to send this e-mail and include key terms such as ‘hostile workplace,’ a term which is often used as a precursor for administrative action.” Id. ¶ 38. Plaintiff responded to Jefferson’s e-mail, which he found to be an inaccurate characterization of the event, that afternoon. Id. ¶ 39. Dodge and Boyle then telephoned plaintiff and instructed him not to send further email correspondence about the matter. Id. Plaintiff alleges that he did not. Id.
On May 17, 2012 — the next business day after Lori Strickland was terminated — defendants Dodge and Boyle told plaintiff that he was being terminated from Alutiiq for insubordination. Id. ¶ 40.
On November 5, 2010, plaintiff filed his complaint in the Superior Court for the District of Columbia against Alutiiq, Dodge, and Boyle. Defendants removed the action to this Court on November 29, 2010, and then moved to dismiss the complaint for failure to state a claim under Fed.R.Civ.P. 12(b)(6).
In Count I, plaintiff alleges he was wrongfully terminated in retaliation for reporting wrongdoing by Bailey and Lori Strickland. Count II alleges a breach of an implied contract arising out the progressive discipline policy, which plaintiff claims was breached when he was summarily fired. Count III alleges promissory estoppel. 1 This claim is based on ai *265 lеged promises made by defendants that they would not retaliate against plaintiff for cooperating with the OIG investigation, and that a progressive discipline policy would be applied before any termination. Plaintiff alleges that he relied on this promise and did not seek another job before participating in the OIG investigation.
Plaintiff seeks compensatory and punitive damages, including back pay and future pay; costs and expenses; and equitable relief, consisting of the re-characterization of his departure as “resignation” instead of “termination,” and a favorable reference from Alutiiq. Compl. at 16.
II. Standard of Review
“To survive a [Rule 12(b)(6) ] motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.”
Ashcroft v. Iqbal,
A claim is facially plausible when the pleaded factual content “allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”
Id.
at 1949. “The plausibility standard is not akin to a ‘probability requirement,’ but it asks for more than a sheer possibility that a defendant has acted unlawfully.”
Id.
A pleading must offer more than “labels and conclusions” or a “formulaiс recitation of the elements of a cause of action,”
id.
at 1949, quoting
Twombly,
When considering a motion to dismiss under Rule 12(b)(6), the complaint is construed liberally in plaintiffs favor, and the Court should grant plaintiff “the benefit of all inferences that can be derived from the facts alleged.”
Kowal v. MCI Commc’ns Corp.,
III. Analysis
A. Count I: Wrongful Termination
i. Plaintiff states a claim against Alutiiq for wrongful termination
Defendants argue that because plaintiff was an at-will employee, his cause of action for wrongful termination fails because he *266 does not allege a sufficient public policy to sustain his claim. The Court disagrees.
“Under District of Columbia law, ‘employment is presumed to be at will, unless the contract of employment expressly provides otherwise.’ ”
Liberatore v. Melville Corp.,
The D.C. Court of Appeals expanded this public policy exception in
Carl v. Children’s Hospital,
The plaintiff in Carl claimed she was wrongfully discharged because she advocated for patients’ rights and against her employer’s intеrests before the Council of the District of Columbia and as an expert witness in court. The D.C. Court of Appeals read a provision of the D.C. Code that prohibits anyone from threatening any witness from testifying before the Council “as a declaration of policy by the Council seeking to ensure the availability of information essential to its legislative function by imposing criminal penalties on anyone who seeks to impede Council access to such information.” Id. at 165. The court concluded that there was an adequately “close fit” between that public policy and the plaintiffs termination because termination of employment is “the most severe and most effective” way for an employer to affect an employee’s testimony before the Council. Id.
Plaintiffs complaint raises the question of whether reporting wrongdoing in connection with government contracting falls within the public policy exception to an at-will employment relationship. 5 U.S.C. § 2302 reflects a clear public policy of encouraging government employees to come forward and report possible problems in federal programs, and there are many other whistleblower protection statutes that protect not only government employees, but private sector employees as well. See, e.g., 15 U.S.C. § 2087 (Consumer Product Safety Improvement Act); 18 *267 U.S.C. § 1514A (Sarbanes-Oxley Act); 29 U.S.C. § 660 (Occupational Safety & Health Act).
