Human Alteration of the Carbon Cycle free essay sample

Human Alteration of the Carbon Cycle Recently, scientists have studied both short- and long-term measurements of atmospheric CO2 levels. Their data revealed that human activities are significantly altering the natural carbon cycle. Since the beginning of the industrial revolution, human activities such as the burning of fossil fuels and deforestation have accelerated, and both have contributed to a long-term rise in atmospheric CO2. Burning oil and coal releases carbon into the atmosphere far more rapidly than it is being removed, and this imbalance causes atmospheric carbon dioxide concentrations to increase. In addition, by clearing forests, we reduce the ability of photosynthesis to remove CO2 from the atmosphere, also resulting in a net increase. Because of these human activities, atmospheric carbon dioxide concentrations are higher today than they have been over the last half-million years or longer. Because CO2 increases the atmosphere’s ability to hold heat, it has been called a â€Å"greenhouse gas. We will write a custom essay sample on Human Alteration of the Carbon Cycle or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Without substantive changes in global patterns of fossil fuel consumption and deforestation, warming trends are likely to continue. The best scientific estimate is that global mean temperature will increase between 1. 4 and 5. 8 degrees C over the next century as a result of increases in atmospheric CO2 and other greenhouse gases. This kind of increase in global temperature would cause significant rise in average sea-level (0. 09-0. 88 meters), exposing low-lying coastal cities or cities located by tidal rivers. Even without the changes in climate, however, increased concentrations of CO2 could have an important impact on patterns of plant growth worldwide. Because some species of plants respond more favourably to increases in CO2 than others, scientists believe we may see distinct shifts in plant species as a result of increasing atmospheric CO2 concentrations, even without any change in temperature. For example, under elevated CO2 conditions, shrubs are thought to respond more favourably than certain grass species due to their slightly different photosynthetic pathway. Human Alteration of the Carbon Cycle free essay sample Human Alteration of the Carbon Cycle Recently, scientists have studied both short- and long-term measurements of atmospheric CO2 levels. Their data revealed that human activities are significantly altering the natural carbon cycle. Since the beginning of the industrial revolution, human activities such as the burning of fossil fuels and deforestation have accelerated, and both have contributed to a long-term rise in atmospheric CO2. Burning oil and coal releases carbon into the atmosphere far more rapidly than it is being removed, and this imbalance causes atmospheric carbon dioxide concentrations to increase. In addition, by clearing forests, we reduce the ability of photosynthesis to remove CO2 from the atmosphere, also resulting in a net increase. Because of these human activities, atmospheric carbon dioxide concentrations are higher today than they have been over the last half-million years or longer. Because CO2 increases the atmosphere’s ability to hold heat, it has been called a â€Å"greenhouse gas. We will write a custom essay sample on Human Alteration of the Carbon Cycle or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Without substantive changes in global patterns of fossil fuel consumption and deforestation, warming trends are likely to continue. The best scientific estimate is that global mean temperature will increase between 1. 4 and 5. 8 degrees C over the next century as a result of increases in atmospheric CO2 and other greenhouse gases. This kind of increase in global temperature would cause significant rise in average sea-level (0. 09-0. 88 meters), exposing low-lying coastal cities or cities located by tidal rivers. Even without the changes in climate, however, increased concentrations of CO2 could have an important impact on patterns of plant growth worldwide. Because some species of plants respond more favourably to increases in CO2 than others, scientists believe we may see distinct shifts in plant species as a result of increasing atmospheric CO2 concentrations, even without any change in temperature. For example, under elevated CO2 conditions, shrubs are thought to respond more favourably than certain grass species due to their slightly different photosynthetic pathway.

