CADY, Justice.

In this appeal, we must decide whether a former employee presented a prima facie cause of action for wrongful termination in violation of public policy. The action was premised on the dual claim that the employee was discharged because he did not support his employer’s decision to terminate another employee and the employer feared he intended to testify on behalf of the other employee in a potential lawsuit. We reverse the order entered by the district court granting summary judgment for the employer and remand the case for further proceedings.

I. Background Facts and Proceedings.

Tom Fitzgerald was employed by Sals-bury Chemical, Inc. at its production plant in Charles City. Salsbury manufactures chemicals and pharmaceutical bulk actives. Fitzgerald was employed as a production foreman at the plant.

Fitzgerald was terminated from his employment with Salsbury on September 19, 1995. The termination followed an incident on August 30, 1995, involving a production worker named Richard Koresh. Koresh failed to properly monitor the *279temperature and pressure of a tank used to mix a chemical compound. His conduct created a potentially dangerous condition.

Koresh was suspended from his employment on September 4,1995, after Salsbury conducted a preliminary investigation into the incident. He was ultimately terminated on September 19, 1995, a few hours prior to the time Fitzgerald was terminated. Fitzgerald was responsible for supervising Koresh on the date of the incident.

Salsbury asserted- Fitzgerald was terminated for failing to properly supervise Koresh and to prevent the potentially dangerous incident. Fitzgerald, however, believed he was discharged because he did not support Salsbury’s decision to discharge Koresh and Salsbury officials feared he would provide testimony in support of Koresh in the course of threatened legal action by Koresh.

The events supporting this claim extend back to August 15, 1995, when Koresh gave deposition testimony in a wrongful discharge action against Salsbury by a former employee named John Kelly. Kelly was terminated several years earlier, one day prior to his scheduled deposition in a wrongful death action against Salsbury by the estate of a former employee. The former employee died after a chemical compound he was mixing at the plant overheated and exploded. Salsbury claimed Kelly was terminated because his unsafe conduct caused the explosion. Kelly claimed he was terminated by Salsbury in an effort to cover up its culpability in the incident. During the deposition on August 15, 1995, Koresh contradicted earlier deposition testimony by two Salsbury management officials concerning the internal investigation of the work practices of Kelly. Koresh also testified he believed Kelly was a safe operator. Following the deposition, Koresh felt shunned by Salsbury management. He was also told by a foreman the company was going to find a way to fire him. After Koresh was suspended on September 4, 1995, he told a Salsbury official that he had hired an attorney and was not going to be another John Kelly.”

Fitzgerald engaged in a conversation with the plant operations manager on September 19, 1995, a few hours prior to the time he was told of his termination. The manager asked Fitzgerald what discipline he believed should result to Koresh because of the incident on August 30. Fitzgerald responded he did not believe it was fair to fire Koresh over a single mistake. Fitzgerald also indicated he did not believe Koresh should be fired in light of his long years of service to the company. The manager then informed Fitzgerald he needed to begin to think like a foreman if he was going to be one, and he needed to find out which side he was on. Fitzgerald was also informed the matter may result in a lawsuit. Fitzgerald does not claim he responded to the statements.

Fitzgerald instituted this wrongful discharge action against Salsbury. He alleged his termination violated a public policy of this state to protect workers who oppose the unlawful termination of a coworker. Additionally, he claimed he was terminated because he intended to provide testimony in Koresh’s future wrongful termination lawsuit that would be unfavorable to Salsbury and the company wanted to discredit his potential testimony as a disgruntled former employee. Fitzgerald claims Salsbury’s motivation to terminate him violated the public policy of this state to provide truthful testimony in court proceedings.

The trial court dismissed the action following a hearing on the motion for summary judgment. It found no public policy of this state was implicated by the two factual claims urged by Fitzgerald. Although the trial court found the criminal statutes against committing and suborning perjury established a public policy prohibiting such conduct, it found no facts to show the criminal statutes had been violated by Salsbury.

*280II. Scope of Review.

Our review of a summary judgment ruling is for corrections of errors of law. Iowa R.App. P. 4; Kennedy v. Zimmermann, 601 N.W.2d 61, 63 (Iowa 1999). Summary judgment is appropriate where there is no genuine issue of material fact and the moving party is entitled to judgment as a matter of law. Iowa R. Civ. P. 237(c). Summary judgment is properly granted where the only controversy is the legal effect of the undisputed facts. Krause v. Krause, 589 N.W.2d 721, 724 (Iowa 1999). When the facts are not in dispute, we will simply decide whether the district court correctly applied the law to the undisputed facts before us. Iowa Tel. Ass’n v. City of Hawarden, 589 N.W.2d 245, 250 (Iowa 1999).

III. The Employer-Employee Relationship.

A. Employment At-Will.

Absent a valid contract of employment, an employment relationship is generally considered to be inherently indefinite and presumed to be at-will. See Anderson v. Douglas & Lomason Co., 540 N.W.2d 277, 281 (Iowa 1995). This means the employment relationship is terminable by either party “at any time, for any reason, or no reason at all.” Phipps v. IASD Health Servs. Corp., 558 N.W.2d 198, 202 (Iowa 1997). The roots of the at-will employment doctrine are more than a century old. It is said to have originated in an 1877 treatise by Horace Gray Wood, which articulated the rule in clear and appealing terms:

With us, the rule is inflexible, that a general or indefinite hiring is, prima facie, a hiring at will, and if the servant seeks to make it out a yearly hiring, the burden is upon him to establish it by proof.... [I]t is an indefinite hiring and is determinable at the will of either party.

Horace G. Wood, A Treatise on the Law of Master & Servant § 134, at 272 (1877). Despite its direct contradiction to the traditional English rule, the at-will rule was judicially adopted in New York, see Martin v. New York Life Ins. Co., 148 N.Y. 117, 42 N.E. 416, 417 (1895), and quickly became the prevailing rule throughout the country.1 The United States Supreme Court gave the doctrine a boost in 1908 in Adair v. United States, when it found a federal law making it a crime to discharge an employee for being a member of a union violated due process guarantees of freedom of contract. Adair v. United States, 208 U.S. 161, 174-75, 28 S.Ct. 277, 280, 52 L.Ed. 436, 442 (1908) (“the right of the employee to quit the service of the employer, for whatever reason, is the same as the right of the employer, for whatever reason, to dispense with the services Of the employee”).

We too have long recognized that “indefinite employment may be abandoned at *281will by either party without incurring any liability.” Harrod v. Wineman, 146 Iowa 718, 719, 125 N.W. 812, 813 (1910). Yet, the passage of time has begun to weaken this once powerful rule. The at-will employment doctrine first began to give way in 1937 when the United States Supreme Court abandoned the Adair holding and upheld the National Labor Relations Act which made it an unfair labor practice for an employer to consider membership in a union as a basis for hiring an employee. NLRB v. Jones & Laughlin Steel Corp., 301 U.S. 1, 45-46, 57 S.Ct. 615, 628, 81 L.Ed. 893, 916 (1937). After this case, courts began to scrutinize the common law doctrine, and the erosion began. See Pennington, 68 Tul. L.Rev. at 1589-90. As one court put it,

[t]he at will presumption, the citadel that once governed the field with such predictability, has been eroded of late by piecemeal attacks on both the contract and tort fronts and the entire field seems precariously perched on the brink of change.

Scott v. Extracorporeal Inc., 376 Pa.Super. 90, 545 A.2d 334, 336 (1988) (quoting Martin v. Capital Cities Media, Inc., 354 Pa.Super. 199, 511 A.2d 830, 834 (1986)).

In recent years three exceptions to the at-will employment doctrine have surfaced to add employee protections to the employer/employee relationship. Generally, these exceptions fall into three categories: (1) discharges in violation of public policy, (2) discharges in violation of employee handbooks which constitute a unilateral contract, and (3) discharges in violation of a covenant of good faith and fair dealing. See Anderson, 540 N.W.2d at 282 (citing Stephen F. Befort, Employee Handbooks & the Legal Effect of Disclaimers, 13 Indus. Rel. L.J. 326, 333-34 (1991/1992)).

We have only adopted the first two recognized exceptions to the doctrine. See Abrisz v. Pulley Freight Lines, Inc., 270 N.W.2d 454, 455 (Iowa 1978) (we first recognized the possibility of public policy exception); Springer v. Weeks & Leo Co., 429 N.W.2d 558, 560 (Iowa 1988) (narrow public policy exception adopted); French v. Foods, Inc., 495 N.W.2d 768, 769-71 (Iowa 1993) (employee handbook may create unilateral contract). We have consistently refused to adopt a covenant of good faith and fair dealing with respect to at-will employment relationships. See Huegerich v. IBP, Inc., 547 N.W.2d 216, 220 (Iowa 1996). Thus, the traditional doctrine of termination “at any time, for any reason, or no reason at all,” Phipps, 558 N.W.2d at 202, is now more properly stated as permitting “termination at any time for any lawful reason.” Lockhart v. Cedar Rapids Community Sch. Dist., 577 N.W.2d 845, 846 (Iowa 1998).

B. The Public Policy Exception.

We have identified the elements of an action to recover damages for discharge in violation of public policy to require the employee to establish (1) engagement in a protected activity; (2) discharge; and (3) a causal connection between the conduct and the discharge. Teachout v. Forest City Community Sch. Dist., 584 N.W.2d 296, 299 (Iowa 1998).

These elements properly identify the tort of wrongful discharge when a protected activity has been recognized through the existence of an underlying public policy which is undermined when an employee is discharged from employment for engaging in the activity. See Tullis v. Merrill, 584 N.W.2d 236, 239 (Iowa 1998) (public policy in favor of permitting employees to make demand for wages due gives rise to an action for wrongful discharge for making a demand for wages); Teachout, 584 N.W.2d at 299 (public policy of this state in favor of reporting suspected child abuse gives rise to an action for wrongful discharge for reporting or intending to report child abuse); Lara v. Thomas, 512 N.W.2d 777, 782 (Iowa 1994) (public policy of this state in favor of permitting employees to seek unemployment compensation gives rise to an action for *282wrongful discharge for seeking partial unemployment benefits); Springer, 429 N.W.2d at 560 (public policy of this state in favor of permitting employees to seek workers’ compensation for work-related injuries gives rise to an action for wrongful discharge for asserting a right to workers’ compensation benefits). However, when we have not previously identified a particular public policy to support an action, the employee must first identify a clear public policy which would be adversely impacted if dismissal resulted from the conduct engaged in by the employee.2 See Yockey v. State, 540 N.W.2d 418, 420-21 (Iowa 1995) (the public policy in favor of permitting employees to seek workers’ compensation benefits not jeopardized by termination from employment for missing work following injury); Borschel v. City of Perry, 512 N.W.2d 565, 567 (Iowa 1994) (no public policy in favor of presumption of innocence in work place to give rise to an action for wrongful discharge for conduct which resulted in criminal charges); French, 495 N.W.2d at 771-72 (presumption of innocence not an actual public policy).

It is generally recognized that the existence of a public policy, as well as the issue whether that policy is undermined by a discharge from employment, presents questions of law for the court to resolve. 2 Henry H. Perritt, Jr., Employee Dismissal Law and Practice § 7.9, at 18 (4th ed.1998) [hereinafter Perritt]; Paul H. Tobias, Litigating Wrongful Discharge Claims § 5:22, at 69 (1995) [hereinafter Tobias]; Roberts v. Dudley, 140 Wash.2d 58, 993 P.2d 901, 905 (2000) (existence of public policy is a question of law). Thus, these questions are generally capable of resolution by a motion for summary judgment. On the other hand, the elements of causation and motive are factual in nature and generally more suitable for resolution by the finder of fact. Tobias § 5:22, at 69-70. Notwithstanding, to withstand summary judgment a plaintiff must not only satisfy the court on the public policy and jeopardy elements of the tort, but offer adequate evidence from which a lack of justification for termination can be inferred. Perrit § 7.9, at 18.

1. Determining Public Policy.

In first recognizing the public policy exception to the at-will employment doctrine, we were careful to limit the tort action for wrongful discharge to cases involving only a well-recognized and clear public policy. Springer, 429 N.W.2d at 560. This requirement has been incorporated in our subsequent cases. This important element sets the foundation for the tort and it is necessary to overcome the employer’s interest in operating its business in the manner it sees fit. Perrit § 7.10, at 19. It also helps ensure that employers have notice that them dismissal decisions will give rise to liability. Stevenson v. Superior Ct., 16 Cal.4th 880, 66 Cal.Rptr.2d 888, 941 P.2d 1157, 1161 (1997).

