Wednesday, December 25, 2019

Essay on We Must Strive to Protect Privacy in Technology

We Must Strive to Protect Privacy in Technology Technology is getting more and more complex as the years come and go. The availability of personal information is easier to access and the risk of it being tampered with is also high. As the years pass, the threat of privacy invasion gets greater and greater and easier to happen. There are several ways that privacy is able to be invaded and there will only be more to come. Americans have had their personal information given away without even knowing it. From dozens of public and private sources that have created consumer profiles, â€Å"the average American is profiled in up to 150 commercial databases† (Hinds 7). People are trying to â€Å"prohibit collection of personal information on the†¦show more content†¦Ã¢â‚¬Å"In countless offices, employers can monitor telephone calls, peruse email messages, and even retrieve supposedly ‘deleted’ files without an employee’s knowledge† (Brin 56). There is nothing the employees can do about this if they never know it is even happening. New technology has been invading organizations as well. The workers of the organizations are also at a high risk. â€Å"Technology enhances the ability of organizations to monitor individuals† and what they do on the job (Regan 2). If they do something on the computer or phone, the possibility of someone else knowing is always there. With this problem growing, it makes workers feel uncomfortable and unsafe with every move they make. In order to feel safer about using a computer, there are some precautions that may be taken to prevent any potential hacking or privacy invasion. Firewalls may be set up to â€Å"prevent any unauthorized access to or from a network.† For a wireless network, Wired Equivalent Privacy (WEP) would be used to avoid hackers. An implement that hackers use to infiltrate a network is called SATAN. It is a â€Å"Security Administrator Tool for Analyzing Networks.† It was initially created to allow administrators to find any vulnerability in a system. Hackers have used this to look at important files and documents that are confidential (webopedia). As time goes on, so will the movement toward protecting privacy from technology. There will always be hackers that findShow MoreRelatedMobile Phones And The Advancements Of Modern Day1333 Words   |  6 PagesThe expanding use of cellular phones and the advancements of modern-day technology are leading the way for a broadening perspective and interpretation of our Fourth Amendment right. Modern technology, such as cellular phones, challenge the standards of an individual s right to privacy as set forth in our Bill of Rights, Amendment No. 4. The conduct of illegal search s and or seizures became more prevalent with the introduction of the cellphone, thus demanding the Supreme Court revisits our FourthRead MoreAnalyzing The Past, Present And Future Of The Congressional Attempt At The Health Care Reform1704 Words   |  7 Pagescongress was the Health Security Act in 1993, which was not enacted until June 2014. The Health Security Act started the foundation for patient privacy and th e security of an individual’s health information. As the years passed the Health Security Act became quickly outdated and needed to be updated to complement the sudden progression of current technology advances. Congress was presented the Kennedy-Kassebaum Act, which defined patient rights and the responsibilities of medical professionals to provideRead MoreTerrorism: Safety vs Privicy1594 Words   |  7 PagesEver since 9-11, we as a country have been divided on many issues. One of the most discussed considers the question of whether retaining our privacy is more important than ensuring our safety. The two texts I will be using to explore this question are: Mobile Phone Tracking Scrutinized by Nikki Swartz Published in the Information Journal, which bills it’s self as â€Å"the leading source of information on topics central to the management of records and information worldwide†(347), in March/April 2006Read MoreCloud Computing And The Protection Of Intelle ctual Property1361 Words   |  6 PagesTrust in Cloud Computing Cloud computing has a duty to protect data privacy and some countries are going to great measures to further ensure that their data is kept within their national borders (Trend Micro, 2013). 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Wyndham Worldwide Corp., the FTC alleged that, â€Å"at least sinceRead MoreCyber Security and Privacy Techniques.1675 Words   |  7 PagesCyber Security and Privacy Techniques Tammy Sublett Harrison College Cybercrime Thomas Hart 12/05/12 In today society almost everyone has some form of computer or phone with internet capacity that are exposed to hackers and those that wish to interrupt the cyber world. It is imperative that we all become better educated to the risks and pitfalls that go along with accessing cyber space from any kind of device with access to the world-wide web. Be it by cell device, laptop, notebook, or homeRead MoreNsa Should Be Stopped. Nsa1177 Words   |  5 Pagesinitially intended to protect the USA by tethering through technology devices to attempt to pick up any suspicious activities. The problem is that many feel as if the NSA has no right to evade their privacy. The NSA should be penalize every time they do so, or should have some type of warrant, but only for last resort, or stopped completely. There are many other ways to go about finding troublesome threats like antagonist programs like CDT as I mentioned earlier. Having your privacy tampered with isn’tRead MoreWhat A Cio Should D o993 Words   |  4 Pagesdiscussion where we were tasked to consider what a CIO should do, I was keenly aware of how our own perspectives were such a large part of how we phrased our responses. Regardless of the topic, thinking from the consumer perspective is different from the business or information technology perspective. In this class, it has become apparent that information technology has its own perspective and set of ethics. In this class, we tried to apply traditional ethics to the uses of information technology, but oftenRead MoreThe Code Of Ethics For Habana Care Dental1170 Words   |  5 Pageswork unsupervised. I would have my own private practice with a collaborative agreement with a dentist. Patients will be referred to the dentist have further dental care. Code of Ethics: Mission Statement: Habana Care Dental is an institution that strives for the excellence in oral health care. Valuable professionals offer a carefully and individual treatment to all of our patients without any distinction or discrimination. Our priority is to bring back health to our patients and a beautiful smileRead MoreThe Positive And Negative Effects Of Privacy And Social Media1518 Words   |  7 PagesThe Oxford dictionary defines Privacy as the state or condition of being free from being observed or disturbed by other people (2017). It should not come as a surprise that websites designed to share pictures, ideas, and what is for dinner, leave individuals feeling that their privacy has been invaded. It is also not surprising that some people are oblivious to the effects of what they post online. It is safe to say the loss of privacy can be self-imposed for societies need to collaborate and socialized

