Green Claims Essay Example | Topics and Well Written Essays - 250 words

Green Claims - Essay Example The consumers consider them â€Å"as not made for them but for people from high class societies† (Klutz, 2009). According the research done by the United Nations Environmental Program in 2009, global market is not really ready for these products. This may be as a result of the consumers’ attitude towards these products. There are various false green claims being made by various companies around the world. These claims cannot be substantiate hence also misleading the consumers. On the other hand, products making green claims have turned to be a global trend where many companies in the world are adapting to this initiative. For green products to become main stream, they should firstly be bought at an affordable price as the rest of other products. The consumers also need to be aware of these products which can be achieved through advertisements, consumer education about green claims. A radical action should also be taken on companies and manufactures who give false green claims on products in the market. Rules and regulations should be set in relation to the green claim initiative. The U.S does not have a national body that oversees green certificates which makes it hard to enforce the Green Claim initiative programs (Sobha, 2008). As a result, U.S products are less competitive in the global market. In this case, it is difficult to examine the effectiveness of green technology in the states. A body independent body that focuses on green technology should be created to empower the Green Claim initiatives. Klutz M. (2009). Environmentally Conscious Materials Handling: New Jersey. John Wiley & Sons,

Written methods Essay Example for Free

Written methods Essay E-mail is used in Perkins as a fast and detailed way to communicate to communicate between departments of the business and a way to send documents from one place to another quickly by attaching them to an E-mail.  ICT robots are used as an easy way to build the engines because all they needed to do was to install some software and programme them for what they are needed to do. Written methods  Financial documents are used as communication to customers and to confirm that their order has been received. There are a variety of financial documents starting with the Order form then going to the delivery note followed by the credit (if needed) ect. Letters are also used as communication to customers, suppliers and other Perkins factories.  Oral  Department meetings are used in Perkins because it is a way for the heads of each of the departments to say what is happening in their department and also to assign jobs to each department and to show others designs for their newest engines. These meetings are time consuming and they might also cause conflict between colleagues sharing their opinions about what is happening in the business. These meetings are held once a week in Perkins and they are attended heads of all functional areas or the head of one department and their employees. Production meetings are used to share ideas about what the next engine will be like. These meetings are also time consuming and can be disrupted easily by lateness.  C2  Communication inside functional areas  Email is used inside the functional areas to send information to other employees this is good because it keeps the employees up to date with what is happening within the department, it is also a fast way of communicating and you can also attach documents. Email can also be bad because employees might send the wrong information or they might send it to the wrong employee. Department meeting are useful inside Perkins no matter if it is a meeting with all the department heads or just the one head of that specific department (this is the one I shall talk about in this paragraph) this is a good method of communication because it means that all employees shall know what their newest assignment but these meetings can also be bad because they are easily disrupted by people being late and these meeting can also cause conflict between workers and compromise the amount of engines made, if some employees are not getting along it will bring down worker morale. Fax is used inside functional area to send important documents around the functional area of the business. This is good because it is like a photo copier and a telephone because employees can send other employees documents and still have the original copy.  Between functional areas  Fax is used between functional areas in the same way as they use it inside the functional area of the business.  Intranet is used between functional areas because it is like a closed circuit internet just for Perkins. It is used to give employees a basic idea of what they may need to do. This is made by the Administration department to let employees know what customers they are providing for and what types of engines they would like. Email is used between functional areas because they can send documents of what the customer wants and how they want it made. This is used by employees to send each other information quickly and neatly.  Communication with people outside the business  The telephone is used to contact people outside Perkins. This can be used to contact people who work for Perkins or customers of Perkins (Perkins generally does not phone customers but they use letters and financial documents) Telephone conferencing is used to have three or more way conversations for people who work at home for Perkins this is useful because they dont have to keep putting people on hold. Telephone conferencing can also be bad because employees may not be able to understand others if they are from other countries. This can also be used to communicate with rich customers.  Letters are used to communicate with customers to see what they want and if they are still loyal to Perkins. They are also used to communicate to shareholders so they can have the information about how the business is running.

Free College Admissions Essays: I Look Great in Ivy! :: College Admissions Essays

I Look Great in Ivy! Â   Discovering and choosing a university that fulfills all of my needs was a rigorous yet exciting task. The Ivy U clearly emerged as the best choice for me and I, as a great match for the university. After visiting the campus, reading the information pamphlet, and researching the university Web site, I realize that Ivy offers what I hope to gain from my college experience. In return, I will contribute to the university as a person with leadership qualities who takes initiative and enjoys participating in school events. Â   For many years, I have wanted to become a midwife, and the Ivy School of Nursing stands out as the premium institution for such training. The university's close proximity to many hospitals will familiarize me with patients and hospital life, allowing me the best training possible. Â   As an individual, I will thrive in the intimate and familiar environment of the nursing school, one of Ivy's smallest schools. Coming from a small high school, I was greatly impressed by my visit to the campus, where I noticed the close relationships between the professors and students, and the strong family feeling within the nursing school. Â   The location of Ivy's nursing school within the large campus of Ivy's other schools offers myriad benefits. Firstly, I will have the opportunity to take classes in any of the other schools at Ivy, and this seamless academic integration will allow me to pursue my interests outside of nursing. Â   In addition to academic breadth, there are a greater variety of extra-curricular activities available on the larger campus. I am excited about continuing my interests in sports and theater. I have played on my high school's varsity volleyball team for two years and I plan to play volleyball throughout college in Ivy's women's club volleyball. I also performed in The Sound of Music in high school and the Teatron will allow me to actively participate in theater. Â   As president of the student council, I have always promoted school spirit, and I intend to continue my enthusiastic involvement throughout my college career. My school places a large emphasis on test grades and homework, creating a serious mood throughout the school. As president, I have tried to enrich the school experience by planning events such as school lunches and interesting field trips.

Iraq iran war of 1980 – major facts

Key Dates Context – Iraq 13 Millions inhabitants Saddam Hussein is still contested in his own parti by A1 Bakr supporters and with Islamic revolution in Iran, Shiis start a revolt in 1979. 1st military power in the region. Arabs = 75%, Kurds = 17%, perstan 2%. 2/2 Sunni, 1/2 Shii and 3% of minority (christians, Jews,†¦ ) Economic dependency on oil. Others sectors were developping. Baasist regim since 1968 and the second â€Å"coup d' ©tat† (1st in 1963).July 1979, Saddam Hussein finally take supreme power after the ‘elimination' of his cousin Hassan A1 Bakr, former Iraq president. Context – Iran 35 Million inhabitants Islamic regim after the 1979 revolution Persian = 61 %, Azeris = 16%, Kurds = 90% Shii, 9% Sunni, 1% non muslim (Christians, Jew, Zoroastrians). Economic dependency to oil (79% of government revenues). Others sectors are badly developped. But still contested. Weakness of military forces due to purges of new regims.Religious differences – Sunni / Shii Had split in 661 after the assassination of All, the 4th Caliph and especially the nephew and son in law of Muhamad as the first one who have convert himself to Islam. Political differences at start. Shii thinks the Caliph should be a descendant of Ali and o Muhamad to have the prophete blood. Sunni gives the caliphate to the best muslim. Religion practice also differs. For Shii, they think Caliphs and Imams can interpret the coran. For Sunni, interpretation. are not really accepted.There is also the 7 revealed / 7 hidden imman theory in Shiism. Today : 90% of Muslim are Sunni. In the 10th Century, 50% and the two main caliphate were ruled by Shii. Arabs / Persians Economic and Political stakes (Iraqi motivations) Shatt al Arab first reason of the conflict Geostrategic Waterway close to the Persian gulf. – Use to be Iraqi – Since the Alger agreements (1975) the two ountries share the area Iraqi wants to get back Shatt al Arab. The Saddam Hussein g overnmant (BAAS) is a lay party: Stop the Islamic expansion in the region.Factors leading to the War Iraqui political and economical motivations Iran is weakened because of the Islamic revolution Saddam feels invincible (30 days of war maximum) Ayatollah Rouhollah khomeini, Islamic revolution leader has bad relationship with Saddam Hussein Saddam Hussein thinks that he has support within Iran (Socialist and non-revolutionary partisants) Saddam Hussein thinks that he has gulfs countries support Iranian Stakes for winning the war After having won 1% of the Iranian territory, Saddam strengthened his trust in winning the war and proposed a ceasefire.

Cari’s Story Essay

An infection in Cari’s nasal passage and pharynx can spread to her sinuses because her sinuses open into the nasal cavity and the throat. The cough reflex makes a coughing response to the larynx, pharynx, and the trachea-bronchial tree. Cari’s respiratory system is clearing her lungs the cilia moving the mucus from the lungs and it starts the cough reflex sending mucus to the pharynx therefore you are able to swallow it or spit it out. The structure found in the terminal bronicoles and alveoli that would normally protect Cari’s lungs from infectious pathogens are called macrophages. The mucous in the lungs would raise the resistance in her air way because the small opening, the buildup would cause. Fluid would have some alveoli drown where they could not function and would buildup friction or rubbing. Cari’s compliance would increase because of the loss of volume reduces total lung compliance and cause it to work harder. The fluid would lower her total lun g capacity by not letting the space by not allowing it to be filled with air. The elevation cause her respiratory rate to alter her ventilation by the volume is total volume of air taken in and out each minute. Cari blood gases would show too much oxygen. The symptoms of panting like a dog and my chest hurts are what make me think she is low in oxygen. The oxygen carrying capacity of hemoglobin is affected by POC 2 and alkaline blood gases are down and the breathing has delivered more oxygen is released from blood and caused more oxygen to be used. The administration of oxygen would help her to breath. The anatomical structures in her respiratory system involved are the lungs and the alveoli. Cari was plagued with a chronic cough due to excessive mucus produced that doesn’t clear. The damaging effects of tobacco smoke because Cari respiratory system to be impaired is nicotine’, nicotine make the bronchioles smaller and decreases.

