Debate as to in-house counsel duties during internal investigation

Here is a link to an interesting debate as to the duties of an in-house counsel during an internal investigation based on this hypo:

Imagine that in-house counsel is conducting an internal investigation and speaks with an employee whose conduct may have been unlawful. The employee does not have her own counsel, so the in-house lawyer makes clear to the employee that the lawyer represents the company and not the employee herself. The employee is reluctant to speak with the lawyer and the lawyer then says to the employee, "You are subject to the company's employment policies, which require you to speak with me about this matter." Is the lawyer's conduct a violation of the rules?