MHE509 Emergency Planning and Methodology Module 3 Case Essay

MHE509 Emergency Planning and Methodology Module 3 Case - Essay Example This paper will examine and respond to the accompanying inquiry: 4) What are a couple of the most significant thought that ought to be considered while assessing the dynamic capacities of the occurrence Commander Can his dynamic capacities be assessed by a manager or other mindful individual without the experience from acting in comparative circumstances 1. In light of the announcements introduced above, do you accept that the new Department obviously perceives the significance of neighborhood government in reacting to and controlling little to direct measure catastrophes Please legitimize your position The US Department of Homeland Security (DHS) utilizes roughly 180,000 individuals. It has an overwhelming strategic: the country's bound together exertion to make sure about America which incorporates the discouragement and anticipation of psychological militant assaults and assurance from and reaction to dangers and risks. The office guarantees sheltered and secure fringes and advances the free progression of trade. (Light, 2007) The DHS unmistakably perceives the significance of neighborhood government in reacting to and controlling little to direct debacles. The division builds up a far reaching review of American vital interests and goals for the security methodology. It recognized the choices to actualize the national security technique by characterizing the security objectives for American culture, and by portraying the inner and outer arrangement instruments required. Moreover, it recognized the grouping of measures expected to react to outer dangers. (Parachini, 2003)The DHS works in close coordination with the nearby government. An away from of this is the DHS depends on the specialists on call, for example, EMS faculty, open works, fire and salvage and police organizations. At whatever point a crisis emerges, one of these neighborhood organizations is the first to get informed or potentially show up to the scene, and subsequently, these nearby offices are intensely included. The state country security executives' top system is to interface interoperable correspondences for specialists on call. The subsequent procedure is to blend the reaction methodologies of state and nearby offices. The third procedure is to build up a state knowledge combination focus where crisis reactions can be broke down and settled. The fourth procedure is to affirm and ensure basic foundation. The Department of Homeland Security likewise helps state and neighborhood crisis the executives endeavors by giving tremendous spending plans in awards, and program support. A significa nt case is the Emergency Management Performance Grant (EMPG) which is an all-risks crisis readiness award program on the side of limit working at the state and neighborhood level. The Homeland Security Grant Program

The main reasons why companies decide to internationalize their Essay

The primary reasons why organizations choose to internationalize their exercises - Essay Example Doorman (2011) recognizes how fundamental the dangers are as they are related with new contestants in a market when section cost boundaries are diminished or in any event, when mechanical headways make it simple for new participants to recreate serious items and mix new serious powers in the market. Development in the opposition after a business’ items are in the development stage along the item lifecycle and when markets are getting soaked with rising rivalry, it is not, at this point practical to keep up the nearness in the household nation. Rather than endeavoring to expand the business’ item portfolio, which isn't generally feasible utilizing existing assets and existing information, firms will look for new remote markets as a chance to construct incomes and expel serious dangers. In this limit, they can keep up the equivalent operational expenses related with item make and make another interest with remote customers as a methods for continuing its overall revenue. Moreover, sourcing and fabricating are currently turning into a more globalized work as industry-wide benchmarks and guidelines are being set up (Cavusgil, Yeniyurt and Townsend 2004). This implies gracefully chain systems are getting progressively homogenous on a worldwide premise which makes it simpler for rivalry in a specific industry to pick up a similar kind of acquirement focal points identified with cost and conveyance. As developing markets build up the dispersion systems and substantial frameworks important to arrive at outside business sectors, contenders can benchmark flexibly procedures and disintegrate any upper hands once accomplished by another contender. Further, the capacity of rivalry to accomplish replicable worth included exercises in acquirement drives another contender to look for new chances to recapture upper hands. Internationalization, as it is identified with acquisition systems, gives new chances to improve new item advancement.

Ray Bradburys Fahrenheit 451, Stephen Marches article Is Facebook Essay

Beam Bradburys Fahrenheit 451, Stephen Marches article Is Facebook Making Us Lonely, and Nicholas Carrs Is Google Making Us Stupid, - Essay Example The coupling of innovation with public activities has come about to a story with an inept and forlorn life ever in the wake of, finishing. This is really communicated underway of various specialists whose center is in uncovering the negative results related with innovation. Crafted by these specialists are Ray Bradbury’s â€Å"Fahrenheit 451†; Samuel Cohen’s â€Å"50 Essays: A Portable Anthology (Is Google Making us Stupid); and Mache’s â€Å"Is Facebook Making Us Lonely?† According to Marche (n.p) dejection is advanced through cutting edge internet based life culture. Rather constructing and keeping up physical kinships, online networking society has advanced kinships established on disengagement and depression. Furthermore, Bradbury uncovers that permitting innovation to supplant all parts of life will result to loss of insight. In his cutting edge society, Bradbury uncovers that the general public is disposing of presence of mind knowledge to su bmit to obliviousness. Be that as it may, for the inquisitive and on edge people like Montag figures out how to see the advantageous side of not grasping numbness however working with knowledge. Besides, from Cohen web crawlers have prompted emotional advancement of idiocy as people’s mind lose fixation and long for quick data to take care of issues. In spite of the fact that there are huge advantages from innovative advances, Ray Bradbury effectively anticipated that innovation would likewise have negative effect on human physical, scholarly and passionate wellbeing as though made obvious by numerous specialists today. Mentally, innovation is answerable for the proceeded with encounters loss of knowledge. In view of the contentions by Bradbury, innovation benefits are countered by the related effect of loss of keenness and lose of contact with standard and significant parts of life. For example, Montag couldn't recall being acquainted with there being dew on grass in the first part of the day â€Å"He out of nowhere couldn't recollect whether he had known

