Did James Comey's document leaks violate the FBI employment agreement?

Paragraph 2 states that all materials acquired in connection with an employee’s official duties are property of the U.S. government and that such materials must be surrendered to the FBI upon an employee’s separation from the agency. Paragraph 3 states that employees are prohibited from releasing “any information acquired by virtue of my official employment” to “unauthorized individual[s] without prior official written authorization by the FBI.” Paragraph 4 of the agreement requires FBI employees, prior to disclosing or publishing information acquired during their employment, to submit the information to FBI authorities for review to determine whether it is authorized for public release.

So if Comey followed protocol and surrendered all government property, including the memos he produced in his capacity as an FBI employee, it would have been impossible for him to provide the memos to his friend. The fact that he was able to provide hard copies of the memos to both his friend and special counsel Robert Mueller suggests that Comey did not surrender them to authorities as required by the FBI employment agreement.