*283In determining whether a clear, well-recognized public policy exists for purposes of a cause of action, we have primarily looked to our statutes but have also indicated our Constitution to be an additional source. Borschel, 512 N.W.2d at 567. We have not been asked to extend our sources of public policy beyond our statutes and Constitution, but recognize other states have used additional sources such as judicial decisions and administrative rules. See generally Tobias § 5:05-:06, at 16-23.

Some statutes articulate public policy by specifically prohibiting employers from discharging employees for engaging in certain conduct or other circumstances.3 Yet, we do not limit the public policy exception to specific statutes which mandate protection for employees. Teachout, 584 N.W.2d at 300. Instead, we look to other statutes which not only define clear public policy but imply a prohibition against termination from employment to avoid undermining that policy. See Borschel, 512 N.W.2d at 568.

Our insistence on using only clear and well-recognized public policy to serve as the basis for the wrongful discharge tort emphasizes our continuing general adherence to the at-will employment doctrine and the need to carefully balance the competing interests of the employee, employer, and society. See Fogel v. Trustees of Iowa College, 446 N.W.2d 451, 455 (Iowa 1989) (common law doctrine of employment at-will is firmly rooted in Iowa law); 82 Am.Jur.2d Wrongful Discharge § 15, at 687-88 (1992) (purpose of public policy exception is to balance competing interests of society, employers, and employees in light of the modern business experience). An employer’s right to terminate an employee at any time only gives way under the wrongful discharge tort when the reason for the discharge offends clear public policy. See Lockhart, 577 N.W.2d at 846.

The need for clarity in public policy is similarly recognized in our reluctance to search too far beyond our legislative pronouncements and constitution to find public policy to support an action. Thus, we must proceed cautiously when asked to declare public policy to support an exception to the at-will doctrine, and only utilize those policies that are well recognized and clearly defined. Burnham v. Karl & Gelb, P.C., 252 Conn. 153, 745 A.2d 178, 182 (2000) (public policy exception is narrow and courts should not lightly intervene to impair the exercise of managerial discretion). Any effort to evaluate the public policy exception with generalized concepts of fairness and justice will result in an elimination of the at-will doctrine itself. See Tobias § 5:05, at 17. Moreover, it could unwittingly transform the public policy exception into a “good faith and fair dealing” exception, a standard we have repeatedly rejected. Id,.; see Huegerich, 547 N.W.2d at 220.

2. Determining Jeopardy to Public Policy.

Once a clear public policy is identified, the employee must further show *284the dismissal for engaging in the conduct jeopardizes or undermines the public policy. See Yockey, 540 N.W.2d at 421 (dismissal for missing work following work injury did not jeopardize public policy favoring filing for workers’ compensation benefits). Thus, this element requires the employee to show the conduct engaged in not only furthered the public policy, but dismissal would have a chilling effect on the public policy by discouraging the conduct. See Teachout, 584 N.W.2d at 303 (public policy to report suspected child abuse implicated when employee is terminated for good faith intent to report child abuse); Lara, 512 N.W.2d at 782 (permitting discharge for conduct which conforms to public policy would create a chilling effect on public policy by indirectly forcing employees to forego the conduct); Smith v. Smithway Motor Xpress, Inc., 464 N.W.2d 682, 684-85 (Iowa 1990) (public policy for employees to file workers’ compensation claim implicated when employee is terminated after receipt of workers’ compensation benefits); Niblo v. Parr Mfg., 445 N.W.2d 351, 353 (Iowa 1989) (public policy for employees to file workers’ compensation claim is implicated when employee is terminated for threatening to file claim). In Lara, we said

Employers cannot be permitted to intimidate employees into foregoing the benefits to which they are entitled in order to keep their jobs. To hold otherwise in this context would create a chilling effect by permitting an employer to indirectly force an employee to give up certain statutory rights.

Lara, 512 N.W.2d at 782. Thus, when the conduct of the employee furthers public policy or the threat of dismissal discourages the conduct, public policy is implicated.

On the other hand, if a public policy exists, but is not jeopardized by the discharge, the cause of action must fail. See Yockey, 540 N.W.2d at 421 (public policy favoring workers’ compensation claim not frustrated if employer terminated employee for missing work due to the work-related injury). The conduct of the employee must be tied to the public policy, so that the dismissal will undermine the public policy; French, 495 N.W.2d at 771-72 (public policy against suborning perjury not implicated if employer terminates the employee after using coercive and highhanded tactics to obtain confession).

This element guarantees an employer’s personnel management decisions will not be challenged unless the public policy is genuinely threatened. Gardner, 913 P.2d at 382. If a public policy exists, but is not jeopardized by the discharge, the cause of action must fail. See French, 495 N.W.2d at 771-72 (public policy against perjury not implicated if employer terminates employee after using coercive or high-handed tactics to obtain confession).

3. Claim of Public Policy to Oppose Wrongful Termination of Co-Employee.

Fitzgerald first claims there is a public policy in this state which protects an employee from discharge by an employer for opposing the wrongful termination of a co-employee. He claims this public policy in favor of opposing the unlawful termination of a co-employee is derived from the Iowa Civil Rights Act, as well as Title VII of the Civil Rights Act of 1964. See Iowa Code § 216.11; 42 U.S.C. § 2000e-3(a) (1994).

Fitzgerald acknowledges the state and federal civil rights acts prohibit an employer from discriminating against a person who opposes a discriminatory practice as defined by the legislation, and do not apply to employee conduct of opposing the termination of a co-employee for engaging in conduct associated with our judicial system. Nevertheless, he argues these statutes, as well as others, reveal a broad public policy for employees to oppose all unlawful employment practices including the termination of a co-employee which is *285contrary to public policy.4 Fitzgerald claims the termination of Koresh was contrary to public policy of this state to provide truthful testimony and he should be afforded the same protection as the law provides Koresh.

We are reluctant to infer a broad public policy from a statute which is limited in its scope to specific discriminatory practices. See Bennett v. City of Redfield, 446 N.W.2d 467, 474 (Iowa 1989) (discipline in discharge provisions of chapter 400 excluded cities with populations of 15,000 or less and did not express a general public policy in favor of progressive disciplinary procedures in termination for good cause).- Instead, we continue to adhere to our guiding principle to only declare public policy which is clearly articulated by a statute or other appropriate source. See Springer, 429 N.W.2d at 560. The statutes identified by Fitzgerald clearly do not expressly protect his conduct and we find nothing which can be inferred from the language of the statutes to establish the broad public policy suggested. See Yockey, 540 N.W.2d at 421 (statute which creates public policy in favor of filing workers’ compensation claims does not embrace employee absenteeism based on work-related injury). Public policy involves a careful balance of competing interests, and we will not interfere with an employer’s interest in running its business as it sees fit unless a clear, well-recognized public policy exists. Gardner, 913 P.2d at 382.

We also observe Fitzgerald has failed to show how any public policy in favor of opposing the claimed unlawful termination of a co-employee would be jeopardized by his dismissal. Fitzgerald offered no evidence that he expressed opposition to the discharge of a co-worker because it was unlawful. Instead, Fitzgerald admits the only objection he voiced to his employer over the termination of Koresh was the length of his employment service and the lack of prior infractions. He offered no evidence he objected to the termination of Koresh for providing truthful deposition testimony. The conduct of Fitzgerald, therefore, did not promote the claimed public policy, and his actions were not necessary to enforce any public policy. Fitzgerald failed to tie his conduct with his claim of public policy. See Yockey, 540 N.W.2d at 421 (discharge for absenteeism following work-related injury does not match public policy against discharge for filing workers’ compensation claim).

4. Claim of Public Policy to Provide Truthful Testimony in a Legal Proceeding.

We next address the claim by Fitzgerald that he was terminated because he intended to provide truthful testimony, adverse to his employer, in a threatened future lawsuit of a co-employee against Salsbury. Our first task is to decide whether a public policy exists in this state against discharge of an employee for giving or intending to give truthful testimony in a legal proceeding.

Before considering our statutes, we observe other jurisdictions have recognized a public policy against firing an employee for giving testimony in court proceedings. The case that broke the ground for this exception was Petermann v. International Brotherhood of Teamsters, 174 Cal.App.2d 184, 344 P.2d 25 (1959). In Petermann, the California Court of Appeals first recognized a cause of action for wrongful discharge when an employee was terminated for refusing to perjure himself at his em~ *286ployer’s request. 344 P.2d at 27. The court found a clear public policy against perjury was reflected in those penal statutes making the commission and subornation of perjury unlawful. Id. The court stated:

In order to more fully effectuate the state’s declared policy against perjury, the civil law, too, must deny the employer his generally unlimited right to discharge an employee whose employment is for an unspecified duration, when the reason for the dismissal is the employee’s refusal to commit perjury.... The public policy of this state as reflected in the penal code ... would be seriously impaired if it were to be held that one could be discharged by reason of his refusal to commit perjury.

Id.

This same reasoning has appealed to other courts when faced with actions by employees who were discharged either for refusing to perjure themselves or for testifying truthfully against their employers. See Merkel v. Scovill, Inc., 570 F.Supp. 133, 140 (S.D.Ohio 1983), overruled in part (on factual basis) by 787 F.2d 174, 178 (6th Cir.1986) (employee fired for refusing to commit perjury); see also Bishop v. Federal Intermediate Credit Bank, 908 F.2d 658, 662 (10th Cir.1990) (employee fired after truthful testimony at a congressional hearing); Freeman v. McKellar, 795 F.Supp. 733, 742 (E.D.Pa.1992) (employee fired after truthful testimony before grand jury); Montalvo v. Zamora, 7 Cal.App.3d 69, 86 Cal.Rptr. 401, 404 (1970) (employees fired because employer believed they intended to testify in a minimum wage action); Martin Marietta Corp. v. Lorenz, 823 P.2d 100, 110 (Colo.1992) (employee fired for refusing to misrepresent quality control deficiencies, an illegal act); DeRose v. Putnam Management Corp., 398 Mass. 205, 496 N.E.2d 428, 431 (1986) (employee fired for failure to testify as employer wanted); Williams v. Hillhaven Corp., 91 N.C.App. 35, 370 S.E.2d 423, 426 (1988) (employee fired for testifying at another employee’s unemployment compensation hearing); Ressler v. Humane Soc’y, 480 N.W.2d 429, 431 (N.D.1992) (employee discharged for testifying truthfully).

Similarly, we find ample statutory support for a public policy in Iowa in favor of refusing to commit perjury. See Iowa Code §§ 720.2, .3, .4. Our statutes make it a crime to commit perjury, suborn perjury, or tamper with a witness. Id. Moreover, this public policy is not simply confined to the refusal to commit perjury but clearly embraces a broader public policy to provide truthful testimony in legal proceedings. Page v. Columbia Natural Resources, Inc., 198 W.Va. 378, 480 S.E.2d 817, 825-26 (1996). A policy in favor of refusing to commit perjury necessarily implies an inverse corresponding public policy to provide truthful testimony. Additionally, the integrity of the judicial system, its fundamental ability to dispense justice, depends upon truthful testimony. This principle forms the basis for our perjury and related statutes. Furthermore, a reasonable employer should be aware that attempts to interfere with the process of obtaining truthful testimony, whether through intimidation or retaliation, is a violation of this public policy. Id.; Stevenson, 66 Cal.Rptr.2d 888, 941 P.2d at 1161. Thus, we conclude the public policy derived from our statutes against perjury and suborning perjury also supports a public policy to provide truthful testimony. We next consider whether this public policy is undermined when an employee is discharged from employment for engaging in the conduct claimed by Fitzgerald.

Salsbury first argues that discharging Fitzgerald cannot jeopardize public policy in favor of truthful testimony in legal proceedings because Fitzgerald never testified in a legal proceeding, was never requested to testify in a legal proceeding, and never expressed an intent to testify. Thus, Salsbury claims the conduct engaged in by Fitzgerald did not match the conduct protected by the public policy.

*287We agree a dismissed employee must engage in conduct related to public policy before the discharge can undermine that public policy. However, we view the good faith intent to engage in a protected activity the same as performing the protected activity. Teachout, 584 N.W.2d at 301. This is because employees would be discouraged from engaging in the public policy if they were discharged for their intent to engage in the public policy the same as if they actually engaged in the conduct. See id.; Niblo, 445 N.W.2d at 351 (public policy in favor of filing workers’ compensation claim for work-related injuries was jeopardized by discharge for threat of filing). Thus, Fitzgerald must only show he had a good faith intent to truthfully testify.

