Meta Vaux Warrick Fuller Visual Artist of the Harlem Renaissance

Meta Vaux Warrick Fuller was born Meta Vaux Warrick on June 9, 1877, in Philadelphia. Her parents, Emma Jones Warrick and William H. Warrick, were entrepreneurs who owned a hair salon and barbershop. Her father was an artist with an interest in sculpture and painting, and from an early age, Fuller was interested in visual art. She attended J. Liberty Tadd’s art school. In 1893, Fuller’s work was chosen to be in the World’s Columbian Exposition. As a result, she received a scholarship to the Pennsylvania Museum School of Industrial Art. Here, Fuller’s passion for creating sculptures developed. Fuller graduated in 1898, receiving a diploma and teacher’s certificate. Studying Art in Paris The following year, Fuller traveled to Paris to study with Raphaà «l Collin. While studying with Collin, Fuller was mentored by painter Henry Ossawa Tanner. She also continued to develop her craft as a sculptor at Academie Colarossi while sketching at Ecole des Beaux-Arts. She was  influenced by the conceptual realism of Auguste Rodin, who declared, â€Å"My child, you are a sculptor; you have the sense of form in your fingers.† In addition to her relationship with Tanner and other artists, Fuller developed a relationship with W.E.B. Du Bois, who inspired Fuller to incorporate African-American themes in her artwork.   When Fuller left Paris in 1903, she had much of her work displayed in galleries throughout the city including a private one-woman exhibit and two of her sculptures, The Wretched and The Impenitent Thief were on display at the Paris Salon.   An African-American Artist in the U.S. When Fuller returned to the U.S. in 1903, her work was not readily embraced by members of the Philadelphia art community. Critics said her work was â€Å"domestic† while others discriminated solely on her race. Fuller continued to work and was the first African-American woman artist to receive a commission from the U.S. government. In 1906, Fuller created a series of dioramas depicting African-American life and culture in the U.S. at the Jamestown Tercentennial Exposition. The dioramas included historical events like the first African slaves being delivered to Virginia in 1619 and Frederick Douglas delivering a commencement address at Howard University. Two years later, Fuller exhibited her work at the Pennsylvania Academy of Fine Arts. In 1910, a fire destroyed many of her paintings and sculptures. For the next ten years, Fuller would work from her home studio, raise a family, and focus on developing sculptures with mostly religious themes. But in 1914 Fuller deviated from religious themes to create Ethiopia Awakening. The statue is considered in many circles as one of the symbols of the Harlem Renaissance. In 1920, Fuller exhibited her work again at the Pennsylvania Academy of Fine Arts, and in 1922, her work appeared at the Boston Public Library. Personal Life and Death Fuller married Dr. Solomon Carter Fuller in 1907. Once married, the couple moved to Framingham, Massachusetts, and had three sons. Fuller died on March 3, 1968, at Cardinal Cushing Hospital in Framingham.

The Persian Gulf War Essay - 907 Words

The Persian Gulf War The war in the Persian Gulf was a war of religious favor, cruel leadership, and greed. Desert Storm or more commonly known ass The Golf War was the same type of war that had accrued in this area for many years except for one fact. In Operation Desert Storm, it was a mix of sophisticated technology and the combined leadership and cooperation from the coalition that was used to end the war in a quick and timely manner. Which in the end probably saved thousands of lives. nbsp;nbsp;nbsp;nbsp;nbsp;In 1979 Saddam Hussien took control of Iraq, and immediately made his presence known when he killed 21 of his cabinet members. He wanted to make his country whole once again. So in 1990 he invaded Kuwait and in less than†¦show more content†¦The names of a few of the major countries were Australia, Canada, Czechoslovakia, and Italy. The war was financed by countries that were unable to send in troops. More than 53 billion was pledged. Saudi Arabia and southern Kuwait were the largest donors. Switzerland also contributed to the allies, after being neutral during both World War I and World War II. nbsp;nbsp;nbsp;nbsp;nbsp;The largest tank battle in the war conclusively showed the superiority of the coalitions tanks new technology that allowed them to attach at an impossible distance where they were basically immune from Iraq fire. Another benefit to the new technology was the new types of metal they were making the tanks out of. It was strong and most importantly light which was necessary for maneuverability reasons. As a whole, the battles showed that the coalition clearly out classed the tactics of the Iraqs emphasized pitched engagements and linear movements as they had been taught by there soviet leaders. In the entire Gulf War Iraq lost around 4,000 tanks and the coalition lost only 4. This quote states the truth about the situation in Desert Storm. quot;Iraq went from the fourth largest army in the world to the second biggest army in Iraq in 100 hours.quot; Said Lieutenant General Tom Kelly. On the final night of the war, within hours of the cease fire, two United States Air Force bombersShow MoreRelatedThe Issue Of The Persian Gulf War3306 Words   |  14 PagesIntroduction: The Persian Gulf War is one of the most recognized wars in our history of war. The Persian Gulf War included Iraq and Kuwait, and would later involve the United States. For a war to occur there must be a just cause. The United States government needed a just cause to go to war with Iraq in the Persian Gulf War. For the purposes of this paper a question that must be answered is; did the United States have a just cause to go to war with Iraq? 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Iraq accused Kuwait of pumping oil and not sharing the benfits, and Kuwait was pumping more oil than allowed under quotas set by the Organization of Petroleum Exporting Countries, it decreased the price of oil, Iraqs main export. Iraqs complaints against Kuwait gr ew more and more harsh, but they were mostly about money. When Iraqi forces began to assemble near the Kuwaiti border in the summer of 1990, several Arab statesRead More The Persian Gulf War Essay example3203 Words   |  13 PagesIntroduction Wars have been apart of this world almost as long as anything else has. Even in the Bible days there are records of wars. There are many reasons that states choose to go to war. Sometimes it is for the expansion of a nation or state, other times it is for financial gains, and it also could be for security or defense purposes. Whatever the case may be, wars have been apart of human life and will always be. There were no differences when it came to the Persian Gulf War. This war involved theRead MoreA Brief Look at the Persian Gulf War1479 Words   |  6 PagesPersian Gulf War, also called Gulf War, (1990–91), international conflict that was triggered by Iraq’s invasion of Kuwait on August 2, 1990. Iraq’s leader, Saddam Hussein, ordered the invasion and occupation of Kuwait with the apparent aim of acquiring that nation’s large oil reserves, canceling a large debt Iraq owed Kuwait, and expanding Iraqi power in the region1. The Iraqi leader Saddam Hussein cl aimed as a reason for the invasion a territorial dispute over the Shatt al-Arab, the waterway whichRead MoreEssay about The Persian Gulf War3279 Words   |  14 PagesIntroduction Wars have been apart of this world almost as long as anything else has. Even in the Bible days there are records of wars. There are many reasons that states choose to go to war. Sometimes it is for the expansion of a nation or state, other times it is for financial gains, and it also could be for security or defense purposes. 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Persian Gulf War veterans would say, â€Å"American soldiers lost their lives’ for oil.† The first Persian Gulf War startedRead More Causes and Effects of the Persian Gulf War Essay717 Words   |  3 PagesCauses and Effects of the Persian Gulf War The Persian Gulf War, often referred to as Operation Desert Storm, was perhaps one of the most successful war campaigns in the history of warfare. Saddam Hussein, leader of Iraq, invaded Kuwait in 1990. In 1991, after weeks of air strikes, US ground forces entered Iraq and Kuwait and eliminated Iraqi presence in 60 hours. Why Would Iraq invade Kuwait? Kuwait supplies much of the world’s oil supplies, and when Hussein invaded Kuwait, he controlled

A Raisin in the Sun free essay sample

â€Å"A Raisin in the Sun† by Lorraine Hansberry is a play centered around an African-American family on the Southside of Chicago set after World War II. This groundbreaking play was the first of its kind revolving around the race relations of the middle of the twentieth century. This play has won over many hearts and minds with its intense drama and relevant storyline. This play’s title is off the poem â€Å"Dream Deferred† by Langston Hughes, where Mr. Hughes contemplates on what happens to a dream deferred â€Å"What happens to a dream deferred? Does it dry up like a raisin in the sun? This play’s main theme is dreams of each of the characters. Each character has their own version of how they want the future to be. Also each dream is centered on how the role of money is going to get them there. This essay will establish commentary on how the dreams of each of the characters is related to the title of the play and also the role of money affecting each of the characters. â€Å"A Raisin in the Sun† is about a family on the verge of receiving a $10,000 payment from the insurance company after the passing of the former head of the household Walter Sr. The family consists of Walter Lee, his wife Ruth and son Travis, Mama, Beneatha (Walter’s sister). They all live together in a cramped apartment with Travis sleeping on the couch. Each of them have a plan for the money but not everything happens on point as they would like to. Mama wants to buy a new home to complete a dream she had with with her husband. Walter Lee believes that they should buy a liquor store and that would put them out of poverty. Ruth also shares a dream with Mama but she really just wants a better place for Travis to grow up in. Beneatha really just wants for Mama to spend the money on whatever her heart desires, but knows that Mama’s desire is to help pay for Beneathas medical school. With everybody having their own version of a dream, soon they start clashing over their competing dreams. Then after Mama goes out, she puts a down payment on a home in a good neighborhood. She then gives Walter some money to look after and to help pay for Beneathas school. He instead gives the money to his buddy and he runs off with the money. To add insult to injury, the head of the neighborhood welcoming committee comes bearing an offer. He tells them that they would be willing to buy them out on the home because they are unwanted. Walter quickly devises a plan to accept the offer from the man but has a change of heart when Mama forces him to do it in front of his son. He gives an eloquent speech and refuses the offer. Then in the ending of the play, they all move. The play opens with Walter Lee waking up and arguing with his wife. Walter is trying to convince his wife Ruth to envision his dream. Which is to enter a joint partnership with his friends to open a liquor store. Walter works as a chauffeur for a wealthy white man and is tired of seeing the extravagant lifestyles of the rich. Walter is agitated by the fact of their poverty and wants to get out of the predicament he’s living in. Ruth is especially mad at the fact that Walter is having friends over late and calls his friends â€Å"loudmouths†. Walter rebuts and tells her of how his other friend was considered a loudmouth and now is grossing over a hundred thousand dollars a year in the dry cleaning business that Walter failed to enter in. Later on, we see Walter making a verbal contract with his friends for the $10,000. Once Ruth tells Mama about Walter’s dream to get out of being poor by opening a liquor store, Mama quickly refuses to agree with him. His mother tells Ruth that they were not meant to do business or even selling liquor. After Mama refuses to side with Walter, he throws a tantrum and walks out. Eventually he finds out that his mother decided to pursue her dream to buy a house. She hands Walter $6,500 and to look after only $3,500 because the other $3,000 would be for someone else. Walter decides to take all of it and invest it into the liquor store. He believes that it would propel his family into another way of life and he would become the hero of the household. But then slowly like a raisin drying up in the sun, his dream is slowly sucked out of him. He finds that one of his friends hustled the other two and ran off with their money. He lost all of the money which he was responsible for. He quickly devises a plan after a visit from the neighborhood association to take the money for the new home and run. Walter really believes that money is the only thing that would make everyone happy. Mama: Son how come you talk so much bout money? Because its life, Mama! Hansberry 1317). He eventually has a change of heart and â€Å"instead of accepting the money, Walter declares his pride in the six generations of his family that have lived in America† (Frank ardilino 181). Soon his dream is suddenly shifted into keeping Mama happy and providing a roof over his families head. Mama is a humble character. She is the care giving mother of the entire household. She doesn’t really express her dreams to anybody and doesn’t pressure anyone to follow her. She realizes that she is entitled to the money that came from the death of her husband and rightfully does what she pleases. Mama early in the play hates the idea of opening a liquor store. She cant really fathom the fact that she is receiving $10,000. Ruth suggests that she take a trip to Europe or South America. Mama replies by saying shes going to put some money away for Beneathas medical school and find a two story home so Travis can have a nice place to play in the summer time. What really bothers Mama is that she is having a hard time making decisions and adjusting to living without Big Walter. She talks of how he was a great father figure and how when she had a miscarriage he basically worked himself to death. Yes, a fine man—just couldnt never catch up with his dreams, thats all†(Hansberry 1304). she decides to take it upon herself to fulfill their dreams. Her dream was differed and put aside for the family. â€Å"Mama’s Christian response to a lifetime of oppression could be read as â€Å"a syrupy sweet,† as the sugaring over of present realities with the crust of faith and prayer. Hansberry’s characters carry the existential load voiced in Hughes’s poem; yet, while these responses on their own are self-destructive† (568 Matthews). While she doesn’t care much for money as her son does, her idea of everything is freedom. Freedom to do whatever one wants. Eventually in the end she collects her fragile little plant just like her family and takes it to the new house to flourish. While Walter and Mama both have reasonable dreams to do whatever with the money. Beneatha is so far the most interesting character in the whole play. She is the younger sister of Walter and is living with the family. Beneathas dreams is not so much so dependent on the money but more of a cultural dream. She is a student at a local college/university studying to be a doctor. She has riffs with her older brother just like how typical siblings always fight. But what makes the fighting different is how Walter doesn’t see too much value in her future as a doctor. Beneatha is constantly at odds with her being in an American family that doesn’t know their heritage. She is dating two men, one is George Murchison and Joseph Asagai. George is the well off suitor of Beneatha. He has a rich family and he is pretty much blind to the race relations of the day. He is constantly acting better than everyone around him. Joseph Asagai on the other hand is a humble Nigerian in America. Beneatha is constantly trying to have George reject her and he repeatedly berates her. Look honey, were going to the theater—were not going to be in it so go change, huh? †(1320 Hansberry). Beneatha really wants to be with Joseph and embraces his culture. For example, when Joseph come bearing gifts, she soon starts to embrace the Nigerian culture. She hates â€Å"assimilationist Negroes† but is partly one. To her money isn’t everything and all she wants is to find her identity. Unfortunately â€Å"The corpses of Beneatha’s various moves to express her self are littered about the Younger family’s collective consciousness, and they â€Å"stink. Beneatha herself often causes a stink if her means of expressing herself is not applauded by all†(Matthews 568). She cant catch a break just as when Walter says that the NAACP even takes a break sometimes. Her dreams aren’t necessarily â€Å"A Raisin in the Sun† but instead stinks like rotten meat. Her views are outrageous and unrealistic. She doesn’t end up finding her self and she must continue on to find herself. Out of all the characters, Ruth most resembles the title. Ruth is the wife of Walter Lee and has a son named Travis. She works as a laborer in other peoples homes. The play describes her as about thirty. We can see she was a pretty girl, even exceptionally so, but now it is apparent that life has been little that she expected, and disappointment has already begun to hang in her face† (1293 Hansberry). Throughout the play she talks about how life isnt always what it seems. It seems as if she has given up. She is tired settled woman. When she is asked about her dream by her husband, she brushes it off. When Mama asks, she sides with Mama buying a new home. One thing that Ruth is confronted with is the pregnancy. She goes out later and puts a five dollar deposit down for an abortion. When accidentally revealing that information, Beneatha quickly starts badgering her about whether it was planned and suddenly Ruth starts feeling sick. She is now confronted with the thought of the baby living with them in an apartment and if they had a home they would be fine. Ruth has lived in the poverty for a long time and her having a child would be either her struggling more or not. Ruth has not been analyzed much even though she has some part in almost all the scenes. What many don’t realize is that she is essentially the one whose dream matters the most. She has taken the care giving responsibility from Mama, she cooks and cleans the house with barely any help from Beneatha, and she still supports her husband and son. While everyone is off expressing their dreams from Big Walter death , she is the only one who doesn’t parade around or fight about the money. She never gets her way only until Mama makes Walter realize that the familys well being comes before his own. Over all Ruths dream does come true without her worrying about the money even though her life previously dried up like a raisin in the sun. A Raisin in the Sun† is a play ahead of its time. It is the epitome of a play that doesn’t step too many boundaries but acknowledges that its there. Hansberry’s art of characterization propels the story. She does not present a black–white conflict per se, but it is always there lingering in the background without sentimentality or propaganda†(Saber 457). There are plenty of topics that push buttons such as abortion and segregation, but those problems dont interfere with all of the characters dreams. They collectively all have a dream for advancement but clash with regards to the money. All of the characters resemble the poem from which the title comes from. Walter is festering like a sore over not advancing in business, Beneathas wanting her family to not assimilate and embrace Africa is stinking like rotten meat. Ruth has dried up with years of taking care of her family and working. Mama is the syrupy sweet that tries to put the good back into her family. We are left with the worry of how they will adjust to a new neighborhood and that thought sags like a heavy load but we wont know if it will explode. A Raisin in the Sun free essay sample A review of Lorraine Hansberrys play A Raisin in the Sun. This paper examines the play A Raisin in the Sun, by African- American playwright Lorraine Hansberry. The paper describes the playwrights life and provides a synopsis of the plays events. The paper states that the moral of this play is as long as people try to do their best for their families, they can lift each other up. Lorraine Hansberrys A Raisin in the Sun was the first play written by a black woman to be produced on Broadway in 1959. Moreover, Hansberry was the youngest and the first black writer to receive the New York Drama Critics Award. She was deeply committed to equality and human rights, and her play approaches important issues and concerns regarding the African-American racial identity and discrimination, and poverty.

