Change of Position Defence

The defendant may claim the defence of change of position. Whether the defendant can successfully establish this defence depends of whether he can prove that his position is so changed that he will suffer an injustice if called upon to repay or repay in full (Lipkin Gorman v Karpnale) * In order to prove a change of position defence, first there must be an adverse change of position by the recipient in good faith and in reliance on the payment (New Zealand Banking Group v Westpac Banking Corporation) * The current position in Australia with regard to the availability of the defence is that the defendant must have (1) changed their position (2) irreversibly (3) in reliance on its receipt (4) in good faith (Australian Financial Services)(1) CHANGE THEIR POSITION / SUFFER DETRIMENT * The defendant must first be able to prove a change in the relative net assets of the defendant which shows that the defendant has acted to his detriment on the faith of the payments received from the plaint iff. In other words, the change must involve a net loss.FACTUAL GAIN BUT NET LOSS * Even where a woman who had purchased new furniture and had got rid of her old furniture on reliance on her receipt, where the court accepted that she was factually enriched by her receipt since her net assets were worth more than what she had before, the change of position defence would nevertheless apply since if she was required to make restitution, she would be left with a net loss. * The mere fact that she continues to benefit from the money does not defeat the defence of change of circumstances. The furniture acquisitions represent replacement of items the plaintiff had in her possession when she would not have replaced the items except for the error. The expenditures were not to meet ordinary expenses or pay existing debts.(RBC Dominion Securities v Hills Industries)IS SPENDING ON ORDINARY LIVING EXPENSES CHANGING YOUR POSITION? In general, expenditure on ordinary living expenses will not be re garded as a detriment or that the defendant changed his position because the defendant has to prove that he acted differently from how he would have ordinarily acted on the faith of the belief that the benefit conferred by the plaintiff was the defendant’s to spend (Australian Financial Services & Leasing v Hills Industries) * However, a defendant is not precluded from relying on the defence of change of position merely because she has spent the money on ordinary living expenses, provided the expenditure is a substantial detriment stemming from her reliance on receipt of the payment. The defence can apply where the defendant does not simply spend the money on such expenses but applies for and is denied benefits to which she is entitled as a result of her receipt (TRA Global Pty Ltd v Kebakoska) In that case, the respondent had been made redundant by her employer who told her she was entitled to a redundancy payment equivalent to 12 weeks pay on severance and accordingly p aid her the sum. She in fact had no such legal entitlement.She subsequently applied for unemployment benefits from Centrelink but was denied them because she had declared receipt of the redundancy money. She was forced to used the bulk of the redundancy money to pay living expenses until she found work eight months later. When the appellant employer sought restitution of the payment on grounds of mistake, the court held that the plaintiff had a defence of change of position despite having spent the money on ordinary living expenses since the expenditure is a substantial detriment stemming from her reliance on receipt of the payment and was denied benefits to which she was entitled as a result of her receipt.DISCHARGING AN EXISTING DEBT * It is not a detriment to pay off a debt which will have to be paid of sooner or later (RBC Dominion Securities v Dawson) In that case Mr Dawson had a Visa debt which he liquidated in a manner he would not have otherwise done had it not been for the mistake on the part of the appellant to overpay him. However, since the Visa debt and those to family members was incurred prior to the mistake, it would have been paid in any event and cannot be said to be to Mr Dawson’s detriment because the payment would be a payment of a debt already owed. (2) IRREVERSIBLY * The second element is that actual, non-speculative and irreversible detriment (Australian Financial Services & Leasing v Hills Industries) The nature of the change must be such that it cannot now be undone such as money received which has been irretrievably paid away or incurring unconditional contractual obligation as a result of receipt. In Australian Financial Services, the plaintiff finance company was duped by a fraudster and two of his companies into advancing money to several legitimate businesses including that of the second defendant to whom the fraudster and his companies owed money so as to discharge their debts. The plaintiff was led to believe that th e purpose of the money being advanced to the defendants was to finance the purchase of equipment they were supplying to the first company when the equipment never existed. Each of the defendants was accustomed to receiving payments for their equipment from finance companies so they were not immediately suspicious of receiving money from the plaintiff.The plaintiff then claiming unjust enrichment against the defendants on the ground that it had made payments under the mistaken belief that the invoices made by the fraudster to the plaintiff, purporting to be from each of the defendants, were genuine and that it would obtain title to the equipment named in the invoices. * In this case, the court held for the defence of change of position to succeed that there must be evidence of an irreversible detriment. The second defendant having foregone default judgments already obtained against one of the fraudster’s companies was in reliance on receipt of the money from the plaintiff was such evidence. * In TRA Global Pty Ltd v Kebakoska, the detriment to the plaintiff such that she was denied benefits to which she was entitled to stemming from her reliance on receipt of the payment was irreversible. In RBC v Dawson, the fact that the purchased new furniture and had got rid of her old furniture on reliance on her receipt would have caused her in the circumstances a loss that is unjust for her to bear and which is not easily reversible. * Thus it seems that the defendant must show at the very least, significant hurdles to getting the money back. (3) In reliance on the receipt/on the faith of receipt * This third element shows that there must be a causal correlation between the detriment suffered and the receipt of the payment. A BUT-FOR TEST IN UK * The mere fact that the recipient may have suffered some misfortune is not a defence unless the misfortune is linked at least on a but-for test with the mistaken receipt (Scottish equitable) There a variety of conscious de cisions which may be made by the recipient in reliance on the overpayment.A CAUSAL CONNECTION IS SUFFICIENT IN AUSTRALIA – ONE CAUSE * In Co-Buchong v Citigroup Pty Ltd, it was held that for the purposes of a change of position defence, a payment is made ‘on the faith of the receipt’ if it is causally linked to the receipt. This requires that the payment would not have been made unless the receipt has been recognised as valid. There is no further requirement that the information upon which the payer was acting be such that, if it were true, the payer would have been entitled to pay the money away in the way that id did. * In this case, Citibank had received instructions purporting to be from the plaintiff to transfer 500,000 from his account to a second account in his name at the NAB.Citibank examined the instruction and determined that it was genuine and paid. NAB then received similar instructions to pay the money away to various overseas bank accounts. Here th e instructions were all forgeries perpetrated by an unknown third party. Citibank claimed restitution of its payment to NAB on grounds of mistake. The issue was whether NAB was entitled to a defence of change of position and whether those payments had to various overseas bank accounts had been made ‘on the faith of its receipt’ of the money from Citibank. It was held that NAB did make those payments on the faith of its receipt and all that was required was a causal link between the payment and the receipt. The fact that a third party fraudster had instructed the bank to make out the payments should not necessarily negate the causal connection between the receipt and its payment so as to defeat the defence (rejecting State Bank v Swiss Bank Corporation) * In such a case, the bank’s good faith receipt may still be a cause of a change of position even if it was not the only cause and this should be enough. * This follows the reasoning in the NSWCA case of Perpetual Trustees Australia Ltd v Heperu. Perpetual had paid away sums to Mrs Cincotta funds represented by the units credited on the faith of the receipt of payments by the respondent who had been induced by fraud to do so.The respondents submitted that Perpetual had not proven that the payments of funds out of the account were made on the faith of the receipt because it paid out the funds represented by the account on the faith of what it was told to do by Mr Cincotta in the original forgery of Mrs Cincotta’s signature at the opening of account and in telephone redemptions. * This was construed to be far too narrow an analysis of what is meant by â€Å"on the faith of the receipt†. Payments on the faith of the receipt meant that they would not have been made unless the receipts had been recognised as valid. Just because there was the element of dishonesty of Mr Cincotta which also was the occasion for the withdrawal of funds, this did not negate the causal connection between the receipt and the payments. The change of position remain causally linked to the receipt. Thus while the test seems to involve a causation element, this is not a but for test but rather that the payments of the money were caused or linked to the receipt of payments from the plaintiff. ANTICIPATORY EXPENDITURE – DOES IT COUNT? * Can a defendant be said to rely on the faith the receipt when there is anticipatory expenditure on the