Thursday, October 31, 2019
MGM604-0802B-01 Organizational Behavior - Phase 1 Discussion Board Essay
MGM604-0802B-01 Organizational Behavior - Phase 1 Discussion Board - Essay Example servation of Kreitz 2008, p.101, ââ¬Å"just as mono-cropping destroys biological diversity, and, in extreme cases, human as well as natural ecosystems, mono-managing similarly destroys diversity within organizations.â⬠The modern business world has proceeded well beyond the legally protected aspects of diversity such as race, gender and age, to embrace a much broader spectrum of diversity that virtually takes into consideration almost every aspect of human differences (Jayne & Diboye, 2004). Such a broad perspective of diversity requires that diversity be seen as having domestic dimensions and international dimensions. According to Loden and Rosener, 1991, the primary dimensions to domestic diversity are, race, gender, sexuality, ethnicity, physical abilities and characteristics. These differences may be taken as resident differences that is present in the work force of any country, within which operate the secondary dimensions of diversity in the form of work experience, education background, geographic location, military experience, income, marital status, parental status and religious beliefs. Thus while dealing with a training program that addresses diversity to a workforce audience from a nat ional perspective it may be sufficient to consider just the primary dimensions and secondary dimensions of domestic diversity. In a country like the United States of America, where there is a coming together of different cultures and in addressing an international work force, it becomes necessary to understand the international dimensions to diversity that is brought about by the culture or cultures that need to be addressed. Much of our understanding of the international dimensions of diversity is owed to Hofstede and his research project that has enabled us to focus on different cultures and not on the individuals that represent these cultures. The Hofstede understanding of international diversity gives us five dimensions or factors to it, which are power distance,
Tuesday, October 29, 2019
Graphic design and architecture Essay Example | Topics and Well Written Essays - 500 words
Graphic design and architecture - Essay Example Architecture and graphic design are fundamentally linked as communication tools, they may be coupled to create unique modern results, and the theory of design plays a role in cross-over of design elements between the two design disciplines. Architecture and graphic design are fundamentally applied forms of design, or those that work within a pragmatic framework and often designed for commercial applications (Andruchow). The two types of design share a fundamental goal: communication. Architectural design seeks to communicate to the viewer or occupant many different messages, ranging from practical issues such as how to navigate a building to more subjective areas, such as communicating the culture of the buildings intended occupants. Architecture used as a communication tool is particularly evident in modern constructions, such as the Prada building in New York, in which architecture is utilized to convey a brand image. The Prada building provides a unique example of the coupling of elements of graphic design with those of architectural design. The commonly accepted elements of design apply across the fields of design, and the Prada design leverages the elements of line, shape, texture, space, size, value, and color in both a three-dimensional architectural form and a two-dimensional juxtaposition of elements across the architectural form (Tuscaloosa K-12).
Sunday, October 27, 2019
Access Inclusion Participation Disability Sport Health And Social Care Essay
Access Inclusion Participation Disability Sport Health And Social Care Essay The Disability Discrimination Act (DDA) defines a disabled person as someone who has a physical or mental impairment that has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities. (DDA, 2005). Access and inclusion into sport and physical activity is difficult for many people with a disabiltiy therefor changes must be made to ensure that every person wishing to take part can do so. This could be changing the facilities so that access is better for disabled people as well as modifying equipment and training programs so that everybody can access the facilities. There are many schemes in place to help give disabled people the opportunity to participate in sporting activities. The Federation of Disability Sport Wales (FDSW) is a pan-disability National Governing Body of Sport. The aim of the scheme is to promote and develop quality sports opportunities for people with disabilities (Disability Sports Wales, 2004). Many studies have been carried out in an increased effort to find connections between disability and physical activity but despite this increased effort problems still remain. Many young disabled people would like to take part in physical activity and in a study the majority of people surveyed expressed a preference to participate in a sporting environment if it was organised within a disability sports. (EFDS, 2005). Sports for the disabled still remain an understudied area and should be improved greatly if it is to develop. A development for disability in sport is needed because there are people who cannot participate in sport because of reasons beyond their own control. For most disabled people, their disability is not the barrier and therefore more should be done to overcome barriers that could be easily eradicated (Barton, 1989) A physically active lifestyle is associated with many health and social benefits. This is also true for those individuals who have a disability or long term health condition. Physical activity can not only decrease the danger of secondary health problems but can also improve all levels of functioning (Hidde et al. 2004). The Disability Discrimination Act (DDA) defines a disabled person as someone who has a physical or mental impairment that has a substantial and long-term adverse effect on his or her ability to carry out normal day-to-day activities. (DDA, 2005) For people with a disability, accessing sporting activities can be difficult as there may not be many facilities to provide for them. Also the sports that they are able to access may not be suitable for them to be included therefore adaptations must be made to the sports to give them the opportunity to participate (Jette, 2003). This should include participation with able bodied participants also. There are schemes which run to organize safe and enjoyable sporting activities for disable people, as well as schemes that look to give access, inclusion and participation in sport for disabled and able bodied people alike (Finch et al, 2001). The Federation of Disability Sport Wales (FDSW) is a pan-disability National Governing Body of Sport. The aim of the scheme is to promote and develop quality sports opportunities for people with disabilities (Disability Sports Wales, 2004). This scheme is set in Wales but there are other schemes that work towards promoting and developing disability sport throughout the UK. This report will look at disability in sport. The main issues that will be looked at are access to take part in sports as well as the inclusion for disability in the sports. With these factors being identified, participation levels for disability in sport will be examined to see what areas of the UK are working towards giving equal opportunities for disabled children and adults. The project will study the schemes and look at how they help to allow access and inclusion to the sports and also the participation levels of disablity in sport. Rimmer et al, (2006) reported that an investigation was carried out into the accessibility of health clubs and leisure centres for people with mobility disabilities and visual impairments. The investigation studied thirty-five health clubs and fitness services in a nationalized field test in which a new piece of equipment was used. The Accessibility Instruments Measuring Fitness and Recreation Environments (AIMFREE), was used for measuring the ease of access of fitness amenities in the built environment, equipment, swimming pools, information, facility policies, and professional behaviour. All the facilities that the test was carried out on confirmed low to moderate levels of accessibility. Some of the deficiencies showed a cause for concern with the Disability Act guidelines regarding the built setting; other problems related to parts of the facility such as the equipment, information, policies, and professional staff (Davies, 2002). Many studies have been carried out in an increased effort to find connections between disability and physical activity but despite this increased effort problems still remain (Fitzgerald, 2008). Hezkiah (2005) stated that young disabled people demonstrated low levels of physical activity and perceptual motor difficulties compared to young people without a disability. This low level of activity and motor learning affects their ability to learn. Major barriers to young disabled people include language conception which is vital for following commands, and physical disabilities, which have an effect on their capability to carry out motor skills (Gatward and Burrell, 2002; Gordon and Williams, 2003). These limits can have an effect on their motivation and add to restricted opportunities for regular involvement in movement, physical activity and sports, which consecutively affects their capability to develop and progress in these important areas of growth and development. Finch et al (2001) set out to determine how important barriers linked with disability are to peoples levels of physical activity. During the study the participants were asked a series of questions to answer for a range of information, and were then asked to specify which physical activities they participate in. The subjects were asked to provide the reasons preventing their contribution in physical activities. No clear inclusion or exclusion information was given therefore the reasons would be their own personal feelings. Findings of the study have shown that 20% of the participants acknowledged current injury or disability as one of the barriers to additional physical activity, with half of the participants expressing it as the most important grounds as to why they do not take part in more physical activities. Current injury or disability was a barrier to physical activity in older people more often than younger participants. Injury or disability was the main difficulty to participate in physical activity for people who are obese based on their body mass index (BMI) more often than those who were underweight or normal weight. Another finding during the study suggested that current injury or disability was a major barrier for people who were not very active more often than people with a high current physical activity level. The findings suggested the importance to target the support of physical activity to older adults and overweight people particularly to get them active by giving them access to facilities along with the inclusion to the activities. They go on to identify the problems that can occur with disability. They state that a person would stop exercising because of a disability rather than just becoming overweight and not exercise because of the weight problem. Rimmer et al (2004) recognized a variety of barriers and facilitators that were associated with participation levels in health and leisure programs and amenities amongst persons with disabilities. The results showed that the participants reported 178 barriers and 130 facilitators. The problems identified were barriers and facilitators connected to the built and natural environment along with economic issues. Emotional and psychological barriers were also identified as a problem. The amount of involvement in physical activity among people with disabilities is affected by a multi-factorial set of barriers and facilitators. Future research could utilize information conducted by Rimmer et al (2004) to develop participation schemes that have a superior probability of accomplishment. A report from the EFDS, (2005) showed that whilst young disabled people valued sport and recreation opportunities, they do not access their chances for physical activity on a regular basis. Disability is not a barrier to participation in sport and leisure. Regardless of rising guidelines and legislation encouraging improved participation in sports and physical exercise by young disabled people, only a restricted quantity of young disabled people do take part in physical activity. Only a small number of young disabled people have access to sport and physical activity opportunities outside the activities obtainable inside curricular time which includes after-school clubs, community opportunities, and general play. The most significant factor that was found to have an effect on physical activity involvement was the persons impairment, with those with multiple impairments less probable to take part than those with a single impairment (Maloney et al, 1993). The most frequent curriculum sports linked with impairment groups and genders were Swimming, Boccia, Ball Games, Football, Athletics, and Cricket. Swimming, Football, Badminton, and theme parks were the most frequent sports and activities participated in, in a community setting. Activities such as Swimming, Boccia, Athletics and Horse Ridding had an important position for the young disabled people with multiple impairments. Barriers to participation included access to facilities and equipment. Improvements in facilities and access to equipment would improve access to sports and recreation opportunities (Williams, 2005) In studies, young disabled people have expressed a fondness for taking part in physical activity when participating in a sporting environment particularly if it was organised within a disability sports club with other people with comparable impairments or an after school club with friends. With consideration to the type of activity, results showed that young disabled people would like to participate in activities that young disabled people already participating in (EFDS, 2005). There are many initiatives set up to give people with a disability an opportunity to participate in sport and physical actvity (Norwich, 2007). The Inclusive Fitness Initiative (IFI) is a proposal that supports the fitness production to develop into a more inclusive plan that can cater for the needs of both disabled and non-disabled people alike. Through a variety of developments, the initiative has