Leadership Styles Essay Example

Leadership Styles Essay In studying the various leadership styles, I found that many, if not all of the styles we covered have some degree of relevance to most peoples leadership practices. A few however, seem to stand out from the rest. I will review these various styles individually. The leadership styles and approaches that will be focused upon are: the Trait Approach (Northouse 15), Skills Approach (Northouse 39), Style Approach (Northouse 69) and the Situational Approach (Northouse 89). I will discuss the five questions every leader should ask of themselves when engaging a team to achieve a goal. Lastly, I will look at emotional intelligence leadership skills, also referred to as EQ, (Northouse 23) . Trait Approach The Trait Approach to leadership implies that in order to be an effective leader, there are certain types of characteristics that you would have to be born with. These trait characteristics have been identified by several researchers. In my opinion, the list is so vast, one would be hard pressed to not find at least a few that they could associate with themselves. The ability to stand out among the masses appears to be a qualifier as well. There seem to be some consistent traits present in the leadership evaluations I conducted. They are: intelligence, self-confidence, determination, integrity and sociability (Northouse 19). While there is much controversy in regard to whether or not one must innately possess these traits, there seems to be an overall agreement that the presence of them make the difference when being considered to be or not to be an effective leader. Skills Approach We will write a custom essay sample on Leadership Styles specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Leadership Styles specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Leadership Styles specifically for you FOR ONLY $16.38 $13.9/page Hire Writer The Skills Approach to leadership shares the concept of being based upon characteristics however, it concludes that although ulitmately there are specific characteristics necessary to be a successful leader, there is opportunity to learn and develop these skills. The skills approach concept summizes that there needs to be the presence of three basic administrative skills-technical, human and conceptual. Technical skill relate specifically to knowledge and aptitude to to apply necessary techniques as well as operate specific equipment and software programs. Human skill is the ability to work cohesively with people. Having this skill and being effective at incorporating it into your leadership style is a critical factor to the success of any goal oriented group effort. If you cannot motivate people to complete the tasks at hand, failure would be imminent. The third administrative skill is the ability to be conceptual in your thinking. You must be able to see the big picture in order to be strategic. If one is unable to envision and embrace the overall concept, the company/organization will not succeed in meeting goals. Style Approach The Style Approach focuses primarily on behavior. Behavior in this regard is broken down into two areas. Task oriented and relationship oriented. An efficient leader finds a balance between the two. Having the ability to toggle between these two areas is only half the battle. A leader must also know when it is appropriate to apply one as opposed to the other. There may be circumstances while working toward one goal both practices need to be applied. A good leader should be able to determine when and how that should happen. This style is one that I can clearly relate to. I work in an industry in which a big part of our success lies in our ability to manage relationships. In order to do that, you must be able to determine the type of person you are partnering with and based upon that determination, you must adapt your approach and communication technique. Style questionnaire, Situational Approach The Situational Approach to leadership is one that I am quite familiar with however, it is one that I don’t necessarily think I embrace to the degree that I should. I find myself thinking that if a person has been hired to perform certain duties, there should be a core competency level present that enables them to complete the tasks they are assigned. I have always been opposed to micro-managing and the Situational Style of leadership felt similar to that practice. This leadership style calls for me to take who I am leading and what their abilities are and what degree of dircection I determine they would require to complete the tasks at hand without becoming frustrated by either lack of direction or lack of empowerment. If I had to equate it, I would say that it is similar to driving a stick shift. I need to know when to put my foot on the gas and when to push the clutch to get into gear. Five Leadership Questions As a leader, there are 5 questions one must ask oneself when engaging a team to achieve a goal. First, determine and take into consideration what is already working. There is an old saying if it isn’t broke, don’t fix it. If there are tried and true practices and tactics that have led to achieving goals, and the goal itself has not changed, there is no need to re-create the wheel. Secondly, clarity is necessary in regard what variables drove the success. If you cannot pinpoint what varibles moved the dial, you cant give effective direction to a team in terms of the best path to take. Third, knowing the objective is necessary to answer the first two questions accurately. If the objective is fuzzy, there is no way to determine the best way to reach point of arrival. Fourth is defining the benfits of reaching goal for stakeholders. These include self-gratification, organizational profitability, bonuses, budget approval and respect of colleagues to name a few. The fiifh question that is necessary tto ask is what more can be done, what can be done better and what should be done differently to acheieve the highest level of success. Once this question is posed, empower and encourage the team to share their ideas. Brainstorming sessions are an invaluable forum for developing new concepts and approaches. It is the perfect setting for determining new approaches by providing a wide array of perspectives. Emotional Intelligence Theory Emotional Intelligence –EQ or Emotional Quotient is a behavioral model that manifests 5 key competencies. They consist of being in touch with and aware of your emotions, self-regulation by manging those emotions appropriately, being able to self-motivate, having empathy by being sensitive to the emotions of others and effectively managing relationships. In addition to having a basic awareness of these competencies, it is necessary for to know how to incoporate them into a leadership style. Professional integrity is very important and a good leader will always be mindful of controlling their emotions. An effective leader learns to step back for a moment and realize that they cannot change other peoples behaviors but they can change the way they react to them. I still hold fast to my professional opinion regarding what the I believe the best practices should be, however, learning and understanding how what drives people to do what they do, say what they say and lead like they lead is influenced by how they are â€Å"hard-wired†, has helped me to appreciate the perspective of others as well. Learning about the diversity of leadership styles has helped me appreciate the perspective of others even though they differ from mine.

Role of Parsi community in Ice Candy Man Essay Example

Role of Parsi community in Ice Candy Man Essay Question: Demonstrate how the changing peceptions of the characters towards each other is a reflection of the instability surrounding them.Answer: Actions, behaviour, gesture, sickness: these are all indications of an unconscious and involuntary mode of existence common to all which, if nothing else, shows that one is alive. The novel, Ice-Candy Man is an emotional book about dispassion and fairness by a Parsi perspective. The novelist, Bapsi Sidhwa adopts a psychoanalytic approach towards her writing inorder to reveal the revulsion of partition of the sub-continent. Sidhwa states, I dont have much faith in human nature. This statement justifies the instablity and chaos that the mindsets of the characters undergo during the partition, especiallythe Ice-Candy Man.The partition of the sub-continent is like the background music of the novel which channelizes the preference and emotions of people from all sects of the society. Ice-Candy Man is a complex character and the way he represent s humanity is something that the ordinary man carries and at the same time he is ignorant of it. He is an embodiment of binary oppositions: good and evil, love and hatred, peace and violence, friendly and reserved, pleasant and unpleasant, sensibility and insanity. However, he is not an amalgam of these attributes at the same time. Infact, he is a victim of the changing circumstances and from positvity he eventually starts to exhibit negative traits.The recurring phrase, the pitiless face of love aptly suits his character. However, his character development contains the element of cause and effect. As Aristotle says, All causes are beginnings. Therefore, the train from Gurdaspur loaded with heaps of dead bodies and womens breasts becomes the cause that paves way to unleash the evil within him. In a rage, he confesses to the Government House Gardener that the sight of the train containing dead Muslims has changed him and he is not reluctant in killing even his acquiantances. It is su bstantiated when he deceives his love Ayaah by abducting her and forcing her into prostitution. He is candid about his hatred and fanaticism for other communities. Thereby, we observe that the external event, i.e. the partiton internalizes and changes his perception which in turn externalizes in the form of violence and suspicion. As a result, he becomes averse to all who do not belong to his community. The conflict between the rational and the illogical is meticulously defined in his mental agony.Partition signifies the disintegration of individual selfhood and the development of a mass-consciousness or will, which disrupted individual self-development. The Aayah who is the nucleus of the circle of various religions portrays the hybridity and complexity of the society. However, the competitors of her love are initially jealous of each other on sexual basis but with the atrocities being committed by numerous sects in the backdrop; suddenly make them aware of their respective religio us identities and practices. Soon, one mans religion becomes another mans poison. Lenny says, The change was sudden.Hence, religion transformed into politics and became a matter of psychological egoism. Jokes were formed inorder to ridicule other religions. Imam Din and Yousaf started to take Friday afternoons off to offer Juma prayers. Similarly, Aayah visited temples and offered joss sticks and flowers to gods. A Brahmin pandit disowns his food when he feels that it has been corrupted by the shadow of an alien religious identity. In the tense communal situation, people felt an urge to keep and sharpen their weapons. Moreover, Aayahs perception towards the Pathan also goes through a vivid change as she acts calmly in his presence. The term, Sikh is used for Sher Singh because Sikhism is his religion and he would represent all Sikhs.Within a broad climate of inherited culture, there are endless variations: each individual differs from the other in outlook and day-to-day religious ph ilosophy. Thus, one incident creates havoc among humanity and things eventually fall apart. It is through the character of Ice-Candy Man that the author effectively communicates the frenzy and madness that jolted the people during the time of partition. On the other hand, we also tend to learn that one must synchronize as he evolves. Otherwise, the negative percetions towards others can transform one into a beast. Indeed, the novel is a trustworthy guide to the heart and mind of human-beings.