An essential element of proof to establish the discharge undermines or jeopardizes the public policy necessarily involves a showing the dismissed employee engaged in conduct covered by the public policy. See Barela v. C.R. England & Sons, Inc., 197 F.3d 1313, 1316 (10th Cir.1999) (must show employee conduct brought public policy into play). Although proof the employee engaged in the conduct is also a part of the causation element of the tort, we must review Fitzgerald’s conduct in this case to determine if it sufficiently matched the public policy of providing truthful testimony.5

Fitzgerald did not directly express an intention to testify truthfully in the lawsuit threatened by Koresh. Furthermore, he never told any company officials he possessed any particular damaging information about the threatened lawsuit. These facts suggest Fitzgerald did not contemplate testifying in a threatened lawsuit by Koresh prior to his discharge. Thus, we must review'the summary judgment record to determine if a reasonable inference can be drawn that Fitzgerald maintained a good faith intent to testify truthfully in a lawsuit action prior to the discharge.

Courts are generally reluctant to rely on summary judgment to resolve cases when intent is a substantive element of the action. Ness v. Marshall, 660 F.2d 517, 519 (3rd Cir.1981). This is because inferences used to determine intent are fact-based. Thus, if two reasonable inferences can be drawn, summary judgment is inappropriate. An inference, however, must not be based on speculation or "conjecture. See Robertson v. Allied Signal, Inc., 914 F.2d 360, 382 n. 12 (3rd Cir.1990).

The conduct engaged in by Fitzgerald prior to his discharge amounted to internal opposition to the termination of a co-employee. Generally, mere internal opposition by an employee to-the employer’s decision to discharge a co-employee would not suggest an inference the employee intended to give truthful testimony in future litigation brought by the discharged co-employee. The internal expression of support for a co-employee under these circumstances is far removed from the external concepts of perjury and truthful testimony in court proceedings. However, there are additional facts which must be considered in our analysis at this stage of the proceedings.

This case is not simply about Fitzgerald expressing support for Koresh. Salsbury not only admonished Fitzgerald for failing to support his employer, but warned him that the matter could result in litigation and he must decide which side he would support. Thus, Salsbury placed Fitzgerald’s support for Koresh in the context of litigation and transformed the conversation into choosing sides in a lawsuit. There was no evidence to suggest Fitzgerald backed down from his support for Koresh after the conversation' turned to litigation. These facts permit a reasonable inference *288to be drawn that Fitzgerald, prior to his discharge, developed an intent to testify in threatened future litigation against his employer.

There are, of course, other inferences that could be drawn from the evidence. However, at this stage we are required to draw those reasonable inferences in favor of Fitzgerald as the nonmoving party to the summary judgment proceedings. In light of these inferences, we conclude that there is evidence to support the claim Fitzgerald engaged in policy-based conduct.

Nevertheless, Salsbury argues the jeopardy element of the tort cannot be satisfied as a matter of law because it never requested Fitzgerald to testify inconsistent with the public policy. Without a request to testify inconsistent with public policy, Salsbury asserts the discharge cannot undermine any public policy. In fact, Sals-bury points out that the dismissal based on an inference that Fitzgerald would testify contrary to the interest of the employer would actually give Fitzgerald a greater incentive to freely and openly testify in conformance to public policy.

Some jurisdictions require the employer to actually make a request to the employee to commit perjury before finding the public policy against perjury is implicated. Bushko v. Miller Brewing Co., 134 Wis.2d 136, 396 N.W.2d 167, 170 (1986); see Meehan v. Amax Oil & Gas, Inc., 796 F.Supp. 461, 468 (D.Colo.1992) (employer never directed employee to act in certain way and never specifically prohibited employee from exercising privilege). Thus, a discharge based on an employer’s concern that the employee will testify truthfully if asked to testify or that the employee intends to testify contrary to the interests of the employer is insufficient to support a cause of action under the public policy exception. Brockmeyer v. Dun & Bradstreet, 113 Wis.2d 561, 335 N.W.2d 834, 840 (1983) (public policy must be clearly identifiable, “[n]o employer should be subject to suit merely because a discharged employee’s conduct was praiseworthy or because the public may have derived some benefit from it”). Other jurisdictions limit the action by requiring an unmistakable threat to the public policy. See Daniel v. Carolina Sunrock Corp., 335 N.C. 233, 436 S.E.2d 835, 836 (1993) (statement by employer reminding employee for whom she worked and to say as little as possible prior to providing testimony was insufficient to implicate the public policy against the perjury).

We believe the dismissal of an employee can jeopardize public policy when the employee has engaged in conduct consistent with public policy without a request by the employer to violate public policy just as it can when the employee refuses to engage in conduct which is inconsistent with public policy when requested by the employer. The focus is on the adverse actions of the employer in response to the protected actions of the employee, not the actions of the employer which may give rise to the protected actions of the employee. Furthermore, in considering whether the dismissal undermines public policy, we not only look to the impact of the discharge on the dismissed employee, but the impact of the dismissal on other employees as well. Public policy applies to all employees. If the dismissal of one employee for engaging in public policy conduct will discourage other employees from engaging in the public policy conduct, public policy is undermined.

In this case, if Salsbury was motivated to dismiss Fitzgerald because he intended to testify truthfully in a future lawsuit, a dismissal would have a chilling effect on other employees by discouraging them from engaging in similar conduct. See Lara, 512 N.W.2d at 782. Thus, it makes no difference that a dismissal in this particular case may give the employee an enhanced incentive to testify after a dismissal. The action by the employer could inhibit other employees from truthfully testifying in the future out of fear of dismissal.

*289Salsbury further argues that interpreting the tort to include conduct alleged by Fitzgerald will open the floodgates to litigation for wrongful discharge on public policy grounds whenever an employee internally expresses reservations over the termination of a co-employee and then is later dismissed for some valid reason unrelated to the prior termination of the co-employee. This argument, however, can be made to practically every public policy claim which serves as the basis for a wrongful discharge action. See Page, 480 S.E.2d at 826. Yet, it is up to the fact finder, in most instances, to determine whether any particular case has merit. We simply recognize a tort for discharge in violation of a public policy to provide truthful testimony, and leave it to the jury to determine if the facts support the claim. The action in this case is based in part upon an internal complaint by the employee, but is enough to withstand summary judgment because the context of the internal complaint justifies an inference of an intent to testify against the employer which may have caused the employer to dismiss the employee.

5. Causation Element.

We next consider if the evidence is sufficient to support a causal connection between the conduct engaged in by Fitzgerald and the discharge. The protected conduct must be the determinative factor in the decision to terminate the employee. Teachout, 584 N.W.2d at 301-02. Of course, if the employer has no knowledge the employee engaged in the protected activity, causation cannot be established. Id.; Perritt §§ 7.21-.22, at 54-55. Similarly, the existence of other legal reasons or motives for the termination are relevant in considering causation.

The causation standard is high, and requires us to determine if a reasonable fact finder would conclude Fitzgerald’s intent to testify truthfully was the determinative factor in the decision to discharge him. Teachout, 584 N.W.2d at 300. Generally, causation presents a question of fact. Thus, if there is a dispute over the conduct or the reasonable inferences to be drawn from the conduct, the jury must resolve the dispute. Perritt § 7.21, at 54. Additionally, any dispute over the employer’s knowledge of the conduct is generally for the jury, as well as the existence of other justifiable reasons for the termination.

In this case, the different inferences to be drawn from the evidence preclude summary judgment. After a recommendation was made to Salsbury to terminate Ko-resh, Salsbury wanted to know if Fitzgerald supported Koresh. Salsbury further expressed disapproval over the support Fitzgerald gave Koresh. Moreover, Sals-bury gathered this information in the context of a potential lawsuit threatened by Koresh. In light of these inferences, summary judgment was improper.

IV. Conclusion.

We conclude the court erred in granting summary judgment. We reverse the decision of the district court and remand the case for further proceedings.

REVERSED AND REMANDED.

All justices concur except LAVORATO, J., who takes no part.

LAMAR, Justice,

for the Court:

¶ 1. This case presents a certified question from the Fifth Circuit Court of Appeals. Robert Swindol sued his employer, Aurora Flight Sciences Corporation, in federal court for wrongful discharge and defamation. Swindol alleged that Aurora had terminated him for having a firearm inside his locked vehicle in the company parking lot. Aurora filed a motion to dismiss, and the district court dismissed Swindol’s wrongful-discharge claim with prejudice,1 stating that it “[could not] say *848that the Mississippi Supreme Court would recognize a third exception to the doctrine of at-will employment,” as proposed by Swindol. As such, the district court found that Swindol had failed to state a claim for wrongful discharge. Swindol appealed, and the Fifth Circuit has now certified the following question to this Court:

Whether in Mississippi an employer may be liable for a wrongful discharge of an employee for storing a firearm in a locked vehicle on company property in a manner that is consistent with [Mississippi Code] Section 45-9-55.

Swindol v. Aurora Flight Sciences Corp., 805 F.3d 516, 523 (5th Cir.2015). The Fifth Circuit also concluded that it “would benefit from [this Court’s] analysis of whether Section 45-9-55(5) bars” Swin-dol’s suit. Id. at 522. We find that an employer may be liable and that Section 45-9-55(5) does not shield Aurora from liability under the facts of this case.

PACTS AND PROCEDURAL HISTORY

¶2. The Fifth Circuit summarized the facts as follows:

Swindol worked for Aurora Flight Sciences Corporation in Mississippi. He parked his car in Aurora’s parking lot with a firearm locked inside. Aurora’s managers learned about the firearm and fired Swindol later the same day for violating a company policy forbidding firearms on company property. Aurora then convened a plant-wide meeting during which its human resources manager told employees that Swindol was a security risk and instructed them to call the police if they saw him near the facility. Swindol sued Aurora in United States District Court in Mississippi. He asserted there was diversity jurisdiction under 28 U.S.C. § 1332. He brought state-law claims for wrongful discharge and defamation. Aurora moved to dismiss Swindol’s complaint under Rule 12(b)(6). The district court granted the motion, dismissing Swindol’s wrongful discharge claim with prejudice and his defamation claim without prejudice. Swindol appealed.

Id. at 520 (footnote omitted).

¶ 3. The Fifth Circuit began its discussion by noting Mississippi Code Section 45-9-55(1), which provides:

(1) Except as otherwise provided in subsection (2) of this section, a public or private employer may not establish, maintain, or enforce any policy or rule that has the effect of prohibiting a person from transporting or storing a firearm in a. locked vehicle in any parking lot, parking garage, or other designated parking area.

Miss.Code Ann. § 45-9-55(1) (Rev.2015). The cross-referenced subsection (2) provides a different rule for certain secured parking lots, but neither party claims that rule applies here.- Swindol, 805 F.3d at 521. It also is “undisputed that Aurora had a firearms policy that is inconsistent with [Section 45-9-55].” Id.

¶ 4. Swindol argued before the Fifth Circuit that it “should interpret Section 45-9-55 to create a ‘separate and additional public policy exception to the at-will doctrine’ because doing so would fortify Mississippi’s public policy supporting the right to bear arms,” Id. But the Fifth Circuit ultimately declined to do so, noting that it had “discovered no Mississippi case law addressing the effect of Section 45-9-55.”2 Id. The. Court went on to say that

*849It is undisputed that Aurora had a firearms policy that is inconsistent .with the statute. Those facts still leave as questions - whether the firing violated the statute and whether it can be remedied in this action despite the employment-at-,will doctrine. We hesitate to intrude into such a seemingly well-settled, area of state law. As the Mississippi Supreme Court has held, employment at will means employers may fire employees “for good reason, bad reason, or no reason at all, excepting only reasons independently declared legally impermissible.” McArn v. Allied Bruce-Terminix Co., Inc., 626 So.2d 603, 606 (Miss.1993) (citation and quotations omitted). The two exceptions to the Mississippi employment-at-will doctrine identified by the McAm court over 20 years ago remain the only two recognized so far. Neither McAm exception applies here. See id. at 607.