The Federal Acquisition Regulations (“FAR”) express a policy that contractors avoid or mitigate organizational conflicts of interests and state that “[e]ach individual contracting situation should be examined on the basis of its particular facts and the nature of the proposed contract.” 48 C.F.R. § 9.505. The FAR also prohibits personal conflicts of interest:
Government business shall be conducted in a manner above reproach and, except as authorized by statute or regulation, with complete impartiality and with preferential treatment for none. Transactions relating to the expenditure of public funds require the highest degree of public trust and an impeccable standard of conduct. The general rule is to avoid strictly any conflict of interest or even the appearance of a conflict of interest in Government-contractor relationships. While many Federal laws and regulations place restrictions on the actions of Government personnel, their official conduct must, in addition, be such that they would have no reluctance to make a full public disclosure of their actions.
48 C.F.R. § 3.101-1. The FAR further prohibit employers from “discharging], demoting] or otherwise discriminating] against an employee as a reprisal for disclosing information to ... an authorized official of an agency ... relating to a substantial violation of law related to a contract....” 48 C.F.R. § 3.903.
Plaintiff alleges that the close personal relationship between the COR, Bailey, and a government contractor, Lori Strickland, violated federal contracting regulations. Compl. ¶ 45. He further alleges that his employers knew that he reported those violations to his supervisors and to the OIG.
Id.
¶ 46. Finally, he alleges that he was fired immediately after the OIG concluded that most of his allegations were substantiated and that Bailey and Lori Strickland were subject to discipline.
Id.
¶ 47. Accepting plaintiffs allegations as true and resolving all inferences in his favor, as the Court must do at this juncture, plaintiff in this case has alleged sufficient facts to state a claim under the
Carl
public policy exception to the general rule against wrongful discharge claims by at-will employees.
See Ware v. Nicklin Assocs., Inc.,
Defendants argue that plaintiff “cannot and does not explain how COR Bailey’s alleged actions constituted a ‘substantial violation of law’ under these sections so as to make applicable FAR 3.903.” Defs.’ Reply at 3. But plaintiff is not required to establish here that his employers violated any particular provision of the FAR; the FAR provisions are relevant to this motion because they are illustrative of the strong public policy against conflicts of interest and favoring the protection of whistleblowers. In
Vreven,
the plaintiff had reported concerns to her supervisors that the defendant was evading taxes in violation of the Internal Revenue Code.
ii. Plaintiff states a claim for wrongful termination against the individual defendants
The individual defendants argue that they cannot be held liable as a matter law for a wrongful termination claim. Although the D.C. Court of Appeals has not addressed this question directly, a review of its opinions in the employment area suggests that it would not bar claims for wrongful discharge against individual employees if the facts established that the individuals acted improperly or illegally. Because the Court must draw all reasonable inferences in plaintiffs favor at this stage, it will allow the wrongful termination claim against the individual defendants to proceed.
Defendants cite decisions of other states holding that individual supervisors cannot be held liable for wrongful termination. Defs.’ Mem. at 11.
4
While it is true that some states prohibit wrongful termination suits against individual supervisors, it is equally true that several states allow such claims.
See Physio GP, Inc. v. Naifeh,
On the other hand, the states that do not allow wrongful termination claims against individual supervisors explain that “the employment relationship is the source of the duty in wrongful discharge torts.”
Physio,
The Court finds the reasoning of the states that have allowed claims against individual employees to be more consistent *269 with the law of the District of Columbia. Although the D.C. Court of Appeals has not directly ruled on this issue in the context of a wrongful discharge action, it has recognized that there may be some circumstances where an individual supervisory employee can be liable for tortious interference with another employee’s contractual relations with the employer.
In
Sorrells v. Garfinckel’s, Brooks Bros., Miller & Rhoads, Inc.,
This holding is consistent with the approach that another court in this district took in
Bowie v. Gonzales,
*270 Whether Dodge and Boyle could be found to be individually liable under D.C. law — that is, whether this case is more like Sorrells than like Press — may also turn on the nature of their employment at Alutiiq. The Sorrells opinion observed:
In Press the individual defendants were officers of the university, not just supervisory employees; ... [a]s officers acting within the scope of their official duties, they served as the alter ego of the university and had the power to bind the university. In the instant case, however, [the defendant] was not an officer of [the defendant employer]. She did not have the power to fire [the plaintiff]; only an officer ... could do that. “ ‘Employer,’ in the context of a corporation, is a ‘person who is realistically the alter ego of the corporation’ and not ‘merely a foreman, supervisor or manager.’ ”
For the purposes of the instant motion, accepting the facts as true and drawing all reasonable inferences in plaintiffs favor, the complaint alleges that defendants Dodge and Boyle were the driving force behind plaintiffs termination, and that their action was in retaliation for plaintiffs cooperation with the OIG investigation. Whether these defendants can ultimately be held liable for wrongful discharge will depend on the facts that are developed on the question of whether their conduct was improрer and, to some extent, what their position was at Alutiiq. At this stage, the Court simply concludes that plaintiff has stated a claim for wrongful termination against them. Therefore, the Court will deny defendants’ motion to dismiss Count I.
