Shafron V Australian Securities and Investments Commission

Question: Discuss about the Shafron V Australian Securities and Investments Commission. Answer: Introduction It was in the year 2012, that a significant clarification of the scope of the duties of the directors of a corporation was provided by the High Court of Australia in the case of Shafron v Australian Securities and Investments Commission (2012) 286 ALR 612 (Shafron) (High Court of Australia, 2012). This was the case in which the extent of the responsibility of an individual who has been granted a position of an officer within the meaning of section 9 of the Corporations Act 2001 (CA). Also, it was clearly stated that an individual who has been an officer could undertake dual roles within an organization under section 9 of the Act as per the extent of responsibility which was provided in this case (Scott, 2012). So, in these kinds of cases the dual roles were not able to be departed for the objectives of examining the duty of care and diligence which was owed by the officer under section 180(1) of the Act. So, in this case, Shafron has specifically clarified what all comprises of participation in making a pronouncement for the objectives of the meaning of the word Officer which was stated in s 9(b) (i) of the CA (Sainty Law, 2012). Background and facts of the Case In August 1998, Mr. Shafron i.e. the plaintiff was appointed by Hardie as a general advocate and company secretary (CS) of the corporation. Though, until November 1998 he was not appointed by the corporation as a CS in a formal manner. In November 1999 with the plaintiff, Mr. Donald Cameron was employed as a united CS of Hardie. In February 2001, the board of directors of Hardie had a meeting in order to consider an offer to depart from the James Hardie group two corporations with major asbestos obligations. The Plaintiff was found to have been in contravention of the section 180(1) of the Act by: Failing to recommend the board of directors of Hardie, that some supplementary data in regard to the partition offer would have been revealed to the Australian Stock Exchange, and Failing to recommend the board of directors of Hardie that an actuarial statement on which the board of directors were dependent in bearing in mind the division proposal did not grant for superimposed price rise when a cautious story would have done so (Tam, 2012). Outline the duties/responsibilities breached and explain why the duties were breached. Section 180(1) of the CA, specifically states that directors of an organization must perform their authorities and fulfill their obligations with the due extent of care and diligence that a prudent individual would work out if they were: The directors or officers of an organization in the situations of an organization; and The officers who were engaged in the office which was held by at the same time had the similar tasks within the organization as, the director or officer (DApice and Curran, 2012). Duties of directors which have been defined under section 180(1) of CA connect not only to directors but to the officers in a broad manner. It was established by the Court of Appeal that the plaintiff was an officer on two different basics as; He was the CS of Hardie, and He was an individual who makes, or contributes in making pronouncements that put an impact upon the entire, or a considerable part, of the trade of the organization. On request, the plaintiff disputed that his duties while being in the position of a CS were restricted to the roles of the CS, and did not broaden to his broad counsel roles (Freeman, 2016). The Plaintiff also want to demarcate his roles while being in the position of a CS by disagreeing that they should be associated to the roles of his cooperative CS, Mr. Cameron, whose roles were chiefly managerial. It was further argued by the plaintiff that he was not an individual who contributed in making the verdict in connection to the parting offer, as it was a pronouncement for the board of directors, of which he was not a part. Lastly, the plaintiff stated that if he was a bureaucrat (on either basis), he had, in any occasion, not violated his obligations in connection both the concern relating to the ASX or the actuarial (Australian Institute of Company Directors, 2017). It was clearly observed by the tribunal that it was significantly to be suspicious for the fact that Mr. Shafron being the director of the corporation could have implemented certain roles in a capacity of a CS and other functions like being a general counsel. There was no proof that the plaintiff has performed some tasks in one capacity