Renault FT Tank in World War I

Renault FT Tank in World War I The Renault FT, often referred to as the FT-17, was a ground-breaking tank design which entered service in 1918. A French light tank, the FT was the first tank to incorporate many design aspects which are now considered standard such as a fully-rotating turret and rear engine compartment. Small by World War I standards, the FT was intended to swarm through the enemys lines and overwhelm defenders. Used by French and American forces on the Western Front, the design was produced in large numbers and retained by many nations until the early days of World War II. Development The origins of the Renault FT may be traced to an early meeting between Louis Renault and Colonel Jean-Baptiste Eugà ¨ne Estienne in 1915. Overseeing the fledgling French tank corps which had been created during the early years of World War I, Estienne hoped to have Renault design and build an armored vehicle based on the Holt tractor. Operating with the backing of General Joseph Joffre, he was seeking firms to moved the project forward. Though intrigued, Renault declined citing a lack of experience with tracked vehicles and commenting that his factories were already operating at capacity. Not to be demurred, Estienne took his project to Schneider-Creusot which created the French Armys first tank, the Schneider CA1. Though he had declined the initial tank project, Renault commenced developing a design for a light tank that would be relatively simple to produce. Assessing the landscape of the time, he concluded that existing engines lacked the necessary power-to-weight ratio to allow armored vehicles to successfully clear trenches, shell holes, and other obstacles. As a result, Renault sought to limit his design to 7 tons. As he continued to refine his thoughts on a light tank design, he had another meeting with Estienne in July 1916. Increasingly interested in smaller, lighter tanks which he believed could overwhelm defenders in ways that larger, heavier tanks could not, Estienne encouraged Renaults work. While this support would proved critical, Renault struggled to gain acceptance of his design from Minister of Munitions Albert Thomas and the French high command. After extensive work, Renault received permission to build a single prototype. Design Working with his talented industrial designer Rodolphe Ernst-Metzmaier, Renault sought to bring his theories into reality. The resulting design  set the pattern for all future tanks. Though fully-revolving turrets had been used on a variety of French armored cars, the FT was the first tank to incorporate this feature. This allowed the smaller tank to fully utilize a single weapon rather than needing multiple guns mounted in sponsons with limited fields of fire. The FT also set the precedent for placing the driver in the front and the engine in the rear. The incorporation of these features made the FT a radical departure from previous French designs, such as the Schneider CA1 and the St. Chamond, which were little more than armored boxes. Operated by a crew of two, the FT mounted a rounded tail piece to aid in crossing trenches and included automatically tensioned tacks to help prevent derailments. Crew positions in a Renault FT-17 tank. National Archives and Records Administration To ensure that engine power would be maintained, the power plant was designed to operate effectively when slanted to allow the tank to traverse steep slopes. For crew comfort, ventilation was provided by the engines radiator fan. Though in close proximity, no provision was made for crew communication during operations. As a result, gunners devised a system of kicking the driver in the shoulders, back, and head to transmit directions. Armament for the FT typically consisted of either a Puteaux SA 18 37 mm gun or a 7.92 mm Hotchkiss machine gun.   Renault FT - Specifications Dimensions Length: 16.4 ft.Width: 4.8 ft.Height: 7 ft.Weight: 7.2 tons Armor Armament Armor: 0.86 in.Armament: 37 mm Puteaux gun or a 7.92 mm Hotchkiss machine gunAmmunition: 238 x 37mm projectiles or 4,200 x 7.62mm ammunition Engine Engine: 39 hp gasoline engineSpeed: 4.35 mphRange: 40 milesSuspension: Vertical SpringsCrew: 2 Production Despite its advanced design, Renault continued to have difficulty getting approval for the FT. Ironically, its chief competition came from the heavy Char 2C which was also designed by Ernst-Metzmaier. With the relentless support Estienne, Renault was able to move the FT into production. Though he had Estiennes support, Renault competed for resources with the Char 2C for the remainder of the war. Development continued through the first half of 1917, as Renault and Ernst-Metzmaier sought to refine the design. By the end of the year, only 84 FTs had been produced, however 2,613 were built in 1918, before the end of hostilities. All told, 3,694 were constructed by French factories with 3,177 going to the French Army, 514 to the US Army, and 3 to the Italians. The tank was also built under license in the US under the name Six Ton Tank M1917. While only 64 were finished before the armistice, 950 were eventually constructed. When the tank first entered production, it had a round cast turret, however this varied depending on the manufacturer. Other variants included an octagonal turret or one made from bent steel plate. French Renault FTs advance through Vaux, 1918. Library of Congress Combat Service The FT first entered combat on May 31, 1918, at Foret de Retz, south-west of Soissons, and aided the 10th Army in slowing the German drive on Paris. In short order, the FTs small size increased its value as it was capable of traversing terrain, such as forests, that other heavy tanks were incapable of negotiating. As the tide turned in the Allies favor, Estienne finally received large numbers of the tank, which allowed for effective counterattacks against German positions. The FT saw use at the Second Battle of the Marne as well as during the Saint-Mihiel and Meuse-Argonne Offensives. Widely used by French and American forces, the FT ultimately participated in 4,356 engagements with 746 being lost to enemy action. Postwar Following the war, the FT formed the armored backbone for many nations, including the United States. The tank saw subsequent action in the Russian Civil War, Polish-Soviet War, Chinese Civil War, and Spanish Civil War. In addition it remained in the reserve forces for several countries. During the early days of World War II, the French still had 534 operating in various capacities. In 1940, following the German drive to the Channel which isolated many of Frances best armored units, the entire French reserve force was committed, including 575 FTs. With the fall of France, the Wehrmacht captured 1,704 FTs. These were redeployed across Europe for airbase defense and occupation duty. In Britain and the United States, the FT was retained for use as a training vehicle. Additional FTs were retained by Vichy French forces in North Africa. These were encountered by American and British forces during the Operation Torch landings in late 1942 and were easily defeated by the Allies modern M3 Stuart and M4 Sherman tanks.

Learning resource on health and well-being Essay

Learning resource on health and well-being - Essay Example In an effort to make this program effective, schools and tertiary education facilities are constantly being encouraged to adopt a strong curriculum which not only caters for the child’s intellectual improvement, but also all aspects revolving around his/her life based on the four key pillars which include: Good health and nutrition is essential to a human development. Schools and generally all learning institutions have much to impact especially when it comes to a child’s health development. While most schools put more emphasis on intellectual growth, the health status of the learner should not be compromised. In most cases learning institutions are expected to provide at least two to three nutritious meals daily to ensure that the children get the strength to move around and concentrate in class. After all no one can learn on an empty stomach. Through this attempt, children are also evaluated and checked by health practitioners to ascertain their health and general nutrition. As such children are guaranteed of a balanced diet both at home and in school. They are also guaranteed of proper medical care which also happens to determine the general performance of the child. As part of creating a healthy society, this resource centers on ensuring that school-going children and youth are at least provided with a balanced diet at school and at home to ensure that they gain both physical and intellectual health (Department for Education and Skills, 2012). One of the most important reasons why children fail to perform as expected is due to their state of mind. According to a recent report the number of school drop-outs in the UK alone stands at an average of 120,000 students each year. While a substantial number of students drop out of school due to financial challenges, it is certain that a greater number leave school due emotional health problems. Although teachers are tasked with the general evaluation of the learner, in most