B. Count II: Breach of Implied Contract
Defendants argue that plaintiffs cause of action for breach of an implied contract should be dismissed because, as an at-will employee who can be terminated at any time, plaintiff cannot reasonably rely on any oral promise about how he would be disciplined. Because plaintiff has not alleged the existence of a written policy that conflicts with his at-will employment status, plaintiff has not stated a claim upon which relief can be granted.
“Under District of Columbia law, ‘employment is presumed to be at will, unless the contract оf employment expressly provides otherwise.’ ”
Liberatore v. Melville Corp.,
Here, plaintiff has alleged that he was verbally “instructed” about Alutiiq’s policy of progressive discipline, which he was required to apply to his subordinates. Compl. ¶ 19. This policy allegedly included requiring employees to receive verbal and written warnings before being terminated. Id. ¶ 54. He further alleges that these policies created an implied contract that plaintiff would not be terminated until certain preconditions are satisfied. Id. Alutiiq counters that plaintiff explicitly acknowledged the at-will nature of his employment by signing an acknowledgement form of the employee handbook. 7 Defs.’ Mem. at 12. It therefore argues that any oral representations about a progressive discipline policy are contrary to the at-will nature of his employment and cannot be enforced because “the two are mutually exclusive.” Id. at 13.
The Court finds that plaintiff has failed to state a claim for breach of an implied contract. Plaintiff received an employee handbook and signed an acknowledgement form that clearly describes the at-will nature of his employment at Alutiiq.
See
Mot. to Dismiss, Exs. A, B. It is true that “[n]ot in every case will a contractual disclaimer clause be adequate to relieve an employer of obligations
specified in its regulations.” Strass,
C. Count III: Promissory Estoppel
i. Plaintiff states a claim against Alutiiq for promissory estoppel
Defendants also argue that plaintiffs claim for promissory estoppel should be dismissed because he could not have reasonably relied on any assurances that he would be subject to progressive discipline when he was an at-will employee.
To establish a claim for promissory estoppel, plaintiff must show (1) a promise; (2) that the promise reasonably induced reliance on it; and (3) that the promisee relied on the promise to his or her detriment.
Simard v. Resolution Trust Corp.,
Here, plaintiff premises his claim on the violation of two promises: (1) that Alutiiq employees would be subject to a progressive discipline policy whereby employees would not be terminated summarily for minor infractions, Compl. ¶¶ 19, 59, 61; and (2) that he would not be terminated for reporting alleged violations of conflict of interest rules and cooperating with the OIG investigation. Id. ¶ 60.
With respect to the first promise, plaintiff does nоt allege he was promised that
he
would be subject to progressive discipline. Plaintiff merely alleges that he was told by Dodge to apply a progressive discipline policy to his subordinates. Compl. ¶ 19 (“Mr. Dodge also instructed Mr. Myers at this time about Alutiiq’s policy of progressive discipline that Mr. Myers was required to employ with his subordinates.”). These allegations cannot support a cause of action for promissory estoppel because there is no allegation of a definite promise made to plaintiff. Because it is unreasonable to rely on an indefinite promise,
Parnigoni,
Plaintiff also alleges that defendants explicitly promised that plaintiff would not be subject to adverse employment actions for his cooperation in the OIG investigation. Compl. ¶ 60 (“Defendants promised Mr. Myers on numerous occasions in person and over the phone that he would not be subject to any adverse employment actions as a result of his cooperation in the investigation.”). He further alleges that Dodge stated that plaintiff “would have to be crazy” to think he would be subject to any action as a result of his cooperation.
Id.
The Court finds that in this instance, the complaint does allege the existence of a definite promise upon which plaintiff could reasonably rely.
See Mahony v. Universal Pediatric Svcs., Inc.,
ii. The individual defendants may be liable for promissory estoppel
Finally, the individual defendants, Boyle and Dodge, argue that they cannot be held liable as a matter of law for plaintiffs promissory estoppel claim. While the facts may ultimately establish that they are correct as a matter of law, the Court cannot dismiss the complaint on its face on those grounds.