and other work in another. Because the responsibilities of a specific CS in specific corporations were the matters of fact, proof of the roles of Mr. Cameron did not show that company secretarial functions of the plaintiff were correspondingly administrative (Hickey and Lam, 2015). The tribunal then measured whether, if the functions of Mr. Shafron could be separated, the division would have an effect on the result. It also renowned that section 180(1) (b) of the Act secures the degree of care and diligence by indicating to the office held and the tasks with the organization of the relevant officer (Comino, 2014). It was then that it was concluded by the tribunal that the term responsibilities which was mentioned in section 180(1) (b) have been defined as the real responsibilities of the authentic officer, not simply the statutory tasks of an individual who holds the office of CS. The findings of the Court of Appeal were at this time was agreed by the tribunals which granted a recommendation in connection to the issue of ASX which was within area of responsibility of the plaintiff. Also, the grant of such suggestion which was granted in connection to the actuarial issue was also within the area of responsibility which was imposed upon the plaintiff being in the position of the director (Wotton Kearney, 2012). Consequently, the responsibilities of Mr. Shafron by being in the position of a company secretary of Hardie were broad enough to hold up a judgment that he owed the duties of an officer in carrying out all of those responsibilities. As per the verdict which was given by the Court of Appeal of New South Wales was appealed and as per the Act the plaintiff was found to be in violation of his obligation of care and diligence by: Failing to give an opinion to the other directors on board that the draft ASX statement which was approved by the Board was deceptive; and Failing to give an opinion to the board that the information which was granted by actuarial Consultants i.e. the plaintiff had been preserved on behalf of JHIL, and This granted the foundation for a cash flow form which was measured by the board in connection to the projected reformation of JHIL, did not take into consideration the the price rises (Mire, 2014). Then the plaintiff approached the High Court and put forward his case. The basic reason of his petition was that though he established that section 180(1) of the CA although would be applicable on him as he was a CS. But the violation of section 180(1) which ASIC had suspected against him were alarmed with measures which he made in his competence as general advocate and not as an executive of JHIL. In other words it could be stated that, his function as general counsel and CS was isolatable into jobs which he embarked on as advocate, and then the responsibilities he assumed as CS. The idea which was provided and mentioned above was rejected that the plaintiff could segregate his tasks and competences. To a certain extent, it was concluded by the tribunal that the responsibilities of Mr. Shafron were inseparable and must be observed as an amalgamated completely (Norton Roseful Bright, 2012). So, in order to reach such conclusion it was specifically established that in order to settle on the range of everyday jobs of an official of a corporation, an individual must inspect all of the work which was carried out for that organization by that officer. In specific it was noted by the tribunal that: The capacity of the role of the plaintiff as a CS could not be determined simply by an evaluation to the function of his co-secretary, whose function never developed to be above merely managerial roles. The Plaintiff did not produced any proof which would have verified or suggested that he carried out certain tasks in the capacity of being a CS, while he carried out others in a different capacity of being a counsellor. The designation of general advocate and CS signified specifically that a significant part of the responsibility of the plaintiff was to take the essential ladders to make sure that JHIL have fulfilled with all pertinent lawmaking necessities. Such requirements include those that were applicable to JHIL as a listed corporation, and that this was related to the stipulation of essential recommendation (Konstantinidis, 2012). When a secured guidance from third parties was taken by the plaintiff then put that guidance before the board of directors of JHIL for its utilization, his liabilities did expanded for recognizing the restrictions of the recommendation which was provided by the third party. So, it was established and pronounced by the tribunal