Abortion and Euthanasia Question Essay Example

Abortion and Euthanasia Question Essay Example Abortion and Euthanasia Question Essay Abortion and Euthanasia Question Essay Christians hold a strong responsibility for those at the beginning and end of their lives there for abortion and euthanasia are very important issues. Roman Catholics believe that abortion which is killing an unborn child is wrong because they believe life starts at conception so someone who commits abortion is killing a life. Christians also believe in the parable of sheeps and goats which means if someone kills a person or hurts a person it is killing Jesus and if life is harmed it is saving Jesus meaning Jesus is in everyone of us even in the unborn child and a person at the end of their life so committing abortion and euthanasia is against the Christian religion. In Mathew 4:23 Jesus went throughout Galilee, teaching.and healing every disease and sickness among the people therefore we should help the unborn child and people suffering just like he did not resorting to abortion or euthanasia but to help the unborn child and look after the person at the end of their lives. Christian also believe We were made in gods image so everyones life should be preserved even the unborn child Some might believe that life at the beginning and the end of life are not as important as life in the middle, but all life is important according to most Christians and also in mark 10:13 the parable tells of people bringing their little children to Jesus to have him touch them. But the disciples rebuke them. Jesus sees this and says to them let the little children come to me, and do not hinder them, for the kingdom of God belongs to them. Meaning Jesus believes that life at the beginning is important as well. The Orthodox Church believes abortion is a heinous act of evil and shouldnt be used to kill an unborn child. But the Church of England has a different view they believe the foetus is important and it is wrong kill the foetus but the mother has the right to have an abortion if she wants. The story of the Good Samaritan is a good example it is trying to tell us to love our enemy but how can we do it if we are allowing people to die. This tells us that Christian responsibility about abortion and abortion is strong. There are other people who argue for abortion. The Anglican Church believes abortion should be used if the mothers life is affected. So either way someone will be killed. The Beatitudes as well say happy are the merciful this means to allow abortion happen and become more merciful. The humanists believe life can be ended if they wish so abortion can be allowed to happen. But euthanasia though will only be made if the person who is ready to die wants it. The Methodists believe the same Pre death Landlines must be relieved all needs including the spiritual must be met Jesus was filled with pity for the helpless by allowing abortion and euthanasia is the common argument for abortion and euthanasia because it gets rid of the suffering of the mother and the person who will die. A Christian responds by having abortion either because of rape which is a horrible experience. And another problem for pregnant women is would they have enough money to support a child as it grows up another reason is if the mothers health is effected which can lead to the mother dieing and the child dieing as well. Also the mother may also be very young and may not hold the responsibility to look after a child or the mother is too old to give birth. Roman Catholics believe you should not have an abortion even if the mother or family is affected, but to help the mother and family through the ordeal rather than forgetting about them because of the saying Should not be indifferent to sorrow and misery. A Christian should do what he can. Christians have a different response for euthanasia, all Christians believe euthanasia is wrong however in some cases some Christians may go against the church and say it would be more merciful to allow euthanasia. Tony Bland was crushed in the Hillsborough disaster. Tony had been put on a life support machine for 4 years till it was switched off by hiss parents consent. A priest said that they had gone against Christianity and committed euthanasia. But another priest said that they werent because Tony was not showing any sign of improvement. Euthanasia is best for people who live a life of suffering and feel themselves that they would rather die than suffer. People who are against abortion or euthanasia find a better way around than allowing the child aborted or the person to die. In Euthanasia Christians care for the patient, give counselling or send them to a hospice, this gives them a good life before they die. Hospices look after patients who are ill and near to dieing, they give them happiness before they die rather than just letting them die which is a bad way to die and euthanasia is the easy way out. Even though they are suffering which in away gets those to heaven just like Jesus who suffered on the cross before being sent to heaven. Allowing Euthanasia is like killing Jesus just like the parable of the sheep and the goats. People should also have the power to decide if someone is to die that is breaking the commandment thou shall not kill. Christians who do not allow abortion keep the baby, put the baby up for adoption or get counselling. These can be difficult to do if they keep the baby it can be hard to afford to look after it or if it is put up for adoption it is hard to give it away. Christians do this so that they dont break the commandment thou shall not kill and breaking also that life start at conception. Roman Catholics say everyone should not commit abortion because Respect for life is not a duty, but embedded in the mind and heart of the human race meaning there is no excuse to have an abortion. The orthodox religion does not have abortions because they believe life is sacred. What Christians believe about life is up to them. They should not try to make others accept their position Christians would argue against this they would say the bible is the word of God, a sacred and holy book. It has wisdom that will never become outdated and will tell people what to do in everyday life. It is 4000years old and the worlds all time best seller. Christians base their rites on the bible and think it should be listened to. I disagree because the bible is old and in that day they never had situations were a pregnant women wanted to have an abortion so how can the bible give advice on how to tackle a way around on not having an abortion. Many believe that Christians should keep their opinions to themselves because they brainwash people in to believing the one thing. However pro life groups believe Christian do not brainwash people, but educate them. Christians speak for those who cannot speak for themselves such as the unborn child and terminally ill. I agree because the unborn child doesnt have the chance to make the decision to live. Many people believe Christians should be listened to because they make the world a better place. They say that Christians do this because it is right not because they will receive a reward on earth. I agree but I think some issues Christians tell our not the right way for instance in South Africa some women suffer from aids because of Christians saying they cant use artificial contraceptive to stop getting aids so women and children die, which is not the right way so Christians should allow artificial contraceptives.

20 Things to Put on Your Bucket List

20 Things to Put on Your Bucket List The end of the year provides a great opportunity for reflection, and in my quarterly business planning day with ActionCOACH in Madison, we did a lot of reflecting. I looked at my experiences, both personal and professional, over the past year, and what the impact has been on who I am. I examined what would need to change about myself to accomplish the things I didn’t accomplish. And I celebrated the accomplishments I did achieve. I wrote a gratitude list that included everything from fennel soup to yoga to the amazing people in my life- friends, family, and clients. Finally, I wrote down some of the things on my â€Å"bucket list†Ã¢â‚¬â€œ the proverbial list of things to do before I â€Å"kick the bucket.† On that list were things like traveling to Japan and Seattle, swimming with dolphins, being a Big Sister, and writing my Life and Leadership book. I also want one of those cool Apple Series 3 watches that counts my swim strokes for me. These items speak to my desire to be adventurous, make a difference for someone, and be at the top of my fitness game. They are more than activities and things; they are about who I want to be. This week, as we approach the last stretch of 2017, I invite you to look into the future, toward the things that you want to be part of your ideal life and the ideal you in the future. Below are some categories offered by ActionCOACH that might spark some ideas – and some that I added. See if you can list something in every category. For the purposes of the exercise, don’t worry about money or practicality. Put your skeptic aside and go wild! Celeste Chua, the author of Bucket List Ideas: 101 Things To Do Before You Die, suggests that you come up with 101 things for your bucket list. That’s a lot of things, but they sure will be a lot of fun to check off! And the exercise is completely free! 20 Questions to Generate Your Bucket List Meet someone you admire Have a particular conversation Achieve something you want to achieve Reach a physical fitness goal Buy or acquire a special item Give a gift Embark on an ultimate challenge Conquer a fear Perform kind acts for others Express your creativity Learn something new or improve a skill Leave a legacy Do something silly/idiotic/ridiculous/crazy fun! Satisfy a curiosity Travel somewhere you’ve always wanted to travel Live somewhere you’ve always wanted to live Go on an adventure with your family or friends Witness a special moment Work in a particular job or field Start a business If you’re stuck, maybe one of these lists could help spark some ideas: Bucket List Journeys Bucket List Goals Celestine Chuas Bucket List Ideas: 101 Things To Do Before You Die As you think about your answers, consider the meaning the activity or thing has for you. Who would you become by attaining or doing it? And/or who would you have to become in order to attain or do it? If you’re willing, please share a couple of things that are on your bucket list and what those things mean to you. Let’s get this conversation going! If you find that going back to school or embarking on a new career pursuit make your bucket list, I would be happy to help you present your best self with MBA admissions help, a custom resume, or LinkedIn profile writing.

3 Examples of How Missing Words Cause Confusion

3 Examples of How Missing Words Cause Confusion 3 Examples of How Missing Words Cause Confusion 3 Examples of How Missing Words Cause Confusion By Mark Nichol In each of the following sentences, the absence of a word or phrase is an obstacle to clarity. Discussion after each sentence explains the problem, and a revision provides the solution. 1. The naturally occurring electrolytes are significantly higher than other brands. The comparison in this sentence is not between electrolytes and other brands; it is between electrolytes in a product marketed under one brand and electrolytes in a product marketed under other brands. This revision uses a pronoun and a preposition to communicate the true equivalency: â€Å"The naturally occurring electrolytes are significantly higher than those in other brands.† 2. The contraception app has become a popular alternative because it doesn’t involve taking any medicines, inserting devices, or hormone patches. Three older contraceptive methods are listed in counterpoint to a newer one, but while the sentence structure requires a verb to precede the word or phrase for each method, â€Å"hormone patches† lacks one. This revision inserts a verb: â€Å"The contraception app has become a popular alternative because it doesn’t involve taking any medicines, inserting devices, or using hormone patches.† 3. Financial institutions are no longer required to implement the rule and retain the option of including mandatory arbitration clauses in their contracts. This sentence is structured as if it consists of a single main clause, but logic requires that it be constructed of two independent clauses. It reads as if â€Å"implement the rule† and â€Å"retain the option . . .† are equivalent, but the complementary phrases are â€Å"are no longer required to implement the rule† and the entire portion of the sentence following the conjunction, so a noun or pronoun must be inserted after the conjunction (along with a comma before it) to form the second independent clause: â€Å"Financial institutions are no longer required to implement the rule, and they retain the option of including mandatory arbitration clauses in their contracts.† Want to improve your English in five minutes a day? Get a subscription and start receiving our writing tips and exercises daily! Keep learning! Browse the Grammar category, check our popular posts, or choose a related post below:"Latter," not "Ladder"25 Idioms with Clean

Obesity Epidemic in America Research Paper Example | Topics and Well Written Essays - 3500 words

Obesity Epidemic in America - Research Paper Example Obesity is considered a major health risk factor in different diseases, especially those related to cardiovascular illnesses (WHO, 2011). These diseases are a major cause of concern because they often lead to high morbidity and mortality rates. The global rates of obesity are fast increasing; people around the world are getting more and more obese. The WHO reveals that by the year 2015, there will be about 2.3 billion overweight adults in the world and about 700 million of these would likely be obese (BBC News, 2008). This problem is considered a contemporary problem because obesity statistics were not even known to exist 50 years ago. This increase has mostly been attributed to the prevalence of convenience foods and labor saving devices which have driven many individuals to high fat diets and sedentary lifestyles. It is also a major issue among children with about 20 million children under the age of 5 being overweight (BBC News, 2008). Since the 1980s, the rates for obesity grew t o extensive levels and in OECD nations, one in 2 adults was considered overweight; 1 in 6 was considered obese (Robb, 2010). This rate is expected to increase by 1% each year for the next 10 years in some nations. These rates are highest in the United States, Mexico, and are lowest in Japan and Korea; everywhere else, the numbers are increasing (Robb, 2010). One in three children of the world is considered overweight. They are exposed to risks associated with obesity including a reduction of 8-10 years in their expected life span – this is similar to smokers. They are also likely to develop diseases like diabetes, cardiovascular diseases, and cancer (Robb, 2010). Obesity is also a burden to the health care system and expenditure because the expenditure among these patients is at least 25% higher than for those with normal weight. In the US, childhood obesity is a major problem and if this issue is not somehow resolved within the next few years, these children would likely suf fer major weight-related diseases much earlier than expected. Considering the above scenario, this paper shall now discuss the obesity epidemic in the United States. It shall discuss the causes of obesity in America, the effects and health issues related to obesity, the current health programs being implemented to address the obesity issue, and the effectiveness of these health programs. This paper shall also come up with recommendations in order to address this growing problem. Body/Discussion Causes of obesity in America There are various causes of obesity in the United States. Experts have weighed in on this discussion and they have acknowledged that the main causes of obesity are the amount, the quality of food intake, and the sedentary living of Americans. The volume of food that the average American is taking seems to have increased during the past few years and the quality of these foods have also shifted to high-fat, high salt, and high-caloric content foods (Goodman, 2006). The fact that Americans have reduced their physical activities is also a major contributory factor to obesity. The portions in the food servings in the US have grown significantly in the past decade or so – especially the portions which are eaten away from home which mostly include fast foods from various food chains. The trends in the US have included the value menus which sell food items, like burgers and fries for lower prices but at lower costs (American Heart Association, n.d). These portions