There is no case law directly on point in the District of Columbia as to whether individual employees can be sued for promissory estoppel under these circumstances. But courts in other stаtes have held that a promissory estoppel claim cam not be brought against agents who were acting on behalf of their principal at the time the promise was made. In
Odyssey Travel Center, Inc. v. RO Cruises, Inc.,
In the Court’s view, the defendants’ motion thus raises a serious question as to whether the plaintiff has stated a claim for promissory estoppel against defendants Dodge and Boyle. The complaint doеs not specifically allege that the individual defendants were acting in any capacity other than as agents for Alutiiq when they promised plaintiff that he would not be terminated for cooperating with the OIG investigation.
See
Compl. ¶ 60 (“Mr. Boyle-specifically told Mr. Myers that Mr. Myers would ‘have to be crazy’ to think that he would be subject to any action as a result of his cooperation.”). Furthermore, promissory estoppel itself is a limited doc
*274
trine.
See Fed. Ins. Co. v. Thomas W. Perry, Inc.,
But as in the case of Count I, the facts that are developed concerning the terms and conditions of the individual supervisors’ employment and their relationship to Alutiiq will inform the application of the agency principles that underlie the defendants’ motion to dismiss. Resolving all inferences in favor of the plaintiff at this point, the Court will permit the claim to proceed, although it may be subject to a summary judgment motion at a later point in the proceedings.
Conclusion
For the reasons stated above, the Court grants defendants’ motion to dismiss in part and denies it in part. Accordingly, it is ORDERED that defendants’ motion to dismiss is denied with respect to Count I of plaintiffs complaint for wrongful termination against all defendants.
It is further ORDERED that Count II оf plaintiffs complaint, for breach of an implied contract, is dismissed without prejudice as against all defendants.
And it is further ORDERED that defendants’ motion to dismiss Count III, for promissory estoppel, is granted without prejudice to the extent that plaintiffs claims are based upon the alleged promise to utilize progressive discipline, but it is denied as to all defendants with respect to the alleged promise not to terminate plaintiff as a result of his cooperation with the investigation.
Notes
. In response to defendants’ motion, plaintiff withdrew his claim for breach of implied contract (Count II) against the individual defendants, Dodge and Boyle, but maintains that cause of action against Alutiiq. Pl.'s Opp. at 13 n. 2.
. As both parties agreed at the hearing held on May 12, 2011, the complaint refers to bоth the employee handbook and the acknowledgement form that plaintiff signed, so the Court may refer to those documents in assessing defendants’ Rule 12(b)(6) motion to dismiss. See Defs.' Mot. to Dismiss, Exs. A and B.
. “Relying on Carl v. Children's Hospital, courts have treated Judge Terry's concurring opinion as the relevant standard.” Vreven v. American Ass’n of Retired Persons, 604 F.Supp.2d 9, 14 n. 5 (D.D.C.2009) (internal citations omitted).
. Defendants also rely on
United States ex rel. Siewick v. Jamieson Sci. & Eng’g, Inc.,
. The seven factors described by the' court are:
(a) The nature of the actor’s conduct,
(b) the actor’s motive,
(c) the interests of the other with which the actor’s conduct interferes’
(d) the interests sought to be advanced by the actor,
(e) the social interests in protecting the freedom of action of the actor and the contractual interests of the оther,
(f) the proximity or remoteness of the actor’s conduct to the interference, and
(g) the relations between the parties.
. Plaintiff also points to other cases in which plaintiffs named individual supervisors as defendants in wrongful discharge claims.
See, e.g., Ware v. Nicklin Assocs., Inc.
. The acknowledgement form states, in pertinent part: '1 have entered into my employment relationship with Alutiiq, LLC voluntarily and acknowledge that there is no specified length of employment. Accordingly, either I or Alutiiq, LLC can terminate the relationship at will, with or without cause, at any time. No statement or promise by a supervisor, manager, or department head may be interpreted as a change in policy nor will it constitute an employment agreement with me.” Mot. to Dismiss, Ex. B (emphasis omitted). The employee handbook itself contains similar language. See Mot. to Dismiss, Ex. A at 7 ("Employment with ALUTIIQ, LLC is voluntarily entered into, and the employee is free to resign at will at any time, with or without cause. Similarly, ALUTIIQ, LLC may terminate the employment relationship at will at any time, with or without notice or cause.”) (emphasis omitted).