Darwin Essay Topics Options

Darwin Essay Topics Options If you are working to determine what you will write about in your essay, these suggestions are what you will need. A critical question needs a severe answer. You've got a wonderful future ahead of you, kid even should you need just a little work by means of your punctuation and grammar. Your subject will represent a wide whole. Men and women work out for different factors. Once you choose the topic which suits you most, bear in mind the reason you write your essay, concentrate on the most crucial details to tell about in your text and don't neglect the significance of senses and feelings in your essay. Besides having an intriguing essay topic, you must use develop it in a suitable way. You may use several examples that can be found on the world wide web at no cost. It is extremely easy to order your paper using our services. Using one of our topics can help you compose a top quality paper. As an example, in college, you might be requested to compose a paper from the opposing perspective. At times, during your nursing program you'll be asked to write several essays and research papers. 1 school of thought believes that children who aren't occupied are more inclined to get into trouble. Whether you're middle school, higher school or university student, you will need to improve your expository essay a bilities. Darwin Essay Topics Secrets Therefore, to write a great essay you've got to brainstorm all thoughts concerning your life experiences. One of the most intriguing sections of a classification essay is exploring the many ways which you can categorize the sections of your subject. Observations show it is useful for couples to live together before creating a choice to marry. In terms of the awards, but the scientist was treated indifferently. You have to be a specialist within the field in order to persuade the audience. You will be sure to get a skilled and effectual essay help because of our very best writers and other team members. If you are conversant with medicine, you can write about nanotechnology, for example. If don't have any single idea about what to write about, look through the topics you've already passed in your textbooks. Alongside the topics, you'd discover loads of papers at no cost. It's possible to go for an intriguing topic from any area of sc ience. The topic needs to be suitable for your essay type. It is going to also be easier to write about a topic you're passionate about. You could be assigned a specific topic or asked to choose the topic by yourself. List down all of the intriguing topics that you run into. The Hidden Facts About Darwin Essay Topics Free Charles Darwin essay samples can be found FreeEssayHelp with no payment or registration. Since 1827 Charles began to delve in the science and made his very first discoveries. Though, there are particular patterns that you are supposed to follow when you compose a descriptive essay. Drop metaphor occurs in the notion of the most difficult writings. A synthesis essay thesis serves as the principal argument of the whole paper. The essay isn't the simplest task to master. Make certain that your essay topic isn't broad, as it'll not be possible that you reveal the key points. An opinion essay outline appears much enjoy a conventional essay outline. Be mindful of the size it must be and begin writing the narrative essay outline. To begin writing your assignment you would want to encounter an interesting and promising topic. Expository essay is a kind of assignment that demands demonstration of your research and reasoning skills on a specific topic. Writing an outline is essential if you need your essay to have a very clear and understandable structure.

Mozambique Essay - 1470 Words

Mozambique Geography Location: Southern Africa, bordering the Mozambique Channel, between South Africa and Tanzania Geographic coordinates: 18 15 S, 35 00 E Map references: Africa Area: total: 801,590 sq km land: 784,090 sq km water: 17,500 sq km Area#8212;comparative: slightly less than twice the size of California Land boundaries: total: 4,571 km border countries: Malawi 1,569 km, South Africa 491 km, Swaziland 105 km, Tanzania 756 km, Zambia 419 km, Zimbabwe 1,231 km Coastline: 2,470 km Maritime claims: exclusive economic zone: 200 nm territorial sea: 12 nm Climate: tropical to subtropical Terrain: mostly coastal lowlands, uplands in center, high plateaus in northwest, mountains in west Elevation†¦show more content†¦ulation (1999 est.) Death rate: 17.31 deaths/1,000 population (1999 est.) Net migration rate: 0 migrant(s)/1,000 population (1999 est.) Sex ratio: at birth: 1.03 male(s)/female under 15 years: 0.98 male(s)/female 15-64 years: 0.95 male(s)/female 65 years and over: 0.71 male(s)/female total population: 0.96 male(s)/female (1999 est.) Infant mortality rate: 117.56 deaths/1,000 live births (1999 est.) Life expectancy at birth: total population: 45.89 years male: 44.73 years female: 47.09 years (1999 est.) Total fertility rate: 5.88 children born/woman (1999 est.) Nationality: noun: Mozambican(s) adjective: Mozambican Ethnic groups: indigenous tribal groups 99.66% (Shangaan, Chokwe, Manyika, Sena, Makua, and others), Europeans 0.06%, Euro-Africans 0.2%, Indians 0.08% Religions: indigenous beliefs 50%, Christian 30%, Muslim 20% Languages: Portuguese (official), indigenous dialects Literacy: definition: age 15 and over can read and write total population: 40.1% male: 57.7% female: 23.3% (1995 est.) Government Country name: conventional long form: Republic of Mozambique conventional short form: Mozambique local long form: Republica de Mocambique local short form: Mocambique Data code: MZ Government type: republic Capital: Maputo Administrative divisions: 10 provinces (provincias, singular#8212;provincia); Cabo Delgado, Gaza, Inhambane, Manica, Maputo, Nampula, Niassa, Sofala, Tete, Zambezia Independence: 25 June 1975 (fromShow MoreRelated Mozambique Essay1491 Words   |  6 Pages Mozambique- a beautiful stretch of land off the Southeast coast of Africa. It is specifically located at latitude 40’27’S to 26’52’S, and longitude from 30’31E to 40’51’E. It’s east coast shores are some of the most tranquilizing while the west coast is bordered by South Africa, Zimbabwe, Malawi, and Tanzania coming from south to north. Mozambique is famous for the Zambesi River and its contribution to the power supply of central Africa. Today the capital of Mozambique is Maputo. The whole countryRead MoreThe Front For The Liberation Of Mozambique981 Words   |  4 Pages1. FRELIMO stood for the Front for the Liberation of Mozambique. FRELIMO began as an independence movement for the liberation of Mozambique from Portugal. After independence, the movement turned into a single party political ruler of Mozambique. A civil war broke out until a new constitution was ratified in 1990. 2. African National Council was the political party that ruled South Africa after post-apartheid. Bishop Abel Muzorewa created it in 1971. The goal of the political party was to net letRead MoreAdolescents And War : How Youth Deal With Political Violence1523 Words   |  7 Pagesspecifically, what these are and how they overcome them. His understanding is that ‘children’ are easily lead into violence because they are small and thus malleable and often become assets in war and violence. 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These members spoke about the life of Mondlane; they focused on theRead MoreThe Violence Of South Africa1372 Words   |  6 Pages(Wanderlust Travel Magazine, 2016), it attracts tourists from all over the world. In addition, one of the largest natural gas reserves in the world was discovered in 2010 along their East coast. Then in 2014, it was reported by Reuters (2014) that Mozambique s mineral-rich economy, one of the Africa s fastest growing, will increase by 8.1 percent in 2014 and this growth is expected to be maintained in 2015 as well (Reuters, 2014). However, in contrast to this beauty and positive growth prospectsRead More4.3 Current Performance. 4.3.1 External And Internal Environment.1397 Words   |  6 Pagescontinuous basis and improve living conditions. Therefore, it’s to provide access to health care, water, sanitation and education in an effort to alleviate poverty levels† states the South32 website. 4.3.2. 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Some major factors in Mozambique thatRead MoreMozambique Is A Sub Tropical Country895 Words   |  4 PagesGeneral background information Mozambique is a sub-tropical country situated in 18ï‚ °15ï‚ ¢S 35ï‚ °00ï‚ ¢E in South Eastern Africa with a land area of over 799,380 km2. The country is divided into ten provinces and 128 districts. Mozambique has about 36 million hectares of arable land (Gà ªmo 2011), and approximately 3.9 million hectares, which make about ten percent of the arable land, are under cultivation with ninety-seven percent cultivated by smallholder farmers(FAO 2005). Mozambique has 1.4 million hectares ofRead MoreMozambique Foreign Direct Investment And Economic Development1395 Words   |  6 Pages2.4. Mozambique Foreign Direct Investment and Economic Development At the end of civil war, Mozambique established the political stability and government established an open market oriented economy and has start to attract significant FDI flows. Mozambique has adopted an unusually strong legal commitment to open its economy to foreign investment as the constitution of 1992 grants the right to foreigners to invest on the entire territory and in all economic sectors. Mozambique with abilityRead MoreEssay about Impacts of Poor Health Services in Mozambique2012 Words   |  9 PagesNationwide,56% of the inhabitantsmoved almost an hour to get to the nearest health Centre andgenerally, only about half of the population has access to community health facilities (Ministà ©rio da Saà ºde, 2007). Equally in many other low earnings countries, Mozambique still hinges on foreign aid to fund the health care sector. In 2008 73% of the health expenditure came from 26 global health partners consist of bilateral, multilaterals, global funds and development financial institutions (WHO, 2008). With such