6 Reasons You Must Stop Wasting Time on Facebook and Invest It on LinkedIn

6 Reasons You Must Stop Wasting Time on Facebook and Invest It on LinkedIn Last week, an article entitled Facebook Lurking Can Make You Feel Miserable, According to Study made a very credible claim that people who spend an hour on Facebook per day (the national average) have more of a tendency toward depression than those who spend 5 minutes per day or less on the site. Some people, many of them teens, may spend many hours on the site, addictively checking their â€Å"Likes† and their friends’ feeds. The study found that Facebook lurking (reading without interacting) leads to depression because we have a tendency to compare ourselves to others. Whether we think they are doing better or worse than we are, these comparisons still lead to depression. (How can they not when we are constantly checking on our friends’ updates?) And here’s the rub: We convince ourselves that we will feel better after using Facebook, whereas the opposite is true. Rather than be uplifted by a sense of connection, most people experience a sense of having wasted time. The study showed that decreasing Facebook use, and staying away from browsing sections that invoke envy, can cause positive changes for people who were experiencing depression. Facebook users were more at risk of depression if they displayed the following: Felt envy after observing others Accepted former partners as Facebook friends Made negative social comparisons Made frequent negative status updates If you’re a LinkedIn user, why subject yourself to this risk when there’s another option? Here’s why I think you would do better to spend your time on LinkedIn: LinkedIn is unlikely to be a waste of time. If you are on LinkedIn, you are almost certainly building your networks or learning something valuable about your industry. You are unlikely to be watching cat videos, looking at gorgeous photographs of places you will never visit, or getting sucked into political conversations. And you only need to spend 20 minutes a day! It’s safer to accept invitations from former partners on LinkedIn. You will not be subjected to updates on their love lives or news about how well they are doing socially without you. While you might experience a twinge upon an announcement of an old partner’s new job, I believe it pales in comparison with what you might feel looking at their Facebook feed. If you’re feeling jealous of other people’s jobs, at least you can do something about it. LinkedIn is designed so that if someone you know gets a job you want, you can reach out to them and talk about how they did it. Maybe you’ll get tips on how to reach that goal yourself! LinkedIn encourages this type of interaction rather than encouraging you to stew in a jealous mire. You’ll learn about relevant topics on LinkedIn rather than have to wade through streams of irrelevant postings. By joining groups on LinkedIn, you can ensure that you receive posts that relate to your fields of interest. You can also manage the information that comes through your LinkedIn news feed (although come aspects of this feature are under construction). As per LinkedIn, you can customize your feed  on desktop and the mobile app by hiding updates from your connections, unfollowing connections and companies, and discovering new content. You’re unlikely to become â€Å"addicted† to LinkedIn. You’ll be able to accomplish what you set out to accomplish on the site, get it done, and move on with your life. Time on LinkedIn is time invested in yourself and your career. It is an exercise in creating opportunities. Every post you publish, well-considered connection you make, and conversation you engage in on LinkedIn creates visibility for you in your professional network. Whatever your career or business goals, this is good news. And Facebook can hardly claim that. One note of caution: Even LinkedIn is not a good place to be late at night. Nighttime use of social media has been linked to sleep problems in many studies. So take care of your LinkedIn activity during daytime or early evening hours! What do you think? Are you ready to trade in your addictive Facebook behavior for some more constructive social media time? I’d love to hear your thoughts (and plans) below. Save Save Save Save

Human Resource Management Essay Example | Topics and Well Written Essays - 1750 words - 2

Human Resource Management - Essay Example Also, a conclusion will be provided in the last section of the paper. 2. The Report Free Malaysia Today’s news report last March 4, 2013 by one of its staff James Pereira has delineated that Malaysian businesses are devoted to stipulate customers with a great service. However, Pereira inscribes that these employees are notably in minority clusters. He insists that for a firm to be recognized internationally, it must be inculcated with employees who are haunted with customer satisfaction. There is indeed a right approach to having an exceptional divergent type of employees, and for this panorama to be feasible, a scientific facet must be on hand. As such, a business to be dubbed as a predominant venture and become a successful world-class firm, it must be infused with a top-flight reputation, which can only be achieved through employees. The top-flight reputation runs the profitable aspects of a firm and the formula to attain this is: â€Å"Right Employee x Right Training x Ri ght Performance x Right Reward = Right Profits† (Pereira, 2013). Notably, having been depicted as a formula of accumulating right profits, the latter is deemed as a paragon that becoming successful is infused with a scientific aspect. 3. Performance Management Right profits are quantified by four aspects, which include right performance (Pereira, 2013); therefore, performance should be managed well leading it to become right. Performance management can be perceived in a broad or narrow context. In the broader context, the administration will be viewed in the conduct of assessing the organizational performance--the measurement and evaluation of the administration of a firm (Pantouvakis, 2011, p.13) --while in the narrow context, the assessment will be held in the performance of every employee. The first step to managing the performance is through role profiling--where employees can be coming from external staffing and internal passages, and thereby synergy must also be instille d (Storey, 2007, pp.274-276). Integrating these employees to work together and establishing the right culture of the organization can help sustain an effective synergy. The concept of integration is very significant because only in integration will rise the dominant aspect of synergy (Moulesong, 2013). Employees will perceive parity of value and unity of direction. They will somehow fathom that every entity in the organization has his or her certain role, and it matches a huge fraction or part of the measures that can assist in achieving the organizational goals effectively. In the light of synergy, employees can become more effective as they integrate them as they work individually (Tanriverdi, 2006, p. 59). The next salient thing the firm must do is to decide the measures, which should be perceived as a succinct set of information that measures the future standards or targets of the firm. Furthermore, setting the standards does not just depict expecting of what has to be done, but implementing what must be done. Diversification is a dominant aspect here since achieving one target cannot be attained with a one-sized-fits-all aspect of business. Otherwise stated, employee diversification can also assist effectiveness and efficiency of operations because one of the competitive advantages of a firm is to have a diversified personnel (Ravichandran, et al., 2009, p.233). Reviewing the performance

Germany and the Gurmans Essay Example | Topics and Well Written Essays - 750 words

Germany and the Gurmans - Essay Example The thought of that period painted in me a negative perception towards Germany and the German people in general. However, my current perception is that of respect and understanding of how Germany has contributed significantly to some of the technological advancements we enjoy in the world today. The historical significance of Germany in shaping the politics of the world is also without doubt. A key theme in this perspective is that Germany has always been a primary player in the world politics and as a result a major contributor to the global affairs. Although I had known that Germany had significant influence in the course of things during the 1st and the 2nd world war, I had not known that the influence dated back centuries ago to great leaders such as Frederick the Great. Germany has also produced one of the best scientists that have contributed significantly to the field of medicine. For instance, scientists like Paul Elhrich and Robert Koch who contributed significantly to the scientific fields of medicine, microbiology and immunology. These are men who dedicated their lives for the noble course of humanity with the aim of improving better understanding of diseases. One wonders the condition of the world had there not existed such scientists. Germany is a country that strived to ensure that it was at the forefront of scientific inventions and therefore consolidating its position as one of the leading countries in the world. Such scientists had the whole world in perspective when conducting their experiments in order to find solutions not to the problems of Germany alone but to the problems of the whole world. In the field of psychology and sociology, Germany also produced one of the key contributors in these fields. The contributions of German sociologists and psychologists improved the understanding of mental diseases and human behaviors in the society, thereby setting the pace for contemporary sociologists and

The (Feasibility)pratical of Using Unmanned Aerial Vehicles in Essay

The (Feasibility)pratical of Using Unmanned Aerial Vehicles in Delivery of Parcels - Essay Example the feasibility of the use of UAVs will help companies such DHL, UPS and FedEx as that specialize in service delivery reduce the cost of operation and consumer charges eventually bringing in efficiency and effectiveness. Moreover, the present tech-savvy society will be able to straightforwardly manage their parcel delivery time thus giving them more intuition. This report uses the qualitative technique where various literatures including journals, research articles, books and papers shall be referenced. Secondary sources will help in determining the drone’s pragmatism, acquiescence, and security. Due to time constraint and data inadequacy, this study shall not delve into the relationship between UAVs and technology or how technology impacts on parcel delivery. However, it hopes to efficaciously answer the questions within the stipulated scope, and recommend what parcel delivery companies should