Monday, December 16, 2019

The Enigma Of Capital And The Crisis Of Capitalism

A Critical Review of David Harvey’s The Enigma of Capital and the Crisis of Capitalism Sudheer Vemuru Economics 490 10 November, 2014 In writing this paper, I have abided by the Honor Code at UNC-Chapel Hill. Signature:____________________ ______________________ ï ¿ ¼ The Enigma of Capital and the Crisis of Capitalism is a forum for author David Harvey to voice his concerns on the contemporary global capitalist model. As a Marxist geographer and anthropologist, Harvey analyzes modern capitalism through a lens of skepticism that results in a scathing renunciation of the capitalist goals of perpetual accumulation and creative destruction. Harvey argues that in a world constrained by scarce resources and burgeoning social barriers, the capitalist process produces a strange dynamic that oscillates between periods of crisis and boom (40). In the end the capitalist may be able to hedge against her losses, but the vast majority of the population will wallow in the doldrums, enslaved by the power of capital and unable to pull themselves up by their bootstraps. Such is the extent of the problem we face in the wake of the Great Recession. The economy continues to grow modestly, while median household income shrinks (Noss 2). The capitalists are reloading on ce again at the expense of Main Street. As Harvey points out, there is a great need to reevaluate of our views of modern capitalism. The Enigma of Capital is just a starting point. Harvey begins his analysis of capitalism with aShow MoreRelatedThe Enigma Of Capital And The Crisis Of Capitalism By David Harvey779 Words   |  4 Pages210-350 Enigma Capital INTRODUCTION The book that I chose to do my book review on was The Enigma of Capital and The Crisis of Capitalism by David Harvey. (Oxford University Press, 2011). The book is about capital flow and how it dictates the very essence of our everyday life. Harvey’s purpose of the book is to help gain a critical understanding of the systemic logic of capitalism and of the role that periodic crisis plays. Within that logic begins with a detailed account of the current crisis. HarveyRead MoreHow Neoliberalism Has Changed The World1221 Words   |  5 Pagesbe acknowledged. According to Sewpaul (2015) there are many consequences to neoliberalism that we face today, such as the overall decrease of people’s standard of living which has reverberating effects in all parts of the globe as mirrored in the crisis of Wall street 2007-08, the gradual reduction of economic growth and the world wide inequality of resources. Some economists have found that neoliberalism has actually contributed to th e distorted level of overall wealth across nations including AfricaRead MoreWhat Does Europe Want?1433 Words   |  6 PagesLate in his life, Freud asked the famous question â€Å"Was will das Weib?†, â€Å"What does a woman want?†, admitting his perplexity when faced with the enigma of the feminine sexuality. A similar perplexity arouses today, apropos the Brexit referendum: what does Europe want? The true stakes of this referendum become clear if we locate it into its larger historical context. In Western and Eastern Europe, there are signs of a long-term re-arrangement of the political space. Till recently, the political spaceRead MoreEssay about Japans Economic Slump2689 Words   |  11 PagesJapans Economic Slump 1. Introduction =============== In only fifty years, Japan has moved from poverty to the highest levels of income, from economic insignificance to leadership from the import of technology and capital to being a major source of their export, from less developed status to the lead of economic position after the United States. After being the best performer in the Organisation for Economic Cooperation and Development (OECD) during theRead MoreChina s New Economy For The New Millennium3231 Words   |  13 Pages China s New Economy for the New Millennium Introduction China has been an enigma for centuries, always one of the world s most impressive civilizations and cultures known for outpacing the rest of the world in the arts and sciences (CIA, 2000; p. ch), often by differences measured not in months or years, but in centuries. 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Nov. 9 – Integrative Thinking: Choices, conflict and the creative spark Feature story: Michael Lee-chin’s crisis of whether or not to sell AIC’s stocks (as he supported them for many years) when they were falling dramatically. He then decided to purchase many of one stock, Mackenzie Financial Group, one of AIC’s major holdings this saved AIC as it became Canada’sRead MoreSociology Exam Study Guide3121 Words   |  13 Pagesand Cultural Relativism o Ethnocentrism-The practice of judging another culture by the standards of one’s own culture o Cultural Relativism-The practice of judging a culture by its own standards †¢ Uniquely American medical enigma o U.S. is almost alone among industrialized countries in circumcising males o Still performed on over  ½ of American newborn males o Circumcision arose out of fears of masturbation and juvenile sexuality o TheRead MoreEntrepreneurial Spirit Among East Asian Chinese9960 Words   |  40 Pagesindividual more entrepreneurial than another is also important, as it helps to identify potential business leaders whose contributions in jumpstarting an economy may be needed. This particularly is useful in East Asian economies, where the economic crisis in the late 1990s has seen rising unemployment and recession. Thus, identifying and inculcating potential entrepreneurs is one way towards finding solutions to stimulate the economy. Hong Kong and Singapore are studied because these economies haveRead MoreOne Significant Change That Has Occurred in the World Between 1900 and 2005. Explain the Impact This Change Has Made on Our Lives and Why It Is an Important Change.163893 Words   |  656 Pages The decades since 1840 have witnessed a striking and unprecedented increase in the human population, in industrial and agricultural production, in global trade and its shift to nonluxury commo dities, 10 †¢ CHAPTER 1 in international capital flows, in transcontinental economic integration, in transportation and communication technology, and in the movement of people. These upsurges and their regional unevenness created unprecedented incentives for long-distance migrations, as well as

Sunday, December 8, 2019

Consumer Behaviour in Australia

Question: Describe about the consumer behaviour. Answer: The market trend of Australia can be determined by the demographic characteristics which help to analyze the need of the varied customers in the country. The demographic characteristics help the industry to evaluate the need of the present trend of the market and also help in market segmentation of the industry as well. The demographic trend also helps in the effective planning of the business and also helps in evaluating the marketing mix and potentiality of the customers towards organizational products as well (Solomon et al. 2012). Thus, the consumer behavior helps industries to analyze their products and also help them to increase the profitability rate through present market demand as well. Thus, the consumer behavior in various ways influences the industries of Australia and also helps in determining the sustainability of the industry. A) Vacation in Australia and New Zealand gets affected by the long life span of the senior citizen. The traveling and transport become difficult for the Australian families and thus the face service constraints regarding improvement and development in the market (Moutinho 2012). The Australian vacation industry thus faces constant challenge regarding long life span of the senior citizen as they find difficult at times in traveling which affects the industry as a whole. The social disadvantage also affects the cost of the industry and thus proves to be difficult for the industry to attract more people towards the industry. The industry also faces constraint regarding accessing private transport due to financial stress, or cost of petrol which also affect the vacation industry in Australia and New Zealand. The cosmetic industry is widely affected by the senior citizen in Australia and New Zealand. Most women are interested in the cosmetic surgery which helps the industry to expand its business and helps in the growth of the industry as well. 48% of women are interested towards the industry and demands for the liposuction (Akehurst et al. 2012). This helps the company in increasing the profit sales of the country and helps in expansion as well. 23% of men are interested towards the industry as well. Remaining 23% of women and 17% of men are also possible interested towards the industry as a whole. Thus, the consumer behavior helps in the growth rate of the industry in the market. The pre-cooked food industry also gets highly affected by the consumer behavior of the senior citizen. The senior citizen needs to maintain the health to stay well and live long. Thus, the pre-coked foods are not well accepted by the people belonging to the senior citizen in the country (Paul and Rana 2012). Australia and New Zealand thus suffer a setback regarding pre-cooked industry as both the countries comprises mostly with aging people. B) The baby boomers are more prone towards the vacation industry in Australia and New Zealand, which helps the industry to increase their growth level more rapidly in the countries as well. The baby boomers after leaving their workplace to find out a reason for relaxation and thus traveling opt to be the best option for the baby boomers to relax (Losasso et al. 2012). The vacation industry in Australia and New Zealand thus gets affected by the baby boomers as they want to travel with the free mind and helps in gaining competitive advantage. The baby boomers with Australia and New Zealand affect the cosmetic industry to a large extent. The boomers between the ages of 40 50 comprise as ideal cosmetic candidates within Australia and New Zealand. The consumer through entering at the age of 50 still feels to be at the 30s and thus become conscious more towards the cosmetic industry (Solomon et al. 2012). This helps the industry to gain competitive advantage and also helps to gain more loyal customers towards the industry. The baby boomers become very conscious regarding the health of the consumer and also help in improving the industrial growth as well. The baby boomers after the retirement tend more towards healthy and nutritious diet which lowers the consumption of pre-cooked industry in the country (Hansen et al. 2012). Thus, the industry gets negative affect from the baby boomers towards the expansion of the market. C) The Generation Y with growing household and also burden with high mortgage tends towards lowering travel interest in the country. The generation Y though gets interested towards tourism, but the burden of mortgage also affect the industry which lowers the profit rate of the industry (Batt and Liu 2012). The net sales of the industry get affected, and thus, the debts hold back Generation Y towards the improvement and development of the industry in the market. The Generation Y tends towards the cosmetic industry to a broad expect. Mostly women tend towards the cosmetic industry rather than men in the society. Though the cosmetic industry does not gain much advantage from this section of the society still, the industry retains its position in the market with minimum net sales profit. Generation Y also tends more towards the pre-cooked industry as the consumer mostly spend time in chasing their career and thus affects the food habit. The pre-cooked industry also attracts more customers through well packaging and gains more loyal customers towards the organizational products and helps in gaining competitive advantage in the market (Dibb and Simkin 2012). The consumer behavior also helps the industry to gain sustainability and thus increase the growth rate of the industry as well. D) Vacation industry in Australia and New Zealand gets affected largely by the "Single Adult" households. The single adults love to travel and are known as audacious explorers. They are believed to treat their life with adventures, and thus, the risk cannot stop them from exploring (Eze et al. 2012). This helps the industry to add value towards the organization and also helps in the expansion of the market as a whole. However, the risk and threat factor influence some from exploring but major population of this section helps in the growth of the industry. The consumer behaviour of the Single Adult group comprises largely towards the expansion of the cosmetic industry in New Zealand and Australia. Women mostly tend towards the cosmetic industry but with the present marketing trend, the consumer behaviour of men also tends towards the industry (Eze et al. 212). This helps the industry towards the development and expansion of the market in the international scenario. The cosmetic industry thus gets highly profitable with the increased consumer behavior and helps in improving the sales rate of the industry. The pre-cooked industry also helps to expand the market through the positive response of consumer behaviour towards the industry. Single Adults tends more towards the pre-cooked industry as they find themselves with less space for themselves and thus the industry gets more loyal customers towards the industry (St Wang 2013). The increased consumer behavior towards the products helps in the expansion of the market and thus helps in improving the quality of the products as well. Single Adults in New Zealand and Australia thus gets more prone towards the pre-cooked industry which further helps the generation to save time and gets high quality of food as well. This helps in the expansion of the industry as well. The demographic characteristics of a varied consumer within Australia and New Zealand help to determine the profitability of the industry. The cosmetic, vacation and pre-cooked industry thus gets affected by the consumer behaviour which affects the profit rate of the industry as a whole. The positive and negative behavior also helps the industry in an evaluation of the need for the industrial products and thus helps in analyzing the expansion of the market as well. The consumer behavior helps the industry to gain competitive advantage and helps in sustainability as well in the market. Reference List: Akehurst, G., Afonso, C. and Martins Gonalves, H., 2012. Re-examining green purchase behaviour and the green consumer profile: new evidences.Management Decision,50(5), pp.972-988. Batt, P.J. and Liu, A., 2012. Consumer behaviour towards food products in Western Australia.British Food Journal,114(2), pp.285-297. Dibb, S. and Simkin, L., 2012. Targeting, segments and positioning.International Journal of Retail Distribution Management,19(3), pp.29-34. Eze, U.C. and Lee, C.H., 2012. Consumers' attitude towards advertising.International journal of business and management,7(13), p.94. Eze, U.C., Tan, C.B. and Yeo, A.L.Y., 2012. Purchasing cosmetic products: a preliminary perspective of Gen-Y.Contemporary Management Research,8(1), p.51. Hansen, T., Risborg, M.S. and Steen, C.D., 2012. Understanding consumer purchase of free of cosmetics: A value driven TRA approach.Journal of Consumer Behaviour,11(6), pp.477-486. Losasso, C., Cibin, V., Cappa, V., Roccato, A., Vanzo, A., Andrighetto, I. and Ricci, A., 2012. Food safety and nutrition: Improving consumer behaviour.Food Control,26(2), pp.252-258. Moutinho, L., 2012. Consumer behaviour in tourism.European journal of marketing,21(10), pp.5-44. Paul, J. and Rana, J., 2012. Consumer behavior and purchase intention for organic food.Journal of consumer Marketing,29(6), pp.412-422. Solomon, M., Russell-Bennett, R. and Previte, J., 2012.Consumer behaviour. Pearson Higher Education AU, 22(1), pp.34-54. Solomon, M.R., Russell-Bennett, R. and Previte, J., 2013.Consumer behaviour: Buying, having, being. Pearson Australia. ST Wang, E., 2013. The influence of visual packaging design on perceived food product quality, value, and brand preference.International Journal of Retail Distribution Management,41(10), pp.805-816.