Applied Leadership - 4476 Words

FINAL PAPER- APPLIED LEADERSHIP INTRODUCTION What is leadership? How does people perceive leadership in their everyday Life? Can we still today, in a world oriented more an more towards individualism and commitment to achievement of personal goals, talk about leadership? Starting from with the question of what is making a person a good leader, I will analyse interviews to 5 people about leadership, then offer an excursus on selected papers about leadership and release, basing on those information the profile of a good leader . STEP 1: What is a good leader? If I would have been asked to define a good leader before attending this course, I would have probably said that a leader is a person which is able to passionate people,†¦show more content†¦He suggests also that a leader should have a good combination of all the different aspects and apply them depending on the different situations. Hill, Linda- Wetzlauer Suzy „Leadership when there is no one to ask: This essay is about determination. Bernabà ¨ showed determination, even through pressures, mobbing and political adverse situation like mani pulite: he had a clear frame of what he intended to do and he did it, showing that strategy and planning can change things and that managers have to be efficient for the job they do, i.e. that it does not exist anymore the job you enter in and you can never get fired. Parcells, Bill The tough work of turning around a team: Parcell, actually a coach, was asked to write an article on his leadership style; his main points were: 1) do never lie. Be honest ; 2) defend your position. No compromises; 3) talk with people separately when commenting and do it positively; 4) move on goals per steps, coach for success. Sull, Donald N. Why good companies go bad: This essay investigates on the reasons which could bring and do bring a company to failure, such as 1. Strategic frames become blinders. Managers need to recognise new options and opportunities ; 2. Processes harden routines. Always search for new, better and cheaper ways of providing goods and services ; 3.Show MoreRelatedCase Study : Applied Leadership Theory Essay909 Words   |  4 PagesCHAPTER FOUR Applied Leadership Theory Introduction Chapter four will define the plan of action to interview Chad Brake, the first shift Senior Supervisor for the Equipment/Component Preparation departments at Pfizer Corporation in McPherson, Kansas. The interview will be designed to pinpoint three key objectives based on the three leadership principles brought together in chapter two and chapter three. The purpose of the interview is to obtain responses from Chad Brake that will validate theRead MoreLeadership Theories Applied By Coach Carter1932 Words   |  8 Pagesthese followers comprises of family, parents, friends, school staff and even the resident community which were densely black people, this basketball team happened to be the pride and hope of that community. This report will outline various leadership theories applied by â€Å"coach carter† as he is fondly called to build up his team to success. VISION AND VALUES Coach Carter’s vision wasn’t limited to just ensuring his team succeed on the court but he had a burning passion to also see the team succeed atRead MoreHow Motivation and Leadership Theories Can Be Applied.3138 Words   |  13 Pagesperformance and, hence, pay, job assignments and other obvious rewards. Leadership In todays business world, effective leadership is gaining precedence over effective management. 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The Triumph of Talent free essay sample

An analysis of individual skill, aptitude, and the ability to do things others cannot and the effects on the philosophy of modernity. This paper discusses capitalism, communism and socialism with the common thread of the individuals role in each society. The writer claims that every person on earth has some special talent, some special ability or ambition, and that by allowing individuals to freely express their individual talents, the entire world reaps the benefits. The writer describes two different meanings of the word talent and concludes that talent, in all its meanings, is the foundation of a better world. Words, like ideas can have many meanings. Take for example the word talent. Mention the term to almost any modern day American or European, and what comes to mind but an actor or an actress on the silver screen, or perhaps a painter, or an athlete. Talent is skill; aptitude, the ability to do things others cannot. We will write a custom essay sample on The Triumph of Talent or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page But, to the ancients talent had quite a different meaning. A talent was a unit of weight most often applied to the measurement of precious metals.

