Sunday, August 23, 2020
Friday, August 21, 2020
Essay --
10. In around 250 words, portray the status of lady in Egyptian culture. Think about the accompanying: Content: â⬠¢ Jobs and assignments for lady In Egyptian culture, ladies were given acceptable standing status in the home and were usually obliged in mud block homes, which were extremely helpful in completing different works in the home, for example, making the great and other stuff. The ladies much of the time visited the commercial center to acquire things, which were required for every day life in Ancient Egypt. â⬠¢ Positions of obligation regarding lady In Egyptian culture, ladies were much on the higher side when related to different realms around Ancient Egypt. In collaboration with sexual orientation which had a place with a similar class that will be dealt with the same given the conditions of Ancient Egypt society. Let along Women in Ancient Egypt were special to all the given rights, which men had. Be that as it may, ladies reserved the option to oversee property, which had a place with had a place with them, and in the event that she wished, she could offer the property to purchase and property she needed without there being a boundary between them. All the more critically a large number of the ascribes to perceive the noteworthy job of ladies in Ancient Egypt society â⬠¢ Rights of marriage and separation In Egyptian culture, one of the numerous rights that had a place with ladies was whether they decided to wed. In any case lady in Ancient Egypt were not essential wed. Endless ladies who decided to wed did as such at a significant youthful age. â⬠¢ Unique female pioneers Numerous ladies in Ancient Egypt were relatively revolutionary. Hatshepsut was the primary ladies to have held a position as pharaoh and afterward started her standard as a pharaoh in 1,500 B.C.E. Furthermore, Hatshepsut dealt with her kin just as built spot of love to the divine beings notwithstanding o... ... Nile River. The immersing time frame persevered from June to September, storing on the stream's banks a covering of mineral-rich residue ideal for rising harvests. In this way the floodwaters had withdrawn; Egypt anticipated little precipitation, so agronomists trusted on the Nile to water their harvests. Old Egyptians refined emmer and grain, just as in excess of a couple of other oat particles, which were all used to make the two significant food staples of bread and strong. Papyrus emanant on the banks of the Nile River and was utilized to deliver paper. â⬠¢ The progression of the pharaoh In any case, the mark of Pharaoh was acquired, subsequently perfect that it was passed down from father to most established child. All the more critically, there were voluminous conditions where the replacement would be killed or even pass on by some coincidence just as have some else have his spot.
Sunday, July 12, 2020
College Essay Topics - How to Choose the Best Essay Topics
College Essay Topics - How to Choose the Best Essay TopicsThe essay topics for college English writing courses can be confusing, because each topic must address different characteristics of the student's writing style. Several students, however, are tempted to use English essays that are too broad or are written in an overly technical manner. As a result, students who are caught in this trap usually do not complete the writing required for their college English course.One of the most common problems with essay topics for college English writing courses is the misconception that writing should be more technical or specific than it needs to be. Since all people are different, writing needs to address every aspect of writing style, even though the broadest statement that can be written about any subject is also the most vague. In this article, I will discuss some of the most important aspects of writing that can make it more successful.Writing is a process of expression is difficult to achieve if it is not part of the learning process. However, if writing is taught in the beginning of any course, students will naturally choose writing topics that would help them to express themselves. Once the writers have a plan in place, the difficulty of writing will drop considerably.The basic concept of writing is that it should be informative and entertaining. In fact, sometimes writers tend to stray away from this important factor. By concentrating on only the presentation of facts, information and ideas, the writers are making a crucial mistake. It is easier to retain the material if it is presented in a fun and creative way.When starting out on the college English writing course, many students write about topics that are more exciting and difficult than they really are. In this case, the material will be much harder to understand and retain than the more straightforward topics that would be best suited for the subject matter of the course. Instead of writing about topics that are too difficult or too exciting, it is important to choose topics that fit well into the learning process.College students who are in college for the first time often find that they cannot remember the topic of their college essay topics very easily. While this is a natural tendency, the more experienced students find that writing essays at the end of college is much easier. The process has become more automatic than the ability to recall the subject matter.One of the most common mistakes made by students on essay topics for college English writing courses is choosing the wrong topic. They fail to choose the topic based on its importance, or on how easy or hard it is to understand, or even on whether it will give them a good grade. Students should choose the topic that would be easiest to learn and understand.After the topic is chosen, students should brainstorm about the style of writing required to cover that topic. Many students make the mistake of using difficult or excit ing language that doesn't match the content of the essay. This strategy will not serve the writer well in the future, since no matter how interesting the topics are, it is often impossible to convey the ideas through difficult language.
Wednesday, May 20, 2020
Human Resources Recruitment - 2739 Words
Attracting top talent to an organization has never been more difficult, are the words of senior recruiter Hamish Davidson of Veredus Executive Resourcing chairman who has more than 18 years experience. Well developed leadership skills, the ability to shift attitudes and behaviors, the capacity to exert effective influence and work through others, the talent for successful partnership working and, most importantly, having the potential to adapt quickly to internal and external change, and to get that change owned and embedded in an organization. These are the core competencies sought by organizations the world over, regardless of sector, industry, specialism, background or level. Because there is a relatively small pool of talent withâ⬠¦show more contentâ⬠¦www.hrcouncil.ca External recruitment involves staffing outside of the organisation. This search can take place in local, regional or international labour markets, depending on numbers, skills, competencies and experiences required, the potential financial costs involved and the perceived benefits involved to the organisation concerned. (Holden: Claydon 2004) Print advertisements are the method where the job is posted in a newspaper or professional journal for public viewing. One condition that must be considered with print advertisements is that they will impact on a number of applicants so it should be presented in a general tone. Its advantage is that it can reach a large audience in a specific area and its disadvantage is that the ad may receive a significant number of applications from unqualified candidates. www.hrcouncil.ca Also, to attract applications a company should attend career fairs and presentations. This caters mainly to soon to be graduates who are more likely to be unclear of their next step in the path of career choice and will be fresh off the press, thus easily moulded to fit the organisation. Presentation of a company, its aims and objectives are prepared to appeal to the interests of this group. RECRUITMENT PROCESS This is the actual procedure in which organisations embark on to recruit candidates. Departments may useShow MoreRelatedHuman Resource Planning Recruitment7002 Words à |à 29 PagesHuman Resource Planning Recruitment Chapter Summary This chapter describes the process an organization uses to plan and recruit so that there will be adequate human resources. The steps described are linking business strategies to future needs, forecasting labor demand and supply, determining in what positions there will exist a labor shortage or surplus, setting goals regarding future human resource needs, and identifying strategies to solve the problems of shortages and/or surplusesRead MoreRecruitment and Human Resources Management1639 Words à |à 7 PagesRecruitment According to Edwin B. Flippo, ââ¬Å"recruitment is the process of searching the candidates for employment and stimulating them to apply for jobs in the organisationâ⬠. Recruitment is the activity that links the employers and the job seekers. In other words, it is a process of finding and attracting capable applicants for employment. The process begins when new recruits are sought and ends when their applications are submitted. The result is a pool of applications from which new employeesRead MoreA Research Of Human Resources Recruitment1997 Words à |à 8 PagesResearch of Human Resources Recruitment Process And Applications in Organisations Abstract: This paper discuss the importance of human resources recruitment in the context of conceptual frameworks based on a brief research of past literatures, found leading organisations (Enterprise Rent-a-Car and British Gas) apply these concepts in the real world to successfully achieve their business objectives. This report concludes that the importance of human resources recruitment processRead MoreHuman Resource Management : Recruitment And Selection933 Words à |à 4 PagesThe focus of recruitment and selection has been how to match the capabilities and inclinations of potential applicants with the requirements and rewards of a given job. It can be said that recruitment and selection represent one of the most important human resource management functions which can serve as the basis for a sustainable competitive advantage over contenders. This implies that the success and even the survival of a company generally depend on the caliber of the workforce. The best prospectiveRead MoreHum an Resource Recruitment And Selection Of Employees2014 Words à |à 9 Pages1. Introduction In this paper, human resource recruitment and selection of employees will be discussed. The main focus will be on a Kenyan company, CMC Holdings Ltd (CMC), which is one of the largest auto and equipment dealers in East Africa. The company has over 3,000 employees with a head office in Nairobi and has branches in eight cities and subsidiary companies in Uganda, Tanzania and South Sudan. The company mission statement states that CMC is:- Committed to providing exceptional customerRead MoreRecruitment Selection - Human Resource Management3985 Words à |à 16 Pages4 1.1 What is HRM? 4 1.1.1 Significant HRM functions 4 1.2 Why recruitment amp; selection is an important part of HRM 4 1.3 Consequence of poor selection 6 2.0 Critical nature of Recruitment amp; Selection 6 2.1 Recruitment 6 2.1.1 Recruitment process (Fisher et al., 2006) 6 2.1.2 Recruitment objectives 7 2.1.3 Recruitment methods 7 2.1.3.1 Internal Recruitment method 7 2.1.3.2 External Recruitment method 7 2.2. Selection 8 2.2.1 Selection policy 8 2.2.2 SelectionRead MoreHuman Resource Management - Recruitment and Selection Process7389 Words à |à 30 Pages HUMAN RESOURCE MANAGEMENT: RECRUITMENT AND SELECTION PROCESSES BADLI SHAH MUHAMAD SALLEH 6091010491 AZWAN ISMAIL 6101025931 JUDE E. EDEIGBU 6093015151 MOHSEN ALI SALEH 6101025881 UNISEL GRADUATE SCHOOL OF MANAGEMENT (UGSM) SEKOLAH SISWAZAH PENGURUSAN UNISEL Table of Contents 1 PART 1: INTRODUCTION OF THE ORGANIZATION 4 2 PART 2 (a): ORGANIZATIONAL STRUCTURE 5 2.1 INITIAL ORGANIZATIONAL STRUCTURE 5 2.2 CURRENT ORGANIZATIONAL STRUCTURE 6 3 PART 2 (b): HUMAN RESOURCE MANAGEMENTRead MoreHuman Resources Planning, Recruitment, And Selection Essay2234 Words à |à 9 Pagesof senior leadership and the Human Resources Managers to take care of their employees and ensure that they are being treated with dignity and respect. HRM must take into consideration the Equal Employment Opportunity (EEO) and Affirmative Action in order to protect employees from discrimination. HRM must consider human resources planning, recruitment, and selection when matching the right candidate with the right position. HRM must find ways of providing human resources development to ensure employeesRead MoreThe Role Of Human Resource Planning : Selection And Recruitment789 Words à |à 4 PagesTraditional People Resourcing (Selection and Recruitment) In todayââ¬â¢s modern working world, companies have increasingly become more competitive in its people resourcing techniques (Delaney Huselid, 1996; Ordiz Fernà ¡ndez, 2005). Over the last decade, leadership teams have shifted its approach and therefore, invested significant time and resources on Human Resource Management (Boselie et al., 2005; Cassell et al., 2002). The role of Human Resources has now become a key integral business functionRead MoreRecruitment Is A Core Function Of Human Resource Management1994 Words à |à 8 Pagespresent a set of useful advice and meaningful insights on the recruitment focus for organizations in the technology industry. It will also provide some facts and explanations on the areas they need to look at, processes they need to consider, as well as pitfalls, issues and ideas relevant to this practice. The report aims to assist organizations and managers to improve or develop on this particular area of recruiting process. Human Resource Management (HRM or HR) is a function in an organization designed
Wednesday, May 6, 2020
Morality in Victorian and Neo-Victorian Novels Essay