How music affect the brain Research Paper Example | Topics and Well Written Essays - 1750 words

How music affect the brain - Research Paper Example The pitch and rhythm of music are primarily the functions of left brain hemisphere, whereas melody and timbre are mostly processed in the right hemisphere of the brain. The processing of meter takes place in both hemispheres of brain. The spatial-temporal tasks are located in the very brain areas which are stimulated by music. Such spatial-temporal tasks include spatial reasoning required to build structures, and physical objects’ 2-D and 3-D manipulation. Music stimulates the brain areas that are related to spatial reasoning. While this effect usually is only 15 minutes long after the end of music (â€Å"How Music Affects†). The spatial reasoning of an individual is markedly increased while listening to music. Brain’s response to music Music constitutes fragile timing violations. Experience suggests the listeners that music is not threatening. The frontal lobes ultimately identify these violations as a source of pleasure. As a result of this expectation, anticip ation is developed that when met, helps develop the reward reaction. A fundamental characteristic feature of music that differentiates it from other stimuli is its ability to conjure up feelings and images which might not necessarily reflect in the memory directly. A certain kind of mystery still remains in the overall phenomena; the factors explaining the thrill of listening to music are integrally linked with synesthesia based theories. The brain of a new born baby has not differentiated its structure into components meant for the identification and appreciation of various senses. It takes time for the brain to develop this differentiation. As the theory suggests, babies perceive the world as â€Å"a large, pulsing combination of colors and sounds and feelings, all melded into one... The "How music affects the brain" essay outlines how the brain understands and processes it. Music constitutes fragile timing violations. Experience suggests the listeners that music is not threatening. The frontal lobes ultimately identify these violations as a source of pleasure. As a result of this expectation, anticipation is developed that when met, helps develop the reward reaction. A fundamental characteristic feature of music that differentiates it from other stimuli is its ability to conjure up feelings and images which might not necessarily reflect in the memory directly. A certain kind of mystery still remains in the overall phenomena; the factors explaining the thrill of listening to music are integrally linked with synesthesia based theories. The brain of a new born baby has not differentiated its structure into components meant for the identification and appreciation of various senses. It takes time for the brain to develop this differentiation. As the theory suggests, babies perceive the world as â€Å"a large, pulsing combination of colors and sounds and feelings, all melded into one experience – ultimate synesthesia† (Mohana). Different areas of the brain become specialized in the different senses with the development of brain over the passage of time. â€Å"After a year of training, the kids who have been in the music training are better able to synchronize to the beat and to remember the beat† (Kraus cited in Wise). Music improves intelligence, learning, cognition, and motor skills.

Business Taxation. See uploaded guidlines Essay

Business Taxation. See uploaded guidlines - Essay Example Research and development (R&D) tax credits are a company tax relief which can either reduce a company’s tax bill or, for some small or medium sized companies, provide a cash sum’. Through a different definition it is noticed that ‘Research and development tax credits are a company tax relief which can either reduce a company’s tax bill or, for some small or medium sized companies, provide a cash sum; the R&D tax credit works by allowing companies to deduct up to 150% of qualifying expenditure on R&D activities when calculating their profit for tax purposes’ (The Small Business Portal, 2006). It should be noticed that the above scheme can lead to the benefits stated above only if specific terms and requirements are met (as it will be explained below). The benefits offered by this scheme to firms across the country can be differentiated. Specifically for small businesses it is noticed by the UK HM Revenue and Customs that the particular scheme can lead to a reduction of the tax bill up to a percentage of 15%. On the other hand, it is also supported that ‘some SME companies not in profit can surrender their R&D tax losses for cash (in the form of a payable credit) of up to 24p per  £1 of actual expenditure within specified categories’ (UK, HM Revenue and Customs, Small Businesses). The level of the benefit can reach up to a 100% of capital allowances for small firms that make a relevant capital expenditure. In order to understand the benefits offered for small businesses in UK under the particular scheme it is necessary to refer primarily to the definition of R&D scheme at least regarding its general characteristics. In this context, it is noticed that ‘broadly, in order to qualify, activities must be creative or innovative work in the fields of science or technology and undertaken with a view to the extension of knowledge and breaking new ground, whether that be through resolving some uncertainty or creating a new or substantially improved

Roman Catholics in Alaska Research Paper Example | Topics and Well Written Essays - 500 words

Roman Catholics in Alaska - Research Paper Example Today, Russian Orthodox Christianity claims over 20,000 followers and over 46 congregations. In addition to Russian Orthodox, general Roman Catholicism represents over 50,000 individuals, with over sixty-eight congregations (‘Alaska Religions’). Remaining within the Christian understanding of religions, other major groups include the Latter-Day Saints, the Assembly of God, and the Episcopalians. While Christianity represents the dominant religion, just like the lower forty-eight states, the other monotheistic religions are prevalent throughout the state. In these regards, both Judaism and Islam have a minority contingent of followers. In terms of specific regional religions, the Thlingets have been demonstrated to exhibit particular spiritual elements specific to the state. In considering the Thlingets, it’s been noted that, â€Å"men naturally grope after the Supreme Being, ‘if haply they may find Him.’ The Thlingets of Alaska are no exception to th e rule† and in speaking about Alaskan natives, â€Å"religion has been and is yet a great factor in their lives† (Jones, pg. 231).

Critical review Article Example | Topics and Well Written Essays - 500 words

Critical review - Article Example The Hofstadter dimensions of culture can be used to analyses relationships across various studies, countries, and different continents (Samaha, 2014, pg, 83). For purposes of future theory, there is a need for four tenets that analyze the essence of culture impact on relationship marketing.42, 378 relationships were used in 144 studies where the continents were six across 29 countries. With the research, the method used in the first study the evidence showed that in support of the tenets that there is the importance of a variety of different cultures were it always varies. This can be explained where individualism and collectivism had effects in 114%- 169% that had an impact that was greater in RM than other cultural situations (Theodosiou,2013, pg 73). Masculinity to femininity had no effect on RM.The second research method of analysis uses the country and regional level approach to establish RM effects when it comes to performance especially out of United States.17%,15%,38% and 55% the RM was seen to be more effective in Brazil, Russia, India and China. This indicates that RM plays a primary role in mist developing countries of BRIC (Sium, 2013, pg 524). Cultural customization is required to establish and build customer relationships that are considered as effective strategies. The model used predicts there is a 150% dependency that builds strong relationships especially in Russia than other countries like United States. Relationship investments were 58% less in Russia was less effective than in USA. The second research method of country to regional approach established that culture influences greatly relationship construction rather than relationship outcomes. In business, a manager may analyze the efficiency of relationship marketing from objective performance outcomes in the countries or regions and may place more

EGBC report Essay Example | Topics and Well Written Essays - 1250 words

EGBC report - Essay Example Researches and extensive studies have shown a direct linkage between energy and population growth. Due to this reason, Egyptian government and other officials have decided to look for different ways which can reduce the GHG emission and power consumption. For the accomplishment of this goal, developing energy efficient building is the first step in identifying the alternative methods of efficient energy. There have been many proposals forwarded for improved performance but manpower and interest is absent here. Many people are experiencing this dilemma however some other people are looking for alternative systems in order to deal with this issue and increase awareness to other people about its importance. In subsequent paragraphs, there are some initiatives taken for the bridging the gap between code compliance and code design. In 2009, a major step was taken by Egyptian government in establishing Egyptian Green Building Council-EGBC. There are many international and national personalities who have become member of this council; they include NGO officers, government officials, ministers, labour leaders, contractors and prominent businessman. The objective of developing this council is to satisfy environmental conservations and energy efficiency by providing opportunities to investors to adopt BEECs and other existing codes. The purpose of focusing on new constructions is that by focusing on it, EGBC can utilize its leverage as an organization to persuade and educate builders, engineers, owners and contractors about the advantages of establishing green constructions on people, community and most significantly, to the nation. In this way, green construction can be a required objective for buildings, construction work and other projects as energy efficiency codes would be tools, material and road map to attai n that desired objective. The imperative motivation is to eradicate the clichà ©d perspectives related to the green

Critical review Article Example | Topics and Well Written Essays - 500 words

Critical review - Article Example The Hofstadter dimensions of culture can be used to analyses relationships across various studies, countries, and different continents (Samaha, 2014, pg, 83). For purposes of future theory, there is a need for four tenets that analyze the essence of culture impact on relationship marketing.42, 378 relationships were used in 144 studies where the continents were six across 29 countries. With the research, the method used in the first study the evidence showed that in support of the tenets that there is the importance of a variety of different cultures were it always varies. This can be explained where individualism and collectivism had effects in 114%- 169% that had an impact that was greater in RM than other cultural situations (Theodosiou,2013, pg 73). Masculinity to femininity had no effect on RM.The second research method of analysis uses the country and regional level approach to establish RM effects when it comes to performance especially out of United States.17%,15%,38% and 55% the RM was seen to be more effective in Brazil, Russia, India and China. This indicates that RM plays a primary role in mist developing countries of BRIC (Sium, 2013, pg 524). Cultural customization is required to establish and build customer relationships that are considered as effective strategies. The model used predicts there is a 150% dependency that builds strong relationships especially in Russia than other countries like United States. Relationship investments were 58% less in Russia was less effective than in USA. The second research method of country to regional approach established that culture influences greatly relationship construction rather than relationship outcomes. In business, a manager may analyze the efficiency of relationship marketing from objective performance outcomes in the countries or regions and may place more