Quality Assurance and Mr. Khan free essay sample

Introduction This paper is prepared based on a case study of garments industry. Mr. Khan started a garments industry. After running for 5 years, he reached at the breakeven point that is no profit and no loss. At the same time, he faced some problems regarding the sustainability of the garments. Here we tried to identify the problems that faced by Mr. Khan based on the on going garment sectors’ condition of Bangladesh. According to us, he did not face any budget problem but he faced performance problem and time problem. After identifying the problems, we tried to give some recommendations regarding the sustainability of his garments industry which are discussed here. 18 Flowchart of problems: 18 Problems identification: 18 The problems we have identified so far, are of mainly three types. The problems are as follows: 1. Performance problems: 1. 1 Poor communication Mr. Khan has poor communication with employees, customers(foreign local) and suppliers appears for several reasons lack of skills or lack of understanding of the importance of strong communication, employees dont get information in a timely manner, employees are given too much information that isnt relevant etc. We will write a custom essay sample on Quality Assurance and Mr. Khan or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page 1. 2 Poor infrastructural design Now a days, the most garments has poor transportation and communication system and building structure, entrance and exit system is bad in case of fire and other accident. 1. Low product quality Sewing defects, Color defects, Sizing defects and Garment defects are quality related problems faced by Mr. Khan which make the product quality low. It creates very bad impression and results in loss of business and reputation. 1. 4 Lack of management policy Today’s garments sector has huge problem with management like- lack of proper instruction, , lack of proper training, workers dissatisfaction with their facilities and payment. 1. 5 Lack of research Although a garment is a thrust sector, lack of proper research and development work remains a major inadequacy for long. The garments do not research about product, buyers and their competitors. 1. 6 Export import barriers 18 Garments are facing export and import barriers. In exporting, garments facing high duty and cota problems. In importing, garments are facing port and customs problems. 1. 7 Limited Export Market Mr. Khan is highly concentrated in two major markets- EU and USA. concentration in a few markets is risky. 1. 8 Excessive labor union Labor union raises their voice for wage increases, set working hours, bonus, on time payment and safety conditions. and productivity. 1. 9 Low productivity of workers The labor productivity of Mr. Khan is much lower. The majority of the workers come from slum dwellers with little or no education. This is one of the reasons of low productivity. Lack of training, motivation and low labor cost are also responsible for lower productivity. 1. 10 Failed to apply TQM (Total quality management) Mr. khan has failed to apply TQM (total Quality Management) in his production process. 1. 11 Lack of high technology Lack of standard machinery results in poor quality and defected garment products. In most of the factories there is theft cases of parts of machines and these are replaced with low quality parts to keep the machine operational. . 12 Limited knowledge in international marketing information Mr. Khan has limited access to current market intelligence and international trade information. Foreign buying houses have been dominating the marketing part of the business. But if these buying houses shift their bases to other countries, Bangladeshi exporters may face serious problems in findi ng their ultimate buyers. For that reason they strike which reflects on profit Limited exported in Germany, UK, France, Netherland, Italy and Canada. The high 18 1. 3 Inefficiency in port management The Chittagong Port is the most important entry and exit point for trade and commerce of the country. It is one of the most inefficient and corrupt ports which seriously hamper the competitiveness of Bangladeshi garment in the world market. The corruptions are- Frequent work stoppage by different service providers, transport workers, Excessive dock labor unionism, Politicization of Collective Bargaining Agents, Direct involvement of powerful local politicians, elite and musclemen, illegal gratification practices. 1. 14 High competition Mr. Khan is facing high competition for other local garments industries and efficient producers like Hong Kong, China, India, Thailand, and Sri Lanka, Vietnam and Caribbean countries. 2. Time problems: 2. 1 Global Recession The garment exporters are suffering badly due to the ongoing global economic crisis. For the worldwide recession, Mr. Khan is realizing low unit value from the overseas market and paying higher unit value for importing raw materials. 2. 2 Lack of resource when needed Resource like electricity, gas and water are not adequate. The raw materials are not also available in our country. Mr. Khan depended on others countries for outsourcing of raw materials which charged higher prices and increased the production cost. 2. 3 Lead time The buyers want the product within a limited time with a best possible price that Mr. khan could not meet up. 3. Money Problems: 18 3. 1 Fluctuation of international prices International price fluctuate heavily. As a result, cost of raw materials increases which ultimately increase the total price. 3. 2 High corporate tax rate In garments industry has to pay high tax on their production as well as VAT. 1. Performance problems: 18 Performance problems and solutions Effective Communication Wonderful nfrastructural design Poor infrastructural design Poor communication Low product quality Improving product quality Effective management policies Lack of management policy Conduct more research Lack of research Effective export import system Export import barriers Limited Export Market Markets exploration Mutual understanding Labor union Low product ivity of workers Increasing productivity of workers Effective use of TQM F ile toa p T M a d p ly Q (T ta q a mn g mn o l u lity a a e e t) Lack of high technology Limited knowledge in international marketing information Use of high technology Buying agent Ensuring efficient management of ports Inefficiency in port management Increasing Competitiveness High competition Recommendation of performance problem: 18 For the performance problems showing above, we are giving the following suggestions: 1. 1 Effective Communication Clearly communication appears to be the key to project success. Effective communication skills can create a more positive outcome. Stay focused on the present employee’s feelings, understanding one another bring solution to communication problem. Effective communication goes both ways- thinking and listening. At first Mr. Khan has to listen what employees and suppliers are saying, customers or buyers want. Don’t interrupt and get defensive. Just hear them and reflect back what they’re saying so they know they are heard. Then Mr. Khan will understand them better and they’ll be more willing to listen to him. Foreign Buyer Local raw material Suppliers Manufacturer (Mr. Khan) Figure of Business Structure Foreign raw material Suppliers Try to see from the view point of employees, customer sand suppliers. Communicate directly with customer and suppliers. Mr. Khan Director Director Line Agent Line Agent Line Agent Line Agent Line Agent Line Agent Figure of Team Communication 18 As messages are passed up or down through the layers of the organization, they pass through a number of different people who can add, take from, qualify or totally twist the original message. Mr. Khan has to begin communication with the directors who receive instruction directly from him. They are then asked to share this information with their group of front line agents. One way to make sure the directives or communication that directors pass down actually get to the front-lines the way he intended is to randomly conduct â€Å"round table† discussions. Pull 3-5 front line agents in for a discussion that is very informal and ask specific questions to get a feel for the messages Mr. Khan has passed down and to make sure the director is doing their job. To overcome fear Mr. Khan must work to develop trust among the employees. Trust develops when Mr. Khan will do what he says he is going to do and by doing his part to help the team succeed. Mr. Khan has to build trust and not violate the confidentiality of the employees who are openly and honestly sharing. Again, the key to honest feedback is to create a trustworthy relationship that employees believe will not come back to hurt them later. . 2 Wonderful infrastructural design To remove this problem Mr. Khan should establish in such type of area where transportation system is well. Mr. Khan’s garment should have large entrance and exit way and alternative way to exit in any kind accidents. For fire accident Mr. Khan’s garment should have enough fire distinguisher. If the garment has large entrance and exit and enough fire distinguisher then every employee will feel safe and will do their job with full attention. Governments can also impose some rule regulation on garments building stricter. 1. Improving product quality Before entering into international market, garment exporters have to carefully frame out the quality standards. There are a number of factors on which quality fitness of garment industry is based on such as performance, reliability, durability, visual and perceived quality of the garment. 18 The broad quality parameters (ISO 9000 series) have to follow for maintaining the export quality. Quality has to be taken care by Mr. Khan, because excuses are not entertained in international market for negligence for low quality garment products. So, Mr. Khan has to produce high quality product, use latest design and technological know- how. Apart from superior quality of the garment, its pricing, packaging, delivery, etc has to be also taken care of. Quality needs to be defined in terms of a particular frame work of cost. So, Mr. Khan needs to follow focus strategy. It means Mr. Khan has to focus on cost and quality at a time. Mr. Khan should know to negotiate a premium price after quality assurance is done. The garment shown in the catalogue should match with the final garment delivered and the garment quality should match the samples shown during taking the orders. It is important to perform according to the promises given to the buyer. Because in international market, quality reassurance is required at every point. Proper documentation and high standard labels on the garment are also important aspects as these things also create good impression. Quality is ultimately a question of customer satisfaction. Good Quality increases the value of a product or service, establishes brand name, and builds up good reputation, which in turn results into consumer satisfaction, high sales and foreign exchange. The perceived quality of a garment is the result of a number of aspects, hich together help achieve the desired level of satisfaction for the local customers and foreign buyers. Therefore quality control in terms of garment, pre-sales service, posts -sales service, delivery, pricing, etc are essentials. 