Marketing Essay Example | Topics and Well Written Essays - 2750 words - 6

Showcasing - Essay Example come the fundamental thought of advertising not long before the disclosure of web showcasing, it is essential to comprehend the level in which organizations or firms have in the long run developed dependent on their ability to acquaint their contributions with imminent clients. Some portion of this paper preceding contending the effect of web on the predominant rationale of promoting is the conversation of the essential idea of advertising. The essential data about this bit is the premise of plausible recognizable proof fair and square assuming any; the promoting idea has advanced from the fundamental. Showcasing as we think about it is made out of sub capacities, for example, selling, publicizing and advancements. These sub capacities are normal zones where organizations can really build up their corporate preferred position (Kotler and Keller, 2008). What makes showcasing so alive today is because of basic five directions controlling any advertising exertion of any association in their promoting exercises. These five directions included creation idea, item idea, selling idea, showcasing idea and cultural promoting idea. Items or administrations are two most basic contributions of organizations, however today some of them only from time to time get a lot of consideration as a result of poor correspondence of data given to individuals. Some may have experienced a specific item or administration however couldn't care less enough because of absence of subtleties or recognition about it. A market-driven system is consequently significant so as to get the shoppers familiar with company’s contributions. One of the approaches to portray a market-driven organization is to watch their cooperation with their objective purchasers. Organizations are continually anticipating unfed necessities of their clients and in this manner they for the most part reward them with relating arrangements. This is the situation of client focused method of managing business with promoting (Kotler and Keller, 2008). Be that as it may, what is by all accounts the most noteworthy and differentiating part here lies on the limit of each firm to pass on or bestow data to its

British and Canadian Legislation International Marketing

Question: Examine about the British and Canadian Legislation International Marketing. Answer: Presentation: As referenced by Pomering (2013) promotions are the channel of correspondence between the advertisers and the customers. Thus, any special crusade needs to fit in with the social and lawful standards of a nation where it will be circulated. In the given contextual investigation, the publicizing effort of Tourism Australia confronted various limitations in the outside business sectors because of its absence of focus on the lawful limits of the on-air promotions. In UK, the BACC (Broadcast Advertising Clearance Center) represented a restriction on the Tourism Australia promotion with the slogan So where the ridiculous damnation right? (Charbonneau 2013). As indicated by the Center, the word grisly was disregarding the codes of publicizing of the Broadcasting Act 1990 and the Communications Act 2003. In addition, in 2007, the Advertising Standards Authority (ASA) requested Tourism Australia to expel all banners from all the motorways as it was disregarding the principles concerning duty to youngsters in the British Code of Advertising. Then again, in Canada, the Canadian Broadcasting Corporation joined the running of the promotion during family programs as the Television Bureau of Canada felt the word Hell as hostile for kids. Also, the CRTC found that that the promotion inferred brew is essential for pleasure and subsequently the ad needed to confront an altering (Charbonneau 2013). Subsequently, it is significant for the promoters to know about the relevant media laws to guarantee no legitimate problems and better market correspondence. As referenced by Pomering (2013) the superfluous legitimate issues identified with the promoting efforts increments operational expense. Besides, it is additionally impeding to the brand picture of an organization. References: Charbonneau, J., 2013. So where the grisly hellfire are you?: Tourism Australia goes head to head with British and Canadian enactment. Global Marketing: An Asia-Pacific Perspective, pp.638-642. Pomering, A., 2013. Indigenous character in the country brand: strain and irregularity in a country's travel industry promoting efforts. Corporate Reputation Review, 16(1), pp.66-79.

Sample of Why You Want to Join This School Essay

Sample of Why You Want to Join This School EssayA sample of why you want to join this school essay is something that is good for students who are applying for an entrance exam. This is also a very good way to evaluate the kind of programs they can enroll in. Some of these programs actually require an essay. It also gives students an idea on what kind of student they should be if they intend to get into the program they are looking for.There are some important things that must be included in these essays. First and foremost, the school's main mission and the main purpose of which they were established. Also, they need to know about the kinds of students they will be dealing with. They have to know the kind of attitude and personality that they will be dealing with.Another thing that you need to include in a sample of why you want to join this school essay is the school's graduation rate. The higher the percentage, the better the chances of success. Remember that students cannot work h ard if they do not feel that they will be successful.In a sample of why you want to join this school essay, you need to emphasize how the school changed the lives of its students. For example, if they went through difficulties at the beginning, they somehow managed to overcome them. If the students faced a challenge that was too big for them to handle, they still somehow overcame it and found the strength to continue with their studies.They also need to show how they have met challenges and still managed to survive despite the challenges. How they managed to survive all the obstacles and still managed to become the best in their field.Also, samples of why you want to join this school essay should be written well so that it can get a very good result. Remember that the good grades you have gained in school do not guarantee that you will be successful at college. The entrance exams are given by different entrance exams.But the entrance exams do not mean that you are a good student. It means that your knowledge and skills are really good enough to pass the tests given by these examinations. So, if you are able to get into a school that does not have any entrance exams for you, it is because you are indeed a good student.To make sure that you write a good essay, you need to take samples of why you want to join this school essay. Learn how to compose and express yourself properly. Also, do not worry that it will be hard for you.

Economy Essay Example | Topics and Well Written Essays - 500 words - 1

Economy - Essay Example tanding of how the economy is using rare assets, financial experts dig into characterizations of GDP and its consequences for the few types of spending happening in the nation. The GDP is isolated into four principle parts. These incorporate utilization, speculation, government buys and net fares. Every one of these segments when included equivalent the GDP. The connection among GDP and its four segments can be communicated as a condition as follows: This condition speaks to a personality (Mankiw 208). This implies the factors of the condition will settle on the legitimacy of the condition. In the condition, a wide range of consumption that is done in the nation are grouped into both of the parts of the GDP. The biggest piece of the GDP is utilization buys and comprised 70% of the GDP in the US in 2007 (Mankiw 211). They involve the consumption of the family unit on shopper products and ventures in a specific period. Utilization buys involve a stream idea (Gwartney et al. 153). The administrations and merchandise that the purchasers decide on are generally nondurable in nature. Uses done on food, dress, diversion and clinical administrations are a piece of utilization buys. These items are not enduring and are spent in a limited ability to focus time. Then again, sturdy items, for example, vehicles structure only one-ninth of the absolute utilization buys and are spent over an extensive stretch of time. Speculation involves the creation of capital products that are going to cause a progression of future administrations. They are not devoured over a brief timeframe and incorporate the ventures of organizations into apparatuses and types of gear just as houses. Net private venture can be completed to swap old hardware or for adding net options to the current pool of capital resources (Gwartney et al. 153). Net speculation is significant in knowing the future extent of efficiency of the economy. In 2007, they rose to 15% of the GDP in

Presentation to Arizona Task Force on Policy and Planning Assignment

Introduction to Arizona Task Force on Policy and Planning - Assignment Example Most importantly, despite the fact that the meaning of maintainable transportation changes, numerous definitions will in general suggest diminished reliance on cars, expanded utilization of open mass travel and expanded utilization of non-mechanized types of transport, for example, bikes and strolling. Dark (2004) especially characterizes practical transportation as the vehicle framework that can meet the present portability and transport needs without trading off the capacity of capacity of things to come ages to have the option to address such issues. In any case, Black (2004) contends that the contemporary vehicle frameworks are right now being ruined from getting reasonable by various factors some of which incorporate lessening oil saves, worldwide environmental effects of the vehicle frameworks, clog and fatalities among others. There are various reasons why I feel that a paradigmatic move in the present Arizona transport arranging is direly required. Despite the fact that Arizona like numerous different states has consistently relied upon the versatility arranging way to deal with build up its vehicle arrangements, this methodology is progressively getting impractical because of wide scope of developing issues including ecological contamination concerns, lessening oil stores, blockage and rising fatalities and expanded endless suburbia among others. Availability arranging approach fundamentally centers around controlling area use game plans so as to decrease the voyaging needs of the individuals from the general public. In numerous pieces of the United States, this may incorporate employments lodging balance, (for example, by finding lodging close to potential working environments), creating travel towns just as empowering manageable types of transport, for example, mass travel, bikes and pedestrianism. Contrasted with the â€Å"mobility† approach that is to a great extent worried about upgrading the capacity of suburbanites to travel quick,

Where can I find topic-wise Cambridge A-level past papers

Where can I find topic-wise Cambridge A-level past papers? Students who are searching for topics from past A-level papers have a number of sources available to them, but care should be taken when using these model papers to ensure that they are properly cited as a source (if they are used) or are otherwise revised to the extent that plagiarism-detection services will not identify matches between the model paper and their own. In addition, there are some sample exemplary papers available here, as well as past question and specimen papers together with their corresponding marking schemes through Cambridge International Examination’s Web site. The Cambridge International Examination’s Web site also offers a pull-down menu that allows users to select A- and AS-level papers according to research areas of interest ranging (alphabetically) from Accounting to Urdu. In addition, the Cambridge International Examination’s Web site also features a resource center that includes learner guides, syllabi, textbooks, and more that can he lp students explore topics of interest in-depth.

Martin Luther King, Jr. Essay - 825 Words

Martin Luther King, Jr. (Essay Sample) Content: Martin Luther King, Jr.NameInstructorCourseDatePaper OutlineThe roman numerals refer to paragraphs while the bullets refer to the points to be covered. * Introduction * Martin Luther King's date/place of birth * King's life in his religious home * How Martin Luther King started fighting out Segregation * Early stages in the fight for equality * Qualities of leadership portrayed by Martin Luther King * Kings first Organizations in his civil rights movement * Goals set by Martin Luther King * Speeches, letters and demonstrations led by Martin Luther King * How he used intelligence in his speeches/letters * Obstacles faced by King in his demonstrations * Nobel Prize * Martin Luther King as a Legend * Why Martin Luther King deserves to be referred to as a legend * King's impact in America * How his words touched many Americans * King's death * Conclusion * Brief summary of the points covered in the essay.Martin Luther King, Jr.Martin Luther King was born in the year 1929, in Atlanta, Georgia. Since his father was a pastor, Martin Luther King was brought up in a religious home, and he followed his father's footsteps. He later became a minister of a Baptist church located in Montgomery, Alabama. Racism prevailed in this city of Montgomery, and as a result, Martin Luther King felt that something ought to be done to eradicate racism in this city. After he was elected as the new president of the MIA (Montgomery Improvement Association), he started various initiatives geared at countering racism. In 1955, Martin organized a boycott against bus transportation after Rosa Park was arrested for not giving up her seat for a white passenger. Actually, this was a good start for great leadership (Schraff 45). This paper aims at discussing Martin Luther King's great leadership, his legacy, and the influences Civil Rights Movement had.Martin Luther King exemplified a leader who is not afraid of anything, and who is ready to use all means in ensuring that rights and privileges of citizens are not violated. He formed several organizations such as the Southern Christian Leadership that helped him to pursue various civil rights activities. Expansion of this organization to national level helped Martin to set a firm foundation for fighting for the rights of his people. He embraced one goal that involved elimination of segregation of black people. He swore not to rest until all his people received equal treatment as the rest of the citizens. By setting such a goal, it shows Martin was a truly dedicated leader, and it depicts excellent qualities of a responsible leader (Gosman 65).In all his speeches, letters, and demonstrations, Martin adopted non-violence acts. Instead of using bloodshed to communicate his demands, he used intelligence to have his demands heard. Even to-date, many leaders refer to Martin's letters and speeches for more knowledge of what good leadership entails. For instance, in his letter 'I have a Dream', he was able to communica te deeply to people's hearts changing the way they perceived black people. King's determination can be noted through the various obstacles he endured in his life. He was thrown to jail and branded a nickname 'Niger', but he did not despair. Through this, he was able to drive fear out of blacks, paving way for realization of equality. Because of his great work, he won Nobel Peace prize at the age of 35 years. The most astonishing thing is that he decided to give over the prize money to finance various civil rights movements. This touched many people for such generosity is rare among leaders (Schraff 113).It is worth referring King as a legend because of the exemplary leadership skills, which he used to set his people free. Through his great speeches, going to jail and the various demonstrations, Martin Luther King can be termed as one of the world's greatest leaders. He showed integrity by being responsible for his actions by facing the law after being accused of various demonstratio ns. After American citizens recognized that King was genuine, and that his actions were geared at ensuring a better America, they were touched, and accepted him as a dedicated leader. Especially his words that all m...