Coca Cola Case Study Example | Topics and Well Written Essays - 5000 words

Coca Cola - Case Study Example The overall market of soft drinks in Australia has experienced a slow but steady growth rate. Key players in the market try as much as possible to amass the market power by acquiring other similar companies in the industry. However, concentration and other market activities in Australia are regulated by The Australian Competition and Consumer Commission. The competition in non-alcoholic market in Australia is stiff and it is difficult for Coca Cola Amatil to increase its market share beyond 75 percent. The greatest business rivalry of the company is Schweppes, which is followed by P& N. The other major challenge facing the industry include dietary issues, which has made most health conscious consumers switch to other products to avoid consumption of the carbonated soft drinks. According to SWOT analysis proper advertising, effective and efficient distribution lines as well as competent sales force are key to success in the soft drinks market. The company requires an extra AU$42 milli on to finance the marketing plan. The money will be obtained from the retained earnings. Table of Contents Table of Contents 2 2.2 Consumer trends 5 3.0 Marketing objectives 15 4.0 Marketing strategies 16 5.3 Monitoring, evaluation and control 19 7.0 References 21 8.0 Appendix 23 1.0 Introduction Coca-Cola Amatil is one of the dominant market players in the Australian soft drinks market. ... David Gonski.The products that are produced and distributed by Coca-Cola Amatil include Coca-Cola, Diet Coke, Coke Zero, Sprite, Sprite Zero, Fanta, Lift, Deep Spring mineral waters, Mother, Appletiser, Grapetiser, Kirks soft drinks, Mount Franklin bottled water, Pump bottled water, Vitamin Water, Powerade, Nestea, Neverfail water coolers, Goulburn Valley juices, Fruit Box, Grinder's Coffee and SPC Ardmona. The Australian beverage company faces stiff rivalry from Schweppes and other smaller players. Coca-Cola sales are driven by economic factors such as pricing, long-term trends, brand loyalty and awareness and seasonality 2.0 Situation Analysis The Australian Coca-Cola Amatil is a company that has distinguished itself as a market leader over the years in the beverage industry of Australia. 2.1 Industry trends Soft drink refers to a non- alcoholic drink whose main ingredient is water. Most soft drinks are sweetened and carbonated. In addition, some have vitamin or higher energy (ener gy drinks) additives. The retail environment of soft drinks is strengthening and major players are introducing new products. The new products are made for consumers who are health conscious and who need convenient beverages. Fraser (2010) revealed that carbonated drinks take over 56 market share of non-alcoholic drinks, bottled water takes 25 percent, the sports drinks takes about 19 percent and the remainder is taken by juice and energy drinks. The soft drink industry in Australia has experienced relatively steady and moderate growth rate in the last five years of about 1 percent per annual. However, the sale of carbonated soft drinks is declining because majority of health-conscious consumers are moving away from high-calorie and sugary beverages to fruit juices, water and non-carbonated

Foreign Literature Essay Example for Free

Foreign Literature Essay Last night I was at the presentation of the Independent Foreign Fiction Prize, at the National Portrait Gallery, where a young Angolan writer, Josà © Eduardo Agualusa, was announced the 2007 winner for his novel The Book of Chameleons, translated from the Portuguese by Daniel Hahn. Set in contemporary Angola, the book is particularly notable for being narrated by a lizard. The judges this year were the poet David Constantine, writer and editor Jennie Erdal, Arts Council Literature officer Kate Griffin, novelist Ali Smith and the literary editor of the Independent, Boyd Tonkin. Admirably the prize is shared between the translator and author, thus honouring an art that often goes unsung. The book was evidently a popular choice and Agualusa received his award in person, accompanied by whoops and cheers. Tonkin extols the prize as a unique bridge between writers abroad and readers at home. As thrilled as I was that this talented newcomer beat such literary heavyweights as Ismail Kadare and Javier Marà ­as, however, I was even more delighted that the award honours a small literary publisher, Arcadia, who recently celebrated their 10th anniversary. The dedicated team at Arcadia are worthy recipients of this prestigious award, not just for bringing this imaginative young writer to an English readership, but overall for their championing of cultural diversity and for widening our literary choice 50% of their 2007 lists are books in translation. Given the effects of globalisation elsewhere, it seems astonishing that we dont translate more foreign literature in this country. Apparently, translated fiction accounts for only 3% of fiction sales in the UK, compared with 30-40% in France or Spain. The British are voracious readers, so why are we so insular? Dont we welcome unusual voices and different perspectives? How can we exert pressure on publishers to produce more translated fiction? For those interested in foreign literature, an excellent resource is Words Without Borders, an online magazine dedicated to promoting international exchange through translation and publishing works/extracts on the web. And if youd like to see Josà © Eduardo Agualusa and Daniel Hahn, theyll be reading from The Book of Chameleons this evening at Foyles bookshop, London, 6.30pm 8.30pm.

Civil Liberties Essay -- essays research papers

As Benjamin Franklin once said â€Å"A people who would trade liberty for security deserve neither†. I totally agree in that we as the people of the United States should not ask for greater safety at the price of liberty. I feel that the government does not have the power to limit our First Amendment rights. The people of this country hold the power and politicians are merely their puppets. These leaders can ask for all kinds of authority during a time like this but all it would take is a string backlash from the public for them to back down. What is it about a time like this that renders these rights so unnecessary? People fought incredibly hard and gave their lives for these standards and for us to discard them at a time like this is disgraceful.   Ã‚  Ã‚  Ã‚  Ã‚  These rights w...

Response to Bell Hooks Keeping Close to Home :: Family Values College

Strong Family Values In Bell Hooks’s essay, "Keeping Close to Home," she suggests that the American educational system forces students to hide, change, or mask the values that they have when they first enter college. While this might be true for some students, this line of thinking does not hold true for me personally. I do not agree with her assertion for, and I have not changed since entering the University of Georgia. The University of Georgia has not placed any pressure on me to change my values due to the fact that I had very strong values when I entered the University, and those same values hold true to me today. The values that I learned from my parents as an infant, child, adolescent, and, most recently, as an adult, are continually enforced and taught to me today. It is because of this strong family support that I have stayed the same as I was before entering college. My family has always preached strong family values that will be with me for the rest of my life, and will be passed on to my children and grandchildren. Some of the family values that I have learned from my family are to always respect my elders and to have good manners no matter what. I believe that values are taught and learned at an early age. If the teaching is successful, as it was in my case, the student should hold true to the values that he or she was raised with. Everybody is raised with different values, whether the difference is religious, moral, or social, and they should all be respected by others. I will not change or alter my values because they are very important to both my family and me, and I firmly believe in them. There are many different types of people on the University of Georgia campus, whether they come from the same or different background than I. There are people of different skin color, religion, ethnicity, and many other different backgrounds. Therefore, there are also many different beliefs in faith and values. At an institution of higher learning, such as the University of Georgia, there is respect for and interest in other people’s beliefs. There is never a push to "change" someone. Some students might alter their beliefs and values, but as for myself I will learn of others, but never change.

Shild’s outcome Essay

The connection between the parent’s status and the child’s well being is frequently argued. Some of the studies in the past have shown that children brought up by two married parents tend to grown better than the others (Sigle-Rushton, Wendy and McLanahan). In most of these studies, the results have been derived by comparing the family structure of single parent and both biological parents. Another aspect of the association of family structure with child’s welfare it the type of relation between the parents. The children having parents with mutual dispute are more likely to have behavioral and psychological problems (Amato and Sobolewski). Therefore while considering the question, ‘are two parents better than one? ’ a fact becomes very clear that the family definitely has an influence on the child’s outcome, well-being and future development. A couple or two parents raising a child have varying advantages. With two parents a lot of responsibilities can be distributed, which prevents the development of massive pressure on one single parent. This is especially useful in case of working parents, who can distribute their office hours in such a way that at any time one of the parents is present with the child. Along with this there is also an economic factor associated with it. With two working parents the child is expected to have a better childhood, with larger number of necessities and luxuries being made available to the child. Along with having larger parental time, attention and emotional support, the two parent children also have advantage of economic security. Apart from the above factors, two parents provide a stable environment to the children. The children parented by two parents have the love and emotional support from both the parents. These children are free from parenting tensions due to distribution of the stress among the parents. This way the children are not subjected to the parent’s tension at an early stage of their life. Therefore they can enjoy their childhood to a better extent than other children. The parents under marital dispute are the only disadvantage of the two parents raising a child. It has been studied that the children growing up with parents under marital dispute grow up with behavioral problems, less education and lower occupational status (Mitchell). But an important point to consider here is that most of the marriages that end in divorces are low-conflicts. Most of the divorces are mutual and seen as a positive step from both the parents and are taken healthily by the children. In case of single parenting or disrupted families the disadvantages are much higher. According to Paul Amato, Professor of Sociology at Pennsylvania State University, â€Å"Specifically, compared with children who grew up in stable, two-parent families children born outside marriage reach adulthood with less education, earn less income, have lower occupational status, are more likely to be idle (that is , not employed and not in school), are more likely to have a non-marital birth (among daughters) have more troubled marriages, experience higher rates of divorce and report more symptoms of depression† (Mitchell). Single parenting creates a lot of pressure both in emotional as well as financial sense, which might lead to a depression or insecurity in the child. The parent is sometimes not able to fulfill the requirements of the child due to such financial crisis. These may include some necessities like good quality education, a home with a social neighborhood and other essential items. Of which the quality of education has a huge impact on the personality of a child. Children going to better schools have more social company and this exhibit lesser behavioral problems. The quality of parenting also has a vast impact on the social well-being of the children. Due to their own problems, which they are not freely able to express out, the parent are not always emotionally strong enough to support their children. These single parents can sometimes let-out their stress on the children, thus creating a negative impact on them. Such parents can also be a little harsh in terms of disciple. Another disadvantage is lack of availability of time. Single parents have to work harder for financial reason, which in turn increases the number of office hours. Such parents tend to have a hectic schedule and lesser time to spend with the children. They leave early in the morning and come back late at night, therefore practically spending no time with their children. The children in turn don’t feel enough attachment and start to develop a barrier with their parents. They start showing behavioral changes and start to get away from relationships. Single parenting is a tough and sensitive job. Delicate care has to be taken to ensure the well being of the child. Single parenting can only be successful if proper attention, love and affection are provided to the child. On the other hand it has been studied and statistically concluded by Paul Amato that â€Å"Compared with other children, those who grow up in stable, two-parent families have a higher standard of living, receive more effective co-parenting, are emotionally closer to both parents (especially fathers) and are subjected to fewer stressful events and circumstances (P. R. Amato). â€Å" Under normal circumstances, two parents are always better than one. Two parents parenting a child provide an emotional as well as financial support to both their spouse as well as their children. Such children are tension free in their childhood and have role models to live up to for the future. Therefore as far as possible the children must be brought up under the guidance of two parents for their happy and prosperous future. Works Cited Amato, P. R. and Sobolewski. â€Å"The effects of divorce and marital discord on adult children’s psychological well-being. † American Sociological Review (2001): 900-921. Amato, Paul R. â€Å"The impact of family formation change on the cognitive, social, and emotional well-being of the next generation. † The Future of Children Volume 15 No 2. CYC-Online, July 2007. Mitchell, Lindsay. Research Confirms Two Parents Better Than One. Media release. New Zealand: www. cyc-net. org/cyc-online/cycol-0707-amato. html , 2007. Sigle-Rushton, Wendy and Sara McLanahan. â€Å"Father absence and child wellbeing: a critical review. † The future of the family (2004): 116-155.