1. 4 Effective management policies 18 For overcome this type of problem Mr. Khan should hire higher educated persons by providing high salary. Because they have the ability to give proper instruction to their workers like- what the buyers want, what quality of work he expect, how the work should do etc. Secondly, the workers are uneducated. For that they can not adopt with the new technology. For such kind of problem Mr. Khan needed educated workers so that they can easily adopt with new technology. On the other hand it is easy to provide higher training to the educated workers. Mr. Khan should setting a minimum wages and salary level and pays the salary and wages on time. And workers should give large space so that they can move easily. It will make the employee more motivated to their work and more devoted to the management policies. 1. 5 Conduct more research Research is needed for every company to sustain in the market. Mr. han should conduct more research also because of changing of time and demand of customers and buyers. The Mr. khan can hire research people to forecast the demand and quality of product. To forecast the buyers demand the research people can talk with the customers and buyers what kind of product and which quality of product they want. The Mr. khan should research about his competitors and their s trategy also. It can possible by observing the competitors very carefully. 1. 6 Effective export import system The governments increase the facility for exporting garments product with a low export duty and should give high dock facility. For cota system government should negotiate with that countries imposes cota on our garments product and can do an exchange deed with those countries. As the garments industry has a big contribution in our economy and we earn a huge amount of foreign currency so government should give extra emphasize on garments raw material by reducing customs formalities. 1. 7 Markets exploration 18 Efforts should be made to develop new markets, at least in large Asian countries such as Japan, China and India. This may help Mr. Khan to sustain his garments growth in the increasingly competitive global market. 1. 8 Mutual understanding Mutual understandings remove the labor union problem. While taking a break from the discussion is sometimes a good idea, always come back to it. If come up to the situation with a constructive attitude, mutual respect, and a willingness to see the other’s point of view or at least find a solution, then Mr. Khan will be able to make progress toward the goal of a resolution to the conflict. Instead of trying to ‘win’ the argument, look for solutions that meet everybody’s needs. Either through compromise or a new solution that gives both what they want most, this focus is much more effective than one person getting what they want at the other’s expense. 1. 9 Increasing productivity of workers Operations are more efficient when employees perform just one task or only certain aspects of a task in order for that job to be conducted at its highest level. Continuous efforts should be exerted to reduce the cost of doing business by increasing productivity. To enhance the productivity of labor, intensive training, worker satisfaction and proper motivation is essential. So, Mr. Khan has to provide on the job training for increase skill of production. He also has to meet the workers demand to satisfy them. Then the worker should be self motivated. Better working conditions with reasonable pay may improve the situation to attract mid to upper-mid level well-educated citizens of the society, which may help improve the productivity of labor significantly. 1. 10 Effective use of TQM Total Quality Management is a management concept . The basis of TQM is to reduce the errors produced during the manufacturing or service process, increase customer satisfaction, streamline supply chain management, aim for modernization of 8 equipment and ensure workers have the highest level of training. Mr. khan should use TQM not only achieve the objectives set out in its policy and strategy, but also, and equally importantly, sustain and build quality. Mr. khan should use TQM focuses on encouraging a continuous flow of incremental improvements from the bottom of the organizations hierarchy. It will make production smooth, increase production quality as well as management quality. 1. 11 Use of high technology Mr. Khan has to provide flawless machineries to achieve better output. Mr. Khan instead of going harsh against the workers must try to find out the real causes of low quality products and time wastage factors if they really want to bring qualitative changes in their products. 1. 12. Buying agent Mr. Khan should use a buying agent who can do all sort of job on behalf of the company and this will be very much handy, once company has enough experience doing foreign trade then it can do all the procedures itself. 1. 13 Ensuring efficient management of ports †¢ †¢ †¢ †¢ Operate the port for 24 hours a day Stop all toll collections that takes place at the entry and as well as within the port. Encourage the establishment of more off dock container freight stations (cfs) (both for exported and imported containers) Permit private sector to take over some of the functions of handling containers. This will reduce the space pressure on the port and minimize delays in handling raw materials. †¢ Simplify the administration of vessels entering the port and reduce the number of forms to be completed from 40 (now) to 7 (as in most ports). 18 †¢ Activate the proposed Asian Development Bank loan project and modernize Chittagong Port. The approach of the loan is to allow privatization of some port operations †¢ †¢ †¢ Revise the antiquated Shipping Act, procure more equipment, and construct the proposed new container port Banning all kinds of strikes within it Special export processing zones have been set up to ensure smooth functioning of factories for export processing. 1. 14 Increasing Competitiveness For increasing competitiveness Mr. Khan has to keep the cost of production lower than that of competitors, bring continuous innovation in technology, offering high quality product at reasonable and take different promotional activates . Time problems Time problems and solutions Global Recession Overcoming global recession Make Resource available Lack of resource when needed Lead time Manage lead time soundly 18 Recommendation of time problem: For the time problems showing above, we are giving the following suggestions: 2. 1 Overcoming global recession The BGMEA must look into it thoroughly and start thinking from now on without wasting time regarding how to tackle the situation and keep our products export on track which accounts for our foreign exchange. 2. 2 Make Resource vailable In garments factory electricity, gas and water are the most important. For this, Mr. Khan should make own bio-gas plant and own electricity plant for their garments and also can use big jars for sustain water. Government should also adequately distribute these. Mr. khan should store sufficient amount of raw material in warehouse to make the supply of raw material smooth and easy when needed. Mr. khan should also find out alternative way to sourcing raw material to buy raw 18 material in low cost when others price is high. Company should keep in mind the following factors to select a supplier whether to home or abroad: †¢ †¢ †¢ †¢ †¢ †¢ Purchase price Technological capacity Distribution costs Reliability regarding just-in-time deliveries Service by the raw materials producer Quick response 2. 3 Manage lead time soundly Lead time is one of the main competitive factors among companies. The ability to deliver quickly influences export, sales and thereby revenue. It normally includes all activities from start to end. Lead time begins with the first receipt of a customer order and ends with customer receipt of the product or service. Mr. han should always make available raw material, use high technology, skillful workers and management team to finish the total process properly and meet the lead time. Customer lead time = [{Information lead time} + {Order lead time}] Total lead time = [{Information lead time} + {(manufacturing lead time) + (shipping time for import fabrics) + (S hipping time for export final product)} Mr. khan should reduce time in the following processes: 18 The proposed structure is: 3. Money problems Money problems and solutions Fluctuation of international prices Adopt with international prices High corporate tax rate Negotiation for reduce tax rate 8 Recommendation of money problem: For the money problems showing above, we are giving the following suggestions: 3. 1 Adopt with international prices When product price will fall in international market, then he should produce fewer products and minimize the import. If in this moment he produces more products and maximizes import, then for fluctuation in international market his product price will be fall. For this reason, he can not success his business and sustain will be impossible. To overcome this problem he should produce and import minimize product. Price Demand Production 3. 2 Negotiation for reduce tax rate 18 When any business organization firstly starts a business, then government do not charge any tax on that business for first five years. After five years government charge high corporate tax. To overcome high corporate tax rate Mr. Khan should maximize the profit because from profit government do not charge any tax. He can maximize the profit to develop his product quality. Conclusion Mr. Khan should continue the project for sustain his business and earn profit. We think he will overcome all of his problems if he follows our suggested way. 18 Appendix The own part done by each group members are given in the next page with name and id. 18