Idealism, Realism, And Marxism - 1559 Words

What do the theories we have looked at to this point (idealism, realism, Marxism) tell us about the prospects, and necessary conditions, for cooperation in international politics? International politics have been in our nation since the beginning of time. Nations have tried to work together and international politics have given many tries a cooperation. In today’s world conflict is always occurring. Many different world issues pop up every single day. Through looking at international relations and the theories included one is able to look beneath the surface to try and figure out what it would take for the nations around the world to cooperate successfully. Every day it begins to seem more and more unlikely for the entire world to get†¦show more content†¦Realism, on the other hand, is the polar opposite. The theory of realism leads people to believe that human nature is fundamentally bad. Those whom are realists look at the world for what it really is. Instead of com ing up with ideas and dreams they work with what is in from of them at the time. This group is made up by those who are driven by the desire to dominate others, form into conflict groups, and perpetually compete for power. This is the side of the world that wants to be the best. Dyson included a strong line in his novel when writing about realists, â€Å"To realists, humans are inherently sinful. We lust for power and dominance, we fear one another, we are violent. This basic nature is unchanging† (27). Right here Dyson helps the reader see how realists really are. They strive for power and want their nation to be the best it could be. This once again comes with good and bad sides. While the determination of this group would help them to get things done, it would also lead to their failures. Due to the ways of which they are so competitive they may resort to violent acts in order to get what they want (27). War may be caused in order to get their way. The third theory that wi ll be brought to attention in this paper is Marxism. This theory differs from the two previous. Marxists have strong beliefs bases off morality along with beliefsShow MoreRelatedThe Traditional Global Environment Evolved Into The Modern Global System1233 Words   |  5 PagesQuestion 1: Starting in 1900, the traditional global environment evolved into the modern global system. As international relations scholars have attempted to examine and explain this change, six worldviews have emerged. These are Realism, Liberalism, Idealism, Neo-Marxism, Constructivism, and Feminism. In an essay format answer, you are to discuss the main characteristics of each worldview. One of the peculiarities of research of international relations is the variety of conceptual constructionsRead MorePhilosophy of Science in Social Research1455 Words   |  6 Pagesapproaches of philosophy of science in social research- * Realism * Empiricism * Positivism * Post positivism * Idealism * Rationalism * Functionalism * Structuralism * Utilitarianism * Instrumentalism * Feminism * Materialism * Skepticism * Nomothetic and Ideographic * Solipsism * Atomism * Holism * Perspectivism * Relativism These are described below- * Realism: Realism is a perspective of social research which representsRead MoreThe Between Domestic And International Affairs1504 Words   |  7 Pagesnations should have the right for self-determination. No one main power should control multiple nations anymore. In 1948, apartheid emerged, where racial segregation was established that would ensure that whites remained the dominant power in Africa. 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Although concentrating on the philosophy of education, itRead MoreAn Ideal Educational Model And How Do Education1386 Words   |  6 Pagesfull potential both as a student and as a member of society. The overview of the different educational philosophies was eye opening to me. The one I disagreed most with was Neo-Marxism. The potential for this ideology is to completely control and dictate the curriculum to promote the ruling classes own agenda. Neo-Marxism seeks to empower and enrich the capitalistic dominant culture. This ideology to me is cold and shows nothing but selfish gain for a socialist government. Schools do not need toRead MoreContemporary Mainstream Approaches : Neo Realism And Neo Liberalism1527 Words   |  7 PagesChapter 8: Contemporary mainstream approaches (neo-realism and neo-liberalism) In the previous chapters, we’ve taken a broad glance of Realism and Liberalism; in this chapter we take a look at the modern version of these political theories and their respective differences. Although Realism and Neo-realism are close in name, they aren’t that close in ideologies. Both theories differ on their definitions of power and anarchy along with their respective model structures of the international system.Read MoreIdealism And Its Impact On Education1668 Words   |  7 Pages As an educator, Idealism was always observe as a Language Arts based theory. Idealism philosophy thrives on logical thinking, a liberal education approach with consequently focusing on theory first ,practice later. The constant effort plus strive that students must accomplish to achieve perfection in reading, writing, speaking and listening is the reason why idealism is paradoxical. Idealism does not take into consideration the constantly changing variables that occur. When I t ook the self-evaluationRead MoreHenry Kissinger : The United States Foreign Policy, Strategy, And Negotiations With Other Countries During The 20th Essay2156 Words   |  9 Pagesformation and breakdown of the Sino-Soviet alliance, the Korean War, Nixon’s trip to China, and the crises in the Taiwan Straits. With the philosophy of Marxism-Leninism, China articulated an alternative vision of its social structure and power relations. Unlike the CPSU who followed orthodox Marxism-Leninism, the CCP integrated the universal theory of Marxism-Leninism with China’s specific condition. China’s national identity was created through a combination of Chinese’s inclusive mindset and ConfuciusRead MoreHenry Kissinger : The United States Foreign Policy, Strategy, And Negotiations With Other Countries During The 20th Essay2162 Words   |  9 Pagesformation and breakdown of the Sino-Soviet alliance, the Korean War, Nixon’s trip to China, and the crises in the Ta iwan Straits. With the philosophy of Marxism-Leninism, China articulated an alternative vision of its social structure and power relations. Unlike the CPSU who followed orthodox Marxism-Leninism, the CCP integrated the universal theory of Marxism-Leninism with China’s specific condition. China’s national identity was created through a combination of Chinese’s inclusive mindset and ConfuciusRead MoreRealism and Liberalism in Literature1397 Words   |  6 Pagescreated and developed by thinkers with the help of historical process. Realism, liberalism, Marxism, constructivism, and idealism are the main theories of international relations but among these 5 mainstream theories, two of them have more validity and effectiveness: Realism and liberalism. These two theories of international relations have a very high reputation and efficiency to explain and understand of the historical process. Realism and liberalism may seem totally different from each other but at

The Benefits And Risks And Auditing Opportunities From...

Youcheng Wang Professor Mohamed Gomma ACCT 208 April 20, 2015 The IT Benefits Risks and Auditing Opportunities from Jacksonville Jaguars 1. Introduction The Jacksonville Jaguars National Football League (NFL) was one of the first major sporting organizations to take advantage of information technology tools to sale snacks and souvenirs in their stadium. From 1995 fans of Jacksonville Jaguars can use Spot Cards to buy drinks, snacks and team souvenirs. In other words, they needn’t to use cash and change to pay for these things. The reloadable Spot Cards, which contain an embedded electronic chip, operate manner similar to other smart cards such as Kinko’s Express Pay cards and many retail establishments including university student identification cards that are used for fee payment, meal and book purchases, and building access. Not only does the Spot Card offer benefits to fans in the stadium, but the use of IT also offers advantages to stadium vendors by providing better financial information when monitoring their business. Though SC offers improvement for the fans and vendors, those sales need assurance that the technology and related information produced is accurate and reliable. 2. Process of IT Payment in Jacksonville Jaguars The payment method of Spot Card at the stadium in 1995 is the first victory try in a major sports stadium. The stadium make the contracts with First Union Bank, (Which latterly was acquired by Wachovia Corporation and now is a part of Fargo

My Community Service At An Elementary School - 2022 Words

I did my community service at an elementary school called daily academy and I taught art to multiple grades. I needed a lesson plan that multiple grade groups could benefit from which lead to my research question; how can two different grade groups learn from the same lesson plan? multi-grade classrooms use lesson plans the entire class can benefit from, like the the one I created, multi grade classrooms have been around as long as the American school system has. My question came from my experience working at an after school teaching program teaching children from kindergarten to sixth grade; I had to teach multiple grade groups at a time, which lead me to creating a lesson plans that would benefit the entire class. I had to keep in mind according to my research; each student s attention span is a minute longer than their age, the age of a student doesn’t determine their ability, and when pairing students to work together, to think about their strengths and weaknesses and be s ure the exercise will benefit all students involved in each lesson. I did not have that much experience with multi-grade classrooms, it was a new concept for me to understand; I looked on many different websites for teachers who teach multi-age classrooms; on these websites I looked for multi-age lesson plans so I could get an idea on how to I would go about preparing my multi-age lesson plans for my class. Eventually I created many different lesson plans I could use in the classroom when I started myShow MoreRelatedVolunteer in a Elementary School Essay600 Words   |  3 PagesMildred Rivas 11-29-2010 Social Justice Volunteering in an elementary school Volunteering is a fulfilling experience. Many people do not take the opportunity to volunteer in their children’s school for a variety of reasons. In fact, volunteering at your child school give you a lot of opportunity and experiences. Personally, I began my volunteer experience this year at Irving Elementary School, ever since that first volunteering opportunity available to me. From helping young studentsRead MoreBecoming An Elementary School Teacher Essay800 Words   |  4 PagesBecoming an Elementary School Teacher An elementary school teacher has numerous daily duties and procedures to follow throughout a school day. Some of the most important task that an elementary school teacher has to do are planning lessons and assigning homework, maintaining grade books, and creating a positive learning environment for students. 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One of the teachers was Mrs. Stevenson who was a third grade teacher; Mrs. Stevenson inspired me to become a teacher. Her students were always first and she made learning fun. One day I will be a great teacher has Mrs. Stevenson. My name is Nancy Perez. I was born on May 24, 1980. I was raised by my grandparents who I truly appreciate for all their hardRead MorePersonal Statement : An Elementary School1117 Words   |  5 Pagesthat most informed me of my values include my parents, my high school teacher Mr. DeLuca and my internship mentor Dr. Henkel. My parents have informed me in values to do the best I can in life and also to show to show respect and kindness to those who you know and do not know. They also have informed me in other values, especially in wanting to pursue a career profession that would contribute to a person’s life. There overall values that they instilled to me help shaped my other values and other participationRead MorePersonal Narrative My Life Essay578 Words   |  3 PagesNarrative My Life I never really thought about where my life was going. I always believed life took me where I wanted to go, I never thought that I was the one who took myself were I wanted to go. Once I entered high school I changed the way I thought. This is why I chose to go to college. I believe that college will give me the keys to unlock the doors of life. This way I can choose for myself where I go instead of someone choosing for me. I have chosen to go to the local community collegeRead MoreCultural Diversity At Washington Elementary School883 Words   |  4 PagesFor my 5th EDUC Lab, I had to go to a local elementary school and take a walk around its neighborhood. 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I consider this town, something, to be very important to meRead MoreMeadow View Elementary School Is My Practicum Site For My Bachelor Of Social Work Essay1461 Words   |  6 PagesMeadow View Elementary School was my practicum site for my Bachelor of Social Work (BSW). The assigned unit, was the Family Resource Center (FRC) which is a government funded agency. Erica Scott is the FRC Coordinator at Meadow View Elementary School, while completing the practicum, Erica Scott demonstrated the epitome of a great social worker. The social work profession requirements include: Being flexible as knowing how to prioritize and complete several tasks at once is crucial to getting thingsRead MoreMartin Luther King, Jr.949 Words   |  4 PagesAs a child, my first memories with race were when my mother was trying to integrate more Native American representation in my early media. However, the lack of Native American representation in children’s books and movies made her search to find fitting and accurate role models for me difficult. In the end, I only had Disney’s Pocahontas and a series of books about Kaya, an American Girl doll. Although she wanted me to learn more about my Native American heritage, these two examples were the only