part of the defendant? * Can reliance be understood as something other than an essentially causal concept where the effect of the defendant’s expenditure follows the cause which is the defendant’s receipt of the enrichment? Or does it mean that the defendant can be said to have acted on the faith of the receipt where it had a reasonable expectation of receipt? * In the case of Dextra Bank, Dextra Bank drew a cheque on its bankers, Royal Bank of Canada in favour of the Bank of Jamaica.Dextra drew its cheque intending to lend the sum spe cified to the Bank of Jamaica against the security of a promissory note executed by the Bank of Jamaica. The Bank of Jamaica intended to buy the specified sum of US dollars in exchange for the equivalent in Jamaican dollars which it paid to individuals understood to be nominated by Dextra. Dextra sued BOJ for restitution of the moneys paid. BOJ claimed that it had the defence of change of position. However Dextra argued that BOJ was relying on actions performed by BOJ before it received the benefit from Dextra and this amounted to anticipatory reliance which could not amount to a change of position. The issue was thus whether anticipatory reliance on the plaintiff’s payment can amount to expenditure on the faith of the benefit of the payment and thus whether an effective change of position defence can be made out. * It was held that it is no less inequitable to require a defendant to make restitution in full when he has bona fide changes his position in the expectation of rec eiving a benefit which he in fact receives, than it is when he has done so after having received the benefit.The court thus held that there should be no effect on the availability of the change of position defence whether the payment is made when the benefit is received or on a reasonable expectation that it is to be received. Anticipatory expenditure can be recognised as payments made on the faith of the benefit of the receipt. This was also recognised in South Tyneside v Svenska Internation where the court held that it does not follow that the defence of change of position can never succeed where the alleged change occurs before the receipt of money, as seen from the facts of Lipkin Gorman where the defence succeeded despite the winning being paid out before getting other gambling bets in. * In Commerzbank, the court held that the relevant question in whether the change of position defence would succeed was whether his decision to change his position was caused or contributed to b y the receipt of the payment. The crucial point the courts have emphasised is the causal relationship between the detriment and the receipt and not the strict when the detriment and the receipt or occurred. 4) In good faith * The defence is not open to a recipient who had changed his position in bad faith as where the defendant has paid away the money with knowledge of the facts entitling the plaintiff to restitution (Lipkin Gorman) * What is crucial to the good faith element is whether the payee had actual knowledge of all the facts constituting the wrongdoing or else had knowledge of such facts as would reasonably raise a suspicion of wrongdoing so that the payee was put on enquiry (Mercedes-Benz v National Mutual Royal Savings Bank Ltd) * Does a person act in good faith unless he acts dishonestly? (Niru) * NO. A person can act in bad faith where the recipient knows that the payer had paid the money to him as result of a mistake of fact or mistake of law and it will in generally b e unconscionable or inequitable to refuse restitution. Just because he is not guilty of dishonesty does not make him innocent. Will knowledge of the mistake bar the defence? * Waitaki- mere knowledge of the fact that the money is not due probably doesn’t bar the defence if d acts reasonably: d knew that the money was not its money to keep and in fact put the money on deposit, ready to repay. D was allowed the defence (albeit partially) when the money was lost through the collapse of the company with whom the sum had been deposited, even though it knew about the mistake when it put the money on deposit. * Lipkin Gorman: In cases where the payee had grounds for believing that the payment may have been made by mistake but cannot be sure, good faith may well dictate that an enquiry be made of the payer.The nature and extent of the enquiry called will of course depend on the circumstances of the case but I do not think that a person who has good reason to believe that the payment was made by mistake will often be found to have acted in good faith if he pays the money away without first making enquiries of the person from whom he received it. * English courts to date appear generally more relaxed about defendant fault, although they have tended to be thinking about fault with regard to the initial receipt of the money (â€Å"should defendant have known about the error†? ), as opposed to fault with regard to what is then done with it. * Whether fault is relevant to good faith? * In both Dextra and Niru, the CA aid that the defendant will only be denied the defence if he was in bad faith when paying away the money * The way the CA in Niru defines bad faith actually comes quite close to a negligence standard – acting in a â€Å"commercially unacceptable way† or with â€Å"sharp practice falling short of outright dishonesty†. If negligence in not realising the mistake is insufficient to bar the defence, then it seems unlikely that negl igence in a decision about how to dispose of the money will be. Also, it would seem strange if a good faith payment to charity could give rise to the defence, but a good faith (but negligent) investment couldn’t? * A different approach is taken in NZ . In Waitaki, fault is relevant. The facts are that the defendant received 50,000. He takes the money and puts it into an investment with the finance company which eventually goes under.The bank then realises they paid him the money under mistake and sue him. * The defendant had relied on the receipt because the bank had forced him to take it. However he had never thought it was valid. The court held that the defendant had partly been at fault in the ultimate loss of the enrichment because he had chosen an insecure investment. Where defendant failed to obtain sufficient security for a risky investment, he had defence reduced by 10%. This introduces the uncertainties of the â€Å"contributory negligence† model of COP, which requires a relative balancing of the fault of p and d in proportioning the amount repayable. The approach was expressly rejected in Dextra as being â€Å"hopelessly unstable†.DEFENDANT WHO ILLEGALLY CHANGES HIS POSITION AS A WRONGDOER * Recently suggested that a defendant who changes position illegally is a ‘wrongdoer’ cannot invoke the defence (Barros Mattos) * The recent case of Barros Mattos now indicates this is highly likely to be the case. In reaching this conclusion, Laddie J drew support from Lord Goff’s ‘wrongdoer’ limitation in Lipkin Gorman: this indicates that defendant can be disqualified from the defence either because of his knowledge of the claimant’s rights before changing his position, or because the change of position itself is â€Å"wrongful†. * Should this affect civil wrongs? This result does not specifically affect restitution for wrongs, since civil wrongs are not considered illegal as such.Despite the co ncept of ‘illegality’ by its very nature being hard to define, it is clear from both Tinsley v Milligan [1994] 1 AC 340 and Nelson v Nelson (1995) 184 CLR 538 that it relates to claims which would run seriously counter to public policy. In Lipkin, Goff suggested that COP should not be open to wrongdoers, but it is not clear that he was referring to those guilty of an innocent breach of duty. DEFENDANT WHO INDUCES THE MISTAKEN PAYMENT IN THE FIRST PLACE * Deliberate: No defence- Goff in Lipkin Gorman- defendant will be in bad faith and bad faith precludes reference to the defence. Note that it is assumed in Niru that dishonesty is sufficient to amount to bad faith, even if it is not always necessary.It is clear from Niru that dishonesty amounts to bad faith, even if defendant can sometimes be in bad faith even where there is no actual dishonesty. * Negligent: No clear authority on this. Defence probably still available, but not if it amounts to â€Å"bad faith† as defined recently in Niru. There, defendant was denied defence on the basis that it had documents in its hands which were forgeries, which it ought to have realised might be forgeries and into which it had failed to make reasonable inquiries. This amounted to failure to act in a â€Å"commercially acceptable† way, tantamount to bad faith and denying the defendant access to the defence, even though defendant was not dishonest in the sense of appreciating the risk of fraud.It is arguable that in the light of Niru, plaintiff would be in a strong position to argue that the defence should be denied to defendant here on the grounds that defendant’s inducement was not â€Å"commercially acceptable† behaviour. * Innocent: Defence probably still applicable, since, if inducement was â€Å"innocent† in the sense of being non-negligent, it might be commercially acceptable behaviour, as per Niru. DOES THE DEFENCE ACT AS A COMPLETE DEFENCE? * No it can apply pro tanto. (Australian Financial Services & Leasing Pty Ltd v Hills Industries) * Meaning you give back to the extent of what you still have. * How does this compare with estoppel? * Estoppel by representation remains available as a total defence to restitutionary claims even in circumstances in which the defence of change of position is available.Properly understood, it does not undermine the defence of change of position as they are based on different elements. In estoppel, one had to prove representation and detrimental reliance. Whether one can plead estoppel however depends on how equitable it is for to make such a claim to the overpayment received. In TRA Global, the court held that equity may intervene to prevent the latter’s unconscientious assertion in certain circumstances. It may be inequitable to assert a full defence of estoppel when you are overpaid 1000 and remain in possession of 500 which was mistakenly paid to you. * Under a defence of change of position, your ent itlement will be 500. |