Management Case Study Example | Topics and Well Written Essays - 3750 words

Management - Case Study Example Resources within an organization includes finances, labor and time, which all are limited, yet important factors of production. In the 21st century, organizations have experienced intensive pressure to shift towards more production-oriented strategies to remain relevant and to overcome the numerous forces that are strenuous to business operations. For a smooth business run, organizational managers have to remain innovative and flexible to adapt to the dynamic market trends in their role of business coordination. Employees form part of the most vital resource that managers have to manipulate to tap their skills and knowledge and to direct them towards production. To optimize, it is important to align the employees to the organizational goals and to get them on board in the process of project implementation. Today, this has become the role that organizational managers have to shoulder if they have to succeed in their management duties. In the recent past, there has been an increase in work-related issues within many organizations due to conflicts as management face new market forces that require a transition into effective management strategies demanded by the dynamic market. ... Analysis of the Situation at Ground Matters on Ground In this case study, the university management experienced a conflict between the human resource manager and the chief Staff manager over the hiring of an employee in a matter of urgency in the organization. After the chief manager completed a selection process of an employee, the Human resource manager required that the employee produce a criminal investigation certificate as was provided by the organizational polices after which the employee would be served with a letter of acceptance. While the chief staff manager feels that in a matter of urgency the organizational policies can be overruled, the human resource manager feels that this would be a threat to these policies and insists on implementing them to the letter. Meeting between the two managers to discuss the issue ended up unsuccessful and as a matter of fact heightened the tension between the two officers. Resultantly, the chief staff officer had to resort to higher manag ement, the director, to resolve the issue at hand. Apart from heightening the tension between the two officers, the conflict between the two managers, had a consequence on the employees directly under them who also divided and supported their respective boss. The hired employee, Senior Academic Program specialist (SAPS) also felt that he was a victim a long and strenuous procedure and this had an impact of their work attitude. In summary, this conflict was extended to the entire organization and consequently had an impact on employee productivity in this organization. Scenario analysis In this case, the human resource manager and the chief staff manager had a conflict that seems to originate from differences in organizational strategy. While the human

Assessment and Office Equipment Essay Example for Free

Assessment and Office Equipment Essay Unit purpose and aim This unit is about using a variety of different office equipment following manufacturer’s and organisational guidelines. Learning Outcomes Assessment Criteria The Learner will: The Learner can: 1. Know about different types of office equipment and its uses 1. 1 Identify different types of equipment and their uses 1. 2 Describe the different features of different types of office equipment 1. 3 Explain why different types of equipment are chosen for tasks 2. Understand the purpose of following instructions and health and safety procedures Exemplification Learning outcomes 1 to 6 must be assessed using methods appropriate to the assessment of knowledge and understanding. A holistic approach to assessment should be adopted so that one piece of evidence covers more than one learning outcome and several assessment criteria. 2. 1 Explain the purpose of following manufacturer’s instructions when using equipment 2. 2 Explain the purpose of following organisational instructions when using equipment 2. 3 Identify health and safety procedures for using different types of equipment 2. 4 Explain the purpose of following health and safety. Procedures when using equipment 2. 5 Explain the purpose of  © OCR 2010 1 keeping equipment clean and hygienic 3. Understand how to use equipment in a way that minimises waste 3. 1 Give examples of waste when using equipment 3. 2 Give examples of ways to reduce waste 3. 3 Explain the purpose of minimising waste 4. Know about the different types of problems that may occur when using equipment and how to deal with them 4. 1 Give examples of equipment problems 4. 2 Explain the purpose of following manufacturer’s instructions and organisational procedures when dealing with problems 4. 3 Give examples of how to deal with problems 5. Understand the purpose of meeting work standards and deadlines 5. 1 Explain the purpose of meeting work standards and deadlines when using equipment 6. Understand the purpose of leaving equipment and the work area ready for the next user 6. 1 Explain the purpose of leaving equipment and the work area ready for the next user 7. Be able to use office equipment 7. 1 Locate and select equipment needed for a task 7. 2 Use equipment following manufacturer’s and organisational guidelines Assessment should be planned. To maximise the opportunities for the candidate to demonstrate their ability to use office equipment. 7. 3 Use equipment minimising waste 7. 4 Keep equipment clean and hygienic 7. 5 Deal with equipment problems following manufacturer’s and organisational procedures 7. 6 Refer problems, if required 7. 7 Make sure final work product meets agreed requirements 7. 8 Make sure that product is delivered to agreed timescale 7. 9 Make sure equipment, 2  © OCR 2010 resources and work area are ready for the next user Assessment This unit is centre assessed and externally verified. A holistic approach to assessment should be adopted so that one piece of evidence covers more than one learning outcome and several assessment criteria and where appropriate, provides evidence across several units. Your assessor will use a range of assessment methods which may include: ? observation of performance in the work environment ? examination of work products ? questioning the learner ? discussing with the learner ? use of others (witness testimony) ? looking at learner statements ? recognising prior learning Evidence requirements A range of evidence should be gathered to cover the Learning Outcomes and Assessment Criteria. Examples may include: ? Job requests/briefs from colleagues ? Copies of work produced using equipment ? Fault/problem logs indicating your response ? Records of training in use of equipment ? Minutes of team/1 to 1 meetings, relating to use of equipment ? Annotated copies of relevant sections in user manuals. The candidate must demonstrate their ability to use a range of office equipment including a computer, printer, and photocopier along with other equipment necessary to carry out their job eg telephone, franking machine,fax machine, data projector, shredder, laminator, binder, paper folder. Guidance on assessment and evidence requirements Refer to sections on Assessment and Evidence requirements above. National Occupational Standards (NOS) mapping/signposting This unit is based on the NOS BAA231 Use office equipment. Functional skills signposting This section indicates where candidates may have an opportunity to develop their functional skills.  © OCR 2010 3 Link to functional skills standards http://www. qcda. gov. uk/15565.aspx Functional Skills Standards English Mathematics ICT Speaking and Listening ? Representing ? Use ICT systems ? Reading ? Analysing ? Find and select information ? Writing ? Interpreting ? Develop, present and communicate information ? Resources Access to a wo rking environment with associated equipment and resources Additional information For further information regarding administration for this qualification, please refer to the OCR document ‘Admin Guide: Vocational Qualifications’ (A850) on the OCR website www. ocr. org. uk.