Joseph And The Bible - 1623 Words

But Joseph himself also had two children – Ephraim and Manasseh. In taking away her disgrace, God showered Rachel with His grace. The Bible does not tell us anything more about Joseph until, at the age of seventeen, we read about him tending his father s flocks with his brothers (Genesis 37:2). Joseph was the favourite of his father, Jacob, since he was the son of Jacob’s old age (Genesis 37:3) and the first born son of his favourite wife. Joseph lived 110 years and there is not a single sin attributed to him. †¢ Joseph endured trials and afflictions that most of us cannot even imagine and nowhere does the Bible ever hint that his faith in God wavered. †¢ Whether he was in the pit, the palace, or the prison, He was the same man. †¢ Hardships did not harden his heart. Riches and power did not corrupt him. †¢ He was hated misunderstood, falsely accused, mistreated, and suffered unjust treatment, yet he never complained In many ways Joseph is a picture of the Lord Jesus Christ. †¢ He was beloved by his father and obedient to his will. †¢ He was hated and rejected by his own brethren and sold as a slave. †¢ He was stripped of his robe. He was sold for silver. He was slandered and lied about. †¢ He was elevated from the place of suffering to a powerful throne. No wonder Joseph is considered a type of Jesus Christ! Jacob, has just finished blessing Naphtali and then his son Joseph comes forward. Jacob pronounces a long blessing on Joseph. Let us consider Jacob’s blessings on Joseph: I.Show MoreRelatedThe Story of Joseph in the Bible and the Koran Essay1068 Words   |  5 PagesJoseph: From the Hebrew Bible and the Koran The Bible and the Koran are both glorious books of the world’s most flourishing religious cultures, Christianity and Islam respectively. At first glance, when you read the story of Joseph from the Hebrew bible and the Koran, they fundamentally seem to talk about similar ideals and storylines. They, however, have some deep seated differences, that may be a little philosophical in nature or might depend on the particular paragraph that we’re comparing. Read MoreA New Way to Read and Study the Bible in Michael Joseph Browns They Don’t Tell You: A Survivor’s Guide to Biblical Studies1370 Words   |  6 PagesMichael Joseph Brown, unveils new ways to read and examine the Bible in his book, titled â€Å"What They Don’t Tell You: A Survivor’s Guide to Biblical Studies†. Although quite technical, the guide, not book, really goes into depth on the process of studying the Bible and its documents. Brown has a new and refreshing way of giving t he reader this information that is necessary in a small group, or for a Biblical scholar. This guide is not meant solely for the biblical scholar and talks in detail aboutRead MoreThe Bible And The Quran968 Words   |  4 Pages The Bible and the Quran, while rooted in many of the same stories, have vast differences that reflect the respective audiences of each religious text. The Bible, which is tailored to Judaism, includes many lessons and covenants involving land and the promise of prosperity; Jews had been uprooted from their ancestral home and needed the reassurance that there were better days to come, the Bible offered this solace. On the other hand, Muhammed is concerned with convincing polytheists that there isRead MoreBible Vs. Koran Essay1623 Words   |  7 PagesThe Bible and The Koran A Comparative Analysis Christianity and Islam have several similar aspects. Both religions praise the same God, although they each have a different given name. Muslims refer to their god as Allah, and Christians simply refer to their god as God. Both religions are monotheistic, and both even have a set of religious laws that all who are righteous abide by. Muslims follow the Five Pillars of Islam, while Christians follow the Ten Commandments. Both religions even have theirRead MoreBible vs. Koran1661 Words   |  7 PagesNiccole Culver World Literature I Professor Walker March 20, 2007 The Bible and The Koran A Comparative Analysis Christianity and Islam have several similar aspects. Both religions praise the same God, although they each have a different given name. Muslims refer to their god as Allah, and Christians simply refer to their god as God. Both religions are monotheistic, and both even have a set of religious laws that all who are righteous abide by. Muslims follow the Five Pillars of Islam, whileRead MoreThe King James Version Of The Bible1517 Words   |  7 Pagesâ€Å"And Joseph found grace in His sight, and he served Him, and made him overseer over his house, and all that he had put into his hand† (Genesis 39:4). This is only one example of the many in the King James Version of The Bible, that tells one who Joseph really was. Joseph was only 17 years old when he was introduced in the Bible. Joseph, was his father’s favorite out of all his brothers, he knew it-and so did they. He received a coat of many colors, which back in this time period everyone had coats;Read MoreThe Field Of Biblical Literary Criticism1168 Words   |  5 Pagesargues that the Bible is a largely cohesive literary text to be read with a literary purpose. In this essay it is asked if assumptions about texts predicated on the study of modern literature can be profitably applied to a multiple-authored, multi-layered collection of ancient provenance such as the Hebrew Bible and offers a brief critique of Alter s discussion of the artistic merits and unity of Genesis chapters 37-39. For a thousand years the Western world has looked toward the Bible as a work ofRead MoreConflicts Of Literature : The Foundation Of The World1425 Words   |  6 Pageswith one of the most popular being the Bible. Known as the world s best-selling book, the Bible has influenced many sectors of society including religion, history, language and lifestyles. Despite the book’s evident influences on society throughout history, the studying and teaching of this spiritual book has significantly decreased generation by generation. John Steinbeck, a credited author, was internally missioned with developing a spiritual need of the Bible in creating the novel To a God UnknownRead MoreThe, By John Wyndham1313 Words   |  6 Pages like to believe that morals are easily determined, but that is far from the truth. To act in juxtaposition, to perform acts that the world would deem immoral, requires a certain level of courage that can be found in the character that is Joseph Strorm. Joseph S trorm is acting in a morally-just sense because as acting patriarch of Waknuk, he is making the difficult decisions that in retrospect, will be essential to the survival of the norms. His questionable acts are in regards to to his fear ofRead MoreEssay about Biblical Themes in Shakespeares the Tempest1742 Words   |  7 Pagesadmired writers who ever lived. He certainly knew his craft and was familiar with all of the literature available at the time. One of the greatest books ever written was of course the bible. Written over the course of more than a thousand years it is a miracle in itself that the book exists. Shakespeare knew his bible, and his work often incorporated and examined biblical themes. Shakespeares last completed work was The Tempest, and it is as complex and deeply moving as any of his works. Readers

Change Management in Dynamic Health Care System Free Solution

Question: Discuss about the Change Management in Dynamic Health Care System. Answer: Introduction The health care management is concerned with the necessary changes in the internal settings. It is noted that the changes in the health care centre often include several complex situations. It is not easy to facilitate any changes without managing the internal associates. Hence, while undertaking any change management, it is required to pay the attention towards proper planning, evaluating, and implementation of the operations (Grol et al. 2013). The study will be discussing the change management process undertaken by the authority of Canberra hospital in Australia. The change management theory will be applied to the discussion in order to understand the requirement of changes. Accordingly, the study will be focusing on the major concerns associated with the change management process. Background of the Health Care Centre Canberra Hospital in Australia is renowned for an acute care teaching hospital that includes almost 600 beds and a referral centre for specialist services. This community-based hospital is considered as the largest public care hospital in the region. Canberra Hospital is registered under World Health Organisation and accredited by the Australian Council in Healthcare Standards (Health.act.gov.au, 2016). In this current scenario, it has been seen that the hospital has been facing the trouble with their poor data management system. It has been noticed that the records of thousands of patients have been compromised due to such poor data management process (Canberratimes.com.au, 2016). Hence, the authority needs to pay attention in fixing up such issues by undertaking the proper change management procedures. Dr. Cooper has provided the evidence to the Assemblys Public Accounts committee regarding the recognisable record manipulation in the hospital. Therefore, the changes in the organisa tional management have become essential to secure the reputation of Canberra Hospital. The study will be concentrating on such issues associated with the internal management of Canberra Hospital and will be recognising the proper changes that are needed to be undertaken accordingly. Key factors for change The organisational changes are needed to be undertaken in order to manage the situational incidents. In case of Canberra hospital the change management process is undertaken to improve the data management system that records the entire information of the organisation. However, there are two major factors responsible for driving the changes within the internal organisation scenario. These are as follows: The first and foremost factor for ensuring changes is the improvisation of the patients record management system. The hospital authority needs to keep the entire records of the patients that are necessary for the emergency purposes (Haas et al. 2013). Another factor for undertaking the change in such regards is to secure the hospital management from privacy breaching allegations. The lack of proper controls on the data management system in the Emergency Department is hampering the privacy of the information. In fact, the executive even admitted their inability to manage the records of the patients. In order to free the hospital from privacy breaching allegations, the change in the data management procedure is necessary (Richards, 2014). Affected Privacy Policy The privacy law in the health care centre is associated with the regulation that determines the protection of the private information of an individual (Herring, 2014). Such information is needed to be stored in the private data management system of a health care centre. During some of the emergency scenario, the information can be extracted accordingly. However, Canberra Hospital is firmly alleged due to the poor data management system. The hospital executive even admitted the mess occurred due to the mismanagement of the private data. Hence, this declaration has created the significant impact on the privacy law in a health care setting. The policy and regulations associated with the privacy concerns are thus hampered accordingly. Theory applied for implementing the changes The change management process is linked with the theoretical perspectives, which considers the sequential process of implementing the changes. In such regards, the management of Canberra Hospital has applied Lewins Change Management Model. The founder, Kurt Lewin has described the three sequential steps to implement the changes. These steps are as follows. Unfreeze Stage: This particular stage is considered as the most important stage of change management model. The stage recognises the reason behind the changes that is needed to be undertaken (Hayes, 2014). For example, it has been seen that the management of Canberra Hospital is firmly alleged against the breaching of privacy laws. The poor data management system is the major reason behind such allegations. The authority has discovered such requirements and implemented the process of improvising the data management system. Such recognition falls under the unfreeze stage of the change management model. Figure 1: Kurt Lewins Change Management Model (Source: Shaw, 2015, p.5) Change: Kurt Lewin has pointed out that ensuring change is not any event; rather it determines the sequential process. However, the second stage of change management model ensures the transition period. The management will be undertaking the changes by identifying the requirements. It is important to note that during such period, it becomes difficult to the authority to manage the people associated with such change (Shaw, 2015). For instance, the management needs to improvise the data storage for keeping the records safe. The use of the highly advanced technologies is required. It is not an easy process to manage the associated employees who are not aware of the process of using such technologies. In such cases, the good leadership is necessary. The proper training and development session provided to the associates will be helpful enough to facilitate such changes. Freezing Stage: The freezing stage is concerning the maintenance of the stability after the change is implemented. When the management of Canberra Hospital is improvising the data management system, it is required to pay the attentions on the consistency. It will be helpful enough in preventing the situation from occurring in the future. Concentrating on such theoretical perspectives, the sequential change can be implemented. Conclusion The study is recognising the reasons for implementing the changes in a health care management scenario. Canberra Hospital is alleged due to the poor data management system, which drives against the privacy breaching laws. Kurt Lewins Change Management Model has been applied to facilitate such changes in the internal organisational scenario. Following such sequential stages, the management of Canberra Hospital will be able to secure the organisational reputation in a significant manner. References Canberratimes.com.au, (2016). Data doctoring sparks hospital records privacy concerns. [online] Canberra Times. Available at: https://www.canberratimes.com.au/act-news/data-doctoring-sparks-hospital-records-privacy-concerns-20120719-22bst.html#ixzz217HtWRP4 [Accessed 26 Aug. 2016]. Grol, R., Wensing, M., Eccles, M., Davis, D. (2013).Improving patient care: the implementation of change in health care. John Wiley Sons. Haas, L., Maryniuk, M., Beck, J., Cox, C. E., Duker, P., Edwards, L., ... McLaughlin, S. (2013). National standards for diabetes self-management education and support.Diabetes care,36(Supplement 1), S100-S108. Hayes, J. (2014).The theory and practice of change management. Palgrave Macmillan. Health.act.gov.au, (2016). About Canberra Hospital | ACT Health. [online] Health.act.gov.au. Available at: https://www.health.act.gov.au/our-services/canberra-hospital-campus/about-canberra-hospital [Accessed 27 Aug. 2016]. Herring, J. (2014).Medical law and ethics. Oxford University Press, USA. Richards, N. M. (2014). Why data privacy law is (mostly) constitutional.Wm. Mary L. Rev.,56, 1501. Shaw, G., (2015). 4 change management models for your small business. National Leasing, pp.3-8.