Theories for Philanthropy: History and Background

Theories for Philanthropy: History and Background It is easy to motivate people to attend fundraising events just ask them to turn up and they will, because its the right thing to do. Discuss Introduction Philanthropy is the act of donating money, goods, services, time or effort to support something that is socially beneficial, has a defined objective, and no material reward to the donor. Whilst the majority of people see this as individual charity, the other side to giving without material reward is fundraising and corporate philanthropy. There is a view amongst some organisers of fundraising events that little extra motivation is needed for people to attend they will simply attend because it is the right thing to do. Of course, there are also those who see philanthropy as only occurring where there is some gain outside of money for the donor, especially when it comes to corporate philanthropy. Instead of being about the ‘right’ thing to do, it is more about the perception of doing the ‘right’ thing as a marketing and PR weapon. [1] This essay will examine the roots of philanthropy and look at some of the motivational factors involved. This will involve loo king at marketing techniques, psychological and philosophical theories as to why people give. The aim of this discussion is to provide recommendations to fundraising event managers to help them better promote their events in light of the motivations discovered. The first section will look at the history and background of philanthropy. History and background of philanthropy The earliest forms of philanthropy can be traced back to religion and the ideas of giving and charity within Judaism, Christianity and Islam. The idea of charity in these texts looks at helping the poor and those in need no matter what their faith or situation. This idea of charity set the beginnings for the secular concept of philanthropy. Where charity and philanthropy differ somewhat is that charity has a commitment to the poor and helpless, whereas philanthropy is not so closely linked to the poor.[2] However, religious faith is still a strong motivator behind philanthropy even today because it instils the belief that giving is the ‘right’ thing to do and an important part of faith. In this sense, it could be said that people need no more motivation than their faith to give to fundraising events. However, faith cannot explain all aspects of philanthropy for those who are not religious or where faith is not an important element.[3] Philanthropy developed into a concept in the seventeenth century to do with being kind and humanitarian, which in the 18th and 19th centuries was then to do with being actively involved in humanitarian projects, such as helping the insane or prisoners, and the abolition of slavery. However, it was towards the end of the nineteenth century that philanthropy began to mean the donation of money to causes that would benefit all levels of society and not just the poor. The emphasis of philanthropy has shifted from just helping the poor to helping all areas of society. The government is now seen as the primary carer for those under or around the poverty line, whilst philanthropists look to benefit society as a whole. This of course does not mean that the poor do not or cannot benefit from philanthropy, but that the goal of philanthropy is now wider than helping just those who are poor.[4] The modern version of philanthropy is very much to do with injection of money into causes and raising funds to help develop socially worthwhile projects. Philanthropy is not just about pouring money into something and forgetting about it, but about giving money so that results can be achieved. In fact, if results are not achieved through the donations then generally the donations to that particular project will be reduced. This is a method that wealthy individuals and organizations use to keep projects accountable and to have a measure of social control.[5] This social control may often be in the interests of the philanthropist and so it begs the question as to whether this is the only motivation behind modern philanthropy. If this is the case, then perhaps the idea that motivation to do the right thing is enough is no longer a valid way to promote or achieve fundraising. The next section will look at some competing theories of motivation with regards to philanthropy to see if this q uestion can be answered. Philosophy and models of motivation One idea of motivation behind corporate philanthropy is obviously that it improves the image of an individual or business whilst also providing an opportunity to shape society in a certain way. In modern philanthropy there is no doubt that this is a part of motivation, but in many ways it acts no differently to idea of ‘doing right’. An individual who gives because they believe it is the right thing to do will give in the same way as an individual or organisation who gives because they perceive that others think it is the right thing for them to do. Corporate philanthropy is a part of business culture today, and companies see it as an important marketing tool – to be seen as an ethical, responsible and socially aware company that looks to give back to the community and to society.[6] Also, there is the other side of fundraising that as a company funds are needed to be generated to be given by philanthropists, and so a good company that can benefit society will have a fundraising strategy. Mullin believes that the key to good fundraising is less to do with motivational factors and more to do with detailed strategic planning and advertising of the event is the key to its success.[7] For Mullin, fundraising works very much like any product with a life cycle of fundraising that determines where and when the best opportunities for gaining funding are within each project or event. Wendroff also believes that the key to successful fundraising is attention to detail and planning, and that there is no real need to look into motivational factors as much as there is to employ proper marketing and organization of the event. If this is taken care of then people will donate because of the feeling that this is a worthwhile cause portrayed by the quality of the event.[8] However, there are a number of other theories with regards to the motivation behind fundraising that can help fundraisers. Sargeant and Jay believe that the motivation for philanthropy comes from push and pull factors. People give not just for one reason but for a wide variety of reasons depending on the social climate, empathy and sympathy for a cause, potential for results from the donation and other factors. These push and pull factors are complex and it is believed that more research into why people give and also why they stop giving is important. If this is not undertaken then organisations are in danger of spending too long developing ‘techniques’ to gain funding rather than really knowing why people want to give and how to then present their project.[9] Other theorists see motivation behind giving as being somewhat different. The philosopher Immanuel Kant sees giving as a simply matter of duty, and that the act of philanthropy is an example of duty to our society. Kant doesn’t believe that humanitarian acts or charity are the motivations behind philanthropy, but rather the shaping of duty, society and law are the motivations behind donation. Whilst Kant’s view may appear somewhat cold and does not take into account the human or sympathy aspect of donation, there is evidence that modern philanthropy does on some level work like this. People give money because they feel it is their responsibility to help society with what they have, and this fits in more with a sense of Kantian duty than being charitable.[10] Despite this, Kant’s view is perhaps too narrow and does not take into account the fact that part of giving is certainly to do with personal feelings towards a specific project. Even if someone feels it might be ‘right’ or their duty to donate, they are less likely to do so if there is no personal fit with the project and understanding of its social worth. Perhaps the view of John Stuart Mill is a better explanation of motivation in this case. Mill’s idea is that people donate because they see it as the rational way of making society most efficient. Giving their wealth to help socially beneficial organizations means that they are helping to maximise utility within society. Whilst this theory also seems extremely well thought-out and neat in that it would be great to think that philanthropists and donors need only learn about a project’s benefit to society to give, it again seems that there is more to motivation than this. It also seems unlikely that all donors clearly see this ‘bigger picture’ and that their wealth being offered to others in this way really is helping the overall efficiency and utility of society. If this were the case then philanthropists would all give to very similar and large-scale projects that could benefit as many people as possible – clearly this isn’t the case.[11] Motivational factors and current climate The problem with all of these theories is that they seemingly take a narrow view on motivation to try and pin down why people donate so that fundraisers can develop techniques to increase funding. However, the situation should probably not be looked at in terms of strict individual motivational factors but rather in terms of the current climate of donation and philanthropy on a local, national and global scale. For instance, whilst values in the UK and US on many topics are quite similar, levels of philanthropic donation are much lower in the UK (less than 1% of GDP) than in the US (2% of GDP).[12] Understanding why different national markets vary in level of donation can help fundraisers to understand why people are donating in a particular area or during a particular time period. The US and the UK differ in their giving policies, with US philanthropy very much to do with ‘charity begins at home’, and that self-interest, social appreciation and public statement of giving are important motivational factors. However, in the UK the act of philanthropy is much more to do with the notion of ‘charity for all’ and the sense of duty that doing something socially worthwhile is important. This is done in a more private way and is not so much linked to personal interest or social acceptance. Despite the US and the UK being quite similar they have very different motivations for giving, and this shows how important it is to know the area and culture that the fundraising is being carried out in. This is perhaps more important than knowing individual motivational factors, because these are likely to change depending on the current climate and market conditions. Certainly, since September 11th and the bombings in London the attitude towards giving has changed as people look again to help others and make more of their influence and wealth than before. However, things are changing again as a worldwide economic slump means people are being more cautious, yet demand for funding is increasing as more is needed from individuals to help support the government.[13] In the current climate it looks like corporate donors will move away from corporate giving for PR, and move towards investing in communities to give them a strategic advantage in the future. With companies having less money and all individuals having to reduce their spending, it seems that currently the emphasis for fundraisers should be on showing worth and value to the companies and individuals who want to invest. Companies should also look towards diversifying their fundraising so that they can survive even if philanthropic donations are in decline.[14] Conclusion Although some people will always give money because they believe it is the right thing to do, philanthropy is no longer synonymous with charity. This means that fundraisers have to do more to get the funds they need than simply appeal to a sense of ‘right’. In an effort to find new techniques to generate funds, fundraisers have looked at the individual motivations behind philanthropy. Whilst the theories presented here all have their merits, individual motivations are too complex, unpredictable and diverse to base fundraising tactics upon. Instead, fundraisers should aim to base their tactics on the current economic climate as well as the fundraising climate within their locality or national culture. This is more likely to give general patterns that can be used to strategically improve fundraising. In the current climate, this means diversifying tactics and even looking to earn a certain amount of funds to offset the effects of the economic slump. Fundraisers should also emphasise the benefits to philanthropists with regards to social and corporate results, as anything that will give donors a strategic or social advantage in the future can be a factor in donation. In conclusion, it is no longer enough for fundraisers to rely on people’s sense of charity and humanity to generate funds. Instead, companies should focus on the worth and social benefit of their projects to attract investors in their particular region. Whilst individual motivational factors are complex and need more investigation, local and national trends can be used to develop fundraising strategies. Bibliography Bennett, R., 1997. Corporate philanthropy in the UK: altruistic giving or marketing communications weapon?. Journal of Marketing Communications, 3(2), pp. 87-109. Boney, R., 2008. Corporate donors adjust to economic slump. Philanthropy Journal, September 15th, 2008. Available at: http://www.philanthropyjournal.org/resources/special-reports/corporate-giving/corporate-donors-adjust-economic-slump Boswell, H., 2003. Motivations for Giving and Serving. (Online). Available at: http://www.learningtogive.org/papers/paper33.html (Accessed 15th November 2008). Bremner, R.H., 1996. Giving: Charity and Philanthropy in History. New Brunswick and London: Transaction Publishers. Johnson, G., and Scholes, K., 2002. Exploring Corporate Strategy 6th Edition. Prentice Hall. Matthewson, D.J., 2001. An analysis of John Stuart Mill’s Justification for Redistribution. Prepared for delivery at the 2001 Annual Meeting of the Western Political Science Association, Alexis Park Hotel, Las Vegas Nevada, March 15-17. Available at: http://faculty.fullerton.edu/dmatthewson/Final%20Mill.doc Mullin, R., 1997. Fundraising Strategy. Directory of Social Change. Sargeant, A., and Jay, E., 2004. Fundraising Management: Analysis, Planning and Practice. London: Routledge. Slim, H., 2001. Not Philanthropy But Rights Rights-Based Humanitarianism and the Proper Politicisation of Humanitarian Philosophy in War. Centre for Development and Emergency Practice, Oxford Brookes University. Available at: http://www.odi.org.uk/hpg/confpapers/slim_new.pdf Wendroff, A.L., 2004. Special Events: Proven Strategies for Nonprofit Fundraising. John Wiley and Sons. Wright, K., 2001. Generosity vs. Altruism: Philanthropy and Charity in the United States and United Kingdom. Voluntas: International Journal of Voluntary and Nonprofit Organizations, 12(4), pp. 399-416. Footnotes [1] Bennett, 1997, pp. 87-91 [2] Bremner, 1996, p. xii [3] Boswell, 2003. [4] Bremner, 1996, pp. xii-xiii [5] Boswell, 2003. [6] Johnson and Scholes, 2002, pp. 35-37 [7] Mullin, 1997, pp. 2-8 [8] Wendroff, 2004, pp. 195-198 [9] Sargeant and Jay, 2004, pp. 111-113. [10] Slim, 2001, pp. 2-5 [11] Matthewson, 2001. [12] Wright, 2001, pp. 399-400 [13] Boswell, 2003 [14] Boney, 2008

Hosue On Mango Street :: essays research papers

3 Sandra Cisnero’s The House on Mango Street is an well-incorporated story told through vignettes shorts sections that piece by piece fit into a puzzle and reveal a theme. This unique story is about a disadvantaged young Chicana girl, named Esperanza, growing up in a poor neighborhood where she feels she does not belong. She does not like what she experiences, and constantly searches for a new future. As Esperanza grows and changes throughout the book, she realizes that women in her culture are treated unfairly, and makes a conscious choice not to fall into the same trap as the women around her. 4 Women all around Esperanza, such as Minerva and Sally, are held hostage, within their own acceptance of an unjust cultural fate. For example, Minerva is a young girl who constantly prays for better luck, and a happier life, but enables her husband to take advantage of her, and therefore sets the path for her unsatisfactory life. â€Å" One day she is through and lets him know enough is enough. Out the door he goes. Clothes, records, shoes. Out the window and the door locked. However, that night he comes back and sends a big rock through the window. Then he is sorry and she opens the door again. Minerva finds herself forgiving without truly seeing that her husband is sorry. She used marriage as a way out from her undesirable life, yet her married life still carries the same characteristics. And so, without fighting for a satisfactory life she settles with the hand she is dealt. 5 Furthermore, Sally, an innocent friend of Esperanza, tries to escape her father’s cruel beatings through marriage, but her circumstances do not change, her husband still treats her as her father has in the past. â€Å" He won’t let her talk on the phone. In addition, he does not let her look out the window. In addition, he does not like her friends so nobody can visit her unless he is working. Sally’s father controlled her and now it is her husband; she thinks that she is escaping when in reality she is just giving the leash to someone else. Sally chose the easiest way out of her life, marriage, she did not see the unfavorable life of the women near her, she just chose a route to flee, without thinking of her future. 6 All in all the women around Esperanza have all taken an easy escape from their surroundings leading them into another life of the same disappointment; and now accept their unhappy consequences, thinking that there is no way-out.