maintained facilities across England to produce a comprehensive service which results in increasing participation levels by disabled people. Parasport is a combined proposal between the British Paralympic Association (BPA) and the services services firm Deloitte. Their aim is to amplify participation levels in competitive sporting events. Parasport aims to improve how talented sports people are being identified and aims to support them at a community level. They plan to provide bursaries to talented and high potential athletes through a partnership with SportsAid. With this help they also set out to establish a new Disability Sports Institute known as Parasport, run by the BPA. The BPA is the body responsible for the elite side of disability sport, although the Parasport project is open to all abilities. Another initiative in place is The Talented Athlete Scholarship Scheme (TASS). This scheme is set up in England and aims to help young and talented athletes who are committed to combining their sport and education to make themselves better. Currently there are 50 sports eligible for TASS, of which 16 are disability sports. This scheme is open to people aged between 16 and 25, with an upper age limit of 35 for people with a disablity. The scheme can provide a package of sporting activities to athletes and give them the ability to access high quality training facilities. An athletics initiative has been launched in by the Sports Council Wales to encourage more children with disabilities to participate in sport. Combined with the Federation of Disability Sport Wales, athletics sessions have been introduced where children can take part in fun sessions with skilled volunteers from Welsh Athletics. The Disability Sport Wales National Community Development Programme is a joint initiative set up between the Sports Council for Wales, the Federation of Disability Sport Wales and 22 local authorities across Wales. The proposal aims to develop excellent community based sporting and leisure opportunities for disabled people throughout Wales (Hughes, 2009) Arthur and Finch (1999) said that people with a disability might recognise the physical and social benefits resulting from participating in physical activity generally. However, a failure to recognise specific guidelines on the necessary frequency and extent of physical activity in order to achieve such benefits, particularly amongst older people, contributes to low participation levels. External barriers resulting in a lack of opportunity to participate in physical activity among people with a disability have been widely discussed in literature (Arthur and Finch, 1999;; Doll-Tepper, 1999; DePauw and Gavron, 2005). Research has shown a range of issues, which include a lack of confidence. With the opportunity to participate, the confidence would grow and give the people a chance to be active. A Lack of physical and emotional support was also a factor that caused people with a disability not to take part in sport and physical activity. Not having someone to go with to the gym or sporting facility is another barrier (DePauw and Gavron, 2005). According to Arthur and Finch (1999), this poses a greater problem for those people with a disability who need some kind of physical, oral or visual assistance or moral support. Lack of information was a big factor in reasons to why they did not participate in sport. Arthur and Finch (1999) found that a lack of information held by people with a disability led to low awareness of the sorts of possible sporting activities and appropriate sport facilities. According to the English Federation of disability sport (2000), the lack of access to information has worsened. Lockwood and Lockwood (1997) and Doll-Tepper (1999) both said that the subsistence of poorly trained service providers, unsuitable activities and inflexible programmes as areas of particular concern. Both Arthur and Finch (1999) and DePauw and Gavron (1995) raise the issue of a lack of available facilities and say that the blame for this is due to cuts in funding. Arthur and Finch (1999) found that poor physical access at existing facilities could present a barrier to the participation of people with a disability in sporting activities, in terms of the inappropriate design of buildings, lack of aids and adaptations to equipment. Negative attitudes towards disability include those of other facility users. DePauw and Gavron (1995) found that college students held negative and stereotypical attitudes towards the inclusion of individuals with a disability in physical education and sport. Arthur and Finch (1999) found a correlation between the negative and conventional attitudes of other sport centre users. This then produced a lack of confidence and motivation for people with a disability. National statistics show the lowest participation rates for disabled people. They produced a Taking part and active people survey which showed that 8.8 9.5% disabled adults participated in regular moderate activity (Sport England, 2006; DCMS, 2007). It also found that 44% of disabled young people did not take part in regular physical activity (Sport England, 2001) Research has shown that disabled young people do participate in sport both in and out of school (Finch et al, 2001). However, both the overall rate of participation and the frequency with which disabled young people take part in sport is lower than for young people in general. There are also important differences between participation in school compared with out of school participation. In school young disabled people participated in sport more frequently than they did out of school. However, this pattern was the reverse for all young people (Corneliben and Pfeifer, 2007) An initiative set up in Ireland is called Disability Sport Donegal. This scheme aims to give children an opportunity to participate in sporting activities. They aim to offer a wide range of activities that include Boccia and martial arts. They develop the programme for inclusion into sports for disabled people. They also look to form a relationship with local schools to include children in sporting activities. With the inclusion within schools they can then develop programmes out side of school and give opportunities to disabled children and adults to take part in sports clubs that provide the safe, fun environment and facilities that are needed to give a wider range of activities to disabled people (Donegal Sports 2007) Research has shown that many people with a disability do not take part in sport because they dont have access to the facilities or equipment they needed (Paciorek and Jones, 2001). In addition travel was shown to be a barrier as they were unable to get to and from any accessible venues. Lack of information was a problem for the many of the participants and parents because they were unaware of facilities or clubs offering activities for disability. Organisations were identified during the questioning, including Viva project and RCT Tigers. Viva is a registered Charity that was established in November 1992 to work with young people with a disability aged between 11 and 25 with who live in Rhondda Cynon Taff. The ethos of the Viva project is to facilitate and support all of its youth members to become fully involved in community activities. Viva believes this encourages young people to develop better liberty and make more choices for themselves. The main aim of Viva is to challenge members to raise their ambitions while they broaden their experiences and abilities. They try to give confidence to the members to develop greater independence and make more knowledgeable choices for themselves. At the same time they expect to raise community awareness in accepting disabled young people as valued citizens (Sports Council Wales, 2006) Vivas aim is to create equal and respected relationships between disabled young people and their non disabled peers. They look for disabled young people to participate in active community amenities, which they may have been conventionally excluded from because of the stigma and separation that is related with disability. Viva believe that by giving young people the same chances as their peers, people can learn and work together to meet the challenges we face in life. RCT Tigers FC is a pan disability football club for young children in the Rhondda Cynon Taff Area which was set up in January 2008. It was founded to improve opportunities for disability sports in Rhondda Cynon Taff. With these organisations set up it is important that extra work is conducted to make them successful. It is imperative because without these organisations people with a disability would not be able to take part in any sport or physical activity. It is also important to develop new initiatives as well as making the existing organisations more accessible by better information and promotion. With the development of initiatives, disability in sport can develop and give opportunity to people where participation would be difficult and inaccessible (Yuen et al, 2007). In conclusion I feel that physical activity and sports participation can improve a disabled persons health and well-being. Regular exercise and inclusion in sports by disabled people is as important as it is for their active counterparts. Professionals working with people with disabilities should enthusiastically encourage participation in sports and recreation activities. The relationship of sports for the disabled is difficult. Sports are a rehabilitating tool for integration into society and a way for them to remain active. In addition, sports and disability as portrayed by the media often still broadcast existing stereotypes that erect social barriers for the disabled, in the area of social perception (Barton, 2001) Sports for the disabled still remain an understudied area and should be improved greatly if it is to develop. A development for disability in sport is needed because there are people who cannot participate in sport because of reasons beyond their own control. For most disabled people, their disability is not the barrier and therefore more should be done to overcome barriers that could be easily eradicated (Barton, 1989)
Friday, October 25, 2019
Business Communication at Sainsburys and Cadburys Essay -- Business M
Business Communication at Sainsbury's and Cadburys Communication There are several different types of communication in a business such as Sainsbury's and Cadburys. INTERNAL Telephone ? When the business is a big building or is a group of small way which are close or far away when telling another group of colleges something important e.g. Telling them that their supplies have arrived. It is the main way of communicating around the business. Telephones are appropriate when you need to talk to someone when it is quicker to ring them rather than going all the way over to the person. Face to face communication ? This is when two of more colleges talk to each other face to face. This could be general slacking or telling them useful information. It is the quickest way of communicating. But if the receiver doesn?t write the message down they will forget the message and it may be important to the functioning of the business. Face to face is appropriate when you need to tell someone a message quickly and they are next to you or if they are in the same area as them. Meetings ? Sometimes it is important that everyone meets face to face to discuss business issues. Usually, an assistant writes down what was discussed and agreed. These are called the minutes and everyone gets a copy. One problem of a meeting is that they take time and have to be planned in advance to make sure that everyone can be there. Intranet - The advantages of Ict upon communica...
Thursday, October 24, 2019
Hate emerging from ignorance
Our world today is filled with chaos and hate emerging from ignorance. I feel we have to take personal responsibility to foster peace and nurture harmony to make the world a more hospitable place. As Mahatma Gandhiââ¬â¢s saying goes ââ¬Å"be the change you want to see in the worldâ⬠, I wish to make a change that would impact our future.I believe that education is one of the most important tools required to accomplish this. An educated mind would certainly be better equipped to make the right decision when faced with a moral conflict. People have to understand that we are all the same, irrespective of how we appear on the outside.Education would help a person understand the world better and could eradicate intolerance. à Hence, I consider an opportunity to work in a diverse environment with people from different cultures and socio-economic backgrounds to be a life-changing experience.I hope being a corps member in ââ¬ËTeach for Americaââ¬â¢ would give me an opportunit y to share ideas and enlighten myself by interacting with people who share common values. I am a strong believer in human dignity and expect everyone to be treated with due respect. I feel that the world cannot become a fair place without everyone given equal access to education.I believe that contributing to something bigger than me would give my life more purpose. Hence, I want to help the underprivileged learn and come up in life. However, this goal cannot be realized overnight as it requires careful planning, structured implementation and continuous evaluation for further improvement.I have managed to maintain a good record throughout my academic career by exercising perseverance and dedication. I have a penchant for working in teams and believe that we can accomplish more if we share responsibilities. I also perceive myself as a person who will always stand up for what I believe is right and express my dissent when I feel something is wrong.I maintain a positive outlook towards life even during hardships, which helps me focus on things that need to be done in the present rather than worrying about the past. I have strived hard to integrate these wonderful values in all aspects of my life and hope to do the same in my professional career as well.I seek immense pleasure in helping other people, especially the ones that desperately need help. It makes my heart ache to see people in our wealthy nation suffer without food and proper care. I am willing to do whatever it takes to revive this situation. I strongly feel that our future generations have to be empowered by higher learning to accomplish this noble cause.I believe that taking baby steps towards change will eventually contribute to something bigger and meaningful. I hope all these qualities of mine will essentially add flavor to your corps community. I would consider it a grand honor if I am accepted to serve as a corps member and promise to put in all my heart in all my pursuits.
