Monday, June 29, 2020
The Horizontal Effect of Human Rights in the UK - Free Essay Example
Application of the à ¢Ã¢â ¬ÃÅ"Horizontal Effectà ¢Ã¢â ¬Ã¢â ¢ of Human Rights Law in the UK à ¢Ã¢â ¬Ã
âThe horizontal effect of the application of human rights law in the UK has important implications for the law of tort in relation to protection of privacy for private citizens. However the law is being applied in a piecemeal fashionà ¢Ã¢â ¬Ã Critically discuss. Introduction: Human rights protect an individual from unwarranted interference by the state, seeking to establish a just social and legal order to enable a person to live a full and productive life, free from fear, tyranny and discrimination and under the rule of law. UKà ¢Ã¢â ¬Ã¢â ¢s accession to the European Convention on Human Rights (1950) and its acceptance of the jurisdiction of the European Court of Human Rights (ECtHR or the Strasbourg court) leading to the enactment of the Human Rights Act 1998 (HRA) to give domestic effect to the Convention rights have had far reaching effects on judicial philosophy, approach and jurisprudence of English courts. This is not to say that common law was oblivious to human rights concerns. In Hertfordshire Police v Van Colle[1] Lord Bingham remarked that it would be surprising if conduct which violated a fundamental right or freedom of the individual did not find a reflection in a body of law ordinarily as sensitive to human needs as the common law but conceded that common law had evolved in a direction indicated by the Convention in areas in which the two overlapped. Given that human rights provisions are aimed at the excesses of the State, this essay discusses the impact of human rights law inter se d isputes between two private individuals, particularly in relation to the protection of privacy, which ordinarily falls under the domain of torts at common law. As such, the essay examines the incremental expansion of human rights provisions into the area of private and privacy law and whether or not the application of this new jurisprudence has been consistent over the years. Vertical and Horizontal Effect: The HRA is intended to have a vertical effect, i.e., it is applicable to laws and acts of state authorities affecting the lives of common citizens. Thus, s 3 requires that every primary and secondary legislation whenever enacted must be interpreted à ¢Ã¢â ¬ÃÅ"in a way which is compatible with the Convention rightsà ¢Ã¢â ¬Ã¢â ¢ failing which a competent court can declare it to be incompatible with Convention rights under s 4 prompting a competent Minister to move a Parliamentary amendment under s 10. S 6 prohibits a public authority from acting in a way which is inc ompatible with a Convention right failing which a à ¢Ã¢â ¬ÃÅ"victimà ¢Ã¢â ¬Ã¢â ¢ can move the court under section 7(1)(b) and seek compensation/damages under s 8(1) of the Act. Accordingly, Wright states that it seems clear that the scheme of the Act precludes direct horizontal effect in terms of basing a private action purely on a Convention right as the differentiation that the Act makes between public authorities which are subject to the Act and other bodies/persons would then be otiose.[2] However, the justification for a à ¢Ã¢â ¬ÃÅ"horizontal effectà ¢Ã¢â ¬Ã¢â ¢, at least what is termed as à ¢Ã¢â ¬ÃÅ"indirect horizontal effectà ¢Ã¢â ¬Ã¢â ¢ is often argued to be through s 6(3) of the Act which proscribes public authorities from acting in a manner which is incompatible with Convention right and includes a court or tribunal. Thus, the argument of academics is that courts are obliged to recognise and give effect to Convention rights even while adjudica ting private disputes.[3] Some basis for this position, particularly with regard to tort cases can also be found in the statements of high constitutional authorities. The Lord Chancellor while rejecting an amendment moved by the Chairman of the Press Complaints Commission to remove courts from the definition of public authority stated that while the courts could not play a legislative role and grant new remedies for infringement of Convention rights unless allowed by common law, they did have a duty to act compatibly with the Convention even in cases involving individuals, thereby affording them an opportunity to develop the common law by relying on existing domestic principles in the realm of trespass, nuisance, copyright, confidence, etc. to develop a common law right to privacy.