How to write a good english essay
Friday, August 28, 2020
The causes and effects of sleep deprivation among students free essay sample
Did you get up at the beginning of today feeling more drained than you did when you hit the sack? Assuming this is the case, something is upsetting your rest. Nonetheless, do you know what it is? This issue is the same old thing but an ever increasing number of understudies experience the ill effects of lack of sleep, which is an absence of rest that viably revive the body, both genuinely and mentally. Stress, unbalance diet, and intuitive gadgets could be the causes to lack of sleep. These elements can result into psychological maladjustment, scholarly execution can be seriously influenced and could prompt the danger of getting corpulence. One of the primary driver of lack of sleep is pressure. Understudies consistently consume the 12 PM oil to complete the task as each instructor nearby gives a task on that week (Smith, 2010). The contribution in humanitarian effort and social exercises pack their timetables (Smith, 2010). Other than that, the predominant factor of potential stressor is family (Brecht, n. We will compose a custom article test on The circumstances and end results of lack of sleep among understudies or then again any comparative subject explicitly for you Don't WasteYour Time Recruit WRITER Just 13.90/page d. , p. 21). Kinjal (2010) states that parental battle has huge effect on their youngsters, for example, savage discussions and utilization of upsetting language before their kids. Kids get a major worry from elevated standards by their folks (Pejakovic, 2012). For example, guardians need their youngsters to prevail in each field (Pejakovic, 2012). Diet can likewise cause lack of sleep. Rehearsing a fair eating regimen is critical to generally speaking wellbeing and rest in light of the fact that your body is as yet working while snoozing. Your body not just requires the sound supplements which is wealthy in products of the soil, fit proteins and entire grains, yet additionally need to evade singed nourishments and sugars (Morris, 2011). Also, nourishments ought to be devoured four hours before sleep time to defeat rest aggravation and confusion (LC, 2008). At the point when assessment is around the bend, understudies consistently drink caffeine which are found in espresso, tea, chocolate, cola, and caffeinated drinks. This is on the grounds that one caffeine can help up our body however now and then it past our need which can add to poor rest (Morris, 2011). Electronic gadgets are regularly disregarded as a lack of sleep cause. Czeisler (n. d. , as refered to in Tarkan, 2011) says that electronic gadgets are tempting understudies to keep awake until late. Understudies will in general answer their telephones or answer to a book in the night (Gustafson, 2009). As indicated by Gradisar (n. d. ), a co-creator of the investigation, intuitive electronic gadgets are progressively mindful and upset the rest cycle (Tarkan, 2011). In addition, the arrival of the rest advancing hormone melatonin is smothered by fake light from the PC screen (Tarkan, 2011). Studies have been directed, overviews have been taken, and it has been examined in the news for a considerable length of time that there are a great deal of results of lack of sleep. One of them is lack of sleep causes psychological maladjustment in understudies. Understudies get irritated for each outlandish explanation when they don't get appropriate rest (ââ¬Å"Sleep hardship effectsâ⬠, n. d. ). For instance, they blow up effectively with no explanation at their companions. This forceful nature can destroy a companionship, so they feel progressively discouraged (ââ¬Å"Sleep hardship effectsâ⬠, n. d. ). Besides, it can likewise prompt certain mental issues (Dixon, 2008). Tsang (2008) has discovered that short sleepers create outrage, uneasiness and stress. Deficient rest likewise managing further confusions that could make your life destroy and jeopardize your prosperity (Dixon, 2008). Another impact of lack of sleep is that it can influence a studentââ¬â¢s scholarly execution in school. Mental weakness which result from lack of sleep prompts poor dynamic and debilitate critical thinking abilities (Dixon, 2008). Short sleepers will diminish their review capacity which is influencing everything from muscle to memory maintenance as rest is one of the bodyââ¬â¢s most imperative procedures (Smith, 2010). Kelly, Kelly and Clanton (2001) show that the diminished capacity to concentrate on instruction related exercises are liable for the lower grade-point midpoints of short sleepers. Indeed, numerous abilities covered up in understudies are influenced, for example, learning aptitudes and subjective conduct (ââ¬Å"Sleep hardship effectsâ⬠, n. d. ). Short sleepers are bound to put on abundance weight and become fat. As indicated by an examination by the University of Chicago, lack of sleep decline bodyââ¬â¢s affectability to insulin (ââ¬Å"Sleep more, liveâ⬠, 2012, p. 34). In this manner, it makes your body put on more weight rapidly (Rodolfo, 2011). The transcendent explanation for putting on weight is that the hormonal levels in the body that control craving vacillate follows from absence of rest (ââ¬Å"Sleep hardship effectsâ⬠, n. d. ). Stoutness, which builds the chances of creating rest apnea or indigestion and related stomach related issues, is expected to not eating appropriately (Morris, 2011). Having a decent nightââ¬â¢s rest is a fundamental necessity for about all pieces of studentsââ¬â¢ life. Absence of a decent nightââ¬â¢s rest can build the dangers of getting intellectually sick, influence scholarly exhibitions, and put understudies at a hazard for heftiness. These are because of stress experienced by understudies, lopsided eating routine, and intuitive hardware that understudies frequently disregard