Mutual Trust in Employment Contracts

Mutual Trust in Employment Contracts Introduction In all the employment contracts a term mutual trust and confidence which is also known as the duty to act reasonably and fairly is implied or not is the question for over the past years. As per the labor regulations in Australia, different range of sources provides different rights and responsibilities of employers and employees, which also creates a huge different level of complications while going through these sources. These terms will generally be implied in an employment contract in Australia that has been widely acknowledged, but at the same time the debate on awarding the damages for a breach of these terms in some of the Australian courts will be challenging as well. Contract Contract is a legal document that states and explains a formal agreement between two different people or groups, or the agreement itself.[1] There are two kinds of contract and they are Express and Implied contract. Express contract is a type of contract which parties state the terms either orally or in writing at the time of its formation. On the other hand implied contract is a contract where terms and condition are not expressly defined at the time of its formation.[2] Employment Contract Employment contract is a category of contract, which used in employment. It is a relation between both parties on the one and stands an employee who is employed by an employer. It contains all terms and condition regarding employment.[3] Mutual Trust and Confidence in Good Faith Analyzing the concepts is very much necessary when it comes to â€Å"breach of mutual trust and confidence† and â€Å"the duty of mutual trust and confidence†. There is a lot of difference between the duty of good faith and the mutual trust and confidence. One talks about the implied duty that will relate to the terms of the contract and the relationship and whereas other talks about the incident of the employment relationship (right to Control). [4] When it comes to incident of the employment relationship, there comes a question whether the relationship of trust and confidence exists or not. Which totally depends on the nature of the employment. So there is a doubt that it has existed and continues to exist, a necessary relationship of trust and confidence between employer and employee. In an employment relationship the subsistence of mutual trust and confidence is very much essential to it. Because the employer cannot accept disloyalty of an employee who has undermine the employer’s business interest.[5] So the employee should not remain with the employer in employment because the employee has destroyed the trust and confidence in the working relationship. Employee’s destruction of trust can be evidenced by different types of conduct and which also depends on the circumstances of the employment. Some of the examples of different types of conduct, which may destroy the trust and confidence, are: demotion;[6] unwarranted carping criticism;[7] withdrawal of employment benefits.[8] It was first originated from the series of cases in the United Kingdom, in which employees totally blame employers for termination of their employment; despite this employers did not expressly dismiss these employees.[9] If any employee can make out that the employer’s conduct was so destructive of mutual trust and confidence, which properly ties up the parties to an employment relationship, than the employee treats employer’s conduct as constructive dismissal. In terms of contract law, employer’s conduct is treated as a repudiation of the employment contract by the employee as they are permitted to do so and elects to terminate the contract and claim damages for wrongful dismissal. On this basis in many of the cases, employee was seeking to claim statutory compensation for termination under the Employment Rights Act 1996 (UK) c 18.[10] Into the English employment law, duty was cemented by the decisions of House of Lords for example in Malik v Bank of credit and Commerce International SA (‘Malik’).[11] This was actually the test case for determining whether the breach of the duty is not to destroy mutual trust and confidence that could sound in damages. So it was held that mutual trust could sound in damages during employment as a consequence of the employer’s breach, that is why following this decision, not to destroy the mutual trust has been engaged to address a wide variety of claims. For example, in Clark v Nomura International Plc[12] and Clark v BET plc[13] So in the development of this duty in English law, which actually came from the decisions of a majority of the House of Lords that breach the common law duty of mutual trust, good faith and fair dealing would not sound damages until the damages flow from only the termination of the employment relationship. So to overreach the limitations already determined by statute,[14] the House of Lords held the common law not to be developed. Since in the United Kingdom the legislation has already imposed a cap on damages for termination of the employment, and also exercising the common law jurisdiction should not award damages that exceed the statutory limits for termination. To compensate for any losses incurred by the employee, damages might be awarded as a consequence of breach of employment contract during employment, but also not for any loss surffered as a consequence of loosing the job.[15] English scientific study of law has allowed damages for breach of the obligation that is not to destroy the trust and confidence, but even not when the damage flowed from the fact or manner of dismissal. Most importantly, in the English Law ‘the giving of the lawful notice cannot itself constitute a breach of the implied term.’[16] When it comes to Australian case law it has generally assumed that duty has been existed not to act in a manner or likely to destroy the mutual trust and confidence when it comes to employment relationship,[17] though no appellate court decision has depended upon such a findings.[18] Both parties to an employment relationship bear the duty not to destroy the mutual trust and confidence has assumed by the Australian courts in more recent times. When it comes to the English law, destruction of mutual trust signifies to the situation in which employees refuses to do something that are legally required to do as per employment contract and than identifies who is to be blamed if termination of the contract ensues. But whereas in Australian law, destruction of mutual trust and confidence has not been found to sound any damages on its own. In Australian case law it distinguishes between the employment relationship and employment contract.