The Crusides Essay Example

The Crusides Essay Example The Crusides Essay The Crusides Essay Please create two journal entries. For the first journal entry you will write as if you are a Crusader. You should discuss the long journey it took for you to reach Jerusalem, your reasons for participating in the Crusades, and any fears you might have. For the second journal entry, you will take on the role of a muslim living in the city of Jerusalem writing about the Crusaders and the attack on the city. 1. Crusader- Dear journal, My days on the ship were ever lasting they seemed to never end but I hung in there. I would see other Crusaders on the ship and they seemed to be ill or sea sick. If you tried asking another Crusader if he was sea sick or not he would say no. Now I myself became a Crusader because I not only wanted to see the land that Jesus live and taught on I wanted to live on it. I was simply a Peasant and I was hoping to get land and freedom from service on the Manor, I was tired of it. Even though at times while I was on the ship I would worry about it sinking or about us getting lost in the middle of the ocean. When we finally arrived close to land we were already almost out of supplies so pulled up to dock and we later learned that we had docked at Italy and they supplied us with reinforcements. When we neared Palestine everybodyy started going crazy on the ship everyone was running around on the ship. As I was preparing to leave the ship I ran into one of the Kings and we started to talk and he told me that if I survived the battle at Jerusalem, he would give me some land and some of his Serfs. My thoughts when we were about to depart the ship were I did what I wanted to do, Ive accomplished it. I also thought why this place was important to us Crusaders and i thought this land is Important to us because this is the land that Jesus lived and taught on and it was the birthplace for Judaism. My thoughts going into this were crazy and I was nervous, But then my thoughts were over and everything just happened and then I wrote this. 2. Muslim- Invasions was all i could see coming. Invasions, Invasions of Christian Crusaders that wanted to take our land from us. We took this land from the Byzanite emperor, and then the Byzanite emperor turned around and sked Pope Urban ll for help, And now here they are. As they invade I sit here and write that is all i can do because they will catch you trying to run from the city and keep you as a servant to the Kings. So all I can do is write and watch. The reason that we conquered Palestine was to make it our first Oiblah and we did. Now they are determined to come and get our land and they will they already have invaded and there is only a ce rtain amount of time before they come get me. So with this I leave my journal untill next time.