Key Factors of Consumer Behaviour Essay

1. Discuss and explain the key factors influencing consumer behaviour. Why must organisations understand consumer behaviour in order to optimise sales? â€Å"Marketing is the activity, set of institutions and processes for creating communicating, delivering, and exchanging offerings that have value for customers, clients, partners, and society at large† (AMA, 2007). â€Å"Consumer behaviour is the judgment of final consumers individuals and households who buy goods and services for personal consumption† (Kotler et al., 1999) There are four key factors influencing consumer behaviour. They are social, cultural, personal and psychological factors. Consumer may tends to change their buying behaviour according to these factors. Cultural factors are described as people who react particular way regard to religion reason. Different culture response differently, how people behave with their buying decision. for instance in Myanmar, majority of people do not have a habit of doing sport or using supplement for diet purposes. In United Kingdom, on the other hand, groups of men and women tend to emphasis on sport and taking supplement. As a supplement business prospective, they should not supply their product or sell in Myanmar. Social factors are mainly influenced by family, close friend and personal attitude. They are also known as ‘reference group’. Reference group are important as the product are satisfied for their needs, the message with forward to another person which is also known as â€Å"word of mouth†. The communication is powerful because we trust our friends’ and colleagues’ opinions. For example, majority of wealthy people do not buy a Primark product, simple because of their status, they should be buying much more expensive product such as Gucci and Chanel. If they do consumer Primark product their friend may talk behind their back which affect the status. After taking cultural and social factors into consideration, the next things people naturally put things into account is personal factors. personal factors can be defined as a belief in which a person think the particular brand is valued to them. Personal factors consists of buyer’s age, occupation, economic situation and lifestyle. Depending on human life cycle, buyers’ decision making is changing in different stages. Therefore, marketer often segment the market and target the consumer life stages. As an example, it is an inappropriate for the marketer to sell Samsung latest smart phone to senior citizen, they may only want to use simple keypad phone. In term of occupation, people are concerning about their status and image in their society. The products that they consume are crucial to his or her status. Psychological factors include belief, interest and motivation. Everyone has their own belief in different way. Often majority of people are bias when buying a particular brand. There is no right or wrong answer, in fact, people learnt from past experience whether the brand had met their needs or how they perceived the brand . For example, Iphone 5, more and more people are getting the new Iphone 5, not because it is very special. In fact Samsung s3, has better functionality than Iphone but still people buys it. This shows people value the brand of Apple and how they perceived the brand. Motivation factors are another factor that consumer think before they buy. According to Maslow theory, different people has different needs. So, marketer should know how to segment the market and target the right person to maximise sales. In summary, organisation should consider how consumer behave for certain product by looking at these four factors. furthermore, communicating with consumer are crucial to the market as they sent the message the consumer about the product’s feature. Therefore, marketer has to be segment the market and target the right consumer to deliver the message across.

Expansion of Islam during the Medieval Period Essay

The development of Islam in world history has resulted in major political, economic, and military ramifications, not only in the Islamic world, but also in the global community at that period. Only decades following the first recitations of the Qur’an by Prophet Muhammad, a vast empire of the Islam religion can be traced from the Atlantic Ocean going all the way to Central Asia in the east. Islam has expanded greatly indeed during the Medieval Era. This new global order has massive implications, and resulted into various wars, and states and governments fought with each other and outside forces. Despite counter-revolutions in the spread of the religion, Islam continued to gain ground in the vast regions of Africa, the India, and Southeast Asia. The Islamic civilization was indeed one of the most highly developed in the world during the Medieval Era, which was later on exceeded by the Europe empires with the economic and military growth of the West. The advancement of Islam during the Medieval period was great and notable, as the religion that is fairly young grew to be one of the most dominant world religions even today, with an estimated more than 1 billion follower, second only in size to Christianity. The preceding paragraphs shall be the historical account of this rise of the Islam religion. Islam religion: Brief Overview The Islamic tradition finds its origins from the teachings of their prophet Muhammad during the 7th Century. Consisting of more than a billion followers all over the world, Islam can be said to be the 2nd biggest of all the world religions. The most holy text of Islam is the Quran, which is believed to have been given to Muhammad by God, or Allah. This religion also recognizes Moses and Jesus as prophets, and regard their teachings as important, which would account for certain parallelisms with world religions such as Christianity. The Islamic life is basically guided by the Five Pillars, which prescribes certain aspects of life and forms their culture and traditions. Believing in a single God whom Muslims would call Allah, most of the Quranic teachings are even used as laws of states that have Islam as the state religion. Like Christianity, the teachings of Jesus are one viewed with high regard; but for Islam, Jesus is a prophet rather than God, hence they reject the Trinity concept. Muslims follow certain codes of conduct, like the daily requirement of praying for a number of times a day and a strict diet, like the refusal to ingest pork. The church of Islam is called the Mosque, wherein like all other religions, certain rituals are being conducted. The history in the medieval era: Rise of the caliphate (632–750) Before starting his move to Medina, where he migrated, Muhammad commenced his teaching of Islam at the holy city of Mecca, and achieved the goal of uniting the Arabian tribes of Arabia into a unified Arab Muslim religious polity. Following the death of Muhammad during the year of 632, there were rising conflicts in the Islamic community on who would succeed him as leader of the community. Nominated to obtain such position was Abu Bakr, who was one of the closest people and collaborator to Muhammad; his name was raised by Umar ibn al-Khattab, also Muhammad’s companion. Abu Bakr was then became the first â€Å"caliph†, as his leadership gained great support. Although his leadership walso experience some opposition who would support another person in the name of Ali ibn Abi Talib, is argued to be a designated successor. The avengement of a defeat in war by the Byzantine forces was made one of the first agenda, although the Ridda wars, or â€Å"Wars of Apostasy†, which was an Arab tribe rebellion, were the first acts of Abu Bakr. The territory of the Caliphate in 750 Umar succeeded as the caliph, when Abu Bakr passed away in the year 634, which was then followed respectively by Uthman ibn al-Affan and Ali ibn Abi Talib, and these first four leaders where dubbed as the al-khulafa’ ar-rashidun or Rightly Guided Caliphs. Under their collective leadership, the Islamic territory saw continual expansion into Persian and Byzantine empires. When Umar was assassinated in 644, the election of Uthman as successor was met with increasing opposition. In 656, Uthman was also killed, and Ali assumed the position of caliph. After fighting off opposition in the first civil war (the â€Å"First Fitna†), Ali was assassinated by Kharijites in 661. Following this, Mu’awiyah, who was governor of Levant, seized power and began the Umayyad dynasty. These disputes over religious and political leadership would give rise to schism in the Muslim community. The majority accepted the legitimacy of the three rulers prior to Ali, and became known as Sunnis. A minority disagreed, and believed that Ali was the only rightful successor; they became known as the Shi’a. After Mu’awiyah’s death in 680, conflict over succession broke out again in a civil war known as the â€Å"Second Fitna†. Afterward, the Umayyad dynasty prevailed for seventy years, and was able to conquer the Maghrib and Al-Andalus (the Iberian Peninsula, former Visigothic Hispania) and the Narbonnese Gaul} in the west as well as expand Muslim territory into Sindh and the fringes of Central Asia. While the Muslim-Arab elite engaged in conquest, some devout Muslims began to question the piety of indulgence in a worldly life, emphasizing rather poverty, humility and avoidance of sin based on renunciation of bodily desires. Devout Muslim ascetic exemplars such as Hasan al-Basri would inspire a movement that would evolve into Sufism. For the Umayyad aristocracy, Islam was viewed as a religion for Arabs only; the economy of the Umayyad empire was based on the assumption that a majority of non-Muslims (Dhimmis) would pay taxes to the minority of Muslim Arabs. A non-Arab who wanted to convert to Islam was supposed to first become a client of an Arab tribe. Even after conversion, these new Muslims (mawali) did not achieve social and economic equality with the Arabs. The descendants of Muhammad’s uncle Abbas ibn Abd al-Muttalib rallied discontented mawali, poor Arabs, and some Shi’a against the Umayyads and overthrew them with the help of their propagandist and general Abu Muslim, inaugurating the Abbasid dynasty in 750. Under the Abbasids, Islamic civilization flourished in the â€Å"Islamic Golden Age†, with its capital at the cosmopolitan city of Baghdad. The Islamic Golden Age (750–1258) By the late 9th century, the Abbasid caliphate began to fracture as various regions gained increasing levels of autonomy. Across North Africa, Persia, and Central Asia emirates formed as provinces broke away. The monolithic Arab empire gave way to a more religiously homogenized Muslim world where the Shia Fatimids contested even the religious authority of the caliphate. By 1055 the Seljuq Turks had eliminated the Abbasids as a military power, nevertheless they continued to respect the caliph’s titular authority. During this time expansion of the Muslim world continued, by both conquest and peaceful proselytism even as both Islam and Muslim trade networks were extending into sub-Saharan West Africa, Central Asia, Volga Bulgaria and the Malay archipelago. The Golden Age saw new legal, philosophical, and religious developments. The major hadith collections were compiled and the four modern Sunni Madh’habs were established. Islamic law was advanced greatly by the efforts of the early 9th century jurist al-Shafi’i; he codified a method to establish the reliability of hadith, a topic which had been a locus of dispute among Islamic scholars. Philosophers Ibn Sina (Avicenna) and Al-Farabi sought to incorporate Greek principles into Islamic theology, while others like the 11th century theologian Abu Hamid al-Ghazzali argued against them and ultimately prevailed. Finally, Sufism and Shi’ism both underwent major changes in the 9th century. Sufism became a full-fledged movement that had moved towards mysticism and away from its ascetic roots, while Shi’ism split due to disagreements over the succession of Imams. The spread of the Islamic dominion induced hostility among medieval ecclesiastical Christian authors who saw Islam as an adversary in the light of the large numbers of new Muslim converts. This opposition resulted in polemical treatises which depicted Islam as the religion of the antichrist and of Muslims as libidinous and subhuman. In the medieval period, a few Arab philosophers like the poet Al-Ma’arri adopted a critical approach to Islam, and the Jewish philosopher Maimonides contrasted Islamic views of morality to Jewish views that he himself elaborated. Starting in the 9th century, Muslim conquests in the West began to be reversed. The Reconquista was launched against Muslim principalities in Iberia, and Muslim Italian possessions were lost to the Normans. From the 11th century onwards alliances of European Christian kingdoms mobilized to launch a series of wars known as the Crusades, bringing the Muslim world into conflict with Christendom. Initially successful in their goal of taking the Holy land, and establishing the Crusader states, Crusader gains in the Holy Land were later reversed by subsequent Muslim generals such as Saladin; who recaptured Jerusalem during the Second Crusade. In the east the Mongol Empire put an end to the Abbassid dynasty at the Battle of Baghdad in 1258, as they overran in Muslim lands in a series of invasions. Meanwhile in Egypt, the slave-soldier Mamluks took control in an uprising in 1250 and in alliance with the Golden Horde were able halt the Mongol armies at the Battle of Ain Jalut. Mongol rule extended across the breadth of almost all Muslim lands in Asia and Islam was temporarily replaced by Buddhism as the official religion of the land. Over the next century the Mongol Khanates converted to Islam and this religious and cultural absorption ushered in a new age of Mongol-Islamic synthesis that shaped the further spread of Islam in central Asia and the Indian subcontinent. Ottomans and Islamic empires in India (1258–1918) The Seljuk Turks conquered Abbassid lands and adopted Islam and become the de facto rulers of the caliphate. They captured Anatolia by defeating the Byzantines at the Battle of Manzikert, thereby precipitating the call for Crusades. They however fell apart rapidly in the second half of the 12th century giving rise to various semi-autonomous Turkic dynasties. In the 13th and 14th centuries the Ottoman empire (named after Osman I) emerged from among these â€Å"Ghazi emirates† and established itself after a string of conquests that included the Balkans, parts of Greece, and western Anatolia. In 1453 under Mehmed II the Ottomans laid siege to Constantinople, the capital of Byzantium. The Byzantine fortress succumbed shortly thereafter, having been battered by superior Ottoman cannonry. Beginning in the 13th century, Sufism underwent a transformation, largely as a result of the efforts of al-Ghazzali to legitimize and reorganize the movement. He developed the model of the Sufi order—a community of spiritual teachers and students. Also of importance to Sufism was the creation of the Masnavi, a collection of mystical poetry by the 13th century Persian poet Rumi. The Masnavi had a profound influence on the development of Sufi religious thought; to many Sufis it is second in importance only to the Qur’an. In the early 16th century, the Shi’ite Safavid dynasty assumed control in Persia and established Shi’a Islam as an official religion there, and despite periodic setbacks, the Safavids remained powerful for two centuries. Meanwhile, Mamluk Egypt fell to the Ottomans in 1517, who then launched a European campaign which reached as far as the gates of Vienna in 1529. After the invasion of Persia, and sack of Baghdad by the Mongols in 1258, Delhi became the most important cultural centre of the Muslim east. Many Islamic dynasties ruled parts of the Indian subcontinent starting from the 12th century. The prominent ones include the Delhi Sultanate (1206–1526) and the Mughal empire (1526–1857). These empires helped in the spread of Islam in South Asia. but by the mid-18th century the British empire had ended the Mughal dynasty. In the 18th century the Wahhabi movement took hold in Saudi Arabia. Founded by the preacher Ibn Abd al-Wahhab, Wahhabism is a fundamentalist ideology that condemns practices like Sufism and the veneration of saints as un-Islamic. By the 17th and 18th centuries, despite attempts at modernization, the Ottoman empire had begun to feel threatened by European economic and military advantages. In the 19th century, the rise of nationalism resulted in Greece declaring and winning independence in 1829, with several Balkan states following suit after the Ottomans suffered defeat in the Russo-Turkish War of 1877–1878. The Ottoman era came to a close at the end of World War I. Conclusion The history of the Islamic religion during the medieval era is great and dynamic indeed, as the rise into global prominence could be noted to be a magnificent and unprecedented event in world history. Truly, the historical struggle of Islam is one that has witnessed countless conflicts and eventually successes. Even today, even as the religion has not regained the glory of the Golden Ages, it remains to be one of the most dominant world religions in our global community, as billions of followers continue to adhere to the teachings of their prophet Mohammad.