[19] The employment relationship is nothing but the actual dealing between employer and employee regulated by different types of law that includes common law of contract and also statutes that impose the mandatory obligations on the parties.[20] Whereas in terms of employment contract it is not automatically terminated when there is dest ruction of relationship of trust, but by electing innocent party.[21] In such circumstances the employees who gets terminated are entitled to be paid any remuneration or some other benefits according to his or her loss of account of premature termination of the employment contract.[22] This also means the payment of remuneration and other benefits that would have been received during a proper notice period. More importantly, the obligation not to destroy the mutual trust does not constrain an employer to take the decision to terminate the employment. So as long as the employer brings together the terms of the contract, and without prior notice and explaining how it should be done the employer is not at all liable for breaching the employment contract simply by deciding to terminate the employee.[23] Australian law has not gone so far unlike the English law, where the obligation is not to destroy mutual trust and confidence with a general duty of good faith and fair dealing in the employment contracts, in which breach might sound in damages. In some of the Australian cases there are few suggestions that on one hand there is two obligations of mutual trust and confidence, and on other hand the good faith, are having nearly the same meaning and these statements tend to be made by the courts who have found to decide upon the matter without any obligations.[24] According to Russell (Appeal) in 2008 â€Å"Although there were said to be two implied terms, it is probably sufficient to identify them as a single obligation.† [25] They derive from the same source, as siblings, that show the existence of a relationship of employment but again to understand it in the better way make it the separate concepts of each of them and with different functions. It is just a matter of choosing a vocabulary to assist in the clear articulation of separate concepts. The terminology of ‘mutual trust and confidence’ is very useful to describe in a particular characteristic of an employment contract that distinguishes it from a contract of sale or other contractual arrangement. Also ‘good faith’ is described as governing principle that is best engaged in interpretation and construction of relational contracts such as employment. Commonwealth v Barker It was in the year 2009 where the Commonwealth Bank of Australia took a step forward to change its Corporate and Financial Services business unit, due to which Mr. Barker’s position in the Bank was removed. As per the policy of the company, if they don’t require any position of the employee they will need to place that concern employee to the other part of the department or other position in the company. But in the case of Mr. Barker the Commonwealth Bank did not imply this policy. On 2 March 2009 Mr. Barker was send a letter to inform him about the redundant of his position but the Bank would like to send him to other area of the Bank. Later there was a meeting where Mr. Barker was told to clear out his desk, give away the keys and mobile phone and not to come to work. The Bank also stops Mr. Barker’s email and intranet facilities. On 9th April 2009, Mr. Barker was sent a letter of termination due to his redundancy and there was no sign of redeploy for Mr. Barker by the Bank. Mr. Barker had given his 23 years in the Bank and his contract of employment showed that he would be terminated only if the Bank is unable to give him a different position but there was no proper word in the contract apart from potential operation of an implied term of mutual trust and confidence. Mr. Barker’s file the case to the trial judge against the Commonwealth Bank and that included the failure of the Commonwealth Bank to give him the employment in some other department of the Bank.[26] What the Bank did to Mr. Barker was not according to the term of the contract of employment. As per the contract there should be mutual trust and confidence between employer and employee but that didn’t work at his time his employment. The policy of the company for redeployment was not utilized at his case of redundant of his position. Mr. Barker was entitled $300,000 from the bank for not following the company’s policy of redeployment. The case was then requested to the Federal Court as the Bank felt the Trial judge has made mistake in giving justice without any proper evidence. The courts refused to accept the appeal as Mr. Barker was more favorable and for this reason Jacobson and Lander JJ were appointed to go through the case in detail under Australian Law. [27] They came to the conclusion on the following grounds: In the court of England the policy support the implied term with the contemporary employment relationship.[28] The employment relationship should take part necessary of common interest and partnership fairly than a serious disagreement or argument.[29] These typical parts called for the result of an action or a decision by law of an obligation, for which employment relationship need to be in its original state.[30] According to the majority, the implied term only work in a particular way in respect of conduct and form a unit by it from the manner of termination of the contract of employment that is, it does not apply at the point of dismissing someone from their job or to steps inextricably linked with dismissal.[31] It was easy to see or understand from their reasons for decision that Jacobson and Lander JJ held that the implication of the implied term by law was necessary For Jacobson and Lander JJ, the Bank’s failure to give redeployment policy was not the important factor. As they found the Bank has not implied term or made something happen: Mr. Barker was a senior employee and worked for more than 23 years. The Common wealth bank was a large corporate organization and The contract (clause 8) contains that the employment may be terminated if the Bank were unable to place the employee in other position.[32] In these conditions of the facts, Jacobson and Lander JJ held that the implied term required the Bank to take positive steps from 2nd March 2009 to advice Mr. Barker about the possibility of redeployment and to give him the option to apply for alternative position within the Bank. [33] Jacobson and Lander JJ confirmed that Mr. Barker has been gone through hurt and distress and even loss of reputations that can never be recovered.[34] As an alternative reason for holding the Bank was liable, Jacobson and Lander JJ found that the same circumstances triggered the operation of the implied tasks of the organization in the contract of employment.