Saturday, August 22, 2020
My Biggest Passion free essay sample
My greatest enthusiasm, other than my better half and children, is riding bikes. This is something that I am still genuinely new to; I have just been riding for around five years now. From the start I was terrified to death, when I was around five or six I tumbled off the rear of one, however when I saw my kids riding with my better half on his and having a fabulous time I concluded I would attempt it and have been snared from that point onward. I want to pass on my energy in the accompanying article, and furthermore show everybody that we on bikes are generally innocuous and simply need a similar politeness out and about that you would give a vehicle or truck. While cruisers appear to be startling and hazardous, when utilized appropriately, they can really be fun and energizing. One of the most significant activities when riding a cruiser is get a protective cap that fits and consistently wear long jeans and sneakers or boots. We will compose a custom paper test on My Biggest Passion or on the other hand any comparable subject explicitly for you Don't WasteYour Time Recruit WRITER Just 13.90/page You need as much dress among you and the black-top if something ought to occur. Be that as it may, first I might want to begin with the historical backdrop of bikes. Riding cruisers for me and my significant other is a fun and loosening up action. We have three major occasions that we do each year; the first is the Vermontville Maple Syrup Run in April, the Blessing of the Bikes in May and afterward our preferred which is our special first night/commemoration ride. A year ago at our Vermontville ride we rode with around 40 bicycles and pulled in to Vermontville with around a hundred bicycles. Storming heavily what not. My significant other can pack enough stuff on our bicycle (tent, hiking beds, sea shore umbrella, cushions and garments) to endure a few days of outdoors. On our normal commemoration trip we can log up to 700 miles in an end of the week. There is not at all like riding down the coast and smelling the water and trees and the air. I truly don't have the foggiest idea how to clarify how much these rides intend to us.
Friday, August 21, 2020
The Great Depression Brought Changes to Art in Many Ways Essay Example for Free
The Great Depression Brought Changes to Art from various perspectives Essay Life In America was increasingly open and out going then ordinary. Jazz clubs opened up at for the most part every square, where youthful energetic individuals would go drink and move the night away. This sort of social action was looked downward on by more seasoned residents that idea this sort of conduct was improper. This would at last lead up to forbiddance and the first run through ver in American history a change was pardoned making liquor unlawful in the United States. This caused crime percentages to soar inside American urban areas causing probably the most famous criminals in American history to rise, for example, A1 Capone. Such a large number of different things came out of the thundering 20s, for example, innovations of the vehicle, radio and planes, new design styles, high rises and motion pictures. With life getting updated did as well, workmanship. For the most part all through the 1920s there were an assortment of workmanship developments and styles that were well known. For example, oddity, Art Deco, reglonallsm and with new advances came photography and furthermore film. In 1929 the financial exchange slammed causing numerous individuals employments and their life reserve funds. Banks were proceeding to come up short and jobless specialists would depend on wrongdoing and robbery to help their families. With the financial exchange crash and numerous individuals in the red, this made ready for some specialists to communicate their emotions, through artistic creation, engineering [pic]and photography. One of the most well known craftsmanship developments during this time was known as American Scene painting. This craftsmanship development dismissed the previous European Modernist and dynamic styles. It basically delineated reasonable scenes of American life. One of the popular American scene painters was Charles Sheeler and was known as a Precisionist painter. HIS canvases for the most part comprised of rearranged types of American processing plants and structures and utilized crisped characterized edges with smooth brushwork all through his artworks. Above is his well known work titled essentially generally found in American