Importance of training in public safety Essay Example | Topics and Well Written Essays - 2000 words

Importance of training in public safety - Essay Example The topic of the work is related to the discussion of why training in public safety is important and why the idea of its importance should be made public. Special accent is made on the role of Human Resource Management personnel in promoting these public safety policies as well as their importance. Despite the fact, that various organizations put a special stress on the necessity to train personnel in the sphere of public safety, many still neglect it. This is why it is essential to discuss the issue in more details. The work will be designed according to the following outline. The background of the problem should be described, and it is clear that it is connected with both the negligence of personnel towards it and the growing threats for the public safety all over the world. The combination of these two factors makes the issue of public safety training of vital importance. The historical perspective is also essential to make the discussion complete. The research will be made through the various literary sources, and will pay additional attention to the importance of public safety training in the light of the events which regularly take place in the country; it does not only include the threat of terrorist attacks, but accidents of mass murders in public places, while any organization and personnel may become the victims of such crimes. The aim of the work is to make the reader understand that public safety training has become the integral part of the public personnel management, but not only s pecialists, but personnel themselves should pay more attention to this issue, as their lives depend on the way they address training. The key attention will be paid to the role of the HRM in providing public safety training and the imporance of this training in private companies and in public safety organizations as well. Background The background of the problem relating to the importance of training in public safety lies in the fact that accidents of various kinds often become the reason for injuries and deaths, this is why training in the sphere of public safety is essential for the organizations, and this aspect should be made an integral part of the public personnel management. In order to estimate the level at which public safety training should be provided in the various organizations, it is essential to see what knowledge personnel possesses at present. The level of safety knowledge in the modern community is different, and thus among the aims of the present work will be to discover the level of the safety knowledge in the modern community among different personnel, and to relate it to the importance of the public safety training. In order to see the importance of the public safety training in public personnel management, the examples of workplace violence will be taken; they often become the causes of de aths and are neglected in the same way, thus needing special attention. The background of the public safety training issue lies in the fact, that this aspect should not only be made one of the priority ones, but should also exercise various techniques for that. However, the background of the problem is directly connected with the historical perspective which should also be discussed in this work. Historical perspective Not only must an organization see to it that employees' rights are not violated, but it must also provide a safe and healthy working environment. Mondy and Noe (1996)

Answer the parts of directions Essay Example | Topics and Well Written Essays - 1000 words

Answer the parts of directions - Essay Example This paper is going to discuss the importance as well as benefits of college education to the success of individuals as well as the drawbacks that accompany it. This paper is going to determine the worth of college education, factoring in its merits and demerits. Lastly, this paper is going to discuss the reasons that support the fact that the benefits that accrue from college education far outweigh the demerits or the drawbacks. College degree sets one in better spots of getting employment. In addition, it enables one meet new friends and professors. College education equips one with a variety of knowledge as well as different levels of thought and understanding. As such, college degree makes one independent in thought, as well as boosts one’s creativity. College degrees are important in creating a chain of helpful acquaintances ranging from making new friends as well as interaction with various cultures. Developing such friendships and links is worthy and more beneficial compared to the drawbacks that are associated with the college education. This leads to information sharing as well as coming up with a myriad of helpful ideas. College education helps one meet new faces, make friends as well as get to know a lot of information concerning their friends. These are some of the few benefits that are derived from a college education, though unexpectedly. Having friends is a very crucial thing in the life of a college student. For instance, as an accounting student, many of my friends have become helpful to me. In addition, I have also become helpful to them in many ways. There are several instances when we share our interests in education. This has always acted to inform me further concerning the future benefits that await me from colle ge. Some of the interests that we always share have even made a few of my friends to change their minds and start looking at the