Sunday, December 1, 2019

International Financial Management Essay Example

International Financial Management Essay INTERNATIONAL FINANCIAL MANAGEMENT Undertaken at â€Å"TECNIA INSTITUTE OF ADVANCED STUDIES† Submitted in the partial fulfillment for the award of the degree of MASTER OF BUSINESS ADMINISTRATION Under the Supervision  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Submitted by and Guidance ofRAMAN KUMAR Ms. Sakshi Goel 05117003910 (Lecturer IFM)MBA- 3rd Sem SESSION: 2010 2012 TECNIA INSTITUTE OF ADVANCED STUDIES (Approved by AICTE, Ministry of HRD, Govt. of India) Affiliated To Guru Gobind Singh Indraprastha University, Delhi INSTITUTIONAL AREA, MADHUBAN CHOWK, ROHINI, DELHI- 110085 E-Mail:[emailprotected] rg, Website: www. tecniaindia. org Fax No: 27555120, Tel: 27555121-24 Ques 1) Bring out the similarities and dissimilarities in the financing facilities at IMF and World Bank. Discuss how the two institutions help in the development of developing countries? World Bank and IMF * The World Bank and the IMF are twin pillars supporting the worlds economic and financial structure. The World Bank is an investment bank owned by its member nations. The IMF functions more like a credit union whose members can draw from a common pool of funds to assist in emergencies. As of Aug. 1, 2010, its biggest borrowers were Romania, Ukraine and Hungary. 19441969 * From July 1 to 22, 1944, the IMF and World Bank Articles of Agreement were formulated at the International Monetary and Financial Conference in Bretton Woods, New Hampshire. On May 8, 1947, France became the first nation to borrow from the IMF. On Sept. 29, 1967, the IMF board approved a plan to establish special drawing rights (SDRs), which are international reserve assets used by member countries to supplement their foreign exchange reserves. 19701985 * On Aug. 15, 1971, the U. S. topped using the gold standard to settle international transactions. In 1974, the IMF adopted a new method of SDR valuation based on a basket of 16 currencies. This basket was simplified on Sept. 17, 1980, to hold five currencies, and today it holds fou r: the U. S. dollar, euro, Japanese yen and pound sterling. On Dec. 2, 1985, the two agencies expressed support for a U. S. initiative for comprehensive adjustment measures by debtors, increased and more effective structural lending by multilateral development banks, and expanded lending by commercial banks. 1986-Onward * On Dec. 9, 1987, the IMF established the Enhanced Structural Adjustment Facility (ESAF) to provide resources to developing nations undergoing fundamental debt restructuring and economic reform. Countries of the former Soviet Union joined the two agencies in 1992. The IMF, in conjunction with the G7, helped stabilize the 1995 Mexican peso crisis and the 1997 Asian currency crisis. On Jan. 8, 2001, the IMF and the Bank announced debt relief for 22 countries, 18 of them in Africa. On Apr. 13, 2003, a joint IMF-World Bank project was launched to monitor the policies and actions needed to achieve the United Nations Millennium Development Goals by 2015. On Sept. 25, 2005, agreement was reached on a G7/G8 proposal to provide 100 percent debt relief to the worlds heavily indebted poor countries (HIPCs). During their April 2006 meetings, the IMF and the Bank focused on ways to finance clean energy in developing countries, and the role of governance in meeting worldwide social, health and economic goals. Similarities Differences The overall structure of the  United Nations System  and  World Bank Group  has been described in previous posts. Both of those groups have expanded exponentially since their creation. Given that both the UN and World Bank were born from the same parents almost simultaneously, the extent of differences among organizations both within and between those two broad institutional systems is surprising: 1. Although membership in all entities within the UN System and World Bank Group is limited to sovereign- states, all members of the United Nations  General Assembly  are not necessarily members of  IBRD  (or other  World Bank  subsidiary bodies or specific UN  specialized agencies); 2. We will write a custom essay sample on International Financial Management specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on International Financial Management specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on International Financial Management specifically for you FOR ONLY $16.38 $13.9/page Hire Writer Although sovereign-state members are represented by their respective governments within  UN  System  and  World Bank Group  entities, different agencies within those governments represent them in those different international bodies (for example, [i] ministries of  foreign affairs  generally represent their governments  in the  General Assembly  and  Security Council, [II] bi-lateral development agencies, ministries of external affairs, or sector-specific  line ministries  normally represent them inspecialized agencies, and [iii] ministries of  finance  or  central banksnormally represent them in the  World Bank  and  International Monetary Fund  [IMF]); 3. Although informal agreements existed that the  Administrator  of the  United Nations Development Programme  (UNDP) and thePresident  of the  World Bank  should both be Americans,6  a wide range of other nationalities have always served in the highest leadership position of other UN specialized agencies; 4. Although senior leaders within both systems stressed the importance of â€Å"country-knowledge† among staff, the UN system began posting  Resident Representatives  to client countries very early-on while the World Bank continues to rely primarily on staff and consultants dispatched from its Washington headquarters; and 5. Although the UN system fairly rapidly expanded its interests in international development assistance and capacity to provide it, the attention of its overall leadership and Secretariat staff remains focused on, in the words of Craig Murphy, â€Å"matters of international high politics. † IMF and World Bank help in the development of developing countries The IMF and World Bank collaborate regularly and at many levels to assist member countries and work together on several initiatives. In 1989, the terms for their cooperation were set out in a  concordat  to ensure effective collaboration in areas of shared responsibility. High-level coordination: During the  Annual Meetings  of the  Boards of Governors of the IMF  and the World Bank, Governors consult and present their countries’ views on current issues in international economics and finance. The Boards of Governors decide how to address international economic and financial issues and set priorities for the organizations. A group of IMF and World Bank Governors also meet as part of the  Development Committee, whose meetings coincide with the Spring and Annual Meetings of the IMF and the World Bank. This committee was established in 1974 to advise the two institutions on critical development issues and on the financial resources required to promote economic development in low-income countries. Management consultation. The Managing Director of the IMF and the President of the World Bank meet regularly to consult on major issues. They also issue joint statements and occasionally write joint articles, and have visited several regions and countries together. Staff collaboration. The staffs of the IMF and the Bank collaborate closely on country assistance and policy issues that are relevant for both institutions. The two institutions also often conduct country missions in parallel and staff participate in each other’s missions. IMF assessments of a country’s general economic situation and policies provide input to the Bank’s assessments of potential development projects or reforms. Similarly, Bank advice on structural and sectoral reforms is taken into account by the IMF in its policy advice. The staffs of the two institutions also cooperate on the  conditionality  involved in their respective lending programs. The 2007 external review of Bank-Fund collaboration led to a  Joint Management Action Plan  on World Bank-IMF Collaboration (JMAP) to further enhance the way the two institutions work together. Under the plan, Fund and Bank country teams discuss their country-level work programs, which identify macro-critical sectoral issues, the division of labor, and the work needed from each institution in the coming year. A recent  review of JMAP implementation  underscored the importance of these   joint country team consultations in enhancing collaboration. Reducing debt burdens. The IMF and World Bank also work together to reduce the external debt burdens of the most heavily indebted poor countries under theHeavily Indebted Poor Countries (HIPC) Initiative  and the  Multilateral Debt Relief Initiative (MDRI). The objective is to help low-income countries achieve their development goals without creating future debt problems. IMF and Bank staff jointly prepare country debt sustainability analyses under the  Debt Sustainability Framework (DSF)  developed by the two institutions. Reducing poverty. In 1999, the IMF and the World Bank initiated the  Poverty Reduction Strategy Paper (PRSP)  approach—a country-led plan for linking national policies, donor support, and the development outcomes needed to reduce poverty in low-income countries. PRSPs underpin the HIPC Initiative and most  concessional lending by the IMF  (in particular, the  Extended Credit Facility (ECF)) and World Bank. Monitoring progress on the MDGs. Since 2004, the Fund and Bank have worked together on the  Global Monitoring Report  (GMR), which assesses progress needed to achieve the UN  Millennium Development Goals (MDGs). The report also considers how well developing countries, developed countries, and the international financial institutions are contributing to the development partnership and strategy to meet the MDGs. Assessing financial stability. The IMF and World Bank are also working together to make financial sectors in member countries resilient and well