Wednesday, October 23, 2019
The Role of Italian Government in Managing their Finance and Economy
There are many insights and studies already conducted with respect to the government system of each nation. Studies were also made to observe how particular governments run the economy of the respective states. Such aspects that include the financial organization of a country, infrastructure programs, foreign policy are some of the most important issues that directly affect the economy of a specific state. Moreover, the form of government is also critical in evaluating the total progress and status of a nation. There are instances that the form of government has direct relation with how well the economy is being run by the ministers and officials of the concerned nation. Italy has very interesting issues with regards to government policies that is being applied throughout the whole nation. In addition to that, Italy is a nation that has experienced various economic turnabouts that did affect the lives of its citizen. It can also be noticed how the government handled these issues and run the Italian economy.Government Regulation on Media in America One of the interesting facts and issues that are all about Italy is when the government implemented decentralization in running the economy. There are lots of advantages being decentralized in running a government rather than being centralized in the various organization structures and bureaucracy. On the other hand, it would do more harm to the economy of a nation once decentralization is not properly managed. The Italian government had decisions leading to these type of management wherein there would be more power being given to municipalities and provinces in running their respective territories. Italy once was a country that is centralized and such moves to amend the strategies in running the government will sure have numerous flaws, evidently because the new system is not yet fully absorbed by those that will be affected by such changes. The idea of decentralization came from the pressures being applied by the regions in the national government of Italy that are considered to be wealthy enough to support their own expenditures and services to the electorate. Such demand to shift the government framework to federalism is being pushed through since the government failed to deliver such service developments adequately to all of its territory. It is also undeniable the influence of these advocates to federalism since the government should have out rightly silenced all of these political pressures. The law that provided the outline for this modified system of government leads the country to various issues and disputes that need to be resolved. According to the Bassanini law (Piperno, 2000), such shift into federalism will provide a new era of how the government will run the economy of the country with a more balanced approach considering the regions, provinces and municipalities involved. Under this framework, more authoritative powers will be given to regions, provinces and municipalities with regards to the strategies on administering their respective local economy. However, according to the law, the national government can still hold authority on decisions that is of national interests. Such limitation is provided in the law to oversee the local authorities in administering their official functions. In addition to that, the law has set limits on the powers given to the local government entities such as any provision or ordinances should foster cooperation among local authorities, and promoting full accountability and responsibility in the decisions being made by the concerned local officials. This also includes the autonomy given to local units in collecting and managing taxes for their respective territories. Such introduction of local monetary collection system and management has further strengthened the power of local officials to collect taxes and dues form their citizens. The table below describes the amount of shares from different government levels. Share of different levels of government on total public sector revenue and expenditure (Piperno, 2000) Central Government Local Government Social Security Agencies Year Revenues Expenses Revenues Expenses Revenues Expenses 1980 59. 1 42. 6 6. 1 27. 1 34. 7 30. 1 1981 59. 7 42. 9 6. 8 30. 4 33. 26. 5 1990 61. 6 47. 4 7. 7 27. 6 30. 6 24. 9 1991 61. 7 47. 0 7. 9 27. 7 30. 3 25. 1 1993 61. 6 50. 1 9. 3 24. 5 29. 0 25. 3 1994 60. 2 47. 7 10. 7 25. 6 29. 0 26. 5 1995 59. 5 48. 6 12. 3 24. 6 28. 1 26. 7 1997 56. 9 40. 6 10. 7 26. 7 32. 3 32. 5 As seen on the table, the local government has increased revenues from the year 1980 up to 1997. This effect was caused by the continuous empowerment of the national government to the local municipalitie s to collect taxes for their respective regions. A significant increase of approximately 5% in the revenue collection was observed and the decrease in the revenue collection under the national government was due to the decentralization process that is being pushed by the officials of the Italian government. These numbers are expected to continue its trend as the advocacy for local government empowerment carry on to its full extent. Legislation made this financial decentralization implemented in the whole structure of the taxpayers to be shared with the national government. The local authorities also ventured to an enhanced system of putting taxes into the petrol industries to improve the tax collection scheme government as stated in their revised revenue distribution law. The local government also made substantial increase on the percentage of taxes being collected to its citizen and the industries to enable them to cover the administrationââ¬â¢s expenditures and the budget deficit they have. As a result, many regions in the northern part of Italy made their corresponding local budgets better that before these decentralization measures were implemented. On the other hand, little effect was observed on the lower classes of municipalities and regions due to the limited resources with respect to the people and industries they have in their regions. Thus, there are still adverse effects as observed in these mentioned low income regions. With regards to the Italian governmentââ¬â¢s effort to administer the whole country, the laws in the land made it clear about all the interventions and systems in the economy. Knowing the structure of a particular government is essential because this is adds up to the bureaucratic control and distribution of services to the populace. This would also provide hints on how the economy is greatly affected by this form of government organization. The Italian government structure consists of the central government, regions, provinces and municipalities. In the present system, the national government holds a tough authority to regional governments. One particular example is that the central government still classifies laws and ordinances that the regions should implement even the regions were given powers to formulate their own legislation measures. The national government can reject regional-made laws that they think would not bring good to the entire nation. There have been conflicts between the central and regional government and when these disputes were brought to the courts, the judicial system always favored the side of the national government. Regional governments were introduced in the Italian government framework only in the 1948 Constitution. (Piperno, 2000). This government entity were provided under the constitution legislative and administrative authorities in the fields of high importance like in agriculture, health sector, tourism industry, transportation departments and other relevant aspects in their respective territories. There were five regions that were established under the same constitution. Before the fiscal decentralization law, regions do not have autonomy in their taxation system and were supported by the national government in their expenditures. For example, the financial support for the health centers in the region comes from the national treasury only, since they do not have money to finance their own health units. Provinces, on the other hand, possesses only limited duties in the former constitution or before the decentralization take effect. There are also situations when provinces did not have any substantial role in administering their corresponding municipalities particularly in those big municipalities and the metropolis. For the other municipalities, their control is mostly seen to take effect in terms of governance and support to the little municipalities and through proper management in rural areas. Municipal governments are mainly responsible for the basic services needed by the people such as potable water systems, domestic waste disposal systems, and other usual necessities of its citizens. With the aid of new legislations, these municipalities were given more powers and privileges such as the rights to vote for their municipal head and the independence in tax collection system. With these new constitutional rights, any municipality can benefit on the taxes it collect and as a result, more funds can be used to spend on the basic services for the populace. On the other hand, the primary weak spot of this approach is that it may create imbalance between rich and poor municipalities since there would be less income for those who have limited collections but with higher expenditures compared to the richer municipalities. Because of that, each municipality needs to find new strategies to strengthen their fiscal situation to maintain a well balanced budget. The table below shows the distribution of revenues in the municipality level form the specified years covered by the statistics made by the central statistics office in Italy. As shown in the statistics above, municipalities then depends their finance on the central government like in the year 1970 until they were given new tax measures including tax autonomy in the year 1972 but only took its significant mark in the year 1996. Other aspects of the Italian governmentââ¬â¢s approach in running the economy reflects on some of the key issues like freedom from foreign interventions, political system, banking systems, transportation sectors, real properties, education, culture and other essential concerns. As a member of the European Union, the Italian government is bounded to follow the laws formulated by the union. However, Italian people will only be prosecuted by the Italian court and the laws of the land, and not on the laws of the union. Italy has more than 2 electoral parties making it more divisive in terms of policies being implemented by the ruling party. Such scenario made the government very unstable because of disagreements even between the members of the ruling coalition. Such problems were added further by accusations of corruption of the leaders and the increasing foreign debt of the country. The banking system in Italy is also greatly affected by the policies being implemented by the Italian government. The banking sector can also be a gauge to measure the economy of a particular country. With regards to the Italian banking system, it is still stable in terms of being part of the European Union which uses Euro as the currency. Since Euro currency is very strong compared to the other currencies, this carries the economy of Italy. Another factor is that the government has no control or intervention over the banking system, making it more independent against any influence that government leaders may bring. With all of the bad scenarios in the political system of Italy, the country still provides great attraction for business investors because of its various provisions to make Italy a better choice in the business climate. The Italian government also ventured into privatization of government owned and controlled corporations. These move by the government provided private firms to own and manage these enterprises and pursue upgrades in the service it gives to the Italian people. The government also has more savings since they do not have to spend public funds to run these corporations. Having said all of these information on how Italian government run their economy, it can be said that the economic growth of Italy depends greatly on the people who are positioned in vital areas of government structures like mayors, governors, legislators and the primary head of the country. These persons hold sensitive positions that dictate the nationââ¬â¢s policies and direction toward progress and continuous advancement with the rest of the world. Corrupt leaders will only add to the problems the country is facing. Italy needs responsible people who would think first the welfare of the nation before themselves. These dedicated people will surely deliver good output for the continuous progress of their nation, Italy.