Intro to Chicano Studies

David E. Dominguez April 21, 2013 ECC RM 169 Introduction to Chicano Studies Midterm Have you ever noticed the numerous similarities between you and your peers? No? Perhaps the way you speak upon one another, the tone, maybe the diction, or even the syntax of your voice can all be apart of ones culture. However, communication is only one of the very many key elements when taking in and digesting the term, ‘Culture’ along with its eclectic and widespread meaning.Now, when I say, â€Å"take in and digest†, I simply am referring to act of embracing and understanding the complete meaning of the word and its effect on our everyday life. Many professionals such as Anthropologist, Doctors, Psychologist, Economist and many more Scientist have their own definition of what culture may be, as well as your regular neighbors, classmates, co-workers, and even teachers. So why is this measly word so important?Well figure this, there is only one race everything else is culture, h ere in the United States of America we are what is defined as a multi-cultural society, nationwide. This means that within our country resign many different ways of life, entertainment, appearance, language, social classes, and even many deaths due to disease, thus resulting in a grand amount of what are called cultural clashes.Categorized as conscious and unconscious, these confrontations have an enormous effect on our civilization. Culture is an essential part of conflict and conflict resolution. Cultures are like underground rivers that run through our lives and relationships, giving us messages that shape our perceptions, attributions, judgments, and ideas of self and other. Though cultures are powerful, they are often unconscious, influencing conflict and attempts to resolve conflict in imperceptible ways.In other words, there are many circumstances in which these types of conflicts are in a sense, uncontrollable, meaning our regulatory system of life may have been pre-judged, now bare with me here, to my understanding due to my research, cultures are more than language, dress, and food customs. Cultural groups may share race, ethnicity, or nationality, but they also arise from cleavages of generation, socioeconomic class, sexual orientation, ability and disability, political and religious affiliation, language, and gender- nd this just to call upon a few. There are also very many theories to this term, culture. For example, The Resource Pot defines culture as mutual adaption of diversity in life, also as respect and celebrated diversity. On the other hand, the concept and theory of The Salad Bowl reveals another meaning to culture, such as acculturation, acculturation is when two or more cultures come into psychological, physical, or even environmental contact and begin to alter their original customs to further adapt to that in which they have discovered.This theory also reads that this part of culture is â€Å"color blind†, not literally of cour se but symbolically, towards race and ethnicity. Lastly there is the theory of The Melting Pot, which is a more assertive and aggressive form of acculturation, in which the dominant of the two cultures will succeed and overthrow, if you will. This particular theory also portrays the word Ethnocentrism. This is the act of judging ones culture based upon your own cultures’ ways and or beliefs.Emic and Etic are terms used by anthropologists and other social scientists referring to two different types of data collected on human behavior. Often used by cultural anthropologists, an â€Å"emic† point of view is one where the analysis of behavioral and cultural systems is defined in terms that are meaningful to the individual who is a participant within that culture, also known as an â€Å"insider's view†. The emic perspective arises from the participant of the culture being observed.Now, the Etic point of view is which comes from the â€Å"outsiders† of the part icular culture in which is being observed. In a comparison, the Etic perspective is used if the representations are in accord with scientific observers. The etic perspective employs a more logical, analytical and anthropological analysis of one who does not participate in the cultural that is being observed. However, despite any differences between these two perspectives, and due to my educational research, anthropologists agree that any ethnographic work ought to be represented using both the emic and etic views.To fully understand a culture, anthropologists must be able to understand the culture empathetically and scientifically. The two approaches build off one another and allow for a wider understanding of culture. Also, there are many elements in which may influence ones social and personal behaviors/identity as well as their mentality and psychological judgment or comprehension. Just to point out a few- life experiences, environment, personal choices, and Adversity†¦ erso nally, I believe you have to give back to those more in need to fully understand who you are as a person, in today’s society it is a â€Å"give me all about me† society and the more you give the more you gain as an individual and the more you grow and develop your own genuine not manufactured characteristics. Yes, I said manufactured characteristics, believe it or not but people are many times shaped and formed into who they are due to what they watch or see on the television screen or from what they hear on the radio stations, even within our children, its an epidemic.The mentality of the youth in any community as well as anywhere else across the globe, is very gullible and vulnerable. For instance, I observe the television shows on the Disney Channel that my four year old, soon to be five year old little sister watches, and I have learned that in each showing there is constant affectionate and loving relationships between young boys and girls. Now although it is port rayed as humor and may seem completely innocent, it makes me wonder how this will effect my baby in the future, along with the sexual and intimate lyrics played both on the radio stations and at home.I feel that the media contributes to the epidemic of pregnancy in young women now a days. That is just one personal opinion of observation from my perspective as an older brother as well as a young Chicano. I have come across these connections between Disney Channel’s young affairs, the radio stations, and the epidemic of pregnancy through my own personal experiences and visualizations of the youth in my family and across the city. My theory goes on much more into depth but lets stay on topic.The media is only another element in which may influence ones identity; another involves the environment, the habitat, and the beings all around the individual. When we enter the world we enter naked physically, socially, and culturally. Unlike other living creatures humans need social exper ience to learn their culture and survive. Only humans rely on culture rather than instincts to ensure the survival of their kind. The natural thing to humans is to create culture. Culture has to be learned it is not apart of a biological make up; but our biological make up makes culture possible.We as humans do not inherit habits and beliefs we acquire them during the course of social experiences. We come into this life without a language, social class, values, morals, religion, race, we do not even know how to love or hate. It is through human contact that people learn to become members of the human community. Culture is the values, beliefs, behaviors, and materials that form the way of life for humans. Culture interprets our surroundings for us and gives us meaning and allows us to express ourselves.To learn any culture is to learn a person’s values, ideas and of what is desirable in life. Values underline or preferences, guides or choices, indicate what we hold worthwhile in life. Values help define the character of a culture, but it does not provide specific courses of actions. Without any morals or values in life there is no culture, and once again, without culture what is life? What is the point of life without Culture? Without Culture life would be meaningless and boring, I think it is an extraordinary craft to learn ones culture who differs from you.

The Four Methods in Lincoln Electric Case Study

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Discussion Question - Essay Example In some occasions, family and friends who visited these patients would participate in the prayer sessions. The three patients, who were all Christians, engaged in prayer to get the necessary spiritual strength to deal with the pain and other limitations caused by the disease. These prayers attracted other Christians within the ward, who were suffering from different diseases. These prayers usually helped the patients deal with the pain, and trust God for their healing. The activity was well-received by other Christians in the ward, but there was some resistance from the Muslims. This came from the different beliefs and praying times followed by the Muslim believers. The Christians would pray in the morning and evening, while Muslims pray three times in a day. The Muslim prayers follow a predefined format whereas Christians do not follow given prayer format. This forced the Muslims to engage in their prayers separately from Christians. However, they were free to join the Christians, and some were involved in the Christian prayer. Patients require spiritual support from nurses, who can participate in their spiritual practices or reinforce their spiritual

Research and academic review related to the strategic importance of Essay

Research and academic review related to the strategic importance of knowledge and the different approaches organisations take to - Essay Example Knowledge and Information Knowledge generally refers to the practical use of information. On the other hand, information refers to the general data expresses by words, images, sounds and number. Information can be shared, stored or transported. On the other hand, knowledge does not have these characteristics. Global retail industry has been considered for the study in order to determine the importance of knowledge in the business process of several organizations within the industry. Only gathering information about advanced process or a new process cannot help an individual or an organization to get success through it. The organizations need to significant level of expertise and knowledge how to implement these applications or tools (Schnedlitz, Morschett and Rudolph, 2010, p.109). It is true that knowledge as opposed to information has become the competitive driver over recent years. Global retail industry has become highly competitive due to the presence of several leading organiza tions. Organizations like Tesco, Walmart, Morrison’s, Sainsbury and others are trying to implement significant strategies in the business process to ensure positive business growth. ... It is true that information about some business tools and strategies help the organizations to think about further strategy development process. But, knowledge about these tools and achieved information can help the organization to make effective decisions that will ensure organizational goal. Knowledge as key source of wealth Earlier, capital, land and labour were considered as the source of wealth and business profit. Now-a-days, knowledge is considered as source of wealth for several business organizations. The major challenge of the knowledge based economy is to ensure and foster innovation. Several leading organizations within the retail industry are trying to capitalize on the potential opportunities that have been created due to globalization and technological revolution (Varley, 2013, p.19). It is true that organizations can adopt and implement advanced technological process in business operation but, cannot get success without effective knowledge about the implementation pro cess. Several leading and popular retail chains around the globe are trying to implement advanced technology in each and every business function, such as manufacturing, logistics and supply chain, finance and human resource management. Competitive success is based on how strategically the organizations intellectually manage the capital. Effective knowledge management is considered as an important strategic instrument. The organizations within the retail industry are implementing differentiated technical instruments to enhance business process. It is true that implementation of advanced technology in logistics and supply chain management helps the leading retail chains to reduce business operation time and cost

Contemporary Marketing Practice Essay Example | Topics and Well Written Essays - 2250 words

Contemporary Marketing Practice - Essay Example It is common to hear among the consumers that they are not subjects to marketing strategies. Most consumers never want to admit that advertisements have immense influence on their tastes and preferences as far as purchases are concerned. The researcher states that the concern on this essay is whether in reality this freedom is exercised or customer’s tastes are subject to marketer’s strategies. This study involves the issues of advertisement in relation to increase of obesity in the society. The paper is generally a review of various literatures. In conducting the study, the researcher explored a number of books, magazines and website articles on the relationship between obesity and advertisements. To ensure that the ideas are not from the same school of thoughts, this study involved experts from diversified fields, among them being nutritionists, educators, critical analysts, scholars and healthcares providers. One thing that was very common in all these sources is tha t adverts influences the decision making of the consumers, who tend to buy the products, despite their harmful effects on their bodies. The study drew much information from previous studies, particularly from published online books. In conducting the study, the researcher also explored the advertisement strategies of some prominent companies such as Unilever, Coca-cola, Kraft Foods, PepsiCo, Nestle, General Mills, Kellogg Co. and ConAgra Foods, all of which had one common feature - they all use a significant amount from their coffer in advertisements.