regulated. The  Financial Sector Assessment Program (FSAP)  was introduced in 1999 to identify the strengths and vulnerabilities of a countrys financial system and recommend appropriate policy responses. Ques 2) What to do understand by swap? What are the various types of swaps? An Introduction To Swaps Derivatives  contracts can be divided into two general families: 1. Contingent claims, i. e. , options 2. Forward claims, which include exchange-traded futures,  forward contracts  and  swaps   3. A swap is an agreement between two parties to exchange sequences of cash flows for a set period of time. Usually, at the time the contract is initiated, at least one of these series of cash flows is determined by a random or uncertain variable, such as an interest rate, foreign exchange rate, equity price or commodity price. Conceptually, one may view a swap as either a portfolio of forward contracts, or as a long position in one bond coupled with a short position in another bond. This article will discuss the two most common and most basic types of swaps: the  plain vanilla  interest rate and  currency swaps. The Swaps Market Unlike most standardized  options  and  futures  contracts, swaps are not exchange-traded instruments. Instead, swaps are customized contracts that are traded in the  over-the-counter  (OTC) market between private parties. Firms and financial institutions dominate the swaps market, with few (if any) individuals ever participating. Because swaps occur on the OTC market, there is always the risk of a counterparty defaulting on the swap. (For background reading, see  Futures Fundamentals  and  Options Basics. ) The first  interest rate swap  occurred between IBM and the World Bank in 1981. However, despite their relative youth, swaps have exploded in popularity. In 1987, the  International Swaps and Derivatives Association  reported that the swaps market had a total notional value of $865. 6 billion. By mid-2006, this figure exceeded $250  trillion, according to the Bank for International Settlements. Thats more than 15  times  the size of the  U. S. public equities market. Plain Vanilla Interest Rate Swap The most common and simplest swap is a plain vanilla interest rate swap. In this swap, Party A agrees to pay Party B a predetermined,  fixed rate of interest  on a  notional principal  on specific dates for a specified period of time. Concurrently, Party B agrees to make payments based on a  floating interest rate  to Party A on that same notional principal on the same specified dates for the same specified time period. In a plain vanilla swap, the two cash flows are paid in the same currency. The specified payment dates are called  settlement dates, and the time between are called settlement periods. Because swaps are customized contracts, interest payments may be made annually, quarterly, monthly, or at any other interval determined by the parties. (For related reading, see  How do companies benefit from interest rate and currency swaps? ) For example, on December 31, 2006, Company A and Company B enter into a five-year swap with the following terms: * Company A pays Company B an amount equal to 6% per annum on a notional principal of $20 million. Company B pays Company A an amount equal to one-year LIBOR + 1% per annum on a notional principal of $20 million. LIBOR, or  London Interbank Offer Rate, is the interest rate offered by  London  banks on deposits made by other banks in the  eurodollar  markets. The market for interest rate swaps frequently (but not always) uses LIBOR as the base for the floating rate. For simplicity, lets assume the two parties ex change payments annually on December 31, beginning in 2007 and concluding in 2011. At the end of 2007, Company A will pay Company B $20,000,000 * 6% = $1,200,000. On December 31, 2006, one-year LIBOR was 5. 33%; therefore, Company B will pay Company A $20,000,000 * (5. 33% + 1%) = $1,266,000. In a plain vanilla interest rate swap, the floating rate is usually determined at the beginning of the settlement period. Normally, swap contracts allow for payments to be netted against each other to avoid unnecessary payments. Here, Company B pays $66,000, and Company A pays nothing. At no point does the principal change hands, which is why it is referred to as a notional amount. Figure 1 shows the cash flows between the parties, which occur annually (in this example). (To learn more, read  Corporate Use Of Derivatives For Hedging. ) | Figure 1: Cash flows for a plain vanilla interest rate swap| Plain Vanilla Foreign Currency Swap The plain vanilla currency swap involves exchanging principal and fixed interest payments on a loan in one currency for principal and fixed interest payments on a similar loan in another currency. Unlike an interest rate swap, the parties to a currency swap will exchange principal amounts at the beginning and end of the swap. The two specified principal amounts are set so as to be approximately equal to one another, given the exchange rate at the time the swap is initiated. For example, Company C, a  U. S. firm, and Company D, a European firm, enter into a five-year currency swap for $50 million. Lets assume the exchange rate at the time is $1. 25 per euro (i. e. , the dollar is worth $0. 80 euro). First, the firms will exchange principals. So, Company C pays $50 million, and Company D pays  ¬40 million. This satisfies each companys need for funds denominated in another currency (which is the reason for the swap). | Figure 2: Cash flows for a plain vanilla currency swap, Step 1. | Then, at intervals specified in the swap agreement, the parties will exchange interest payments on their respective principal amounts. To keep things simple, lets say they make these payments annually, beginning one year from the exchange of principal. Because Company C has borrowed euros, it must pay interest in euros based on a euro interest rate. Likewise, Company D, which borrowed dollars, will pay interest in dollars, based on a dollar interest rate. For this example, lets say the agreed-upon dollar-denominated interest rate is 8. 5%, and the euro-denominated interest rate is 3. 5%. Thus, each year, Company C pays  ¬40,000,000 * 3. 50% =  ¬1,400,000 to Company D. Company D will pay Company C $50,000,000 * 8. 25% = $4,125,000. As with interest rate swaps, the parties will actually net the payments against each other at the then-prevailing exchange rate. If, at the one-year mark, the exchange rate is $1. 40 per euro, then Company Cs payment equals $1,960,000, and Company Ds  payment would be $4,125,000. In practice, Company  D would pay the net difference of $2,165,000 ($4,125,000 $1,960,000)  to Company C. | Figure 3: Cash flows for a plain vanilla currency swap, Step 2| Finally, at the end of the swap (usually also the date of the final interest payment), the parties re-exchange the original principal amounts. These principal payments are unaffected by exchange rates at the time. | Figure 4: Cash flows for a plain vanilla currency swap, Step 3| Who would use a swap? The motivations for using swap contracts fall into two basic categories: commercial needs and  comparative advantage. The normal business operations of some firms lead to certain types of interest rate or currency exposures that swaps can alleviate. For example, consider a bank, which pays a floating rate of interest on deposits (i. e. , liabilities) and earns a fixed rate of interest on loans (i. e. , assets). This mismatch between assets and liabilities can cause tremendous difficulties. The bank could use a fixed-pay swap (pay a fixed rate and receive a floating rate) to convert its fixed-rate assets into floating-rate assets, which would match up well with its floating-rate liabilities. Some companies have a comparative advantage in acquiring certain types of financing. However, this comparative advantage may not be for the type of financing desired. In this case, the company may acquire the financing for which it has a comparative advantage, then use a swap to convert it to the desired type of financing. For example, consider a well-known  U. S. firm that wants to expand its operations into  Europe, where it is less well known. It will likely receive more favorable financing terms in the  US. By then using a currency swap, the firm ends with the euros it needs to fund its expansion. Exiting a Swap Agreement Sometimes one of the swap parties needs to exit the swap prior to the agreed-upon termination date. This is similar to an investor selling an exchange-traded futures or option contract before expiration. There are four basic ways to do this. 1. Buy Out the Counterparty Just like an option or futures contract, a swap has a calculable market value, so one party may terminate the contract by paying the other this market value. However, this is not an automatic feature, so either it must be specified in the swaps contract in advance, or the party who wants out must secure the counterpartys consent. . Enter an Offsetting Swap For example, Company A from the interest rate swap example above could enter into a second swap, this time receiving a fixed rate and paying a floating rate. 3. Sell the Swap to Someone Else Because swaps have calculable value, one party may sell the contract to a third party. As with Strategy 1, this requires the permission of the counterparty. 4. Use a Swaption A  swaption  is an option on a swap. Purchasing a swaption would allow a party to set up, but not enter into, a potentially offsetting swap at the time they execute the original swap. This would reduce some of the market risks associated with Strategy 2.. Conclusion Swaps can be a very confusing topic at first, but this financial tool, if used properly, can provide many firms with a method of receiving a type of financing that would otherwise be unavailable. This introduction to the concept of plain vanilla swaps and currency swaps should be regarded as the groundwork needed for further study. You now know the basics of this growing area and how swaps are one available avenue that can give many firms the comparative advantage they are looking for.