Morality in Victorian and Neo-Victorian Novels An essay on Jane Eyre, The Mill on the Floss, The French Lieutenants Woman, Possession and The Dress Lodger The Victorian era is one bound to morality. Morality is also defined through the traditional and religious standards that structure the way of life for many Victorians. Morality is defined as the proper principles and standards, in respect to right and wrong, which are to be practiced by all humanity. Ideally, these include obtaining decent careers, being sexually inactive prior marriage, and being faithful when married. Who defines proper behaviour for Victorians? Mainly, the idea of what is right or wrong is based upon the traditions practiced by ones forefathers, along withâ⬠¦show more contentâ⬠¦However, these issues are presented in their immoral state to display the moral right. This is furthered enhanced by the difference between the social classes and genders; what is genuinely wrong for one class or gender is not always wrong for the other. The issue of class warfare is presented through many aspects, mainly occupation and sexuality. Surprisingly, both aspects intertwine and reflect Victorian ideas about such issues. Both authors chose to demonstrate the expected morality within labour (if one is so unfortunate to possess one) through the immoral characters of prostitutes and the men who come to them. Contradicting Victorian notions, Neo Victorian novels present prostitutes as not rootless social outcasts but as poor, independent, working women - they are unfortunate females just trying to make ends meet. They are primarily young, single women, few of whom support illegitimate children. Prostitution offers young women more independence, economically and socially, than would otherwise be available to them. The only condition that seems to dispose women to prostitution is economic relocation. However, no matter the independence or money, prostitutes are seen as necessary evils because they offer their services willingly t o different men, many whom are from the higher class. The feelings commonly thought of as Victorian attitudes towardsShow MoreRelatedAnalysis Of Tipping The Velvet By Sarah Waters1475 Words à |à 6 Pagesoften-transgressed representations. Specifically looking at this representation in Tipping the Velvet by Sarah Waters a Neo-Victorian fiction novel, Analysing how the performance and act of a male impersonation is created represented and how the act is received. Neo ââ¬âVictorian literature is most commonly seen as contemporary fiction or culture, which is usually set between 1837 and 1901- during the Victorian era, or it is highly influenced by this period. In the years that followed 1901 and up until this very dayRead MoreThe development of the novel in the 20th century1416 Words à |à 6 Pages4. The novel from 1881 to 1914 Over the eighteen eighties there was a split in fiction. The first indication towards it was Henry James essay The Art of Fiction (1884), which referred to the novelists calling as a Sacred office. Besides, there appeared a stratification of fiction due to primary education for all. Parallel to this, novelists saw themselves apart from the public, as dedicated men. This new modern conception involved dignity and a sense of glory. Another change was from the three-volumeRead MoreMorality And Ethics On Transhumanism1796 Words à |à 8 Pages Morality and Ethics on Transhumanism A Concentrated Look at The Diamond Age Stephan Ehr Science Fiction HU 424 April 17, 2015Ã¢â¬Æ' Envision a world where nano sized robots can burrow themselves into your skin just by touching something or perhaps explode within you on command. Consider perchance, a world were humans have collective thoughts and can generate the processing power of a super computer. Sounds like something out of an awesome dream or a nightmare, depending on how you perceive it.Read MoreEssays on Vehicular Pollution3726 Words à |à 15 Pages When John Williams created the sound of the future in Star Wars, it was the sound of 19th-century Romanticism--still the most popular style for epic film soundtracks. Beginning in the last decades of the 18th century, it transformed poetry, the novel, drama, painting, sculpture, all forms of concert music (especially opera), and ballet. It was deeply connected with the politics of the time, echoing peoples fears, hopes, and aspirations. It was the voice of revolution at the beginning of the 19thRead MoreEssays on Vehicular Pollution3733 Words à |à 15 Pageshalls. When John Williams created the sound of the future in Star Wars, it was the sound of 19th-century Romanticism--still the most popular style for epic film soundtracks. Beginning in the last decades of the 18th century, it transformed poetry, the novel, drama, painting, sculpture, all forms of concert music (especially opera), and ballet. It was deeply connected with the politics of the time, echoing peoples fears, hopes, and aspirations. It was the voice of revolution at the beginning of the 19thRead MoreThe And, The, And The Element Of A Person s Psychological And Emotional Outlet3243 Words à |à 13 Pagesthere being an absence of consent. It was also claimed that a person who demands pain upon themselves (masochism) is also committing a crime. As well as this, it is said if an individual is to get into a state where his fetish is over powering his morality he could be coerced and led to do the worst crimes. In terms of the law and the sentences for these persons, it is concluded that in this study that there appears a pronounced ethical guideline in the immersion of bondage and fetishism. Having saidRead MoreGp Essay Mainpoints24643 Words à |à 99 Pages Sports and Media 8. Foreign Aid a. How effective is Foreign Aid? 9. Migration a. Is migration/having foreigners good? 10. Subjects a. Literature b. History c. Mathematics d. Universal language 11. Businesses a. Business morality b. Charities as businesses 12. Democracy a. Good vs. Bad 13. Social Issues (only stats provided) a. Gender b. Family c. Equality 14. Governance a. World Governance 15. Others a. Cooperation b. Education c. Crime Read MoreOne Significant Change That Has Occurred in the World Between 1900 and 2005. Explain the Impact This Change Has Made on Our Lives and Why It Is an Important Change.163893 Words à |à 656 Pagesworldwide after 1990) did not stop the multiplication of migration controls, the proliferation of identity documents, and ever more complex laws to sift and select the optimal migrant. In this sense, neoliberalism has proved to be more ââ¬Å"quasiâ⬠than ââ¬Å"neo,â⬠promoting the free movement of goods, capital, technologies, information, and culture, but not of people. At the most brutal level, the consolidation of borders and purification ofà national spaces has produced millions of refugees as one of the
Mass Communication Globalisation and Communication
Question: Discuss about theMass Communication for Globalisation and Communication. Answer: Introduction: Globalisation can be defined as a process by which business organisations initiates and conducts their business operations on a global scale. It can be referred to as the process of interaction and integration carried out by business firms to exert an international influence. Communication skills are highly significant for business organisations to achieve growth and success in a global environment (Baldwin et al., 2013). In this context, the present essay aims to demonstrate the importance of communication skills for business organisations operating in global context. Globalisation and Communication Organisations around the world need to expand their businesses on an international level in order to stay competitive for ensuring their sustainability and growth. Organisational communication plays a key role in the success of businesses in a global context. Businesses carrying out their operational activities in a global environment often face the issues regarding cross-cultural interactions. This has caused organisations to adopt and implement cross-cultural communication skills for gaining success globally (Moseley, 2009). In this context, organisational communication can be referred as developing an effective pattern of interpersonal communication between individuals in an organisation. Cross-cultural communication skills in an organisation refer to gaining an appropriate understanding of different types of business cultures, beliefs and interaction strategies. The presence of cross-cultural communication skills is highly significant in workplace culture of organisations operati ng in a global environment. Cross-cultural communication emphasizes on developing an understanding of the impact of individual differences on interacting with people belonging to diverse cultural backgrounds (Guang and Trotter, 2012). The need for cultural awareness is pertinent for organisations for developing required skills and competencies in the employees to facilitate cross-cultural communication. Cultural differences impact the communication pattern by influencing vocabulary, colloquial expressions and voice tone between individuals. For example, American and Japanese business people can interact with each other effectively through gaining proper understanding of the varying culture of two countries. As such, different business cultures have varying sets of communication rules that need to be identified by an organisation in advance before operating globally (Guang and Trotter, 2012). The business organisations need to develop a workplace culture by establishing groups and teams having required competencies and skills of interacting with people across different boundaries appropriately. This can be achieved through implementation and adoption of communication skills development programs by organisations to provide linguistic training to the employees in accordance with the languages and cultures of different countries. The training program of an organisation should also provide a proper knowledge regarding the conflict styles, eye contact, posture, physical expressions that are followed in different business cultures. The training programs will enable geographically dispersed team of an organisation to effectively share information across its various business units effectively. The geographically dispersed team would be able to carry out face-to-face meetings with its foreign suppliers, customers and team members through development of required cross-cultural communication skills (Moseley, 2009). The globalisation has also caused the need of virtual communication in workplace dynamics of an organisation. Virtual communication refers to interaction between people across different cultures through the use of online platform. Face-to-face communication has increasingly become difficult for businesses operating in a global environment. This has caused the need of introducing online technologies for sharing information across different business boundaries. Business operating globally often develops virtual teams that rarely meet personally but interact with each other through the use of online technologies such as email, video conferencing, telephonic communication and many others (Ebrahim et al., 2009). Virtual communication has proved very beneficial for global organisations to overcome the geographical boundaries and facilitates instant communication across the globe. Modern business organisations need to have proper awareness regarding the various virtual online tools that can be utilised for sharing information in a global environment. They should possess in-depth understanding of the benefits and limitations of different online communication platform to utilise each one of them effectively to achieve maximum effect. Virtual communication is gaining dominance over the traditional method of communication by transferring information easily across the borders and enabling organisations to chive a competitive advantage (Oertig, and Buergi, 2006). Mass communication is essential for business operating globally to exchange information across large group of people. Mass communication is referred as delivering and transferring information to large group of people through use of advertising challenges such as press, radio, television, online platforms and launching business campaigns. Mass communications enables organisations to reach to large number of group of people as possible. The use of online technologies can prove to be largely beneficial for organisations to reach target audiences quickly and easily. The use of social networking sites such as Facebook and Twitter is facilitating organisations to promote their products and services to global customers within a short span of time (Chen, 2012). However, in this context is important for organisations to design effectively the communication message so that it conveys specific information that provides adequate knowledge to the target audiences about organisational objectives. The message delivered to the target audiences should not be complex and rather simple to be easily understood by specific group of people. The advertising platform used for mass communication should also incorporate channels for interacting with customers to understand their needs and requirements. This is highly important for organisations operating globally to achieve customer satisfaction by developing their products and services in accordance with customer demands (Kheeshaeh, 2010). The presence of effective leadership styles is also essential for organisations to develop effective communication styles for exchanging information globally. For example, conducting virtual meetings requires providing proper motivation and knowledge to the employees in advance regarding their role and responsibilities. This is necessary so that organisational employees in virtual settings can effectively share their input without any ambiguousness. The business leaders hold the responsibility of aligning the organisational objectives with challenges present in external global environment appropriately. The leaders must possess cultural intelligence that is having the ability to interact with people belonging to diverse cultural backgrounds (Oertig and Buergi, 2006). This can be achieved through gaining proper knowledge regarding the cultural values that drives the attitudes, behaviour and believe of an individual. The cultural intelligence of business leaders is very essential to de sign and implement effective training programs to enhance the cross-cultural communication skills of the employees. They should proper motivation to the employees so that they achieve cross-cultural training imparted to them successfully and develop the required skill-sets. Business leaders are directly responsible of developing a workplace culture that provides adequate support and resources to the employees for undertaking a specific change and enhance their cross-cultural communication abilities. In this context, transformative leadership theory states that a leader should enhance the participation of its sub-ordinates to identify the needed change and developing a vision to implement the change in an organisation. As such, it can be states that that skills and competencies of a leader is interconnected with the success of a business organisation operating in global context (Somech, 2009). Conclusion Thus, it can be stated from the overall discussion held in the essay that organisations worldwide seek to operate globally for expanding their business operations and maximise their profitability. There is high impact of external global business environment on driving changes in an organisation communication pattern Businesses are implementing cross-cultural training for enhancing the skills and competencies of individuals in an organisation so that they can interact with diverse people across boundaries effectively. Virtual and mass communication is also becoming increasingly important for businesses to interact with specific group of people across the globe appropriately. References Baldwin, J.R. et al. 2013. Intercultural Communication for Everyday Life. John Wiley Sons. Chen, G. 2012. The Impact of New Media on Intercultural Communication in Global Context. China Media Research 8(2), pp. 1-10. Chuang, S. 2013. Essential skills for leadership effectiveness in diverse Workplace development. Online Journal for Workforce Education and Development 6 (1), pp.1-23. Ebrahim, N. A. et al. 2009. Virtual Teams: a Literature Review. Australian Journal of Basic and Applied Sciences 3(3), pp. 2653-2669. Guang, T and Trotter, D. 2012. Key issues in cross-cultural business communication: Anthropological approaches to international business. African Journal of Business Management 6 (22), pp. 6456-6464. Kheeshaeh, M. 2010. Effects of Globalization on Mass Media In The World. International Journal of Asian Social Science 2(10), pp.1672-1693. Moseley, A. 2009. Improving Cross-Cultural Communication Skills: Ask-Seek-Knock. Leadership Advance Online XVII, pp.1-11. Oertig, M. and Buergi, T. 2006. The challenges of managing cross-cultural virtual project Teams. Team Performance Management 12 (1/2), pp. 23-30. Somech, A. 2009. The effects of leadership style and team process on performance and innovation in functionally heterogeneous teams. Journal of Management 32(1), pp. 132-157.