[35] This implied the state of being forced upon the need for one party to take positive steps without which the other party is unable to enjoy a right or to be in a better position because of the contract.[36] By comparing the case where an employee despite to be knowing for the benefit unless it is brought to his attention by the employer. [37] After paying great attention to details and had judgment in which he completely study the gradual development of English and Australian case law in relation with the implied term of mutual trust and confidence, Jessup J concluded that: â€Å"the question whether the implied term is part of the law of contracts of employment in Australia has never been answered in the affirmative by an Australian appellate court in the sense of being of the ratio decided.†[38] His Honor went onto hold that the implied term of mutual trust and confidence was not needed for the pleasure of the rights conferred by the contract of employment.[39] Jessup J described the implied term as having â€Å"the potential to act as a Trojan horse in the sense of revealing only after the event the specific prohibitions which it imports into the contract.†[40] His honor makes a decision that the implied term, if accepted, â€Å"would enable defined limits in the existing fabric of common law and equitable remedies to be side-stepped†; and that the implied term would â€Å"overlap a number of legislated prohibition and requirements, thus tending to compromise the democratically-drawn architecture† by closely connected with the employment obligations.[41] Jessup J further held that the fact of being express reservation in the Bank’s redeployment policy â€Å"did not †¦leave any scope for the conclusion that by merely failing to comply with the policy, the Bank breached the implied term.†[42] The largest part of the case was in favor of Mr. Barker and at least for now, that in the period of time when express terms to the contrary is away, there is an implied term of mutual trust and confidence in every Australian employment contract. The decision moved to a higher level for consideration if the employers should clearly deliberate the implied term from employment contract. To whatever degree, it won’t be too complicated as given: As far as possible giving particular attention to the implied term, and The way of dealing by the majority judges, that particular circumstance triggered the operation of the implied term. The majority decision is turned upside down by the High Court of Australia on appeal; employers now need to put the implied term of mutual trust and confidence and the implied duty of cooperation to their list for them to remember all the time. In addition to the matters such as rise in the adverse action claims in dealing with their employees. When it comes to advantages and disadvantages for employers and employees of having such an implied term in the employment contract, employees should always remain faithful and sincere to the employer’s interest. Any confidential document or information of the company should not be shared outside the workplace to its competitors and it should remain internal within the workplace.[43] Whereas employers make decisions from the policies so they have to pay extra attention to its policies and regulations. In Barkers case federal court advised the employers to conduct themselves in a way that it wont destroy their relationship of trust and confidence with employee. When it comes to common law employers have to make sure that workplace is a safe place for employees to work. Employees have a huge advantage in having the implied term mutual trust and confidence because if there is a severe breach in the employment policies which is found than through the award of damages by the court, it will not only be considered a breach of an implied term. Conclusion In my view the term mutual trust and confidence is very much important to be implied in the employment contract. Because having the term mutual trust and confidence in the contract will create a comfortable working environment and also conditions can be achieved between both employer and employee. Incase if such implied term is not reflecting in the employment contract than either the employer or the employee would be permitted to act in a way that is not necessarily in accordance with the will of the contract. And also the practice of obeying rules between employer and employee are included in the viewpoint of an implied term. [1] Cambridge Advance Learner Dictionary (3rd Editioin) [2] ibid [3] Mark Freedland, the personal employment contract 2003 Oxford University press. [4] Gillies v Downer EDI Limited [2011] NSWSC 1055 [5] Concut Pty Ltd v Worrell (2000) 176 ALR 693. [6] Russian v Woolworths (SA) Pty Ltd (1995) 64 IR 169. [7] Lewis v Motorworld Garages Ltd [1986] ICR 157. [8] Clark v Nomura International plc [2000] IRLR 766. [9] Courtaulds Northern Textiles Ltd v Andrew [1979] IRLR 84. [10] Lewis v Motorworld Garages Ltd [1986] ICR 157. [11] [1998] AC 20. [12] [2000] IRLR 766. [13] [1997] IRLR 348. [14] Johnson v Unisys Ltd [2003] 1 AC 518, 544 [56]–[58] (Lord Hoffmann). [15] Gogay v Hertfordshire County Council [2000] IRLR 703. [16] Kerry Foods Ltd v Lynch [2005] IRLR 680, 682 [16] (Clark J). [17] Sappideen et al, above n 10, 162 [5.230] and the cases cited there. [18] Aldersea v Public Transport Corporation (2001) 3 VR 499. [19] Visscher v Giudice (2009) 239 CLR 361. [20]Byrne v Australian Airlines Ltd (1995) 185 CLR 410. [21] Visscher v Giudice (2009) 239 CLR 361. [22] Thomson v Orica Australia Pty Ltd (2002) 116 IR 186. [23] Russell (Trial) (2007) 69 NSWLR 198; Rogan-Gardiner [2010] WASC 290 (22 October 2010). [24] Russell (Appeal) (2008) 72 NSWLR 559, 567 [32], [25] ibid [26]Barker v Commonwealth Bank of Australia[2012] FCA 942 (3 September 2012). [27] 2013] FCAFC 83 at para [79], [28] 2013] FCAFC 83 at paras [94]-[95], [29] [2013] FCAFC 83 at para [81], referring to the Full Court of the SA Supreme Court decision inSouth Australia v McDonald(2009) 104 SASR 344 [30] [2013] FCAFC 83 at paras [72], [107]. [31] [2013] FCAFC 83 at paras [72], [97]. [32] [2013] FCAFC 83 at paras [110]-[111]. [33] [2013] FCAFC 83 at paras [112], [117], [130]-[132]. [34] 2013] FCAFC 83 at paras [152]-[158]. [35] 2013] FCAFC 83 at paras [118]-[128]. [36] 2013] FCAFC 83 at para [122]. [37]As in the House of Lords decision inScally v Southern Health and Social Services Board[1992] 1 AC 294, discussed by the majority inBarker[2013] FCAFC 83 at paras [114]-[115], [123], [128]. [38] 2013] FCAFC 83 at para [280 [39] 2013] FCAFC 83 at paras [288]- [295], especially paras [289]-[290]. [40] 2013] FCAFC 83 at para [340]. [41] 2013] FCAFC 83 at para [340]. [42] [2013] FCAFC 83 at para [351]. [43] Ansell Rubber Co Pty Ltd v Allied Rubber Industries Pty Ltd (1967) VR 37.