Tuesday, November 26, 2019

Cinematography in Fight Club essays

Cinematography in Fight Club essays Both the cinematography and editing often have an important role in portraying to the viewer the underlying themes and ideas being communicated by a particular films plot. David Finchers film Fight Club is an excellent example of how various editorial and cinematic effects can greatly reinforce the themes of a film as well as create the an appropriate atmosphere in order to further enthrall the viewer into its plot. In Fight Club the protagonist unknowingly has a severe split personality disorder and is portrayed by two characters, the narrator played by Edward Norton and Tyler Durden played by Brad Pitt. While the fact that these two are actually the same person is not made known to the viewer until the end of the film, the majority of the film is spent creating a dichotomy between the behaviors and ideals of these two characters in order to shock the unsuspecting viewer upon discovering the truth about the protagonist. In a larger sense the differences between the protagonists con flicting personalities reflect differences inherent in the entire social structure of modern America. In making Fight Club David Fincher, as well as the films entire production team use a great deal of editing effects and cinematography in order to illustrate the dichotomy between, not just Tyler and the narrator, but also their conflicting ways of life. One of the most important methods used in showing the differences between the narrators stereotypical yuppie lifestyle and Tylers self destructive, anti-establishment driven compulsion is the lighting and color used in various scenes throughout the film. Places such as the narrators condo and workplace are always well lit and seem to be in perfect order. The color schemes of such places, as well as the outfits worn by the narrators coworkers and neighbors usually consist of neutral, non-flashy colors such as whites and gray and seem generic and typica...

Friday, November 22, 2019

With Practice

With Practice I once took the AWAI course for copywriters. You know the one. Its where they talk about six-figure income from copywriting and how to earn some serious bucks once you take their course. They asked me to be an affiliate, and I did it for a long while, but one condition was that I receive a copy of the first course to study. Yes, it was a legit course. The advice was sound. I endorsed it for a long while. One of the simplest lessons in the course, however, amazed me. They advised to simply copy down existing letters used in commercial campaigns, written I felt like I was copying my mothers cursive writing as a child. Id read a line, then write it. Read another line, then write it. The logic was that there is power in muscle memory. When we repeat something, we retain it in our minds. After all, we practice sports over and over to get it right. Sewing, running, painting, singing, whatever it is, the more werepeat the drills, the closer we get to doing the task well. Using that theory, you can copy great pages of writing Before you holler plagiarism, I assure you that the exercise does not mean that you copy the work into your own story. And it does not mean that youll accidentally spit out three paragraphs of JK Rowlings words into your story and not know it. Butyou will absorb some of her techniques. Greg Digneo wrote a post on Boost Blog Traffic last week called The Brain-Dead Simple but Astonishingly Effective Way to Become a   Better Writer. Imagine how my brows rose when I saw this blog post telling other bloggers to copy great blog posts to learn how to   master blogging. ( http://boostblogtraffic.com/better-writer/ ) What I found fascinating in Gregs post, however, was that Picasso learned how to paint so well You learn to write without so much passive voice.You learn to write more colorfully.You learn to write in a certain verb tense better.You learn to write a particular point of view better.You learn to diversify your sentence structure better.And the list goes on and on Dont want to copy the pages verbatim? Then read them over and over. Your mind is a phenomenal sponge. It absorbs. It learns when you dont think its learning. Make yourself read great works, repeatedly, and the skills sink in. Or you could practice writing them, pretending youre in the mind of a great author, hoping some of that magic sloughs off on you.

Thursday, November 21, 2019

MG3122 STRATEGIC MARKETING Essay Example | Topics and Well Written Essays - 2000 words

MG3122 STRATEGIC MARKETING - Essay Example 2.0 John Lewis John Lewis is renowned departmental store chain of United Kingdom. The store chain has expanded business throughout the country within last hundred years. The company is headquartered at London, United Kingdom. The departmental store chain was founded by John Lewis in the year 1864. In the initial period the organization started their operation as single store but soon they transformed their business model into departmental store chain with the help of John Lewis Partnership. 2.1 John Lewis Partnership The partnership model gives opportunity to employees to gain partial ownership and contribute as stakeholder to business operation of the departmental store chain. John Lewis Partnership provides partial ownership or partnership benefits to existing thirty nine thousand employees of the company (McCallion, 2010). The John Lewis Partnership has won 'Retailer of the Year' in the year 2011. Recent report published by the company shows that they have more than 81,000 permane nt staff as well as partners. John Lewis has been ranked as one of premium departmental store chains of United Kingdom. They have already opened thirty eight outlets and also planning to establish strategic business units in foreign shore within next five years. The London based departmental store chain has achieved annual gross sales revenue of ?8.7bn in the year 2011 (John Lewis Partnership, 2012). 2.2 Business Strategy Business model of the company can be understood in the following manner. The company operates with 30 departmental stores across United Kingdom in order to provide multi brand products to customers The company has opened eight John Lewis at home stores They have also established 285 Waitrose supermarkets for selling products on online platform Business strategy of the company relies on three interdependent variables such as s Partners, profit and customers in order to achieve sustainable business growth. Strategic initiatives of the company can be analyzed in the f ollowing manner. Providing maximum sustainability and security to partners in order to motivate them to perform well. The company has understood that satisfied partners can help them to improvise in daily operation which will help them to increase operational excellence. Partners need to emphasize on recruiting and retaining loyal customers through providing them excellent customer triads such as quality, service and price. The company tries to retain sufficient profit margin for partners in order to sustain commercial vitality of the company. John Lewis distributes profits to staffs and partners on regular basis in order to motivate them to perform well (John Lewis Partnership, 2012). 3.0 Industry Overview John Lewis has cemented a premier position in retail and departmental store industry. The company faces competition in the field of Furniture Manufacturing, Consumer durable Manufacturing, Textile Manufacturing and Grocery Supermarket. ASDA Group, Arcadia Group, Marks & Spencer a nd Argos Limited are major competitors for John Lewis. Swedish furniture retailing giant IKEA has recently entered in retail