Though the Mississippi Supreme Court has not expanded the exceptions after McAm, the court has been clear that the legislature has the authority to create new exceptions. See, e.g., Kelly v. Miss. Valley Gas Co., 397 So.2d 874, 876 (Miss.1981). In Kelly, 'the court held that the employment-at-will doctrine barred the plaintiffs ‘claims for retaliatory discharge based ón his employer’s firing him for exercising his statutory right to file a workmen’s compensation claim. Id. The: Kelly court based' its decision largely on the lack of a statutory provision expressly making it a crime for an employer to discharge an employee for filing such a claim. Id. The Mississippi statute here, though, goes beyond just giving rights to employees. It is express that an employer may not enforce a policy prohibiting employees from having weapons in their locked vehicles. See § [46-9-55]. The issue as we see it is whether that prohibition is sufficient to create an exception to the Mississippi ■ employment-at-will doctrine.

Id. at 521-22/ The Fifth Circuit decided also that' it would “benefit from [this Court’s] analysis of whether Section 45-9-55(5) bars this'suit.” Id. at 522. Section 45-9-55(5) provides:

(5) A public or private employer shall not be liable in a civil action for damages resulting from or arising out of an occurrence involving the transportation, storage, possession or use of a firearm covered by this section.

Miss,Code Ann. § 45-9-55(5) (Rev.2015).

¶ 5. So, the Fifth Circuit concluded,

Section 45-9-55 clearly expresses a public policy prohibiting employers from barring employees from possessing firearms in the manner the plaintiff claims • he did. Yet there'are no state-law authorities to guide us in deciding how this statute affects the employment-at-will doctrine. Mississippi state courts have not identified any exceptions to the doctrine beyond those in McAm. That consistency raises compelling comity interests that -stay our hand from adding an exception in federal court even were we to decide an exception had been statutorily created. , The Mississippi .Supreme Court is the only court that can definitively decide whether the well-settled M.cAm doctrine has been affected by Section 45-9-55.

Swindol, 805 F.3d at 522. The certified question quoted above followed.

. ANALYSIS

Employment-At-Will Jurisprudence in Mississippi

¶ 6. Mississippi has followed the common-law rule of at-will employment for more than 150 years. Kelly v. Mississippi Valley Gas Co., 397 So.2d 874, 874-75 *850(Miss.1981). See also Butler v. Smith and Tharpe, 35 Miss. 457 (1858). In short, either party may terminate the employment at will, and the parties “may have a good reason, a wrong reason, or no reason for terminating the employment contract.” Kelly, 397 So.2d at 874-75. Stated more broadly, “ ‘absent an employment contract expressly providing to the contrary, an employee may be discharged at the employer’s will for good reason, bad reason, or no reason at all, excepting only reasons independently declared legally impermissible.’” McArn v. Allied Bruce-Terminix Co., Inc., 626 So.2d 603, 606 (Miss.1993) (quoting Shaw v. Burchfield, 481 So.2d 247 (Miss.1985)).

¶ 7. In Kelly v. Mississippi Valley Gas Co., Plaintiff J.C. Kelly

[urged the Court] to adopt a public policy exception to the common law rule that an employment contract at will may be terminated by either party with or without cause or justification, and hold an employer liable to an employee in a common law tort action when an employer has discharged an employee for filing a workmen’s compensation claim.

Kelly, 397 So.2d at 874. But this Court declined to carve out a “public policy exception” to the employment-at-will rule, noting

While the harshness of the terminable at will rule is subject to exception in light of express legislative action, the absence of explicit statutory provision of a civil remedy in the Mississippi workmen’s compensation statute argues against recognizing a cause of action for retaliatory discharge.

Id. at 875 (quoting Green v. Amerada-Hess Corp., 612 F.2d 212, 214 (5th Cir. 1980)) (citations omitted). This Court said that, while Kelly’s arguments had “considerable appeal,” they were “clearly for the Legislature to assess, not the judiciary.” Kelly, 397 So.2d at 876. This Court noted the lack of a retaliatory-discharge provision in Mississippi’s Workmen’s Compensation Law, as well as the lack of a provision making it a crime for an employer to discharge an employee for filing a claim. Id. As such, this Court concluded that it would be “engraft[ing] on the law an exception different from that expressed by the Legislature,” which was not its function. Id.

¶ 8. The United States District Court for the Northern District of Mississippi addressed Mississippi’s employment-at-will jurisprudence a few years later in Laws v. Aetna Finance Company, ITT, 667 F.Supp. 342 (N.D.Miss.1987). The plaintiff there alleged that his employer fired him after he refused to participate in illegal loan “packing.” Id. at 343-44. The district court recognized that Mississippi “clearly” was an employment-at-will state. Id. at 344. But the court also opined that “the Mississippi Supreme Court has not previously decided a case applicable or similar to the case sub judice.” Id. The district court thus proceeded to make an Erie 3 guess, concluding that “the Mississippi Supreme Court would recognize a limited public policy exception to the employment-at-will rule where an employee alleges that his discharge was motivated by a refusal to engage in illegal acts for his employer.” Id. at 348-49.

¶ 9. In coming to this conclusion, the district court wrote

The focal point of the defendants’ argument, then, is that even when at-will employees are discharged for refusing to engage in unlawful practices harmful to the public, not simply for exercising statutory rights given to them as em*851ployees as in Kelly, the courts are powerless to fashion any relief at common law. The defendants’ argument can be further reduced to the contention that under Mississippi’s law there can never be a modification of the employment-at-will rule unless it is made by the Legislature. This argument completely ignores the fact, however, that the employment-at-will rule itself was created and clarified by the Mississippi Supreme Court in Butler and Rape, supra, and merely applied to the workers’ compensation law in Kelly.

The Mississippi court has already’stated in dicta that it is prepared to reconsider Mississippi’s common law employment-at-will rule and to vary from its previous unswerving adherence to the harsh rule adopted in Kelly when the appropriate ease is presented.

The prevailing rule on employment at will appears to be that where. a clear ' mandate of public policy' is violated by an employee’s discharge, a cause of action for wrongful termination does arise. The court finds no contrary evidence that Mississippi would reject the opportunity presented in this case to adopt a narrow public policy exception to the termination at will doctrine, given a factual situation in which an at-will employee is discharged for refusing to commit unlawful acts for his,employer-.

Id. at 346-48 (footnotes and citations omitted).

¶ 10. And in distinguishing Kelly, the district court noted that Kelly

simply reflected judicial unwillingness to tamper with a detailed statutory scheme that regulated one aspect of the employer-employee relationship.... The instant case presents no problem of en-grafting an exception onto any existing statutory law, since -the terminable at will doctrine.is a judicially created one and can thus be modified by the judiciary.

Id. at 345. The district court also noted that “the public policies underlying Laws’ discharge are not contained in any statutory scheme as to which there was any basis for assuming that either Congress or the Mississippi Legislature would have contemplated the need for an anti-retaliation provision.” Id.

■ ¶ 11. Six years later, in McArn v. Allied Bruce-Terminix Co., Inc., this Court adopted the limited public-policy exception predicted by the district court in Laws. McArn alleged that his employer had fired him after- he reported its illegal acts. McArn, 626 So.2d at 606. In reversing the trial court’s directed verdict in favor of the employer, this Court wrote . .

We are of the opinion that there should be in at least two circumstances, a narrow public policy exception to the employment at will doctrine and this should be so whether there is a written contract or not: (1) an employee who refuses to participate in an illegal, act as. in Laws shall not be-barred by the common law' rule of employment at will from bringing an action in tort for damages against his employer; (2) an employee who- is discharged for., reporting illegal acts of his employer to the employer or anyone else is not barred by the employment at will doctrine from bringing action in tort for damages against his employer. To this limited extent this Court declares these public policy exceptions to the age old common law rule of employment at will.

Id. at 607. The McArn Court also reiterated that an employer may fire an employee for any reason, “excepting only reasons independently declared legally impermissible.” Id. at 606.

*852¶ 12. This Court’s most recent pronouncement on the employment-at-will doctrine came last year in Galle v. Isle of Capri Casinos, Inc., 180 So.3d 619 (Miss. 2015). This Court reiterated that, absent a written contract, an employment relationship in Mississippi is at-will. Id. at 622. This Court also noted that it recently had “clarified that ‘[a] McArk claim alleging wrongful discharge in violation of public policy is based on an employer’s duty not to thwart the public interest by terminating employees for speaking the truth.’ ” Id. (quoting Cmty. Care Ctr. of Aberdeen v. Barrentine, 160 So.3d 216, 220 (Miss. 2015)).

¶ 13. But this Court declined to extend the McAm public-policy exception to Galle, because Galle was a “willing participant” in his employer’s illegal conduct:

We find ho public-policy reason to allow an employee who willingly participated in an illegal scheme and who blew the whistle only after the illegal scheme was revealed, to claim the McAm exceptions to the employment-at-will doetrine. Because Galle is an at-will employee and because his claim does not fall within McAm’s narrow public-policy exceptions to-the employment-at-will'doctrine, Galle has failed to state a legally cognizable claim for wrongful- discharge in violation of public policy.

Absent the narrow public-policy exceptions announced in McAm or prohibitions contained in federal or state law, an employer may fire an at-will- employee for any reason or no reason at all.

Galle, 180 So.3d at 623 (emphasis added).

¶ 14. Review of these cases reveals that, though this Court zealously applies the employment-at-will doctrine, that doctrine is not absolute. Employers m'ay not Are employees for one of the public-policy reasons detailed in .McAm, nor may they fire employees for reasons “independently declared legally impermissible.” “ ‘[Ajbsent an employment contract expressly providing to the contrary, an employee may be discharged at the employer’s will for good reason, bad reason, or no reason at all, excepting only reasons independently declared legally impermissible.’ ” McArn, 626 So.2d at 606 (quoting Shaw v. Burchfield, 481 So.2d 247 (Miss.1985)) (emphasis added). “[TJhe harshness of the terminable at will rule is subject to exception in light of express legislative action .... ” Kelly, 397 So.2d at 875 (quoting Green v. Amerada-Hess Corp., 612 F.2d 212 (5th Cir.1980)) (citations omitted) (emphasis added).

¶ 15. “We are of the opinion, that there should be in at least two circumstances, a narrow public policy exception to the employment at will doctrine....” McArn, 626 So.2d at 607 (emphasis added). “It is an employer’s duty not to thwart the public interest by terminating employees_” Galle, 180 So.3d at 622 (quoting Cmty. Care Ctr. of Aberdeen v. Barrentine, 160 So.3d 216, 220 (Miss.2015)) (emphasis added). “Absent the narrow public-policy exceptions announced in McAm or prohibitions contained in federal or state law, an employer may fire an at-will employee for any reason or no reason at all.” Galle, 180 So.3d at 623 (emphasis added).

¶ 16. Both the parties and the district court framed the issue as whether this Court should judicially-graft another “exception” to the employment-at-will doctrine. But we need take no such action here, because the Legislature already has. In short, we find that “express legislative action” and “state law prohibitions” exist in . this case. Stated differently, we find that the Legislature has declared it “legally impermissible” for an employer to terminate an employee for having a firearm *853inside his locked vehicle on company property.4

Mississippi Law Regarding Firearms

¶ 17. Article 3, Section 12 of the Mississippi Constitution is entitled “Right to Bear Arms” and provides that

The right of every citizen to keep and ■ bear arms in defense of his home, person, or property, or in aid of the- civil power when thereto legally summoned, -shall not be called in question, but the Legislature may regulate or forbid carrying concealed weapons.

Miss. Const, art. 3, § 12 (emphasis added). And Section 97-37-1(2) of the Mississippi Code provides that

(2) It shall not be a violation of this section [the concealment of a deadly weapon statute] for any person over the age of eighteen (18) years to carry a firearm or deadly weapon concealed within the confines of his own home or his place of business, or-any real property associated with his home or business or within any motor vehicle.

Miss. Code Ann. § 97-37-1(2) (Rev.2014) (emphasis added).

¶ 18. Finally relevant here is Section 45-9-55 of the Mississippi Code, which we quote in its entirety:

(1) Except as otherwise provided in subsection (2) of this section, a public or private employer may not establish, maihtaiú, or enforce any policy or rule that has the efféct of prohibiting a person from transporting or storing a firearm in a locked vehicle in' any parking lot, parking garage, or other designated parking area.

(2) A private employer may prohibit an employee from transporting or storing a firearm in a . vehicle in a parking lot, parking garage,.or other parking area the employer provides for employees to which access is restricted or limited through the use of a gate, security station or other means of restricting or limiting general public access onto the property.