Discussion question Essay Example | Topics and Well Written Essays - 500 words - 7

Discussion question - Essay Example While this is true however, education does not necessarily translate into economic growth of a country, it is only a single factor to the various reasons for economic growth. Education has faced a significant expansion in the last decades across the world, with countries registering double-digit growth patterns. In the 1990s, the world, according to Easterly (73), had 99 percent enrollment for primary education. Education investment has brought little or no impact in the world economy and especially for the countries themselves. Growth of human capital in a country does not necessarily mean that their contribution to the growth of a country. If the argument that education brings growth to a country, fresh graduates should be entitled to higher salaries than experienced workers should. However, salary increment is based on the years of experience, making this belief to be untrue. In fact, Easterner (77) is of the opinion that, the contribution of education growth and growth of a worker’s output is negligible, stating that in some African countries, this growth is actually negative. The Gross Domestic Product per worker in is just a small percentage in most Eastern Europe and the Soviet Union countries. With time, the median growth rate of poor countries in the world has kept a declining trend overtime, indicating a poor education contribution to growth, yet education received a massive growth. Due to in direct effects of human capital, countries with higher initial human capital are likely to have a faster growth than those with low initial human capital.in case the level of human capital and physical capital are both high, there will be high returns on physical capital investment until there is a balance between the two(76-77). In all nations worldwide, variations in the country’s growth have little contributions from variations in growth of the human capital, rising more serious concerns regarding initial schooling and

LEADERSHIP AND CHANGE MANAGEMENT Essay Example | Topics and Well Written Essays - 2750 words

LEADERSHIP AND CHANGE MANAGEMENT - Essay Example In order to meet the new business situation, the company had to implement many changes. This paper investigates the change that has taken place in SMC since the acquisition. The research provides company’s profile and its history as a basis for further investigation on the influence of the acquisition and a new parent Sinosteel Corporation (Sinosteel) on the Midwest Corporations. The purpose of this study was to research and critically examine the change process in SMC, analyze the impact of the change on employees and on the company as a whole. Some critical review and recommendations are based on the leadership knowledge. The methodology of the study implies a review of related academic journals that helped to examine the company’s changing process. A questionnaire was filled in by SMC employees to provide the researcher with a clear picture of how in particular the change was implemented. A list of key questions will be made for interviewing a SMC decision-making exe cutives was based on the data collected from the questionnaires and conceptual framework from the journals. 2. Introduction and Objectives The purpose of the study was to review and critically analyze the changing process that took place in Sinosteel Midwest Corporation. Before the acquisition the company was operated by its founder and several major shareholders, as top executives and broad members. Most of these executives (i.e. broad members) left the company having sold their shares to Sinosteel, the company’s current owner. The major objectives of the company were changed too. Previously, the main goal of Midwest was looking for strategic investors (business partners) to finance the company’s iron ore projects development. Midwest was then supposed to use its revenue from selling iron ore to pay back to the investors. To change the situation, Sinosteel, as one of the biggest Chinese iron ore traders, does have an ability to finance the project development and, at the same time, provides a big demand for SMC’s iron ore. Since financing is not a problem anymore, SMC’s core business has changed to work more efficiently on the development of iron ore projects. A serial of change from business strategy to organizational structure have been made to meet the new situation and new requirement. Therefore, this study has explored how the SMC’s management team designed its new strategy and new structure for them to correspond to the new conditions the company works in after the acquisition. The research also examines how the change implementing process was leaded by a new Chinese Managing Director and whether the company’s leadership was effective enough as to implement the changes successfully. The impact of the change on both SMC employees and the company in general has been reviewed. Finally, the study provides some recommendations on how such changes can be implemented more effectively and what lessons other businesses c an learn from SMC’s experience? 3 Organizational Context – Sinosteel Midwest

A Letter to God by Gregorio Lopez Y Fuentes Essay

A Letter to God by Gregorio Lopez Y Fuentes - Essay Example However, the expected rain turned to hail and soon destroyed all his crops which placed his family in an anticipated hunger throughout the year. Thinking about his God whom he knows would provide for their needs, the farmer then writes a letter to him which he sent through the mail. In the amusement of the postman and the postmaster, the former tried to correspond with the farmer but found the task to be challenging when he opened the letter and found out that the farmer was asking for a hundred pesos in order to re-sow the fields and to live by while they wait until harvest time. The postmaster then made his best to raise the money but was able to just send seventy pesos. When the farmer received his mail, he was disappointed when he opened it seeing it was not the full amount he asked for. So he made another letter telling God he just received seventy pesos and asking him to send the full amount of a hundred pesos because he badly needs it. Moreover, he asked the money not to be se nt through the mail because the post office employees are crooks, thinking the thirty peso deficit was taken by them.

Economics of Canadian Immigration Essay Example | Topics and Well Written Essays - 500 words

Economics of Canadian Immigration - Essay Example In describing the political culture of Canada, certain recent happenings never fail to feature prominently. The Quebec separatist movement and the emergence of conservatism especially in the west are some of the issues that have had great impacts on the Canadian political culture especially in the last two decades (Little 112-125). The propositions in the Quebec agenda and the differences in these policies in relation to the federal policies that define the rest of Canada are indeed topical issues that greatly define the political culture in Canada. The Quebec separatists’ need to secede from the greater Canada was an issue that did not go down well with the Canadian government (Wiley 32). The fundamental concept that arises in the Canadian political analysis is the concept of immigration to Canada and its effects in shaping the political culture in Canada. Most Canadians, unlike Americans, strongly feel that their government should be involved in the political and economic aspects of life in the country (Jameson 78). This support of the government arises out of the historical experiences that marked the Canadian evolvement. Unlike the US, the resistance of republicanism in Canada created a culture of less individualism and more support for government activities (Russell 11). The adoption of British parliamentary and legal systems coupled with loyalist conservatism is certainly the idea behind the Canadians’ obsession with better forms of governance and good politics (Bond 34-42). Such a mindset has been very instrumental in creating a unique political identity in Canada. On the contrary, it has been noticed that most Canadians are never very keen in paying att ention and learning the overall history of their country and its effects on their present lives (Ballack 89). They instead focus majorly on the history of specific regions or the history of a specific people in Canada. Such an analysis does not inundate one with the very pertinent

Keeping it Real Coca-Cola Case 2010 S2 Study Example | Topics and Well Written Essays - 750 words

Keeping it Real Coca-Cola 2010 S2 - Case Study Example The equality, need, restitution and status quo will also be examined. The individuals involved in the company, communities that need assistance from the decision as well as changing what is needed so it is fair in the future is also considered so it can provide and implement new alternatives for those that are in the company (Blader, Tyler, 2003). For procedural justice to become effective and to provide a fair opinion, there is the need to create a specific criteria that is matched during a case. The first is that there should be objective evidence that states whether something is fair or not in a given case. If it is subjective then it may be coming as a matter of opinion or from individuals who are not looking for justice but instead are interested in a different agenda in the court proceeding. For instance, in a given situation, the reactions that is a part of what occurs both from the situation and as a result, should be noted. The psychological concepts that relate to this should also be noted, such as depression, anxiety or other forms of discomfort or trauma that occur as a result. However, the outcomes that are noted from a given situation should come from evidence, reactions and noticing different concepts from the present moment. By following these main criteria, there can be an overall evaluation of whether someth ing was ethical and provided the correct behavior for individuals (Lind, Tyler, 2000). The criteria that are available should not only include the reactions and noticed changes among individuals. It is also important to notice the social psychology that is associated with the main concepts and proceedings of what occurs. The outcomes that are a part of the distribution, social processes that occur and the psychological responses need to be included in the procedural justice criteria. More importantly, reaching a solution which provides a sense of justice and fairness needs to be combined with understanding more