design, Jewelry, furniture, garments and handcrafts all through the 1920s. Its geometrical plan with equal lines kept the smoothness style all through the 1920s. Oddity was initially shaped in Europe and with workmanship understudies from America they had brought the style over to the United States. The absolute most well known surrealist was Alexander Calder and Joseph Cornell. Calder was a stone worker and an architect who was motivated by surrealist painters in Europe to shape and make moveable bits of craftsmanship. One of his well known works was Lobster Trap and Fish Tail. The entirety of the parts moved, not precisely, yet with the breeze. Individuals think he was a theoretical craftsman, yet he needed to invigorate the creative mind. Regionalism was another workmanship development that was impacted by the American Scene painting. Award Wood was a regionalist painter who concentrated on the ordinary living in America. His American Gothic is a reasonable painting of what seems, by all accounts, to be a couple before their homestead house. Be that as it may, it is really expected to be a more established Iowa rancher and his little girl. The Regionalist development is partitioned into two gatherings. One is the social pragmatist and was affected by the social difficulties of the lower class. The other was the Regionalist and they were increasingly engaged of the positive side of things, (for example, Grant Wood), planning to drive America out of the downturn. A Regionalist painter named Thomas Hart Benton, painted his Instruments of Power from the wall painting America today. Which shows a wall painting of a wide range of mechanical enhancements during this timeframe. It comprises of a train, plain, electric towers, steam motors and different images of industry. The social pragmatists were basically centered around the American specialist and tried to change the hard financial occasions of the Great Depression. Indeed, the vast majority of the social pragmatists dismissed vision and concentrated on how the specialists saw the subjects and delineated how they felt about the subject. Social pragmatist style was related with hard-edged strong figures that are twisted and transformed. The developments principle objective was to show battles of the working America. The main social pragmatist during this time was Aaron Douglas, who was additionally the main craftsmen for the Harlem Renaissance. During World War l, million of African Americans moved toward the north to search for occupations. In the south there was very little open door at all for African Americans. This would be later called the Great Migration. This would cause incredible racial pressure in the north. In Harlem, anxious to impart their social considerations to the remainder of the world, African Americans would then investigate their new environmental factors and examination with usic, composing and workmanship that reform the Harlem Renaissance. Aaron Douglas would be the cutting edge of the Harlem Renaissance. He would deliver extraordinary works, for example, Aspects of Negro Life: From Slavery Through Reconstruction. This piece was intended for African Americans to acknowledge they are a piece of this world and this nation. The composition is a reenactment of the Emancipation Proclamation, which proposes that Douglas was attempting to strengthen their part ever. Douglass style was profoundly impacted conceptual style. He would utilize a constrained shading palette in his compositions utilizing an ariety of light and dim complexities inside his works. Rather than Aaron Douglas, a youthful Jacob Lawrence would show up, painting an arrangement called The Migration of the station. He utilized a theoretical style and straightforward shapes that fits the types of Cubism and African American people workmanship. In March 1933, recently chose president Franklin D. Roosevelt recommended an arrangement to renew the American economy. The arrangement was known as the new arrangement and was just a guarantee to the American individuals this new arrangement would get America out of the financial downturn. Numerous associations came out of this new arrangement plan. For starving craftsman, this gave them a prime chance to bring in cash and furthermore to show their centerpieces. The Public Works of Art Project (PWAP) was an association that was going to give craftsman work. The PWAP didn't keep going long however it gave craftsmen a resuscitating support. At that point in 1935 a much comparative association set up called the Federal Art Project (FAP) utilized more than 5,000 craftsmen from 1935 to 1943. Craftsmen, for example, Michael Lensin would profit by this association. His painting Mining gives a genuine comprehension of the American laborer. A significant part of the FAP craftsmanship were wall paintings, models nd frescos that despite everything exist all through the nation. The vast majority of the topic in these show-stoppers was for the most part about American battle and American success and accomplishments. These associations would create painters, however would likewise deliver incredible picture takers that would catch genuine liv e pictures of individuals. This new innovation would then