[4] That the courts do not have the authority to carve out new areas of tortious liability and causes of action has been reiterated in the landmark case of Campbell v MGN as well.[5] At one extreme are the proponents of à ¢Ã¢â ¬ÃÅ"direct horizontal effectà ¢Ã¢â ¬Ã¢â ¢ of the Act who assert that the HRA is directly applicable to private disputes and the courts are obliged to take into account this legal position. The most ardent supporter in this regard has been the late academic and Queenà ¢Ã¢â ¬Ã¢â ¢s Counsel, Sir William Wade.[6] Murray Hunt is also a supporter of this position, writing in 1998 that pre-enactment documents (White Paper, Parliamentary debates, etc.) and Convention jurisprudence all à ¢Ã¢â ¬ÃÅ"point irresistiblyà ¢Ã¢â ¬Ã¢â ¢ to the fact that the Convention is horizontally applicable when the Act comes into force but will not give rise to an independent cause of action for breach of Convention rights and that over time, nobody will be without a remedy in domestic law for breach of their Convention rights.[7] Another argument in support of this notion is that the terminology of à ¢Ã¢â ¬ÃÅ"horizontalityà ¢Ã¢â ¬Ã¢â ¢ is itself misleadin g as it presumes that the HRA regulates the relationship between the citizens and the state as asserted by Sedley LJ. However, the true objective of the Act is to charge the state with a positive duty to protect human rights violations by abuse of power, whether by public or private entities.[8] Courts, however, have been less than certain on the horizontal effect or application of the Act or Convention rights on inter se disputes and judicial opinion in this regard shows a chequered history. Thus, in Gregory v Portsmouth City Council[9] decided just before the HRA came into force, the House of Lords did not take into account Convention rights or European jurisprudence while disposing of a case in which the issue was whether the tort of malicious prosecution extended to malicious domestic disciplinary proceedings, concluding unanimously that it did not. On the other hand, other cases like Reynolds[10] and Arthur[11] decided around the same time proclaim that it was à ¢Ã¢â ¬ÃÅ "common groundà ¢Ã¢â ¬Ã¢â ¢ that the Act would soon come to force and consideration would have to be given to Convention rights and attached jurisprudence. The passage of time has not shed too much clarity on the matter and there have been cases in which it has asserted that common law should not develop in line with Convention rights as the Act provides ample remedies under ss 7 and 8 thereof to redress human rights violations. This view was adopted by the House of Lords in Watkins v Home Office[12] and reaffirmed by Lord Brown in Van Colle.[13] Similarly, in JD v. East Berkshire Community Health NHS Trust Ors Lord Nicholls drew a clear distinction between the approach of the court in considering negligence claims in tort and those under the Convention/HRA, stating that à ¢Ã¢â ¬ÃÅ"sometimes in human rights cases(it is) appropriate for an international or domestic court to look backwards over everything which happened. In deciding whether overall the end result was acce ptable the court makes a value judgment based on more flexible notions than the common law standard of reasonableness and does so freed from the legal rigidity of a duty of care.'[14] Nonetheless, as will be seen later, the influence of the Act/Convention is certainly there in tort cases. Steele characterises the influence of the Act on tort law as a à ¢Ã¢â ¬ÃÅ"cascade- no less real, but less predictable and far harder to trace with certaintyà ¢Ã¢â ¬Ã¢â ¢ but argues that even of the Act was repealed, the à ¢Ã¢â ¬ÃÅ"values inherent in the law of tort and resembling the Convention rights that have been reinforced or energised by the Actà ¢Ã¢â ¬Ã¢â ¢ would not necessarily be unravelled simply by such a repeal and the courts would also perhaps not be inclined to do so.