Tuesday, November 19, 2019

Mechanical engineering Essay Example | Topics and Well Written Essays - 1250 words - 1

Mechanical engineering - Essay Example Because of this blatant impunity that led to massive environmental degradation, global warming crept in altering the global climate for worse. The wanting state of global climate has been a major force behind the dedication that manufacturers across the world have show towards developing new technologies that are environmental friendly unlike the past. The advancement in technology has focused on improving efficiency to the optimum, while focusing on causing as minimal destruction to the natural environment as possible. Several scholars have dedicated their time to finding new technologies in the field of engineering and one can access numerous resources pointing out at the milestones that engineering technology has achieved over the years. The biggest question is: how is advancement in technology significant to engineering field as well as the current and future world? While some sources (Simister; Dodgson; and Conding et al.) postulate that improvement in engineering technology will improve efficiency and making life better, others (Mayer; and Elektorowicz) hold that new engineering technologies are developed with the idea of environment conservation, which is a crucial factor for reducing global climate change. The purpose of this paper is to explore various sources of information relevant to back up the claim that advancement in technology is crucial for high efficiency level and environmental conservation. In her article The Sport-Utility Vehicle: Debating Fuel-Economy Standards in Thermodynamics, Shannon Mayer discusses Fuel-Economy Standards in Thermodynamics, declaring that the world of the 21st century faces critical problems because of the persistent increase in the rate of population. According to her, the world needs engineers with technical experience and critical thinking ability in order to analyze and develop mitigation strategies. In her paper,

Sunday, November 17, 2019

School Life in the 1950s Essay Example for Free

School Life in the 1950s Essay School Life in the 1950’s was harder than today because the facilities were few and inadequate. Teachers were stricter and corporal punishment was still in use. They had fewer subjects and wealth, discrimination, sexism and racism meant they could only do certain subjects. After World War 2 there was a baby boom and as a result in the 1950’s schools were quickly filling up as the children enrolled. The enrolments increased as much as 30% over the ‘baby-boomers’ decade. In the year 1950 there were 166 437 existing elementary and secondary schools in the USA to educate over 29 million students. As the amount of students increased, the schools and resources declined. It was reported by the Office of Education in 1953 that there was a shortage of 345 000 classrooms, meaning overcrowding in 60% of America’s classrooms and up to 20% of schools failed to meet basic safety standards (statistics- www. encyclopedia. com/doc/1G2-3468301830. html 6/08/2013) School facilities were even more unpleasant for the coloured people of America. Their schools were separate from the white people and they were poorly funded by the government. â€Å"By 1950, the inequality in educational achievement between white students and minority students had increased since 1900, when very few Americans or and race or gender attended high schools, and formal education was only marginally a factor in national economic and social life†- historians Mondale and Patton. (www. illinoishistory. gov/Illinois%20History/Jan05-21Vargas. pdf 14/08/2013). This all changed in 1954; when a father named Mr Brown took his case to the United States Supreme Court declaring his daughter should be allowed to go to school with white children. â€Å"Mr Brown was upset that his daughter had to walk over a mile through railroad yards to get to a black school when a white one was only seven blocks away† (www. livinghistoryfarm. org/farminginthe50’s/life_12. html 14/08/2013). The United States Supreme Court declared a â€Å"Separate but equal† system (desegregation) in schools and made a start on ending discrimination in other institutions. The country school buildings were usually â€Å"made of wood with weatherboards outside and tongue-and-groove timber for the interior walls. Most schools were elevated on stumps to provide a rudimentary play area underneath, which was usually concreted. The rough-hewn stumps would be painted with tar to deter white ants, and constant checking of stumps, walls, toilets and even toilet seats for termites was part of the head teacher’s job†. Up the front of the classroom there were â€Å"two large blackboards, almost square in shape, fixed to the wall. Sometimes an extra blackboard would stand on an easel as well. A wooden cupboard with doors, known as a ‘press’, held all the class books and teaching materials. There was usually no other shelving† (www.starfieldobservatory. com/Nambour/Schooling. html 14/08/2013). The school facilities in 1950 were basic and inadequate and the students and teachers had to make do with what they had. The schools of 1950 were lacking equipment but one piece of equipment was most certainly not lacking in most schools and that was the cane or ruler. Teachers used the cane to spank the disobedient and troublesome students and it was usually very effective – â€Å"I really can’t remember kids sort of stepping out of line very much because they knew that they would be getting disciplined severely. There was very little leeway, but then again, there were very little problems† – Student in 1950 (www. angelfire. com/falcon/hist232/interviews%20l. html 14/08/2013). The main reason students got spanked were: â€Å"talking or being disruptive in class, not lining up properly or being rambunctious either inside or outside the school† (www. angelfire. com/falcon/hist232/interviews%20l. html 14/08/2013). Teachers could cane across the hand or across the buttocks or often slap around the head without fear of punishment, as the offence was â€Å"caused† by the child. If the offence was viewed serious enough the student went to the headmaster for ‘6 of the best’ with a heavy cane. â€Å"They used the cane a lot, usually first resort not last. She said it was normal for girls to get the cane in front of all the class with skirt, or as it was for her, gymslip raised up. They could get 2, 3, 4 strokes in front of class, occasionally some got 6 strokes. But if it was thought serious they were sent to the headmaster. Always bare off headmaster, skirt up knickers down. Six minimum, could be up to 12. She said it was normal to see someone being caned† (http://www.experienceproject. com/stories/Used-To-Get-The-Cane-At-School/2211915 16/08/2013). There was no appeal against that system of punishment and many parents believed the teacher was acting in the child’s best interests. Other methods of punishment were intimidation, strapping, removal from class, loss of privilege, writing lines and verbal put-downs were all regularly used. As stated before, the class numbers were increasing so teachers had to teach more students, meaning discipline was becoming more stringent as the teacher tried to keep the class in control. The 1950’s was the time of the cold war and there was a great tear of nuclear war. In certain areas of America the ‘fallout’ tests were being brought in where the students were required to go through a fake atomic bomb attack and they would find refuge under their desks (little did they know this wouldn’t protect them from radiation! ). It was more for the teacher and parent’s piece of mind. Teachers of 1950 were sterner and more stringent than today, corporal punishment was in use making sure students did all their work and behaved in the right manner. The main subjects taught to high school students in the 1950’s were reading, writing, arithmetic, history, biology, domestic science or home economics and woodwork, â€Å"Social sciences, history, geography, sociology, economics, political science, and psychology† (http://www. viu. ca/homeroom/content/topics/programs/Curriclm/ss1950. htm 16/08/2013). Some more advanced subjects like music, trigonometry, Latin or Spanish and algebra, were added to the richer schools as it was rare to find a decent and qualified teachers. In nearly all schools it was â€Å"necessary† for girls to do domestic science and learn the skills of cooking and needlework. For the boys it was â€Å"necessary† for them to do woodwork or woodshop and learn the skills of craftsmanship. Girls couldn’t do the ‘boy’ subjects and vice versa. Science was taught theoretically and there was rarely a chance for them to do experiments. Subjects were taught in a ‘chalk and talk’ system where the teacher would stand up at the front of the classroom and talk to the class and write the topic information on the chalkboard. The students would listen and copy the work into their books. It wasn’t very common for students to do practical work and field trips were very basic. In the out of the way country schools teachers had to teach many subjects and most didn’t just have their certain subject they specialised in, meaning the teachers most of the time weren’t fully trained to be teaching some subjects and were giving out false information. (http://www. livinghistoryfarm. org/farminginthe50s/life_12. html 16/08/2013). The black people schools had limited teachers and facilities. Most of their schools just had the basic subjects and it was only after 1954 when the Supreme Court announced desegregation did this change and the black people were allowed to go to school with the white people and have access to their assortment of subjects. â€Å"The subjects taught in elementary school were maths, reading, social studies, science, art and music† (http://library. thinkquest. org/J002606/1950-60S. html 14/08/2013). Although music was usually just a basic sing-a-long with the teacher and it would happen once, maybe twice a week. The schools in the 1950’s didn’t have the variety of subjects we have today and it was limited even more because of many social issues such as racism, sexism and families wealth. School life was harder in the 1950’s because of the lack of facilities and their poor conditions, the students had to cram into overcrowded dingy classrooms and the coloured children had to walk miles to get to their black people schools. Schools were stricter and corporal punishment meant teachers were allowed to hit the students on the hand or over the head and parents let this happen as they believed it was good for the their child. The assortment of subjects choices available to the students in the 1950’s was limited and became even less as social issues such as racism, sexism, wealth and discrimination got in the way. The children and teens of 1950’s had to put up with an inadequate education system nevertheless many went on to become successful in business and life. Bibliography Anali Vargas, ‘Some Major Differences Between High School in the 1950’s and Now’-Page 4, www. illinoishistory. gov/Illinois%20History/Jan05-21Vargas. pdf, August, 2013 Going to school in the 1940’s and 50’s, www. starfieldobservatory. com/Nambour/Schooling. html, August, 2013 The 1950’s: Education: Overview. â€Å"American Decades† http://www. encyclopedia. com/doc/1G2-3468301830. html, August 13, 2013 Farming in the 1950’s: Education in rural America http://www. livinghistoryfarm. org/farminginthe50s/life_12. html, August 2013 Vanessa Lockstein, Ontario School discipline, 1950-Present www. angelfire. com/falcon/hist232/interviews%20l. html, August 2013 Schooling in the 1950’s. http://library. thinkquest. org/J002606/1950-60S. html, August 2013 Senior High School: 1950 http://www. viu. ca/homeroom/content/topics/programs/Curriclm/ss1950. htm, April 2005.