change photography and will motivate future picture takers since the beginning. Photography was the most well known types of workmanship during the Great Depression. With new innovation for cameras it was simple for picture takers to catch pictures wherever they went. The photos caught genuine individuals with genuine battles. It additionally caught the brutal truth of the Great Depression. Numerous picture takers would go an alternate course and attempt to advance increasingly constructive pictures, for example, youngsters moving and making some great memories. The Works Progress Administration (WPA) would employ these picture takers to catch certain pictures to advance positive life. The Great Depression was a timespan when individuals expected to see the brutal real factors of the Depression and how it impact individuals, particularly the lower class residents. A picture taker, for example, Walker Evans was known as one of the experts of hotography. He took pictures of numerous individuals during the Great Depression and indicated the tiresome battles of Americans. Walkers utilization of lighting, structure and catching incredible detail was what made him a pioneer in the photography world. His photographs of tenant farmers and migrants during the Depression show the unforgiving real factors of their circumstance. He was recruited by the Farm Security Administration (FSA) to take a progression of photos of families living in run down homes. A photograph taken in 1936 shows a family living in poor and messy conditions presenting before the camera. They all look run down and crushed. He put them legitimately into the focal point of photo ensuring that they were the point of convergence of this image. You can see all through the image Just how horrendous these day to day environments were. He would then complete more arrangement of photos of the lower class during the Great Depression. symbolism of the Depression to show watchers the effect of the battling economy. The Farm Security Administration knew about how photos affected open idea. There are Pictures, for example, mioung Girls Knitting Stockings in Southern Hosiery Mill by Lewis W. Hine, which shows young ladies in a production line working in a cruel tmosphere. This was a prior photograph taken during World War l. He would then concentrate more on the advancement of America. He took an exceptional photograph called Rivetting on the arch, a quarter mile up. It was a photograph taken of laborers during the development of the Empire State building. A few photographic artists took photos of the positive, numer ous picture takers were increasingly inquisitive about the battles during the Great Depression. One picture taker specifically was Dorothea Langes
Tuesday, May 26, 2020
What Absolutely Everyone Is Saying About Vet Tech Essay Samples
What Absolutely Everyone Is Saying About Vet Tech Essay Samples What the vast majority of students don't know, nevertheless, is there are scholarships for just about whatever can pay for most or all the schooling! Most programs can be finished in two to three decades or five consecutive semesters. You should get in touch with the school of your choice and they'll be able to provide you information regarding tuition, in addition to financial aid. Contacting each individual school will offer all the details involved with the admissions process. This platform was made to fulfill the requirements of those that are interested in getting an essay done fast. There are times that you try to do your best and even then you're not able to score well in your home tasks. If you are able to use the provided information in a prudent way, you'll be in a position to create your efficient study program. Our site provides custom writing help and editing support. The War Against Vet Tech Essa y Samples Veterinary assistants are growing in demand throughout the country whilst pay rates also continue to rise. The admissions procedures to be a veterinary technician differ according to every school. Most veterinary technicians enter in the field with an associate's degree, but this isn't the only choice readily available to you. A vet tech also has to understand that his duties will differ from professional and knowledgeable veterinarians. The Birth of Vet Tech Essay Samples Though this task requires just a few things to finish, most students find it extremely tricky to compose an essay with quality. It is possible to easily depend on us to find essay help as we have a tendency to assist and guide the students with the aid of our professional experts. Writing a good essay is about more than simply using proper English. Your college counselor can offer valuable insight into how to boost your college application essays, so make sure to find feedback on your drafts whenever possible. You are able to easily buy unique college essays and don't neglect to tell friends and family about it. While it's true that there are a few excellent writers in college some find it extremely tough to write. Today, most college students find it difficult to compose an essay on a particular topic. The ideal thing about us is that each and every time you can buy original essay papers for sale. The type of essay you're looking for will be provided to you within the deadline offered to you. Now you can get genuine college essay online, one that is going to fit your financial plan and get your work done too. Don't neglect to mention people A vet should realize that a huge portion of their occupation is dealing with people, say tutors. You are likely to love our work. 