Discount Pricing - Prices in a slow economy Article

Discount Pricing - Prices in a slow economy - Article Example A survey conducted from Henry H. Harteveldt represented that companies are trying to cut down on their business travelling budget and are very strictly and cautiously making decisions regarding air travel for business (MOUAWAD, 2012). This article relates to the course because the course is about pricing decision making, in pricing decision making the companies such as the airline companies have to decide whether or not to increase prices and what activities can be done in order to attract more customers. This decision can not be made by the companies until and unless they take the decision making of the travelers and consumers in their analysis. Their analysis will show that the consumers do not have confidence in the economy and they are spending money very cautiously, they are trying to save every penny in order to ensure profits and to remain safe from going out of business. MOUAWAD, JAD. "Business Travel Is Rising, but Not Necessarily the Travel Budget - NYTimes.com." The New York Times - Breaking News, World News & Multimedia. N.p., n.d. Web. 5 Oct. 2012.

WEIGHT WATCHERS AND JENNY CRAIG Essay Example for Free

WEIGHT WATCHERS AND JENNY CRAIG Essay Weight Watchers and Jenny Craig Millions of people have lost weight using the Weight Watchers and Jenny Craig weight loss programs. Weight Watchers and Jenny Craig are two of the most popular diets in the United States that has similar weight loss options available for would be dieters. Among other popular diets, U.S. news ranks Weight Watchers #1 in best weight loss diets and ranked Jenny Craig #2 . In 2010 Weight Watchers retired its old point system and started a new point system. With the new system, counselors will know if their clients are using their points wisely. With Jenny Craig there is no point counting. There method is a three level food, mind, and body approach to lose weight and keep it off. Although, their approach to weight loss is different, both Weight Watchers and Jenny Craig claims clients can lose up to two pounds a week. No diet is easy, but Weight Watchers and Jenny Craig both have their perks to make dieting easier. With the Weight Watchers program, dieters are allowed to eat whatever they want if a client uses their points wisely, along with eating foods containing protein and high in fiber. Clients can also eat unlimited fruits and vegetables. Dieters are also encouraged to eat â€Å"power foods†, such as whole grains, lean meats, and low fat dairy products. Weight Watchers encourages their clients to choose foods rich in nutrients, but not loaded with calories. That is Weight Watchers primary goal, to give their dieters the weight loss edge. Weight Watchers has improved its plan to incorporate today’s science along with a proven to work formula for their clients. The key to having success on the Weight Watchers diet program, is to eat healthy filling foods. With Jenny Craig, clients get a personalized meal and exercise plan, plus weekly counseling sessions with a consultant. Your meals are pre-packaged and delivered to your door. Jenny Craig meal portions are small. You will eat three times a day and dinner comes with a dessert. The program teaches their clients how to eat small frequent portions. It also teaches their clients how to increase their energy levels. Jenny Craig also teaches its clients how to b alance their lives to maintain their weight loss. The program offers support for its clients with a 24 hour support line. Just like its counterpart Weight Watchers, Jenny Craig encourages eating fruits and vegetables, whole grains, and reduced fat dairy products. Jenny Craig’s pre-packaged menu serves as a  model of healthy eating, clients will gradually learn how to cook at home for themselves. Since the Jenny Craig method is calorie based, a client will develop a menu based on their weight, height, and goals. With Jenny Craig recognizing the correct portion size is the first step to weight loss. When choosing diet programs, a person should take certain issues into consideration before starting that program. Even though Weight Watchers have revitalized their point counting method, it is still very tedious. After a long day at work, a person may not feel like tallying points. Cooking a pre-packaged Jenny Craig meal in the microwave may be much easier. The Achilles heel for the Jenny Craig diet, is you are not allowed any ho me cooked or restaurant meals until you are ready. The cost is something else to consider when deciding between these two programs. With Weight Watchers, the cost will vary depending on if you choose weekly in person meetings or using online tools only. They offer unlimited meeting passes for $39.95, which also includes access to the online tools, or a person can pay as they go, which will range from $12 to $15 per week and a one- time registration fee of $20. To follow online only, a three month plan is $65. Keep in mind none of these fees includes the cost of food. There is no way to water it down, Jenny Craig is expensive. The exact cost will vary from city to city. The registration fee can exceed $400, and one week’s worth of Jenny’s cuisine can cost a person $100 at the least. The average person cannot afford this diet program, and for that kind of money may devise their own diet plan that will save them money. Both of these programs can be pricey, and the last thing that a person on a diet should be worried about is money. Maybe, that is why Weight Watchers and Jenny Craig use celebrity endorsers, their clientele may mostly be made up of people consisting of the upper-middle class or rich. They are both known for their use of celebrity endorsers, but have different views on how they should be used. For Weight Watchers, collecting celebrity spokespeople is not their way. Jenny Craig on the other hand, is pursuing any celebrity that wants to lose weight. Weight Watchers has had only four celebrity endorsers, with Jennifer Hudson as the fourth. Jennifer Hudson has lost 80 pounds on the Weight Watchers plan. Jenny Craig employs six active spokespeople, including Valerie Bertinelli who has lost 40 pounds on the program. These two diet programs has their similarities and their differences. It all depends on  what the dieter feel is right for them. It may also depend on what the dieter can afford. Weight Watchers focuses on teaching their clients how to eat wisely and how to keep the weight off. While, Jenny Craig focuses on an individual approach to weight loss and portion control. Both guarantees weight loss and entices would be dieters with celebrities and their weight l oss stories. Weight Watchers and Jenny Craig, both disagree on how celebrity endorsers should be used, but continue to use their celebrity endorsers because of their popularity. A dieter should keep in mind that results will vary and they may not have the same results as Jennifer Hudson or Valerie Bertinelli. Weight Watchers and Jenny Craig are considered to be the two most popular diets in the U.S. Jenny Craig appears to be expensive, but the more simple approach to weight loss, while Weight Watchers is less expensive, but requires strict point counting. Your schedule, way of life, and budget may be the deciding factors between the two. Single less obligated people may go with Weight Watchers, while busy family orientated individuals may choose Jenny Craig. The choice is yours.