that the extent of care and diligence which was mentioned in section 180(1) of the Act was single-minded by observing at the situations of the organization. The section has also included the workplace and liabilities of a director within the organization that the director in subject had. Therefore, it was clearly specified by the tribunal that to what extend the director would be liable and what responsibilities he had within the organization, in spite of how or why those tasks came to be forced on the official. So, the appeal what the dismissed by the tribunal by stating that a person who was a CS with a lawful background would be predictable to raise issue relating to the probable misleading declarations which were there in revelation duties. Also, it was because of the close participation of the plaintiff in the actuary recommendation that the elevating of the restrictions of that recommendation was an accountability that fell within liability of the plaintiff while being in the position of a CS (Austin, Standen, and Reynolds, 2012). Implications The inference of the verdict which was granted in this case had no doubt been the subject of further discussion and investigation. As what was clearly observed in this case was that a CS who was also general advocate would not be able to simply divide his or her work among the capacity of being a general counsel and CS. It was done more or less, when that conduct was being questioned by the request of section 180(1) of the Act. CS with a lawful backdrop should also take into account that they have to not depend on opinion which was founded from third parties, and should make sure that the board was informed of the restrictions that instruction would have (Jacobson, 2012). Conclusion So, at the end it was concluded that the plaintiff had a far-reaching implications for those helping both as officer, within the meaning of section 9 of the CA and other functions. The verdict makes it clear that the two functions were not departed for the objective of the obligation of care and diligence necessities of the CA. The function of an officer enlarges not only to the legislative responsibilities but to the responsibilities which were essentially undertaken by the officer. So, in this case, the plaintiff could not segregate his responsibilities as the CS and as general counsel. Finally the matter reconfirmed that the standard of care in section 180(1) as integrating the actual responsibilities the officer disturbed had within the corporation not just the statutory responsibilities. And, this verdict served as another advice to those who serve on boards which were covered by the CA, that a high standard of care would be required. Similarly a prejudiced knowledge as well as dedicated responsibilities may enlarge this standard further (Boyce, 2012). References Austin, R., Standen, M., and Reynolds, C. (2012) The High Court decides the James Hardie case. [Online] Minter Ellison. Available from: https://www.minterellison.com/files/uploads/Documents/Publications/Alerts/NA_20120509_JamesHardieDecision.pdf [Accessed on 19/1/17] Australian Institute of Company Directors. (2017) Role of the company secretary.[Online] Australian Institute of Company Directors. Available from: https://aicd.companydirectors.com.au/~/media/cd2/resources/director-resources/director-tools/pdf/05446-6-7-duties-directors_role-company-secretary_a4_web.ashx [Accessed on 19/1/17] Boyce, L. (2012) Shafron v ASIC - general counsel, or counsel of perfection?. [Online] Dibbs Barker. Available from: https://www.dibbsbarker.com/publication/Shafron_v_ASIC_-_general_counsel__or_counsel_of_perfection.aspx [Accessed on 19/1/17] Comino, V. (2014) James Hardie And The Problems Of The Australian Civil Penalties Regime, University of New South Wales Law Journal, 37(1), 195- 207. DApice, B and Curran, C. (2012) Company officers Duty of Care obligations for those who have more than one job description. [Online] Charities Not-For-Profits Law. Available from: https://www.charitiesnfplaw.com.au/2012/07/02/duty-of-care-obligations-for-employees-who-have-more-than-one-job-description/ [Accessed on 19/1/17] Freeman, I. (2016) Shafron V Australian Securities And Investments Commission [2012] Hca 18. [Online] Lavan. Available from: https://www.lavan.com.au/advice/corporate_services/james_hardie_when_is_an_in_house_counsel_liable_as_an_officer_of_a_company [Accessed on 19/1/17] Hickey, M, and Lam, V. (2015) Jumping at shadows shadow and de facto directors. [Online] Sparke Helmore Lawyers. Available from: https://www.sparke.com.au/insights/jumping-at-shadows-shadow-and-de-facto-directors/ [Accessed on 19/1/17] High Court of Australia. (2012) Peter James Shafron V Australian Securities And Investments Commission [2012] HCA 18. [Online] High Court of Australia. Available from: https://www.hcourt.gov.au/assets/publications/judgment-summaries/2012/hcasum18_Shafron_v_ASIC.pdf [Accessed on 19/1/17] Jacobson, D. (2012) ASIC V Shafron: Liability Of Company Secretary (James Hardie). [Online] Bright Law. Available from: https://www.brightlaw.com.au/asic-v-shafron-liability-of-company-secretary-james-hardie/ [Accessed on 19/1/17] Konstantinidis, K. (2012) In-house counsel may be exposed to prosecution, disqualification, penalty or payment of legal costs. [Online] Colin Biggers Paisley Lawyers. Available from: https://www.cbp.com.au/publications/2012/august/in-house-counsel-may-be-exposed-to-prosecution,-di [Accessed on 19/1/17] Mire, S.L. (2014) Its not Fair!: The Duty of Fairness and the Corporate Regulator, Sydney Law Review 36(445), 446. Norton Roseful Bright. (2012) The James Hardie Decisions: Australian Securities Investments Commission v Hellicar Ors [2012] HCA17; Shafron v Australian Securities Investments Commission [2012] HCA 18 [Online] Norton Roseful Bright. Available from: https://www.nortonrosefulbright.com/knowledge/publications/66582/the-james-hardie-decisions-australian-securities-investments-commission-v-hellicar-ors-hca17-shaf [Accessed on 19/1/17] Sainty Law. (2012) Shafron v ASIC: take-aways for General Counsel. [Online] Sainty Law. Available from: https://www.saintylaw.com.au/wp-content/uploads/2012/08/Shafron-Vs-ASIC-takeaway-August-2012.pdf [Accessed on 19/1/17] Scott, P. D. (2012) Shafron v Australian Securities and Investments Commission (2012) 286 ALR 612 , University of Tasmania Law Review 31(2) 155. Tam, K. (2012) The sting for General Counsel in the James Hardie decisions - Shafron v ASIC and ASIC v Hellicar. [Online] Hunt Hunt Lawyers. Available from: https://www.hunthunt.com.au/SiteMedia/w3svc1265/Uploads/Documents/Shafron%20decisionMay2012.pdf [Accessed on 19/1/17] Wotton Kearney. (2012) High Court Rules James Hardie Directors Approved Misleading Asx Release. [Online] Wotton Kearney. Available from: https://www.wottonkearney.com.au/downloads/case%20note%20-%20james%20hardie%20directors%20approved%20for%20misleading%20asx%20release.pdf [Accessed on 19/1/17]

Wuthering Heights Essay Thesis Example For Students

Wuthering Heights Essay Thesis The Substantial Choices that Altered Many DestinationsBy: Rebecca SloanThe Earnshaws and the Lintons both made many substantial choices that arbitrated their egotistic and non-egotistic destinations. Throughout the course of Emily Brontes novel, Wuthering Heights, one may have noted Hareton and Catherines ability to overcome their differences, unlike their parents.Bronte shows the differences between her two main couples through their upbringing, characteristics, and their abilities. The elder Earnshaw and Lintons childhoods are different than the childhoods of their children. The Earnshaws upbringing was done at Wuthering Heights by their father. Wuthering Heights was a dark, stormy place, filled with anger and rejection.Mr. Earnshaw spoils Healthciff and is distraught if anyone shunned him, even if it were his own children. Hindley is the best example; Mr. Earnshaw shipped him away to college so that he could give all of his attention to Healthcliff and Catherine. Although Mr. Earnshaw died Hindley came back and forbid Healthcliff to study. Which automatically degraded Healthcliff to a mere servant on the heights. Through this quote told by Nelly, He drove him from their company to the servants, deprived him of the instructions of the curate, and insisted that he should labor outdoors instead.(38) Hindley pretty much gets total revenge on his father through punishing Healthcliff. Catherine spent five weeks with the Lintons at Thrushcross Grange, a happier home with loving parents and close family bonds.Its inhabitants, Edgar and Isabella, were brought up like royalty, so when Catherine arrived she was spoiled as well, Isabella emptied a plateful of cakes into her lap and.. They dried and combed her beautiful hair, and gave her a pair of enormous slippers, and wheeled her to the fire.