[15] Privacy and Human Rights: The concept of privacy is essentially a concept of the United States articulated first in the famous article by Samuel Warren and Louis Brandeis entitled The Right to Privacy in 1890 in which the authors asserted that it was an extension of the tort of trespass which hitherto was applicable only to tangible/physical property and was necessitated due to the march of technology and an overzealous press which allowed increased interferences into ones personal life that impacted on ones right to be let alone.'[16] Traditionally, there is no distinct tort of invasion or breach of privacy in the United Kingdom. As late as 2004, Lord Hoffmann stated in Wainwright Anor v Home Office that The need in the United States to break down the concept of invasion of privacy into a number of loosely-linked torts must cast doubt upon the value of any high-level generalisation which can perform a useful function in enabling one to deduce the rule to be applied in a concrete case. English law has so far been unwilling, perhaps unable, to formulate any such high-level principleà ¢Ã¢â ¬Ã¢â ¢ going on say that privacy could be protected under several common law and statutory remedies including trespass, nuisance, defamation, malicious falsehood, equitable action for breach of confidence, the Protection from Harassment Act 1997 and the Data Protection Act 1998 but the law still left gaps which may or may not be filled by judicious development of an existing principle.'[17] In the context of the Convention, the right to privacy is provided as a qualified right (subject to national security, public safety, prevention of crime and protection of health and morals as well as the rights and freedoms of others) in Article 8 thereof which states that à ¢Ã¢â ¬ÃÅ"Everyone has the right to respect for his private and family life, his home and his correspondenceà ¢Ã¢â ¬Ã¢â ¢ [Art. 8(1)]. The seminal case of the Strasbourg court dealing with the right to privacy in a dispute between private entities is Von Hannover v Germany[18]relating to paparazzi photographs of a celebrity which could not be prevented from being published in the popular press, the court found in favour of the Applicant and held that there was no public interest inherent in publication of private photographs and that the state in such circumstances had a positive duty to ensure the privacy of its citizens under Article 8. An example of both the vertical as well as horizontal application of Convention rights is the decision of the ECtHR in Peck v UK[19] in which CCTV camera footage of the applicant trying to commit suicide was released by the Council to the local print and TV press which showed it extensively was regarded as violation of his Article 8 right. While this may be an admirable extension of Article 8 rights for privacy protection in the private space, English courts have expressed doubt on the absolute nature of the principle and the direct horizontal application of Article 8 rights in the private sphere. In a recent decision in Malik v Fassenfelt Ors, Lord Toulson has stated that the primary ambit of Article 8 is a negative injunction on the State to not interfere with a persons private life or home, etc. except on limited grounds. The nature, scope and ambit of the states positive obligations remain unclear. It is true that the Strasbourg court has held in some cases that there is a positive duty of the state to take measures for protection of a persons private life from interference by another private person or private enterprise, for example, against criminal acts X Y v Netherlands[20] and MC v Bulgaria[21] or against the paparazzi as in Von Hannover. à ¢Ã¢â ¬ÃÅ"However, these are striking and unusual cases in which the applicants were victims of particularly objectionable conduct which seriously impaired their ability to lead a normal life. Article 8 does not ordinarily apply to regulate conduct in the private sector.[22] However, this may be regarded as obiter dicta since the Court of Appeal in Ash Anor v McKennitt Ors[23] has placed great reliance on Von Hannover and the principle of restricting me dia freedom and opting for its rationale rather than the permissiveness accorded to the press by such decisions as A v B plc.