Thursday, April 23, 2020
The Louisiana Purchase and National Health Care Reform free essay sample
The Louisiana purchase Was unconstitutional, but Was never challenged because it benefited the country. On the national health care law, many states have started lawsuits claiming that Congress did not have the authority to require citizens to buy insurance, an important part of the law that was passed to make sure that all people have access to health care. National health care reform may also prove to be an historic advance, but the Ignited States Supreme Court will soon decide if the law is constitutional or whether Congress exceeded its authority in passing the law.Throughout the seventeenth, eighteenth and nineteenth centuries, economic imperialism became a popular method many European countries used, in which power was gained through wealth. A common tactic countries would use to gain wealth was through conquering territories and reaping the benefits of the resources that came with them. France completely adopted the idea of economic imperialism, and under the leadership of its Emperor, Napoleon Bonaparte, France controlled territories all around the world by the beginning of th e nineteenth century. We will write a custom essay sample on The Louisiana Purchase and National Health Care Reform or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page However, Napoleon found that maintaining control and power in the many territories that France had obtained, was far more difficult than gaining the land itself, especially when it came to the land France controlled in North America. French resources were spread thin already, and the Louisiana Territory being an Ocean away did not help either. When Napoleon heard that the United States population was growing rapidly, he knew it was only a matter of time before the Americans would start spilling over into the French territory, and there was little that he could do to stop them.A successful uprising in Haiti, formerly controlled by France, was the final event that convinced Napoleon to re-evaluate his priorities and tactics he would use to maintain the Empire that he had worked so hard to build. Napoleon decided to focus his resources on dominating Europe, and to cut his losses for the territories in North America. By selling the Louisiana territory not only would Napoleon have one less region to worry about and be able to strengthen his forces elsewhere, he would also be quickly acquiring money, which was exactly what he needed to finance his endeavors in Europe.The land that Napoleon would sell to the United States, in what is now as the Louisiana Purchase, was 828,000 square miles. It later would become all or part of 15 of the united States and two Canadian provinces. The land covered all or part of the following states: Arkansas, Missouri, Iowa, Oklahoma, Kansas, Nebraska, Minnesota west of the Mississippi, most of North and South Dakota, northeastern New Mexico, northern Texas, part of Montana, Wyoming, Colorado, and Louisiana. Altogether, the Louisiana Purchase covered land that is now about 23% of the United States. The United States paid France $1 1,250,000 for the land, in addition to canceling 3,750,000 in war debts that the French owed the United States. The total cost of the land came out to be $15 million. This was an incredible deal for the United States; however, it did come with some complications.Thomas Jefferson knew that if he did not act quickly, Napoleon would take the deal off the table and France would become a military threat to the United States. The treaty was signed on April 30th, 1803 by Secretary of State James Monroe as he was instructed by President Jefferson, who announced the treaty to the rest of the country on July 4th of Thayer, but there was a problem. To save time, President Jefferson did not address the situation with Congress; he simply decided to make the deal. The Constitution did not state any specific grant of power to the President to purchase land, moreover, in it was written that no new state shall be formed or erected Without the consent of the Legislatures of the States concerned as well as Congress, (Article Four, Section Three, United States Constitution). Article Four also gave to Congress, not the President, the power to dispose of and make all needful Rules and Regulations respecting the Territory or otherProperty belonging to the United States. (United States Constitution) Even preceding the Constitution, the Articles Of Confederation stated that, no other colony shall be admitted into, and entitled to, all the advantages of the union, unless such admission be agreed upon by nine states, (Everett Somerville Brown, The Constitutional History of the Louisiana Purchase) which reflects the historical intention of how new states should be admitted.Thomas Jefferson felt President Jefferson was known for being a die-hard Anti-Federa list in favor of strict interpretation of the Constitution, but he also let strongly that this purchase was necessary if the United States had any hope of developing into a world power, so he did what to do to make the purchase happen. Originally, he drafted an amendment to the Constitution to allow him to make the purchase, but in the end, he decided to do without it.After the treaty was signed, President Jefferson declared that it was the noblest work Of our whole lives Frown this day the United States take their place among the powers of the first rank. (page 54, Mr.. Jefferson Lost Cause: Land, Farmers, Slavery, and the Louisiana Purchase). The land the United States purchased from France averaged out to about three cents an acre and it doubled the size of the country, but despite what this purchase meant to the future of the United States many people, opposed it for various reasons.Federalists were angered because, [Anti-Federalists] had passionately denounced the argument of Alexander Hamilton and other Federalists that there were implied powers in the Constitution that entitled the government to take action In areas not covered in the text of the national charter, (Thomas Fleming, The Louisiana Purchase). Some even went as far s to call President Jefferson a hypocrite for working around The Constitution. Other Federalists opposed the purchase because they felt it might send the wrong message to Britain, who at the time was at war with France.Another huge issue was that due to the Third Treaty of San Oldness between France and Spain, France wa s not legally allowed to sell the territory to a third party. As Henry Adams said: The sale of Louisiana to the United States was trebly invalid; if it were French property, Bonaparte could not constitutionally alienate it without the consent of the Chambers; if it Were Spanish property, he could not alienate t at all; if Spain had a right of reclamation, his sale was worthless. -Henry Adams, Habits of Empire: A History of American Expansionism Whether or not the sale was worthless, if it went through it could cause tension between the U. S. And Spain and the last thing any Americans wanted was to start an unnecessary war with Spain. Others were wary about the Louisiana Purchase because of concerns about allowing all those living in the territory to become citizens, including foreigners and freed black slaves.Finally, there was concern that by increasing the number of states that had slaves, it would add o the tension be;men the North and the South. Soon after the purchase was signed, the House called for a vote to deny the request for the purchase, but it failed by two votes, 59-?57. The Federalists even tried to prove the land belonged to Spain, not France, but available records proved otherwise. However, despite their attempts, the Louisiana Purchase was ratified with a vote of twenty-four to seven on October 20.On the following day, it authorized President Jefferson to take possession of the territory and establish a temporary military government. President Obama soon after he was elected decided to make expanding access to health care insurance one of the main goals and accomplishments of his Presidency. In 201 0, approximately 49. 9 million Americans did not have health insurance. (Common Wealth Fund Blob) This affects many Americans who are not poor enough to get insurance from the government, but cannot afford to buy health insurance for themselves, and/or their children.Twenty-seven percent of people with incomes below $25,000 did not have health insurance in 2010, which means that they often delay getting health care or dont see a doctor when they need to because they cannot ford to pay for medical care. President Obama proposed national health care legislation in order to end the worst abuses of the insurance industry, with strong consumer protections. The law would be a major step forward to making sure that everyone has health insurance, which is the case in most advanced Western nations, except the United States.The national health care legislation contains hundreds of provisions, including a requirement that individuals purchase health insurance so that not only sick individuals would buy insurance. In the public debate, this has men called the individual mandate. The legislation would prevent insurance companies from denying insurance to people who already have a serious illness, called a pre-existing condition. It would also keep the cost of insurance down and allow parents to include their children on their policies until the children become age 26.National health care legislation was also passed to make it more affordable for people to buy insurance so that if they lost a job or changed jobs they would be able to get a new insurance policy. In order to make it possible to put these changes in place, the legislation included the individual mandate. Since the national health care legislation was passed, March 10, 2012, twenty-six states have brought lawsuits claiming that the law is unconstitutional because of the individual mandate.The case is now before the United States Supreme Court which heard arguments for three days in March, 2012 and is expected to provide a decision this month. The Supreme Court has a majority of members appointed by Republican Presidents who are likely to be affected by their own political views as they decide the case. In fact, the members of the Supreme Court appointed by Republican Presidents seemed to agree that the individual mandate would violate the Constitution when they heard arguments about the case in March.Opponents Of the law claim that Congress exceeded its authority and violated individual rights by requiring individuals to buy health insurance. They say that it would lead to unl imited government authority if government could force individuals to spend money to make themselves healthier, arguing that for instance, government could make people get a membership at a gym or eat broccoli. During the arguments before the Supreme Court, he justices asked if Americans could be forced to buy cell phones or burial Insurance.Those who support the individual mandate argue that government has the authority to regulate commercial decisions under the Commerce Clause of the Constitution and already regulates many decisions that people make for their own good and the benefit of others, such as requiring people to wear stables, buy car insurance, attend school until age 18. These decisions also limit individual choice. Those who support the law also argue that when people do not buy health care they affect everyone else in society who must ay for the hospitals and doctors that treat people without insurance.The Louisiana Purchase and the national health care legislation are very different in pieces of legislation, but the opposition they faced despite how revolutionary they are makes them very similar. The Louisiana Purchase has completely shaped what America is as a country toda y. If our country was the same size now as it was in 1803, it never would have been able to become the world power it is today. Maybe Jefferson worked his way around the Constitution a little bit, but he did it with good intentions. In addition, in doing o he did not put the rights of individuals in jeopardy.If an opportunity like the Louisiana Purchase, that will undoubtedly bring a plethora of benefits to the country, presents itself, our president should be allowed to use his judgment and exceptions that need to be made, should be. As far as Obama Care goes, it is unclear to me why so many people have such a big problem with it and its constitutionality, when we already are required to buy car insurance. What is so much worse about being forced to buy health insurance than being forced to buy car insurance?The answer is thing, so I do not understand why people have made such a huge deal about being required to have one type of insurance when We are already required to have another. The United States Supreme Court decision should uphold the national health care legislation and recognize the power of electe d representatives -the President who proposed the law and Congress who adopted it-?to take this dramatic step to make health care more available to all Americans. The President and Congress, as elected representatives should have broad power to act in the public good, so long as they do not violate the civil rights of individuals.