Motives, Triggers And Barriers To Internationalization

Motives, Triggers And Barriers To Internationalization In general, internationalization occurs when the company expand its business activities into foreign markets. There might be several reasons for this. Of course, the most frequent reason is to expand profits, but this is not the only one. The motives and triggers for internationalization are a key concept for firms that are planning to enter the global market since both concepts will shape the internationalization strategy or path (Äijà ¶ et al) and main characteristics of this process. Table 2 and Table 3 present the main motives and triggers. If the main reason to start exporting is to increase profits and growth, the potential new markets will be those where the competition is less fierce and margins can be set on a higher level. If the goal is to reduce costs by expanding the economies of scale, the target countries might be anyone, independent of the profit level that the company can achieve there as long as there are positive. If the fierce competition in the local market is the driver to star exporting, then the foreign market will be determined as a defensive strategy mainly by forces external to the firm. Another crucial concept is the barriers hindering the export initiation. If any one of this factors or a combination of them is available in the firms context, it may hold back the internationalization of the firm for a long period or even forever. According to Hollensen (2008), the critical factors hindering internationalization initiation are mainly internal. Table 4 summarizes these barriers. In the Day Chocolate case, and based on the general information analysed and on the company history, it will be assumed that the primary motive to start the internationalization process is to increase profits and to grow in revenue. In addition, some foreign market opportunities could be considered as a motive. On the other hand, Competitive Pressure as a reactive motive could also have been stated, but it does not seem the main one according to the information analysed. The Day Chocolate is a small company and usually the firms that react to competitive pressures are larger than they are. Furthermore, Days revenue and market share are increasing according to companies figures, so the competitive pressure is not really a problem yet. The rest of the motives in Table 2 were discarded after a careful examination. The main trigger found in the The Day Chocolate case can be the Perceptive management. The company management is highly professional, includes people with many different backgrounds and the fact that the headquarters are in London -a well known international financial and trade centre- provides another good reason to support this interpretation. The second trigger might be the Importing as inward internationalization. Although the products and the headquarters are I the United Kingdom, the production facilities are located in Germany and the final product is exported from there to the U.K., according to the BBC[19]. The knowledge accumulated by importing the product from one European country to England can be used to make easy the export process to any other European nation. In order to be able to answer the question regarding to which country they should go (export or invest in) it is assumed that no barriers hindering the export initiation exists or that if they exist, they are preventable at an affordable cost. It can also be assumed that these barriers will not stop the internationalization of the firm but rather slow the velocity at which the company expands abroad. 2.5.2. Strategic approach to internationalization Once it has become clear that the firm can, needs or wants to export or expand their operations abroad, there is a need of knowing how and where to go. In order to answer these questions it is necessary to have a framework to guide the analysis. For The Day Chocolate case the guidebook presented in Internationalization Handbook by Äijà ¶ (Äijà ¶ et al. 2005) was the most appropriated. This structure is presented in Figure 5. According to Äijà ¶ the first part (Part I) in Figure 5 is the selection of the appropriate Internationalization Path. In his book, he presents three typical pathways that the internationalization process of a software firm may take, but his steps and conclusions can also be expand to any firm in the confectionery market like Days chocolate. This area under discussion is also the same as the one that Hollensen refers as Internationalization theories or models in the third chapter of his book Essentials of Global Marketing. For the purpose of this work, the 3 pathways presented by Äijà ¶ can also be increase with the many other presented by Hollensen. Among many models, paths or theories, the most well known are the one presented in Table 5. Based on Days corporate webpage statistics and from private sector publications[20], like Tranchell Doherty, it can be assumed that the company started it internationalization process by choosing an Organic growth path. The timeline on the firms webpage confirms that Devines management decided to begin their operations abroad in markets that are very close in location but also in culture and institutions like the United States and that the internationalization process has been taking place in small but incremental steps. The size of the company and the market where it operates also support this view. In contrast with what happens with large companies, where the internationalization process happens in a relatively continuous and incremental fashion, for SMEs (like The Day Chocolate) in general this process is made in small incremental steps. According to Hollensen, usually for SMEs the internationalization process is relatively discrete and every project is distinct and individual. The fact that the company operates in the confectionery industry and not in the IT sector, among other facts, is also a good reason for not considering this firm chocolate as a born global company. Freeman (2002) also states that for Small and Medium Enterprises managers tend to gather and look for relevant knowledge and information before becoming internationalization ready, which is consistent with Devines history and with the Uppsala model[21]. In 2007, the company took the next step in its internationalization process by setting a foot in the United States market by opening offices there. According to Johanson, and Wiedersheim-Paul (1975) that would have constituted the third stage. 2.5.3. The country choice Once the company has determined the path for internalization, its management needs to start the potential markets selection process (Part II in figure x.1). To address this problem, the screening process detailed in Rugman and Collinson (1995) will be used. 2.5.3.1. First screening: determining what product to offer to the world market This first screening is crucial in determining the potential of the companys goods in markets other than the local. This task can be carried on successfully by using a wide number of market research tools. International trade statistics inspection, competitors financial information analysis and research papers or databases that are offered by international multilateral organizations like FAO, the World Bank and the IMF could be valuable tools as well. In general, chocolate confectionery is offered in all almost the countries of the world. In this sense, initially there are a large number of potential countries where to choose from. However, in this case, the company is selling a very specific product (high quality + socially friendly chocolate) that limits the scope of this first screening. One drawback when dealing with this kind of specific and one-in-a-kind characterized goods is the lack of information or the excessive cost of getting it. A first measure to identify the potential foreign markets for The Day Chocolate would be analysing the world trade evolution of Fair-Trade products. That might help the firms management in recognizing the most active markets for this kind of products. As it is shown in Table 6 and according to the Fairtrade Labelling Organizations (FLO) in 2009 they were many countries showing a dynamic market for this kind of products. Among them, it is necessary to highlight Canada, Finland, Australia and New Zealand where the surge in the transactions was higher that 65% in the first case and about 60% in the other tree cases. Other nations with a remarkable performance were Spain, the Netherlands, Belgium, Germany, Ireland and Sweden. Although the U.K. and the United States presented a performance below the average growth rate of 15%, it is necessary to state that they are still by far the most important markets in volume for organic and fair-traded goods. Regarding the specific case of this companys main product, a NGO -TransFair USA- declare that during 2008 the imports of fair-trade certified cocoa into the U.S. rose at rates of more than 50%.[22] Finally, the genuine potential of every market will be ultimately determined by the interaction with other factors such as socio cultural forces and economic conditions. 2.5.3.2. Second screening: Macroeconomic and financial conditions The last World Economic Outlook report from the International monetary Fund (IMF)[23] clearly shows what to expect for the upcoming years. The developed countries GDP will grow on average 2,5% in 2011, still trying to recover from 2007s financial crisis. The U.S., Germany, and the U.K, together with some developed Asian countries such as South Korea will be presenting above average growth rates. However, some countries like Spain, Italy and France will show a growth rate between 0% and 1%. On the other hand, developing nations are expected to growth on average 6,5%, with Developing Asia and Latin America leading among these regions. From a macroeconomic point of view, the next years are going to be very good ones for most of the developing countries and also for some developed nations. For the purpose of this document, the countries will be segmented in four categories, considering that The Day Chocolate should focus in the short run on those that are not experiencing a recession. Table 7 contains this information. However, the product that they are offering is not a cheap one. It is a premium product and usually the prices are above the average. In this context, the income levels of the consumers are also an important factor to be considered. This is what Rugman Collinson (1995) called the Market intensity. Figure 6 shows the relation between the per capita income level for all developed countries and the expected GDP growth for 2011. As it is shown, there are 1 group that is more desirable for the company. The second quadrant comprises all countries showing both very high income level and high expected level of economic activity. However, the companys management might find also attractive potential markets in countries that do not have a very high level of per capita income, but whichs economies are growing very fast (Quadrant 4). 2.5.3.3. Third screening: Political and Legal forces This step covers the examination of the political and legal forces in every potential market. There might be trade barriers that obstruct the export process or the lack of solid institutions can represent a serious risk in the form of the future losses. One way to detect this serious problems is by addressing to the World Economic Forums (WEF) Global Competitiveness Index (GCI)[24]. This index includes a weighted average of several different components, each one of them measuring a diverse feature of the competitiveness. Those components are grouped into 12 categories or pillars. The first one of these pillars is Institutions. The GCI is calculated for 140 countries and the results are available free of charge. Table 8 presents the most important variables and their weight within the first pillar: Institutions. Table 9 provides some of the results obtained by the WEFs researchers for the 2010/11 index[25]. There it can be seen that the countries with the most stable or trustworthy are in general also those with a higher level of economic development. 2.5.3.4. Forth screening: socio-cultural forces A multinational corporation or a company desiring to become one should examine the main social and cultural disparities between the potential market and the home country. The concepts of cultural distance and psychological distance as presented in Hollensen (2008) have the potential of disturbing the normal flow between the foreign market and the company. Language, religion, work habits, ethnicity, age and many other socio-cultural factors may influence the decision regarding where to locate the operations. Maps 1 and 2 illustrate this theory by presenting the world distribution of the main religions and of the English speaking nations. For The Day Chocolate to avoid problems generated by cultural distance it will be recommended to establish operations or to export to anglo-saxon countries, like former British colonies or commonthwealth nations. Other european nations, specially those from German and Nordic origins, might be suitable in this first stage of internationalization. In a future stage, and after reducing these distances by means of the learning process, the firm might also attempt to gain a foot in more culturally distant markets. Focus groups activities and consumer surveys can help the firm in determining the main differences and similarities between the foreign market and the headquarters values and culture. 2.5.3.5. Fifth screening: Competitive enviroment This last stage of the analysis focuses on the competitive forces. Confronted with comparable and equally desirable potential markets, the firms tend to internationalize to those where the competition is less ferocious. The lack of competition can provide the company with some degree of monopolistic power that might have the power to increase the earnings. In the case analyzed, there were detected many new actors entering into the market in the last years, also some big players in the industry like Nestle and Cadbury are making efforts to tap this fast growing segment[26]. Despite these facts, competition is still not a barrier in most of the national markets analysed. Special attention should be paid to Germany, Switzerland and Austria, where several small and medium local producers have a long lasting tradition manufacturing chocolate products of world recognized quality[27]. 2.5.3.6. Final selection According to The Day Chocolates website, the firm currently operates in 11 markets. In the U.K.[28] and in the United States, the company has direct control over its business. In the rest of the countries, they rely on other companies, which are in charge of the distribution channels (Canada, Norway, Sweden, Netherlands, Denmark, Slovakia, Czech Republic and Japan). Trough the screening process and its five stages many countries were considered as potential new markets: Finland, Australia, New Zealand, Belgium, South Korea, Germany, Switzerland and Romania. Germany and Switzerland were discarded mainly because of the competitive environment and in second place because some possible cultural distance. South Korea was finally not considered fundamentally because the huge cultural distance and also because the physical distance. Due to the market size and growth projections, the chocolate per capita consumption[29], the similarities in the socio-cultural environments, the reliable legal and political framework, the expected friendly competitive context this document concludes that The Day Chocolates management should make an effort to analyse in more detail the potential of the following new markets: Australia, Finland, Belgium and New Zealand.