[24] Buxton LJ in McKennitt admitted that the two rulings could not be reconciled but deemed A v B to be inapplicable to the proceedings before it by stating that à ¢Ã¢â ¬ÃÅ"If the court in A v B had indeed ruled definitively on the content and application of article 10 then the position would be different; but that is what the court did not do. Having made the important observation that the content of the domestic law was now to be found in the balance between articles 8 and 10, the court then addressed the balancing exercise effectively in the former English domestic terms of breach of confidence. No Convention authority of any sort was even mentioned.à ¢Ã¢â ¬Ã¢â ¢ Thus, in McKennitt, the court not only placed importance on Convention rights but impliedly regarded Convention jurisprudence to be more applicable in view of the grafting of Articles 8 a nd 10 into English tort law on protection of private information. The High Court in Rocknroll v News Group Newspapers Ltd has regarded this approach in McKennitt as indicative of the fact that Von Hannover à ¢Ã¢â ¬ÃÅ"has been identified as definitive of this aspect of the English tort of misuse of private information.à ¢Ã¢â ¬Ã¢â ¢[25] Such a reading comports with other English cases as well. In Campbell for instance, English courts have explicitly held that development of common law has been in harmony with Convention rights and accordingly read Article 8 right as part of the common law ground of breach of confidence while granting relief to the appellant in a private dispute thereby recognising the horizontal application of Convention right. When considering an Article 8 right, another right, that of freedom of expression of a person seeking to use the sensitive information (usually the press but not always) provided for in Article 10 also comes into play. This freedom is recognised in s 12(3) of HRA and according to the House of Lords is a direct Parliamentary response to apprehensions of restrictions against the media[26] when enforcing Article 8 rights upon enactment of the HRA that leaves no doubt that horizontal application of Article 8 rights was contemplated or envisaged by the lawmakers. Therefore, the position that emerges is that Articles 8 and 10 rights have been à ¢Ã¢â ¬ÃÅ"shoehornedà ¢Ã¢â ¬Ã¢â ¢ into the tort of breach of confidence in such circumstances while considering whether there has been any breach of privacy in such circumstances[27] and as such it does not matter whether the guilty party is a public body or a private entity. When Articles 8 and 10 are in conflict, Lord Steyn has given the à ¢Ã¢â ¬ÃÅ"ultimate balancing testà ¢Ã¢â ¬Ã¢â ¢ in In re S (a child) where he has stated that neither article has precedence over the other and that a comparative analysis on the specific rights claimed and justifications f or interference or restriction should be undertaken along with the proportionality test.[28] Ward LJ in the landmark decision of ETK v News Group Newspapers Ltd[29] has kept Article 8 as the centre of the first stage test when deciding an application for interim injunction to restrain publicity of private information which is to ascertain whether the applicant has a reasonable expectation of privacy so as to engage Article 8; if not, the claim fails. In case Article 8 is applicable, the court can move to the second stage and apply Lord Steyns four parts ultimate balancing test. These guidelines including the applicability of Article 8 have been quoted with approval by the High Court in recent cases such as PNM v Times Newspapers Ltd Ors[30] and Rocknroll, which all involve disputes between private entities. In fact, in Murray v Big Pictures (UK) Ltd[31] in which the court held that the privacy of the famous author, JK Rowlingà ¢Ã¢â ¬Ã¢â ¢s infant son were violated by the priva te media companies, the claim was largely based on the violation of the childà ¢Ã¢â ¬Ã¢â ¢s Article 8 Convention right indicating that the court was operating from the standpoint of s 6(3) of the HRA as discussed above. Conclusion: From the above overview, it may be reasonably concluded that