Tuesday, March 17, 2020
Bulworth Summary Essay Example
Bulworth Summary Essay Example Bulworth Summary Paper Bulworth Summary Paper Name: Instructor: Course: Date: Bulworth Summary Bulworth is a political, satirical movie that follows the life of Jay Bulworth a senator. He is seeking re-election to his seat as the senator of California. However, his re-election campaign is not going well, and he relies on businesses and organizationsââ¬â¢ donations to run his campaigns. His opinions, therefore, had to be conservative in order to obtain the financial assistance he required from the businesses and organizations. His ideologies began to lose favor with the citizens of his state, and this diminished his popularity. Jayââ¬â¢s family was also encountering financial problems, and he decides to negotiate a 10 million dollar life insurance policy and plans his own death. If he dies, his family will get the money, and their money woes will be over. This movie highlights all the characteristics of American Politics. Jay changes his opinions on politics and starts telling the truth and pointing out the wrongdoings of the government. This makes his popularity return, and he discovered he did not want to die but rather, he wanted to make a change in the political landscape. He tries to call of the arrangement for his assassination, but he is told that he is too late. He hides in a young womanââ¬â¢s house, Nina to avoid being killed. Nina was a love interest of the senator; they meet in one of the campaigns. However, on one day as he leaves to address a campaign, he is shot and he dies from his injuries. This movie tackles the various aspects that constitute American Politics. Issues such as financial support from large multinationals in order to support their ventures for instance exist in the United States and other countries, as well. Culture, conservatism and liberalism, have been highlighted in the movie Bulworth. Jay has to remain conservative and support the ideologies that were present in the 1970s in order to maintain the financial aid he is receiving from the big firms. He could not address the needs of the citizens and this made his popularity dwindle further. This happens in American politics as well, some leaders may support some ideologies, not of their own free will but because that are obliged to. Campaigns are a costly affair and only the politicians with the right backing will be able to carry out and effective campaign. Politicians should fight for the rights of the citizens who elect them, as opposed to those who pay them if liberalism were to be present in America; all he citizens would obtain the lifestyles they deserve. Socialism and Capitalism is another aspect that dominates American politics. Capitalism refers to the ownership of production methods by private organizations while Socialism refers to the ownership of these methods by the citizens themselves. Politics has always supported capitalism. They support it because the capitalists are the source of their financing. In the case of socialism, not a small minority will have all the money; it will be spread out in the country. Politicians will not benefit from this and therefore, they do not support it. Bulworth has highlighted this issue remarkably through the depiction of the main Characterââ¬â¢s need to get financial aid from the capitalists. The movie has reflected on an occurrence that takes place in the American Political landscape. Racism and class has always been a feature of American politics. Politicians have tried to deny this fact by claiming they are not racist, and including other races in their campaigns, but it is still deeply entrenched. Most politicians originate from a lineage of other politicians before them or are from rich and influential families. In the movie, Jayââ¬â¢s opponent was such and individual, rich and powerful. He was not in need of any financial aid and his financial position enabled him to gain favor with the voters. Race also influences politics because the association with minority groups such as the blacks affects the ratings of the politicians as it did with Jay when he started giving speeches as a rap. His popularity increased with the minority groups but reduced with the whites. The movie has displayed the American political landscape remarkably, as it has brought out the features it encompasses. ââ¬Å"Bulworth summaryâ⬠Star pulse. 2012. Retrieved from: starpulse.com/Movies/Bulworth/Summary on 4 October 2012.
Sunday, March 1, 2020
Chemicals That Could Make You Fail a TSA Swab Test
Chemicals That Could Make You Fail a TSA Swab Test If youre flying, you may get pulled aside by a TSA agent for a swab test. Also, your baggage may get swabbed. The purpose of the test is to check for chemicals that might be used as explosives. The test cant check for all the chemicals that might be used by terrorists, so it looks for two sets of compounds that can be used to make many types of bombs: nitrates and glycerin. The good news is the test is highly sensitive. The bad news is, nitrates and glycerin are found in some harmless everyday products, so you could test positive.Ã Getting swabbed doesnt seem to be particularly random. For example, some people get swabbed nearly every time they fly. This may be because theyve tested positive before (possibly related to a penchant for making smoke bombs and other small pyrotechnics) or because they meet some other criteria. Just expect to be swabbed and be prepared. Heres a list of common chemicals that may cause you to test positive. Avoid them or else be ready to explain the test result, because it can take a while for TSA to complete its evaluation of your belongings, which can translate into a missed flight. Common Products That Test Positive Hand soaps that contain glycerin (Rinse very thoroughly after washing your hands.)Lotions that contain glycerinCosmetics or hair products, which may contain glycerinBaby wipes, which may contain glycerinCertain medications (such as nitroglycerin and other nitrates)Lawn fertilizers (Nitrates: Wash your hands and especially your shoes.)MunitionsAccelerantsFireworks and other pyrotechnics What to Do If Youre Flagged Avoid becoming hostile and aggressive. It wont speed the process. Youre likely going to get patted down by an agent of the same gender who will also empty your bag for additional testing. Theres a chance your luggage may get pulled, although this rarely happens; its also unlikely that you will miss a flight because of the test. Be aware of chemicals in your environment and able to trace your steps to help TSA identify the source of the triggering compound. Sometimes you wont have any idea why you flagged the test. But, careful attention to hygiene may help you avoid the situation. The best advice is to arrive early enough before your flight to get through security. Try to avoid the problem, plan for it, and dont overreact if it happens to you.
Thursday, February 13, 2020
Economics Paper in MLA format including 2 primary source documents Term
Economics in MLA format including 2 primary source documents - Term Paper Example The price where the curves intersect is called the market price and this is where both the consumers and producers are willing to supply a certain quantity. The demand curve is downward sloping due to the fact that as the price reduces, the ability and willingness to purchase on the consumersââ¬â¢ part increases meaning that there is negative relationship between the quantity demanded and price of the product. On the other hand, the opposite can be said for the supply curve. A positive relationship exists between the quantity supplied and price. As the price increases, the producers are more capable and willing to supply the product and hence the upward sloping curve. Consumer surplus is when a consumer is getting to buy a product at a price which is lower than that which the consumer is willing to pay. Therefore all the area between the demand curve and the market price line is classified as consumer surplus. Producer surplus is the excess which the producer earns as a result of the difference in the market price and the quantity the producer is willing to supply at certain prices. Producer surplus is the area below the market price and above supply curve. Business and Labor The mergers process may be beneficial for the industry in the short run specifically for industries which involve huge costs and research and development projects. The greater financial pool available to these companies is required to undertake large research operations and improve new technologies. It also is about the efficiency of the companies that is if they have been able to increase their efficiency through this process and whether they have passed this efficiency to the buyers. The mergers process may increase the efficiency because now at a larger operations base, the company may be able to achieve economies of scale which is the reduction of average production costs as a result of the increase in production. Coming towards the minimum wage laws, the governments often introduce the policies of minimum wage which acts as a floor to the price of labor employed. When the government enforces the laws of minimum wages, then the market forces are disturbed and equilibrium ceases to exist creating a gap between the demand and supply, which is of labor in this case. The disequilibrium in theory results in a rise in the supply of labor but the demand reduces as the labor is now more costly. However, the magnitude by which this disequilibrium is caused depends upon the circumstances prevailing in each economy and varies from country to country. United States Finance The economy of United States of America was performing very well at the start of the century but then went under deep recession in the year 2008 with the credit crunch and all the financial institutions seem to crumble at the same time. People started to default, and the society and institutions started to face liquidity issues. Soon with this credit crunch, the debts started to rise and the economy sta rted to experience its effects which included the rising unemployment rates and decreasing gross domestic product (GDP) of US economy. Since the financial crisis struck in the year 2008, the US debt has been very high. According to a recent news article, the United States debt is nearly as much as the total value of all its goods and services produced in the US during the financial year. CNBC reports that the total value of the US debt is $14.96 trillion which means that the
Saturday, February 1, 2020
International Business Finance Research Paper Example | Topics and Well Written Essays - 2000 words
International Business Finance - Research Paper Example re liable to pay the interest at the pre-determined rate throughout the tenure of the bonds and repay the face value at the time of maturity which means there is no question of incurring loss for the investors out of investing in such financial instrument (Burger, Sengupta, Warnock and Warnock, 2014). However, in recent times it has been noticed in Europe that in some countries such as Denmark, Germany and Switzerland, the government bonds as well as corporate bonds are yielding the investors a negative return. To be more specific, such negative yields are not inflation-adjusted returns; the bonds are simply yielding the investors less than their capital (Ivashina and Becker, 2015). Therefore, the research paper will aim to investigate regarding credibility of bonds as a financial instrument, their buyers and the factors that may influence such investor to purchase bonds even with negative returns in order to find out the rationale behind such negative return and to identify buyersâ â¬â¢ motivation behind purchasing such bonds with negative yield. For the purpose of analysis, relevant economic theory that may justify the reason behind buying bonds with negative yields shall also be incorporated. Traditionally, bond is considered to be one of the most secured investment options among all other financial instruments available in the financial system. Dann (2005) has defined financial instrument as a mechanism that institutes a contractual right between the borrower and lender to receive and deliver some of money. Bond is a financial instrument that establishes a indenture between the two parties: bond holder and issuer. The indenture specifies that the issuer will pay a fixed or variable rate of interest during the whole life of the bond and will refund the principal amount at the time of maturity (Maginn, Tuttle, McLeavey and Pinto, 2010). Bonds can be of various types such as fixed and floating rate of bonds, zero coupon bonds, perpetual bonds, inflation-index bonds
Friday, January 24, 2020
Bob Marley Essay -- Biography Biographies Bio
Bob Marley is a name most people know but his accomplishments and dedication to music is often overlooked. Bob was more than just a reggae artist, he was an inspiration to the country of Jamaica. He was a role model to the poverty stricken island and gave hope to many people. Bob was born on February 6, 1945 in his grandfather's house. He was the son of a poor farm girl and a British naval Captain. Soon after his birth Bob's father, Norval Marley, left his mother. He remained responsible and provided financial support and occasionally came back to see them. In the 50's a depression hit Jamaica and Bob followed his mother to West Kingston also known as Trenchtown. It was in Trenchtown were Bob's love for music began. Bob Marley's music has given people everywhere hope for a better tomorrow. His life and involvement with the Rastafarian movement left an impact on the world that is still felt today. He sang of peace speaking out against slavery, poverty, and oppression. His philosophy was to send a message through his music that all people are equal and should unite together to make this world a much better place for our future generation. "Every man gotta right to decide his own destiny"(Stephens 2). When Bob Marley said this he was referring to the battle with the Americans and the Indians of the west, where slaves from Africa were forced to fight. He wrote the song "Buffalo Soldier" as a tribute to the injustice of the war. They were brought to America and forced to fight against the Native American Indians. The Indians called them buffalo soldiers because their hair was tightly woven and to them, it resembled the curly and matted buffalo's coat. In the line "Stolen from Africa, brought to America Fighting on arrival, figh... ...y never gave up on his goal for world peace. The point of many of these songs were that you will never loose until you give up your fight. If everyone gave up on the things they were doing once they had failed then where would the world be today? If the U.S. had surrendered in our first world war when one soldier was shot down would we have our great country today? No, we wouldn't because no one gets anywhere when they give up. No one has anything when they give up just another failure to write in their book of history that will most likely not be remembered. All of our great leaders had to try more than once to get what they fought for. Like George Washington fought for freedom for years and when he got it he was known as a great leader to America and it's future generations. Maybe if the world were like Bob Marley we could be further into the future than we are now.
Thursday, January 16, 2020
Qualities of a Good Parent Essay
Love and Discipline Raising children can be extremely difficult at times. While there are numerous qualities required to be a good parent, there are two basic qualities that every parent should consist of while raising their children. By a parent obtaining love and discipline in the raising of their children will result in good parenting. A good parent must make his or her child feel cherished at times; however, a parent must also discipline children when necessary. Love is extremely important for a parent to provide while raising children and should be a main goal of any parent. A parent can provide this quality to a child by doing activities that he or she enjoys. For example, a parent can play games or read a favorite book of the childââ¬â¢s desire. If a child is shown attention by a parent it gives them a sense of feeling important and cared about by a loved one. When a child consumes of the feeling of importance it allows confidence to increase. Another way a parent can express love to a child is by being affectionate. A hug, kiss on the cheek, or simply saying, ââ¬Å"I love youâ⬠can allow a child understand that his or her parent truly does love them. When a child is shown affection by his or her parent then they can assure themselves that the love from the parent it always present. It is common for children to feel as if their parent does no longer love them after they have done something wrong; therefore, by a parent reassuring his or her child that they will love them no matter what can relieve a child of that fear. If a parent provides love as quality while raising children, then good parenting will be a result. Another quality a good parent should have while raising children is discipline. When a child has done something wrong a parent must perform some type of disciplinary action to force the child to understand what he or she did is wrong and cannot happen again. If a parent allows a child to misbehave without any discipline, then the child will have the mentality that what he or she did is okay and will continue to misbehave. By a parent performing disciplinary action with his or her child, then the child will understand that their parent has authority over the choices made and the consequences to follow. Discipline does not always mean a parent must hit orà spank a child; restricting the childââ¬â¢s limitations on what he or she may enjoy can also do solve the problem. For example, if a child enjoys playing video games or going places with friends a parent can restrict the childââ¬â¢s ability to do these things after they have misbehaved. By a parent provides discipline to their children when needed, it will then teach a child that misbehaving is not tolerated and can result in punishment. Disciplinary actions are necessary for a parent to accomplish being a good parent. All in all, parenting is a lot of work, and is not easy. There are many responsibilities that come along with parenting. Parents must always provide love for children, but also discipline when needed. Every child is unique, and needs to be handled differently.