International Relations Essays Global Culture

International Relations Essays Global Culture What is meant by a global culture and how and why do transnational corporations seek to promote such a culture? A global culture can be seen in one of two ways. One suggests that today’s communications and technologies allow a more open spread of culture around the world – people in far corners of the globe are able to be aware of and share each others culture. It is a view that sees global culture as generally positive – something that encourages diversity and a mixing of culture and has enabled people around the world to overcome national boundaries to embrace common causes. The more common perception of global culture is that of a Western, predominantly American culture gradually imposing itself around the world, often to the detriment of long established local cultures. For analysts opposed to globalisation this type of global culture is slowly killing diversity and devastating traditional ways of life. Scholte suggests that this viewpoint is that: â€Å"Globalisation introduces a single world culture centred on consumerism, mass media, Americana and the English language† (p23 Scholte 2000). It is this type of global culture in particular that transnational companies are linked to and are generally happy to promote. Transnational companies have become economic superpowers as globalisation has spread and the development of a global culture is seen to benefit them economically. Certainly the potential wealth that the transnationals can offer to indigenous populations can take precedence over the upholding of local tradition and culture. The basic human desire to accumulate wealth can often override cultural, ethnic and religious factors when transnational companies set their sights on economic expansion in a particular area. A global culture involves the spread of popular cultural icons around the globe, often diluting and overriding local cultures with the threat that the vast cultural diversity that the world offers will one day be submerged beneath a dull uniformity. Advances in technology and communications have helped propagate cultural globalisation. Digital communication, satellite television and the Internet are methods of communication that can overcome any national boundaries or government control – as Held and McGrew write: â€Å"Many national controls over information have become ineffective. People everywhere are exposed to the values of other cultures as never before† (p17, Held and McGrew 2003). Deregulation of media ownership along with technological advances combined in the latter decades of the twentieth century to allow the largest media companies to establish networks in many countries. This media influence gives companies the opportunity to promote their own cultural preferences and it is notable that the global media is dominated by the same eight transnational media companies that dominate the US media: General Electric, ATT Media, Disney, Time Warner, Sony, News Corporation, Viacom Seagram and Bertelsmann (p261 Held and McGrew 2003). These companies aggressively seek to become global players – the US market is largely developed and the global markets provide better opportunities for expansion and getting ahead of the competition – Time Warner predict that non-US sales will yield the majority of their revenue within the next decade. With the global expansion of US media companies comes the global expansion of US culture. The power of Hollywood is one of the prime examples of cultural globalisation with an American agenda. A seemingly endless line of films promoting an American cultural and political agenda emanate from Hollywood and have driven independent film making in many regions either out of business or underground. Some countries such as Norway, Mexico and South Africa have seen government subsidies try to support domestic film production companies, whilst the success of the Indian ‘Bollywood’ film industry is one of few examples of cinema audiences resisting the spread of a global culture. The economic benefits to the transnationals can be huge. Cable and digital television channels across the globe are owned by the major transnational companies and are hugely important parts of their revenue streams. Major Hollywood studios were expecting revenue from global TV rights to their film librarie s to have exceeded $11 billion by the end of 2002 (p261 Held and McGrew 2003). The marketing power of the transnational companies ensures that the values, brands and culture of the US are spread globally. Some of the largest brands generate money that outstrips many national economies – Coca Cola’s brand for example was estimates by a brand consultancy to be worth $68.9 billion. (p119 Legrain 2002) The continuing expansion of such brands through the development of a global culture is something certain to boost the profits of the transnationals. Writers on globalisation such as Naomi Klein in particular link brands to global culture and the influence of the transnationals. She writes: â€Å"Power, for a brand-driven company, is not attained by collecting assets per se, but by projecting one’s brand idea onto as many surfaces of the culture as possible†¦Ã¢â‚¬  (New Statesman 24 Jan 2000). This view of those opposed to globalisations suggests that propelling popular cultural icons into established cultures and forcing homogenous culture to take a back seat to Western culture is very much the aim of transnational companies.   Certainly, the marginalisation and dilution of local cultures through the efforts of Western media and brand marketing is a concern. Lloyd Fernando writes ominously: â€Å"The world is truly eclectic and simultaneous these days and Marshal Macluhan’s deterministic vision of us all being plugged into one vast electrical organism like domestic animals at a a trough is far too close for us to laugh at† (P111 Mittelman and Othman 2001). The spread of the English language is another aspect of a global culture that transnational companies promote. In addition to Western films, music and media being promoted across the globe in an attempt to dominate popular culture, the ability to speak English is becoming seen as practically a necessity to get on in many of the world’s poorer nation – financial and economic institutions worldwide are adopting English and it is increasingly difficult to operate in the world’s markets without the language. Mandal states: â€Å"Globalizers actively promote English as a purely functional and even neutral language that is synonymous with economic growth, technological advancement and modernity as a whole† (p120 Mittelman and Othman 2001) and it is clear that non-governmental organisations such as the IMF and World Bank largely support the transnational companies in their promotion of English as a global language. Much of their analysis of the economic crisis in South East Asia in the 1990s suggests that the countries in the region that recovered best were those that had made the most progress in introducing the English language into the culture.   Across the globe, governments are accepting this aspect of global culture – in South Korea large scale English villages are being developed for locals to immerse themselves into the language, whilst the Mongolian government, in a country landlocked by Russia and China has announced long term plans to make English its primary second language. One of the greatest fears of those opposed to cultural globalisation is that it offers English speaking and western culture as something to aspire to whilst abandoning traditional culture. Hirst and Thompson write that: â€Å"National cultures that aim to be dominant over the individual that belong to them are increasingly projects of resistance to and retreat from the world† (p266 Hirst and Thompson 2000) – in effect, people and cultures that do not embrace the Western led global culture are seen as conservative, suspicious and most probably less likely to see investment from transnational companies. Globalisation is not going to go away, neither are the huge transnational companies. Some see the growth of a global culture and the wealth and opportunity that these huge organisations can bring as something for which diversity of culture can be sacrificed. They also argue, correctly, that people wherever they live do have a choice. Whatever the power of western marketing, if people across the globe choose to maintain their own culture and reject global or western culture, they have the power to do so. Others continue to argue that cultural globalisation in itself promotes diversity and a respect for other cultures. Those opposed to globalisation remain strongly opposed to the spread of the stereotypical McDonalds and Coke culture that personifies Western and particularly American culture. For transnational companies, profits are the bottom line and continual expansion across the globe is one of the best ways to ensure that they continue to make a profit. Transnational companies, ri ghtly or wrongly, have little concern for the protection of local culture – if a global culture will ensure that more of their products are sold, they will continue to promote it.   Bibliography Jan Aart Scholte, Globalization – A Critical Introduction, Macmillan Press Limited, London 2002 Philippe Legrain, Open World: The Truth About Globalisation, Abacus, Great Britain, 2002 Robert McChesney, The New Global Media in Held and McGrew The Global Transformations Reader, Polity Press, Cambridge 2002 Naomi Klein, Tyranny of the Brands, article New Statesman, 24 January 2000 James H Mittelman and Norani Othman, Capturing Globalisation, Routledge, London 2001 Paul Hirst and Grahame Thompson, Globalisation in Question, Polity Press, Cambridge 2000 Christopher Cook, Human Dignity Needs Protection, article at www.populist.com/00.2.cook.html

Comparing John Stuart Mills The Subjection of Women and Florence Night

Comparing John Stuart Mill's The Subjection of Women and Florence Nightingale's Cassandra For thousands of years, women have struggled under the domination of men. In a great many societies around the world, men hold the power and women have to fight for their roles as equals in these patriarchal societies. Florence Nightingale wrote about such a society in her piece, Cassandra, and John Stuart Mill wrote further on the subject in his essay The Subjection of Women. These two pieces explore the same basic idea, but there are differences as well. While they both recognize its presence, Mill blames the subjection of women on custom, and Nightingale blames it on society. These appear to be different arguments, but they may be more similar than they seem. Mill’s and Nightingale’s work both have the main theme of men dominating over women. Mill introduces his work with, â€Å"the principle which regulates the existing social relations between the two sexes — the legal subordination of one sex to the other — is wrong in itself†¦and it ought to be replaced by a principle of perfect equality† (Mill 1156), letting the reader know his stance on the issue right away. Nightingale’s article also starts off with a strong statement in the form of a question. She wonders why women are given such useful gifts if utilizing them is socially unacceptable: â€Å"Why have women passion, intellect, moral activity...and a place in society where no one of the three can be exercised?† (Nightingale 1734). Although these works both have the same thread running through them, they place the blame for the occurrence in different places. In Mill’s essay, he places the blame for the suffrage of woman on custom. He says, â€Å"custom...affords i... ... sound like completely different arguments; however, they are both placing the blame on one relationship. Custom and society exist together in a dependent relationship. One cannot be without the other. Custom defines what society does, and society does what custom defines; therefore, this relationship is blamed for the subjection of women in these two pieces. They may appear to have different arguments, but they are really arguing the same thing. This enforces the ideas Mill and Nightingale convey in their work: two different things seemed to have been blamed, and yet, after further analysis, the blame ended up resting in the same place. We can conclude that the subjection of women is likely to rest on this particular relationship because both of their arguments boil down to it, and Mill’s and Nightingale’s essays are more similar than at first believed to be.