(42) This clearly made Catherine more aware of her social status and who she wanted to be. It also opened her eyes to the truth about her true love Healthcliff. If she were to marry a rich man she could save him from her brother Hindley and learn to love Edgar. As she clearly told Nelly from her selfishness in Chapter nine Edgar must shake off his antipathy, and tolerate him I can aid Healthcliff to rise, and place him out of my brothers power This was normal for the time period, however, left Edgar whom truly loved Catherine with the no one to care for him. Edgar was a true man whose only bad trait was, loving Catherine. The children of these characters show stronger will power and the ability to overcome differences. Maybe it was the difference in their childhoods from their parents or that they had characteristics of all to bring them together and dismiss all hatred. Hindleys child Hareton was also brought up at the Heights. He, however, received love from Nelly in his early months. Although, he was very young this could have shifted his whole view of love. Nelly protected him from his fathers fits and loved him like he was her own. Hareton might not have remembered her but deep down knew he was loved. After Nelly left Wuthering Heights, Healthcliff raised Hareton. Due to Heathcliffs revenge on Haretons father Hindley, Hareton was brought up a worker on the farm and was not educated. We will write a custom essay on Wuthering Heights Thesis specifically for you for only $16.38 $13.9/page Order now Catherine and Edgars child, Cathy, was brought up in Edgars home, Thrushcross Grange, in a happy environment. She was loved and sheltered by both her father and Nelly. Because of Edgars faith he was able to move past his loss, Cathys mother Catherine, and focus on loving his daughter. She was however, kept at the Grange and lived a very sheltered life. Her father and Nelly did not tell her about her relatives down the road because of her purity and her well being. Due to her childhood she was enabled to possess many favorable qualities that led her to dominate her own future, unlike her mother. Cathy was able to choose to be happy. She was capable of knowing right and wrong and whom she loves. Cathy knew it was wrong to make fun of Hareton so like her mother, she decided to help educate him. Unlike her mother, she overcame all of her selfishness and realized her love would overcome the unfavorable acts of her uncle. Like Hareton she was robbed of her land and money and forced to roam Wuthering Heights paying off the debts of her forebear. .uc8db2f1599c78dedb176e1e34f7e4955 , .uc8db2f1599c78dedb176e1e34f7e4955 .postImageUrl , .uc8db2f1599c78dedb176e1e34f7e4955 .centered-text-area { min-height: 80px; position: relative; } .uc8db2f1599c78dedb176e1e34f7e4955 , .uc8db2f1599c78dedb176e1e34f7e4955:hover , .uc8db2f1599c78dedb176e1e34f7e4955:visited , .uc8db2f1599c78dedb176e1e34f7e4955:active { border:0!important; } .uc8db2f1599c78dedb176e1e34f7e4955 .clearfix:after { content: ""; display: table; clear: both; } .uc8db2f1599c78dedb176e1e34f7e4955 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .uc8db2f1599c78dedb176e1e34f7e4955:active , .uc8db2f1599c78dedb176e1e34f7e4955:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .uc8db2f1599c78dedb176e1e34f7e4955 .centered-text-area { width: 100%; position: relative ; } .uc8db2f1599c78dedb176e1e34f7e4955 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .uc8db2f1599c78dedb176e1e34f7e4955 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .uc8db2f1599c78dedb176e1e34f7e4955 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .uc8db2f1599c78dedb176e1e34f7e4955:hover .ctaButton { background-color: #34495E!important; } .uc8db2f1599c78dedb176e1e34f7e4955 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .uc8db2f1599c78dedb176e1e34f7e4955 .uc8db2f1599c78dedb176e1e34f7e4955-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .uc8db2f1599c78dedb176e1e34f7e4955:after { content: ""; display: block; clear: both; } READ: Arvin-and-Edgar team bolsters Long Wharf EssayWhen Cathy came to the Heights, Hareton decided, just like Healthciff, that he wanted to learn to show Cathy that he is more than just a laborer. This quote clearly identifies Haretons feelings towards Cathys advent into his life and his evading of Healthcliff. He had been content with daily labor and rough animalenjoyments, til Catherine crossed his path- Shame at her scorn, and hope of her approval were his first prompters to higherpursuits; and instead of guarding him from one, and winning him the other, his endavours to raise himself had produced just thecontrary result. (259) These two pair of lovers made many decisions that altered their futures in many ways. The parents left their children with the same choices to make because of their lack of judgment. Hareton and Cathy were able to overcome many differences between both themselves and their parents. To many peoples surprise their decisions resulted in an almost perfect conclusion, a conclusion and future of unending happiness.