Belonging in Ancestors and Feliks Essay Example for Free

Belonging in Ancestors and Feliks Essay Fundamentally one can only really feel a true sense of belonging for a nominal moment in time. The actual instance of belonging is intangible and not permanent. Due to this, any form of belonging will involve compromise, sacrifice and some degree of tension as different ideals compete for supremacy. We will continue to accumulate different senses of belonging and disregard the others as we grow, evolve and adapt to different situations. Due to the varying and conflicting belonging ideals, we will become frustrated and the joy of belonging may become a burden upon us at times. This frustration and momentary joy of searching for ones place of belonging are explored in Skrzynekcis Ancestors and Feliks, as well as Homecoming a novel by Cynthia Voigt. It implores the audience of these texts to relate to the happenings of the characters in the texts. The texts requires us to place ourselves in the shoes of the characters feeling their sense of connectedness, belonging and self identity through the links of family ancestors and or heritage. The poem Ancestors allows the reader to be positioned to feel the connection through our own ancestors and the attributes they bring to the forefront. They allow us to delve into the unknown or forgotten realms of our own history and allows us to draw upon these memories in order to feel content with our own sense of identity within society. It is a basic human notion of feeling as though we are not alone and we are apart of something greater then ourselves. In the poem Shrzynecki, there is an attempt to illustrate to the audience that he feels a sense of isolation in regards to the separation from his ancestors. The poem represents that without a clear understanding of our own history or ancestry we lack a clear sense of self as we are unaware of our past values, motives and/or attributes. This representation of ideas is presented through the use of metaphor and narrative voice. The Star metaphor To what star do the footprints lead? represent an unclear sense of direction the star being the focal point of navigation which demonstrates the idea that without knowledge of your ancestry we cannot be certain of our place in this world. Another prominent language feature in this poem is the use of rhetoric. The rhetorical questions of who, what, why and where represent the uncertainty of the Authors own past as there is a missing link from his ancestors and himself. The use of second person narrative voice in Ancestors, for example why do you wake positions the reader to look beyond the constraints of Skrzynekcis written words and to consider our own ancestry. A The second text Feliks illustrates to the audience that we need some type of belonging in order to fit into society. In the poem the father drew upon his memories of Poland through his garden. Skrzynekci on the other hand was unable to create a link to his heritage or the present as he was torn between the new society and his old traditions. He failed to create a solid link to either of his heritages and thus conflict is presented to Skrzynekci. This conflict is one that creates many difficulties in regards to the way Skrzynekci related to his family and friends. In the first stanza of the poem My gentle father kept pace only with the joneses of his own minds making link to the fact that his father was not affected by the outside happenings and he was the only one whom dictated the way in which he did things. This then put strain on Shrzynecki as he began to feel more and more isolated from the new society as his father was rejecting the new practices rather then assimilating. Another present language feature is the use of hyperbole. The hyperbole ten times around the world is used to exaggerate Skrzynekcis thoughts in regards to his father. Throughout the poem it is evident that Skrzynekci holds his father in high esteem and wishes not to disappoint his parents by choosing to assimilate into the Australian culture. This leaves Skrzynekci in an isolated state as he does not feel a sense of belonging to either the old or new heritage. In the novel Homecoming the theme of belonging runs throughout the entire novel. The novel tells the story of the 4 Tillerman children as they find themselves alone in their car (being abandoned by their mother), some miles from their home, in a shopping mall parking lot in Peewauket, Connecticut. The children go on a journey in order to find a place to live; a search for a home, a physical place where they can belong. They end up living with their grandmother. Through their journey in the novel they search for belonging within themselves, realizing that they are stronger as a family and that, although they have different personalities, strengths and weaknesses, they belong together. The children also struggle to see where they belong in the wider world, in society, as individuals and as a unit. It becomes apparent though the novel that family is a major symbol of belonging as within the home front the children learn this vital concept. Their Homecoming is a journey that leads them to a long-lost grandmother who remains the key to unlocking their family history and ancestry. They start to learn that families can be fragile, and that if they are not nurtured and protected, they can fall apart as in the case of their family. In regards to the contrasting of the three various texts one must position themselves both in the own realms of society and that of the author. We have to adapt to the authors context in order to fully comprehend the text and its entirety. All three texts present the themes of belonging/not belonging within themselves and society. In regards to Skrzynekcis poems we are able to understand that any link, either being that of family ancestors or even heritage creates a sense of belonging due to the link we have created to something greater than ourselves. The novel Homecoming links to the poems through the use of not belonging and the sense that Peter Skrzynekci felt and expressed through his poems. Homecoming links indirectly to Ancestors as both texts bring family and its importance to the vanguard. Homecoming and Feliks contrast as they allow the audience to become aware of different senses of belonging, such as the garden in Feliks and the mother in Homecoming. However in both instances the texts allows one to feel as though they are connected even when they feel as though there is absolutely no sense of belonging present. To conclude, all the three texts above illustrate the importance and the evolving nature of belonging. Thus the fundamental necessity to belong brings to the forefront that motivation for living, the reason for feeling placed within society and the drive for continuing growth and development on our journey through life. SUPERFLUOUS SHORT SENTENCES ARE MORE IMPACTUAL CONCISE It may be as though we are unable to really feel a true sense of belonging and the only essence that is closets to true belonging is that to oneself. This would ultimately mean that we cannot be truly be connected to anything until at the end of ones life when we reflect upon all the different places of belonging. It also brings to the vanguard that one can only really feel a sense of connectives or understanding of self if they are aware of their own history. It allows us to no longer feel isolation as we can clearly see where our ideals, motives and values originated. The language features that are present in this text demonstrate these factors and enable us as the reader to further understand the text and its meanings.

Physics of Sailing :: physics sport sports boating sail boat

The Hull of the boat is the frame which keeps the boat and its crew floating in the water. The mast is the tall pole that sits vertically near the center of the hull, the mast is what the sails are attached to to keep them suspended and straight. The boom is a large pole attached to the bottom part of the mast which is able to rotate up, down and side to side. The sails attach to the boom and the mast then the person controlling the main sail moves the boom around to change the direction and tension in the mainsail. The rudder is atached to the rear of the boat and is what essencially steers the boat (note that the rudder alone will not steer the boat exactly where you want to go in a sailboat unlike other motorboats). The most difficult part of a sail boat for most beginners to understand is the keel or centerboard. The keel of the boat does many things, it acts as a pivital point for sharp turns and "jibbing", it helps keep the boat upright by lowering the center of gravity of the boat, it works to keep the boat moving in a line of motion close to that of the direction that the boat is facing. This is because the boat is usually being pushed heavily to the side by the wind. And the keel also works to pull the boat into the direction of the wind the same way the sails do. This is a concept that I will discuss later on. The Sails: The sails of the boat are what provide the forward thrust. There can be several sails but in every sail boat there is a main sail. That is the sail which is attached to the mast and is usually the tallest sail on the boat, it is controlled by the boom and has several attachments used for slight adjustments to get the most effeciency. There is usually a "jib", a smaller sail in the front of the boat attached to a guy wire which reaches about %75 of the height of the mast or main sail. The jib provides additional forward force but is just as usefull in providing manuverability in low speed or low wind situations or moving out of a docks area. In this site I will refer only to sailboats with a standard mainsail and jib, as in the picture to the right.

Case Laws for Commercial Laws

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