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By the close of the statement, the reader should have the ability to observe the world through your eyes. Strong personal statements often start with a concise background that will act as the foundation for the message you want to convey. When starting your own personal statement, you want to make sure you're starting with something that catches your readers attention. It's quite simple to use together with self explanatory. The Vet Tech Essay Samples Chronicles To learn what your state requires, visit the AAVSB website by click on this link. Even then you're unable to discover the informative and accurate info. Learn your state's guidelines by visiting this website! To find out more about Student Chapters of NAVTA and locate a membership application, see the SCNAVTA page. Veterinary assistant certification programs can be finished in under a year and can result in a quick start in the veterinary field. It's important to see that veterinary technicians want to do a variety of duties. Veterinary technicians are an essential part of the veterinary practice. If a veterinary technician made a decision to further their education and become a specialist, based on the specialty they would concentrate on, they can earn a lot higher income. As soon as you've passed the ideal courses and exams, locate a mentor, work toward an apprenticeship, or locate an establishment that provides a great deal of on-the-job training. Fifteen continuing education credits and renewal every 2 years are expected to keep the certification. While the work market might be stable for veterinary technicians, the career doesn't pay a considerable volume.
Friday, May 15, 2020
Comparative Commentary - Mango St and Annie John - 1114 Words
Comparative Essay: gender roles in The House on Mango Street and Annie John Question 3: To what extent do male and female literary characters accurately reflect the role of men and women in society? In this essay I will analyse to what extent the characters in the novels The House on Mango Street (text A), by Sandra Cisneros, and Annie John (text B), by Jamaica Kincaid, reflect the role of men and women in society. These two novels criticise patriarchal societies, where ââ¬Å"women are taught to think as men, identify with a male point of view and to accept as normal and legitimate a male system of valuesâ⬠¦Ã¢â¬ . In both of them, there are clear examples of chauvinism, which conditions the lives of Esperanza Cordero, a ââ¬Å"Chicanaâ⬠who livesâ⬠¦show more contentâ⬠¦However, Annie is called a slut by her mother only because she was talking to a group of boys. Thus, we can see that women have fewer rights than men, which can lead them to a miserable life. Secondly, ââ¬Å"Chicanasâ⬠and Antiguans are affected by marriage. Historically speaking, in both cultures young women were obliged by their parents to get married, without any possibility to express themselves. Since that moment, they are destined to live oppressed by a man they do not love. In Sandra Cisnerosââ¬â¢s book, Esperanza tells us how her grandmother, described as ââ¬Å"a wild horse of a womanâ⬠, was thrown a sack over her head and forced to marry Esperanzaââ¬â¢s grandfather. Similarly, in text B there is also a victim of a marriage of convenience. Annie Johnââ¬â¢s parents want her to marry someone once she is in England, as a way of preserving Antiguaââ¬â¢s culture, but she refuses. Thus, we can notice that Annie wants to disconnect herself from this patriarchal society, which submits her to a life without any type of rights. This is also the reason why she is disappointed the last time she sees her friend, Gwen. This girl is also obliged to marry a boy at an early age, and although she is thrilled with the idea, she subjugates to their parentsââ¬â¢ desire instead of fighting for her rights. When Annie hears this news from Gwen, she completely understands that the relationship that once
Wednesday, May 6, 2020
Ict Ethical Dilemma Or Ethical Situation - 1137 Words
Title of the Topic:- Ethical Dilemma or Ethical Questionable situation related to ICT in newspaper or work place within last 6 months Worlds: - 700 Introduction:- In last 5 to 6 years there are very fast growing infrastructure with technology in Computer which changes the whole world scenario in many ways and all things are now rest on privacy , security that offering new tools to learning computer networks to students , professional and making digital world with lots of emerging technology. Recent years, Computer software and hardware all depends on networks and combining technology with networking integrates more powerful energy. This newer form has given many ethical dilemmas like e-learning, communication, copyright interpreted with the help of ICT ethical dilemma. These new issues will be now counted as more dangerous thing in