Usability Electronic Health Record Systems -Myassignmenthelp.Com

Question: Discuss About The Usability Electronic Health Record Systems? Answer: Introduction The organization ABC utilizes manual system in order to store data as well as information of the patients. However, it is identified that the utilization of manual system within the organization creates number of issues as well as challenges, which are mainly associated with accessibility, productivity as well as security. In order to resolve the issues, the higher authority of the organization wants to utilize electronic healthcare record system. Objectives The main objective of the project are as follows: To resolve the issues that are mainly associated with the manual record system To implement digital health record system To increase the accessibility as well as security of the data and information that will be stored in the record system of the organization Problem that is solved It is identified that the use of electronic health record system helps in resolving the issues that are mainly associated with the manual record system of the organization. In addition to this, the electronic health record system helps in making the access easier, proper workflow, improving decision support system and more. Alignment of the project with organizational goals The project is mainly aligned with the goals of the organization with the help of steps which are as follows: Consulting key stakeholders Building decision making framework setting priorities Benefits for the user The benefits of the users includes: Easier access to data Easily get accurate data as well as information Improved interaction and communication Improves efficiency Metrics for measuring success The metrics for measuring success include: Successful completion of project on time Completing entire project within the estimated budget Achieving the objectives of the project Satisfaction of the customers Deliverables The deliverables of the project include: Implementation of electronic health record system Design documents Software tools and software Progress report Usability report Timeframe and how it will be met The entire project will be completed within 4 months and the timeframe of the project will be maintained by utilizing following methods that are as follows: Bridging gap between execution and strategy formulation Maintaining executive sponsorship Adopting agile methodology Weekly meeting Analyzing progress Resources required The resources that are required include: Human resources: The human resources who are involved in the project are: Project manager Project planner Supervisor Technical engineer IT analyst Risk analyst Financial manager Financial resources: It is identified that budget of around $40,000 is required for completing the project. Technical resources: The technical resources include various types of hardware as well as software that are needed. Risks and issues The risks and issues which are associated with project include: Improper budget estimation Inexperienced project managers Improper management People responsible for the project The people who are responsible for the project include: Project planner Supervisor IT analyst Risk analyst Financial manager Process of reporting the project The process of reporting within the project includes: Documentation Meetings Seminars and more References Fleming, Q.W. and Koppelman, J.M., 2016, December. Earned value project management. Project Management Institute. Kerzner, H. and Kerzner, H.R., 2017. Project management: a systems approach to planning, scheduling, and controlling. John Wiley Sons. Mir, F.A. and Pinnington, A.H., 2014. Exploring the value of project management: linking project management performance and project success. International journal of project management, 32(2), pp.202-217. Snyder, C.S., 2014. A guide to the project management body of knowledge: PMBOK () guide. Project Management Institute: Newtown Square, PA, USA.

Women in Prison Issues and Challenges Faced by Female Inmates

Introduction The correctional facilities offered by the Criminal Justice System are of immense importance for the effective running of the society. This is because it is through these avenues that those members or the society who do not abide by the laws and codes of conduct established can be punished and effectively rehabilitated.Advertising We will write a custom research paper sample on Women in Prison: Issues and Challenges Faced by Female Inmates specifically for you for only $16.05 $11/page Learn More Even so, the United States has a phenomenal number of inmates serving in her state correctional facilities. While men traditionally make up the bulk of the inmates in US correctional facilities, women are the fastest growing group of incarcerated persons in US (Hutchinson 440). Women therefore make up a significant percentage of incarcerated persons and their unique needs and realities are they serve their terms has gained more prominence. This paper shall set out to give an informative analysis on the issue of women in prison. The paper shall especially concentrate on the issues that are peculiar to women; abortion, Psychological functioning during Pregnancy and child birth. The paper shall also look at the alarming of rates of suicides of women in prison and how women can best be reintegrated back to society after serving their sentences. Issues Affecting Women in Prison Incarcerated Women and Abortion One of the rights that women have championed and gained in the 21st century is the right to access abortion services. While this are services that free women have access to fairly easily, the same cannot be said for women prisoners. This is a big issue considering the fact that 6-10% of women in custody at any particular time are pregnant (Sufrin, Creinin and Chang 6). While abortion is deemed a â€Å"reasonable, appropriate and constitutional measure† and it is the right of a woman to request for one regardless of her b eing incarcerated, research by the renowned political scientist Rachel Roth indicated that correctional facilities’ abortion policies are inconsistent and lack any form of standardization (Sufrin, Creinin and Chang 7). As a result of this, incarcerated women are faced with various barriers in their quest to obtain pregnancy termination. Research conducted by Sufrin, Creinin and Chang on the provision of abortion services for incarcerated women revealed that while majority of health care providers for incarcerated women asserted that abortion services were provided for prisoners, there was lack of well established procedures for arranging for such procedures (9). The lack of a written policy on prisoners who request abortion means that prisoners are at the mercy of prison officers who may deny their abortion requests at will. Women who request for elective abortions can therefore be denied by facilities which make distinctions between â€Å"medically necessary† and â₠¬Å"elective abortions†.Advertising Looking for research paper on criminal law? Let's see if we can help you! Get your first paper with 15% OFF Learn More Abortion services for incarcerated women are also greatly dependent on the political trends of the particular state. Research indicated that states dominated by Republican legislatures were less likely to help imprisoned women obtain abortion as compared to states dominated by Democratic legislatures (Sufrin, Creinin and Chang 10). This political influence on correctional health system is detrimental to prisoner’s who seek elective abortions. Denying women the right to an abortion is tantamount to violating the Eight Amendment which guarantees all prisoners the right to health care. Women’s right to choose for an abortion is guaranteed by the law regardless of incarceration. Even so, the Abortion policies employed by some prisons greatly limit the prisoners’ access to health care. Sufrin, Cr einin and Chang propose that correctional health system should strive to come up with written policies on abortion that clearly articulate the pregnancy termination provisions available to the prisoners (10). This can help achieve quality service for the incarcerated women with positive outcomes. Psychological functioning during Pregnancy As a matter of fact, the pregnancy phase is an especially challenging period in a woman’s life as she undergoes various physical and psychological changes. Considering the fact that an estimated 6-10% of women are pregnant as of the time when they are getting into prison, a significant number of women prisoners experience the various challenges that are inherent in pregnancy. A common condition experienced by the pregnant women is depression and anxiety. Research indicates that incarcerated mothers face more stressors than other inmates as a result of visitation concerns and separation from their families. Pregnant inmates in particular stan d the risk of elevated levels of anxiety and depression. This anxiety and depression experienced by the mother can have negative effects for infant development by increasing the infant’s susceptibility to psychopathology. A reality that pregnant women in prison face is the impeding separation from their newborns. Women who deliver while in prison spend about 1 or 2 days with their newborns after which the babies are taken away from them (Hutchinson et al. 441). Hutchinson et al. reveal that this separation and loss is â€Å"likely to be emotionally demanding and may even be a traumatic experience for many women† (441). This initial trauma may make it impossible for the mother to reconnect with their baby when they are reunited. This assertion is corroborated by a study by Sajaniemi et al. which revealed that the disruption in the initial bonding process of child and mother as a result of separation significantly affects the development of secure attachments. In additio n to this, the stress that comes from this separation may result in violent outbursts that result in the disciplinary action being taken against the incarcerated new mother.Advertising We will write a custom research paper sample on Women in Prison: Issues and Challenges Faced by Female Inmates specifically for you for only $16.05 $11/page Learn More Pregnant incarcerated women are more predisposed to hostilities and angry outbursts as a result of their condition. While studies reveal that all pregnant women are likely to exhibit anger and hostility as a result of the hormonal changes they are undergoing, the hostile and angry reactions are higher in pregnant incarcerate women(Hutchinson et al. 441). This combined with situations such as lack of enough food for the mother and baby only serve to escalate tempers. This condition places the incarcerated women at great risk of interpersonal violence and infractions in prison. Such behaviors not only endange r the unborn child but they lead in disciplinary action being taken against the pregnant prisoner. In times of pregnancy and childbirth, social support is highlighted as one of the most important care practices. While incarcerated pregnant women are surrounded by their peers in prison, research indicates that majority of them do not use their prison peers as a source of social support (Hutchinson et al. 447). Instead, the women mostly rely on their own mothers and/or the baby’s fathers. However, incarcerated women encounter significant barriers in their attempt to receive the much needed support. Incarceration results in limited visitation and access to telephones. Considering the fact that regular visits with children and maintenance of regular family relationships during incarceration significantly reduces the likelihood of the inmate reverting to crime after release, Hutchinson et al propose that correctional facilities should promote visitations (450). The women may also be imprisoned at facilities that are considerable distances from their homes therefore limiting the number of visits that their families’ can afford. In addition, many prisons do not allow family and friends during labor and delivery. This causes significant psychological distress to the pregnant women. After having their babies’, women are required to make plans for placement of the infant’s for the interim period between birth and the mother’s release from the correctional facility.Advertising Looking for research paper on criminal law? Let's see if we can help you! Get your first paper with 15% OFF Learn More Hutchinson et al revealed that women who could not find a good potential caregiver expressed significant distress since the infant would have to be taken into the custody of the Department of Social Services and likely placed into foster care (447). Even the women who find potential caregivers problems related to the interim caregiver to whom they relinquish the care of their infants. The women experience a wide range of emotions ranging from jealousy, concern for child’s well being to appreciation for the care provided to the child on their behalf. Hutchinson et al reveals that most of the interim caregivers are the inmates own mother and these results to concern if the mother has a history of neglectful or abusive parenting (442). This results in the incarcerated mother having high levels of stress due to concern for their children. Prisoners giving Birth Approximately 1400 women give birth while under incarceration every year. This places them in a precarious position sinc e giving birth even in the best of circumstances is an involving process. Incarcerated pregnant women face unique issues in addition to the issues that are common to mothers in general. The unique issues mostly revolve around discomforts exacerbated by pregnancies and the stress brought about by the impending birth. Hutchinson proposes that correctional institutes establish specific interventions geared towards addressing the unique needs of pregnant inmates (450). A particularly novel support tool for women giving birth is the Birth Companions which was formed in 1996 with the primary aim of offering support for prisoners giving birth (Marshall 225). Birth Companions in essence provides experienced birth partners who offer support to women who are about to give birth. The Birth Companions visit the prison and offer birth plans for pregnant women as well as provide the much needed support during labor. This assists reduce the anxiety that women in prison are predisposed to and assis ts the women focus on their babies’. Support during pregnancy results in positive experience by the pregnant inmates and research indicates that the support of an experienced birth companion significantly improves the outcomes for mother and baby. Marshall documents that in a study involving over 1300 pregnant women, it was fount that â€Å"women who received continuous labor support were more likely to give birth virginally, needed less interventions, and had higher satisfaction rates and slightly shorter labors (225). Bearing in mind these positive results, it would be beneficial to have birth support services provided for every pregnant woman, incarcerated or not. Suicides of women in Prison Recent reports have called to attention the escalating rates of suicide among incarcerated women. Thomas documents that the suicide rate among female prisoners is a phenomenal 20times more common than among females in the general population. In any context, these are very troubling re velations and they point to a profound problems experienced by women in the correctional system. The first major problem that females encounter is despair. While many female prisoners experience despair as a result of their incarceration, the prison environment is not conducive to an open express of this despair (Liebling 384). This is because of over-medicalization of the problem of suicide which results in hospitalization in cases of suspected suicide risk. Hospitalization results in segregation of the prisoner therefore leading to an escalation of the situation as a result of loneliness. As such, women who are at risk of suicide opt to keep their despair hidden instead of seeking help. Research indicates that younger women are especially at risk of attempting suicide than any other group due. The reasons for this include the fact that young inmates are susceptible to threats and attacks from others and generally have less resources and skills to avert such behaviors. This bullyin g and victimization in young offenders results in higher likelihood of committing situation specific suicides by the young female prisoners. Research by Liebling noted that prisoners who had committed suicide were more likely to have spent sometime in seclusion or protective custody while in the correctional facility (392). As such, being bullied and victimized by the other inmates is a common precursor to the prisoner attempting suicide. Most of the women who commit in suicide have pre-existing issues with depression and these conditions are escalated as a result of the prison conditions. One study revealed that those who committed or attempted suicide were currently seeing the visiting psychiatrist or had a history of mental health issues before incarceration (Liebling 393). From these findings, it is clear that there is a link between the mental health of the prisoner and suicide rates. Liebling asserts that the significance of drug abuse in suicide prison remains as potent as ev ery and particularly among the suicides that occur during the early periods of custody (384). Research indicates that a significant number of female prisoners are incarcerated as a result of drug related offenses. Thomas articulates that more women are entering prison because of drug-related crimes and many of them are addict (353). While in prison, they lack access to their drugs of choice and hence experience withdrawals without the support facilities that they would have on the outside. Social justice and women leaving prison One of the core goals of correctional facilities is to rehabilitate people for successful reintegration into the society. Fortune et al. state that while the goal of women’s correction is for women to leave correctional institutes stronger than when they went in, the stigma associated with incarceration results in women returning to the communities feeling even more powerless (19). Being accepted back into the community or being rejected from it after release from prison has a major implication on a woman’s ability to reintegrate. Re-entry into community is mostly hampered by the stigma which results in offenders being perceived as bad. Stigma may result in the ex-convict isolating themselves from the community. This social isolation greatly reduces the opportunities for women to establish supportive relationships that are a prerequisite to post-prison empowerment. Social justice and shared responsibility are two of the principles which if effectively employed can assist in the effective reintegration of ex-convicted women into the society. The principle of shared responsibility sees the entire society as being responsible for the creation and implementation of services for the incarcerated women (Fortune et al. 24). Dispelling the myths and negative perceptions about which are propagated by the media about incarcerated women, the negative connotation associated with ex-convicted women can be dispelled. By use of programs such as â€Å"Stride Night† which provide a platform for interaction between incarcerated women and community volunteers, a better understanding is borne and the volunteers can help dispel the stigma associated with incarcerated women (Fortune et al. 25). Brown and Stuart confirm that mentoring has become a popular and effective tool for reintegrating and resettling ex-prisoners. Mentoring offers the woman prisoner a nonjudgmental ear and a person who is not connected with the former criminal world that the ex-prisoner may have been involved in. The first days following release, women are especially prone to falling back to old detrimental habits such as substance abuse, criminal activities and abusive relationships (Fortune et al. 23). By having a mentor, the former prisoner stands a better chance of leading a changed life. Brown and Stuart reveal that the value of mentors to the ex-convict mentee is greet since mentors could act as character references for employment and h ousing for the ex-prisoners and even attend court for child custody hearings (42). This social capital that the mentors can provide to the female ex-convict is of great importance since most women live in isolation after being released from prison either in an attempt to make a clean start from their turbulent past or due to issues of personal safety. Discussion and Conclusion Correctional facilities are a necessary aspect for the administrative component of a country to function efficiently. From this paper, it is clear that there are a number of major issues that women prisoners face during incarceration. These issues have a negative impact on the women and decrease the likelihood of them. Marshall reports that the health issues of women have been overlooked by the correctional system which was designed primarily for men (227). This is especially true when dealing with pregnancy of inmates. As it currently stands, handling of pregnant women in prison varies from prison to prison. For example, while shackling of pregnant incarcerated women is generally condemned, only six states have laws expressly condemning the practice (National NOW Times). As such, prisons in the states which do not have explicit laws against this practice can engage in this practice without fear of legal redress. There have been calls for the establishment of a set standard for how pregnant women should be treated during pregnancy and birth in all prisons. As has been noted, conditions such as overcrowding, a lack of access to medical care and increased assault against the prisoner exacerbate problems that result in suicide risks among the inmates. The prison administration can therefore alleviate suicide rates by improving the living conditions of the inmates. In addition to this, protection of younger prisoners from victimization and bullying can reduce the amount of distress they experience therefore reducing their risk of committing suicide. The ultimate goal of correctional faciliti es is to mold convicts for future reintegration into the society. Through social justice and mentoring programs, ex-convicts can be successful reintegrated into society and allowed to make a meaningful living and consequently play a part in the noble task of building the nation. By accepting the ex-prisoner women into the community, the society will demonstrate its faith in the rehabilitative property of the prison systems and absolve the ex-felon since they have already repaid their debt to society by serving time. While the role played by the criminal justice system is imperative for the well being of the society, the human rights of the prisoner must be respected and conditions made as humane as possible. As it currently stands, incarcerated women’s access to abortion services is not guaranteed and support during pregnancy is inadequate. Women are also susceptible to suicide and psychological trauma in pregnancy. Correctional service institutes must strive to address these problems so as to make women’s stay at prisons less traumatic. Works Cited Brown, Mark, and Stuart Ross. â€Å"Mentoring, Social Capital and Desistance: A Study of Women Released from Prison.† Australian New Zealand Journal of Criminology 43.1 (2010): 31-50. Felice Yuen, et al. â€Å"Social justice and women leaving prison: beyond punishment and exclusion.† Contemporary Justice Review 13.1 (2010): 19-33. Liebling, ALison. â€Å"Suicides in young prisoners†. Death Studies, Sep/Oct93, Vol. 17 Issue 5, p381, 29p Mariaskin, Amy et al. â€Å"incarcerated women’s psychological functioning during pregnancy.† Psychology of Women Quarterly 32.4 (2008): 440-453. Marshall, Denise. â€Å"Birth Companions: working with women in prison giving birth.† British Journal of Midwifery 18.4 (2010): 225-228. National NOW Times. â€Å"Anti-Abortion Terrorism Threatens Lives, Women’s Rights.† National NOW Times 42.1 (2010): 2. Sufrin, Carolyn , B., Mitchell D. Creinin, and Judy C. Chang. â€Å"Incarcerated Women and Abortion Provision: A Survey of Correctional Health Providers.† Perspectives on Sexual Reproductive Health 41.1 (2009): 6-11. Thomas, Sandra P. â€Å"Suicides of Women in Prison.† Issues in Mental Health Nursing June 2009: 353. This research paper on Women in Prison: Issues and Challenges Faced by Female Inmates was written and submitted by user Mackenzie Bush to help you with your own studies. You are free to use it for research and reference purposes in order to write your own paper; however, you must cite it accordingly. You can donate your paper here.