Air Force ROTC Essays - Military Ranks, Free Essays, Term Papers

Air Force ROTC Essays - Military Ranks, Free Essays, Term Papers Air Force ROTC 130th Cadet Wing Cadet Guide Spring 2016 Cadet: Table of Contents Chapter 1: Introduction.... 3 Chapter 2: Contacts, Info Distribution 4 Chapter 3: Customs & Courtesies........... 5 Chapter 4: Physical Fitness Standards & Jodies......... 11 Chapter 5: Drill & Ceremonies.......................... 15 Chapter 6: Uniform Wear.............. 19 Chapter 7: Conclusion 25 Signature Page.26 Chapter 1 Introduction Welcome to the Air Force Reserve Officer Training Corps 130th Cadet Wing! If you are reading this handbook, you have decided to make the initial steps in learning to become a successful Airman and leader in the United States Air Force. The 130th Cadet Wing participates in a leadership laboratory, also known as LLab, which will help you be prepared for Active Duty, and the opportunities it brings. This handbook is the official 130th Cadet Wing, Cadet Guide, which is designed to give you a well-rounded knowledge of Air Force basics, uniform wear, customs & courtesies, and the like. This guide is not a replacement of the requirements mandated by the leadership lab syllabus or the instruction of a cadre member and/or a cadet officer, Air Force Instructions (AFIs), or AFROTC Instructions (AFROTCIs). Rather, it serves as a supplemental material and guide toward where to learn more about your expectations as a cadet in the ROTC program, here, at Cadet Wing 130. Study hard, be confident, never fail, and never leave an Airman behind! Make sure your flight mates and fellow GMC know about this book and learn of its contents. You will be expected to use what you learn in this book at Det 130 and in your Air Force future. If you have any questions about the material, contact your flight mates first, then your POC Flight Commander. Good luck! Chapter 2 Contact Information & References Detachment 130 Contact Information 2419 6th Street, Northwest, Douglass Hall B-29 Washington, DC 20059 Phone: 202-806-6788 Fax: 202-806-4506 Cadet Wing 130 Website: www.det130.org Air Force Website: www.airforce.com Air Force ROTC Website: www.afrotc.com Cadre Members: Lieutenant Colonel Joyner Detachment Commander Captain Richard Frantz Operations Flight Commander Technical Sergeant Anndee Troxler NCOIC, Personnel Staff Sergeant Pamela Torres NCOIC, Knowledge Operations Ms. Ralphine Pughsley Administrative Assistant Information Distribution: Each week the cadet leadership will publish a document called Operations Orders (Ops Orders). This document details what the cadet wing will be doing throughout the week. It lists times, location, and uniform of the day (UOD) for every Leadership Lab as well as physical training session. They are published two ways. First, they will be emailed out over the wing list-serv (to get added to this listserv, email the webmaster at [emailprotected]). The second way is they will be posted to the cadet wing website (see above). The same method of distribution will apply to any other important announcement. If you were to have a question about any ops orders or announcement made you would direct that question through your chain of command (see Chapter 3, Number X). References (source of information in Guide)*: AFI 36-2905: Fitness Program AFI 36-2903: Dress and Appearance of Air Force Personnel AFMAN 36-2203: Drill & Ceremonies Manual Holm Center T-203: AFROTC Field Training Manual Holm Center T-703: Holm Center Training Manual AFROTCI 36-2010: Cadet Training Programs AFROTCI 36-2011: Cadet Operations *These guides can be located online with any internet search engine Chapter 3 Customs, Courtesies and Detachment Etiquette I. Absence and Tardiness Military Tardiness Standard As a cadet, you are expected to be early (usually 15 minutes) for any military-related event. If you are going to be late let your flight commander or supervisor know ahead of time. Be professional; phone calls, e-mails, and text messages are appropriate however, remember to use your customs and courtesies at ALL TIMES! AFROTC Attendance Policy In AFROTC, 80% of your attendance is the minimum standard. As officers, we exceed the minimum. If you need to be excused for academic, work-related, family, or emergency reasons, you need to send an Absence Request Form (ARF) to your direct superior at least 48 hours prior to the scheduled event. In the case of failure to meet attendance minimums, disenrollment from the AFROTC program will be considered. II. Military Etiquette Conduct while in Uniform Never walk on the grass (unless for reveille or related ceremonies). Spitting, chewing tobacco or gum and smoking are not permitted in formation. Cadets should avoid these actions in uniform as they detract from professional appearance. When consuming food or beverage in uniform, do so in a professional manner.