emerging world. Over the decade the use of this technology increased very significantly in education, Governments and educational Places. The analysis using the Doing Ethics Technique (DET) Recently China has suffered from ethical dilemma where hackers of china attacked on NY Times systems and stolen the important information about password of other employees. Hackers entered into system lookout the networks of NY Times and get into it and find the relevant information about employees and also gets reporters password. The attackers first targeted on malware like malicious software which actively to rise entry into any computers on the timesShow MoreRelatedThe Ethical And Ethical Views Behind Computer Scientists1622 Words à |à 7 PagesThere has been a legitimate distinction between the moral and ethical views behind computer scientists being responsible for the action that they take upon the problems that they can face from the systems that they design. They must be faced with the codes of ethics and the morality issues in order to acknowledge the user about the responsibility that they must encounter in order for the use of technology. In the case of the technological society, the IT technology must include security measuresRead MoreThe Impact Of Information Technology On Society And Legal Requisites1148 Words à |à 5 Pagesclass the goal of learning this subject is to expose the legal responsibility and professional behavior by studying different case studies and present IT related articles which represent ethical, social and/or legal issues, situation and dilemmas. In doing this, tutorials and lectures provided framework of ethical thinking. This essay will reflect on how exploration of this subject framework has helped my insight into the practical application of ethic knowledge. As discussed in first lecture I learntRead MoreWhy Ethics Is Considered An Exhibited Behaviour Is Right Or Wrong?2815 Words à |à 12 Pages 1. Step I: Understand the situation Ethics is regarded as the parameters used to judge whether an exhibited behaviour is right or wrong in relation to all the relevant parties involved (Rossouw and Van Vuuren 20). In the case under consideration, the background behind the firing of Harry is under scrutiny due to his risk taking tendencies. Although he is a talented software engineer, his employer and supervisor have a different perspective of him. They consider him wild and unorthodox. He has managedRead MoreThe Ethics Of The Ethical Values2535 Words à |à 11 PagesThe ethical values are part of every person in all countries around the world. Each society has its own culture, beliefs, values, customs or habits that tend to shape the population that reside or were born in the country. Individuals tend to learn their ethical values at a pre-conventional period, during childhood and at that time, the beliefs of what is wrong or right start to be shaped inside them. EthicsRead More Global Information Infrastructure Essay2337 Words à |à 10 Pagesand to narrow the gap between countries. The world stands today on the threshold of a Global Information Society. This position has been arrived at through the truly remarkable advances that have been made in recent years in the development of ICT as well as the construction and development of national and global information infrastructure. Through these developments it is now both technically and economically feasible to bring modern information and communications technologies to any part ofRead MoreHow The Superintendents Leadership Program Transformed Me As A Leader?3557 Words à |à 15 Pagesdirections of our organization. I am confident now to declare that I have developed my reflective thought into a degree higher than before. Smith (1983, p.124 quoted by Daisy Arredondo Rucinski and Patricia A. Bauch in ââ¬Å"Emerald Article:Reflective, ethical, and moral constructs in educational leadership preparation: effects on graduatesââ¬â¢ practicesâ⬠as published in Journal of Educational Administration, p 489) defined reflective thought as ââ¬Å"an active response to the challenge of the environment.â⬠BeforeRead MoreEssay on Ethics and Management Decision Making4729 Words à |à 19 Pagesof their limited conceptual schema and donââ¬â¢t consider moral values while making decisions. Mostly managers are known for moral values, and they are not greedy and egoists, the underlying issue is that they have narrow perspective on a particular situation so they donââ¬â¢t view the moral consequences of their decisions. They actually lack the ability to imagine a range of possible issues, consequences and solutions. So just because of their shorter insight they make wrong moral decisions which later giveRead MoreThe Impact of Information Communication Technology on Malaysia Communication Cultur e in the Era of Globalization7293 Words à |à 30 PagesCommunication Technology (ICT) revolution in the late 1990s. The plethora of technology proliferation happens in a structured progression, one after another. Technological improvements began to tangibly influence our way of life. Today, even primary schools are equipped with ICT teaching tools (i.e. laptops LCDs). Nevertheless, ICT plays as a key enabler of globalization that changes