Case Analysis on Satyam Essay Example for Free

Case Analysis on Satyam Essay This case illustrates the downfall of Satyam, one of the biggest IT giants in India, because of the fraudulent activities carried out by its founder Mr. Ramalinga Raju and his associates. Business world at that point had garnered immense respect for Satyam in terms of risk management and corporate governance practices and Satyam was ranked as the fourth largest IT Company in India. This was the case before December 16, 2008, when Satyam promoter Mr. Ramalinga Raju proposed his intent to acquire Matyas Infra and Matyas Properties. When this announcement of acquisition reached to the public, investors had a tremendously negative reaction towards Satyam’s decision. Satyam founder eventually admitted fraud in a financial statement revealing that he had been cooking the books of Satyam for quite some time. Raju and his team manipulated cash balance, bank balance, accrued interest figures, overstated debtors and understated liability in order to manipulate the share prices of the company in the market by misleading its investors and the public. After admission of fraud, share prices of Satyam sharply fell down and Satyam was eventually removed from the New York stock exchange and the Bombay stock exchange. The US investors initiated several class action suits against Satyam for its fraudulent activities and top executives of Satyam were charged with violation of federal securities laws by issuing false and misleading financial statements. The Satyam scandal has shaken the roots of the Indian financial market and has put a big question mark on corporate governance and how far corporations (people) can go to enhance their own personal benefits. Major Issues in the Case Corporate governance Satyam failed to follow the corporate governance practices that every firm was meant to follow, it looked for loop hopes that could be tweaked to enhance the company’s profit and hide liabilities from the investors as well as the general public. The Satyam Board was composed of ‘chairman-friendly’ directors who failed to question managements strategy. They were also extremely slow to act when it was known that the company was in financial distress. The Board ignored critical information related to financial wrongdoings before the company ultimately collapsed. Agency problems The Chairman (Ramalinga Raju) and the CFO (Srinivas Vadlamani) worked together to defraud the stakeholders for their personal gain, while the investors thought that the company was generating revenues, and investing in different areas. Clearly, the Chairman and CFO had personal gain in mind rather than company benefit. There also seems to be conflicting interest of the management and the shareholders i. e. the management wanted to take over two construction companies Maytas properties and Maytas Infra which was against the interest of the shareholders. Arguments It’s hard to imagine a leading company like Satyam manipulating its financial statements but in this highly competitive industry it is necessary to remain profitable in order to survive in the long-run. This is perhaps the reason why Satyam resorted to manipulating its financial statement. We can see that there were large amount of manipulation in the income statement as well as in the balance sheet of Satyam’s financial statements. Manipulation in the Income Statement The income statement consisted of some inconsistencies that were made intentionally to maintain the level of profitability of the company. The amount of sales revenue has been overstated by Rs. 588 crore i. e. was recorded as Rs. 2700 crore instead of Rs. 2112 crore. The operating profit margin was recorded as Rs. 649 crore (i. e. 24 % of the sale revenue) when the actual operating profit margin was Rs. 61 crore (i. e. 3 % of the sales revenue). The number of employee was also manipulated i. e. it was recorded as 52000 employees when the actual number of employees was only 43622 employees. Manipulation in the Balance Sheet  The balance sheet also seemed to have some level of inconsistencies from the actual value that were done intentionally to show a strong liquidity position of the company. The cash balance that was recorded as Rs. 5361 crore consisted of non-existence amount of Rs. 5040 crore i. e. the actual cash balance was Rs. 321 crore. The assets side also consisted of accrued interest of Rs. 376 crore which was non-existent and the debtors amount was overstated by Rs. 490 crore i. e. the actual value of debtor was Rs. 2161 crore whereas the recorded value was Rs. 2651 crore. The liability side of he balance sheet was understated by Rs. 1230 crore which was the amount borrowed from the known sources by Mr. Raju to ensure the operations are running. Even after such manipulations the regulatory authorities, the independent executive and the external auditors were not able to raise the red flag which shows that there is a huge hole in the corporate governance. The company also seems to be having conflicting interest between the management and the shareholders. The company was looking to diversify its business by taking over the construction companies Maytas Properties and Maytas Infra at a cost of 1. billion dollars. Satyam was looking to enter the real-estate business but this was a surprising strategic decision for the shareholders. The shareholders wanted Satyam to expand in related businesses. The negative reaction of the shareholders toward the decision caused the share prices to fall by 70% in a just a few days of the decision. Managerial Implication Agency problem The problem of motivating one party to act on behalf of another can be called the principal-agent problem or agency problem for short. (Wikipedia, 2013) Agency problems arise in a variety of different contexts. The agency problem usually refers to a conflict of interest between a companys management and the companys stockholders. The manager, acting as the agent for the shareholders, or principals, is supposed to make decisions that will maximize shareholder wealth. However, the decision must be in the favor of all parties but it was not the case with Satyam. Satyam decided to acquire Maytas Properties and Maytas Infra. The shareholders resisted the decision claiming it to be unrelated business and acquisition should not take place with Maytas which became a finishing blow to the company. Corporate governance and business ethics Corporate governance refers to the system by which corporations are directed and controlled. The governance structure specifies the distribution of rights and responsibilities among different participants in the corporation (such as the board of directors, managers, shareholders, creditors, auditors, regulators, and other stakeholders) and specifies the rules and procedures for making decisions in corporate affairs. (Wikipedia, 2013) Governance is a mechanism for monitoring the actions, policies and decisions of corporations. On a quarterly basis, Satyam’s earnings grew. Mr. Raju admitted that the fraud which he committed amounted to nearly $276 million. In the process, Satyam violated all the rules of corporate governance. The Satyam scam has been an example for following poor governance practices. The issue of governance rose at Satyam because of non fulfillment of the obligation of the company towards its stakeholders like separating roles of board and management, and also the role of CEO and chairman. Business ethics reflects the philosophy of business, one of whose aims is to determine the fundamental purposes of a company. Business ethics are implemented in order to ensure that a certain required level of trust exists between consumers and various forms of market participants with businesses (Investopedia, 2013). The culture in Satyam, especially dominated by the board, symbolized such an unethical culture. Satyam as the smallest of the four players was under pressure to show good results in order to survive. Apart from this there was greed causing them to indulge in unethical behavior. On the one hand, Raju’s rise to stardom in the corporate world joined with immense pressure to impress investors made him a compelled leader to deliver outstanding results. On the contrary, Mr. Raju had to suppress his own morals and values in favor of the greater good of the company. The lure of big compensation to members further encouraged such behavior. In the end the fraud came to an end and the implications were great. Alternatives The failure of company like Satyam which had been awarded for its corporate governance and risk management creates a dilemma for the investors as to which company to believe and invest. Hence, investors, board, government intervention, accounting standards and ethics and Code of conduct must all work hand in hand to resolve the issue. Investors play an important role in detecting fraudulent activities of a company. They must ensure that information about the company is latest and from trustable source. Hence, they should take more care and compare the trend of the company with the industry before investing. Board must monitor the ethical policies and the way they are being maintained in the company. Transparency and effectiveness in auditing and regulatory checks through internal and external auditors and monitoring agencies should be maintained as it helps to build and maintain trust and loyalty from stakeholders, increase goodwill and investor’s confidence and establish long lasting credibility for the company. Government should play an active role in company’s affair, frequently checks of the company’s performance and take necessary steps to discourage malpractice and falsification. There is a need to create strong measures to prevent fraudulent activities from happening in future and the auditing firms also need to be brought under the regulatory umbrella. Moreover, all companies need to practice ethical behavior. Every company should also have its own fraud detection mechanism. It is also important for companies to establish an organizational culture, which supports ethical conduct through a code of conduct and properly laid out corporate governance policies and procedures.