Tuesday, October 22, 2019
Mayfield High School Maths Coursework Essays
Mayfield High School Maths Coursework Essays Mayfield High School Maths Coursework Essay Mayfield High School Maths Coursework Essay Essay Topic: High School I have chosen this particular hypothesis because many students who tend to have a high IQ, have a high KS2 result too. I have also chosen this hypothesis because, many students at my school who have a high IQ tend to do well in their KS2 exams and get a high grade and therefore I would like to find this out for my-self. The data which I will be using to find out if my hypothesis is right or wrong will be from Mayfield High School. All the data that I will need will be provided for me at school on the computers. This data will include a range of different information on students from years 7-11. Sampling For my hypothesis I will be choosing a sampling size. I have chosen my sample size to be 50, as it will be more accurate. Also using the sample size of 50 will give me a wider range of data and therefore help me with my hypothesis more. There are various samples, which can be used. However, I am going to use random sampling and stratify sampling and this way it will avoid bias results. The random sampling will pick out my data in any order. The below formula is used to stratify my samples. The formula that I will use to work out my samples is:- Number of students used in sample= Total number of girls/boys in year X Sample Size Total number of students in the school Below is a table with the data which we were provided and also showing how I worked out my samples. All the samples are 0d.p Year Group Number of Boys Samples for Boys Number of Girls Samples for Girls Total 7 151 151/1183 x 50 = 6 131 131/1183 x 50 = 6 282 8 145 145/1183 x 50 =6 125 125/1183 x 50 = 5 270 9 118 118/1183 x 50 = 5 143 143/1183 x 50 = 6 261 10 106 106/1183 x 50 = 4 94 94/1183 x 50 = 4 200 11 84 84/1183 x 50 = 4 86 86/1183 x 50 = 4 170 The number in bold, tells me how much samples I will need from the girls and boys and it also tells me how much samples I will need from each year. Random Sampling After doing the stratified sample, I had to choose the students which I will use to prove my hypothesis. I will need to pick them out from the data which is provided on a spreadsheet. I will pick the samples out by using the random formula which is:- (RAND()*150+1) However, the number after the * changes depending on how much girl or boy students there are in that year. When I put the number in I had to minus one away and then add one back on. However, as I wanted a couple of samples for the same year and same gender, I kept on pressing F9 until I got the random amounts of students I needed. Below are all my samples which I have gathered by using the random formula:- Random Numbers For Year 7 Boys: 103, 119, 89, 6, 4, 78 For Year 7 girls: 73, 114, 30, 23, 34, 76 For Year 8 Boys: 134, 96, 29, 60, 63, 104 For Year 8 Girls:- 39, 69,112, 36, 10 For Year 9 Boys: 64, 11, 14, 48, 81 For Year 9 Girls: 6, 130, 54, 101, 28, 4 For Year 10 Boys: 66, 88, 57, 84 For Year 10 Girls: 60, 53, 66, 47 For Year 11 Boys: 37, 26, 8, 16 For Year 11 Girls: 65, 50, 43, 33 Relevant Data The table below shows the IQ and KS2 results of each student that was selected. This is all the necessary data that is needed. However I have not noted which students are from which years to make sure it is not biased in any way. IQ ENG MATHS SCIENCE 107 5 5 5 106 5 4 5 108 4 5 5 101 4 4 4 99 4 4 4 104 4 5 5 122 5 5 5 100 4 4 4 104 5 4 5 100 4 4 4 109 5 5 5 97 4 4 4 100 4 4 4 112 5 5 5 100 4 4 4 114 5 5 5 100 4 4 4 105 5 4 4 89 3 3 3 114 5 5 5 108 5 5 5 101 4 4 4 101 5 4 4 92 3 3 4 102 5 4 4 91 3 3 4 109 4 5 5 102 4 4 5 91 3 4 4 117 5 5 5 110 5 4 5 100 4 4 4 116 5 5 5 101 4 4 4 100 4 4 4 100 4 4 4 110 5 5 5 102 3 5 4 99 4 4 4 100 4 4 4 92 3 3 3 92 4 3 3 96 3 3 3 106 5 5 5 103 5 4 4 100 4 4 4 103 4 4 5 100 4 4 4 98 4 4 5 92 3 3 4 My Graph From my samples I am going to create a graph. I have decided to do a scatter graph because; it will make it easier for me to see if my hypothesis is correct. It will make it easier for me see this, as all my points will be plotted on the graph and therefore it will give me a better understanding of my results and also a clear view of my correlation line. Below is my graph:- From the graph you can see that my hypothesis is correct. This is because as the IQ results are going higher, so are the KS2 results going higher. I think this because, the clever you are, the more intelligent you are, as you know many things and you can gain more marks. However, from the graph you can see that there is a strong positive correlation. We can see this because, as the KS2 results are going higher, the IQ goes higher too. For example, a student who has a low KS2 result, such as, a level 3, they have a low IQ. However, if you look at the graph, a student who has got a level 5 for English, Maths and Science has got the highest IQ. Product Moment Correlation YR GROUP X Y XY X Y Yr 7 Boys 107 5 535 11449 25 106 5 530 11236 25 108 5 540 11664 25 101 4 404 10201 16 99 4 396 9801 16 104 5 520 10816 25 Yr 7 Girls 122 5 610 14884 25 100 4 400 10000 16 104 5 520 10816 25 100 4 400 10000 16 109 5 545 11881 25 97 4 388 9409 16 Yr 8 Boys 100 4 400 10000 16 112 5 560 12544 25 100 4 400 10000 16 114 5 570 12996 25 100 4 400 10000 16 105 4 420 11025 16 Yr 8 Girls 89 3 267 7921 9 114 5 570 12996 25 108 5 540 11664 25 101 4 404 10201 16 101 4 404 10201 16 Yr 9 Boys 92 3 276 8464 9 102 4 408 10404 16 91 3 273 8281 9 109 5 545 11881 25 102 4 408 10404 16 Yr 9 Girls 91 4 364 8281 16 117 5 585 13689 25 110 5 550 12100 25 100 4 400 10000 16 116 5 580 13456 25 101 4 404 10201 16 Yr 10 Boys 100 4 400 10000 16 100 4 400 10000 16 110 5 550 12100 25 102 4 408 10404 16 Yr 10 Girls 99 4 396 9801 16 100 4 400 10000 16 92 3 276 8464 9 92 3 276 8464 9 Yr 11 Boys 96 3 288 9216 9 106 5 530 11236 25 103 4 412 10609 16 100 4 400 10000 16 Yr 11 Girls 103 4 412 10609 16 100 4 400 10000 16 98 4 392 9604 16 92 3 276 8464 9 Total ?5125 ?98 ?21732 ?527837 ?904 Standard Deviation for X and Y Data Standard deviation for IQ Results SD = ? ? à ¯Ã ¿Ã ½ ? ? à ¯Ã ¿Ã ½ - - n n n = 50 (number of samples) ? ? = 5125 (whole sample added together) ? ? à ¯Ã ¿Ã ½ = 527837 (Square of each data point of the sample added together) SD = 527837 5125 à ¯Ã ¿Ã ½ 50 50 SD = 10556.74- (102.5)à ¯Ã ¿Ã ½ SD = 10556.74- 10506.25 SD = 50.49 SD = 7.105631569 SD = 7.1 (1 D.P) The average value for the X data is:- 5125 = 102.5 50 This therefore, shows that my data is not reliable, as my points would not be close together. I know this because the number that I got when working out my standard deviation, it was, 7.11 and when I worked out the average mean I got 102.5 and therefore, these two numbers are far apart. Standard deviation for the KS2 Results:- SD = ? y à ¯Ã ¿Ã ½ ? y à ¯Ã ¿Ã ½ - - n n n = 50 (Number of sample) ? y = 98 2 (Whole sample added together) ? yà ¯Ã ¿Ã ½ = 904 (Square of each data point of the sample added together) SD = 904 98 à ¯Ã ¿Ã ½ 50 50 SD = 18.08 (1.96) à ¯Ã ¿Ã ½ SD = 18.08 3.8416 SD = 14.2384 SD = 3.773380447 SD = 3.8 (1 D.P) The average value for Y data is:- 98 = 1.96 50 This show that my results for my Y data is reliable, as my standard deviation answer was, 3.77 and my average value answer was, 1.96. As the two numbers are close, this therefore proves that my data is reliable. Product Moment Correlation Coefficient I am now going to work out the Product Moment Correlation Coefficient this is normally written as, Yxy. I will work this out by using the table on the sixth page. I will work this out by using the following formula:- ?xy ?x ?y - - n n n ?xà ¯Ã ¿Ã ½ ?x à ¯Ã ¿Ã ½ ?yà ¯Ã ¿Ã ½ ?y à ¯Ã ¿Ã ½ - X n n n n ? SD = ? ? à ¯Ã ¿Ã ½ ? ? à ¯Ã ¿Ã ½ - - n n SD = ? y à ¯Ã ¿Ã ½ ? y à ¯Ã ¿Ã ½ - - n n Top of Yxy: 21732 5125 98 - - x = 434.64 (102.5 x 1.96) = 233.74 50 50 50 Bottom of Yxy: 527838 5125 à ¯Ã ¿Ã ½ = 7.105631569 50 50 10556.74 10506.25 = 50.49 904 98 à ¯Ã ¿Ã ½ - = 3.773380447 50 50 18.08 3.8416 = 14.2384 Yxy = 2.33.74 / (7.105631569 x 3.773380447) Yxy = 2.3374 / 26.81225123 Yxy = 0.086900573 Yxy = 0.1 (1 D.P) Conclusion Conclusion for my product moment correlation coefficient From working out the standard deviation, I have concluded that my regression line has no correlation. This is because my end result which I got after working out the standard deviation my regression line was 0.0869 This therefore, shows that my regression line has no correlation. However, I am able to tell that my regression line is a positive because it is not a negative number. This shows that my hypothesis was correct, but it was not strongly proved, as my regression line was not a perfect correlation. Overall, from the whole hypothesis I found that the higher the IQ results a student has and more likely they are going to have a higher KS2 result too. You are able to see this on my graph earlier in the work. This therefore proves my hypothesis to be correct.