The Ethics Concerning Space Debris Essays -- Outerspace Essays

The Ethics Concerning Space Debris In more than 40 years of space activities some 3800 launches led to about 25000 observable space objects larger than 10 cm of which 8300 were still in orbit by September 1997. Only 6% of the catalogued orbit population are operational spacecraft, while 50% is said to be due to "decommissioned satellites," spent upper stages, and objects such as launch adapter and lens covers, which are mission related. The other 44% is originating from 140 on-orbit fragmentations. These events have been the main source that has generated a population of objects larger than 1cm on the order of 70000 to 150000. Efforts to provide a definitive assessment of this problem have been directed toward analyzing the hazard level presented by particular debris populations and predicting how this hazard level will change with time. Much less effort has been directed toward satellite design and strategies to minimize the short-term and long-term effects of debris deposition.[9] Larger pieces of debris can cause catastrophic collisions with both manned and unmanned spacecraft. Currently, manned missions are planned around known pieces of space debris, "continuation of present design and operational practices and procedures ensures that the probability of collision will increase and will eventually reach unacceptable levels, perhaps within a decade." As stated by the AIAA the space debris issue should be faced by all space users, and coordinated action should be taken immediately if the future use of space is not to be seriously restricted. "There is an immediate need for an international dialog to be initiated on the space debris issue, with the goal of forming responsible groups to coordinate research ... .../ [5] Rossi, A., "Long Term Evolution of Earth Orbiting Objects," [Online Document], 1996 Mar 12, [cited 2000 November 17], Available HTTP: http://apollo.cnuce.cnr.it/~rossi/publications/oslo/oslo.html [6] Goldstein, R.M., and S.J. Goldstein Jr., "On the Flux of Millimetric Space Debris," [Online Technical Document], Jet Propulsion Laboratory, 1994. [7] Baker, Howard A., Space Debris: Legal and Policy Implications. The Netherlands: Martinus Nijhoff Publishers, 1989. [8] Christol, Carl Q., International Liability for Damage Caused by Space Objects. American Journal of International Law, Vol 74, Num 3, April 1980. Available: JSTOR Journal Storage. [9] AIAA "Position Paper prepared by the AIAA Technical Committee on Space Systems" [Online document], July 1981 [Cited 2000 November 17], Availab HTTP:http://www.aiaa.org/policy/papers/space-debris.html

Coco avant Chanel :: Coco avant Chanel

Coco avant Chanel est un film franà §ais rà ©alisà © par Anne Fontaine, qui est sorti au cinà ©ma le 22 avril 2009 en France. Anne Fontaine est une rà ©alisatrice, actrice et scà ©nariste franà §aise nà ©e au Luxembourg et a connu beaucoup de succà ¨s avec ce film. Audrey Tautou, la merveilleuse actrice franà §aise tient le rà ´le de Coco Chanel. Coco avant Chanel est un film biographique et romantique, qui s’intà ©resse aux annà ©es de formation de la grande couturià ¨re Coco Chanel. Ce film a bien à ©tà © reà §u par les critiques et a connu un immense succà ¨s auprà ¨s du public. Mondialement, ce film a gà ©nà ©rà © des recettes de plus de 43 millions de dollars. Cette Å“uvre a à ©tà © sà ©lectionnà ©e pour quatre nominations au BAFTA (British Academy of Film and Television Arts), trois nominations du Cinà ©ma Europà ©en, six nominations de Cà ©sar, et l’Oscar des meilleurs costumes. Ce film biographique raconte la vie de Gabrielle Bonheur Chanel, la conceptrice de mode, modiste et grande couturià ¨re franà §aise cà ©là ¨bre pour ses pià ¨ces de và ªtements de haute couture. Gabrielle Chanel est issue d’un milieu modeste. Sa personnalità © hors du commun, son assurance et sa franchise ont fait d’elle, une personne charismatique. Chanel et sa sÅ“ur, Adrienne, ont à ©tà © abandonnà ©es par leur pà ¨re quand elles à ©taient jeunes et elles ont grandi dans un orphelinat. Gabrielle attendait tous les dimanches que son pà ¨re vienne les chercher dans l’orphelinat. Quelques annà ©es plus tard, elles dà ©butent comme couturià ¨res et chanteuses dans un cabaret majoritairement frà ©quentà © par la classe ouvrià ¨re de l’à ©poque. Gabrielle est surnommà ©e  « Coco  » à   cause de chansons qu’elle chante tous les soirs avec sa sÅ“ur. Lorsque sa sÅ“ur lui informe qu’elle va se dà ©mà ©nager à   Paris pour à ©pouser son baron, Gabrielle dà ©cide à   son tour qu’elle a besoin d’un nouveau paramà ¨tre dans sa vie. Elle rend visite à   son ami Baron Balson (Benoà ®t Poelvoorde), un riche proprià ©taire de chevaux de course, qui vit dans la banlieue de Paris. Baron Balson lui permet d’entrer dans la haute socià ©tà © franà §aise. Tranquillement, Gabrielle commence à   s’intà ©resser davantage à   la mode. Elle conà §oit des chapeaux et des và ªtements pour la femme moderne, avec l’idà ©ologie minimaliste que la simplicità © est mieux. Pendant son sà ©jour avec le Baron Balson, Gabrielle rencontre et tombe en amour avec Boy Capel (Alessandro Nivola), un homme d’affaires anglais. Elle ne savait pas qu’il à ©tait sur le point de marier une femme de la haute hià ©rarchie anglaise, mais les deux amoureux s’engagent tout de mà ªme à   se planifier des visites rà ©gulià ¨res.