How to Write an Essay in the Context of a GRE Essay Sample SOP

How to Write an Essay in the Context of a GRE Essay Sample SOPIf you are wondering how to write an essay in the context of a GRE Essay Sample SOP, then this short article will explain that in layman's terms. An essay can be a tough subject to tackle for students from a variety of disciplines. Since an essay is usually the first time an average student will be faced with a problem solving situation, it is imperative that the essay remains coherent and consistent throughout the piece. An essay should cover various topics.It is not always easy to know what subjects should be tackled in a question and answer session, but there are some general guidelines that you should follow when writing an essay. When following these guidelines, a question is usually asked about the primary topics, and the essay is essentially a synthesis of the responses provided. This article will highlight some of the areas where an essay can address.The focus of a GRE Essay Sample SOP should be the content of the essay. You should focus on presenting the major issues of the essay in a concise and cohesive manner. Here are a few common topics that may be included in an essay: Arguments, Logic, Ideas, Argumentation, Solutions, and Proof. This is just a quick overview of the areas where an essay can cover. There are other topics as well that will be addressed in an essay.Another area where an essay can be written is in regards to grammar. In general, you will need to ensure that your essay is grammatically correct. Students often complain about essays that are difficult to decipher and complete. To help reduce the frustration experienced by students who are attempting to read and understand essays, make sure your essay is free of grammatical errors.One thing that you should also keep in mind is that you are allowed only two minutes per paragraph in your essay. Any additional information should be provided in a paragraph that follows the two-minute rule. As such, you should try to introduce your material in a brief way.Speaking of language, another thing to keep in mind is that you should know some basic rules in English grammar. The American College of Pedagogy recommends the use of three rules in writing an essay. These are in-paragraph -emphasis, meaning, and grammar. Your three rules should be followed to the letter.Finally, in writing an essay, GRE subject matter is a topic that should be addressed as well. For example, if the topic is ethics, you should attempt to address it in some way in the essay. You should consider the topic from a professional point of view, even if your topic is more personal.There are many more topics that can be covered in an essay. The biggest idea to remember is that if you want to write an essay that will be accepted by your school, you should take into account the various aspects of the essay before you begin. This will ensure that your essay is unique and stands out from the rest.

Personality profiling in sport Essays

Personality profiling in sport Essays Personality profiling in sport Essay Personality profiling in sport Essay Describe theories related to personality and how they affect sports performance. Evaluate critically personality profiling in sport. What is a personality? Hollander tells us that a personality Is the sum of an individuals characteristics which make a human unique. But it is not known for sure what a personality actually is or how we actually begin to form them. There exist three main personality theories and each of them relate to sports performance in their own way. The first theory is called the trait perspective theory. Trait theory states that we are born with personality characteristics that influence the way in which we behave in sport and in everyday life. Personality traits are stable and therefore vary little over time. Some sports performers may have an aggressive trait and this may surface in a variety of different situations. The key people behind this theory are Eysenck, Cattell and Girdano. Eysenck identified four primary personality traits and arranged them in a 2 dimensional diagram. The model was laid out in a cross, and at one end you have introversion and extroversion, and the other stable and neurosis. According to Eysenck you could either be stable or neurotic, but not both for example. It is said that extroverts, with their outgoing and sociable nature, would be more suited for team games such as football. Where as a quiet, reserved Introvert would be mores suited for individual sports such as archery. This data was collected by POMS, or profile of mood states a type of personality profiling. Cattell argued that more than just two or three dimensions were needed in order to create a full picture of a persons personality. He proposed that personality could be reduced to and measured in terms of 16 personality factors. He argued that measuring these factors via his test would give an appropriate personality profile. He recognised that personality was more dynamic than Eysenck suggested and could fluctuate according to the situation. So according to Cattell, a football player who never normally shows signs of aggression, may show signs when involved in a certain situation. Girdano was also a trait theorist and he suggested there are two distinct personality types, Type A and Type B. Type A according to Girano would be; highly competitive, have a strong desire to win, fast working, controlling and prone to stress. Type B would be the polar opposite of this, and would be; non-competitive, unambitious, slow working, no urge to control and less prone to stress. From this we see that the first distinct personality type would be more suited and more successful for a team game, and Type B would be more suitable for an individual game. We also see that Type A would be likely to get stressed in high pressure situations where as Type B would keep calm, however it would be likely for Type B to be unable to trigger any sort of aggressive or competitive characteristic when it mattered. The second theory is called the social learning perspective theory. The social learning theory, developed by Bandura, differs from trait and interactional approaches in that it sees individual differences in behaviour as resulting from different learning experiences. This means that what determines an individual’s response to a situation is not so much their genetic make-up or the constraints of the particular situation, but instead how past experience has taught that person to act. Behaviour therefore changes depending on the situation and is therefore a product of our interaction with the environment. Banduras model shows us how this personality theory affects sports performance. An inexperienced performer may be inspired by the positive attitude and commitment of an experienced player, and then chooses to copy desirable approach, receiving positive reinforcement in doing so. The third and final personality theory is the interactionist approach, which was based on the work done by Hollander. It is a combination of the trait and social learning perspectives. It suggests to us that personality is modified and behaviour is formed when genetically inherited traits are triggered by an environmental circumstance, thus meaning that behaviour is unpredictable. It also explains to us why behaviour can change in different situations, so for example a competitive rugby player may not be so competitive when off the field of play. Personality profiling is done to see which personalities are fit for what sport, and if a certain individual personality is one that all athletes may share. This is difficult due to the fact there is no clear, universal definition of a personality. Personality profiling involves measuring an athlete on a number of personality scales and building up a picture of their strengths and weaknesses. Tests can be measured in a various number of ways, through; questionnaires, interviews, observations or profile of mood states. There are a number of problems with personal profiling though. There is no conclusive evidence that a sports personality actually exists, so far there only exists theories surrounding the matter and no hard evidence. Profiling results are usually subjective, and conclusions may be influenced by personal opinions with no support of scientific evidence. Profiling results are invalid more often than not. It is feared that an athlete may unconsciously modify their own behaviour to match up to the profile ascribed to them. There also exists a reliability issue, due to the fact questionnaires are often carried out using self report, so therefore not always answered correctly or honestly.