Monday, October 21, 2019
Bank Corruption Literature Review Essay
Bank Corruption Literature Review Essay Bank Corruption Literature Review Essay Example Bank Corruption Literature Review Essay Example Arshad, S., Rizvi, S. (2013). Impact of corruption on bank profitability: An analysis of Islamic banks. International Journal of Business Governance and Ethics, 8(3), 195. The authors of the article discuss the fact of bank corruption on the examples of Islamic countries. The main claim of the article consists in the idea that corruption is one of the most negative social processes that bears negative influence on the economy of the country. Arshad and Rizvi (2013) have a conviction that despite the negative results of the corruption, banks have a tendency to prosper during this process. In addition, the assumption is based on the research conducted on the comparison of the amount of corruption and the banksââ¬â¢ income. The study showed that the more level of corruption in a country is, the more prosperity the banks experience. This assumption can be characterized as a credible one due to the obtained results. Additionally, this idea can be used in the economic planning: the action of corruption has to be moved in the correct direction, which, on the one hand, would control the levels of corruption, and on the other hand, balance its level with banksââ¬â¢ prosperity and have a positive effect on a countryââ¬â¢s development. As a consequence, this strategy can be applied to the economic policy regarding various types of regulations aimed at controlling the balance and interaction between corruption and bank system. Bodenhorn, H. (2015). Bank chartering and political corruption in antebellum. National Bureau of Economic Research, Corruption and Reform: Lessons from Americas Economic History, 231-257. Speaking about the types of policy that are called to collaborate with banks and private business, the author of the article regards the notion of corruption in the framework of the contemporary particularities of the economy. Along with this, the authors distinguish the advantages and drawbacks of the democracy as a political power in connection with the banking in the world. Having conducted the research, Bodenhorn (2015) claims that banks have a tendency to ââ¬Å"provide some appreciation for the potential scale for corruption and briberyâ⬠(Bodenhorn, 2015, p. 240). In other words, similarly to Arshad and Rizvi, the author sees a great benefit of bank corruption. On the one hand, in the light of bank corruption, there is only one side that suffers a country. On the other hand, the prosperity of the banks is a manifestation of the countryââ¬â¢s flourish, in any case. It means that the benefits that can be extracted from bank corruption have to move in the same direction with the stated policy of a country. Applying this point of view to the official policy would contribute to the rising of the taxes and fees payment amount, which is generally acknowledged to be vitally important for a country. Casillas, G., Paredes, D., Cervantes, A., Torres, S. (2015). New measures to fight corruption and conflict of interest. The authors of the article are convinced that corruption should not be regarded as something completely unexpected. They think that corruption is as usual as, for instance, elections or a law-making process. It is necessary to regard this phenomenon from another point of view. The main claim of the article consists in the assumption that it is important to establish a so-called sense of transparency. The more governmental control over economy and bank system is produced, the more exactness and transparency will it provide. This proposal is worth of the further regard since the democracy, as well as the social order established long time ago, needs updating. This presupposes the change of the things and the way of thinking, which had been unsuitable for or not understood by the people. This sort of things comprises of the corruption and its manifestations within society. Certainly, it takes time to create a new system of the policies, which would incorporate the basis and traditions of the former styles of governing. It is necessary, however, to understand the course of time and its particularities, which require to be up-to-date, and to create a system that would provide the successful functioning of a country. Hence, implementing corruption in the bank system of a country will permit to enrich the state budget due to the money incoming. Campos, J., Pradhan, S. (2007). The many faces of corruption. Washington, D.C.: World Bank. The book in question discusses the history of the phenomenon known as corruption. The authors provide a reader with a number of stories that illustrate how corruption was widespread throughout the humankindââ¬â¢s history. Campos and Pradhan (2007) suppose that corruption has always been an integral and inseparable part of the society and politics. As a consequence, the authors have a conviction that bank corruption as a spread particularity of the contemporary society has a right to exist. The essential strategy provided in the book is centered on the assumption that bank corruption should be a legislative phenomenon, which will contributes to the countryââ¬â¢s prosperity. Analyzing such an approach, it is possible to draw the conclusion that bank corruption is becoming a positive tendency. Oppositely, the authors believe, corruption has never been a positive phenomenon. The point is that it is an important and complex task for the government to turn it into a useful one and make it bring fruitful results that are expected. In other words, the many challenges that numerous countries of the world are currently facing can be met by making corruption a positive event. Obviously, it is necessary to elaborate a well-laid plan that would be followed during many years. Implementing such a vision of corruption will totally change the world and make it live and function in another way. Johannesson, I., Steendam, M. (2014). Can mobile banking reduce the presence of corruption? A minor field study in Kenya. The article written by Johannesson and Steendam (2014) represents a brand new approach to the notion of corruption. The authors of the article do not state that corruption should be legalized or make an emphasis that it is a positive phenomenon. The solution for the bank corruption proposed in the article is characterized as the most innovative, and it is expected to produce fruitful results. In their article, the authors discuss a multimedia platform known as M-Pesa called to stabilize the countryââ¬â¢s financial and economic affairs by controlling and observing the vast sums of money circulating in the banks. This will permit to find and prove the fact of corruption and its amount. In reality, this program can be implied in the majority of the biggest world banks, as well as the banks of the poor countries. The last ones are the most suitable for this program since the phenomenon of corruption is extremely spread within their economies. Implementation of the program is called to serve as a powerful tool in overcoming the negative outcomes of corruption. Kolstad, I., Fritz, V., Oââ¬â¢Neil, T. (2008). Corruption, anti-corruption efforts and aid: Do donors have the right approach. The article in question represents a result of the project conducted in order to establish the linkage between effective governance principles and the poverty rates decrease. The authors have a conviction that corruption is a mechanism that lies between these two aspects. It has neither positive nor negative impact. This phenomenon, in the authorsââ¬â¢ opinion, is called to divide the countries into such categories as poor, developing or rich. Bank corruption as an essential part of the overall corruption serves, in addition to this, as a tool that shows whether a country is able to transcend from one class to another and indicates what amount of attempts should be taken. This approach is based on the research conducted and the results obtained. According to its results, the constantly growing interest in corruption is determined by the necessity of it reduction or making it play a role of contributing factor in a countryââ¬â¢s economy. The ideas presented in the article can be interpreted in a dual way; however, it is necessary to understand that such a vision of corruption in the bank area is worth of implementing in order to help overcome poverty in the countries that experience it. Krudop, J. (2010). Surviving financial corruption: The attack of a rogue bank. Tate Publishing. The book under analysis represents a financial and economic issue of bank corruption experienced in the USA. The book is built as a memoir with scientific explanations and proofs of the phenomenon of bank corruption. The author states that the essential idea here is not to struggle against it, but change the way of thinking in such a way that would make bank corruption work for the benefit of the country. Such an approach is one of the most progressive, and it summarizes the ideas of the mentioned above articles and books, which state that the best way to stop any socially acknowledged negative phenomena is to legalize them. Having the bank corruption legalized will, first and foremost, stop the fact of struggling; secondly, it will direct the flows of money into the necessary areas. As a consequence, the states and countries will have an extra income for their local and central budgets. This fact is called to contribute to the growth of economy and industry, improving peopleââ¬â¢s quality of life. The process of changing the understanding of corruption within banks will implement the newer vision of bank system. Capitalism, as the author has a conviction, has two ways to exist nowadays: on the one hand, it can stay the same and stop its existing by self-destruction; on the other hand, it can be reborn by the numerous and absolute changes, which would take place not only in the external part of the human life and activity, but inside the human mind. Manacorda, S., Forti, G., Centonze, F. (2014). Preventing corporate corruption. Cham: Springer International Publishing. The book regards the bank corruption at the international level and explains the reasons of its beginning, evolution and thriving. Along with this, the authors make an emphasis on the examples of international bank corruption and show the consequences they have on a single country and international relations. The authors have distinguished a so-called Anti-Bribery Corruption Model, whose main idea and principle of work consists in preventing corruption inside the private companies, firms, organizations and corporations. This, as the authors believe, will contribute to the improvement of economic situation and will establish stability. Analyzing this tool, one can think that is really likely to work and perform great results. (This had been proved due to its usage by several US companies, the majority of which was represented by banks). Implementing this program into all the banks functioning in the USA, for instance, will save an incredibly large amount of money. In other words, the states and central government will have financial benefits manifold larger than they currently have. It means that the proper application of the method is able to improve a great number of social life areas and the quality of citizensââ¬â¢ lives. Olken, B., Pande, R. (2011). Corruption in developing countries. Abdul Latif Jameel Poverty Action Labââ¬â¢S Governance Initiative, August. The article represents an innovative look at bank corruption and explains the ways it will function in the future. The advantage of the article is that it provides a reader with a number of definitions of corruption in order to investigate the ways it influences economy and the methods that are likely to be applied to overcome it. The key point of the article consists in the idea that ââ¬Å"bureaucratic corruption takes place at the implementation end of public policiesâ⬠(Olken Pande, 2011, p. 4). In other words, the authors have a conviction that corruption brings decline in whatever field of human activity and it has to be stopped. The ways to do this can be numerous. One of the most effective one, in accordance with the authors, consists in the improvement of the law system. Furthermore, the authors suggest widely using the most recent technological devices called to contribute to prevention of corruption. This idea can be characterized as useful; however, it does not provide an innovative way of look at the problem, i.e. it is mainly based on the traditional way of struggle against corruption, which is not acknowledged as an effective or fruitful one. It means that this is not enough to change or fix the law system ââ¬â it is more important to change human outlook and perception of the outcomes that corruption results in.
Sunday, October 20, 2019
How Biobutanol Can Be Used as a Motor Fuel
How Biobutanol Can Be Used as a Motor Fuel Biobutanol is four-carbon alcohol derived from the fermentation of biomass. When it is produced from petroleum-based feedstocks, its commonly called butanol. Biobutanol is in the same family as other commonly known alcohols, namely single-carbon methanol, and the more-well-known two-carbon alcohol ethanol. The importance of the number of carbon atoms in any given molecule of alcohol is directly related to the energy content of that particular molecule. The more carbon atoms present, especially in a long carbon-to-carbon bond chains, the denser in energy the alcohol is. Breakthroughs in biobutanol processing methods, namely the discovery and development of genetically modified microorganisms, has set the stage for biobutanol to surpass ethanol as a renewable fuel. Once considered usable only as an industrial solvent and chemical feedstock, biobutanol shows great promise as a motor fuel due to its favorable energy density, and it returns better fuel economy and is considered a superior motor fuel (when compared to ethanol). Biobutanol Production Biobutanol is derived mainly from the fermentation of the sugars in organic feedstocks (biomass). Historically, up until about the mid-50s, biobutanol was fermented from simple sugars in a process that produced acetone and ethanol, in addition to the butanol component. The process is known as ABE (Acetone Butanol Ethanol) and has used unsophisticated (and not particularly hearty) microbes such as Clostridium acetobutylicum. The problem with this type of microbe is that it is poisoned by the very butanol it produces once the alcohol concentration rises above approximately 2 percent. This processing problem caused by the inherent weakness of generic-grade microbes, plus inexpensive and abundant (at the time) petroleum gave way to the simpler and cheaper distillation-from-petroleum method of refining butanol. My, how times change. In recent years, with petroleum prices heading steadily upwards, and worldwide supplies getting tighter and tighter, scientists have revisited the fermentation of sugars for the manufacturing of biobutanol. Great strides have been made by researchers in creating ââ¬Å"designer microbesâ⬠that can tolerate higher concentrations of butanol without being killed off. The ability to withstand harsh high concentration alcohol environments, plus the superior metabolism of these genetically enhanced bacteria has fortified them with the endurance necessary to degrade the tough cellulosic fibers of biomass feedstocks such as pulpy woods and switchgrass. The door has been kicked open and the reality of cost competitive, if not cheaper, renewable alcohol motor fuel is upon us. Advantages So, all of this fancy chemistry and intense research notwithstanding, biobutanol has many advantages over here-to-fore easier-to-produce ethanol. Biobutanol has a higher energy content than ethanol, so there is a much lower loss of fuel economy. With an energy content of about 105,000 BTUs/gallon (versus ethanolââ¬â¢s approximate 84,000 BTUs/gallon), biobutanol is much closer to the energy content of gasoline (114,000 BTUs/gallon).Biobutanol can be easily blended with conventional gasoline at higher concentrations than ethanol for use in unmodified engines. Experiments have shown that biobutanol can run in an unmodified conventional engine at 100 percent, but to date, no manufacturers will warrant use of blends higher than 15 percent.Because it is less susceptible to separation in the presence of water (than ethanol), it can be distributed via conventional infrastructure (pipelines, blending facilities and storage tanks). Thereââ¬â¢s no need for a separate distribution network.It is less corrosive than ethanol. Not only is biobutanol a higher-grade more energy dense fuel, but it is also less explosive than ethanol.EPA te st results show that biobutanol reduces emissions, namely hydrocarbons, carbon monoxide (CO) and oxides of nitrogen (NOx). Exact values depend upon the engine state of tune. But thatââ¬â¢s not all. Biobutanol as a motor fuel- with its long chain structure and preponderance of hydrogen atoms- could be used as a stepping-stone in bringing hydrogen fuel cell vehicles to the mainstream. One of the biggest challenges facing hydrogen fuel cell vehicle development is the storage of onboard hydrogen for sustainable range and the lack of hydrogen infrastructure for fueling. The high hydrogen content of butanol would make it an ideal fuel for onboard reforming. Instead of burning the butanol, a reformer would extract the hydrogen to power the fuel cell. Disadvantages It is not common for one fuel type to have so many obvious advantages without at least one glowing disadvantage; however, with biobutanol versus ethanol argument, that doesnââ¬â¢t appear to be the case. Currently, the only real disadvantage is there are many more ethanol refining facilities than biobutanol refineries. And while ethanol refining facilities far outnumber those for biobutanol, the possibility of retrofitting ethanol plants to biobutanol is feasible. And as refinements continue with genetically modified microorganisms, the feasibility of converting plants becomes greater and greater. Itââ¬â¢s clear that biobutanol is the superior choice over ethanol as a gasoline additive and perhaps eventual gasoline replacement. For the past 30 years or so ethanol has had most of the technological and political support and has seeded the market for renewable alcohol motor fuel. Biobutanol is now poised to pick up the mantle.