while the initial stages of horizontal application of human rights in privacy law was in doubt, a majority of cases leave no doubt that it is indeed applicable. As stated by Steele and noted by the High Court in Theakston v MGN Ltd[32] this has been made possible by grafting Convention principles into tort law which removes any limitations on the status of the guilty party. Cases such as Murray presume Article 8 to be an integral part of English law in its own right and do not question the assertion of the right against private entities despite the intervening framework of the HRA, which concentrates on the acts, and omissions of public authorities. Bibliography A v B plc [2003] QB 195 Arthur J.S. Hall and Co. v Simons [2000] 2 All ER 673 Ash Anor v McKennitt Ors [2006] EWCA Civ 1714 Campbell v MGN [2004] 2 AC 457 Cream Holdings Ltd Ors v Banerjee Ors [2004] 4 All ER 617 Douglas v Hello! (No3) [2006] QB 125 Ewing K, à ¢Ã¢â ¬ÃÅ"The Human Rights Act and Parliamentary Democracyà ¢Ã¢â ¬Ã¢â ¢ (1999) 62 Modern law Review 79 ETK v News Group Newspapers Ltd [2011] EWCA Civ 439 Gregory v Portsmouth City Council [2001] 1 All ER 560 Hertfordshire Police v Van Colle [2009] 1 AC 225 Hunt M, à ¢Ã¢â ¬ÃÅ"The Effect on the Law of Obligationsà ¢Ã¢â ¬Ã¢â ¢ in Basil Markesinis (ed), The Impact of the Human Rights Bill on English Law (Clarendon Press 1998) In re S (a child) [2005] 1 AC 593 JD v. East Berkshire Community Health NHS Trust Ors [2005] 2 AC 373 Klug F, The Human Rights Act 1998, Pepper v Hart and All That [1999] PL 246 Malik v Fassenfelt Ors [2013] EWCA Civ 798 MC v Bulgaria (2003) 15 BHRC 627 Murray v Big Pictures (UK) Ltd [2008] EWCA Civ 446 Peck v UK [2003] ECHR 44 PNM v Times Newspapers Ltd Ors [2013] EWHC 3177 (QB) Reynolds v Times Newspapers Ltd [2001] 2 AC 127 Rocknroll v News Group Newspapers Ltd [2013] EWHC 24 (Ch) Sedley S, Freedom, Law and Justice (Hamlyn Lectures 1999) 38Wright J, Tort Law and Human Rights (Hart Publishing 2001) Steele J, Tort Law: Text, Cases, and Materials (2nd edn, OUP 2010) Theakston v MGN Ltd [2002] EWHC 137 (QB) Von Hannover v Germany [2004] ECHR 294 Wade W, à ¢Ã¢â ¬ÃÅ"Horizons of Horizontalityà ¢Ã¢â ¬Ã¢â ¢ (2000) 116 LQR 217 Wainwright Anor v Home Office [2004] 2 AC 406 Warren S and Brandeis L, à ¢Ã¢â ¬ÃÅ"The Right to Privacyà ¢Ã¢â ¬Ã¢â ¢ (1890) 4 Harvard LR 193 Watkins v Home Office [2006] 2 AC 395 X Y v Netherlands (1985) 8 EHRR 235 1 [1] [2009] 1 AC 225 [58] [2] Jane Wright, Tort Law and Human Rights (Hart Publishing 2001) 22 [3] Keith Ewing, à ¢Ã¢â ¬ÃÅ"The Human Rights Act and Parliamentary Democracyà ¢Ã¢â ¬Ã¢â ¢ (1999) 62 Modern law Review 79, 89 [4] In Francesca Klug, The Human Rights Act 1998, Pepper v Hart and All That [1999] PL 246 [5] [2004] 2 AC 457 [6] William Wade, à ¢Ã¢â ¬ÃÅ"Horizons of Horizontalityà ¢Ã¢â ¬Ã¢â ¢ (2000) 116 LQR 217 [7] Murray Hunt, à ¢Ã¢â ¬ÃÅ"The Effect on the Law of Obligationsà ¢Ã¢â ¬Ã¢â ¢ in Basil Markesinis (ed), The Impact of the Human Rights Bill on English Law (Clarendon Press 1998) 180 [8] Stephen Sedley, Freedom, Law and Justice (Hamlyn Lectures 1999) 38 [9] [2001] 1 All ER 560 [10] Reynolds v Times Newspapers Ltd [2001] 2 AC 127 [11] Arthur J.S. Hall and Co. v Simons [2000] 2 All ER 673 [12] [2006] 2 AC 395 [13] Van Colle (n 1) [138] [14] [2005] 2 AC 373 [93] [15] Jenny Steele, Tort Law: Text, Cases, and Materials (2nd edn, OUP 2010) 24-26 [16] Samuel Warren and Louis Brandeis, à ¢Ã¢â ¬ÃÅ"The Right to Privacyà ¢Ã¢â ¬Ã¢â ¢ (1890) 4 Harvard LR 193, 193-196 [17] [2004] 2 AC 406 [18] [18] [2004] ECHR 294 [19] [2003] ECHR 44 [20] (1985) 8 EHRR 235 [23] [21] (2003) 15 BHRC 627 [153] [22] [2013] EWCA Civ 798 [44] [23] [2006] EWCA Civ 1714 [24] [2003] QB 195 [25] [2013] EWHC 24 (Ch) [11] [26] Cream Holdings Ltd Ors v Banerjee Ors [2004] 4 All ER 617 [15] [27] Douglas v Hello! (No3) [2006] QB 125 [53] [28] [2005] 1 AC 593 [17] [29] [2011] EWCA Civ 439 [10] [30] [2013] EWHC 3177 (QB) [31] [2008] EWCA Civ 446 [32] [2002] EWHC 137 (QB) [28]
Tuesday, June 2, 2020