Equity and Trusts Problem Questions

Equity and Trusts Problem Questions The first step we should attend to briefly is to define what a trust is. Simply put, a trust is a relationship under the law of equity[1] that arises when one person (the settlor) vests the legal title in another person (the trustee) for the benefit of a third-party called a beneficiary. The trustee holds the legal title and the beneficiary-(ies) possess the equitable title and as such the trustee owes them a duty to carry out the duties as defined by the settlor[2]. The most basic species of trust is an express private trust; this is a â€Å"trust which is declared intentionally by the settlor†[3]. There is no fixed mechanism or form of words for creating such a trust because â€Å"equity looks to intent rather than the form†[4]; see Paul-v-Constance[5]. Hudson (p.72) speaks of â€Å"exposing† a trust which demonstrates that it exists by law and is not created by the courts retrospectively. Express trusts can be established during the life of the settlor or as i n this case, via instructions placed in their will.[6] There are two basic sets of requirements for valid trusts; the first is that there needs to be three basic certainties as per Knight-v-Knight[7]; defined as certainty of intention, subject matter and object – if any one fails then there is no trust. The first of these requires that there was a certainty of intention by the purported settlor â€Å"that the person receiving the property is under a mandatory legal obligation to carry out the wishes of the settlor†[8]. Secondly and only logically, it must be certain what the subject of the trust is i.e. the property. Finally, there must be certainty of object i.e. there needs to be someone with equitable ownership to enforce the trust, see Re Endacott[9]. The second basic requirement is that the trust must be constituted i.e. the legal title must pass to the trustee(s). This should not be an issue here because as executors Edward and Sandra would have already acquired legal title of all Alice’s estate[10]. DISPOSITION A Alice’s disposition is potentially void as a trust due, firstly to uncertainty of intention; the disposition does not suggest Alice intends to impose a legal obligation on Edward to carry out her wishes. Rather it potentially suggests she was imposing on him a â€Å"power†. In essence, trusts impose an obligation to act and powers authorise people to carry out certain tasks with a lower level of compulsion.[11] The task we have is to decide what Alice intended and according to Dixton (p.67) â€Å"it is very easy to confuse trusts and powers, especially since most power are given to people who are otherwise trustees†. Edwards (p.80) advises that to differentiate between them is â€Å"a matter of construction for the courts, based on identifying the intention from†¦the language and the document as a whole† He further suggests that a significant indicator would be â€Å"existence of a gift in default of appointment† and wide discretion. Applying t his to our facts, we see that Alice grants him à ¢Ã¢â‚¬Å¡Ã‚ ¤10,000 to buy a small memento for â€Å"such of my relatives as have not received anything under the other provisions† and after doing this â€Å"to keep what is left†. It is submitted that this does not meet the necessary level of certainty, especially as Edward keeps what is left over, it is merely a power; a power of appointment[12], outside of a trust instrument[13].To impose a trust situation in this case would be to ignore the warning in Re Hamilton to â€Å"take the will you have to construe and see what it means, and if you come to the conclusion that no trust was intended then say so†. The next issue is what kind of powers these are and what level of compulsion exists on Edward to carry out the tasks. This could be a personal power[14] or a fiduciary power and this will turn on whether he was given the power in his capacity as a son or executor. Wilkie (p.52) says if it is a personal power he could distribute â€Å"spitefully, or capriciously, or even go to sleep and forget about exercising the power at all†. You could argue that Alice gave the power to her son in his capacity as a son; and so considering the remainder goes to him then it is all but an absolute gift. He could just buy a few relatives key-rings as mementoes and be done with it. The beneficiaries would have no equitable interest in any property as its quantum is unknowable. The second view you could argue is that he has to exercise the power in his capacity as executor and so he has a higher level of onus upon him. It is submitted that as such, this power of appointment would be what is known as a hybrid or intermediate power[15] in that he is authorised to distribute it to a certain category of objects, relatives, excluding those who have already benefited. The level of compulsion or onus is debatable. In Re Hay’s Settlements[16], it was held that he just cannot ignore this power to appoint randomly, he must make efforts to complete it. And in McPhail-v-Doulton[17] the leading case in this area it was said he â₠¬Å"must act in a responsible manner according to its purpose† and â€Å"make survey of the range of objects† that† will enable him to carry out his fiduciary duties.† Wilkie (p.52) says that there is much lessor onus is on a donee[18] of a power to locate those who may be objects. However, other commentators, see Penner (58+) say the onus depends on the type of power as well as who has been granted it. However, even with ‘powers’, the subjects and objects need to be ascertained and Alice has simply defined â€Å"small memento of me† and â€Å"relatives† minus those who benefited from the will; these are problematic. Firstly, the subject matter is conceptually uncertain[19]; as per Palmer-v-Simmonds[20] and so potentially void; what is ‘small’ and what is a ‘memento’[21]. Secondly, â€Å"relatives† could be taken to be anyone with a common ancestor and as you work back far enough this could include almost anyone. However, in Re Baden’s Deed Trusts (No.2)[22], relatives was equated to next-of-kin and held to be conceptually certain; a strange decision considering how rigid the court has been on conceptual uncertainty. Furthermore in McPhail, the test to ascertain objects for a power was decided as the ‘is or is not’ test described by Wilberforce as, â€Å"can it be said with certainty that any given indi vidual is or is not a member of the class?† Thus it appears possible that we could, if necessary, reach a legal definition of the objects although the problem is the subject of the power. The advice to Edward is pretty clear; as a trust this fails and so based on Curtis v Rippon[23], he could take the entire amount of à ¢Ã¢â‚¬Å¡Ã‚ ¤20,000 seeing that the amounts to be given to relatives are uncertain and so the absolute gift to him takes effect over the failed trust. However, if viewed as a power, he may be under compulsion to distribute some of the à ¢Ã¢â‚¬Å¡Ã‚ ¤20,000 buying small mementos for relatives once he complies with the above; although, in practice few would be willing, or able, to compel him to execute this power. DISPOSITION B Does the phrase â€Å"fullest trust and confidence† indicates certainty of intention to create a trust? In Re-Adams-and-Kensington-Vestry[24] a husband gave property to his wife in â€Å"in full confidence that she will do what is right†, yet this was held to only impose a moral obligation upon her. However, in Comiskey-v-Bowring-Hanbury[25] the phrase â€Å"in full confidence† was held to impose a trust. The similarity in these cases is superficial and it is apparent that each was judged on its individual merits and potential settlor’s intentions. Hence, the mechanical application of phrase simply turns the law on its head. It is much more insightful to follow Re Hamilton comments listed above in part A and use common sense. Applying this, it is submitted there is potentially a certainty of intention, but we also need to examine the other certainties. On ‘certainty of subject’; it is trite law that, as per Re-London-Wine-Co[26] that trust property must be ascertainable. In that case un-segregated wine voided certainty. This was supported in Re-Goldcorp-Exchange-Ltd[27] . Mustill[28] said â€Å"rights in property, whether equitable, cannot exist in the air†¦ it can only exist in relation to property which is specifically ascertained†, i.e. physical segregation is necessary[29]. However we are not dealing with a situation exactly similar to Re-London-Wine. Under a will, the executor takes full title to the property on the death and according to Martin(p.60) the â€Å"equitable ownership is in suspense† – the trust has not yet been constituted whereas it allegedly had in London-Wine. All the executors need to do is to walk down to the cellar and physically segregate fifty bottles of wine and identify them as trust property and transfer legal title from Edward/Sandra, as executors, to Edward pers onally. It is obvious Alison knew what was in her wine cellar so the property she is referring to really was not a specific 50 bottles of wine, but 50 of the 80 wine bottles I know I have in my cellar. How else could she describe them if they were homogeneous, was an 80 year old woman close to death meant to go down to her cellar and move bottles around? However, it is the â€Å"old friends†, the potential objects of this trust, which poses more serious problems. The phrase â€Å"my old friends† is conceptually uncertain[30]; both words are subjective; what is a ‘friend’ and what is ‘old’? With the knowledge that this would be a fixed trust if the three certainties were present; i.e. each beneficiary entitled to an â€Å"equal† share then IRC-v-Broadway-Cottages-Trust[31] states that all the beneficiaries must be able to be listed and there is no room for any conceptual uncertainty. The disposition states that Edward should cure any uncertainty and his word is â€Å"final†. However, this is not likely to be accepted by the courts. In Re-Tuck’s-Settlement-Trusts the court allowed a Rabbi, as per the trust document, to cure an issue of uncertainty i.e. whether someone was of â€Å"Jewish blood†[32]. However, the Rabbi was acting in his capacity as expert on the Jewish faith and evidencing the meaning of the words not defining them. You could make a good argument that Edward could define his mother’s old friends just like the Rabbi defined Jewish blood, but it would go against current legal and academic opinion so as a trust it would likely fail. However, the advice in this case might be that this could be treated like above, as a power. This is because, as a power Edward could use the â€Å"is or is not test† rather than the â€Å"complete list† test and so circumvent this issue and give Edward much more leeway to carry out his mother’s intentions. Remember the preference of the courts will be to see Alice’s wishes carried out rather than not. DISPOSITION C There is clearly an intention to create a trust with the subject matter of à ¢Ã¢â‚¬Å¡Ã‚ ¤20,000, because it is stated. It is further obvious that it is a discretionary trust[33]; this is a type of express trust where the trustee has what is called ‘dispositive discretion ’ i.e. an ability to decide the quantum of trust property, if any, goes to each beneficiary[34]. It is important to note the difference between this and a fixed trust; in a fixed trust the beneficiaries have a severable equitable claim on the property because they can usually calculate what they are entitled to. In a discretionary trust the trustees can exercise discretion; and in this case the basis of this discretion is those â€Å"they find most deserving.† The real issue is who exactly are the objects of the trust; that are subject to this discretion?[35] We are given no names but rather a class description â€Å"such of the first 300 people to have crossed the Victoria Bridge on the 24th of October 2008†. Such descriptors in theory pose no problems. However, if we assume that this date has passed[36], then we are presented with a difficult evidential problem. It is important to point out that the names of the 300 people who were first over Victoria Bridge is a fact; they are an absolute certainty; it is just the trustees don’t know who they are yet. Hence, it is not an issue of ‘conceptual certainty’ as to the class descriptor; it is not like â€Å"old friends†. The issue is one of evidential uncertainty in that the trustees do not have enough evidence to write down a complete list. The courts have grappled with this problem but it is now clear from McPhail-v-Doulton that previous requirements for a c omplete list, like for fixed trusts, are no longer valid. The test now is the â€Å"is or is not† test as outlined above. Hence, the trustees do not need to know the 300 people who crossed the bridge, they only need to meet the test set by Wilberforce in McPhail; â€Å"can it be said with certainty that any given individual is or is not a member of that class†. The issue now is could anyone do this with sufficient certainty. It would not be enough to show you crossed the bridge on the day but that you were one of the first three hundred to do so[37]. This turns on facts we don’t have; considering the coverage of police cameras in London it is likely there is one focused on Victoria Bridge so this might help candidates prove their claim. To conclude this section, the advice is whoever can prove with sufficient certainty that they fall within the class, and then they will become beneficiaries of the trust. However, if no one can prove then the trust will fail for lack of certainty of objects and the à ¢Ã¢â‚¬Å¡Ã‚ ¤20,000 result back to Alice’s estate. There are a number of other issues which should be covered briefly for Edward and Sandra. Assuming the three certainties are present, then the trust is properly constituted (as the potential trustees they are also executors and have legal title). To be a trustee you need to have reached the age of 18; we are not told Sandra’s age but presumably she complies with this. The trust is defined to be for 21 years i.e. 21 years after Alice’s death and this is permissible under Section 13 of the Perpetuities and Accumulations Act 1964. However, it is worth pointing out to Edward and Sandra that the trust is unlikely to last as long as 21 years. Although the beneficiaries would have no rights severally because as Penner (p.85) describes them they are â€Å"mere postulants, seeking the trustees’ largesse†; they could have rights jointly because it is an exhaustive trust[38] i.e. Alice appears to have instructed them to spend all the 20K and there are no devices to return unspent money to the estate. As such the beneficiaries may have rights jointly to petition the court to simply give them the trust property, see Martin (p.211) which presumably they would have agreed to divide equally[39]. References – Bibliography Burn, E, Trusts Trustees Cases Materials 6th Edition, Oxford University Press. Dixon, M, 2005, Equity and Trusts Q A, Cavendish Publishing. Edwards, K, 2000, Essential Equity and Trusts, Routledge. Duddington, J, 2007, Equity and Trusts Law Express, Pearson. Hudson, A, 2005, Equity Trusts, Routledge Cavendish. Mohamed, R, 2004, Cases Materials on Trusts, Routledge Cavendish. Martin, J, 2005,Hanbury Martin, Modern Equity 17th Edition, Sweet Maxwell. Penner, J, 2005, The Law of Trusts Core Text 4th Edition, OUP. Wilkie, M, 2008, Equity and Trusts Blackstones Q A 2008/2009, OUP. 1 Footnotes [1] Space precludes a discussion on the fundamentals of equitable law see Duddington(p.2+). [2] A trust is an onerous obligation and should not, and will not, be imposed casually by the courts if any doubt exists; especially as the courts may ultimately be called to adjudicate upon its operation [3] Hudson(p.38) [4] Re Williams 1897 [5] On the other hand you can use the word â€Å"trust†, as per Tito v Waddell (no2) and this might not create one. [6] They are often known as ‘testamentary trusts’; but not substantially different to inter vivos trusts. [7] 1840 [8] Dixon(p.61) [9] 1960 [10] We are told the will is valid and that is all we need to concern ourselves about with that matter. [11] Martin(p.171) [12] appointment in this sense means the power to give or to appoint the property to someone. [13] Powers can operate „insideâ€Å"or „outsideâ€Å", those outside are known as bare powers i.e. less encumbered by the obligatory nature of the trustees duty. [14] Beware of terminological problems with these phrases, see Wilkie(p.51) [15] See Mohamed(p.118) [16] 1982 [17] 1982 see Burn(p.84) for a discussion of the case and test. [18] The person who is authorised to exercise a power. [19] see Disposition B and C for more details and Duddington(P.15,16) [20] 1854 [21] see below for more detail [22] 1973 [23] 1820 [24] 1884 [25] 1905 [26] 1986 PCC 121 [27] 1985 [28] Quoted in Penner(p.205) [29] It is worth noting the ruling in Hunter v Moss which appears to run contrary to this albeit with intangibles. [30] Penner(p.197+) In Re Gibbard’s Will Trusts 1967 and RE Barlow’s Will Trusts 1979 â€Å"friends† was held certain but the former has been overruled and the latter referred to different legal circumstances. [31] 1955 [32] see Duddington(p.20) [33] see Dixon(p.65+) [34] See Martin(p.104+), see also Edwards(p.77) for concise analysis. [35] I am interpreting the will as meaning there is a potential class size of 300 and over these discretion is exercised. [36] It is not 100% clear from the rubric that his date has passed, although the use of â€Å"to have crossed† clearly infers it. [37] A suggestion of administrative un-workability might arise here [38] It is interesting to note that discretionary trusts presents theoretical problems in that you can ask the question ‚who holds the equitable rights to the property?’ without beneficiaries who enforce the terms of the trust; there is an obvious risk that trustees can become slack in their duties. See Penner(p84+) [39] Space precludes a detailed analysis of these issues