Patterns of Behaviour Essay

To form a reaction the particles must collide in high speed. The faster the particles collide the more kinetic energy is produced. This produces a bigger reaction. There are five key variables that affect the rate of a reaction (in this case with a solid and a solution): Change in temperature An increase in heat energy within the particles leads to more kinetic energy. Therefore there is more collision of particles and it increases the rate of the reaction. When we decrease the amount of heat energy, this will evidently slow down the reaction. For example we slow down the process of our food rotting by placing it in a fridge or a freezer. Change in concentration The concentrations of acids are classed in molars, so 2m would quite a strong concentrated acid, 0. 5m would be a very dilute weak acid and 1m would be in between the two. Also, the more concentrated the acid, the more particles it contains, so there is more of a chance for collisions.   Change of particle size Increasing the surface area of the particles would lead to more collision. We do this by making the particles smaller. For instance peeling a large potato would not take as long as peeling four small potatoes; this is because the smaller potatoes have a larger surface area for you to peel. Pressure (for gases only) Increasing the pressure would bring particles closer together so there would be more of a chance for collision.   Catalyst A catalyst lowers the activation of energy required, consequently there being a faster reaction. The three variables we are choosing to show which effect the rate of reaction in our experiments are: Particle size Concentration   Temperature Pressure was inappropriate to use as a variable, because we were not using two gases and a catalyst was unsuitable to use for small tests like these. I think that the tests in changing the temperature will have the fastest times, as the hotter a solution is the more the particles will move and collide, thus the rate of carbon dioxide being produce will be faster. I also think that the large particles test will take the slowest amount of time because of the lack of surface area and the reverse will occur with the test with powered calcium carbonate. Plan We will be running a various number of experiments to prove what effects the rate of reaction with calcium carbonate (marble chips) and hydrochloric acid. The balanced equation for these reactants along with the products: Calcium carbonate + hydrochloric acid calcium chloride + carbon dioxide + water Ca Co + 2 HCl Ca Cl + Co + H O When experimenting with the effects of the particle size we will use three sizes: large marble chips, small marble chips and powered calcium carbonate. For the tests in concentration of acid we will use 2m, 1m and 0. 5m. We will use 50cc of hydrochloric acid in each test to guarantee precise results. Finally for the experiments with the changes of temperature we will be heating the acid using a bunsen burner for two temperatures: 30i and 40i , then leaving the acid at room temperature (around 22i ). We will measure the temperature accurately using a thermometer. These will be the only three things that we are going to vary, to explain what affects the rate of reaction. We will also only be testing one variable at a time. For example, in the test for concentration we will obviously be varying the concentration of the acid (0. 5, 1 and 2m) but we will be keeping the temperature and the particle size the same (room temp. and small marble chips). To tell us what actually affects the rate of reaction we will monitoring how fast carbon dioxide is given off. To find this out we will have a plastic basin containing water. A test tube measuring 10cc filled with water will be held upside down in the basin of water and a delivery tube will be attached to the beaker holding the acid and calcium carbonate and the other end will be positioned in the test tube in the water. We will use all the same apparatus to ensure everything is fairly tested and is accurate to the equipment we are using. As the acid reacts with the calcium carbonate, carbon dioxide is released. This will travel through the delivery tube and into the test tube. The test tube will fill up with carbon dioxides and the water will pushed out. We will be timing this with a stop clock. As the water descends to 1cc we will record the time, then at 2cc, again at 3cc and so forth. At the end of each experiment we should have 10 times recorded. For each factor, instead of just performing the experiment once, we will repeat it three times to provide us with a more accurate end result. In total we will be doing 27 tests to show what effects the rate of reaction. Diagram To make certain that this method is good enough and to certify that it worked properly we will carried out a trail experiment. We used all the average variables for fair testing. So the temperature was at room (22i ) the concentration not to strong or weak (1m) and the small marble chips. Trial experiment results 1 molar room temperature small marble chips Min/sec 1cc 1:41 2cc 3:15 3cc 4:46 4cc 6:13 5cc 7:35 6cc 9:03 7cc 10:34 8cc 11:56 9cc 13:27 10cc 14:33 The carbon dioxide was released very slowly in this test. It took over fourteen and a half minutes for it to finish and this would not be practical because of the limited time been given to conduct all our experiments. It took so long, because we had only put one small marble chip in. There were no more calcium carbonate particles to react with the acid particles, so this had a dramatic effect on the time. On In each test we do we will always place more particles than the amount we need, so there is excess calcium carbonate at the end to make sure it does not run out during the test. Because this was the first time we were trying the tests out we were a bit slow placing the bung on and maybe some of the carbon dioxide had escaped. To improve our main experiments to achieve accurate results we had to place the bung on as soon as we dropped in the calcium carbonate to make sure no carbon dioxide escaped. Results Concentration 0. 5 molar room temperature small marble chips 1st 2nd 3rd Average Temperature Room temperature 1molar small marble chips 1st 2nd 3rd AverageAnalysis On the concentration graph the average of the 0. 5m results was looked very different compared to the 1m and 2m averages. Because it took the longest time to reach 10cc of carbon dioxide, the gradient of the line of best fit sloped very gently. The release of carbon dioxide started off very slow at the being. It took 1:30 minutes to reach 1cc, then the rate quickened and in 2 minutes 5cc of carbon dioxide had been given off. On the graph the gradient in those two minutes steepened. The rate slowed down after that and the release of carbon dioxide was gradual and steady.

American Conspiracies essays

American Conspiracies essays There is no doubt that the American government has been withholding evidence of conspiracy activities from the populace, but the question remaining would be how deep do these secrets run? As a citizen of the United States of America, one deserves the right to know the truths about certain events. Two of the greatest events shrouded in conspiracy would be the JFK assassination and the Pearl Harbor bombing. The assassination of John F. Kennedy happened more that 30 years ago, but there is no other event that has received such voluminous writing, research and speculation in the first three decades after it happened. Obviously the most contemplated theory is the lone gunman theory. Autopsies reveal that there was more that one shot, but the government states that they came from single striking range (Griffith 1). If that were so, then James Tague would not have been struck in the cheek by a flying projectile. When the shots were fired, James Tague was standing near the triple underpass in the Dealy Plaza (Griffith 2). He was standing about 450 from the TSDB when suddenly a bullet struck the curb on Main Street about 20 feet from where he was standing(Griffith 2). A local officer noticed blood seeping from Tagues cheek. It was most likely caused by flying concrete after being struck by a bullet. Tague described the mark on the curb, as it appeared when he saw it: There was a mark. Quite obviously, it was a bullet, and it was very fresh(Weisberg, Case Open, 141; Warren Commission Report 116). The lone gunman theory allows for one miss, yet if the supposed shot from the sixth floor window hit the curb near Tague, then it was a wild miss(Griffith 1). The theory that J. Edgar Hoover proposed was that the lead fragment from the fatal headshot struck the curb and hit Tague in the cheek. That is where the lone ...

Health Care Needs Of At-risk Populations In Rural Georgia Coursework

Health Care Needs Of At-risk Populations In Rural Georgia Coursework Health Care Needs Of At VULNERABLE AND AT RISK POPULATIONS Vulnerable and at Risk Populations Vulnerable and at risk populations refers to groups of peoplewhose health care is not properly integrated into the health system due to their ethnic, geographic, health, cultural and economic characteristics. In Georgia, black people are one of the most vulnerable group and who are at risk. Black people in Georgia form thirty per cent of the total population in Georgia. Black people in Georgia are at a higher risk of having chronic ailments. This means that their particular health needs are based on the fact that they are prone to having chronic ailments (Chesnay, 2005) . Chronic ailments cannot be cured. However, they can be controlled and patients can be put out of risk. This means that patients have to visit health centres in order to be treated. Some of the chronic ailments include asthma, diabetes, blood pressure and heart disease. Black people do not receive the best health care in Georgia since they are disc riminated against due to their ethnicity. This has made it hard for sick patients to get medical assistance. Cubans are also vulnerable and at a risk. Seventy percent of Cubans living n Georgia where majority are women with a 40 percent have a higher chance of living with Aids.It is also important to understand children also have a chance of HIV.They are part of the minorities living in Georgia. They mainly suffer from cardiovascular disease. They find it hard to gain health care due to their ethnicity. American Indians are also a minority in the State of Georgia. They are vulnerable and at a risk for Chronic ailments. Minorities in the state of Georgia do not have access to better and quality health care owing to the discrimination they face (Chesnay, 2005). This has been made difficult by the fact that the ratio of minority doctors to native doctors is 1:16. This puts their lives at a danger.ReferencesChesnay, M. (2005). Caring for the Vulnerable. New York: Lea and Blanchard

Managerial Position of Manager Bank of America Essay

Managerial Position of Manager Bank of America - Essay Example A trustworthy manager can direct to more productive outcomes and is able to increase the achievements of any organization. Good management can improve the reputation of the bank and job satisfaction of employees. Thus, it can provide good customer satisfaction and increase the customer base. Managerial Functions Bank manager is in charge for the overall improvement and performance of the bank and the employees. The function of bank manager is to ensure superior service quality, business improvement and accomplishment of target (Peke, n.d.). The most important function of a bank manager in Bank of America is to develop the business of the bank. Bank manager always strives to increase the income through increasing the customer base. Bank manager is liable for setting the goals and planning a way to fulfill them. It is the function of bank manager to regularly examine the progression of other competitor banks and assess their business activities. A bank manager must ensure to maintain t he professional standard and the policy of the bank (Stanley St Labs, n.d.). Kinds of Managers Control Freak: This type of managers prefer to control all operations of the bank on his own. They do not prefer employees to make any kind of managerial decision whether it is a small decision or big. This kind of manager never tells the details about any assignment to complete it. Autocratic: Manager of this kind does not care about the workers. This type of manager is quite tuff and they are pretty clear about their need. Team Builder: This kind of managers is proficient at their work. They are quite open near subordinates and they seek for creativity from the workers. These kinds of managers do any task in particular way and by involving the employees. Managerial Roles In banking there are several roles for managers which are: Operation manager: These types of managers are open to the customers and have good communication skill. They deal with the customer directly about any kind of pr oblem. Retail manager: These types of managers handles the retail operations such as bank cashier, ATM operations, manage the deposit and withdrawal, money order, utility bill and others. Investment manager: The role of investment manager is to manage the account of customer, freight brokerage, analyze the investment, and manage the investment fund and operational investments. Financial manager: The role of financial manager is to manage the bill, account, and other financial services. Loan manager: Loan manager assess the loan requests, verify the customers’ capability to repay the loan amount and provide approval of loan. These types of managers are specialized in business, consumer and credit lending (Profitableinvestment, 2011). Managerial Skills Technical: A manager must be able to use specific methods or techniques to perform the managerial task. The technical skill is not associated with usage of equipment, machinery or technology. It is related with the usage of vario us managerial techniques in decision making such as break even analysis, planning any training program, conduct an interview and others. Interpersonal: A manager must possess skill to lead the employees. The interpersonal skills of manager consist of motivating the employees, resolving any disagreement and communicating with customers and other people. Conceptual: Conceptual skills are extremely important for middle level or top level managers. A manager should be capable of ‘grasping the whole picture’ of any bank. Communication: This is the basic skill of all bank managers. A manag

Understanding Challenges In The Third Sector Essay - 3

Understanding Challenges In The Third Sector - Essay Example Now besides donations, the organization charges for its services from people who can afford to pay, which enables them to look after poor and destitute people. Large businesses and corporations donate generously to such organizations in the form of cash and kind. They help with the purchase of equipment, construction and contribute whatever is needed for extraordinary circumstances. The public also trust charitable organization and appreciates the work that they are doing. The public also donates in their individual capacities according to what they can afford. Besides cash and kind, many people voluntarily give their time to these organizations, which spares the organization from spending money to hire people for performing these tasks. People also organize walks and other special events such as musical programs, shows or organize dinners for raising funds. All proceeds are all donated to charitable organizations such as St. Elizabeth to meet all its expenses. What I think is that to be successful, charitable organizations need a local as well as an international perspective. The local chapter addresses and looks after communal issues, while their global perspective, reputation and image is looked after by the international wing. In this technological age, the international image is as important as the local image and reputation of the organization. The global recession has left more people without jobs and needing help from charitable organizations. Cost of Medicare have more than tripled in the last decade, and even people who are earning well might not be able to afford medical expenses for their dependents, especially those requiring special care. With the economy in such a bad condition and people without jobs, it is not possible to raise adequate funds from local communities. Charitable organizations have to look outside their localities and sometimes even outside their countries for support for their charitable work. . I know for a fact

Visitor management (Heritage sites) Essay Example | Topics and Well Written Essays - 2000 words

Visitor management (Heritage sites) - Essay Example tions are majorly designed with strategic tools and approaches to improve visitors’ experience within a particular heritage tourism site (Shackley, 2009). The primary objective of this study is to develop a critical understanding about the different types of strategic processes of managing visitors in global cultural heritage sites. In this regard, the essay tends to identify the strategic directions as well as different managing and controlling tools or approaches used by the organisations or managing committees to offer exceptional visiting experience to each group or individual customers in the heritage sites. In relation to the modern competitive scenario in the tourism business industry, the process of managing visitors especially in the heritage sites ranges from cultural to urban destinations. According to the recent visitation and conservation strategies of the global destinations, there are numerous objectives to why the process of visitor management has been recognising as an increasingly important area to be undertaken by the groups responsible to manage visitors in the heritage sites. World Heritage Sites (WHS) conserve an Outstanding Universal Value (OUV) with adequate authenticity and integrity that grasp the attention of the visitors irrespective of their geographical locations. Therefore, the WHS can be widely accepted as a core and the most valuable drivers in the tourism industry to generate major financial contribution in the global economy. In this regard, the key purpose of the management departments in the WHS is to ensure that the nominated properties are effectively p rotected for bringing major economic and socio-cultural development on the present and the future generation (Leask & Fyall, 2006). In relation to the recent changes in the pace of globalisation, an effective management of the WHS includes a strong cyclic process with long-term and day-to-day activities with the aim of protecting and conserving wellness of the nominated