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Vivamus et eleifend massa. Suspendisse nec arcu et ligula posuere aliquam. Integer quis arcu vitae nisi sodales tincidunt. Proin elementum ante quis mauris Integer dictum magna vitae ullamcorper sodales Integer non placerat diam, id ornare est. Curabitur sit amet lectus vitae urna dictum tincidunt vel vitae velit Vestibulum ante ipsum primis in faucibus Praesent pretium, massa ut consequat commodo, libero turpis dignissim lacus, facilisis porttitor risus mi vitae purus. Related posts News Building success: Dual Degree students win at USASBE Community How going beyond business at Hult helped me launch my company Admissions Accepted Students Weekend: A weekend to remember Careers Career mapping: How to become an executive in the next 5 years 0 Thought leadership How to prepare for an uncertain future in a world of AI News Is mail a dying form for businesses and marketing? Instagram Hult Rotation offers you a chance to study in a truly global way. Our rotation program allows you to study and be immersed in some of the finest cities in the world. ðŸ⠸: @jasminmanzano . Hult Rotation offers you a chance to study in a truly global way. Our rotation program allows you to study and be immersed in some of the finest cities in the world. ðŸ⠸: @jasminmanzano . Each year, Hult seeks to enroll a talented and ambitious incoming class from all over the world. We look for diverse students with a wide range of experiences, perspectives, and interestsââ¬âstudents who will thrive in our unique educational atmosphere. Are you ready for a truly global experience? ðŸ⠸: @iambrunadiniz . Each year, Hult seeks to enroll a talented and ambitious incoming class from all over the world. We look for diverse students with a wide range of experiences, perspectives, and interestsââ¬âstudents who will thrive in our unique educational atmosphere. Are you ready for a truly global experience? ðŸ⠸: @iambrunadiniz . Weââ¬â¢re excited to start 2020 on a ranking high! Hult is proud to have been placed #28 in Poets Quants 2020 rankings for Best Undergraduate Business Schools in the US. Taking a huge leap of 32 places from our 2019 position, weââ¬â¢re also very happy to have secured top positions in key categories like: life-changing experience, practicality of the degree, and global immersion. . With five global campuses, a student body of over 130 nationalities, and a learn-by-doing approachââ¬âHult offers a student experience like no other. . Weââ¬â¢re excited to start 2020 on a ranking high! Hult is proud to have been placed #28 in Poets Quants 2020 rankings for Best Undergraduate Business Schools in the US. Taking a huge leap of 32 places from our 2019 position, weââ¬â¢re also very happy to have secured top positions in key categories like: life-changing experience, practicality of the degree, and global immersion. . With five global campuses, a student body of over 130 nationalities, and a learn-by-doing approachââ¬âHult offers a student experience like no other. . ââ¬Å"Iââ¬â¢m from an engineering background and needed a whole new skill set for the industry I wanted to switch to. I learned a lot about myself and how I deal with being out of my comfort zone. I learned both soft and hard skills, from how to work in very diverse teams to key accounting metrics and strategy. I was surprised by how weak I was at certain tasks in English or how strong I actually was in other areas. Hult gave me opportunities to try new things and meet people from places I never thought I would have friends. . My internship experiences gave me the chance to broaden my view of different cultures and different companies. I had the opportunity to work and live with people whose values differed from people in my home country. I thought that this would be difficult, but it gave me the chance to reflect on my own values and assess if they were a result of my home country environment or if they were intrinsically mine. . Diederick ter Kulve (@diederick.terkulve) Netherlands Masters in International Business . ââ¬Å"Iââ¬â¢m from an engineering background and needed a whole new skill set for the industry I wanted to switch to. I learned a lot about myself and how I deal with being out of my comfort zone. I learned both soft and hard skills, from how to work in very diverse teams to key accounting metrics and strategy. I was surprised