Wednesday, January 8, 2020
Research Paper on Letters from an American Farmer by J....
The definition of what America is, and furthermore what an American is, has been eternally elusive. However, it can be reasonably said that the vision of America rests upon freedom of expression, the right to property, and self-determination. These ideas are explored in one Europeanââ¬â¢s examination of American agricultural society in the late 18th century. Letters from an American Farmer by J. Hector St. John de Crà ¨vecÃ
âur illustrates the gilded nature of the early vision of America; one that appears to be simplistic and based in freedom, but lies on a foundation of oppression and greed. Crà ¨vecÃ
âur was a native of France, who - at the age of 20 - immigrated to North America. After a short military career in Canada, Crà ¨vecÃ
âur purchased land inâ⬠¦show more contentâ⬠¦The American farmer is his own landlord, and is content with a precedent of continual work, and limited governmental interference in his business. (Plotkin 392) He goes on to state that the continual flow of immigrants into America will facilitate the eventual civilization of far western lands. In this onward march westward, ââ¬Å"...industrious people...will change in a few years that barbarous country into a fine fertile, well-regulated district. Such is our progress, such is the march of the Europeans toward the interior parts of this continent.â⬠(Crà ¨vecÃ
âur 609) This early reference to manifest destiny puts on display, for the European reader, the sheer vastness and availability of land in the New World, as opposed to the marked lack of such available land in Europe. Crà ¨vecÃ
âur also makes reference to the fact that the citizens of America cannot possibly draw from one single European culture, due to the diverse background of immigrants. This ââ¬Ëmelting-potââ¬â¢ milieu of peoples is part of the foundation upon which Crà ¨vecÃ
âurââ¬â¢s America, because it prevents monolithic identification with one European background. (Cunliffe 130) Possibly the largest difference between European and American,Show MoreRelatedEssay on The American Christian Holocausts5005 Words à |à 21 PagesThe American Christian Holocausts As a high school student I was always annoyed by students who would ask: Why do we have to learn this stuff [history] anyway? We learn history so we dont repeat our mistakes. This is the common answer that my teachers, my father, and just about any other adult would give. This answer made perfect sense to me then, and I easily accepted it. In high school, students learn about the Nazi-Holocaust, and rightfully so. Information abounds regarding this topic. However
Monday, December 30, 2019
Countries Bordering the Mediterranean Sea
The Mediterranean Sea is a large body of water with Europe to the north, northern Africa to the south, and southwestern Asia to the east. The narrow Strait of Gibraltar to the west is the only outlet to the Atlantic Ocean. Its total area is 970,000 square miles, and its greatest depth is off the coast of Greece, where it is 16,800 feet deep. Because of the Mediterraneans size and central location, it borders 21 countries on three continents. Europe has the most nations with coastlines along the Mediterranean Sea with 12. Populations listed are from mid-2017. Africa Algeriaà covers 919,595 square miles and has a population ofà 40,969,443. Its capital is Algiers. Egyptà is mostly in Africa, but itsà Sinai Peninsulaà is in Asia. The country is 386,662 square miles in area with a population ofà 97,041,072. The capital is Cairo. Libya has a population ofà 6,653,210 spread over 679,362 square miles, but about a sixth of its residents are centered in the capital of Tripoli, the nations most populous city. Moroccosà population isà 33,986,655. The country covers 172,414 square miles. Rabat is its capital. Tunisia, whose capital is Tunis, is the smallest African nation along the Mediterranean, with justà 63,170 square miles of territory and a population of 11,403,800. Asia Israel has 8,019 square miles of territory with a population of 8,299,706. It claims Jerusalem as its capital, although most of theà world fails to recognize it as such. Lebanonà hasà a population ofà 6,229,794 squeezed into 4,015 square miles. Its capital is Beirut. Syriaà covers 714,498 square miles with Damascus as its capital. Its population is 18,028,549, down from a high of 21,018,834 in 2010 due at least in part to a longstanding civil war. Turkey,à with 302,535 square miles of territory, is in both Europe and Asia, but 95 percent of its land mass is in Asia, as is its capital, Ankara. The country has a population of 80,845,215. Europe Albania is 11,099 square miles in area with a population of 3,047,987. The capital is Tirana. Bosnia and Herzegovina, formerly part of Yugoslavia, covers an area of 19,767 square miles. Its population is 3,856,181, and its capital is Sarajevo. Croatia, also formerly part of Yugoslavia, has 21,851 square miles of territory with its capital at Zagreb. Its population is 4,292,095. Cyprus is a 3,572-square-mile island nation surrounded by the Mediterranean. Its population is 1,221,549, and its capital is Nicosia. France has an area of 248,573 square miles and a population of 67,106,161. Paris is the capital. Greece covers 50,949 square miles and has as its capital the ancient city of Athens. The countrys population is 10,768,477. Italys population is 62,137,802. With its capital in Rome, the country has 116,348à square miles of territory. At just 122 square miles, Malta is the second-smallest nation bordering the Meditteranean Sea. Its population is 416,338, and the capital is Valletta. The smallest nation bordering the Mediterranean is the city-state of Monaco, which is just 0.77 square miles and has a population of 30,645. Montenegro, another country that was part of Yugoslavia, also borders the sea. Its capital is Podgorica, it has an area of 5,333 square miles, and its population is 642,550. Slovenia, another part of the former Yugoslavia, calls Ljubljana its capital. The country has 7,827 square miles and a population of 1,972,126. Spain covers 195,124 square miles with a population of 48,958,159. Its capital is Madrid. Territories Bordering the Mediterranean In addition to 21 sovereign countries, several territories also have Mediterranean coastlines: Gibraltar (British territory on Spains Iberian Peninsula)Ceuta and Melilla (two autonomous Spanish cities on the northern African coast)Mount Athos (autonomous part of the Greek Republic)Akrotiri and Dhekelia (British territory on Cyprus)The Gaza Strip (Palestinian National Authority)
Sunday, December 22, 2019
The Health Insurance Portability And Accountability Act (...
The Health Insurance Portability and Accountability Act (HIPAA) was enacted for the purpose of protecting the privacy of a client s personal and health information.à ¹ Under HIPAA, protected health information (PHI) includes but is not limited to the following: a person s name, address, date of birth, age, phone and fax numbers, e-mail address, medical records, diagnosis, x-rays, photos, prescriptions, lab work, or test results.à ¹ In this particular case scenario, a healthcare employee not only breached HIPAA in regards to publically releasing a patientââ¬â¢s PHI without the consent of the patient, but they also betrayed their patientââ¬â¢s trust. Regardless of any personal relationship a physical therapist would have with another healthcare professional, steps must be taken to assure that this breach in patient confidentiality is rectified and that a similar mistake is not made again. This particular situation is made increasingly difficult due to the nature of not only m y professional working relationship with this fellow member of the healthcare team, but also by the fact that I consider her one of my closest friends. Although I am not directly in charge of a certified occupational therapy assistantââ¬â¢s (COTA) patient case load, it is my ââ¬Å"legal obligation to protect confidential patient/client informationâ⬠according to Principle 2E of the Physical Therapy Code of Ethics.à ² Also according to the Physical Therapy Code of Ethics section 4C, ââ¬Å"physical therapists shall discourageShow MoreRelatedThe Health Insurance Portability And Accountability Act ( Hipaa )1113 Words à |à 5 PagesMost of us are familiar with The Health Insurance Portability and Accountability Act (HIPAA), as the federal law that ensures protection and security of patientsââ¬â¢ personal and health information. Its initial purpose was to protect transmittal of electronic health information as technology began replacing paper (records, communications, and such.) While our personal information is being protected, and it prevents insurance companies from using this information against us when they are determiningRead More The Health Insurance Portability and Accountability Act (HIPAA)882 Words à |à 4 PagesHealth Insurance Portability and Accountability Act The Health Insurance Portability and Accountability Act, most commonly known by its initials HIPAA, was enacted by Congress then signed by President Bill Clinton on August 21, 1996. This act was put into place in order to regulate the privacy of patient health information, and as an effort to lower the cost of health care, shape the many pieces of our complicated healthcare system. This act also protects individuals from losing their healthRead MoreThe Health Insurance Portability And Accountability Act ( Hipaa )1383 Words à |à 6 PagesIn 1996 the Health Insurance Portability and Accountability Act (HIPAA). This act of congress has changed how every covered entity manages and distributes health information. Standards have been established for providers. Patients have the right to view their health records. They also have recourse if their health information is disclosed without their permission. As a patient you (or your personal representative) have the right to view and receive a copy of your medical and billing records fromRead MoreThe Health Insurance Portability And Accountability Act ( Hipaa )1533 Words à |à 7 PagesINTRODUCTION: PRIVACY IN HEALTHCARE The Health Insurance Portability and Accountability Act (HIPAA), public law was enacted on August 21, 1996 (HIPAA - General Information, 2013, April 2). HIPAA required the Secretary to issue privacy regulations to rule individually identifiable health information (HHS.gov, n.d.). The Health Insurance Portability and Accountability Act (HIPAA) applies to health plans, health care clearing houses, and to any health care provider who carries health information into electronicRead MoreThe Health Insurance Portability And Accountability Act ( Hipaa )899 Words à |à 4 Pagesinformation present in health care. In their field of work, nurses organize data they collect and incorporate it into effective nursing interventions and care plans. As technology increasingly arises in health care, nurses have the duty to maintain privacy and confidentiality of their patient. Therefore, nurses must be proficient in nursing informatics, are responsible for adequate information and documentation, and must abide the Health Insurance Portability and Accountability Act (HIPAA) to safeguard theirRead MoreThe Health Insurance Portability And Accountability Act ( Hipaa )1171 Words à |à 5 Pagesfixtures in any business or health care related profession. While these advances increased workplace efficiency and the ease in which one could access company and patient information, it opened organizations and individuals up to security breaches and unsecured information. Overall, these developments brought to light the need for enhanced security and patient control over medical records and treatment. In 1996, the Health Insurance Portability and Accountability Act (HIPAA) was enacted by CongressRead MoreHipaa Or Health Insurance Portability And Accountability Act Of 1996983 Words à |à 4 Pages HIPAA or Health Insurance Portability and Accountability Act of 1996 is a set of laws aimed to protect people from losing their health insurance coverage during change or loss of employment, to c ontrol health care fraud and abuse, and to maintain patient`s health information and/or status confidential. The origins of HIPAA go as far back as the 1990 when medical records were suggested to become computerized, management of health care records was questioned and portability of health insurance becameRead MoreHealth Insurance Portability And Accountability Act Of 1996 ( Hipaa )1319 Words à |à 6 Pagescovers information security within Healthcare: â⬠¢ Health Insurance Portability and Accountability Act of 1996 (HIPAA) â⬠¢ Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009, â⬠¢ Affordable Care Act of 2010 2. Review and describe each regulation in your own words in minimum 1000 words. Health Insurance Portability and Accountability Act of 1996 (HIPAA) HIPAA, the federal Health Insurance Portability and Accountability act was signed into law in 1996 by President ClintonRead MoreThe Health Insurance Portability And Accountability Act Of 1996 ( Hipaa )1685 Words à |à 7 PagesOffice of Civil Rights (OCR) maintains one of the most well-known laws meant to protect the privacy of health information - the Health Insurance Portability and Accountability Act of 1996 (HIPAA). HIPAA is composed of statute and rules such as the Privacy Rule, Security Rule, Breach Notification Rule, and others. These rules cover various aspects of health information security. For example, ââ¬Å"the HIPAA Security Rule specifies a series of administrative, physical, and technical safeguards for covered entitiesRead MoreThe Health Insurance Portability And Accountability Act Of 1996 ( Hipaa )1686 Words à |à 7 PagesLaw 104-191, the Health Insurance Portability and Accountability Act of 1996 (HIPAA). The purpose was to improve the Medicare program under tit le XVIII of the Social Security Act, the Medicaid program under title XIX of such Act, and the efficiency and effectiveness of the health care system. This public law encouraged the development of a health information system through standards and requirements for the electronic transmission of certain health information (aspe.hhs.go). The Act established a program The Health Insurance Portability And Accountability Act (... In 1996 the Health Insurance Portability and Accountability Act (HIPAA). This act of congress has changed how every covered entity manages and distributes health information. Standards have been established for providers. Patients have the right to view their health records. They also have recourse if their health information is disclosed without their permission. As a patient you (or your personal representative) have the right to view and receive a copy of your medical and billing records from physicians, pharmacists and health insurance provider. This record can be electronic or a paper copy. Patientââ¬â¢s can also request that their health records be sent to another health care provider. A health care provider or health plan mayâ⬠¦show more contentâ⬠¦If your provider wants to share information about you, they must request permission from you to do so. If you find that your medical record contains an error, you can request a correction. Your physician is required to respond to this request. If the physician does not agree with you, the patient is allowed to write a statement of disagreement that must be kept with your records. A breach is usually described as ââ¬Å"an impermissible use (or disclosure) under the Privacy Rule that compromises the security or privacy of protected health information.â⬠There are three exceptions to the definition of ââ¬Å"breach.â⬠The first exception applies to the unintentional acquisition, access, or use of protected health information by a workforce member. This can also apply to a person acting under the authority of a covered entity or business associate. If such acquisition, access, or use was made in good faith and within the scope of authority, it qualifies as an exception. The second exception applies to the inadvertent disclosure of protected health information by a person authorized to access protected health information at a covered entity or business associate to another person authorized to access protected health information at the covered entity or business associate, or organized health care arrangement in which the covered entity participates. In both cases, the information cannot be further used or