Saturday, October 19, 2019
Defeat at Shiloh Essay Example | Topics and Well Written Essays - 500 words
Defeat at Shiloh - Essay Example In discussing the mentioned battle, this essay shall focus on Purdy's engagement, the arrival of the Confederates and the movement from Corinth. Preparations for what was later to be known as the Battle of Shiloh began in February 1862. In the wake of the Confederate loss of both Fort Henry and Forte Donelson, the Confederate General Alber Sydney Johnston withdrew to Tennessee for reorganization purposes. Recognizing that the Confederates were planning for action, Major General Ulysses Grant moved his army to West Tennessee, occupying Pittsburg Landing by March 1862. Directly following, orders were issued to Major General Don Carlos Buell to join Grant and, with their joint armies, undertake a seizure of the Memphis and Charleston Railways (Veit). The plan, as explained by Suhr was to cut off Confederate supplies and, to all intents and purposes, encircle and suffocate the Confederate forces. Even as the Union army was proactively planning to offset what they had determined to be Confederate preparations for offensive, and take the offensive themselves, the Confederate General, Johnston, was preparing for an offensive on Grant's forces, scheduled for April 4th, 1862 (Bagby).
Friday, October 18, 2019
Mexico's Global business Essay Example | Topics and Well Written Essays - 2000 words
Mexico's Global business - Essay Example The topography is very diverse, and the climate reflects this fact. At any time of the year you can find an area of Mexico with a perfect climate. Many parts of the central highlands and some coastal locations, have "perfect" weather all year round (Blog, 1996). The country can be split into four geographical areas namely, The Baja Peninsula, The Pacific Coast, The Caribbean coast and The Central Highlands. The Baja has a climate that varies considerably from its west coast to its east coast and north to south. The coastal areas get hot and humid weather in the summer and ideal weather in the winter. The central highlands get ideal weather year-round. The northern desert areas have very hot weather in the summer and cool nights in the winter with some snow on occasions. Details on climate can be obtained from the more specific pages in Virtual Mexico (Blog, 1996). The economic health of Mexico is basically more focused on travel and tourism. The other areas in which the country has a good reputation are industrial production, oil and gas production, textiles and clothing and agriculture. Mexico is highly dependent on exports to the U.S., which represent more than a quarter of the country's GDP. The result is that the Mexican economy is strongly linked to the U.S. business cycle. Real GDP grew by 4.8% in 2006 and by 3.3% in 2007 (Bureau of Western Hemisphere Affairs, 2008). Hundreds of North American factories have been built to take advantage of the lower labor costs. Mexico has 1/5 of the world's oil reserves. Mexico produces and exports a wide selection of agricultural goods. Just about every kind of fruit and vegetable is grown on giant modern irrigated farms and small family plots. Political Conditions of Mexico Mexico is bogged down in a grim economic crisis, and the people are tired of inflation, of poverty, and of the appalling poverty-linked crime wave. The government of Mexico is a federal republic (Lake, 1998). The 1917 constitution provides for a federal republic with powers separated into independent executive, legislative, and judicial branches. Historically, the executive has been the dominant branch, with power vested in the president, who promulgates and executes the laws of the Congress. The Congress has played an increasingly important role since 1997, when opposition parties first made major gains. The president also legislates by executive decree in certain economic and financial fields, using powers delegated from the Congress. The president is elected by universal adult suffrage for a 6-year term and may not hold office a second time. There is no vice president; in the event of the removal or death of the president, a provisional president is elected by the Congress (Burea u of Western Hemisphere Affairs, 2008). In the 2006 elections, the PAN emerged as the largest party in both the Senate and the Chamber of Deputies, with just over 40% of the seats in each house of Congress. It does not enjoy a legislative majority. Although the PRI no longer controls the presidency and has fewer
Is Neoliberalism in Crisis Today Term Paper Example | Topics and Well Written Essays - 3000 words
Is Neoliberalism in Crisis Today - Term Paper Example In the last months of the year 2008, following the financial crisis, people readily accepted that it was the demise of neoliberalism, and thus whether it was a total end of neoliberalism and would it lead to the emergence of new political and economic policies, and what form they would take were the crucial questions which require deliberate attention and time (Brand and Sekler, 2009, 5 ââ¬â 8). The rise of neoliberalism came about as a result of the deep revolutionary changes in the global economy in the 1970s, it was, however, a passive and tacit revolution which strengthened the capitalist system by the means of complete transformation of the social, political and the economic system of the countries of the world from the ââ¬Ëaboveââ¬â¢- which was the dominant political and social forces. The major aspect of the new concept was the liberalization of the market along with the deregulation of the political system. The system was a success initially and triumphed by encompa ssing the national economies of numerous nations across the globe. In the 1970s, the Keynesian approach in the post World War 2 era crumbled and marked the epoch of Neoliberalism (Altvater, 2009, 73). The end of the Bretton Woods system of fixed exchange rates in March 1973 and the liberalization of the financial markets under the governance of Margaret Thatcher in Great Britain was the beginning of neoliberalism. The decisions regarding the formation of the critical prices, such as the exchange rates around the world, and the interest rates charged on borrowing and saving, and therefore the regulatory policies were no longer regulated or officially controlled. Instead, these decisions were left at the disposal of the private sector, such as multinational banks, speculative investment and other funds and also the transnational corporations. The wave of privatization of the public services and goods began, and the newly formed private sectors set off to create financial innovations, forming new instruments to increase gains.Ã
Thursday, October 17, 2019
Constructivists approach towards management of change Essay
Constructivists approach towards management of change - Essay Example This research will begin with the statement that social constructionism is considered to be an ââ¬Ëepistemologyââ¬â¢ owing to its approach of knowledge. The philosophy of social constructionism accentuates on the communication among the people in a particular group. Basically, social constructionism is based on three main assumptions. The relational and the social constructionist perspective would be discussed in this paper in order to understand about personality clashes. These perspectives would be discussed so as to bring in clarity for the reason of professional effectiveness. The notion of ââ¬Ëconstructââ¬â¢ focuses on the structure of reality that is made. In other words, it can be said that people build up stories, theories, and ideas in order to assist them in coping up with the real world. Furthermore, the knowledge possessed by people does not impartially mirror the outside reality. It is all the time shaped from oneââ¬â¢s own insights, knowledge, and princip les. The notion of ââ¬Ësocialââ¬â¢, states that the structures which are concentrated on the surrounding world are possible to be developed only with the help of communication with others. Knowledge or experiences are said to subsist only in the instance when it is communicated with another individual. Constructs are communicated stories and these facilitate people to operate as a collective group. The notion of social constructionism stresses on the fact that these structures are practical and is bound to be helpful in the course of daily activities.... 00) and Botella & Herrero (2000) that an amalgamative connection between the approaches of social constructionism and cognitive constructionism could be termed as ââ¬Ërelational constructivismââ¬â¢. The perception of Adlerian reverberates with the theory of social constructionism in relation to the socio-cultural sources for the growth of human psychology. Although it was agreed that humans lived in a world that has individuals or persons and which is socio-cultural but each and every person had a differentiating feature of personhood which is being obtain by every individual. The theory of relational constructionism defines the process undertaken which leads to effective and developmental social construction. A perspective in relation to the relational constructionist provides fresh and prosperous likelihoods for importance in the courses of relations as well as social communications. Relational constructionism facilitates an individual or a person to have a ââ¬Å"participato ry world viewâ⬠and presumes the dominance of relations to be the source in which identities, intercultural relations, learning and communities, which are viewed as social structures, are constantly formed and altered. In case of relational constructionism, relating is not considered to be a personal action any more and no more condensed to be one-sided informal relations with comments. Being a perspective, it provides a more prosperous set of probabilities in regard to the way relating can be theorized. To add further, the principle of relational perspective is regarding what subsists or is present which is also referred as ontology. It is then linked with the way people recognizes it and makes it probable and helpful to inquire about the methodical suppositions of participants as well as the academic
Economics Essay Example | Topics and Well Written Essays - 2000 words