(3) This section shall not apply to vehicles owned or leased by an employer and used by the employee in thé course of his-business. 1

(4) This section does not authorize a person' to' transport or store a firearm on any premises where the possession of a firearm is prohibited by state or federal law.

(5) A public or private employer shall not be liable in a civil action for damages resulting from or arising out of an occurrence involving the transportation, storage, possession or use of a firearm covered by this section.

Miss.Code Ann. § 45-9-55 (Rev.2015) (emphasis added).

¶ 19. So in short, the Mississippi Constitution grants citizens the right to keep and bear arms, and it provides that that right “shall not be called in question.” Miss. Const, art. 3, § 12. Section 97-37-1(2) specifically declares that the act of carrying a firearm within a motor vehicle is not a crime under the concealed-carry law. And Section 45-9-55 specifically precludes employers from “establish[ing], maintain[ing], or 'enforcing] any policy or rule that has the effect of prohibiting a *854person from transporting or storing a firearm in a locked vehicle.... ”

¶20. We find that these three provisions establish the “express legislative action” and the “state law prohibitions” envisioned by this Court in Kelly and McAm. And, as this Court also wrote in McAm, “an employee may be discharged at the employer’s will for good reason, bad reason, or no reason at all, excepting only reasons independently declared legally impermissible.’ ” McArn, 626 So.2d at 606 (quoting Shaw, 481 So.2d 247) (emphasis added). The Legislature has “independently declared” via Section 46-9-55 that terminating an employee for having a firearm inside his locked vehicle is “legally impermissible.” As Swindol succinctly argued before the district court: “an employee is wrongfully discharged if terminated for an act specifically allowed by Mississippi law, the prohibition of which is specifically disallowed by .,. statutory law.”

Subsection (5) Does Not Shield Aurora From Liability.

¶21. Aurora argued before the Fifth Circuit that Section 45-9-55(5) “contains an explicit bar” prohibiting a civil action for damages under these facts. Specifically, Aurora argued that Section 45-9-55 “contains a sweeping, explicit bar to civil actions for damages against employers,” and that Swindol’s suit “falls squarely within this prohibition.” We disagree.

¶ 22. As quoted above, Section 45-9-55(5) provides

(5) A public or private employer shall not be liable in a civil action for damages resulting from or arising out of an occurrence involving the transportation, storage, possession or use of a firearm covered by this section.

Miss.Code Ann. § 45-9-55(5) (Rev.2015) (emphasis added). We find first that this subsection plainly establishes freedom from liability for the actions of employees or third parties. In other words, while the Legislature said in Subsection (1) that employers could not enforce policies or rules that “had the effect” of prohibiting a person from having a firearm in a locked vehicle, it also chose to grant employers immunity should some sort of “occurrence” result from that prohibition.5

¶ 23. Moreover, while we recognize that Subsection (5) contains broad language, we find that to interpret it as Aurora does would render Subsection (1) meaningless. And this Court previously has stated unequivocally that “[a]ll parts of a statute are to be given effect if possible.” Miss. Pub. Serv. Comm’n v. City of Jackson, 328 So.2d 656, 658 (Miss.1976). Further, this Court repeatedly has said that “[t]raditional statutory construction ‘requires that a statute receive such construction as will, if possible, make all its parts harmonize with each other, and render them consistent with its scope and object.’” Legislature of State v. Shipman, 170 So.3d 1211, 1217 (Miss.2015) (quoting Owens Corning v. Miss. Ins. Guar. Ass’n, 947 So.2d 944, 946 (Miss.2007)) (emphasis added). We do not see any “harmony” in an interpretation finding that the Legislature, on the one hand, specifically precluded employers from prohibiting firearms inside locked vehicles on their premises, but then, on the other hand, granted employers complete immunity from damages for any violation of that prohibition. Nor would that inter*855pretation be consistent "with the “scope and object” of the statute as a whole. In short, we find that Subsection (5) provides Aurora no protection under the facts of this case.

CONCLUSION

¶ 24. While Mississippi is an at-will employment state, that doctrine is not absolute. This Court repeatedly has stated that the doctrine must yield to express legislative action and/or prohibitions found in federal or state-law.' We find that such “express legislative action” and “state law prohibitions” exist here. We also find that Subsection (5) does not protect Aurora from liability under the facts of this case. As such, we answer the certified question affirmatively.

¶ 25. CERTIFIED QUESTION ANSWERED.

WALLER, C.J., DICKINSON AND RANDOLPH, P.JJ., KITCHENS, KING, COLEMAN, MAXWELL AND BEAM, JJ., CONCUR.

HOWE, Chief Justice:

INTRODUCTION

T1 We granted certiorari to review the decision of the court of appeals holding that defendant did not violate a clear and substantial public policy when it terminated plaintiff's employment. See Rackley v. Fairview Care Ctrs., Inc., 970 P.2d 277, 282 (Utah Ct.App.1998).

BACKGROUND

T2 On November 1, 1998, plaintiff Cathleen L. Rackley began working as an at-will employee for defendant Fairview Care Centers, Inc., as the administrator of a nursing home known as Fairview West. In that capacity, she made suggestions to management and took steps to bring the care facility into compliance with both federal and state law. For example, plaintiff implemented changes in payroll so that if a payday fell on a weekend or holiday, employees would be paid the first prior working day. Additionally, she informed employees that by law they were entitled to a Hepatitis B vaccination at Fair-view's expense. Plaintiff also instituted changes in employee scheduling, food service, laundry service, and in the basic cleanliness, organization, and efficiency of Fairview West.

13 Sometime in February 1994, Karleen Merkley, the manager responsible for resident funds at Fairview West, informed most of the members of the staff that a check for $720 from the Veteran's Administration was expected to arrive for resident Ms. Mellen, and that Ms. Mellen was not to be notified when it came. Plaintiff was not informed of that prohibition. Sharon Mellen, Ms. Mel-len's daughter-in-law who had been aiding Ms. Mellen in managing her financial affairs for many years, had requested that Ms. Mel-len not be told about the money because she feared Ms. Mellen would try to use it to move out of Fairview West and attempt to live on her own. Sharon wanted to inform Ms. Mellen of the check's arrival personally and to convince her to use the money to purchase a new wheelchair.

{4 In the latter part of February, upon notification that the check had arrived, Sharon went to Fairview West, signed an authorization form in the presence of a witness, and took the check and deposited it in Ms. Mel-len's personal bank account.1 Soon thereafter, plaintiff became aware that the check had arrived and had been picked up by Sharon. She notified Ms. Mellen of that fact. Ms. Mellen was upset that she had not been informed of the check's arrival or subsequent deposit and consequently requested that plaintiff contact Sharon on her behalf.

15 There is some dispute about the content of the phone call to Sharon. Plaintiff contends that she simply told Sharon she had notified Ms. Mellen of the arrival of the check and expressed concern about the impropriety of keeping the information from Ms. Mellen. Plaintiff asserts that Sharon "screamed" at her for telling Ms. Melien about the money because "she was promised that nobody would find out about the money, that Karleen had talked to her and nobody should find out about it." Sharon contends that plaintiff called her at her place of work, yelled at her over the phone, and accused her *1025of dishonesty and improper conduct. She stated, "[all she did was kept telling me, you're stealing Ms. Mellen's money, you can't do that, you need to turn it-return the money to Fairview West.... She was very unprofessional. - She had me in tears." Plaintiff did not then notify Joseph Peterson, owner and general manager of Fairview, of what had transpired or request investigation by any outside authority.2

16 Shortly thereafter, Sharon contacted Peterson and told him her version of what had happened. Peterson then arranged a meeting with plaintiff, Merkley, and Sallie Maroney (the manager of Fairview East) to discuss the incident. At that meeting, Merk-ley and Maroney received written reprimands for failing to tell Ms. Mellen about the check, and a new official policy was instituted requiring that residents be informed of all their incoming funds, regardless of who assisted them with their financial affairs. Plaintiff was reprimanded for calling Sharon at work. Peterson said he would arrange an appointment with Sharon, Maroney, plaintiff, and himself to discuss the incident. The meeting was then adjourned. .

T7 Days later, Peterson again called plaintiff into a meeting where he indicated that he was considering terminating her over the Mellen incident. While there is some confusion over what happened next, the parties have stipulated that for purposes of this case, plaintiff was terminated by Fairview.3 Rackley filed this action, claiming she was wrongfully discharged in violation of public policy.

T8 After a bench trial, the court held that a clear and substantial public policy of notifying care facility residents of the arrival of their funds had been implicated and that notifying Ms. Mellen and contacting Sharon were actions furthering such policy. On appeal, the court of appeals reversed the trial court's judgment, holding that notifying care facility residents of the arrival of their personal funds is not required by any clear and substantial public policy, and therefore, terminating plaintiff was within Fairview's discretion under the employment-at-will doe-trine. See Rackley, 970 P.2d at 282. We granted certiorari. This court has jurisdiction over this matter pursuant to section 78-2-2(8)(a) of the Utah Code.

ANALYSIS

T9 The parties dispute the precise issue before us. Fairview contends that the key issue is whether notification to care center residents of the arrival of their personal funds is a clear and substantial public policy. Plaintiff disagrees and asserts that the policy at issue is not the extremely narrow policy of notifying residents of the arrival of their funds, but the broader right of residents to manage their own financial affairs. Plaintiff asserts that the court of appeals's narrow interpretation of the policy at issue erroneously requires that "all the specifics of a given - employment - termination - seenario would have to be most specifically anticipated by constitutional provision, statute, or regulation in order [for] a claim for wrongful termination for violation of public policy [to] succeed." '

I 10 We have held in the past that mate reliance on a public policy exeeption to the at-will rule requires an attempt to identify the proper sources of public policy and the principles which underlie it." Berube v. Fashion Ctr., Ltd., 771 P.2d 1033, 1042-43 (Utah 1989). We agree with plaintiff that if we were to require the law to be so specifically tailored, the public policy exception would be meaningless. Thus, we hold that the proper issue before us is whether a care facility resident's right to manage her own funds constitutes a clear and substantial pub-lie policy.

On certiorari, we review the decision of the court of appeals, not that of the trial court. See Lysenko v. Sawaya, 2000 UT 58, ¶ 15, 7 P.3d 783. Whether a clear and substantial public policy exists supporting a wrongful discharge claim based on an employer's violation of that policy is a ques*1026tion of law. We review the court of appeals's conclusions of law for correctness and afford them no deference. See Bear River Mut. Ins. Co. v. Wall, 1999 UT 33, ¶ 4, 978 P.2d 460.

112 Under Utah law, an employment relationship entered into for an indefinite period of time is presumed to be at-will and gives rise to a contractual arrangement where the employer or the employee may terminate the employment for any reason, exeept as provided by law. See Ryan v. Dan's Food Stores, Inc., 972 P.2d 395, 400 (Utah 1998); Fox v. MCI Communications Corp., 931 P.2d 857, 859 (Utah 1997); Brehany v. Nordstrom, Inc., 812 P.2d 49, 53-55 (Utah 1991); Berube, 771 P.2d at 1044; Bihlmaier v. Carson, 603 P.2d 790, 792 (Utah 1979). Both parties in this case agree that plaintiff was an at-will employee of Fairview. Thus, under ordinary cireumstances, plaintiff could have been terminated for any reason and at any time.

113 However, there are exceptions to the at-will presumption. An at-will employee may overcome the at-will presumption by showing: "'(1) there is an implied or express agreement that the employment may be terminated only for cause or upon satisfaction of another agreed-upon condition; (2) a statute or regulation restricts the right of an employer to terminate an employee under certain conditions; or (8) the termination of employment constitutes a violation of a clear and substantial policy'" Burton v. Exam. Ctr. Indus. & Gen. Med. Clinic, Inc., 2000 UT 18, ¶6, 994 P.2d 1261 (quoting Fox, 931 P.2d at 859); see also Ryan, 972 P.2d at 400; Retherford v. AT & T Communications, 844 P.2d 949, 958-59 (Utah 1992) (implied or express agreement and public policy exeeptions); Heslop v. Bank of Utah, 839 P.2d 828, 836-38 (Utah 1992) (implied or express agreement exception); Peterson v. Browning, 832 P.2d 1280, 1281 (Utah 1992) (public policy exception); Hodges v. Gibson Prods. Co., 811 P.2d 151, 165 (Utah 1991) (same). "Employers have a duty not to terminate any employee, 'whether the employee is at-will or protected by an express or implied employment contract,' in violation of a clear and substantial public policy." Ryan, 972 P.2d at 404 (quoting Retherford, 844 P.2d at 960). If an employer breaches this duty, the terminated employee has a cause of action in tort against the employer. See Ryan, 972 P.2d at 404; Fox, 931 P.2d at 860; Retherford, 844 P.2d at 959; Peterson, 832 P.2d at 1283-86.