Business case on MS woes Essay

1. Describe the human resource planning implications for Microsoft in terms of the SWOT analysis. HR planning at Microsoft may consider performing its own SWOT analysis to enhance higher-level analyses at the company. We should expect that the firm’s HR planning would include points such as : ​Strengths: †¢ Talented employees at the â€Å"top of their game† in the industry †¢ Reputation as an industry leader Weaknesses: †¢ Conflict management )infighting) †¢ Compensation and benefits are no longer perceived as competitive or favorable Opportunities: More aggressive and focused recruiting efforts Marketing existing compensation and benefits Threats: Competitors, such as Google and e-bay. New entries into the industry 2. In your opinion, could these dramatic resignations have been predicted by Microsoft management? Defend your position. History repeats itself. In other industries, the front-runners eventually faced competition in the marketplace for customers and resources, which includes human resources.If Microsoft had solid communication mechanisms in place to field feedback from dissatisfied employees, management may have known about the pending exits.Many companies experience turnover after benefits are reduced or changed.Many companies experience turnover after â€Å"start-up† because employees who are successful at start-ups look for new opportunities once businesses are off-the-ground. Thus, considering all above grounds, I think Microsoft has predicted those resignations and prepared their alternative backup plan. 3. Using- Exhibit 5.1, describe the strategic implication from the outflow of creative talent at Microsoft . Without people, the structure has gaps. If the structure isn’t solid, the strategy doesn’t have the support it needs. Goals run the risk of not being met, making it difficult for the company to achieve its mission.

Basic Company

Mr. James Pierce had recently received word of his appointment as general manager of the Jackson Plant, one of the older established units of The Rose Company. As such, Mr. Pierce was to be responsible for the management and administration at the Jackson Plant of all functions and personnel except sales. Both top management and Mr. Pierce realized that there were several unique features about his new assignment. Mr. Pierce decided to assess his new situation and relationships before undertaking his assignment.He was personally acquainted with the home office executives, but had met few of the Jackson personnel. This case contains some of his reflections regarding the new assignment. The Rose Company conducted marketing activities throughout the United States and in certain foreign countries. These activities were directed form the home office by a vice president in charge of sales. Manufacturing operations and certain other departments were under the supervision and control of a seni or vice president.These are shown in Exhibit A. For many years the company had operated a highly centralized-functional type of manufacturing organization. There was no general manager at any plant; each of the departments in a plant reported on a line basis to its functional counterpart at the home office. For instance, the industrial relations manager of a particular plant reported to the vice president in charge of industrial relations at the home office, and the plant controller to the vice president-controller, and so on.Mr. Pierce stated that in the opinion of the top management the record of the Jackson Plant had not been satisfactory for several years. The Rose board had recently approved the erection of a new plant in a different part of the city and the use of new methods of production. Lower costs of processing and a reduced manpower requirement at the new plant were†¦

SWOT vs. STEEP Essay Example

SWOT vs. STEEP Essay Example SWOT vs. STEEP Essay SWOT vs. STEEP Essay The relative importance of decision making policy in a certain company may well predict the overall capacity of the business to perform well in the market. In line with this aspect, there are corporate philosophies that were created to help in the process of defining a better way to address the need for development and sustainability. The creation of SWOT and STEEP are just some of the basic domains in aiding the strategic planning process in a certain business.The existence of these two particular philosophies greatly influence the planning methods employed in a company. However, some companies prefer one compared to the other. This brings a notion whether the two perspectives provide the same advantages in properly addressing the needs in strategic planning. A relative comparison may be done to inhibit the appropriate impression whether SWOT is much better than STEEP or vice versa. This will at least address the considerations of businesses if they actually provide the same capacit y of benefits in policy making attributes.SWOT means (strengths, weaknesses, opportunities, threats) while STEEP is (societal, technological, ecological, political). At this very sense, the relative goal of SWOT remains in the overall internal inflictions for the company. The business can at least formulate a development strategy by identifying the relative factors included in it. The Strengths allow the industry to identify its optimistic value of operations; Weaknesses identify the common errors done in the business planning which can be avoided; Opportunities offers the process of identification of the positive acquisition of ideas in the environment while Threats give a plausible notion for external factors that may inflict harm to the business processes. As a matter of fact, the SWOT analysis gives constructive information which could help in matching and complimenting the firm’s resources and capabilities to the competitive environment in which it operates (QuickMBA, 19 99).On the other hand, STEEP rather identifies almost all the possible external sources of change in the internal business planning strategy. This includes the identification of various factors that only incorporates the influence of the outside world to the organizations processes. The company becomes a passive structure in the dynamic of marketing since it can only identify the actual relative events that currently induce the social structure. The Social and Political patterns become the predictor factor in doing marketing strategy, increasing the risk of trending the business operation to what the events demand. This could be a harmful step especially to the market segments where other preferences may be at existence. Moreover, Technological and Ecological factors erase the need for the company to explore other alternatives since these two factors can readily suffice the needs of a business but only in a short term approach.There are various ways that can be considered in creatin g the most appropriate marketing strategy. However, the organization should first identify what market segments it wishes to conduct its business operations. In any case, the SWOT remains at a more advantage state compared to STEEP because the change and operation process starts within the company itself and not external factor driven, enriching further what aspects the business is expert at.Bibliography:QuickMba (1999). SWOT Analysis. Strategic Management.Retrieved May 4 2007, from quickmba.com/strategy/swot/