Saturday, December 14, 2019
The Modern Information Technology Free Essays
The information age is the age we live in today, and with the information age comes an age of ethics. When we deal with the new technologies introduced every day, we need to decide what we must consider ethical and unethical. We must consider all factors so that the use of the information readily available to many persons is not abused. We will write a custom essay sample on The Modern Information Technology or any similar topic only for you Order Now ââ¬Å"Information technology will be the most fundamental area of ethical concern for business in the next decadeâ⬠(Houston 2). The most widely used tool of the information age is the computer, whether it be a PC or a network of computer systems. As we enter the information age the newness and power of information technologies tests the ethics of the average person, not just the criminal and causes thousands of computer crimes to be committed daily. The most common computer crime committed daily, some aware and many not, is the illegal sharing of computer software. Software is any of the programs used in operating a digital computer, as input and output programs, as defined by Funk and Wagnalls Standard Desk Dictionary. When you purchase computer software, you purchase it with the understanding that it will be for se on a single computer, once installed on that system, it is not to be loaded on any other computer. However many people are not aware of this understanding, and many load a program on a couple of computers or on a whole network of computer systems not aware that they are committing a crime. Even though you probably will not be prosecuted for loading a program on a friends computer, this is where your ethics come in. Do you consider anything when you share a program with others? If not then consider the programmers of the software who are denied compensation for their developments every time you distribute a iece of software. ââ¬Å"Why is it that people who wouldnââ¬â¢t think of stealing pack of gum will copy a $500 piece of softwareâ⬠(Houston 3)? A popular form off illegal software distribution is throughout the online world. Whether it be the Internet, America Online, CompuServe, Prodigy, or a BBS (Bulletin Board System), software ââ¬Å"piratesâ⬠thrive freely online. These so called ââ¬Å"piratesâ⬠operate by uploading pieces of software, commonly referred to as ââ¬Å"warezâ⬠, into an online serviceââ¬â¢s database then sending through e-mail the rights to download them. ââ¬Å"The Information Superhighway has opened the door to a new kind of highway robbery ââ¬â the home shoplifting networkâ⬠(Mattia 43). When you access a online service, you are identified through an account which most commonly consists of a user ID and password. The password is so you only can access the online service with your user ID. Many people online use their own accounts to access their service, but many steal and use the accounts of others or make fake accounts. When online, these account ââ¬Å"piratesâ⬠many times trick other users into giving their passwords to them by impersonating an employee of the online service. Others can hack into the online services mainframe computer and steal thousands of accounts. Probably the most common method of getting online without paying is the use of fake or fraudulent accounts. These are made by giving false information when attempting to gain access to an online service. Name, address, phone number, and billing information, such as checking account or credit card number, are all falsified in obtaining an online account. With these stolen and fake accounts, software ââ¬Å"piratesâ⬠have virtually unlimited time to download their ââ¬Å"warezâ⬠without any charge to them. Many people donââ¬â¢t consider the people behind the creation of software when they illegally distribute it. The developers of software are not properly compensated for their work because of the extent of software piracy. No one can argue with a software companyââ¬â¢s desire, and right, to make sure everyone using their products has paid for it (Furger 73). The numbers add up, it is estimated that in 1994 alone that software companies lost $15 billion from illegal software copying (Maremont 65). It is not only illegal, but clearly unethical to distribute software knowing hat the people behind the software are experiencing the downfalls of Every time software companies cannot compensate their programmers for their work, more people are out of a job. Consider this, you enter a store and purchase an item, during this transaction you give your name and phone number. The person you have given this information to then enters it into a computerized database. After this person has collected a sufficient amount of names, they then sell it to a telemarketing firm for a profit. This action is legal, but is it ethical. Do you want your name sold without your consent? Most people donââ¬â¢t because they donââ¬â¢t want to be bothered by sales persons on the telephone. Also, your address could be sold and you put on a mailing list. Then its an issue of do you want your mailbox filled with junk mail. This action is unethical for the simple reason of consent. If the person had just gained consent to enter the names into his/her database then he would not have committed and unethical act. One conclusion from studies sponsored by the National Institute of Justice is that persons involved in computer crimes get form skills and interests at an early age. Usually they are introduced to computers at home or in school and usually start their ââ¬Å"career pathâ⬠with illegally copying software (McEwen 2). As young people interact with hackers, they incorporate the beliefs of the hackers into their own. Many of these unconventional beliefs of young hackers about information and computers leads them to a career in computer crime. Many times it is the lack of education by parents and schools that helps to make these beliefs all the more true to a young person. Computer criminals have their own set of beliefs about information and computers. Their beliefs are based on obvious unethical reasoning. For example, hackers believe that computerized data are free and should be accessible to anyone. They also believe that passwords and other security features are simply obstacles to be overcome in obtaining data that should already be available and while data should never be destroyed, there is nothing wrong with viewing and transferring data for oneââ¬â¢s own use (McEwen 2). One member of the Legion of Doom, a nationwide group of hackers who exchange information about computer systems and techniques o break into them, has said, ââ¬Å"Hackers will do just about anything to break into a computer except crashing a system, thatââ¬â¢s the only tabooâ⬠(McEwen 2). The key to stop computer criminals from forming is education. It is often times the case that people commit computer crimes without even know they are doing so and the reason for this is the lack of education. Few schools teach computer ethics, and parents of arrested hackers are usually unaware that their children have been illegally accessing computer systems (McEwen 2). Colleges and universities do not usually include computer use and abuse in their ourses, arguing that it is the responsibility of the schools. On the other hand, many secondary school educators are not sure about what should be taught and are reluctant or unable to add ethical computer education to many subjects in the curriculum. Textbooks on computer literacy rarely mention computer abuses and individual responsibilities. Educators and software developers have worked together to prevent software piracy in educational institutions. In 1987, the Software Copyright Committee of the International Council for Computers in Education (ICCE) developed a policy to guide educators. The policy call on school districts to teach staff the provisions of the copyright law and both staff and students the ethical and practical implications of software piracy. This policy has been adopted by many school districts across the country (McEwen 3). In recognition of the problems arising with the illegal and unethical use of computers, criminal justice forces have begun to crack down on computer criminals. In 1989, three computer crime studies were sponsored by the National Institute of Justice. One of these studies examined different organizational approaches for computer crime nvestigation and prosecution, another documented the experiences of several dedicated computer crime units, and the third developed a computer crime investigation handbook (McEwen 2). Computers are a permanent fact of life in work places and classrooms across the country. More businesses are likely to incorporate policies on information access and confidentiality in their employee orientation and training programs. Many schools and universities, responding from pressure around them, are beginning to incorporate computer ethics into their courses. How to cite The Modern Information Technology, Papers
Friday, December 6, 2019
Essentials and Influence of Business Communication
Question: Discuss about the Essentials and Influence of Business Communication. Answer: Introduction: The relatively unstructured brainstorming method involves suggesting verbal ideas. The situation is analyzed and discussed in a detailed way so that group members can get detailed information about the issue and work accordingly. Once the ideas are solicited and presented, the members of the group begin the evaluation process. They evaluate the suggestions and ideas presented. Brainstorming is a useful method as it generates alternatives. Electronic brainstorming may be utilized to the fullest as the message can be spread quickly through email, or online discussion room (Guffey and Loewy 2012). Consensus decision making method Large groups can utilize the consensus decision making process. This approach generates widespread agreement and participation. This process is beneficial as it is inclusive, collaborative, participatory, cooperative, and agreement seeking. It includes a large number of stakeholders. Everybody would get an opportunity to contribute their ideas. This method gives voice to every participant and incorporates their concerns into a proposal (Russ 2013). The concerns of all group members are included in the decision making process. Since it is a large sized group, the managers can also convey their messages and ideas through media. Techniques and plans to be avoided The greatest problem of a large group within an organization is groupthink. Groupthink is a nefarious misstep for a group. Groupthink reduces the potential of the members. In-group pressure results in deterioration of moral judgment, mental efficiency, and reality testing. Hence, groupthink must be avoided. Moreover, one person should not be dominant over the other. Every person must be heard. He/she must be given the chance to speak and convey their ideas. Isolation between members in any group must be avoided as isolation shuts down individuals from the external world. The isolation gets heightened to such an extent that it becomes a survival strategy for the group. This is detrimental as the decision making ideas are unidirectional. Such separation creates boundaries and reduces the scope of innovation (Kernbach et al. 2015) Recommendations for seating plans and techniques The first step to solve any problem within a group is to define and identify the problem. A problem is half solved if it is stated well. The next step is to analyze the situation. It is imperative to examine the symptoms, causes, effects, and subproblems. To solve a problem, it is imperative to think in a reflective manner. The self-regulatory skills must develop to achieve a better learning process within a group. Tutorials and seminars can be an effective way to facilitate the learning process. Tutorials can promote investigation of issues, self-motivation, and deep thinking and learning (Hair 2015). The teaching sessions within a small group must be based on principles such as introducing the topic, maintain group role, ground rules, debriefing, and briefing. Techniques and plans to be avoided The physical and mental distance between the members of a group must be minimal. Even if it exists, it must be diminished. For a small group, a small room must be assigned. The physical distance is essential to create a close relationship between the members. Hence, the greater physical distance must be avoided. When group members are unable to establish contact with themselves, the problem arises. They must be able to hear and see each other clearly. An overcrowded room poses an adverse impact on the decision making process of group members. The room must be adequately lighted and comfortable. It must comprise a board, overhead project and other tools essential for a meeting or working without any impediments(Kernbach et al.2015). Establishing communication within the team members is critical. The gap in communication may lead to severe consequences. References Guffey, M.E. and Loewy, D., 2012.Essentials of business communication. Cengage Learning. Hair, J.F., 2015.Essentials of business research methods. ME Sharpe. Kernbach, S., Eppler, M.J. and Bresciani, S., 2015. The Use of Visualization in the Communication of Business Strategies An Experimental Evaluation.International Journal of Business Communication,52(2), pp.164-187. Russ, T.L., 2013. The influence of communication apprehension on superiors' propensity for and practice of participative decision making.Communication Quarterly,61(3), pp.335-348.