Case study Essay Example | Topics and Well Written Essays - 250 words - 32

Case study - Essay Example Per se, the products are mainly associated with fun placing them in the category of luxurious products (Naggar 159). An effective problem to this problem is developing strategies for marketing the cereals. One of the best marketing strategies will be effective campaign (Naggar 169). Effective campaign will incorporate some of the traditional Arabic food into the breakfast basket for the whole family. The campaign should target mothers and house helps as they form the chief consumers/buyers of food stuff (Naggar 180). The second solution will be is merging with local companies to increase credibility to the consumer. Arabian countries have strict rules when it comes to many things and among them is food. A merger with a local company will effectively dilute the mistrust of the products being offered by Kellogg Company (Naggar 191). These mergers apart from increasing acceptability in the new markets, they also reduce competition of the market share. Kellogg Company management should encourage take- over and mergers with local companies (Naggar 200). Kellogg Company should understand the consumers and consumer behaviors of the people in the gulf countries in order to effectively penetrate these markets (Naggar 220). The above two solutions form core bases for the impending problem of the

Creative imagination Essay Example | Topics and Well Written Essays - 1250 words

Creative imagination - Essay Example However, the two philosophers’ approaches to Kant differ in several fundamentally different ways: while Singer presents Kantian ideas in fluid form, embedded in the context of a linear history developing the concept of the â€Å"aesthetic†, Warnock presents Kant analytically: developing Kantian ideas in a systematic, step-by-step fashion. In fact, these two approaches may be applied to the entireties of the two works. While Singer tries to build a narrative history for the reader, Warnock’s piece is much less designed for the non-philosopher. She presents difficult concepts in a linear fashion, and builds on them progressively to reach conclusions, whereas Singer embeds philosophical ideas into his logical edifice. Paying close attention to the way in which both accounts present Kant’s relation of imagination to the human production of art, we can see how well both approaches work in achieving the same end: understanding of what the aesthetic really is and how imagination is related to it. Mary Warnock begins her chapter on imagination’s relation to the aesthetic with a discussion of what David Hume had to say on the matter. She moves on to Kant’s Critique of Judgment, which is his seminal work in aesthetic philosophy. Warnock notes immediately the difficulty of assessing Kant’s message in the third Critique, which is ambivalent towards its overarching purpose, and she makes a sharp contrast between Hume and Kant, the latter having placed a much greater emphasis upon the world of reason and understanding. So, whereas Hume thought of an idea as a sensation, or a shallow impression, Kant saw it as a magnificent entity produced in the highest of faculties. Between reason and understanding lies judgment for Kant; the reflective judgment, Kant says, can be illustrated by both natural science and the aesthetic. In natural science, this judgment is only available when the scientist assumes finality in nature—that

The Key to Patience Essay Example for Free

The Key to Patience Essay Patience is a word that I constantly hear from my mother. My mother’s days as a young child were rough and not as convenient as things are now. Back in the 1970’s, in Dominican Republic there wasn’t such things as iPad’s, iPod’s and Iphone’s. Although it wasn’t the best life, she always had patience with everything she did and it truly brought her a long way. In the book â€Å"Life Lessons†, patience is one of the topics that the author Elizabeth Kubler ‘Ross and David Kessler mentions. It discusses on how patience affects our lives and the consequences in not having patience. I myself know I don’t have all the patience in the world however, by reading this book I actually think I’m not so bad. Elizabeth mentions how one of the hardest and frustrating lessons in life is realizing that we don’t always get what we want. You may want something now but you may not get it for a while. One of my favorite lines in this chapter is â€Å"In this modern world, people are not used to living in discomfort.† I adore that line because it is absolutely true! We all expect our results quickly and were all used to having things done immediately. For instance, if were hungry there’s always food available, from microwave dinners to all night grocery stores and restaurants. I’ve learned that according to the book, we need to develop faith and believe that everything will be okay. Trying not to always be in control of the situation and just letting things happen when there supposed to happen is what we need to do. In this world patience is crucial. For example, waiting in line to purchase items, our job, cooking, and people! Increasing the input of patience in everyone will bring out a better atmosphere and create a healthier way to work things out.

My Good and Bad Habits :: Personal Narrative Essays

My Good and Bad Habits A habit can be many things, some good, some not so good. Everyone has habits that they would like to change and maybe improve upon. I believe the majority of habits I have are good ones but some are not. These bad habits are the ones I will talk about. Smoking is a bad habit that is not only harmful to myself, but also to the people around me, namely my wife and children. They are the ones that receive the most harmful and the most concentrated amounts of smoke. I inhale through a filter, my wife and children do not. Another of my irritating and potentially harmful habits is my ability to let anger build up inside and redirect it to another source. The main reason that I say that this is potentially harmful is that when a man lets his anger build up over an extended length of time he eventually becomes a bomb, ready to explode at any time. This anger could show up at any time and be redirected toward anything, such as cars, other people, or things in the home. After the birth of my first child, I had to learn to develop constructive ways to vent anger. One of those ways was to go off alone, count to ten, and think about what it was that made me angry. After I discovered the root of my anger, I often asked myself, "Will it do me or anyone else any good to be angry?", and, "Will being angry do anything to solve the problem", and the answer to both questions was usually no. By the time I had done the walking and thinking, I was usually not angry anymore. Even in light of these habits I believe the worst habit is my use of foul language. I know that "four letter words" are only a sign of a limited vocabulary but old habits die hard. I believe I have gotten better after my son was born, due to the fact that it seemed he could repeat the "s" word more plainly than he could say "ball" and usually at the most inopportune times.