No Country for English

No Country for English No Country for English No Country for English By Maeve Maddox In preparing to write a review of No Country for Old Men, I glanced at some online discussions of the film to see what other people were saying. The grammarian in me overcame the movie critic as I found myself paying more attention to the mode of expression than the thoughts being expressed. In Dustins Review of the film I found three items that distracted me from the content. 1. Of the character Sheriff Ed Tom Bell, the reviewer observes just as he has previously laid witness to similar atrocities over the decades One lays claim to something, but one simply witnesses an atrocity. 2. Again speaking of the sheriff, the reviewer says all he tragically finds in Gods place is an empty void Since the word void means empty or an empty place. it seems a case of belt and suspenders to talk about an empty void. 3. Of the killer, played by Javier Bardem, the reviewer says Whenever he comes in contact with someone, the viewer holds their breath, quite aware of the extent to which he is capable of. In addition to the agreement problem of the viewer holds their breath (which some readers may wish to defend), theres another problem: quite aware of the extent to which he is capable of. Three separate idioms have been crammed into one convoluted sentence. Lets break it down. This killer is a psychopath who kills human beings the way farmers slaughter beef. Very quickly the movie-goer knows that this person would as soon kill you as look at you. The viewer, therefore, is aware of what the killer is capable of. The viewer is aware of the extent of the killers depravity. The viewer is aware of the extremes to which the killer will go. A lot of work has gone into the site on which this review appears. It may contain some outstanding reviews. Its a shame that the first article Ive read contains such careless writing. I now hesitate to look at the others. Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Grammar category, check our popular posts, or choose a related post below:15 Terms for Those Who Tell the Future3 Cases of Complicated HyphenationPhrasal Verbs and Phrasal Nouns

How male and female Regard Interaction and Leadership Differences in Essay

How male and female Regard Interaction and Leadership Differences in the business communication - Essay Example This is particularly brought about by the perceived inferiority of women, a notion that is largely driven by historical gender inequalities. Despite the extant differences, its should also be noted that they do not form a basis for stereotyping whereby one gender is considered as having better or more advanced communication skills and thus better placed to be effective and competent leaders. On the contrary, in spite of the differences, experience has shown that men and women are still able to meet certain goals and emerge as business leaders with equally effective and good communication skills (Winter, Neal and Waner, 2001). This paper, therefore, explores the differences in how males and females regard interactions and leadership in business setting by looking at the physiological and psychological gender differences, task differences, expertise differences, differences in communication and leadership styles and draws on a conclusion on how they impact on their roles as leaders in at the work place. Gender Differences Men and women are two distinct genders with totally different physiological attributes as evident in the manner in which they act, communicate and methods they employ to influence others around them. These gender differences in communication and influence tactics have a significant role to play in defining their leadership styles at the workplace. Academic research has shown that men have a higher likelihood of being chosen as leaders than men while women generally take considered to take a backstage position and deal with everyday tasks. This is mainly because men and women view the purpose of communication from totally two different perspectives. While men use communication as a way of exerting dominance over others and achieving tangible results, women employ language as a medium of enhancing social connections and creating durable relationships with those around them (Wood, 1996). Another physiological difference between men and women is tha t while the female gender is generally considered to be more expressive, cautious and courteous in their verbal interactions with others, men on the other hand are more assertive, and power hungry (Basow and Rubenfield, 2003). It is these differences in the physiological and psychological nature of the two genders that make men to be likely chosen as leaders as they are more assertive and always desire to posses power, while women, showing tentativeness in their interactions, usually stay in the background and are mainly involved in the everyday tasks. John Gray (1992) identified different communication styles depicted by men and women, suggesting that men are more likely to be goal oriented and are mainly driven by the desire to achieve results. Women on the other hand vale fostering of relations and mainly define desired accomplishments by the type of relationships they build over time. More are more of introverts when it comes to dealing with problem situations as they prefer to keep to themselves while women prefer to talk out issues and involve the opinion of others. Task Differences One difference that stands out between men and w

Industrial Relation Essay Example | Topics and Well Written Essays - 250 words