Friday, November 29, 2019
Piercing the Corporate Veil England and Wales
Introduction The main reason for forming a corporation is to protect owners from liabilities and debts of their ventures. This guarantees the continuity of the corporation. However, we have noted cases whereby courts have reached a point of considering a separate business enterprise as a way of gaining unfair advantages over creditors and other claimants.Advertising We will write a custom essay sample on Piercing the Corporate Veil: England and Wales specifically for you for only $16.05 $11/page Learn More Moreover, it is clear that courts apply various standards for various types of business entities. Therefore, such variations in decision-making can affect the future decisions of courts when piercing the veils of other entities, which can have significant ramifications for the owners. This paper looks at circumstances under which courts can decide to pierce the corporate veil using cases from England and Wales. It also reviews both past and recent tren ds and how they may affect future decisions of courts. Piercing the Corporate veil Shareholders of business corporations and limited liability entities design their organisations to protect themselves from creditors. Individual investors take risks by making investments in new or existing businesses. The public favours creations of new entities because of job creation. In addition, they also act as sources of taxes for the government. Corporations and limited liability companies are responsible for business developments as they protect their owners from failure resulting from business activities. Thus, if the new corporation fails, it is responsible for all debts it incurred as a new venture. However, corporations protect shareholders from such claims. Thus, the business owner has no obligation to pay such debts unless there are personal guarantees of the owner against debts. Therefore, in case of lawsuits, business entities face risks of losing their assets. However, the corporate veil protects assets of the owner. Thus, we can say that not many entrepreneurs would risk their personal wealth without a corporate shield.Advertising Looking for essay on business corporate law? Let's see if we can help you! Get your first paper with 15% OFF Learn More We have to note that the lawsuit may only remain as a form of threat to the business only if the owner treats that business as a distinct and separate entity from himself. In most cases, the court may establish that the corporation has no real assets to pay for its debts. In this case, the creditor may seek to convince the court that a corporate shield should not apply in the case. Instead, the creditor will strive to recover the debts from personal assets of the owner. This practice of collecting debt is piercing the corporate veil in order to get the courtââ¬â¢s decision regarding the ownerââ¬â¢s obligations for the creditor in debts incurred. Shareholder Protection and Piercing the Corporate Veil Courts have often delivered some controversial rulings about piercing the corporate veil. The landmark case of Salomon v A Salomon Co Ltd of 1897 is one of such court rulings. The recent case that has influenced the idea of piercing the corporate veil is the case of VTB Capital Plc v Nutritek International Corp (VTB Capital) of 2011. There is also the case of Antonio Gramsci Shipping Corp v Stepanovs (Gramsci) of 2011. These cases have created new interests regarding the scope of piercing the corporate veil (Pugh, 2012). In the case of Gramsci, the Court ruled that it was appropriate to pierce the corporate veil of Stepanovs so that Gramsci could enforce terms of the agreement under the contract. The Court based its decision on the fact that the owners established the company to perpetuate fraud by abusing structure and personality of the company. The UK has effective Corporate Governance Codes (the Code). It works based on ââ¬Å"comply or explainâ⬠principle. This gives it flexibility of adoption among corporations of the UK. The Code has gained popularity due to its effectiveness in promoting corporate governance in the UK. According to the Code, ââ¬Å"corporate governance is the system by which board of directors direct and control companiesâ⬠(Financial Reporting Council, 2012). The main reason for corporate governance is to promote effective growth of business through prudent management, which bring the long-term success of the corporation. As a result, the Code ensures that corporations exist to serve interests of shareholders and the public.Advertising We will write a custom essay sample on Piercing the Corporate Veil: England and Wales specifically for you for only $16.05 $11/page Learn More However, the Code can only controls regulatory practices of corporations, but it cannot control their internal affairs such as acquisitions of assets or credit facilities. Thus, corporations are liable for their own d ebts. In some cases, there are exceptions regarding directors or shareholders obligations to creditors (Rogowski, 1999). Thus, creditors may seek personal assets of directors and shareholders. Given such conditions, courts may pierce the corporate veil of the corporation and hold shareholders liable for debts. Shareholders have enjoyed limited personal liabilities. This implies that such directors and shareholders are not liable for creditors (Gower Davies, 2003). Occasionally, shareholders or directors may fail to uphold financial integrity and effective corporate governance requirements. In these cases, directors or shareholders risk becoming personally liable for corporation debts. This is because creditors or the court may establish that there is no difference between the shareholder and the corporation. Theories of piercing the corporate veil The principle of piercing the corporate veil differs from one country to another. It also creates confusion in the corporate law because of the idea of limited liability. The views among corporate law scholars point to interpretations of limited liability and corporation activities when handling the corporate veil issue. Two theories exist to explain the idea of piercing the corporate veil. They also explain why courts can lift the corporate veil. First, there is the alter ego or self-theory. This theory looks at ââ¬Å"if there is a distinctive nature of the boundaries between the corporation and its shareholdersâ⬠(Forji, 2007). Second, instrumentality theory focuses on the use of a company by ââ¬Å"its owners in ways that benefit the owner and not the corporationâ⬠(Forji, 2007). Thus, on any given case, the court shall decide which theory applies in a particular case. However, courts have not been effective in piercing the corporate veil and may only do it to achieve equitable results for both parties.Advertising Looking for essay on business corporate law? Let's see if we can help you! Get your first paper with 15% OFF Learn More Situations under which the court lift the veil of corporation Occasionally, courts may ignore the provision of limited liability and pierce the corporate veil. This applies when the court perceives that shareholders may not be different from the company. In this case, the court disregards the provision of corporations as a separate entity. Instead, it treats the two as a single entity (Payne, 1997). In English and Wales company laws, the courts insist on establishing a distinction between the business and its owners. Thus, Anglo-Saxon courts reflect on several issues before piercing the corporate veil. These may include some irregularities in the companies, in the partnership, groups, and subsidiaries. The company may be a sham, facade, or a creation of another company with intentions of facilitating evasion of fiduciary requirements. In this case, they automatically disregard the separate personality of the company in question (Bainbridge, 2001). Fraud English and Wales courts have pierced the corporate veil in cases involving fraud. In this case, a shareholder of a corporation establishes the corporation for evasion legal or fiduciary obligations. This is when the intention to create a corporation is to deny the creditorsââ¬â¢ pre-established legal rights and refute claims. The famous case is that of Re Edelsten ex parte Donnelly. In this case, the court did not ascertain fraud of the owner of the company, who failed to take the responsibility regarding his creditors basing his decision on limited liability. This means that the court could not rule out fraud as the establishment of the business was not out of sham (Farrar, 1990). Shareholder created the company in order to protect any property acquired after bankruptcy from ending with the one of bankrupt trustees. Creditors incur unjust costs Sometimes, creditors may incur unfair costs or losses and the court may decide to pierce the veil. Unfairness may cause courts to pierce the corporate veil. The cou rt may argue that it would result to justice and fairness for the creditor. Lack of a clear separation between the entity and the owner Some business owners have failed to establish a distinction between their personal lives and their entities. In this case, the plaintiff may request the court to declare the business as a sham entity, which does not exist. Therefore, owners take personal operation of the business and are liable for debts incurred. Agency Some companies operate as corporate groups. Thus, the parent company may not be clear. Scholars argue that the parent company may conceal its identity under the agency name. The courts have argued that companies do not exist to serve the purpose of being agents for their owners. Instead, they are separate entities. The case that explains the role of agency in piercing the corporate veil is Barrow v CSR Ltd (Forji, 2007). However, it is difficult to establish that the company operates as agent to its shareholders. Thus, courts may re fuse to pierce the veil in that case. This was the case of The Electric Light and Power Supply Corporation Limited v Cormack where the court did not pierce the veil (Forji, 2007). Corporate groups The courts also do not hesitate to pierce the veil in corporate partnerships. A good example to illustrate this instance is the case of Bluecorp Pty Ltd v ANZ Executors and Trustee Co Ltd (supra). The court declared, ââ¬Å"Inter-relationship of the corporate structure and the degree of their participation in shared enterprise with benefits reaped from steps initiated and plans executedâ⬠(Forji, 2007). Sham The court may consider a sham or a facade when lifting the corporate veil. In this case, the real plans behind the establishment of the entity are vague and may not be real. Briefly, it is something that makes false appearance, disguise, and or serves to conceal the real purpose behind its existence. The case of Sharrment Pty Ltd v Official Trustee in Bankruptcy served to explain a sham (Forji, 2007). Fraud and sham go together. Courts have maintained that an argument for a sham also depends on an argument for a fraud. This is because shareholders cannot perpetuate fraud using a legal and an existing entity. Consequences of Piercing the Corporate Veil If courts pierce the corporate veil, then the business owner become personally liable for the entityââ¬â¢s debts. Thus, the owner loses rights to limited liability. Instead, the creditors turn to the shareholders personal properties, homes, other investments, and bank accounts to clear their business debts. The recent arguments in the case of Gramsci and VTB Capital highlight how the judges give diverse views about piercing the corporate veil of an entity. Judges argues for or against their decisions regarding rulings of whether or not they ought to have pierced the corporate veil. Several corporate scholars review the case with increased interest to understand whether the courts have established cases of in justice and impropriety in the case. A closer look at the VTB Capital Inc. v. Nutritek International Corp The Court of England allowed for an appeal in the case of VTB, which has raised several questions regarding the legality of piercing or lifting the corporate veil. This case shall provide an opportunity for the Court to explain circumstances under which a Court can pierce the veil. It shall also demonstrate the Courtââ¬â¢s position regarding the shareholders or directors of the company with reference to facility agreements. We have to recognise that there is no definite rule on how the case can go as the decision entirely rests with the Court. In all, this case shall set a new precedent on the doctrine of piercing the corporate veil. The impact of VTB case shall extend beyond England and Wales to other countries under the Commonwealth influence. Facts about VTB case This case comes from the failure of Russagroprom LLC (RAP) of to repay its loan to Capital (VTB). RAP acquired a loan facility in order to facilitate an acquisition of some dairy companies for Nutritek International Corporation (Nutritek). Nutritek is the defendant in this case. VTB is an English company operating as a subsidiary of the Russian Bank, JSC VTB Bank of Moscow. VTB granted a facility to RAP through a ââ¬ËFacility Agreementââ¬â¢ terms. They also executed many interest rate swaps (ISA). RAP is a Russian company. However, when RAP failed to service the facility, VTB saw it appropriate to sue the loan beneficiary, Nutritek. Nutritek is a Virgin Island company of England. VTB also sued two foreign affiliates of Nutritek. In addition, the list also included a Russian (Malofeev) VTB claimed as the owner and controller of the companies. VTB argued that Malofeev was the main beneficiary of the facility, owner and controller of Nutritek, its foreign affiliates, and RAP (Kain, 2012). The company first made its claims under tort. It claimed that Nutritek and other defendants were liab le for deceit or fraud and conspiracy. VTB claimed that Nutritek and its associates engaged in two acts of fraudulent activities that facilitated its entry into the facility arrangement and ISA. First, VTB claimed that Nutritek and its associates misrepresented that RAP was an independent entity with its own arm of control. Second, VTB also claimed that Nutritek and its associates misrepresented the actual value of the company to its auditors, Ernst Young Valuation Company, which conducted valuation for VTB Moscow. VTB acquired an ex parte order that allowed it serve Nutritek and its associate ex juris in 2011. Ex parte order also had a ââ¬Å"worldwide freezing of Malofeevââ¬â¢s assets of US $200 millionâ⬠(Kain, 