Ethics for a Criminal Justice Career Essay

For someone who chooses to become a law enforcement officer he or she must understand the importance of having moral ethics standards in order to do the job effectively and professionally. Police officers are held by the public to a higher standard of morality and are expected to be above reproach. Sadly, we see in the news all to often police officers that have exhibited unethical conduct both on the job and in their private lives. When an officer commits an improper act of some type it impacts the entire law enforcement profession, in some cases it makes it hard for other officers to do their job without ridicule. Unfortunately, the public does not differentiate between officers, departments, or uniforms when a scandalous act occurs. The purpose for anyone pursuing a law enforcement career to study ethics is essential to keep the integrity and the trust of the public. A look into how and why officer should make ethical decisions, to examine the motives for the choices they make and see what is the influence that guides them to make the choices they do. The Denver Police Department for example has the recruits in the police academy recite the police code of ethics every morning along with the pledge of allegiance. This tradition has carried on because of a police scandal that took place in 1961 that involved a number of officers who were committing burglaries, 47 officers were stripped of their badges and then went to prison. That year became known as the city of Denver’s year of shame, in a reprint of the original article in the Denver Post in February of 2010, the question was asked, How did it happen? â€Å"The department made it easy for us,† the leading police-burglars said. They pointed to a breakdown in departmental discipline and supervision that made it possible for them to double as safecrackers. As the year ended, steps were being taken to repair that breakdown. The International Assn. of Chiefs of Police was undertaking a departmental reorganization program, which is expected to make sweeping changes in pol ice  command policy, and, possibly, in command personnel. Some observers argue that only a thorough shakeup can restore public confidence in the scandal-ridden department. The answer the officers gave was insufficient because they were blaming the police department’s lack of supervision and breakdown in discipline as a reason for their crimes. Police officers need to have their own built in reasons for choosing the most ethical way, because even with increased supervision and discipline officers spend most of their shifts without supervisors around them. An officer must develop a decision making process that will be based on a standard that causes them to make the ethical decision immediately when faced with a moral dilemma. There are four major perspective theories of ethics that influence the decision making process for making choices, they are the Moral Virtue perspective, the Deontological/Formalism perspective, the Utilitarianism perspective, and the Biblical perspective. The moral virtue perspective is based largely on Plato and Aristotle theories, in (Sam Souryal’s book, Ethics in Criminal Justice, 2007) he points out that Aristotl e argued, â€Å"that because no one is born ethical (or unethical), people must spend their entire lives actualizing their potential in pursuit of happiness. This lifelong endeavor should be regarded not only as a means, but also as an end, desirable in itself.†(p.14) Aristotle believed that virtue ethics are learned through habit; therefore the application of virtuous behavior is brought about only through practice. Law enforcement agencies when recruiting candidates do extensive background investigations that include going to the schools they attended growing up and interviewing their teachers and friends. A polygraph test is given and psychological profiles are done all with the intention to determine those who demonstrate strong moral values before they are hired. In an FBI Bulletin article that focuses law enforcement ethics shows that in the pursuit of finding those who exhibit virtue ethics they say: Police departments’ best efforts will not prevent instances of police misconduct. Proponents of virtue ethics argue that certain officers misbehave because they lack character. These â€Å"bad apples† managed to â€Å"slip through the cracks† despite their unethical values. They argue that police abuse occurs in isolated incidents and involves a few immoral opportunists who were corrupt before they became officers. Unfortunately, this interpretation fails to explain how otherwise  exemplary officers with no prior history of wrongdoing, many of whom are sterling role models in their families, churches, and communities, can become involved in misconduct. (www.fbi.gov) In police academies across the nation are training police officers in ethics, it has become part of the curriculum in order to prevent a scandalous situation. In an online article at PoliceOne.com makes a very interesting point concerning virtue ethics development in a person: It is unlikely that an increase in ethics training alone will lead to more ethical policing. You can’t t rain ethics in the same way as other skills. It’s not a definable ability but is instead the result of education comprised of peer discussions, formal and informal training, and thoughtful reflection. (www.policeone.com) There needs to be more than just virtue ethics which morality is an overall concept to of people wanting to make their lives better. A problem that arises is who determines what things can be done to accomplish this, a choice to do something to live a better life could hurt someone else’s quality of life. Now a look into what is called the Utilitarianism theory as defined in a book on Criminal Justice Ethics by (Cyndi Banks, 2009) which states that consequentialist theories contend that the right thing to do always depends on the goodness of consequences. Utilitarianism is a consequentialist moral doctrine because, for the utilitarian, morality is solely a matter of consequences. (p.280) There is an appeal of utilitarianism to people because as (Rae, 2009) points out, â€Å"All one must do is weigh the anticipated good consequences of an action against its anticipated harmful ones – the bottom line produces a greater balance of benefits. If it produces greater benefits, then it is the most moral course of action† (p.74) The police officers in Denver that were committing the burglaries could have and may have used this theory as a justification for their illegal acts. It was said that their pay was not sufficient and they needed to do this in order to provide for their families, the benefit of that would outweigh the crime. Rea also shows how utilitarianism could justify obvious injustices, â€Å"such as contriving evidence against an innocent person to prevent widespread social unrest that would result in loss of life and substantial property damage.† (p.75) This theory if used in the law enforcement profession could cause incredible harm to their community and could justify immoral choices. This cannot be a theory that should be used by police officers to guide them in  making ethical choices because the end does not justify the means. The Deontological theory according to (Banks, 2009) Is in contrast with the utilitarianism theory because it takes the view that to act rightly, persons must first of all refrain from doing thins that can be said to be wrong before the fact; these wrong acts are defined by what are variously called rules, laws and constraints. The Deontological theorists claim that the rightness or wrongness of an act depends entirely upon the kind of act that has occurred and not upon its consequences. (p.p. 280-281) For law enforcement officers the deontological perspective would be a much better theory to follow because the decision would be based on the act itself. If the act a police officer would chooses is wrong, he or she should not even consider doing it for no other reason than it is wrong. This would be inline with the police code of ethics that sets out strict guidelines for officers to do, no matter what the circumstances are. â€Å"The Christian will tend to be more deontologically oriented because of the emphasis on Christian Ethics on the commands of God as moral absolutes and guiding principles.† (Rae, 2009 p. 17) After becoming a Christian while on the police force the difference in the work ethic was obvious to the command staff. The power of the Holy Spirit was transforming in giving the ability to follow God’s law and to understand that whatever decision was made, is for the glory of God. The Biblical perspective is the guiding force for a Christian officer; it does not automatically prevent ethical struggles, the same issues and temptations are still out there such as the high rate of divorce, alcoholism and suicide. They all could succumb to the same problems as any police officer such as anger, lust and promiscuity, greed, hatred and bitterness in the face of their daily challenges. It is easy sometimes in this field to forget obedience and submission to God’s authority, while possessing the authority given to them as police officers. They must always remember that they are slaves of God and he gives all authority in heaven and on earth. It is difficult to understand how any officer without Christ can function and remain pure given the environment they work in. An officer with a Biblical perspective should not be as prone to giving in to unethical decisions when facing dilemmas A police officer’s perspective will determine the way he or she handles the ethical dilemmas  that occur on the job. The verse found in Colossians 2:8 should be the guide for a Christian police officer to follow the Biblical perspective and not the perspectives the world offers, â€Å"See to it that no one takes you captive through hollow and deceptive philosophy, which depends on human tradition and the elemental spiritual forces of this world rather than on Christ.† (NKJV) References Banks, C. (2009). Criminal Justice Ethics, Theory and Practice (2nd ed.). Thousand Oaks, CA: Sage Publications Inc. Eldridge, L. (2011, June 16). Situational ethics and the moral chaos of modern policing. In issues/articles/3804919-Situational-ethics-and-the-moral-chaos-of-modern-policing/ PoliceOne.com. Retrieved May 3, 2014, from http://www.policeone.com/patrol- issues/articles/3804919-Situational-ethics-and-the-moral-chaos-of-modern-policing/ Fitch, B. D. (2011, October). Focus on Ethics Rethinking Ethics in Law Enforcement. In The FBI- Federal Bureau of Investigation, Bulletin . Retrieved May 2, 2014, from http://www.fbi.gov/stats-services/publications/law-enforcement-bulletin/october- 2011/focus-on-ethics Holy Bible: New King James Version. (1982). Nashville, TN: Thomas Nelson. Rae, S. B. (2009). Moral Choices, An Introduction to Ethics (3rd ed.). Grand Rapids, MI: Zondervan. Souryal, S. S. (2007). Ethics in Criminal Justice, In Search of Truth (4th ed.). Newark, NJ: Matthew Bender & Company Inc. Whearley, B. (2010, February 15). Exposà © of Police Burglaries Marked City’s ‘Year of Shame’ [Electronic version]. The Denver Post.

New media Essay

New media has interpreted the means we start out and produce content. New media such(prenominal) as the internet is making it easier for good deal to get their opinions across which creates content and allows a two- management dialogue. New media and technologies such affectionate media interlockings change the way a mortal perceives the argona. In the past decades, old call media was the only form of media employ to receive content and sharing content was non as easy interchangeable it is at a timeadays. net profit hatful be easily accessed, with the renewing process still continuing it is now easy for the earth to create and transfer content which form discussions. Habermas conception of the unexclusive sphere (Scannell 2000).Habermas defined the idea of the public sphere as a complaisant space in which all participants speak as equals, made rational arguments, mat up free to question authority and tralatitiousisticistic political assumptions. New media is broadcasted though digital media and online sites such as Facebook and the internet. Content is divided up and created done social media by uploading or publishing content such as images, videos and text. New media allows individuals to receive and sh atomic number 18 content. The rapid development of computer attainment leads to the outgrowth of brand-new type media which is transforming the world and the way how deal perceive the world. Interactivity which distinguishes new media from their traditional counterparts endows them with capability to transform the rule of communion. ground on the efficacious computer science and technologies, new media quick engulf the intact world. Rather than evolving from traditional media and extending to new handle traditional media pass away to reach, new media argon completely some other tool with in all different social organization and mechanism against which they function. They rag it possible to micturate a three-dimension world resembling but what humanity beings actually put out and give people a hard-nosed feeling by and by stepping in. This capacity leads to a new mode of cultural representation, simulation. The implications argon more than right to imitate and violate true, but besides include creating truenesscreating a domain that cannot exist in the actual world.The interactivity near associated with new media encapables them the transform the pompous chat mode as well. The one-way reading flow in traditional media changes into the nonpartisan dialogue, then into assemblage discussion. realistic communities and social networks absent shape. There, communication participants are no nightlong persons in conventional sense, but garnish into roles. A atomic number 53 person can have sundry(a) roles to present in different spaces created by new media. An vitrine of the two way dialogue is the break up THE BUDGET on the sbs site and through social media such as twitter peopl e who attended the rally were able to connect and present their opinions to sbs.Online social networking communities are transforming the way we are experiencing television/network channel content. Social media connects people from local anesthetic to global. Online communities utter everything that excites, entertains, energies or anything that creates an emotional stick with certain kind of stuff. Social sites like Twitter and Facebook are the platforms where communities share information, ideas and insights.To conclude, media quickly to engulf the whole world. Rather than evolving from traditional media and extending to new fields traditional media fail to reach, new media are completely another tool with totally different structure and mechanism against which they function. They make it possible to construct a three-dimension world resembling exactly what human beings actually live and give people a realistic feeling after stepping in. This capacity leads to a new mode of cult ural representation, simulation. The implications are more than just to imitate and reveal true, but also include creating truth creating a reality that cannot exist in the actual world.The interactivity closely associated with new media enables them the transform the conventional communication mode as well. The one-way information flow in traditional media changes into the two-way dialogue, then into group discussion. Virtual communities and social networks take shape. There, communication participants are no longer persons in conventional sense, but reduce into roles. A single person can have various roles to present in different spaces created by new media. Cultural representation andcommunication are no longer what they used to be in face of the powerful engine. This is what new in New Media exactly means transformations.ReferenceMedia and modernism A Social Theory of the Media butt B. Thompson 2014. Media and Modernity A Social Theory of the Media John B. Thompson The Struc tural Transformation of the Public knowledge domain J.Habermas 2014. http//www.sbs.com.au/news/article/2014/07/06/anti-budget-rallies-held-around-country-0 Meikle, Graham & Young, Sherman (2012) Ch 3 From Broadcast to Social Media in Media Flew, terry (2008) Approaches to new media from New media Van Dyke, N., Soule, S. A., & Taylor, V. A. (2005). The targets of social movements Beyond a focus on the state. Research in Social Movements, Conflicts and Change, 25, 27-51. Howley, K. (2007). partnership media and the public sphere. Media studies Key issues and debates, 342-360. Scannell, P. (Ed.). (1991). Broadcast talk (Vol. 5). Sage.http//www.abc.net.au/news/2014-07-06/storify-bust-the-budget-protests/5575378