{14 To succeed on a wrongful discharge claim for violation of such a public policy, plaintiff must satisfy a four-pronged test. Plaintiff must prove that (1) her employment was terminated; (2) a clear and substantial public policy existed; (8) the plaintiff's conduct implicated that clear and substantial public policy; and (4) the termination and conduct in furtherance of the public policy are causally connected. See Ryan, 972 P.2d at 404; Heslop, 839 P.2d at 837; Wilmot v. Kaiser Aluminum & Chem. Corp., 118 Wash.2d 46, 821 P.2d 18, 28-29 (1991). Because Fairview concedes for purposes of this case that plaintiff was terminated, we move directly to the second prong.

I. CLEAR AND SUBSTANTIAL PUBLIC POLICY

115 The public policy exception to the employment at-will presumption is much narrower than traditional notions of public policy. See Ryan, 972 P.2d at 405. Only "clear and substantial public policies will support a claim of wrongful discharge in violation of public policy." Ryan, 972 P.2d at 404; see also Peterson, 832 P.2d at 1282. The nature and scope of what constitutes a "clear and substantial" public policy, however, is not always easily discernible. See, eg., Patton v. United States, 281 U.S. 276, 306, 50 S.Ct. 253, 74 L.Ed. 854 (1980) ("The truth is that the theory of public policy embodies a doctrine of vague and variable quality...."). "In Utah, we have frequently invoked the concept of public policy without articulating precisely its origin or definition." Berube 771 P.2d at 1042; see also Fox, 931 P.2d at 860 (stating that "a more precise definition of the term must await the time when this Court has had sufficient experience with a number of cases"); Peterson, 832 P.2d at 1282 ("'The identification of clear and sub*1027stantial public policies will require case-by-case development.").

1 16 Our prior cases in this area provide us with some general governing principles. We have stated that a public policy is "clear" if it is plainly defined by one of three sources: (1) legislative enactments; (2) constitutional standards; or (8) judicial decisions. See Dixon v. Pro Image Inc., 1999 UT 89, ¶ 31, 987 P.2d 48 (citing Ryan, 972 P.2d at 405); Hodges, 811 P.2d at 165-66; see also Burton, 2000 UT 18 at ¶ 6, 994 P.2d 1261 (stating that "declarations of public policy can be found in constitutions and statutes"). For example, we have held that the enforcement of a state's criminal code that reflects Utah policy constitutes a clear and substantial public policy. See Peterson, 832 P.2d at 1283 (holding that employer who fired employee for refusing to feloniously provide false information on tax forms could be held liable for wrongful termination); Hodges, 811 P.2d at 166-68 (holding that discharged employee had action for wrongful termination where employee was fired for refusing to accede to extortionate demands by employer).

117 We have also held that a pub-lie policy is "substantial" if it is of "overreaching importance to the public, as opposed to the parties only." Ryan, 972 P.2d at 405. "[Wle must ... inquire whether the discharge is against public policy and affects a duty which inures to the benefit of the public at large rather than to a particular employer or employee." Foley v. Interactive Data Corp., 47 Cal.3d 654, 254 Cal.Rptr. 211, 765 P.2d 373, 379 (1988); see, eg., Fox, 931 P.2d at 861-862 (holding that retaliatory termination for reporting possible criminal conduct of co-workers to employer does not give rise to a violation of substantial public policy). Statutes that simply regulate conduct between private individuals or impose requirements whose fulfillment does not implicate fundamental public policy concerns are not sufficient to require an exeeption to the at-will presumption. See id. As we stated in Ryan:

First, one must ask whether the policy in question is one of overarching importance to the public, as opposed to the parties only. Second, one must inquire whether the public interest is so strong and the policy so clear and weighty that we should place the policy beyond the reach of contract, thereby constituting a bar to discharge that parties cannot modify, even when freely willing and of equal bargaining power.

972 P.2d at 405.

118 It is important to note, however, that "not every employment termination that has the effect of violating some public policy is actionable." Fox, 981 P.2d at 860. "[EJven those principles which are widely held values may not be sufficient to justify wrongful termination recovery." Berube, 771 P.2d at 1048. This court "'recognizes the importance of keeping the scope of the public policy exception narrow to avoid unreasonably eliminating employer discretion in discharging employees'" Dixon, 1999 UT 89 at ¶ 31, 987 P.2d 48 (quoting Ryan, 972 P.2d at 405); see also Peterson, 832 P.2d at 1285-86 (Howe, A.C.J., concurring) (" 'The public policy exception is narrow enough in its seope and application to be no threat to employers who operate within the mandates of the law.... Such employers will never be troubled."). We have held, and continue to ensure, that "public policies [are construed] narrowly and will [protect] only those principles which are so substantial and fundamental that there can be virtually no question as to their importance for promotion of the pub-lie good." Berube, 771 P.2d at 1043.

119 "Legitimate reliance on a public policy exception to the at-will rule requires an attempt to identify the proper sources of public policy and the principles which underlie it." Id. at 1042-48. The court of appeals found that the following constitutional and statutory provisions did not provide grounds for a finding of clear public policy: (1) article I, sections 1 and 27 of the Utah Constitution; (2) federal and state ombudsman provisions provided in 42 U.S.C. § 8058g(a)(8) and (5) and sections 62A-3-201 to -202 of the Utah Code; and (8) 42 U.S.C. § 1396r(c)(6), R482-150-4 of the Utah Administrative Code, and 42 C.E.R. *1028§ 483.10.4 We address each in turn.

A. Article I, Sections 1 and 27 of the Utah Constitution

120 Plaintiff first asserts that two provisions in the Utah Constitution form the basis of a clear public policy. Article I, section 1 of the Utah Constitution provides in pertinent part that "(alll men have the inherent and inalienable right to ... acquire, possess and protect property...." Article I, seetion 27 provides that "[fIrequent recurrence to fundamental principles is essential to the security of individual rights and the perpetuity of free government." While these two provisions .do protect the right to acquire, possess, and protect property, they do not enunciate the narrow type of policy envisioned by our case law ereating the public policy exception. The right of a care facility resident to manage her own funds is not "plainly defined by ... [these] constitutional standards." Ryan, 972 P.2d at 405.

B. 42 USC. $ 3058g(a)(8) and (5), and Utah Code Ann. §§ 62A-3-201 to -208

11 21 Next, plaintiff contends that 42 U.S.C. § 3058g(a)(8) and (5), and sections 62A-3-201 to -208 of the Utah Code also plainly define such a public policy.5 Plaintiff specifically points to subsections (a)(3)6 and (a)(5)7 in support of her position. However, subsections (a)(8) and (a)(5) are devoid of any language relating to a resident's right to manage her funds. While these provisions broadly discuss the duty of the ombudsman to monitor and protect the rights of care facility residents, they in no way state a narrow and clear public policy necessary for an exception to the at-will rule. This statute governs the duties and functions of the office of the ombudsman and its representatives and entities, and in no way enunciates rights of care facility residents.

[ 22 Similarly, we find sections 62A-3-201 and -202 of the Utah Code unavailing. The stated purpose of these provisions "is to establish within the division [of Aging and Adult Services] the [Utah] long-term care ombudsman program for the aging ... and identify duties and responsibilities of that program ... in order to address problems relating to long-term care." Utah Code Ann. § 62A-3-201 (2000). In pertinent part, the ombudsman is to address the difficulties of the aging citizens of the state by assisting in asserting their civil and human rights as residents of care facilities through legal *1029means. See id. We similarly find this language too broad to constitute a clear and substantial specific public policy.

C. 42 U.S.C. § 1896r(c)(6), Utah Admin. Code R482-150-4 and 42 C.F.R. § 488.10

%23 Next, plaintiff contends that 42 U.S.C. § 18396r(c)(6), R432-150-4 of the Utah Administrative Code and 42 C.F.R. § 483.10 provide a clear basis for her public policy claim. First, 42 U.S.C. § 1396r, which governs the requirements care facilities must meet to obtain grants for medical assistance programs, provides that "[the nursing facility ... may not require residents to deposit their personal funds with the facility." 42 U.S.C. § 18396r(c)(6)(A)(i). Subsection (c)(6) includes guidelines for how care facilities are to manage resident funds when management of such funds has been authorized by the resident. Although not clearly stated, this section could imply that care facility residents have the right to manage their own financial affairs. In the past we have held that we may look beyond the provision in question to determine whether the motivating policy behind it constitutes a clear and substantial public policy. See, eg., Heslop, 839 P.2d at 837 (finding that the "general" purposes of the Utah Financial Institutions Act constitute a clear and substantial public policy). However, we conclude that a mere hint to such an underlying policy, as is the case here, is insufficient to constitute the type of clear and substantial policy necessary to establish an exception to the employment-at-will doctrine. Thus, we hold that 42 U.S.C. § 1396r(c)(6) does not rise to the level of a clear public policy.

24 Rule 482-150-4.400 of the Utah Administrative Code provides that "Itlhe resident has the right to maintain his financial affairs and the facility may not require a resident to deposit his personal funds with the facility." Utah Admin. Code R82-150-4400 (1994). Both of these sections plainly state that care facility residents have the right to manage their own finances.

125 Additionally, 42 C.F.R. § 483.10, governing resident rights that must be recognized by long-term care facilities, provides the most detailed and applicable provision. It states:

The resident has a right to a dignified existence, self-determination, and communication with and access to persons and services inside and outside the facility. A facility must protect and promote the rights of each resident, including ... the right to manage his or her financial affairs, and the facility may not require residents to deposit their personal funds with the facility.

42 C.F.R. § 488.10(c). This regulation explicitly states that care facility residents have the right to manage their own funds.

126 However, we have earlier pointed out that a clear public policy must be found in our statutes or constitutions, see Burton, 2000 UT 18 at ¶ 6, 994 P.2d 1261; Peterson, 832 P.2d at 1282; Hodges, 811 P.2d at 165-66; Berube, 771 P.2d at 1043, or judicial decisions, see Hodges, 811 P.2d at 165; Berube, 771 P.2d at 1043. The provision in 42 C.F.R. § 483.10 is an executive agency regulation that governs practice and procedure before federal administrative agencies. Similarly, R432-150-4.400 is a provision in the Utah Administrative Code.

127 Administrative regulations by their very nature are not "substantial" under our case law. The character of the public policy exception is that it furthers policies that "protect the public or promote public interest." Berube, 771 P.2d at 1048. Agency regulations are created by the agencies themselves and are tailored to govern specific ageney needs. The public policy exception must be " 'narrow enough in its scope and application to be no threat to employers who operate within the mandates of the law and clearly established public policy as set out in the duly adopted laws.!" Peterson, 832 P.2d at 1285 (Howe, A.C.J., concurring) (citation omitted). Thus, we hold that while 42 C.E.R. § 483.10 and R482-150-4.400 of the Utah Administrative Code expressly state that care facility residents have the right to manage their own funds, our case law does not allow for administrative regula*1030tions alone to constitute expressions of clear public policy.8

11 28 In so holding, we recognize that care facility residents are often at the mercy of the facilities in which they reside. Residents face many challenges as their mobility decreases and their ability to take care of themselves physically, mentally, and emotionally deteriorates. However, while we agree with plaintiff that "[the rights of nursing home residents, especially with the increasing longevity of Utah residents and the growth of Utah's population, are a matter of most significant public concern," we also recognize the reality that many residents, while remaining in control of their funds, voluntarily seek the assistance of family members or friends with their banking and spending decisions. That appears to have been the situation in the instant case. Such efforts by honest and helpful advisors should be encouraged and not discouraged by rigid, government-imposed requirements.

II. CONDUCT IMPLICATING A CLEAR AND SUBSTANTIAL PUBLIC POLICY

129 Because we do not find that a clear public policy has been enunciated by statute, constitutional provision, or judicial decision, we need not address whether plaintiff in notifying Ms. Mellen of the arrival of her funds, or calling Sharon at work and questioning the propriety of her removing those funds from Fairview West, constituted conduct in furtherance of that policy. Neither need we determine whether such conduct was causally related to plaintiffs termination. Thus, defendant did not violate the law in terminating plaintiff because of her involvement in the Mellen incident.