Contract Law

Introduction In today’s economic climate businesses often exert commercial pressure during contract negotiation stages. This is a normal part of the process and parties to a contract generally know when pressure being exerted is lawful. Although there is a difference between commercial negotiation and illegitimate pressure, it is often difficult to distinguish between the two. Furthermore, because economic duress can arise from pressure that is not in itself unlawful, parties may be unaware that the pressure they are subjecting a party to a contract is actually economic duress. Despite this, if a court finds that one party to a contract has exerted illegitimate pressure on another party, the innocent party may be able to establish a claim of economic duress. Given how uncertain the economy is at present, hard bargaining is a common form of negotiation, though it is vital that businesses are aware of the risks when exerting pressure that is likely to be deemed illegitimate. It is unclear ho w this distinction can be made, nonetheless, which suggests that further clarity is needed within this area. This study intends to explain the developments that have taken place in the doctrine of economic duress and why the courts perceived a need for a more robust approach in light of the Williams v Roffey Brothers and Nicholls (Contractors) Ltd [1991] 1 QB 1 case. Duress Duress is a common law defence that allows a contract to be set aside in instances where one party has been subjected to force or pressure from the other party to enter into the contract. Duress has been defined as â€Å"making someone do something against his will, or making someone perform an illegal act, by using threats, coercion or other illicit means† (Dictionary, 2014: 1). Duress is basically the use of unlawful means to force another to perform an act by either threatening them or performing an act of violence. The party claiming duress will be required to show that they did not have a choice but to enter into the contract (Cserne, 2009: 57). Economic duress, on the other hand, is a fairly new phenomenon that is becoming an important tool for determining whether a contract that has been entered into is enforceable or not. Economic duress happens when a person’s economic interests are damaged from being forced or coerced into entering into a contract. This type o f duress has been defined as the â€Å"unlawful use of economic pressure and/or threats intended to overcome the free will of a person, in order to force him or her to an involuntary agreement or to do something that he or she would not otherwise do† (Business Dictionary, 2014, 1). Economic duress is essentially a contract law defence that allows a person to dispute the formation of a binding contract by arguing that that they were forced to enter into the contract. Previously, parties to a contract could only rely on the doctrine of consideration for protection when they were being subjected to economic duress. Consideration is the price that one party will pay for another party’s promise (Card et al; 2003: 63); Collins v Godefroy (1831) 1 B&Ad 950. The doctrine of consideration does not allow parties in a contract to insist on further payments to perform tasks they are already required to perform under the contract simply because they are in a stronger bargaining pos ition; Stilk v Myrick (1809) 2 Camp 317. Economic Duress and Commercial Pressure It is now widely accepted by the courts that undue commercial pressure can amount to duress. The doctrine of economic duress has evolved significantly from various trade union decisions including; Universe Tankships v International Workers Federation (â€Å"The Universe Sentinel†) [1983] 1 AC 366 and Dimskal Shipping v International Works Federation (â€Å"The Evia Luck†) [1992] 2 AC 152. In The Universe Sentinel, a trade union, which had blacklisted a ship, forced the owner to provide payment before they would remove the ship from the black list. As there would have been disastrous consequences if the ship could not sail, the owner made the payment. Because the ship owner had no other practical choice but to make the payment, he later brought a successful claim for the recovery of the money by establishing economic duress. Similarly, in The Evia Luck a trade union insisted that a ship owner signed various contractual documents so that his ship could sail, which was fou nd by the court to be a form of economic duress. In order to make an economic duress claim, there are a number of elements the claimant will need to be established. These are; a) that the pressure was illegitimate; b) that the pressure was a significant cause that induced the claimant to enter into the contract; and c) that the practical effect of the pressures means that the claimant has no other choice but to enter into the contract (Ohrenstein, 2013: 2). The claimant will be entitled to avoid the contract and claim restitution of any monies that have been paid under it if these elements can be established. In deciding what amount to illegitimate pressure, the court will take a range of factors into account. For example, in DSND Subsea Ltd v Petroleum Geo Services ASA [2000] EWHC 185 it was made clear that the court will be required to consider whether the breach of contract was an actual or threatened breach; whether the person whom exerts the pressure has acted in good or bad faith; whether the claimant had any real or practical alternative but to give in to the pressure; whether the claimant protested at the time; and whether the claimant sought to rely on the contract. One of the most successful forms of economic duress is a threat to breach a contract. In Siboen and The Sibotre [1976] 1 Lloyd’s Rep 293 charterers of two ships threatened to break their charterparties by refusing to pay the agreed charter rate if the rate was not lowered. The owners of the ships had been informed that the charterers had no substantial assets and that the charterers would otherwise go into liquidation if the charter rates were not lowered. This information was not actually true but it caused the owners to reduce the rates nevertheless. It was found that economic duress could apply to this situation as all of the relevant factors were present. Since this decision, the courts seem to have accepted that economic duress is coercive and therefore worthy of the same relief as duress to the person or property (Chen-Wishart, 2012: 316). In spite of this, the practical application of economic duress has been subject to much confusion and it has been questioned when, if ever, renegotiations should be enforced. It would seem, under the doctrine of consideration, that renegotiations can never be enforced on the basis that â€Å"no additional consideration supports the promise to pay more or accept less† (Chen-Wishart, 2012: 316). Under the promissory estoppel doctrine, the promise to pay the same for less can be enforced in limited circumstances, though this does not apply if illegitimate pressure has been exerted. Therefore, if it can be demonstrated that illegitimate pressure has been applied to the renegotiation of a contract, that contract will not be enforceable. Because commercial contracts are extremely competitive, it is likely to be the case that some form of pressure will always be applied. Though the question to be determined is whether the pressure that has been applied is legitimate or not. This is l ikely to be extremely problematic and thus cause a great deal of complexity for the courts. As exemplified in the cases above, threats to blacklist a ship and refuse its release may constitute duress. Further examples of where economic duress has occurred can be seen in the cases of North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd [1979] QB 705 and Pao On v Lau Yiu Long [1979] UKPC 17 where threats to terminate a contract in the absence of a renegotiation is also illegitimate unless it can be legally justified. What will be deemed â€Å"legally justified† is largely a matter to be determined based upon individual facts and circumstances, though there is likely to remain a lot of confliction in this area. In Williams v Roffey Brothers Ltd [1991] EWCA Civ 5 the Stilk case was severely limited by the courts. Here, the consideration requirement was extended to include â€Å"practical benefits† and thereby covered the promise to perform an existing contract. Here, a number of contractors promised to refurbish 27 flats with a sub-contractor performing the carpentry. Before the flats were finished, the sub-contractor realised that he had under-priced the contract and was resultantly facing financial difficulty. The main contractors offered the sub-contractor a financial inducement to finish the contract on time. It is trite law that consideration is needed for a party to that contract to be able to sue on it. Since the sub-contractor was doing no more than he was already bound to do under the contract, consideration was lacking. Surprisingly, it was held by the court that because the contractors had received a benefit from the sub-contractor, in that they avoided the penalty clause of the main contract, the sub-contractors claim was successful. This did not mean that consideration was present as the benefit did not move from the promisee, although there was a clear departure from the orthodox principle of consideration principle. The doctr ine of consideration maintains that a contract will not be supported by the performance of an existing duty unless that duty exists by virtue of a third party contract (Noble, 1991: 141). This decision conflicts with the decision in Stilk which demonstrated that consideration needs to be of economic value to be deemed good consideration and that it needs to move from the promise as also shown in; White v Bluett (1853) 23 LJ Ex 36; Thomas v Thomas (1842) 2 QB 851; Shadwell v Shadwell (1860) 9 CBNS 159; and Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295). It has also been argued by Cheshire et al; that; â€Å"the time has come to recognise formally the alternative definition of consideration and admit that the rationale behind the refusal to enforce some types of consideration is pure policy† (Cheshire et al; 2012; 77). Arguably, it appears that the consideration principle is rather outmoded and in need of reform so that a more robust approach to economic duress can be taken by the courts. At present, much confusion arises as to when economic duress can be used as a defence. Judges thus need to err on the side of caution to prevent commercial pressure being mistaken for economic duress and vice versa. Still, as stressed by the court in Adam v Opel Gmbh v Mitras Automotive [2007] EWHC 3481; â€Å"the list of matters to be considered in assessing legitimacy is not exhaustive, and the weight to be attached to each of them will depend on the facts of the individual case.† Furthermore, it was also stated in the case that the decision to be made will involve some element of value judgement when considering whether the pressure that was exerted on the claimant crossed the line from that which must be accepted in normal robust commercial bargaining. It is clear from the decision in this case that the courts have made some attempts to provide clarity in this area and that each case will be decided on its own facts. In the more recent case of Kolmar Group AG v Traxpo Enterprises Pyt Ltd [2010] EWHC 113 it was evidenced that a contract variation between a supplier and a customer will unlikely amount to duress if the supplier is unable to perform a contract as a result of financial difficulties that will cause the supplier to become insolvent. Another problem that arises when it comes to economic duress is whether lawful conduct can amount to illegitimate pressure. Whilst it is possible, it is also extremely rare as shown in CTN Cash and Carry Ltd v Gallaher Ltd [1993] EWCA Civ 19; GMAC Commercial Credit Ltd v Dearden [2002] All ER (D) 440 (May) and Wright v HSBC Bank plc [2006] EWHC 930 QB. Consequently, economic duress will continue to pose many problems as there will always be a debate as to whether particular circumstances may or may not give rise to a claim for economic duress. Because of the uncertainty within this area, it is evident that a more robust approach needs to be taken so that greater clarity and consistency can be provided. Economic duress has also been criticised for being causation-led, thereby meaning that a lack of causation will prevent a successful claim from being made. In Pao On v Lau Yiu Long [1979] UKPC 2 it was pointed out by Lord Scarman that in deciding whether causation was present, it will need to be considered whether the claimant; a) protested; b) had a practical alternative open to him; c) received independent advice; and d) acted promptly. This decision has been criticised for being inconclusive and failing to take into account the fact that claimants may not think that there is any point in protesting. This was recognised by Chen-Wis hart when it was argued that; â€Å"these factors are inconclusive. The victim may not protest because he sees no point in it or he may not wish to antagonise the coercing party whose performance he needs† (Chen-Wishart, 2012: 318). It is clear that the facts and circumstances of each case will be the determining factor as to whether the claimant has suffered economic duress or not. Because of the uncertainty that exists in this area, however, it is often difficult for those entering into commercial contracts to acknowledge that they are exerting pressure that is considered illegitimate, especially when there is a possibility that lawful pressure will also be capable of amounting to economic duress. As a result of this, Young warns against exerting commercial pressure that the courts may possibly consider economic duress: â€Å"Abusing your upper hand can leave the strong open to claims† (Young, 2012: 23). Conclusion Overall, whilst the doctrine of duress is well established in English law, the doctrine of economic duress still remains largely uncertain. This generally arises from the difficulty of distinguishing between legitimate and illegitimate economic duress. As such, it is up to the courts to decide when a person’s economic interests have been damaged from being forced or coerced into entering into a contract. Hence, the court will be required to consider whether the re-negotiation of the terms of the contract were lawful and whether the person being subjected to the economic duress, should be entitled to rescind the contract that they entered into. This is an important defence in ensuring that parties to a contract have equal bargaining power. Nevertheless, the practical application of economic duress has been subject to much confusion over the years, which may result from the reasoning that has been provided by the courts. There appears to be a lack of consistency that is being pr ovided, which highlights the need for future reform to this area. Whilst there is a difference between commercial negotiation and illegitimate pressure, it has proven extremely difficult to distinguish between the two, especially since lawful conduct can also amount to illegitimate pressure. In order to provide clarity to this area, it seems as though a more robust approach is therefore needed by the courts. References Business Dictionary. (2014) Economic Duress, [Online] Available: http://www.businessdictionary.com/definition/economic-duress.html [07 July 2014]. Card, R. Murdoch, J. and Murdoch, S. (2003) Estate Management Law, OUP, 6th Edition. Carr, N. (2011) Walking the Line – The Balance Between Legitimate Negotiation and Economic Duress, Available [Online]: [07 July 2014]. Chen-Wishart, M. (2012) Contract Law, Oxford University Press. Cserne, P. (2009) Duress in Contracts: An Economic Analysis, Contract Law and Economics, Volume 6, 2nd Edition. Furmston, M. P. Cheshire, G C. and Fifoot, C H. (2012) Cheshire, Fifoot and Furmston’s Law of Contract, Oxford University Press: London. Dictionary. (2014) Duress, [Online], Available: http://www.yourdictionary.com/duress [07 July 2014]. Noble, M. (1991) For Your Consideration, New Law Journal, Volume 141, Issue 1529. Ohrenstein, D. (2013) Key Developments in Contract Law: Economic Duress, Radcliffe Chambers, [Online] Available: http://www.radcliffechambers.com/media/Misc_Articles/Key_Developments_in_Contract_Law_-_Economic_Duress_2013.pdf [07 July 2014]. Young, A. (2012) When Pressure Turns to Duress, Construction Law Journal, Volume 23, Issue 5. Cases Adam v Opel Gmbh v Mitras Automotive [2007] EWHC 3481 Collins v Godefroy (1831) 1 B&Ad 950 CTN Cash and Carry Ltd v Gallaher Ltd [1993] EWCA Civ 19 Dimskal Shipping v International Works Federation (â€Å"The Evia Luck†) [1992] 2 AC 152 DSND Subsea Ltd v Petroleum Geo Services ASA [2000] EWHC 185 GMAC Commercial Credit Ltd v Dearden [2002] All ER (D) 440 (May) Kolmar Group AG v Traxpo Enterprises Pyt Ltd [2010] EWHC 113 North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd [1979] QB 705 Pao On v Lau Yiu Long [1979] UKPC 17 Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295) Shadwell v Shadwell (1860) 9 CBNS 159 Siboen and The Sibotre [1976] 1 Lloyd’s Rep 293 Stilk v Myrick (1809) 2 Camp 317 Thomas v Thomas (1842) 2 QB 851 Universe Tankships v International Workers Federation (â€Å"The Universe Sentinel†) [1983] 1 AC 366 White v Bluett (1853) 23 LJ Ex 36 Williams v Roffey Brothers and Nicholls (Contractors) Ltd [1991] 1 QB 1 Wright v HSBC Bank plc [2006] EWHC 930 QB