Malaysian public life in a big way. In fact, after the September 11, 2001 tragedy, ICT in this country has becomeRead MoreBusiness Process Reengineering and Human Resource Management6517 Words à |à 27 Pagesmultidisciplinary teamworking. It highlights BPRââ¬â¢s cursory treatment of the human dimension of its programme for radical organizational change and raises the question of how HRM specialists are to respond to its trivialisation of the complexities and dilemmas associated with the reengineering of work processes. Introduction ââ¬ËThere is a new-look menu over at the Consultantsââ¬â¢Cafe. Good old soupe du TQM and change management pate are off. Perhaps you would care to try some business process reengineeringRead MoreHealth: Sociology and Social Care9095 Words à |à 37 Pagesable to explore how communication skills are used in health and social care 2 Understand how various factors influence the communication process in health and social care 3 Be able to explore the use of information and communication technology (ICT) in health and social care. à UNIT CONTENT 1 Be able to explore how communication skills are used in health and social care Relevant theories: humanistic, behaviourist, cognitive, psychoanalytical Techniques and purposes: techniques eg written
Tuesday, May 5, 2020
Behind Subsidiaries Holding Parents Liable ââ¬Myassignmenthelp.Com
Question: Discuss About The Behind Subsidiaries Holding Parents Liable? Answer: Introduction The company form of business structure has been given the status of separate legal entity, which is amongst the key features of this form of business structure. As per the separate legal entity concept, the companies are treated as a separate person from the ones who are supposed to run the affairs of the company (French et al. 2016). There have been numerous case laws where this concept has been applied but the case where this concept was born was that of Salomon v A Salomon And Co Ltd [1897] AC 22. The Corporations Act, 2001 (Cth), which is the act which governs the affairs of the company, also contains provisions regarding this status of the companies. In the following parts, a discussion has been carried whereby this very concept, particularly in context of Australia has been elucidated. Companies as Artificial Legal Person As was stated in the introductory segment, one of the characteristics of a company form of business structure is that a company is deemed as a separate artificial legal person. This is amongst the leading reasons for the popularity of company form of business structure (Abbott, Pendlebury and Wardman, 2007). As per this concept, the company has an existence in the eye of law where it is treated separately from the members and management of such company. Also, the choice of the name of company is always restricted as one name can only be given to one company. This name helps the company in making a case against others and even to others, in making a case against the company (Latimer, 2012). Also, owing to this artificial legal person status, even though a company is deemed as a person but the artificial segment of it gives it perpetual existence. So, the death of the management or directors does not mean the end of the company, effectively giving the company, an everlasting life (Kerr, 2014). A company does end, but only through liquidation, winding up, or an order of the court. As a result of this separate status of the company, for the debts of the company, the shareholders cannot be sued. They can only be asked to pay such sum of money, which is unpaid on their shares. Hence, the personal assets of the individual cannot be claimed upon by creditors in case the company fails to repay their debts (Gibson and Fraser, 2014). In Salomon v A Salomon And Co Ltd the House of Lords affirmed the concept that once a company is incorporated, it is deemed as a legal entity and it is separate from its shareholders. In the quoted case, the company was given a corporate personality whereby the creditors of the insolvent company could not sue the shareholders of the company for paying up the pending dues of the company. In this case, Salomon had incorporated the limited company for his long standing personal business where he was a shoe manufacturer. All of the shares were held by him and he had attained debentures upon the transfer of his former business to this incorporated company (Kershaw, 2012). Upon the failure of the company, the liquidator of the company made a contention that these floating charges should not be honoured, along with the contention to hold Salomon liable for the debts of the company, which led to Salomon making a case against them. The court held that the company had been incorporated in a proper manner and so, the court was not required to speculate upon the exorbitances and motives of the companys incorporation. Just because the shares of the company were held by a single person, did not change the fact that the company was separate person in law and was distinctive from the individuals who directed its will and mind. The court stated that the corporate veil of the company could only be lifted when there was an extraordinary case (Swarb, 2017). This is not the only case where the