Economics - Essay Example Apart from economic factors, cultural and political issues also affect inflation rate. The activities of workersââ¬â¢ union might create pressure on the wage rate preventing any downward movement of the same. Therefore production cost will not come down and hence increase in supply is restrained. An increase in supply of money or credit in the economy can make the incidence of inflation strong in an economy. The global financial crisis which resulted from the excess credit and increasing defaulters especially in the housing loan market led to inflationary pressures owing to increasing demand and cost of basic necessities around the world (Nanda). For the Gulf Countries where oil is a key commodity and factor responsible for growth, the rise in oil prices from 2005-2006 led to increase in related products. The increase in oil prices across the world has been occurring at a rate higher than the depreciation of the dollar. The spot price of oil rose by 171.9 percent ($65.66) and achi eved the highest point in August 2006 (reaching the peak at $76.01). Depreciation of dollar across a wide spread of currencies took place at 13.8 percent (Oxford Business Group 38-39). The paper attempts to compare two different Gulf Countries, Bahrain and UAE, with respect to the incidence and impact of inflation. Inflation The first outcome of inflation is usually reflected in the purchasing power of money. Hence there is a reduction in the real value of a good. Inflation rate which measures the price inflation has both positive and negative impacts on the economy. On one hand it reduces the real value of wealth in hands and on the other it creates an expectation of inflation in future and leads to a fall in savings and investments. If there is increased activity of accumulation of goods in apprehension that price might rise further, then there might be a crisis of supply of products in the market. If one considers the positive effects it may be reflected in adjustments of nominal interest rates which help in controlling recessions. Seeing from the demand side, low and moderate inflation are caused by demand side changes or alteration in the number of suppliers at times of crisis and increase in money supply. Going by the Keynesian viewpoint, demand-pull inflation is brought about by a rise in private and government expenditure leadings to high demand. This reflects a grot hint he economy since such higher demand and favorable market situation will lead to higher investment and growth. However cost push inflation which is brought about by supply side shock (fall in supply) could be owing to some natural calamities or high prices of inputs. For instance a sudden increase in oil prices might affect the supply side of those products for which oil is used as raw material or input. The built-in inflation is brought about by a wage-price circle where workers try to keep prices up in keeping with the market price and employers in turn pass this labor cost on to the consumers in the form of higher prices. The essential way out from inflation is the monetary policy and central banks resort to high interest rates and slowed money supply growth to control inflation. Keynesian school of economics suggest that demand can be increased during recession and decreased during boom in order to control inflation; this might be brought about by both monetary and fiscal policy adjustments (Ball). Inflation in Bahrain Inflation as not really an issue for Bahrain as it
Wednesday, October 16, 2019
Applying Counting Method Speech or Presentation Example | Topics and Well Written Essays - 500 words
Applying Counting Method - Speech or Presentation Example At first we had 5 choices, then 4, and then 3.The total number of options was 5*4*3=60. We had to pick three pupils out of the five. To do this, we had to start with all the 5 options, then4, and, lastly, 3 when we ran out of the top three positions. The factorial for this is: 5! =5.4.3.2.1, but we only need 5*4*3 .So how do we get rid of 2*1? If we do 5!/2!, we get this: 5!/2!=5.4.3.2.1/2.1=5.4.3we used 2, because this is what remained after picking the top three positions. This can further be expressed as: 5! / (5-3)! This means that we use the first three numbers of 5! On the other hand, combination is very simple, since the order does not matter. Dog, cat, and a goat. Letââ¬â¢s figure out how many different ways these animals can be rearranged. We have 3 choices for the first animal, 2 for the second animal, and 1 for the last one. Therefore, we have 3*2*1 ways to rearrange the animals. Since there are 30 runners for the qualifier, the first run can be ran by all of them, the 2nd by 29, the 3rd by 28, the 4th by 27, and so on until the remaining individual is one in the track. Hence, the answer is 30
Economics Essay Example | Topics and Well Written Essays - 2000 words
Economics - Essay Example Apart from economic factors, cultural and political issues also affect inflation rate. The activities of workersââ¬â¢ union might create pressure on the wage rate preventing any downward movement of the same. Therefore production cost will not come down and hence increase in supply is restrained. An increase in supply of money or credit in the economy can make the incidence of inflation strong in an economy. The global financial crisis which resulted from the excess credit and increasing defaulters especially in the housing loan market led to inflationary pressures owing to increasing demand and cost of basic necessities around the world (Nanda). For the Gulf Countries where oil is a key commodity and factor responsible for growth, the rise in oil prices from 2005-2006 led to increase in related products. The increase in oil prices across the world has been occurring at a rate higher than the depreciation of the dollar. The spot price of oil rose by 171.9 percent ($65.66) and achi eved the highest point in August 2006 (reaching the peak at $76.01). Depreciation of dollar across a wide spread of currencies took place at 13.8 percent (Oxford Business Group 38-39). The paper attempts to compare two different Gulf Countries, Bahrain and UAE, with respect to the incidence and impact of inflation. Inflation The first outcome of inflation is usually reflected in the purchasing power of money. Hence there is a reduction in the real value of a good. Inflation rate which measures the price inflation has both positive and negative impacts on the economy. On one hand it reduces the real value of wealth in hands and on the other it creates an expectation of inflation in future and leads to a fall in savings and investments. If there is increased activity of accumulation of goods in apprehension that price might rise further, then there might be a crisis of supply of products in the market. If one considers the positive effects it may be reflected in adjustments of nominal interest rates which help in controlling recessions. Seeing from the demand side, low and moderate inflation are caused by demand side changes or alteration in the number of suppliers at times of crisis and increase in money supply. Going by the Keynesian viewpoint, demand-pull inflation is brought about by a rise in private and government expenditure leadings to high demand. This reflects a grot hint he economy since such higher demand and favorable market situation will lead to higher investment and growth. However cost push inflation which is brought about by supply side shock (fall in supply) could be owing to some natural calamities or high prices of inputs. For instance a sudden increase in oil prices might affect the supply side of those products for which oil is used as raw material or input. The built-in inflation is brought about by a wage-price circle where workers try to keep prices up in keeping with the market price and employers in turn pass this labor cost on to the consumers in the form of higher prices. The essential way out from inflation is the monetary policy and central banks resort to high interest rates and slowed money supply growth to control inflation. Keynesian school of economics suggest that demand can be increased during recession and decreased during boom in order to control inflation; this might be brought about by both monetary and fiscal policy adjustments (Ball). Inflation in Bahrain Inflation as not really an issue for Bahrain as it
Tuesday, October 15, 2019
Strong relationships Essay Example for Free
Strong relationships Essay Dreams can be described as reflections, unconscious wishes, and a by-product of mental house keeping or interpreted as a brain activity. Guiley (1998) says, ââ¬Å"Dreams are the inner powers that project out creativity which has changed livesâ⬠. All these descriptions may be true or false depending on which type of the dream that has occurred during the night. In is interesting that a greater percentage of dreams occur at night. Then the question is why do many dreams occur at night? Noticeably, this it the time of resting and every body part or organ rest or relax. This means organs like the heart, lungs and the brain do not rest but they relax. Therefore, this time of the day, that is during rest some crucial brain activity goes on and in many occasions it is a reflection of what might have happened during the day. There are many types of dreams, some of them turn out to be nightmares where some people may walk at night, others scream and few have lucid dreams for instance some people dream of playing football and they throw legs at night as if they are kicking the ball they had watched or they had played during the day whereby some end up kicking anything near them only to be awakened and find they are not injured. Other dreams may be about relationships especially among lovers. Parker (1999) says, ââ¬Å"There is believe that the mind consists of three things that is the ego, the super ego and the id. The unconscious side that is the id consists of instinctive drives called pleasure principleâ⬠et al Freud (2001) agrees, ââ¬Å"that most desires expressed in dreams are sexualâ⬠. This is may be the reason why people experience sexual arousal and wet dreams. There are strong relationships between physiological theories and psychological theories. It has been concluded by the scientists that many dreams occur during the Rapid Eye Movement (REM). Every person dreams, right from the toddlers or infants to the aged but dreams differ. This means a teenagerââ¬â¢s dreams may not be same as of the elderly dreams. Averagely everybody dreams every night but the intensity of the dreams differ depending on the reflective stance of the brain at that time. Time is also a factor for dreams, some dreams are short and others are long winded depending on the time taken in dreaming. Parker (1999) observes that, ââ¬Å"a dream takes roughly 30- 45 minutes and those awakened during the REM are able to remember or recall their dream at that momentâ⬠. Some dreams are so vivid that they can be revealed immediately a person wakes up. Many of the dreams are forgotten before or immediately a person wakes up. Them memory plays an integral role on dream remembrance as Christos (2003) concurs, ââ¬Å"Neural network models suggest that memories are constantly competing with each other, they change with time and some memories are easily displacedâ⬠Dreams are extremely important in many ways, for instance, prophets during the ancient times were able to discern events to come and or befall people or a community through dreams. Lukeman (2001) says that, ââ¬Å"in some dreams, we tap into prophecy and other kinds of information that cannot be known in the ordinary sense. â⬠Parker (1999) agrees that, ââ¬Å"whether old superstitions can help you see the future is questionable but a great deal of empirical evidence suggest that dreams can be prophetic. The most interesting dreams of the future can come through a phenomenon called lucid dreams. â⬠A good number of musicians confess that their greatest musical hits appeared in dreams at night. One day I dreamt on how to manufacture a pistol and if I had the time I could have drawn the sketch just the way I saw it in the dream but unfortunately three day passed and I forgot the whole sketch. The dream came about after one of the family members had regularly thwarted my good plans to go overseas for further studies. So, I was extremely annoyed and I could think of any way to eliminate him. Luckily I did not do it and today the family member is a good neighbor. This dream falls under the psychological theory. I had suffered psychological torture after losing a golden chance to go overseas for further studies. Therefore good things produce good dreams while bad and stressful things cause bad or evil dreams. Conclusion Dreams are essential for psychological and physiological aspects of life. Lukeman (2001) says, ââ¬Å"Dreams are crucial to every day health and well being. Studies have shown that bizarre things start to happen when people are prevented from dreaming. Things like confusion, exhaustion and physical illnesses start to manifest. â⬠References: Christos, G. (2003). Memory and Dreams: The Creative Human Mind. New York: University of New South Wales. Freud, S. (2001). On dreams. New York: Dover Publications. Parker, C. H. (1999). The Hidden Meaning of Dreams. Carlsbad: Sterling Publishers Guiley, R. H. (1998). Dreamwork for the Soul. Boston: New York: Berkely Trade Publishers. Lukeman, A. (2001). What Your Dreams Can Teach You. New York: M. Evans and Company Inc.