Competition in Energy Drinks, Sports Drinks, and Vitamin-Enhanced Beverages Essay Example for Free

Competition in Energy Drinks, Sports Drinks, and Vitamin-Enhanced Beverages Essay The strength of these companies had been growing strong but had a slight decline in recent years. SWOT for the Industry Strength: Product Expansion – many new products have been developed Distribution Channels – Can use convenience stores, grocery stores Able to deliver with carbonated soft drinks Weakness: Price is high compared to soft drinks Unhealthy ingredients Caffeine is not regulated – like in soft drink industry Opportunity: Consumer demand Supplier Channels – ingredients, cans, labels Product Innovation – provides differentiation. Brand Loyalty – taste, image, energy boosting Brand building skills needed 2 oz. energy shots Threat: Economy Scientific evidence that some products are not healthy Effect people with heart arrhythmias and insomnia Mix with alcohol Relaxed Drink Niche – abuse with prescription cough syrup As we look at this SWOT analysis of the alternative beverage industry we notice that there are some opportunities that they have created and are able to use in the future. Consumers’ choices are changing from the standard soft drink to alternative beverages. The key is to be sustainable by building up these products. The main opportunity to help with sustainability is to build brand loyalty. Try building up the knowledge and uses of your brands will help you gain the skills needed to continue building the brand. Porter’s five-forces model reveals that the overall alternative beverage industry attractiveness is high. Some beverage companies, such as PepsiCo and Coca-Cola, have mastered the art of brand building in the alternative beverage market and have been rewarded with rapid growth rates. The rising population of health conscious consumers is increasingly leaning towards alternative beverages that are believed to offer greater health benefits. The strongest competitive force, or most important to strategy formulation, is the threat of entry of new competitors. Competitive pressure from rival sellers is high in the alternative beverage industry. The number of brands competing in sports drinks, energy drinks, and vitamin-enhanced beverage segments of the alternative beverage industry continue to grow each year. Both large and small vendors are launching new products and fighting for minimal retail shelf space. More and more consumers are moving away from traditional soft drinks to healthier alternative drinks. Demand is expected to grow worldwide as consumer purchasing power increases. Another strong competitive force is buyer bargaining power. Convenience stores and grocery stores have substantial leverage in negotiating pricing and slotting fees with alternative beverage producers due to the large quantity of their purchase. Newer brands are very vulnerable to buyer power because of limited space on store shelves. Top brands like Red Bull are almost always guaranteed space. This competitive force does not affect Coca-Cola or PepsiCo as much due to the variety of beverages the stores want to offer to the customer. As a result of this certain appeal, the two companies’ alternative beverage brands can almost always be found shelf space in grocery/convenience stores. Distributors, like restaurants, have less ability to negotiate for deep pricing discounts because of quantity limitations.

Hablando de Inteligencia Exitosa (aprendizaje) :: essays research papers

Hablando de Inteligencia Exitosa by Dumar Là ³pez CONTORNO Tesis: La base del aprendizaje, se encuentra en la confrontacià ³n que se realice entre los conceptos propios y los ajenos, sustentados en fuentes verà ­dicas que proporcionen una informacià ³n exacta. Sin embargo, para el à ©xito se hace necesaria la correcta transicià ³n entre informacià ³n y conocimiento, que se logra dando significado propio a la primera. I. Trabajo en grupo #1: Ideas propias, no siempre la mejor opcià ³n 1) Descripcià ³n: a) Sin bases sà ³lidas. b) Auto didactismo. 2) à mbito cognoscitivo a) Aproximacià ³n al salà ³n de clase. II. Trabajo en grupo #2: Experiencia, distracciones y proposiciones 1) Descripcià ³n: a) Puntos de comportamiento. 2) à mbito cognoscitivo a) Los profesores como facilitadotes. b) Conformar conocimiento. III. Trabajo en grupo #3: El papel de las tecnologà ­as de la informacià ³n 1) Descripcià ³n: a) Útiles para la educacià ³n. b) En constante desarrollo. 2) à mbito cognoscitivo a) Mà ºltiples funciones del hipertexto y el chat. IV. Caracterà ­sticas del à ©xito: 1) Descripcià ³n: a) Confianza en sà ­ mismo. b) Parte de la inteligencia. 2) à mbito cognoscitivo a) Mentes creativas y prà ¡cticas. Hablando De Inteligencia Exitosa La base del aprendizaje se encuentra en la confrontacià ³n que se realice entre los conceptos propios y los ajenos, sustentados en fuentes verà ­dicas que proporcionen una informacià ³n exacta. Sin embargo, para el à ©xito se hace necesaria la correcta transicià ³n entre informacià ³n y conocimiento, que se logra dando significado propio a la primera. Primeramente, basado en experiencias propias afirmo que el trabajar solo y sin colaboracià ³n o pensamientos diferentes provoca el encasillamiento en ideas y conceptos en la mayorà ­a de las ocasiones errà ³neos. En este caso, no existe correccià ³n por alguien talvez mà ¡s experimentado o sapiente del tema a tratar. Personalmente, la aficià ³n por los computadores sà ­ funciona en estas ocasiones con las facilidades del hipertexto y el Chat permitiendo variados contrastes con ideas diferentes. Segundo, como afirman algunos autores tales como Klausmeier (1915), Vygotsky (1978), y Piaget (1950), el trabajar en un ambiente solitario aunque es efectivo para evitar distracciones, no es lo mejor para generar conocimiento. Por lo tanto, en determinadas situaciones estudiando solitariamente no se logra encadenar y dar un significado correcto a la informacià ³n. Finalmente, la palabra à ©xito siendo tan extensa no puede conformarse de una sola letra, sino del conjunto coherente de estas ademà ¡s de una tilde que genera su correcta pronunciacià ³n, a la tilde le proporcionamos el papel de la experiencia y a las demà ¡s letras, conceptos propios y ajenos. Asimismo, significa el porquà © de conformar la unidad (significado) a travà ©s del agrupamiento de algunas partes (conceptos). Para concluir, al compilar algunos conceptos junto a informacià ³n proporcionada por fuentes experimentadas con ideas propias se genera un texto coherente y no teà ³rico, demostrando lo que segà ºn Robert Sternberg (1997) serà ­a el producto de una â€Å"inteligencia prà ¡ctica y creativa† determinante del à ©xito.

Clinical Analysis: One Flew over the Cuckoos Nest

This is strongly exhibited in the film, through nurse Ratchet's cold, dominating manner of inning of the ward. In the film Chiefs character is written off as deaf & dumb by both the staff and other patients, he often appears catatonic. Broaden does not participate In the therapy circle and appears to be only treated regularly through drugs. He Is presented In the story as a patient with the longest tenure at the institution. The film also alludes to him having had large numbers of shock treatments during his stay.In the novel his character is described as having paranoid hallucinations of dense overwhelming fog generated by The Combine, a massive piece of machinery that intros people. The Chief isolates himself through his facade of being deaf and dumb. Eventually when Macarthur is able to get him to speak, the Chief reveals a story about his father being â€Å"worked on† by society. When he opens up, the Chief also lets on that he appears to see people as either big or small, he views people of confidence and strong spirit as large.The Chief describes himself as a small man, his perception of himself speaks of feelings of weakness or low self efficacy and depression. To properly diagnose Broaden today, a Callahan Is likely to conduct preliminary ABA work & tests to rule out other possible causes for the schizophrenia like symptoms. A clinician would test him for commonly abused drugs that cause schizophrenia like symptoms for example, & conduct a basic physical to rule out medical illnesses that may be causing these symptoms as well as review medical history.A clinician would take note of Broadens very apparent symptoms of Psychosis: marked by hallucinations & delusions (The Combine), disturbances in sensory perception (the fog strongly held personal beliefs (The Combine controls people, reception of people as either being small or big) as well as emotional expression (his blunted flat affect, even when speaking to Macarthur ( speech Is flat, monotone & lacking in signs of typical emotion).A clinician would also pickup on less obvious thinking behavior problems (in this case voluntary lack of speech). They would also need to determine whether Bromide's prolonged depressed mood is a symptom of schizophrenia or one of major depressive disorder or bipolar disorder. Psychosocial treatments would include: rehabilitation, individual psychotherapy, Emily education, self help & support groups and antispasmodic drugs. Social and vocational training would be administered early on after the antispasmodic medication has been administered.As it deals with the immediate issues of isolation and helps teach the individual how to readjust to life outside of the sheltered/ controlled environment of a hospital setting, rehabilitation would be an integral step in eventually returning to life in the outside world. In the film Broaden appears to benefit greatly from forced social interaction with Macarthur. Macrographs character takes on the role of th erapist with The Chief. He treats Broaden with respect and speaks to him instead of at him, which creates a bond of trust.Macarthur also takes the time to involve Broaden in social activities like conversations and group activities (basketball games). The scene where Broaden successfully dunks the ball in the game against the orderlies exhibits the great effect of these simple therapeutic exercises. At the end of this scene Broaden no longer moves at a slow & sluggish pace, appears to come out of his catatonic state and even wows a change in affect with appropriate smiling after scoring in the game.Receiving personal social attention, as well as being involved in the basketball game seems to do wonders for Broaden' isolation & self efficacy issues. Individual psychotherapy would involve regularly scheduled talks between the patient and therapist, to focus on current or past feelings, problems and experiences. Regular interaction with an empathetic person could guide the patient into a more grounded state and put them in touch with the outside world/reality. Problem solving ND coping skills could be learned from reality based therapeutic exercises.As patients are often released and into the care of family members, it is important that they are educated on schizophrenia, relapse prevention & troubleshooting. Learned coping problem solving skills could result in a more successful outcome of care and readjustment of their family member. Self help and support groups would be used to provide mutual support and continued safe & empathetic social outlet for the patient. Patient support groups allow the patient to develop a sense of community with other patients as well as a resource of growth and learning from the sense that they are not alone in their condition.In a way Macarthur follows the psychosocial treatment pattern with The Chief, who at the end of the movie describes the way he perceives himself as â€Å"big as a damn mountain† and has developed proble m solving skills, clearly resolved his self able to make the decision to and accomplish escaping the ward. This comes in stark contrast to the methods exhibited by Nurse Ratchet that focused on maintaining control of the patients, & order of the institution, with a disregard for support/care of the progress of the individual patient.