2012). Nutritekââ¬â¢s reaction aimed at setting the orders aside. As a result, VTB realised it was appropriate to amend its claims. In this new claim, VTB claimed that Nutritek and its associates acted jointly on several occasions with RAP to disregard the Faci lity Agreement and ISA arrangements. VTB argued that, under these new claims, the Court would pierce the corporate veil of RAP. VTB based its main argument rested on the fact that the ââ¬Å"Facility Agreement contained forum-selection and choice-of-law clauses in favour of Englandâ⬠(Kain, 2012). VTB claimed that the Court could consider all defendants as responsible parties to the facility under the Facility Agreement. In this case, the Court could apply ââ¬Å"the English forum-selection clause, or base the case on the English CPR Practice Direction, which permitted service ex juris in relation to contractual claimsâ⬠(Kain, 2012). Discussion of the case Judge Arnold dismissed VTBââ¬â¢s claims in November 2011. On the other hand, he granted the Nutritekââ¬â¢s motion of the service ex juris order. This also extended to the worldwide freezing of Malofeevââ¬â¢s assets. The judge claimed that VTB had not established whether England was the appropriate location to t ry the case. Judge Arnold maintained that even if the Court pierced the corporate veil of RAP, it could not guarantee that the legal consequences would mean that the Court could enforce the Facility Agreement and ISA against Nutritek and associates. Further, the Court reaffirmed Arnoldââ¬â¢s ruling on June 20, 2012 at the English Court of Appeal. Lloyd argued that there was no such principle as piercing the corporate veil. However, the Judge had only one provision for VTB. It argued that the Court could look into the case based on the companyââ¬â¢s corporate sham or facade. In this case, the Judge argued that the case of was only valid under ââ¬Å"special circumstances, which indicate that it was a mere faà §ade concealing the true factsâ⬠(Kain, 2012). The Judge asserted that: ââ¬Å"â⬠¦ In cases in which that is done, the authorities show that it will or may lead to the granting of remedies against the company which, veil piercing apart, might appear in principle to be available only against those controlling it; and, equally, against the controllers when they might appear in principle to be available only against the companyâ⬠â⬠¦.. (VTB Capital plc v Nutritek International Corp and others [2012] EWCA Civ 808). Lloyd also maintained that the Court had the competency and the capacity to pierce the corporate veil in case there was no other means to ensure that the company and its controllers take responsibility for their wrongdoing. Lloyd also established the following arguments from the case. First, Lloyd noted that ownership and controls of entities alone do not guarantee piercing the corporate veil. Second, the court cannot simply pierce the veil in ââ¬Å"the interest of justice even if there is no third party in the caseâ⬠(Kain, 2012). Third, the Court can ââ¬Å"only pierce the veil on grounds of improprietyâ⬠(Kain, 2012). Fourth, there must be a connection between the use of the companyââ¬â¢s structures in order to evade or conceal liability and the impropriety. He also notes that the companyââ¬â¢s engagement in impropriety alone does guarantee piercing its corporate veil. Fifth, the Court argued that it was necessary to establish both an act of impropriety, control, and ownership of the entity by the offender. In this case, the offender uses the corporate to conceal the real facts with the intention of concealing impropriety. Finally, the Court also recognised that an entity could also be a sham from its inception, even if the ownership did not intend to use it for deception. Therefore, the Court agreed that it could pierce the corporate veil based on the relevant offense of fraudulent or dishonest activities involving misuse of the corporate identity in order to conceal the facts behind the corporation identity. The failed VTBââ¬â¢s Claims From these observations, the Court established that VTB had a case against Nutritek and its associates, and that it was proper to pierce the corp orate veil of RAP. In this sense, the issue was whether it was possible for the Court to pierce the corporate veil of RAP in order to render the defendants (Nutritek and its associates) liable for the Facility Agreement and ISA. However, VTBââ¬â¢s claims did not succeed on the following ground, at least, from Lloydââ¬â¢s argument. According to Lloyd, after reviewing the English law, they established that they could not support the idea of granting equitable relief against the corporation or its owners beyond this. In other words, the Court could not hold the owner as an actual party to the contract. Given this view, the Court rejected claims of undisclosed principals as agents of the contract. According to the Court, VTB assumed that, under the English law, the Court could hold a party responsible to a contract because of controls or ownership. However, the Court established that none of the parties had any idea about the contract. The Court also noted that to accede to VTBâ⠬â¢s claims would amount to making intrusions into the principle of law that respects contractual agreements between parties, and any other party interested in the contract. In this light, the Court noted that the case of VTB did not fall under this category and that a stranger to the contract was not liable to the contract. The Court also did not recognise the puppet entity and the controlling puppeteer. However, it was important to identify the puppet company and its owners to justify the grant of a judicial remedy when it was convenient and necessary to do so. Still, the Court could not go to the extent of treating the puppeteer and the puppet entity as the other parties because they were distinct entities. The Court noted that fulfilling this claim amounted to ignoring Salomon principles. In this context, the Court could not assume that the puppeteer and the puppet entity were party to the contract. In short, Lloyd noted that it was not proper to use the common law as VTB had suggested. In other words, the court did not recognise VTBââ¬â¢s claims of piercing the corporate veil of RAP in this case. Any such decision would indicate that the Court surpassed the current principle of the common law. Further, it would mean that the Court brought new parties to the contract. The Court expressed that such claims could not apply in this case because it was not the right one for such common laws. The Court viewed this case as a commercial deceit that English law could handle under tort. This implied that VTB could only make claims against defendants under tort principles for deceits and wrongful acts. Therefore, the Court claimed that there were ââ¬Å"no policy reasons for giving the case an artificial remedy in a situation, which VTB did not needâ⬠(Kain, 2012). According to the Court, VBT merely invoked claims to support it cases because it ââ¬Å"assumed that the English courts could assume jurisdiction in its claimsâ⬠(Kain, 2012). Possible contr ibutions of the case with regard to piercing the corporate veil This case has created debates regarding the legal principle of piercing the corporate veil. Consequently, it will have significant influence among the Commonwealth states. Courts and commercial lawyers must also review their approaches with reference to this case and principle of piercing the corporate veil. This case raises some issues of fundamental interests. First, the Court established that VBTââ¬â¢s claims had no factual, legal, or principle basis under English common law in which the Court could lift the corporate shield of RAP. According to this ruling, the Court cannot make a controller of another entity a party to a contract of another company. In this sense, the Court observed ââ¬Å"the principle of a separate legal entity and the law of privity of a contractâ⬠(Kain, 2012). Scholars may argue that this decision can limit Englandââ¬â¢s attraction for foreign cases involving corporate disputes. How ever, the English Court has clarified significant matters about piercing the corporate veil. This implies that the Court cannot just rule to satisfy the claims of another party. It must observe principles of common laws. Any ruling in favour of piercing the corporate veil of RAP could have created new controversies regarding the principle of corporate law. Second, if the Court could have affirmed VBTââ¬â¢s claims, then it would have raised issues regarding the remedies available to VBT and the position of the companyââ¬â¢s controller with reference to separate and distinct party to the contract. Affirming these claims of VBT would mean disregarding the principle limited liability for corporation directors. Thus, the Court avoided contradict the principle of separate legal personality in the benchmark ruling of Saloman v A Saloman Co Ltd [1897] AC 22. Third, we must also note that VBT wanted the Court of England to pierce the corporate veil of a foreign company. The Court of A ppeal did not refer to RAP as a foreign company. The issue arises whether it is appropriate for the Court of England to a pierce a veil of a foreign company and the possible consequences of doing so. On the other hand, we must also note that VBT is a Virgin Island company. Thus, the Court acted under English law. However, it did not confirm the position of RAP as a foreign entity. We must also recognise careful analysis of the English law by the Court. This analysis helps commercial entities and lawyers understand circumstances under which the Court can pierce the corporate veil. Thus, it helps clear discrepancies in past rulings. For instance, in the case of Gramsci, the Court had to pierce the corporate veil. As a result, the puppeteer or the controlling mind had to bear responsibilities of the contract. In contrast to VTB case, questions arise whether the Court made a wrong judgment on the case of Gramsci. In other words, the Court did not obey the principle of separate legal ent ity of the owners. In addition, the Courtââ¬â¢s ruling highlighted that it could only pierce the corporate veil based on the principle of equitable remedies. In this manner, the puppeteer must not evade its contractual liabilities. However, the Court could not take such action on a non-contractual puppet or puppeteer. However, this case is not over just yet. VTB applied for an appeal to the Supreme Court. This implies that new decisions on piercing the corporate veil of a corporation and its controlling minds shall emerge. Conclusion This matter raises some controversies regarding the relevancy, applicability, and effectiveness of the principle of piercing the corporate veil. In this case, the Courts should declare their positions regarding the principle of piercing the corporate veil. This is because Judge Arnold declared that there is no such principle as piercing the corporate veil. From the above examples, it is clear that the act of piercing the corporate veil is not clear. It is also controversial and will persist to be so for many years coming. The case of VTB shows that piercing a corporate veil exists only in theories. For instance, the Court noted that it was only valid under a ââ¬Å"special circumstance, which indicates that it was a mere faà §ade concealing the true factsâ⬠(Kain, 2012). With reference to the above terms, English law does not recognise the principle of piercing the corporate veil. In addition, the use of terms like ââ¬Å"a mere faà §ade concealing the true factsâ⬠makes VTBââ¬â¢s claims under piercing the corporate veil difficult. Conversely, English Courts are willing to preserve well-established and long-standing principles of common laws like the rule of corporate personality. This is exactly how the Court ruled on the case of VTB. It recognised the claim that Nutritek and its associates were independent party to the contract. Thus, were not part of the agreement consequently, had no liability over the claims . Nevertheless, we have to recognise that there are no provisions on how courts should rule on cases about piercing the corporate veil. Still, rulings may also vary from various jurisdictions. For instance, the outcome of the case could have been different in Russia where RAP has its origin. Therefore, we have to look at how courts appreciate different cases involving piercing the corporate. We can see the contradicting decisions on Gramsci and VTB cases and the merits under each case. The ruling could have different if there were direct issues like fraud, sham or facade, unfairness, corporate groups, and agency. Most courts pierce the veil based on these issues. However, the Court established that the case of VBT was a deceit with a perfect remedy under tort laws. Thus, it ignored the inappropriate conducts of the controlling mind behind the deceit. These rulings make the concept of piercing the corporate veil uncertain and not reliable for creditors. The concept is also undergoing inevitable changes. Thus, the issue persists whether Courts can go beyond injustice and impropriety. Still, we have also recognised that the English Court can only pierce the veil to grant equity to parties in dispute. This ruling also demonstrates that Courts still focus on fraud as the key requirement for piercing the veil. Reference List Bainbridge, S 2001, ââ¬ËAbolishing Veil Piercingââ¬â¢, J. Corp Journal of Corporate Law, vol. 26, p. 479. Farrar, J 1990, ââ¬ËFraud, Fairness and Piercing the Corporate Veilââ¬â¢, Canadian Business Law Journal, vol. 16, p. 474. Financial Reporting Council 2012, Annual Reports. Web. Forji, A 2007, The Veil Doctrine in Company Law. Web. Gower Davies 2003, Principles of Modern Company Law, 7th edn, Sweet and Maxwell, London. Kain, B 2012, UK Supreme Court to Pierce the Issue of the Corporate Veil: VTB Capital Inc. v. Nutritek International Corp. Web. Payne, J 1997, ââ¬ËLifting the Corporate Veil: A Reassessment of the Fraud Exceptio nââ¬â¢, Cambridge Law Journal, vol. 1997, p. 56. Pugh, C 2012, ââ¬ËUnited Kingdom: Piercing The Corporate Veil ââ¬â Recent Developments, Mondaq Corporate Company Law, vol. 2012 , pp. 1-4. Rogowski, G 1999, Company Law in Modern Europe, Dartmouth Publication, Sudbury, MA. This essay on Piercing the Corporate Veil: England and Wales was written and submitted by user Stephanie N. to help you with your own studies. You are free to use it for research and reference purposes in order to write your own paper; however, you must cite it accordingly. You can donate your paper here.
Subscribe to:
Posts (Atom)