Thursday, November 14, 2019

Can You Love Someone Too Much? Essay -- essays research papers

What a question to ponder! I have tried writing this essay many times and have realized that this is a very difficult topic. â€Å"Is it possible to love someone too much?† If you look at the question you first must define what love is and what it means to you before you can determine if it is actually possible to love someone too much. The Webster Dictionary defines love as â€Å"profoundly tender, a passionate affection for another person†. In my opinion, to love someone is to care not only about them as a person but also about their well being. You can love a person even if that individual does not feel the same way about you, or if the person just doesn’t understand why you are feeling this way toward him or her. It’s like when you’re a little kid and your parents tell you all the stuff not to touch, not to do, and they keep on reminding you over and over again. They’re reminding you constantly, not to get on your nerves, but because they don’t want you to get hurt. They love you, and because of this strong feeling of love, they want to make sure you are safe. To love someone is to have such strong feelings, so deeply felt that your life would not be complete or the same without them. You would do anything in the world to be with them and you will do absolutely everything for them because it feels good and right. This reminds me of a song by Canadian artist Brian Adams Everything I do I do it for you. He sings of a strong love in this song. A love that everything he does makes...

Tuesday, November 12, 2019

Equity and Trusts: Barnes V Addy Second Limb

Introduction This paper examines the development and scope of accessory liability under the second limb of Barnes v Addy as it stands in both England and Australia. As to the law in England, the focus will be on the rearticulation of the principle of accessory liability under the second limb as stated in Royal Brunei Airlines Sdn Bhd v Tan. In particular, it will consider the extent to which the decision has reconciled inconsistencies in earlier authority and remedied those issues propounded to be inherent in the traditional formulation of the principle. At this stage, this traditional principle remains good law in Australia.However, as suggested in Farah Constructions Pty Ltd v Say-Dee Pty Ltd, there is potential for the English approach to be adopted in the Australian context. Such an adoption may be advisable in light of the judicial and extra-judicial commentary suggesting that the orthodox approach is in fact not properly aligned with equitable principles. The discussion of this possibility involves not only an assessment of the advantages and disadvantages of each approach, but also a determination as to the extent to which the separate application of each approach could result in a divergent outcome.The development of the second limb of Barnes v Addy in Australia- ‘knowing assistance’ The classic authority on the circumstances in which third parties will be held accountable for their involvement in a breach of trust or fiduciary duty is the English case of Barnes v Addy. It was in this case that Lord Selbourne LC articulated the much cited and analysed statement of principle that has come to form the modern law: †¦ trangers are not to be made constructive trustees merely because they act as the agents of trustees†¦unless those agents receive and become chargeable with some part of the trust property, or unless they assist with knowledge in a dishonest and fraudulent design on the part of the trustees. This statement has come to be understood as allowing liability to be imputed on a party in two distinct circumstances, where the third party either knowingly receives trust property, or assists with knowledge in a breach of trust or fiduciary duty.This paper seeks only to consider the latter. In what ostensibly remains the authoritative case on this second limb of Barnes v Addy in Australia, the High Court in Consul Development Pty Ltd v DPC Estates Pty Ltd, (‘Consul Development v DPC’) not unlike other cases at the time, focussed predominantly on the level of knowledge which would be sufficient to attract accessory liability in the circumstances before them.The primary question was not one of the dishonesty or otherwise of the actions of the third party, but of that third party’s knowledge of the dishonesty of the fiduciary. The majority, it seems, realised that the terms ‘constructive notice’ and ‘actual notice’ did not in themselves comprise the requisite sophisti cation for dealing with the matter of the knowledge of the third party.They instead expressed the required degree of knowledge within particular parameters, with neither Stephen J nor Gibbs J willing to extend these parameters to include a negligent failure to inquire on behalf of the third party. In Equiticorp Finance Ltd v Bank of New Zealand, Kirby P (in dissent) indicated support for the Consul test of knowledge, and attempted to clarify the judgement in Consul Development v DPC with reference to the decision in Baden, Delvaxs & Lecuit v Societe Generale pour Favoriser le Development du Commerce et de L’Industrie en France SA (‘Baden’).He equated the degrees of knowledge set out by the High Court in Consul Development v DPC with the first four categories as stated in Baden thereby confirming that both actual and constructive knowledge, but not constructive notice, would constitute the requisite degree of knowledge necessary to render a third party liable unde r the second limb of Barnes v Addy. Similar findings have been made in later cases where Consul Development v DPC has been declared authority on the matter, although such an explicit reference to the Baden scale is not always present.Conversely, other judges have found the judgement in Consul Development v DPC to be inconclusive, adopting a narrow interpretation of the judgement of Stephen J and restricting the requisite knowledge only to the first three categories of the Baden scale. This tendency toward a narrow approach increased following the decision in Royal Brunei Airlines Sdn Bhd v Tan (‘Royal Brunei’) as courts attempted to reconcile the UK and Australian lines of authority.However in other cases, such as Gertsch v Atsas it was held that that the acceptance of the first four Baden categories was synonymous with accepting a standard of honesty. Given the discordant state of the Australian authorities, the High Court took the opportunity in Farah Constructions Pt y Ltd v Say-Dee Pty Ltd, (‘Farah Constructions’) to clarify the Australian position on knowing assistance.Their Honours declared, in obiter, that Australian courts should continue to follow the decision in Consul Development v DPC, thereby continuing to see as necessary the requirement of a dishonest design on the part of the fiduciary, and subscribing to the proposition that where the third party’s knowledge falls within the first four categories of the Baden scale it will answer the requirement of knowledge under the second limb of Barnes v Addy.In what has been referred to as a â€Å"profound shift in the rules of judicial engagement† following Farah Constructions, lower courts have regarded themselves as obligated to follow the obiter of the High Court and have thus returned to an orthodox approach. However, the law in Australia is far from settled on this point and a case is yet to come before the High Court with the facts necessary to allow for a rec onsideration of the principles enunciated by the Privy Council in Royal Brunei. The development of the second limb of Barnes v Addy in England- ‘dishonest assistance’While in Australia the courts are returning to an orthodox approach towards accessory liability, in England, the courts are grappling with a reformulation of the principles under the second limb of Barnes v Addy following the decision in Royal Brunei. In this case, the Privy Council refocussed the relevant inquiry in cases concerning liability under the second limb of Barnes v Addy away from the third party’s knowledge of the trustee’s dishonesty, to the dishonesty of the accessory themselves.Consequently, the dishonesty (or lack thereof) of the trustee or fiduciary is irrelevant as it is the dishonesty on the part of the accessory that attracts liability. There is nothing new about the application of a dishonesty-based in inquiry into the liability of accessories to a breach of fiduciary duty , with Lord Nicholls suggesting that before the inquiry â€Å"donned its Barnes v Addy strait-jacket† judges hadn’t regarded themselves as confined to inquiries into the levels of knowledge of the accessory.It may even be said that the dishonesty-based inquiry had retained its place in contemporary law prior to Royal Brunei, and that it was merely obscured by the additional and more tedious requirement of determining the level of knowledge of the accessory. For example, in Agip (Africa) Ltd v Jackson Millet J stated: There is no sense in requiring dishonesty on the part of the principal while accepting negligence as sufficient for his assistant.Dishonest furtherance of the dishonest scheme of another is an understandable basis for liability; negligent but honest failure to appreciate that someone else's scheme is dishonest