Industrial Relation - Essay Example Restaurant businesses lack human resource management skills and resources and in turn employees lack union representation A penalty rate is an issue in the industrial relations facing by the restaurant industry (taken to also include cafà © operators and catering providers, but excluding large franchise operators). Penalty rates in particular have apparently caused restaurant owners cost difficulties. The employer pays the penalty for requiring workers to work at unsociable times such as late at night, weekends and public holidays. In the restaurant industry Saturday penalty rates are 1.25 times ordinary earnings, on Sundays the rate is 1.5 times, and on public holidays the rate is 2.5 times. Overtime, that is work beyond ordinary hours, also attracts penalty rates. The union view is that staff should not have to work at minimum wages during unsociable hours. The essential point of conflict for the restaurant industry is the need for some protection of the unskilled and vulnerable workforce contrasted with the need for restaurant owners to achieve an adequate level of business profit and return on equ ity in a very competitive and low margin business. This type of IR framework increases staff hiring pressure, because owners and managers face increased employment risks. The above trends indicate that penalty rates are likely to increase the risk of a restaurants failure. Small restaurant operators are very likely to use family members or ‘safe’ employees extensively to avoid industrial risks. The pluralist approach assumes that any employment relationship automatically has the potential for conflict and this is why effective conflict management so important, and this is the aim of Fair Work Australia. The role of the state is to protect the weak and to try and reconcile conflicting opinions and to keep conflict within

Religion and So-called German Christians Essay Example for Free

Religion and So-called German Christians Essay Religion continues to be one of the most influential forces in the world. It has been seen to provide great peace and harmony to believers, but it has also been the cause if not an actual reason for some of historys greatest wars. It can be used as justification from leaders of war, can it also serve as an instrument of resolution as well? Religion has come to be a much stronger force than any material incentives. It is far better at directing positive behaviour towards social betterment than any laws or physical force. For instance, Ghandi and Martin Luther King Jr conducted non-violent protests based upon religious beliefs. Religion can also be used to help bring people together as they are more willing to work together. By contrast, places that reject religion, such as Revolutionary France, communist Russia and China, or Nazi Germany are often very brutally oppressive. However, it is not always the case. For example, Iran: a country where religion is so prevalent is equally as oppressive as these countries. Incidentally, religion can be very dangerous because it can and has been used to justify horrific acts. Crusaders not only killed many Muslims, they also massacred many Jews and Eastern Christians in the process of attempting to win control of the Holy Land. Adolf Hitlers followers among them the so-called German Christians were believers in their Fuhrer. The Inquisition carried out its torture in the name of God. Religion should never be involved in politics because it can then be used as an instrument of control. However, in places where religion develops freely and people have free access to places of worship, it provides people with a sense of hope, praying serves as therapy and members of a congregation feel a sense of community and friendship. Some of the greatest works of art were created in the name of God. Furthermore, Woodrow Wilson suggested that a strong affinity exists between religious commitment and patriotism. Love of country, just like the love of God certainly inspires good deeds but not always. Furthermore, religion may have led to the creation of the worlds finest art, but it has also caused its destruction. Religion can be a source of extreme nationalism. In Christianity, Islam and Judaism, God is described as mighty warrior, just king and righteous judge. He apparently punished the unjust, the unrighteous and the disobedient. The idea that a nation is the instrument of Gods will has led to war and the subjugation of people viewed as ungodly. Fundamentalism clouds everything. There is a need to be right and superior, which develops an ego and once we fall foul to it, we are lost. Conversely, biblical commandments are the basis of Western ethical and legal systems. It has seen to teach us tolerance for people with other beliefs and opinions. Usually believers are more peaceful, law-abiding and tolerant than the non-believers in the world. Some people need it psychologically and without it may step to extremism such as suicide or anarchy. However, some live in a delusion and in a constant state of intellectual dishonesty. Some people, who are so far devout in their own beliefs, use them to beat other beliefs and religious groups into submission. Religions like Islam justify holy wars against the unfaithful, meaning those of other religions. This can also be seen in the violence of the crusades launched by Christians in the medieval period and by later wars between Protestant and Catholic. Religious conviction like the extremist Hindu groups against Christians and Muslims in India has paved the way for the terrorist attacks in New York City on September eleventh 2001. Religious clashes have led to some of the most heinous human behaviour in recorded history. Western states grew as a result of religion and religious philosophy. Western European and North American societies are still based on Protestant ideals of diligence, thrift and moderation. The very existence of theocratic state, proves that governments in these states are much more stable than regimes in secular countries because leaders are viewed as appointed by God. Political stability, in turn, leads to economic welfare. Despite this, Theocratic states become totalitarian regimes because they are based upon obedience to a ruler who is seen as Gods representative rather than a democratic constitution. They may be stable but they are not essentially concerned with their peoples welfare. By prioritising religious imperatives over economic development and by their intolerance of the questionable types who drive economic process states like Iran have become corrupt, authoritarian and poor. In conclusion, I believe that religion provides many opportunities and hope for those who have nothing else to turn to, it helps bring unity and sometimes peace into communities. However, I also believe that it has become a perversion of the redemptive message of Jesus, by so-called devout humans using their beliefs to ruin and destroy the lives of many others. I myself am agnostic and am very open-minded.