In Washer v. Bank of America (1943) 21 Cal.2d 822, the National Labor Relations Board ordered plaintiff's former employer, a bank, to reinstate him. An officer of the bank made the following statement: "'We cannot see how this institution could possibly reinstate anybody who had admitted he had falsified his expense account, who has been guilty of flagrant insubordination.'" (Washer v. Bank of America, supra, at p. 825.) While the statement did not literally state that plaintiff had falsified expense accounts or been guilty of insubordination or even mention plaintiff by name, the issue was whether "by its natural and probable effect upon the hearer or reader, the statement would tend to injure the appellant in his occupation . . . ." (Id. at p. 828.)