is not. This can be set alongside other cases which suggest that that the requirement of dishonesty on the part of the principle is in fact a compel ling reason not to require dishonesty on the part of the fiduciary, as they are an ‘accessory’ who merely needs to be is linked to the conduct of the principle. Millet J, however, seemingly wishes to see this principle extended, so that dishonesty is required on the part of both parties.The decision in Royal Brunei does not precisely echo this formulation of the dishonestly principle (Lord Nicholls ultimately went on to conclude that that the fiduciary need not be dishonest at all in order for the accessory to be held accountable), but instead clarifies and affirms a general principle in light of other commentary on the point. Consequently, Lord Nicholls in his judgement has set out what is necessary for the inquiry into the accessory’s dishonesty, stating that courts should look to determine whether the person acted â€Å"as an honest person would in the circumstances† in light of their actual knowledge at the time.He further explains that the question sh ould be approached objectively and indicates that the test is not one of the ‘reasonable person’. He seeks to clarify this test of dishonesty with the following examples: If a person knowlingly appropriates another’s property, he will not escape a finding of dishonesty simply because he sees nothing wrong in such behaviour†¦Honest people do not knowingly take other’s property†¦[or] participate in a transaction if he knows it involves a misapplication of trust assets to the detriment of the beneficiaries.Nor does an honest person in such a case deliberately close his eyes and ears, or deliberately not ask questions, lest he learn something he would rather not know, then proceed regardless. This passage, while meant to further explain the test for dishonesty, initially seems difficult to reconcile with later comments, where his Lordship makes explicit reference to the departure from the orthodox inquiry into degrees of knowledge, stating that the w ord â€Å"knowlingly† should be avoided and that the Baden scale was â€Å"best forgotten†.While it seems unproblematic to abandon the Baden scale of knowledge, commentators and courts alike have found difficultly in divorcing the concept of dishonesty from knowledge itself and the most recent authoritative decision on the point Barlow Clowes International Ltd v Eurotrust International Ltd (‘Barlow Clowes’) confirms that an inquiry into dishonesty does to some degree require an inquiry into the knowledge of the third party. Comparison of the English and Australian position One of the objectives of the court in Royal Brunei was to remedy some of the problems with the orthodox approach to accessory liability.Such problems were not only present in English courts, but have also plagued Australian courts and were not resolved in by the High Court’s affirmation of the knowledge-based test in Farah Constructions. Firstly, Lord Nicholls in Royal Brunei soug ht to realign the principles of accessory liability with equitable doctrines and focussed primarily on the conscience of the accessory themselves. In the orthodox approach, as expressed in Consul Developments v DPC, the inquiry is not into the state of mind of the accessory themselves but into the accessory’s knowledge of another’s state of mind.It has been suggested that the inquiry has thus been misplaced, and that although it results in an indirect finding of dishonesty on the part of the accessory, it is much further removed from equitable principles than the Royal Brunei approach. Lord Nicholls also sought to do away with the confusion surrounding the need for judges to distinguish between the different levels of knowledge, in particular constructive knowledge and constructive notice.However, as noted above, Lord Nicholls on several occasions makes reference to the knowledge of the accessory which is the reason that the degree to which the test of dishonesty is di vorced from an inquiry into knowledge has been questioned. However, what must be realised here is that the inquiry into knowledge that is embarked upon as part of the dishonesty based approach is different to that which was required under the knowledge based approach.This redirection for the knowledge inquiry was first considered in Twinsectra Ltd v Yardley where a difficulty arose in determining whether Lord Nicholls had intended for an objective or subjective approach to be taken to dishonesty. In the leading judgement, Lord Hutton tendered the â€Å"combined test† which required that the third party’s conduct be dishonest by the standards of the reasonable person as well as requiring an appreciation by the third party that by those standards his or her conduct was dishonest.This combined test endured much academic criticism and was seen as being inconsistent with the objective test enunciated by Lord Nicholls in Royal Brunei. The Privy Council, and in particular, Lo rd Hoffman (who was in the majority in Twinsectra Ltd v Yardley) had the opportunity in Barlow Clowes to clarify the comments made in Twinsectra Ltd v Yardley. It was stated that the majority in Twinsectra Ltd v Yardley had, in fact, always espoused a test in line with that which was conceptualised in Royal Brunei and it was commentators who had skewed this test into a different form.Despite the contempt that many commentators had for this account, the statement of a complete principle of dishonest assistance was applauded. Incorporated in this principle was the conclusion that the liability of the accessory was not dependant on a requirement for fraud or dishonesty on the part of the fiduciary, but depended solely upon whether the accessory was at fault. This is the converse position of the orthodox approach, whereby a third party can escape liability even where they know they are assisting in a breach of fiduciary duty, provided that the fiduciary was not acting dishonestly.Thomas J in Powell v Thompson held that protecting a person with a guilty conscience in this manner was not in line with equitable principles, and his consequent assertion that the conduct of the principle should be irrelevant was later approved in Brunei. One significant consequence of the divergent approaches in what are currently the UK and Australian positions on this matter would be the substantial difference in outcome in cases where the fiduciary had acted innocently.Provided that all other requirements are satisfied, in the UK the accessory would be held liable however in Australia they would not. Further to this, while some Australian judges have found it difficult to distinguish the traditional approach from that of Royal Brunei, the fact that the orthodox reliance on the Baden scale restricts investigations only to knowledge and not to other attributes or types of conduct, lends weight to the argument that in certain circumstances there would be divergent outcomes of the two ap proaches. Perhaps, it is best to take FarahConstructions as authority on this point, with the High Court in this case imputing that one of the reasons it is directing courts to treat the approaches distinctly is due to the potential for the different formulations of the principle to lead to different results. Conclusion In line with the arguments presented in this paper, it is submitted that the approach to accessory liability espoused in Royal Brunei is preferable to that which was propounded in Consul Development v DPC due what is an ostensible irreconcilability of the latter case with conventional equitable doctrines.This assertion turns on the manner in which the judges in Consul Development v DPC dealt with the requirement for a dishonest and fraudulent design on the part of the fiduciary as per Lord Selbourne LC in Barnes v Addy. Like many other cases at the time, Consul Development v DPC was concerned more with attempts to define what Lord Selbourne had meant by a â€Å"dish onest and fraudulent design† rather than questioning whether it was an appropriate criterion for the imposition of liability on a third party.Consequently, when it came to fulfilling equity's calls as to inquiries into the conscience of the defendant, courts were misguided and came to focus instead on the conscience of the principle. The arguments in favour of the retention of this approach are largely set out in reliance on the requirement that the third party be implicated in the conduct of the fiduciary. However, as suggested in Royal Brunei, assistance in itself should be enough to draw a sufficient connection between the accessory and the fiduciary.It was this realisation which enabled Lord Nicholls in Royal Brunei to reformulate the principle under the second limb of Barnes v Addy so as to redirect inquiries into the minds of defendants to their appropriate place in accordance with equitable principles. Although the adoption of the approach in Brunei may not result in ma jor shift in the law of accessory liability in Australia, it’s contemplation of circumstances in which the third party can be held liable even where the fiduciary is innocent would at the very least resolve the seemingly inequitable approach to this point as it stands in current Australian law. 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