Case Laws for Commercial Laws

LGEAL PERSONALITY Foss v Harbottle (1843) 67 ER 189 is a leading English precedent in corporate law. In any action in which a wrong is alleged to have been done to a company, the proper claimant is the company itself. This is known as â€Å"the rule in Foss v Harbottle†, and the several important exceptions that have been developed are often described as â€Å"exceptions to the rule in Foss v Harbottle†. Amongst these is the ‘derivative action', which allows a minority shareholder to bring a claim on behalf of the company. This applies in situations of ‘wrongdoer control' and is, in reality, the only true exception to the rule. The rule in Foss v Harbottle is best seen as the starting point for minority shareholder remedies Judgement The court dismissed the claim and held that when a company is wronged by its directors it is only the company that has standing to sue. In effect the court established two rules. Firstly, the â€Å"proper plaintiff rule† is that a wrong done to the company may be vindicated by the company alone. Secondly, the â€Å"majority rule principle† states that if the alleged wrong can be confirmed or ratified by a of members in a general meeting, then the court will not interfere, Edwards v Halliwell [1950] 2 All ER 1064 is a UK labour law and UK company law case about the internal organisation of a trade union, or a company, and litigation by members to make an executive follow the organisation's internal rules Some members of the National Union of Vehicle Builders sued the executive committee for increasing fees. Rule 19 of the union constitution required a ballot and a two third approval level by members. Instead a delegate meeting had purported to allow the increase without a ballot. Jenkins LJ granted the members' application. He held that under the rule in Foss v Harbottle the union itself is prima facie the proper plaintiff and if a simple majority can make an action binding, then no case can be brought. But there are exceptions to the rule. First, if the action is ultra vires a member may sue. Second, if the wrongdoers are in control of the union's right to sue there is a â€Å"fraud on the minority†, and an individual member may take up a case. Third, as pointed out by Romer J in Cotter v National Union of Seamen[1] a company should not be able to bypass a special procedure or majority in its own articles. This was relevant here. And fourth, as here, if there is an invasion of a personal right. Here it was a personal right that the members paid a set amount in fees and retain Salomon v A Salomon ; Co Ltd [1897] AC 22 is a landmark UK company law case. The effect of the Lords' unanimous ruling was to uphold firmly the doctrine of corporate personality, as set out in the Companies Act 1862, so that creditors of an insolvent company could not sue the company's shareholders to pay up outstanding debts. membership as they stood before the purported alterations. Facts Mr Aron Salomon made leather boots and shoes in a large Whitechapel High Street establishment. He ran his business for 30 years and â€Å"he might fairly have counted upon retiring with at least ? 10,000 in his pocket. † His sons wanted to become business partners, so he turned the business into a limited company. His wife and five eldest children became subscribers and two eldest sons also directors. Mr Salomon took 20,001 of the company's 20,007 shares. The price fixed by the contract for the sale of the business to the company was ? 9,000. According to the court, this was â€Å"extravagent† and not â€Å"anything that can be called a business like or reasonable estimate of value. † Transfer of the business took place on June 1, 1892. The purchase money the company paid to Mr Salomon for the business was ? 20,000. The company also gave Mr Salomon ? 10,000 in debentures (i. e. , Salomon gave the company a ? 10,000 loan, secured by a charge over the assets of the company). The balance paid went to extinguish the business's debts (? ,000 of which was cash to Salomon). Soon after Mr Salomon incorporated his business a series of strikes in the shoe industry led the government, Salomon's main customer, to split its contracts among more firms (the government wanted to diversify its supply base to avoid the risk of its few suppliers being crippled by strikes). His warehouse was full of unsold stock. He and his wife lent the company money. He cancelled his debentures. But the company needed more money, and they sought ? 5,000 from a Mr Edmund Broderip. He assigned Broderip his debenture, the loan with 10% interest and secured by a floating charge. But Salomon's business still failed, and he could not keep up with the interest payments. In October 1893, Mr Broderip sued to enforce his security. The company was put into liquidation. Broderip was repaid his ? 5,000, and then the debenture was reassigned to Salomon, who retained the floating charge over the company. The company's liquidator met Broderip's claim with a counter claim, joining Salomon as a defendant, that the debentures were invalid for being issued as fraud. The liquidator claimed all the money back that was transferred when the company was started: rescission of the agreement for the business transfer itself, cancellation of the debentures and repayment of the balance of the purchase money. Lee v Lee’s Air Farming Ltd [1961] AC 12 is a UK company law case, concerning the veil of incorporation and separate legal personality. The Privy Council reasserted that a company is a separate legal entity, so that a director could still be under a contract of employment with the company he solely owned. Facts Mrs Lee’s husband formed the company through Christchurch accountants, which worked in Canterbury, New Zealand. It spread fertilisers on farmland from the air, known as top dressing. Mr Lee held 2999 of 3000 shares, was the sole director and employed as the chief pilot. He was killed in a plane crash. Mrs Lee wished to claim under the Workers’ Compensation Act 1922, and he needed to be a ‘worker’, or ‘any person who has entered into or works under a contract of service†¦ with an employer†¦ whether remunerated by wages, salary or otherwise. The company was insured (as required) for worker compensation. The Court of Appeal of New Zealand said Lee could not be a worker when he was in effect also the employer. North J said[1] â€Å"the two offices are clearly incompatible. There would exist no power of control and therefore the relationship of master-servant was not created. ADVICE The Privy Council advised that Mrs Lee was entitled to co mpensation, since it was perfectly possible for Mr Lee to have a contract with the company he owned. The company was a separate legal person. Lord Morris of Borth-y-Gest said It was never suggested (nor in their Lordships’ view could it reasonably have been suggested) that the company was a sham or a mere simulacrum. It is well established that the mere fact that someone is a director of a company is no impediment to his entering into a contract to serve the company. If, then, it be accepted that the respondent company was a legal entity their Lordships see no reason to challenge the validity of any contractual obligations which were created between the company and the deceased†¦ It is said that the deceased could not both be under the duty of giving orders and also be under the duty of obeying them. But this approach does not give effect to the circumstance that it would be the company and not the deceased that would be giving the orders. Control would remain with the company whoever might be the agent of the company to exercise†¦ There appears to be no great difficulty in holding that a man acting in one capacity can make a contract with himself in another capacity. The company and the deceased were separate legal entities. Perpetual Real Estate Services, Inc. v. Michaelson Properties Facts Aaron Michaelson formed Michaelson Properties, Inc in 1981. Aaron was the sole shareholder and the corporation's president. It was a business for real estate joint ventures. It entered a joint venture with Perpetual Real Estates (forming a partnership called â€Å"Arlington Apartment Associates†) to build condominiums. As they were building, further finance was needed. Michaelson Properties Inc could not put up its share, so Perpetual loaned it $1. 05m, and got a personal guarantee from Aaron. The apartments did not turn out to be built that well. Purchasers sued the partnership successfully for $950,000. Perpetual Real Estates paid it off on the partnership's behalf. Then they sought Michaelson Properties Inc to contribute its share. It did not have the money, and went bust. So they sued Aaron to pay. He argued that Michaelson Properties, Inc was a separate legal person to him, and it was inappropriate to pierce the corporate veil. At first instance the jury held Aaron should pay. Aaron appealed. Judgment Wilkinson J noted that Virginia law had assiduously upheld the â€Å"vital economic policy† of respecting a corporation as a separate legal entity, since it underpinned the operation of vast enterprises. He emphasised that the veil would only be lifted where a defendant exercises â€Å"undue domination and control† and uses the corporation as â€Å"a device or sham†¦ to disguise wrongs, obscure fraud, or conceal crime. â€Å"[1] He said the description of the law which the jury had heard was in a â€Å"rather soggy state† and emphasised that it was not enough that â€Å"an injustice or fundamental unfairness† would be perpetrated. â€Å"The fact,† he continued, â€Å"that limited liability might yield results that seem â€Å"unfair† to jurors unfamiliar with the function of the corporate form cannot provide a basis for piercing the veil. Because there was no evidence that Aaron was attempting to defraud anybody, the veil could not be lifted. There was no â€Å"unfair siphoning of funds† when Aaron paid himself a dividend, because distribution was entirely foreseeable when the money was given, and the distribution happened well before any suit was filed. The fact that Aaron had given personal guarantees strengthened the corporate veil presumption, because the transactions recognized it existed. Veil lifting by the courts (1) Where company is a Sham or Facade Adams v Cape Industries English law has suggested a court can only lift the corporate veil when (1) construing a statute, contract or other document; (2) if a company is a â€Å"mere facade† concealing the true facts, or (3) when a subsidiary company was acting as an authorised agent of its parent, and apparently not so just because â€Å"justice requires† or to treat a group of companies as a single economic unit, in the case of tort victims, the House of Lords suggested a remedy would in fact be available. In Lubbe v Cape plc[1] Lord Bingham held that the question of proving a duty of care being owed between a parent company and the tort victims of a subsidiary would be answered merely according to standard principles of negligence law: generally whether harm was reasonably foreseeable. the decision in Yukong Line Ltd of Korea v Rendsburg Investment Corpn of Liberia (No 2) [1998] 2 BCLC 485 was timely in pointing out that creditors have no standing, individually or collectively to bring an action in respect of any such duty. Toulson J, held that a director of an insolvent company who, in breach of duty to the company, transferred assets beyond the reach of its creditors owed no corresponding fiduciary duty to an individual creditor of the company. The appropriate means of redress was for the liquidator to bring an action for misfeasance (the Insolvency Act 1986, section 212). ?Notwithstanding the logistical issue of locus standi raised by Toulson J. the question of directors’ duties to creditors again emerged in two recent decisions of the Companies Court 2) Where the company is used for a fraudulent purpose Sri Jaya Berhad v RHB Berhad The courts in Singapore thus far have been reluctant to pierce the corporate veil when called upon to do so and indicated that they would only exercise their power when called upon to do so sparingly . Re Darby, ex parte Brougham [1911] 1 KB 95 is a UK company law case concerning piercing the corporate veil. It is a clear example of the courts ignoring the veil of incorporation where a company is used to conceal a fraudulent operation. Facts Darby and Gyde were undischarged bankrupts with convictions for fraud. They registered a company called City of London Investment Corporation Ltd (LIC) in Guernsey. It had seven shareholders and issued ? 11 of its nominal capital of ? 100,000. Darby and Gyde were the only directors and entitled to all profits. The company purported to register and float a company in England called Welsh Slate Quarries Ltd, for ? 30,000. It bought a quarrying licence and plant for ? 3500 and sold this to WSQ for ? 18,000. The prospectus invited the public to take debentures in WSQ. It stated the name of LIC, but not Darby and Gyde, or the fact that they would receive the profit on sale. WSQ failed and went into liquidation. The liquidator claimed Darby’s secret profit, which he made as a promoter. Darby objected that the LIC and not him was the promoter. Judgment Phillimore J rejected the argument. LIC ‘was merely an alias for themselves just as much as if they had announced in the Gazette that they were in future going to call themselves ‘Rothschild ; Co’. They were ‘minded to perpetrate a very great fraud’ __________________________ Creation of Agency (1) Actual Authority The doctrine of estoppel comes into play here to prevent a principal from asserting to a third party that the agent has authority when in fact he does not, and then subsequently the principal seeks to renege on an agreement on the basis that the agent never had actual authority. In law, apparent authority refers to the authority of an agent as it appears to others,[3] and it can operate both to enlarge actual authority and to create authority here no actual authority exists. [4] The law relating to companies and to ostensible authority are in reality only a sub-set of the rules relating to apparent authority and the law of agency generally, but because of the prevalence of the issue in relation to corporate law (companies, being artificial persons, are only ever able to act at all through their human agents), it has developed its own specific body of cas e law. However, some jurisdictions use the terms interchangeably. In Freeman and Lockyer v Buckhurst Park Properties (Mangal) Ltd [1964] 2 QB 480 the director in question managed the company's property and acted on its behalf and in that role employed the plaintiff architects to draw up plans for the development of land held by the company. The development ultimately collapsed and the plaintiffs sued the company for their fees. The company denied that the director had any authority to employ the architects. The court found that, while he had never been appointed as managing director (and therefore had no actual authority, express or implied) his actions were within his ostensible authority and the board had been aware of his conduct and had acquiesced in it. Diplock LJ identified four factors which must be present before a company can be bound by the acts of an agent who has no authority to do so; it must be shown that: 1. a representation that the agent had authority to enter on behalf of the company into a contract of the kind sought to be enforced was made to the contractor; 2. uch a representation was made by a person or persons who has ‘actual' authority to manage the business of the company, either generally or in respect of those matters to which the contract relates; 3. the contractor was induced by such representation to enter into the contract, i. e. that he in fact relied upon it; and 4. under its memorandum or articles of association the company was not deprived of the capacity either to enter into a contract of the kind sought to be enforced or to delegate authority to enter into a contract of that kind to an agent. The agent must have been held out by someone with actual authority to carry out the transaction and an agent cannot hold himself out as having authority for this purpose. [5] The acts of the company as principal must constitute a representation (express or by conduct) that the agent had a particular authority and must be reasonably understood so by the third party. In determining whether the principal had represented his agent as having such authority, the court has to consider the totality of the company's conduct. 6] The most common form of holding out is permitting the agent to act in the conduct of the company's business, and in many cases this is inferred simply from allowing the agent to use a particular title, such as ‘finance director'. The apparent authority must not be undermined by any limitations on the company's capacity or powers found in the memorandum or articles of association, although in many countries, the effect of this is reduced by company law reforms abo lishing or restricting the application of the ultra vires doctrine to companies. 