CONCLUSION

130 After careful review, we hold that defendant did not violate a clear public policy in terminating plaintiffs employment. We therefore affirm the court of appeals.

1 31 Associate Chief Justice RUSSON, Justice DURRANT, and Judge EYRE concur in Chief Justice HOWE'S opinion.

1 32 Having disqualified himself, Justice WILKINS does not participate herein; District Judge Donald EYRE, Jr. sat.

DURHAM, Justice,

dissenting:

133 I respectfully dissent. There is, I believe, abundant support for the proposition that a long-term care facility resident's right to manage her own funds is a matter of clear and substantial public policy. We are dealing here with one of our system's most fundamental and well-understood rights: the right of a legally competent person to control her property and manage her financial affairs.

11 34 This right is so fundamental and well-understood that it has not in fact been elaborated extensively in our constitution or legislative enactments; instead, it is a "given," a predicate for numerous related policies and protections in the law. These policies are reflected in the Utah Administrative Code, in federal statutes and regulations, in the Utah Probate and Criminal Code, in our own decision in In re Guardianship of Valentine, 4 Utah 2d 355, 294 P.2d 696 (1956), and in section 1 of the Utah Constitution.

1 35 This court has stated that public policy is "clear" when it is plainly defined in one of the following sources: (1) legislative enactments, (2) constitutional standards, or (3) judicial decisions. See Ryan v. Dan's Food Stores, 972 P.2d 395, 405 (Utah 1998). In Berube v. Fashion Centre Ltd., 771 P.2d 1033, 1043 (Utah 1989), the source of this trilogy, this court stated:

[We will construe public policies narrowly and will generally utilize those based on prior legislative pronouncements or judicial decisions, applying only those principles which are so substantial and fundamental that there ean be virtually no *1031question as to their importance for the promotion of public good.

Id. (emphasis added).

136 In Berube this court adopted for the first time a public policy exception to the at-will employment rule. We expressed caution about the limits of the exception and therefore identified possible sources of public policy that were unquestionably legitimate. Be-rube, however, was not intended to create an exclusive list of all possible sources as the language above reflects. Rather, it was an attempt to ensure that this court deferred to legitimate sources of public policy in the broader community instead of having a free rein to "invent" public policy on its own.

¶ 37 Three years after Berube, in Peterson v. Browning, 832 P.2d 1280 (Utah 1992), we explored the issue further:

We will not attempt here to define the full scope of the term "public policy" for the purposes of the exception to the at-will doctrine.... [The public policy exception applies in this state when the statutory language expressing the public conscience is clear and when the affected interests of society are substantial. The identification of clear and substantial public policies will require case-by-case development.

Id. at 1282 (emphasis added).

[ 38 This court is now faced with the question of whether to recognize a public policy exception protecting the right of a legally competent long-term care facility resident to manage her own financial affairs. I believe that the majority's view of the legitimacy of the public policy in question is mistaken. We can, and should, recognize administrative regulations as a valid source of Utah public policy for exceptions to the at-will employment doctrine; the regulatory process occurs through legislative delegation and under legislative oversight. It is undertaken by persons and entities with considerable expertise and knowledge regarding legislative intent. Furthermore, there is clear and substantial public policy supporting a long-term care facility resident's right to manage her funds in related federal regulations identical to those adopted by this state, in the Utah Probate and Criminal Code, in Utah case law, and in the Utah Constitution.

I. UTAH ADMINISTRATIVE CODE RULE 482-270-19(1) & RULE 432-270-10(5)(s)

€ 39 Rule 482-270-10(5)(s) of the Utah Administrative Code expressly sets forth the rights of long-term care facility residents. Among other rights, residents are granted "the right to manage and control personal funds, or to be given accounting of personal funds entrusted to the facility." Utah Admin.Code R482-270-10(5)(s). The Utah Administrative Code further states, "[rlesidents have the right to manage and control their financial affairs. The Facility may not require residents to deposit their personal funds or valuables with the facility." Utah Admin.Code R432-270-19(1).

140 The majority opinion acknowledges this language but fails to regard it as an expression of public policy because "administrative regulations by their very nature are not 'substantial.'" First, I disagree with the notion that the administrative regulatory process is, by definition, not substantial. More importantly, however, it is the content of the regulation that should be examined for substance, not merely its location in statutory or regulatory language. Ignoring administrative regulations merely because they are not "legislative enactments" overlooks the reality of the process of statutory delegation to administrative agencies and the hugely significant role that administrative regulation plays in our economy and society.

41 Other states have recognized administrative regulations as a legitimate source of public policy. Recently, the California Supreme Court held that administrative regulations could be a source of fundamental public policy exceptions to the at-will employment doctrine. See Green v. Ralee Eng'g Co., 19 Cal.4th 66, 78 Cal.Rptr.2d 16, 960 P.2d 1046 (1998). In Green, the California Supreme Court explained:

[OJne of the primary reasons for requiring the public policy that gives rise to a wrongful termination action to have a basis in either constitutional or statutory provisions is to limit judicial policymaking lest [courts] mistake their own predilections for *1032public policy which deserves recognition at law. . .. [When courts discover public policy in regulations enacted under statutory authority, they are not mistaking] their own predilections for public policy, but rather are recognizing a public policy that the Legislature has formulated and the executive branch has implemented.

Id. at 1054 (alteration in original) (internal quotations and citation omitted).

142 Other states have accepted administrative regulations as a source of public policy. See Saffels v. Rice, 40 F.3d 1546, 1550 (8th Cir.1994) ("An at-will employee may state a claim under Missouri's public policy exception when an employer's act of discharging the employee is violative of a statute, a regulation based on a statute, or a constitutional provision."); Adolphsen v. Hallmark Cards, Inc., 907 S.W.2d 333, 337 (Mo.Ct.App.1995) (stating that regulations governing public policy will often relate to a clear mandate of public policy); Pierce v. Ortho Pharm. Corp., 84 N.J. 58, 417 A.2d 505, 512 (1980) ("The sources of public policy include legislation; administrative rules, regulations or decisions; and judicial decisions."); Yetter v. Ward Trucking Corp., 401 Pa.Super. 467, 585 A.2d 1022, 1026 (1990) ("The sources of public policy ... include legislation; administrative rules, regulation, or decision; and judicial decision." (citation omitted)).

143 This court should follow such well-reasoned authority and acknowledge administrative regulations as a legitimate source of public policy in Utah. Administrative regulations may in some cases be even more authoritative than statutory language because the agencies that draft them are more aware of the issues facing the organizations being regulated and the needs of individuals being protected. It is entirely clear, in my view, that the subject administrative regulations reflect the values of the state of Utah concerning the fundamental right to control one's property and to manage one's financial affairs when one is a competent resident of a long-term care facility.

IL 42 U.S.C. § 1896r(c)(6) & 42 C.E.R. § 488.10

44 In addition to rule 482 of the Utah Administrative Code, we have further evi-denee of public policy in the virtually identical federal regulatory language enacted pursuant to 42 U.S.C § 1896r(c)(6). See 42 C.F.R. §$ 488.10. In Peterson v. Browning, 832 P.2d 1280 (Utah 1992), this court held that federal law, and even the law of other states, is a valid source of public policy:

Persons who are terminated from their employment because they refuse to engage in illegal activities that implicated clear and substantial Utah public policy considerations should be protected regardless of whether the applicable law is that of Utah, the federal government, or another state.

Id. at 1283. We required in Peterson that there be a connection between the Utah public policy and the law from another jurisdiction. "Although many state and federal laws will reflect Utah public policy, and may, in fact, provide a source of Utah public policy, a plaintiff must establish the connection between the law violated and the public policies of Utah." Id.

11 45 A review of the federal statutes and regulations concerning long-term care facility residents cited above establishes the connection between the federal regulations and the public policies of Utah. Under 42 U.S.C. § 18396r(c)(6), "[the nursing facility ... may not require residents to deposit their personal funds with the facility" 42 U.S.C. § 18396r. Subsection (c)(6) of the statute gives long-term care facilities guidelines for managing residents' funds when the facilities are granted authority to do so. The underlying policy of 42 U.S.C. § 1896r(c)(6) is clearly to protect the rights of long-term care facility residents, including their right to manage their funds. There would be no reason for these guidelines without the fundamental premise that residents have the right to manage their own financial affairs. Contrary to the majority opinion, I believe this federal statute does more than "hint to such an underlying policy." Rather, the principle the statute embodies is so fundamental it requires no more explicit reference; it easily rises to the level of the clear and substantial *1033public policy necessary to establish an exception to the employment-at-will doctrine. Virtually no one-lawmaker, judge, or private citizen-would be willing to controvert the notion that competent persons cannot be deprived of their right to control their property, even if they live in a long-term care facility.

'I 46 The language of the related regulation contained in 42 C.F.R. § 483.10 (identical to that in rule 432-270-19) is directly tied to the statutory purpose of 42 U.S.C. § 1896r. It states:

A facility must protect and promote the rights of each resident, including ... [tlhe resident has the right to manage his or her financial affairs, and the facility may not require residents to deposit their personal funds with the facility.

42 C.F.R § 488.10(c)(1) (emphasis added).

147 We made clear in Peterson that we will accept federal law when it has a connection to a Utah public policy or value. The connection is evidenced here by the nearly word-for-word replication of this federal rule by the Utah Administrative Code.1

III. UTAH CODE ANN. § 75-5401

{48 Further support for the public policy in question is found in the Utah Probate Code. Section 75-5-401 deals with protective proceedings for minors and disabled persons. It states:

(2) Appointment of conservator or other protective order may be made in relation to the estate and affairs of a person if the court determines that the person: (a) is unable to manage the person's property and affairs effectively for reasons such as mental illness, mental deficiency, physical illness or disability, chronic use of drugs, chronic intoxication, confinement, detention by a foreign power or disappearance; and (b) has property which will be wasted or dissipated unless proper management is provided or that funds are needed for the support, care and welfare of the person or those entitled to be supported by the person and protection is necessary or desirable to obtain or provide funds.

Utah Code Ann. § 75-5-401(2)(a), (b) (emphasis added). This section provides a structure to ensure due process for allegedly disabled persons before they may lawfully be deprived of their right to control their property. This is clear evidence that the Utah legislature recognizes the right to control property as an important and fundamental value. This section explicitly protects the rights of all persons to manage their "property and affairs" unless and until they are determined by a court to be incompetent to do so. It is, in my view, an entirely adequate legislative source for the public policy ensuring the right to manage one's property.

IV. UTAH CODE ANN. § 76-5-111

149 As the majority points out, we have held that prohibitions contained in our criminal code reflect public policy. See Fox v. MCI Comm. Corp., 931 P.2d 857, 860 (Utah 1997). Section 76-5-111 of the Utah Code deals with the abuse, neglect, or exploitation of a disabled or elder adult. In part, it states:

(4)(a) A person commits the offense of exploitation of a disabled or elder adult when the person: (i) is in a position of trust and confidence, or has a business relationship, with the disabled or elder adult and knowingly, by deception or intimidation, obtains or uses, or endeavors to obtain or use, the disabled or elder adult's funds, credit, assets, or other property with the intent to temporarily or permanently deprive the disabled or elder adult of the use, benefit, or possession of his property, for the benefit of someone other than the disabled or elder adult.

§ 76-5-1(1(4)(a)(i))

150 I do not suggest that this statute demonstrates that criminal conduct occurred in this case. It does, however, plainly criminalize acts that "temporarily or permanently deprive" an elder adult of the "use, benefit, or possession of his property." Utah Code *1034Ann. § 76-5-111(4)(a)(@). It is noteworthy that the criminal statute explicitly mentions "deception" as a prohibited means of depriving older persons of the "use, benefit, or possession" of their property. Id. Thus, this section provides a further illustration of the fact that the state of Utah has a well-defined public policy for the safeguarding of the property of older adults and their control thereof.

V. IN RE GUARDIANSHIP OF VALENTINE

151 For over forty-five years, this court has recognized a citizen's right to control his or her financial affairs. In a case involving a petition for the appointment of a guardian of the property of an alleged incompetent, this court stated, "[the right of every individual to handle his own affairs even at the expense of dissipating his fortune is a right jealousy guarded and one which will not be taken away except in extreme cages." In re Guardianship of Valentine, 4 Utah 2d 355, 294 P.2d 696, 702 (1956) (emphasis added).