concept of separate legal entity was upheld by the court. Another leading matter in this regard is the case of Lee v Lee's Air Farming [1961] AC 12 in which in the company, Lee held all of the issued capital save for one share which the attorney of Lee held. The affairs of the company were effectively under his control. While he was on the job, he was killed and his widow made a claim for claiming the workers compensation, based on him being a worker. However, the New Zealand Court of Appeal rejected this claim based on the notion that Lee had effective control over the company but was not its employee. Upon the appeal being made to the Privy Council, the Council made inference from the case of Salomon and stated that the individual could work in dual capacity. In short, the Privy Council stated that the company is a separate legal entity and so, the shareholder and directors who enter a contract with the company, would be deemed as an employee of the company (Bourne, 2016). The Corporations Act, 2001 affirmed the stand on company being an artificial separate person. Under section 119 of the Corporations Act, the company comes into existence, on the very day on which it is registered, as a body corporate. And upon its formation, the company is to be deemed as a separate person, which carries on the operations of the company, which includes getting into the contractual obligations (Federal Register of Legislation, 2017). Section 198A(1) of this act provides that the companys business has to be managed as per the directions of the directors of the company. Section 198A(2) of this act covers that the powers can be exercised by the directors, which relate to the company (WIPO, 2015). This shows that the directors have only been given the power to run the affairs of the company on behalf of the company and not on their free will, which shows that the affairs of the company are run as per the will and mind of the directors but for the company, as per the objec tives of the company (Cassidy, 2006). Even though the artificial legal person status has been embedded in the Australian companies, along with the companies of thee other world, with changing time, this concept has also grown. This is with particular reference to the identification of where the affairs of the company have been conducted in a manner which requires the separate legal entity concept to be upheld and where there is a need to pierce the corporate veil (Bonomelli, 2014). With the advancements of this age, and the growing minds of the individuals, the case laws where this concept is effectively used, is being manipulated and at times, the theme of holding the company as an artificial legal person proves to be a costly affair for the different stakeholders. The leading example of this is the use of this concept in an unfair manner in the different cases associated with James Hardie Industries Limited, for instance ASIC v Macdonald (No. 11) [2009] NSWSC 287 and Peter James Shafron v Australian Securities and Investments Commission (2012) HCA 18; 286 ALR 612 (Norton Rose Fulbright, 2012). Even though the key management personal associated with this company were penalized and even disqualified, it does raise a question on the time delay which is taken from an incident occurring, to the relevant individuals being punished. The future of company law thus has to change to cope up with this misuse of the company being an artificial legal person, where they use this artificial legal person to their benefit and where the piercing of corporate veil takes a lot of time to be effective. This makes it very clear that the present day law, even though punishes the ones who are responsible for misusing this status, need to be more stringent and stricte r so that the wrongdoers think twice about misusing the artificial legal person status. Particularly, the penalties which can be imparted to the wrongdoers need to be raised as these were formed years ago. Hence, there is a need to raise the maximum amount of pecuniary penalty which can be awarded in such cases so that the individuals have to face a higher penalty which actually puts a hole in their pocket as the present penalties are just not sufficient in this regard. Conclusion To conclude the discussion carried above, the companies are deemed as artificial legal person as a result of which, the companies are treated separately from the director and the other key personnel who run the business of the company on the behalf of the company. There have been not one, but different case laws in which this concept has been upheld but Salomon was the key case where this concept was upheld and which have been quoted time and again. The Corporations Act also upholds this status of the companies and the companies are deemed as artificial separate legal person upon the registration of the company. However, the present day corporate law falls short of stopping the individuals from misusing the corporate status of the companies for their own personal use. This highlights the need for a change to be brought in the corporate law so as to raise the maximum limits of pecuniary penalty which can be awarded to the wrongdoer. 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