7] However, statutory reforms do not affect the general principle that a third party cannot rely upon ostensible authority where it is aware of some limitation which prevents the authority arising, or is put on enquiry as to the extent of an individual's authority. [8] In some circumstances, the very nature of a transaction would be held to put a person on enquiry. Facts Lord Suirdale (Richard Michael John Hely-Hutchinson) sued Brayhead Ltd for losses incurred after a failed takeover deal. The CEO, chairman and de facto managing director of Brayhead Ltd, Mr Richards, had guaranteed repayment of money, and had indemnified losses of Lord Suirdale in return for injection of money into Lord Suirdale's company Perdio Electronics Ltd. Perdio Ltd was then taken over by Brayhead Ltd and Lord Suirdale gained a place on Brayhead Ltd's board, but Perdio Ltd's business did not recover. It went into liquidation, Lord Suirdale resigned from Brayhead Ltd’s board and sued for the losses he had incurred. Brayhead Ltd refused to pay on the basis that Mr Richards had no authority to make the guarantee and indemnity contract in the first place. Roskill J held Mr Richards had apparent authority to bind Brayhead Ltd, and the company appealed. That has been done in the judgments of this court in Freeman ; Lockyer v Buckhurst Park Properties (Mangal) Ltd. [1] It is there shown that actual authority may be express or implied. It is express when it is given by express words, such as when a board of directors pass a resolution which authorises two of their number to sign cheques. It is implied when it is inferred from the conduct of the parties and the circumstances of the case, such as when the board of directors appoint one of their number to be managing director. They thereby impliedly authorise him to do all such things as fall within the usual scope of that office. Actual authority, express or implied, is binding as between the company and the agent, and also as between the company and others, whether they are within the company or outside it. Ostensible or apparent authority is the authority of an agent as it appears to others. It often coincides with actual authority. Thus, when the board appoint one of their number to be managing director, they invest him not only with implied authority, but also with ostensible authority to do all such things as fall within the usual scope of that office. Other people who see him acting as managing director are entitled to assume that he has the usual authority of a managing director. But sometimes ostensible authority exceeds actual authority. For instance, when the board appoint the managing director, they may expressly limit his authority by saying he is not to order goods worth more than ? 00 without the sanction of the board. In that case his actual authority is subject to the ? 500 limitation, but his ostensible authority includes all the usual authority of a managing director. The company is bound by his ostensible authority in his dealings with those who do not know of the limitation. He may himself do the â€Å"holding-out. † Thus, if he orders goods worth ? 1,000 and signs himself â€Å"Managin g Director for and on behalf of the company,† the company is bound to the other party who does not know of the ? 00 limitation (2) Apparent Authority An ‘apparent’ or ‘ostensible’ authority, on the other hand, is a legal relationship between the principal and the contractor created by a representation, made by the principal to the contractor, intended to be and in fact acted upon by the contractor, that the agent has authority to enter on behalf of the principal into a contract of a kind within the scope of the ‘apparent’ authority, so as to render the principal liable to perform any obligations imposed upon him by such contract. To the relationship so created the agent is a stranger. He need not be (although he generally is) aware of the existence of the representation but he must not purport to make the agreement as principal himself. The representation, when acted upon by the contractor by entering into a contract with the agent, operates as an estoppel, preventing the principal from asserting that he is not bound by the contract. It is irrelevant whether the agent had actual authority to enter into the contract. In ordinary business dealings the contractor at the time of entering into the contract can in the nature of things hardly ever rely on the ‘actual’ authority of the agent. His information as to the authority must be derived either from the principal or from the agent or from both, for they alone know what the agent’s actual authority is. All that the contractor can know is what they tell him, which may or may not be true. In the ultimate analysis he relies either upon the representation of the principal, that is, apparent authority, or upon the representation of the agent, that is, warranty of authority. The representation which creates ‘apparent’ authority may take a variety of forms of which the commonest is representation by conduct, that is, by permitting the agent to act in some way in the conduct of the principal’s business with other persons. By so doing the principal represents to anyone who becomes aware that the agent is so acting that the agent has authority to enter on behalf of the principal into contracts with other persons of the kind which an agent so acting in the conduct of his principal’s business has usually ‘actual’ authority to enter into. | First International v Hungarian International Bank| An agent who had no apparent authority to conclude a transaction might nevertheless have apparent authority to make representations of fact concerning it, such as the fact that his principal had given the necessary approval for it. The Court of Appeal dismissed an appeal by the defendant, Hungarian International Bank Ltd, and upheld a decision of Judge Michael Kershaw QC, sitting as a deputy High Court judge in the Commercial Court on 23 October 1991, giving judgment for the plaintiff, First Energy (UK) Ltd. The case concerned an alleged contract under which the defendant was to provide the plaintiff with business finance. One of the issues was whether the defendant's agent had ostensible authority to communicate the offer upon which the contract was based. The judge held that he did, and that the plaintiff accepted that offer, so creating the contract. Mary Arden QC and Michael Todd (Chaffe Street, Manchester) for the defendant; Giles Wingate-Saul QC and Andrew Sander (Davies Arnold Cooper) for the plaintiff. LORD JUSTICE STEYN said a theme that ran through the law of contract was hat the reasonable expectations of honest men must be protected. It was not a rule or principle of law. But if the prima facie solution to a problem ran counter to reasonable expectations of honest men, this criterion sometimes required a rigorous re-examination of the problem to ascertain whether the law did compel demonstrable unfairness. In the present case, if their Lordships were to accept the implication s which the defendant had placed on observations of the House of Lords in Armagas Ltd v Mundogas SA (1986) 1 AC 717, it would frustrate the reasonable expectations of the parties. The plaintiff's case was that the defendant's agent, while not authorised to enter into the transaction, did have ostensible authority to communicate his head office's approval of the financing facility. He had sent the plaintiff a letter to this effect, which the judge held amounted to an offer capable of acceptance by the plaintiff. The law recognised that in modern commerce an agent who had no apparent authority to conclude a particular transaction might sometimes be clothed with apparent authority to make representations of fact. A decision that the agent did not have such authority would defeat the reasonable expectation of the parties. It would also fly in the face of the way in which in practice negotiations were conducted between trading banks and trading customers who sought commercial loans. RATIFICATION The agent whose act is sought to be ratified must have purported to act for the principal: Keighley, Maxstead ; Co v Durant [1901, UK], endorsed by Crowder v McAlister [1909, Qld] per Cooper CJ – â€Å"There can be no ratification of a contract by a person sought to be made liable as a principal, unless the person who made the contract professed to be acting on behalf of the other at the time. Keighley, Maxstead ; Co v Durant [1901, UK]: An agent had authority to purchase grain up to a particular price. Ended up contracting to pay too much, KMCo first decide to ratify, then change their minds. Problem was that the contract was in the name of the agent and of D. D sues, but loses. a. At the time the act was done the agent must have had a competent principal: Corporations Law – s 131(1). b. At the time of ratification the principal must be legally capable of doing the act himself. c. The principal must have full knowledge of all material facts relating to the act to be ratified. Ratification must take place within a reasonable time of the agent’s act unless the contract stipulates another more specific timeframe. The principal has no right to see if market conditions improve, or similar, before ratifying: Prince v Clark (1823). Ratification: entering into an unauthorised contract The principles of ratification Where an agent enters into an unauthorised contract, the principle may be happy to adopt it. This can be done by the process of ratification. For ratification to be available, however, the agent must purport to act on behalf of a principle, the principle must be in existence at the time of the contract, and the principle must have capacity. The agent must purport to act on behalf of a principle Because the agent must purport to be acting on behalf of another, ratification is not available where the principle is undisclosed. The third party must know that there is, or is supposed to be, a principle in the background. If the third party thinks that the agent is acting on his or her own account, no later ratification will be possible. The principle must be in existence at the time of the contract The second requirement for ratification, that is, that the principle is in existence at the time of ratification, arises mainly in relation to contracts made on behalf of new companies which are being formed. In Kelner v Baxter, it was held that if the company was not existence (in that it had not been incorporated) at the time of the contract, it could not later ratify the agreement. The purported ‘agents’, the promoters of the company, were therefore personally liable. Such personal liability is now imposed by statute, by virtue of s 36C of the Companies Act 1985. The principle must have capacity The final requirement is that the principle must have capacity. There are in theory two aspects to this rule. The first rule is that the principle must have capacity to make the transaction at the time of the contract. This has most obvious relevance to minors, who want to ratify after reaching majority. It could also apply to contracts made outside the powers of a company. The second aspect is that the principle must have capacity at the time of ratification. This was applied in Grover and Grover Ltd v Matthews. A contract of fire insurance was purported to be ratified after a fire had destroyed the property which was the subject of the insurance. It was held that this was ineffective because at the time of the purported ratification the principle could not have made the contract himself (because the property no longer existed). ‘Capacity’ is thus being given a rather broader meaning than usual, to cover the issue as to whether the principle would have in practice been able to make the contract in question. Ratification is retrospective in its effect, and the original contract must be treated as if it had been authorised from the start. This was confirmed by the Court of Appeal in Presentaciones Musicales SA v Secunda. The implications of this rule are clear from the decision in Bolton Partners v Lambert. Bolton Partners owned a factory, which Lambert offered to buy. This offer was accepted by the managing director, though in fact he had no authority to do this. On 13 January, there was a disagreement, and Lambert withdrew his offer. On 17 January, Bolton Partners started proceedings for breach of contract. On 28 January, the Board of Directors of Bolton Partners ratified the actions of the managing director. Lambert argued that this ratification came too late, but the Court of Appeal held that it had retrospectively validated the original contract, and that Lambert’s attempt to withdraw was therefore ineffective. INDOOR MANAGEMENT RULE and LIABLITY OF CRIMINAL and TORTOUS ACTS Royal British Bank v Turquand (1856) 6 E;B 327 is a UK company law case that held people transacting with companies are entitled to assume that internal company rules are complied with, even if they are not. This â€Å"indoor management rule† or the â€Å"Rule in Turquand's Case† is applicable in most of the common law world. It originally mitigated the harshness of the constructive notice doctrine, and in the UK it is now supplemented by the Companies Act 2006 sections 39-41. The rule in Turquand's case was not accepted as being firmly entrenched in law until it was endorsed by the House of Lords. In Mahony v East Holyford Mining Co[1] Lord Hatherly phrased the law thus: When there are persons conducting the affairs of the company in a manner which appears to be perfectly consonant with the articles of association, those so dealing with them externally are not to be affected by irregularities which may take place in the internal management of the company. So, in Mahoney, where the company's articles provided that cheques should be signed by any two of the three named directors and by the secretary, the fact that the directors who had signed the cheques had never been properly appointed was held to be a matter of internal management, and the third parties who received those cheques were entitled to presume that the directors had been properly appointed, and cash the cheques. The position in English law is now superseded by section 40 of the Companies Act 2006,[2] but the Rule in Turquand's Case is still applied throughout many common law jurisdictions in the Commonwealth. According to the Turquand rule, each outsider contracting with a company in good faith is entitled to assume that the internal requirements and procedures have been complied with. The company will consequently be bound by the contract even if the internal requirements and procedures have not been complied with. The exceptions here are: if the outsider was aware of the fact that the internal requirements and procedures have not been complied with (acted in bad faith); or if the circumstances under which the contract was concluded on behalf of the company were suspicious. However, it is sometimes possible for an outsider to ascertain whether an internal requirement or procedure has been complied with. If it is possible to ascertain this fact from the company's public documents, the doctrine of disclosure and the doctrine of constructive notice will apply and not the Turquand rule. The Turquand rule was formulated to keep an outsider's duty to inquire into the affairs of a company within reasonable bounds, but if the compliance or noncompliance with an internal requirement can be ascertained from the company's public documents, the doctrine of disclosure and the doctrine of constructive notice will apply. If it is an internal requirement that a certain act should be approved by special resolution, the Turquand rule will therefore not apply in relation to that specific act, since a special resolution is registered with Companies House (in the United Kingdom), and is deemed to be public information. Liability In English law, a corporation can only act through its employees and agents so it is necessary to decide in which circumstances the law of agency or vicarious liability will apply to hold the corporation liable in tort for the frauds of its directors or senior officers. If liability for the particular tort requires a state of mind, then to be liable, the director or senior officer must have that state of mind and it must be attributed to the company. In Meridian Global Funds Management Asia Limited v. Securities Commission [1995] 2 AC 500, two employees of the company, acting within the scope of their authority but unknown to the directors, used company funds to acquire some shares. The question was whether the company knew, or ought to have known that it had acquired those shares. The Privy Council held that it did. Whether by virtue of their actual or ostensible authority as agents acting within their authority (see Lloyd v Grace, Smith ; Co. [1912] AC 716) or as employees acting in the course of their employment (see Armagas Limited v Mundogas S. A. [1986] 1 AC 717), their acts and omissions and their knowledge could be attributed to the company, and this could give rise to liability as joint tortfeasors where the directors have assumed responsibility on their own behalf and not just on behalf of the company. So if a director or officer is expressly authorised to make representations of a particular class on behalf of the company, and fraudulently makes a representation of that class to a Third Party causing loss, the company will be liable even though the particular representation was an improper way of doing what he was authorised to do. The extent of authority is a question of fact and is significantly more than the fact of an employment which gave the employee the opportunity to carry out the fraud.