1 52 In this case, Sharon Mellen, Ms. Mel-len's daughter-in-law, asked Ms. Merkeley, Fairview's management person in charge of residents' funds, not to inform Ms. Mellen of the arrival of a check from the Veteran's Administration. - According to Fairview, Sharon Mellen wanted to tell Ms. Mellen personally about the arrival of the check. Apparently, Sharon Mellen wanted to proceed in this manner because she planned to buy Ms. Mellen a new wheelchair with this money but knew she would have to convince Ms. Mellen to agree to the purchase. Fair-view argues that it was proper for Fairview's staff to withhold this information from Ms. Mellen because Sharon Mellen was authorized to handle Ms. Mellen's money.

153 It is undisputed that Ms. Mellen signed a document stating: "I hereby certify that Sharon Mellen has authorization to assist me in managing my personal needs allowance funds." (Emphasis added.) However, the language of this document does not in any way authorize Sharon or Fairview to deprive Ms. Mellen of her right to manage her personal finances by concealing the whereabouts of her funds or withholding information from her. As stated in In re Guardianship of Valentine, the right of every individual to manage his or her own financial affairs is jealously guarded. Id. at 702. It is impossible for one to manage one's financial affairs if one is purposefully deprived of the knowledge of relevant information, such as the arrival or deposit of a personal check. Furthermore, according to the language of section 75-5-401, Sharon cannot handle Ms. Mellen's money, or direct Ms. Mellen on how to spend her money, without Ms. Mellen's knowledge and consent, unless Ms. Mellen has been declared incompetent. The written document relied on by defendants does not constitute a relinquishment by Ms. Melien of her right to manage her financial affairs, nor has Ms. Mellen been declared incompetent through the proper procedures.

154 It is important to note that Ms. Merkely and Ms. Maroney received written reprimands from Fairview for failing to tell Ms. Mellen about her check. In fact, a new policy was instituted by Fairview after this incident requiring that residents be informed of all their incoming funds, regardless of who assists them with their financial affairs. This change was, I submit, an acknowledgment by Fairview of what the laws and public policy of Utah require.

VI. ARTICLE I, SECTION 1 OF THE UTAH CONSTITUTION

1 55 Finally, I disagree with the majority's rejection of article I, section 1 of the Utah Constitution as a source for the public policy at issue here. That section declares that "[all men have the inherent and inalienable right to ... acquire, possess and protect property." The majority claims that while these provisions "protect the right to acquire, possess, and protect property, they do not enunciate the narrow type of policy envisioned by case law creating the public policy exception." - It is difficult to imagine a right more fundamental and more well understood than the right to "protect" and manage one's own property, including one's financial affairs. Unlike the majority, I believe that public policies so broad and unquestioned as these are in fact enforceable through an ex*1035ception to the at-will employment rule. This is particularly so where the Utah legislature, its regulatory agencies, this court, and the federal government have all incorporated the policy into law. Constitutional rights by their nature are fundamental, and I am at a loss to understand the majority's rejection of the right to "acquire, possess and protect property" as a reflection of universal public policy in the state of Utah. For the foregoing reasons, I would reverse.

OPINION BY JUSTICE CLEO E. POWELL

Frances L. Robinson ("Robinson") appeals from the Circuit Court of Prince William County's final order granting summary judgment in favor of the Salvation Army and Joel DeMoss (collectively, "the Salvation Army") and dismissing Robinson's claim of common law wrongful termination for refusing to commit fornication (Code § 18.2-344 ). On appeal, Robinson asks this Court to reverse the decision of the trial court, find that Code § 18.2-344 provides a valid basis for stating a wrongful termination claim, and remand the case for further proceedings.

I. BACKGROUND

Robinson was an at-will employee of the Salvation Army for three years, until she was fired in June 2012. Robinson thereafter filed a wrongful termination suit alleging that she was terminated for refusing requests from DeMoss, her store manager, to engage in fornication. Robinson alleged DeMoss "regularly made inappropriate comments when he was alone with [her]." Robinson also alleged DeMoss inappropriately inquired about her romantic life; suggested he wanted to sleep at her home; asked whether she was a "freak" or wanted to "freak" with him; commented on her cleavage; made hand gestures indicating he wanted to slap Robinson on the buttocks; and told employees that Robinson was "prime rib," had let him "nibble on her ear," and made comments to Robinson about another female employee's attendance at a party commenting that "the only open thing[s]" at a party "were [the employee's] legs." Robinson played secret recordings of her conversations with DeMoss *579to Evelyn Sears, the Human Resources officer. Shortly thereafter, Robinson was terminated without explanation.

In its motion for summary judgment, the Salvation Army asserted Robinson could not prove she was fired for refusing to commit a violation of Code § 18.2-344 because the Court ruled that statute was unconstitutional in Martin v. Ziherl , 269 Va. 35, 42-43, 607 S.E.2d 367, 370-71 (2005). In response, Robinson argued that there remained a factual dispute as to whether DeMoss conditioned her employment on having sex with him and, therefore, impliedly offered her a continuing paycheck in exchange for sex. She contended that the fornication statute remained viable as a basis for her common law wrongful termination claim, despite the holding in Martin.

The trial court granted the motion for summary judgment and dismissed Robinson's amended complaint with prejudice, holding:

Termination of employment for refusing to engage in sexual activity in violation of [Code § 18.2-344 ] was at one time grounds for a Bowman1 claim. However, the statute has since been held unconstitutional by the Supreme Court of the United States and by the Supreme Court of Virginia. Lawrence v. Texas , 539 U.S. 558 [123 S.Ct. 2472, 156 L.Ed.2d 508] (2003) ; Martin v. Ziherl , 269 Va. 35, 607 S.E.2d 367 (2005). Martin explicitly struck down [Code] § 18.2-344, and implied that sexual activity can be outlawed only if it "involve[s] minors, non-consensual activity, prostitution, or public activity." 269 Va. at 42, 607 S.E.2d at 371 (citing Lawrence , 539 U.S. at 564 [123 S.Ct. 2472] ).

....

[Robinson's] theory here is similar: while unconstitutional, the statute is still on the books, and accordingly, still represents the public policy of Virginia. However, I view the question differently: is it the public policy of Virginia to enforce an unconstitutional statute, by classifying-as a tort-the refusal to engage in conduct barred by an unenforceable statute, in light of the Supreme Court of Virginia holdings that parties have a right to engage in that same conduct? I do not find that it is. As a result, the claim based on the alleged request to violate [Code] § 18.2-344 is dismissed for this reason.

(Some citations omitted). This appeal followed.

II. ANALYSIS

Despite our holding in Martin, Robinson asks the Court to find that Code § 18.2-344 provides the basis for a valid public policy ground to support her Bowman claim for wrongful termination. We disagree.

The Court has recognized an exception to the employment-at-will doctrine for a violation of public policy. Bowman v. State Bank of Keysville , 229 Va. 534, 331 S.E.2d 797 (1985). "[I]n our previous cases dealing with Bowman -type exceptions to the employment-at-will doctrine, this Court has consistently characterized such exceptions as 'narrow.' " City of Virginia Beach v. Harris , 259 Va. 220, 232, 523 S.E.2d 239, 245 (2000) (quoting Lawrence Chrysler Plymouth Corp. v. Brooks , 251 Va. 94, 98, 465 S.E.2d 806, 809 (1996) ). One such exception specifically recognized in Bowman is that an at-will employee who is discharged based on a refusal to engage in a criminal act may have a valid cause of action for wrongful discharge.

Robinson seeks to base her cause of action on a public policy argument underlying Code § 18.2-344. Code § 18.2-344 provides that, "[a]ny person, not being married, who voluntarily shall have sexual intercourse with any other person, shall be guilty of fornication, punishable as a Class 4 misdemeanor." In Mitchem v. Counts , 259 Va. 179, 190-91, 523 S.E.2d 246, 252-53 (2000), we recognized the exact same cause of action on which Robinson rests her claim. However, in 2005, we addressed the issue again in Martin, where we applied the Supreme Court's rationale in Lawrence v. Texas , 539 U.S. 558, 577-78, 123 S.Ct. 2472, 156 L.Ed.2d 508 (2003) (holding that a state statute criminalizing sodomy as applied to homosexuals was unconstitutional), *580and held that Code § 18.2-344 violated the Due Process Clause of the Fourteenth Amendment as it applies to private, consensual conduct. We further clarified our ruling, noting that

[i]t is important to note that this case does not involve minors, non-consensual activity, prostitution, or public activity. The Lawrence court indicated that state regulation of that type of activity might support a different result. Our holding, like that of the Supreme Court in Lawrence, addresses only private, consensual conduct between adults and the respective statutes' impact on such conduct. Our holding does not affect the Commonwealth's police power regarding regulation of public fornication, prostitution, or other such crimes.

Martin , 269 Va. at 42-43, 607 S.E.2d at 371.

Robinson argues that Martin did not find that Code § 18.2-344 was unconstitutional as to non-consensual conduct between two adults in the workplace and, therefore, demands regarding such conduct constitutes a violation of public policy under Bowman. "Clearly, the declaration that the holding did not affect the Commonwealth's police power regarding other crimes is the essence of an as-applied analysis of constitutionality of the statute. After Martin, Code § 18.2-344 still has efficacy as noted; consequently, it was not facially invalidated by our opinion." McDonald v. Commonwealth , 274 Va. 249, 258, 645 S.E.2d 918, 923 (2007).

While Code § 18.2-344 remains in the Code, it only remains valid in the limited application as outlined in Martin and its remaining scope does not provide support for a Bowman exception for a violation of public policy wrongful termination claim based on private consensual sexual activity between adults. In order for Robinson's claim to succeed, the Court would have to determine from the record before us that Robinson was encouraged to engage in "public fornication, prostitution, or other such crimes" by DeMoss.2 Id. The record, however, does not suggest in any way that the alleged conduct included a request for any kind of public sexual activity whatsoever. While there are multiple allegations that DeMoss made inappropriate comments and gestures to Robinson while her supervisor, nothing in the record shows that he asked her to participate in any kind of public sexual activity that would constitute a criminal act of public fornication.3

Robinson's reliance on VanBuren v. Grubb , 284 Va. 584, 733 S.E.2d 919 (2012) is misplaced. VanBuren does not support her contention that Code § 18.2-344 remains a basis for wrongful termination claims under circumstances where a supervisor coerces an employee's consent. Instead, VanBuren answered a narrow certified question from the United States Court of Appeals for the Fourth Circuit:

Does Virginia law recognize a common law tort claim of wrongful discharge in violation of established public policy against an individual who was not the plaintiff's actual employer, such as a supervisor or manager, but who participated in the wrongful firing of the plaintiff?

VanBuren , 284 Va. at 587, 733 S.E.2d at 920. Moreover, that question was posed and answered in the context of an allegation of adultery, under Code § 18.2-365, and lewd and lascivious cohabitation, under Code § 18.2-435, not Code § 18.2-344. VanBuren references Mitchem (decided five years prior to Martin ) in passing as an example of a circumstance where a valid criminal law could provide a basis for a cause of action based on public policy because VanBuren's discharge was

based on the employee's refusal to engage in a criminal act. Mitchem v. Counts , 259 Va. 179, 190, 523 S.E.2d 246, 252 (2000) (holding discharge based upon refusal to engage in fornication and lewd and lascivious *581cohabitation to be against public policy). VanBuren similarly alleges that her discharge resulted from her refusal to engage in the criminal acts of adultery and lewd and lascivious cohabitation. There is no question that VanBuren has stated a cognizable wrongful discharge claim against her employer, Virginia Highlands.

Id. at 590, 733 S.E.2d at 922. VanBuren is inapposite because the claim there was based on a valid criminal act, whereas here Robinson bases her claim on an act that has been decriminalized. To the extent that there is any confusion, VanBuren's reference to Mitchem was not intended to overrule Martin as to the continued validity of Code § 18.2-344.

III. CONCLUSION

Following the rationale of Lawrence and Martin, Code § 18.2-344 does not support a public policy Bowman claim for wrongful termination in this case. Because we have ruled that Code § 18.2-344 is unconstitutional as applied to private consensual sexual activity between adults, demands regarding such activity can no longer provide the basis for a valid allegation of wrongful termination whether the employee accedes to the demands or is terminated for refusing the demands. Robinson has not alleged any facts to show that she was asked to engage in any public sexual activity. Accordingly, we find that the trial court did not err in granting the Salvation Army's motion for summary judgment and dismissing Robinson's complaint with prejudice. For the foregoing reasons, we will affirm the judgment of the trial court.

Affirmed.