Free Essays on Piaget Theory Applied To Education

Piaget’s Theory of Cognitive Development – Assignment 1 Our thinking changes drastically, though slowly, from our birth to our maturity because we constantly strive to make sense of the world. According to Piaget, four factors interact to influence changes in our thinking over our lives. These factors are biological maturation, activity, social experiences, and equilibrium. Piaget concluded that we inherit two basic tendencies, or invariant functions. Organization is the combining and averaging then recombining and rearranging of thoughts and behaviors into a more coherent system. Adaption is the tendency to adjust thoughts and behaviors to the environment. Piaget described our organized system of thought allowing us to mentally represent objects and events of our world, as schemes. These basic building clocks of thinking can be very small and very specific, like the â€Å"sucking on a straw† scheme or the â€Å"recognize and carnation† scheme. The simple structures are continuously combined and coordinated to become larger and more general like the â€Å"drinking scheme† or a â€Å"categorizing plants† scheme. In addition to the tendency to organize our psychological structures, we also inherit a tendency to adapt to our environment. The basic processes of adaption are assimilation and accommodation. Assimilation is a process of trying to comprehend some things new by fitting it into our existing schemes. Using our existing schemes to make sense of our world sometimes distorts the new information; like calling a skunk a kitty the first time a child sees a skunk. Accommodation occurs when information cannot fit into any existing schemes and new scheme structures must be developed. We change our existing schemes to adjust our thinking to fit the new data, instead of adjusting the new data to fit our thinking (assimilation). Two strengths of Piaget’s theory are matching problem solving and knowledge construction. In problem solving... Free Essays on Piaget Theory Applied To Education Free Essays on Piaget Theory Applied To Education Piaget’s Theory of Cognitive Development – Assignment 1 Our thinking changes drastically, though slowly, from our birth to our maturity because we constantly strive to make sense of the world. According to Piaget, four factors interact to influence changes in our thinking over our lives. These factors are biological maturation, activity, social experiences, and equilibrium. Piaget concluded that we inherit two basic tendencies, or invariant functions. Organization is the combining and averaging then recombining and rearranging of thoughts and behaviors into a more coherent system. Adaption is the tendency to adjust thoughts and behaviors to the environment. Piaget described our organized system of thought allowing us to mentally represent objects and events of our world, as schemes. These basic building clocks of thinking can be very small and very specific, like the â€Å"sucking on a straw† scheme or the â€Å"recognize and carnation† scheme. The simple structures are continuously combined and coordinated to become larger and more general like the â€Å"drinking scheme† or a â€Å"categorizing plants† scheme. In addition to the tendency to organize our psychological structures, we also inherit a tendency to adapt to our environment. The basic processes of adaption are assimilation and accommodation. Assimilation is a process of trying to comprehend some things new by fitting it into our existing schemes. Using our existing schemes to make sense of our world sometimes distorts the new information; like calling a skunk a kitty the first time a child sees a skunk. Accommodation occurs when information cannot fit into any existing schemes and new scheme structures must be developed. We change our existing schemes to adjust our thinking to fit the new data, instead of adjusting the new data to fit our thinking (assimilation). Two strengths of Piaget’s theory are matching problem solving and knowledge construction. In problem solving...

Objective Presentation Essay Example | Topics and Well Written Essays - 250 words

Objective Presentation - Essay Example These actions are usually guided by a job description to make them efficient and effective. However, the job description reflects on the organizational structure to assist the staff know the job titles, supervisor and subordinate, specific tasks required, department or units, and among others. In addition, staff members are usually under the control of people of higher ranks known as managers. These managers use an organizational structure to assist them determine which human, technical, and financial resources are available, which resources are lacking, and how resources should be allocated to attain organizational objectives and goals. There are three organizational structures and include Hierarchical, matrix and network structure. However, the optimal structure is a matrix or team structure. This is because it encourages interaction and participation among staff members, hence enhancing interpersonal relations. In addition, it also encourages managers to be more of group leaders and facilitators hence increasing accountability among staff members in an organization. When comparing the matrix structure with the rest, it always emerges the best. Managers in a Hierarchical structure always act as the final decision-makers, but those in matrix structure, focus on the accomplishment of shared objects of the team. In addition, staff members involved in a network structure, usually have a lot of differences in their affiliation and may fail to come up with a common goal. In matrix structure, staff members coordinate with one another and with their facilitator whose primary responsibility is to set objectives and evaluate

Environmental Impact of Products Essay Example | Topics and Well Written Essays - 1250 words

Environmental Impact of Products - Essay Example Their examples can be used to show how companies had to change their products and their processes in order to become more environmentally friendly. Environmental degradation has become a very important topic for the world today watchdog groups as well as concerned bodies focus on various ways and means in which they can force giant companies to help the environment rather than harm it (Green, 2005). Government regulation, think tank pressure, as well as the opinions of various consumer groups, can force companies to become friendlier towards the environment (Schulte, 2006). Undoubtedly, human activities including the actions taken by corporations have had a visible impact on the global environment and this has been noted by the scientific community at large. While the government can make laws to regulate a bare minimum to be done by corporations, consumers have to ensure that they do not support those companies which are hurting the environment (VonAncken, 2006). Consumers who have access to vast amounts of information about the companies they make purchases from can demand that the brands or businesses which they support behave ethically and show their responsibility for not hurting the environment. Organisations have to show that they are ethical producers since consumer wish to be ethical themselves and may make the purchase decisions based on knowing if the company is helping the environment rather than hurting it (Ethical Consumer, 2006). By being friendly to the environment, companies such as Apple and Cadbury Schweppes are helping their shareholders and investors (Phillips, 2003). Through the scientific developments in recycling, proper water conservation, and more efficient technologies for generating energy, individuals and companies have made great advances in becoming more environmentally responsible. At the same time, these efforts fall short of what will be needed in the world for sustained long-term prosperity.