Contract Law Introduction In today’s economic climate businesses often exert commercial pressure during contract negotiation stages. This is a normal part of the process and parties to a contract generally know when pressure being exerted is lawful. Although there is a difference between commercial negotiation and illegitimate pressure, it is often difficult to distinguish between the two. Furthermore, because economic duress can arise from pressure that is not in itself unlawful, parties may be unaware that the pressure they are subjecting a party to a contract is actually economic duress. Despite this, if a court finds that one party to a contract has exerted illegitimate pressure on another party, the innocent party may be able to establish a claim of economic duress. Given how uncertain the economy is at present, hard bargaining is a common form of negotiation, though it is vital that businesses are aware of the risks when exerting pressure that is likely to be deemed illegitimate. It is unclear ho w this distinction can be made, nonetheless, which suggests that further clarity is needed within this area. This study intends to explain the developments that have taken place in the doctrine of economic duress and why the courts perceived a need for a more robust approach in light of the Williams v Roffey Brothers and Nicholls (Contractors) Ltd [1991] 1 QB 1 case. Duress Duress is a common law defence that allows a contract to be set aside in instances where one party has been subjected to force or pressure from the other party to enter into the contract. Duress has been defined as â€Å"making someone do something against his will, or making someone perform an illegal act, by using threats, coercion or other illicit means† (Dictionary, 2014: 1). Duress is basically the use of unlawful means to force another to perform an act by either threatening them or performing an act of violence. The party claiming duress will be required to show that they did not have a choice but to enter into the contract (Cserne, 2009: 57). Economic duress, on the other hand, is a fairly new phenomenon that is becoming an important tool for determining whether a contract that has been entered into is enforceable or not. Economic duress happens when a person’s economic interests are damaged from being forced or coerced into entering into a contract. This type o f duress has been defined as the â€Å"unlawful use of economic pressure and/or threats intended to overcome the free will of a person, in order to force him or her to an involuntary agreement or to do something that he or she would not otherwise do† (Business Dictionary, 2014, 1). Economic duress is essentially a contract law defence that allows a person to dispute the formation of a binding contract by arguing that that they were forced to enter into the contract. Previously, parties to a contract could only rely on the doctrine of consideration for protection when they were being subjected to economic duress. Consideration is the price that one party will pay for another party’s promise (Card et al; 2003: 63); Collins v Godefroy (1831) 1 B&Ad 950. The doctrine of consideration does not allow parties in a contract to insist on further payments to perform tasks they are already required to perform under the contract simply because they are in a stronger bargaining pos ition; Stilk v Myrick (1809) 2 Camp 317. Economic Duress and Commercial Pressure It is now widely accepted by the courts that undue commercial pressure can amount to duress. The doctrine of economic duress has evolved significantly from various trade union decisions including; Universe Tankships v International Workers Federation (â€Å"The Universe Sentinel†) [1983] 1 AC 366 and Dimskal Shipping v International Works Federation (â€Å"The Evia Luck†) [1992] 2 AC 152. In The Universe Sentinel, a trade union, which had blacklisted a ship, forced the owner to provide payment before they would remove the ship from the black list. As there would have been disastrous consequences if the ship could not sail, the owner made the payment. Because the ship owner had no other practical choice but to make the payment, he later brought a successful claim for the recovery of the money by establishing economic duress. Similarly, in The Evia Luck a trade union insisted that a ship owner signed various contractual documents so that his ship could sail, which was fou nd by the court to be a form of economic duress. In order to make an economic duress claim, there are a number of elements the claimant will need to be established. These are; a) that the pressure was illegitimate; b) that the pressure was a significant cause that induced the claimant to enter into the contract; and c) that the practical effect of the pressures means that the claimant has no other choice but to enter into the contract (Ohrenstein, 2013: 2). The claimant will be entitled to avoid the contract and claim restitution of any monies that have been paid under it if these elements can be established. In deciding what amount to illegitimate pressure, the court will take a range of factors into account. For example, in DSND Subsea Ltd v Petroleum Geo Services ASA [2000] EWHC 185 it was made clear that the court will be required to consider whether the breach of contract was an actual or threatened breach; whether the person whom exerts the pressure has acted in good or bad faith; whether the claimant had any real or practical alternative but to give in to the pressure; whether the claimant protested at the time; and whether the claimant sought to rely on the contract. One of the most successful forms of economic duress is a threat to breach a contract. In Siboen and The Sibotre [1976] 1 Lloyd’s Rep 293 charterers of two ships threatened to break their charterparties by refusing to pay the agreed charter rate if the rate was not lowered. The owners of the ships had been informed that the charterers had no substantial assets and that the charterers would otherwise go into liquidation if the charter rates were not lowered. This information was not actually true but it caused the owners to reduce the rates nevertheless. It was found that economic duress could apply to this situation as all of the relevant factors were present. Since this decision, the courts seem to have accepted that economic duress is coercive and therefore worthy of the same relief as duress to the person or property (Chen-Wishart, 2012: 316). In spite of this, the practical application of economic duress has been subject to much confusion and it has been questioned when, if ever, renegotiations should be enforced. It would seem, under the doctrine of consideration, that renegotiations can never be enforced on the basis that â€Å"no additional consideration supports the promise to pay more or accept less† (Chen-Wishart, 2012: 316). Under the promissory estoppel doctrine, the promise to pay the same for less can be enforced in limited circumstances, though this does not apply if illegitimate pressure has been exerted. Therefore, if it can be demonstrated that illegitimate pressure has been applied to the renegotiation of a contract, that contract will not be enforceable. Because commercial contracts are extremely competitive, it is likely to be the case that some form of pressure will always be applied. Though the question to be determined is whether the pressure that has been applied is legitimate or not. This is l ikely to be extremely problematic and thus cause a great deal of complexity for the courts. As exemplified in the cases above, threats to blacklist a ship and refuse its release may constitute duress. Further examples of where economic duress has occurred can be seen in the cases of North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd [1979] QB 705 and Pao On v Lau Yiu Long [1979] UKPC 17 where threats to terminate a contract in the absence of a renegotiation is also illegitimate unless it can be legally justified. What will be deemed â€Å"legally justified† is largely a matter to be determined based upon individual facts and circumstances, though there is likely to remain a lot of confliction in this area. In Williams v Roffey Brothers Ltd [1991] EWCA Civ 5 the Stilk case was severely limited by the courts. Here, the consideration requirement was extended to include â€Å"practical benefits† and thereby covered the promise to perform an existing contract. Here, a number of contractors promised to refurbish 27 flats with a sub-contractor performing the carpentry. Before the flats were finished, the sub-contractor realised that he had under-priced the contract and was resultantly facing financial difficulty. The main contractors offered the sub-contractor a financial inducement to finish the contract on time. It is trite law that consideration is needed for a party to that contract to be able to sue on it. Since the sub-contractor was doing no more than he was already bound to do under the contract, consideration was lacking. Surprisingly, it was held by the court that because the contractors had received a benefit from the sub-contractor, in that they avoided the penalty clause of the main contract, the sub-contractors claim was successful. This did not mean that consideration was present as the benefit did not move from the promisee, although there was a clear departure from the orthodox principle of consideration principle. The doctr ine of consideration maintains that a contract will not be supported by the performance of an existing duty unless that duty exists by virtue of a third party contract (Noble, 1991: 141). This decision conflicts with the decision in Stilk which demonstrated that consideration needs to be of economic value to be deemed good consideration and that it needs to move from the promise as also shown in; White v Bluett (1853) 23 LJ Ex 36; Thomas v Thomas (1842) 2 QB 851; Shadwell v Shadwell (1860) 9 CBNS 159; and Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295). It has also been argued by Cheshire et al; that; â€Å"the time has come to recognise formally the alternative definition of consideration and admit that the rationale behind the refusal to enforce some types of consideration is pure policy† (Cheshire et al; 2012; 77). Arguably, it appears that the consideration principle is rather outmoded and in need of reform so that a more robust approach to economic duress can be taken by the courts. At present, much confusion arises as to when economic duress can be used as a defence. Judges thus need to err on the side of caution to prevent commercial pressure being mistaken for economic duress and vice versa. Still, as stressed by the court in Adam v Opel Gmbh v Mitras Automotive [2007] EWHC 3481; â€Å"the list of matters to be considered in assessing legitimacy is not exhaustive, and the weight to be attached to each of them will depend on the facts of the individual case.† Furthermore, it was also stated in the case that the decision to be made will involve some element of value judgement when considering whether the pressure that was exerted on the claimant crossed the line from that which must be accepted in normal robust commercial bargaining. It is clear from the decision in this case that the courts have made some attempts to provide clarity in this area and that each case will be decided on its own facts. In the more recent case of Kolmar Group AG v Traxpo Enterprises Pyt Ltd [2010] EWHC 113 it was evidenced that a contract variation between a supplier and a customer will unlikely amount to duress if the supplier is unable to perform a contract as a result of financial difficulties that will cause the supplier to become insolvent. Another problem that arises when it comes to economic duress is whether lawful conduct can amount to illegitimate pressure. Whilst it is possible, it is also extremely rare as shown in CTN Cash and Carry Ltd v Gallaher Ltd [1993] EWCA Civ 19; GMAC Commercial Credit Ltd v Dearden [2002] All ER (D) 440 (May) and Wright v HSBC Bank plc [2006] EWHC 930 QB. Consequently, economic duress will continue to pose many problems as there will always be a debate as to whether particular circumstances may or may not give rise to a claim for economic duress. Because of the uncertainty within this area, it is evident that a more robust approach needs to be taken so that greater clarity and consistency can be provided. Economic duress has also been criticised for being causation-led, thereby meaning that a lack of causation will prevent a successful claim from being made. In Pao On v Lau Yiu Long [1979] UKPC 2 it was pointed out by Lord Scarman that in deciding whether causation was present, it will need to be considered whether the claimant; a) protested; b) had a practical alternative open to him; c) received independent advice; and d) acted promptly. This decision has been criticised for being inconclusive and failing to take into account the fact that claimants may not think that there is any point in protesting. This was recognised by Chen-Wis hart when it was argued that; â€Å"these factors are inconclusive. The victim may not protest because he sees no point in it or he may not wish to antagonise the coercing party whose performance he needs† (Chen-Wishart, 2012: 318). It is clear that the facts and circumstances of each case will be the determining factor as to whether the claimant has suffered economic duress or not. Because of the uncertainty that exists in this area, however, it is often difficult for those entering into commercial contracts to acknowledge that they are exerting pressure that is considered illegitimate, especially when there is a possibility that lawful pressure will also be capable of amounting to economic duress. As a result of this, Young warns against exerting commercial pressure that the courts may possibly consider economic duress: â€Å"Abusing your upper hand can leave the strong open to claims† (Young, 2012: 23). Conclusion Overall, whilst the doctrine of duress is well established in English law, the doctrine of economic duress still remains largely uncertain. This generally arises from the difficulty of distinguishing between legitimate and illegitimate economic duress. As such, it is up to the courts to decide when a person’s economic interests have been damaged from being forced or coerced into entering into a contract. Hence, the court will be required to consider whether the re-negotiation of the terms of the contract were lawful and whether the person being subjected to the economic duress, should be entitled to rescind the contract that they entered into. This is an important defence in ensuring that parties to a contract have equal bargaining power. Nevertheless, the practical application of economic duress has been subject to much confusion over the years, which may result from the reasoning that has been provided by the courts. There appears to be a lack of consistency that is being pr ovided, which highlights the need for future reform to this area. Whilst there is a difference between commercial negotiation and illegitimate pressure, it has proven extremely difficult to distinguish between the two, especially since lawful conduct can also amount to illegitimate pressure. In order to provide clarity to this area, it seems as though a more robust approach is therefore needed by the courts. References Business Dictionary. (2014) Economic Duress, [Online] Available: http://www.businessdictionary.com/definition/economic-duress.html [07 July 2014]. Card, R. Murdoch, J. and Murdoch, S. (2003) Estate Management Law, OUP, 6th Edition. Carr, N. (2011) Walking the Line – The Balance Between Legitimate Negotiation and Economic Duress, Available [Online]: [07 July 2014]. Chen-Wishart, M. (2012) Contract Law, Oxford University Press. Cserne, P. (2009) Duress in Contracts: An Economic Analysis, Contract Law and Economics, Volume 6, 2nd Edition. Furmston, M. P. Cheshire, G C. and Fifoot, C H. (2012) Cheshire, Fifoot and Furmston’s Law of Contract, Oxford University Press: London. Dictionary. (2014) Duress, [Online], Available: http://www.yourdictionary.com/duress [07 July 2014]. Noble, M. (1991) For Your Consideration, New Law Journal, Volume 141, Issue 1529. Ohrenstein, D. (2013) Key Developments in Contract Law: Economic Duress, Radcliffe Chambers, [Online] Available: http://www.radcliffechambers.com/media/Misc_Articles/Key_Developments_in_Contract_Law_-_Economic_Duress_2013.pdf [07 July 2014]. Young, A. (2012) When Pressure Turns to Duress, Construction Law Journal, Volume 23, Issue 5. Cases Adam v Opel Gmbh v Mitras Automotive [2007] EWHC 3481 Collins v Godefroy (1831) 1 B&Ad 950 CTN Cash and Carry Ltd v Gallaher Ltd [1993] EWCA Civ 19 Dimskal Shipping v International Works Federation (â€Å"The Evia Luck†) [1992] 2 AC 152 DSND Subsea Ltd v Petroleum Geo Services ASA [2000] EWHC 185 GMAC Commercial Credit Ltd v Dearden [2002] All ER (D) 440 (May) Kolmar Group AG v Traxpo Enterprises Pyt Ltd [2010] EWHC 113 North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd [1979] QB 705 Pao On v Lau Yiu Long [1979] UKPC 17 Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295) Shadwell v Shadwell (1860) 9 CBNS 159 Siboen and The Sibotre [1976] 1 Lloyd’s Rep 293 Stilk v Myrick (1809) 2 Camp 317 Thomas v Thomas (1842) 2 QB 851 Universe Tankships v International Workers Federation (â€Å"The Universe Sentinel†) [1983] 1 AC 366 White v Bluett (1853) 23 LJ Ex 36 Williams v Roffey Brothers and Nicholls (Contractors) Ltd [1991] 1 QB 1 Wright v HSBC Bank plc [2006] EWHC 930 QB