Monday, October 14, 2019
Analysis of Doctrine of Equity
Analysis of Doctrine of Equity The doctrine of equity was created to fill in the gaps of common law by providing more flexible remedies, unlike common law which only provide damages such as injunction, specific performance, equitable estoppel etc. Equity only governed by the maxims where it is based on the principles of fairness and conscience and are not as strict as common law. Hence, as the doctrine of equity developed and became more and more flexible in the past centuries, it has now been argued by many academics that equity is now too conceptually messy to be useful.Ãâà It has been argued that equity is a blend of strict rules and discretionary principles which attributes to English Law with its flexibility. He further explained that equity comprised of firm rules as well as discretionary principles which will be applicable in different circumstances.[1] In deciding this, the flexibility of equity would be discussed, especially in the areas of such as the three certainties, Quistclose trust and doctrine of fiduciaries. In the case of Knight v Knight[2], Lord Langdale MR had laid down the three certainties test to create a valid private express trust. Certainty is an important element in trust as without certainty, the intention, object and subject of the trust could not be determined by the courts which would then lead to an invalid trust. Under certainty of intention, the settlor must use very clear words and expression to impose a legal obligation for the trustee to hold the property on trust. Generally, imperative words are more encouraged to be used in a will as compared to precatory words. In the case of Re Adams[3], the phrase in full confidence was used in the clause and it was held that there was no trust created as there is no imperative words used in the will. However, in Comiskey v Bowring[4], even the same phrase was used as in Re Adams case, but it was held that the wording created a trust. It could be submitted that the courts now no longer only look at a single word to determine whether there is a trust but look at the whole of the will. In more complex situations where there are no documents available, the courts might infer intention from acts or the words of the parties. In Paul v Constance[5], it was held that the words the money is as much yours as it is mine is sufficient to make a valid trust as there was repeated conduct and has a clear intention. It was suggested that the courts are being too generous in the decisions. However, in Jones v Lock[6], it was held that it was insufficient to manifest a clear intention for the father to create a trust for the son. The problem is that both cases were lack of specific intention to create a trust, there were only general intention to benefit. However, both cases were held differently. It could be argued that the actions were louder than the words in Pauls case. Gardner suggested that the difference of both cases was merely the reflection of changing judicial attitudes.[7] Next, under the certainty of subject matter, the test used by the courts would be whether the property could be certainly identified. However, the courts have recently created an artificial distinction between tangible and intangible property. In Re London Wine Co[8], it was held that no two bottles of wine are alike and therefore it could be identified for their customers. However, in Re Goldcorp Exchange Ltd[9], it was held that the claimants whose gold bullion had been segregated were successful in the claim but not those whose bullion had not been segregated. The reasoning was that the stock of the gold has been constantly changing and it was hard to say which particular piece of gold belongs to any particular customer. It could be submitted that the courts were trying to uphold the principle of fairness by having a different decision from Re Londonscase as the tangible property items here could not be segregated properly. On the other hand, in Hunter v Moss[10] where the property is intangible, a different approach was taken by the courts. In the case, it was held in favour of the claimant and stated that the segregation as in tangible property is not necessary where a trust is made over an intangible property. The reasoning for this is that since the shares is indistinguishable from one another, they will be treated as equal. Based on all three cases above, it could be seen that this area is messy as this certainty has not been applied consistently and the judges have too much discretion changing the judicial attitudes. Lastly, the certainty of object matter required that there must be ascertainable beneficiaries in a trust. Re Baden (No.2)[11] had shown that there are different approaches to deal with when there is a class of objects in a discretionary trust. The test used in the case was originated from McPhail v Doulton[12] where the application of a complete list test was impossible and borrowed the is or is not test from Re Gulbenkians Settlements[13] to determine the beneficiaries. However, there are 3 interpretations on the applicability of the test. Firstly, Sachs LJ upheld the literal application of the original test, but reversed the burden of proof on the claimant to proof that he falls within the class of beneficiaries. Sachs LJ further noted that this does not apply to all discretionary trust situations as a lot of trust with uncertainty would be validated. Secondly, Megaw LJ suggested the approach used in Re Allen[14]which was overruled by Re Gulbenkians case where it held that a trust should be valid if a substantial number of people can show that they are in the class. Finally, Stamp LJ suggested a strict approach where he stated that it is necessary for both conceptual and evidential certainty to exist without any unknown of the certainties. Any unknown of the certainties would lead to an invalid trust. It could be submitted that this area would be too messy for the future cases to refer as there are too many different views. The flexibility of equity could also be found in Quistclose trust which created by Lord Wilberforce in Barclays Bank Ltd v Quistclose Investments Ltd[15]. The Quistclose trust arises when a company borrows money with a particular purpose in mind for that money. Lord Wilberforce suggested there are primary trust to pay dividend and secondary trust arose in favour of the lender if primary trust failed. However, this was heavily criticised as it failed to meet the three certainties to be a valid trust. Later, Lord Millet in Twinsectra v Yardley suggested that there is only one resulting trust instead of two trusts while majority of the court held that it was an express trust. In Re EVTR[16], Dillon LJ suggested that it was a constructive trust for the purpose of the loan.Moreover, academics like Alastair Hudson had suggested that the better analysis for this should be an express trust.[17] Furthermore, in Re Farepak Food[18], Mann J held that there was no trust and described this is as a contractual relationship as opposed to trustee-beneficiary.[19] Furthermore, equity also shown its flexibility in fiduciary area. A fiduciary is a person who holds a position of trust and confidence. Fiduciary has the duty to act in the best interest of the principal in a fiduciary relationship. A fiduciary is bound by the no conflict rule where he must make sure that his duties to the principal do not conflict with his own interest and not allowed to make a profit. The leading case would be Boardman v Phibbs[20] which involves trust where it applied the strict rule which originally from cases such as Keech v Sandford[21] and Bray v Ford[22].The decision was a made in majority of the judges while the other two judges gave dissenting judgments. Lord Upjohn in dissenting suggested that the case should be approached in a more equitable angle and should be decided on its own individual facts instead of laying down a strict rule to be followed like the common law courts. However, in Murad v Al-Saraj[23], the majority of courts again decided by following the rules. Arden LJ from the majority suggested that the court should revisit the inflexibility of rule of equity in harsh circumstances. Furthermore, Jonathan Parker LJ from majority also suggested that it is the time for the court to relax the severity of the rule. In minority, Clarke LJ suggested that the fiduciary could argue for a share in profits even though they breached their duty by reasoning with Warman International v Dwyer[24]. In Foster Bryant Surveying v Bryant[25], it was held that the defendant was not required to account his subsequent profit as the facts were different from the traditional cases. It was suggested that this case law would only be followed when there are same facts in the future. Based on the above, equity has been flexible to evolve to suit the needs of the society. Hence, it is tremendously complex as it was built centuries of laws, but the courts are free to generate new principles and to adapt or apply the old ones depending on the situation. As suggested by Alastair Hudson, equity forces us to consider the plight of the individual in this complex world and to save that individual from being caught up in the legal machine or exposed to irremediable suffering.[26] In conclusion, it could be submitted that equity is still useful even though it might be conceptually messy as shown above. However, this would be inevitable as equity has to be flexible but it would be also required to maintain some consistencies across the cases to prevent the law from being vague. (1650 words) Bibliography Books Gardner S, An introduction to the Law of Trusts (3rd edn OUP 2011) Hudson A, Equity and Trust, (8th edn, Routledge, Oxon, 2015) Hudson A, Great Debates in Equity and Trusts,(1st edn, Palgrave Macmillan 2014) Electronic Sources Alastair Hudson, The Fundamentals of Quistclose Trusts, http://www.alastairhudson.com/trustslaw/Quistclose.pdf accessed on 13rd February 2017 Table of Cases Barclays Bank Ltd v Quistclose Investments Ltd [1970] AC 567 Boardman v Phibbs [1967] 2 AC 46 Bray v Ford [1896] A.C. 44 Comiskey v Bowring-Hanbury [1905] A.C. 84 Foster Bryant Surveying Ltd v Bryant [2007] EWCA Civ 200 Hunter v Moss [1993] 1 WLR 934 Jones v Lock [1865] 1 Ch App 25 Keech v Sandford [1726] Sel. Cas.Ch.61 Knight v Knight [1840] 3 Beav 148 McPhail v Doulton [1971] AC 424 Murad v Al-Saraj [2005] EWCA Civ 959 Paul v Constance [1977] 1 All ER 195 Re Adams Kensington Vestry [1884] LR 27 ChD 394 Re Allen [1953] 1 All ER 308 Re Badens Trusts (No.2) [1973] Ch 9 Re EVTR [1987] BCLC 646 Re Farepak Food and Gifts Ltd (In Administration) [2008] BCC 22 Re Farepak Food and Gifts Ltd (In Administration) [2008] BCC 22, 34 Re Goldcorp Exchange Ltd (In Receivership) [1994] 3 WLR 199 Re Gulbenkians Settlements Trusts [1968] UKHL 5 Re London Wine Co (Shippers) Ltd [1986] PCC 121 Warman International v Dwyer [1994-5] 182 CLR 544 [1] Alastair Hudson, Great Debates in Equity and Trusts,(1st edn, Palgrave Macmillan 2014) [2] Knight v Knight [1840] 3 Beav 148 [3] Re Adams Kensington Vestry [1884] LR 27 ChD 394 [4] Comiskey v Bowring-Hanbury [1905] A.C. 84 [5] Paul v Constance [1977] 1 All ER 195 [6] Jones v Lock [1865] 1 Ch App 25 [7] Simon Gardner, An introduction to the Law of Trusts (3rd edn OUP 2011) 52-3 [8] Re London Wine Co (Shippers) Ltd [1986] PCC 121 [9] Re Goldcorp Exchange Ltd (In Receivership) [1994] 3 WLR 199 [10] Hunter v Moss [1993] 1 WLR 934 [11] Re Badens Trusts (No.2) [1973] Ch 9 [12] McPhail v Doulton [1971] AC 424 [13] Re Gulbenkians Settlements Trusts [1968] UKHL 5 [14] Re Allen [1953] 1 All ER 308 [15] Barclays Bank Ltd v Quistclose Investments Ltd [1970] AC 567 [16] Re EVTR [1987] BCLC 646 [17] http://www.alastairhudson.com/trustslaw/Quistclose.pdf, The Fundamentals of Quistclose Trusts, accessed on 13rd February 2017 [18] Re Farepak Food and Gifts Ltd (In Administration) [2008] BCC 22 [19] Re Farepak Food and Gifts Ltd (In Administration) [2008] BCC 22, 34 [20] Boardman v Phibbs [1967] 2 AC 46 [21] Keech v Sandford [1726] Sel. Cas.Ch.61 [22] Bray v Ford [1896] A.C. 44 [23] Murad v Al-Saraj [2005] EWCA Civ 959 [24] Warman International v Dwyer [1994-5] 182 CLR 544 [25] Foster Bryant Surveying Ltd v Bryant [2007] EWCA Civ 200 [26] Alastair Hudson, Equity and Trust, (8th edn, Routledge, Oxon, 2015)
Subscribe to:
Posts (Atom)