by how weak I was at certain tasks in English or how strong I actually was in other areas. Hult gave me opportunities to try new things and meet people from places I never thought I would have friends. . My internship experiences gave me the chance to broaden my view of different cultures and different companies. I had the opportunity to work and live with people whose values differed from people in my home country. I thought that this would be difficult, but it gave me the chance to reflect on my own values and assess if they were a result of my home country environment or if they were intrinsically mine. . Diederick ter Kulve (@diederick.terkulve) Netherlands Masters in International Business . Say a big hello to our Bachelor of Business Administration program cover star, Elisa Orus Plana âÅ" ¨ . ââ¬Å"Iââ¬â¢m excited for the futureââ¬âespecially that I cant predict whats going to happen. Maybe Ill end up in Mexico working for a trading company or maybe in Africa, developing my own business. Everything is possible, and the options are constantly changing. I love the idea that Im never going to be stuck doing the same job until the end of my life if I dont want it to be like this. . Hult really supports me and my ambitions and truly believes that we deserve to be considered as professionals as well as students. Here, I get to express not just my opinions but all elements of myself. From my creative side with the Fashion Society to my finance and business sides in Trading Club and the Management Consulting Club. We get a different type of learning here. Not just essential knowledge and theory, but practical skills and mindset. The school is always evolving. Weââ¬â¢re encouraged to innovate and to always look for new ways of doing traditional things. We learn how to be more confident and become aware of how we can impact our environment. The school aims to help you become a better version of yourself and to stand out from the crowd.ââ¬Å" . Elisa Orus Plana French Bachelor of Business Administration Class of 2021 Say a big hello to our Bachelor of Business Administration program cover star, Elisa Orus Plana âÅ" ¨ . ââ¬Å"Iââ¬â¢m excited for the futureââ¬âespecially that I cant predict whats going to happen. Maybe Ill end up in Mexico working for a trading company or maybe in Africa, developing my own business. Everything is possible, and the options are constantly changing. I love the idea that Im never going to be stuck doing the same job until the end of my life if I dont want it to be like this. . Hult really supports me and my ambitions and truly believes that we deserve to be considered as professionals as well as students. Here, I get to express not just my opinions but all elements of myself. From my creative side with the Fashion Society to my finance and business sides in Trading Club and the Management Consulting Club. We get a different type of learning here. Not just essential knowledge and theory, but practical skills and mindset. The school is always evolving. Weââ¬â¢re encouraged to innovate and to always look for new ways of doing traditional things. We learn how to be more confident and become aware of how we can impact our environment. The school aims to help you become a better version of yourself and to stand out from the crowd.ââ¬Å" . Elisa Orus Plana French Bachelor of Business Administration Class of 2021"> During the final days of 2019, you probably reflected on what youââ¬â¢ve accomplished this yearââ¬âand even this decadeââ¬âand what youââ¬â¢d like to achieve in 2020. Let us know in the comments below. During the final days of 2019, you probably reflected on what youââ¬â¢ve accomplished this yearââ¬âand even this decadeââ¬âand what youââ¬â¢d like to achieve in 2020. Let us know in the comments below. ââ¬Å"The first time we did group work on the program, I went head-to-head with a colleague. It taught me a lot about how I see people, how people see me, and how conflict can be resolved in a kind and productive way. The best feedback you get, when delivered constructively, is the most critical because it really feeds into how you lead. Iââ¬â¢ve completely reversed my leadership styleââ¬âthe result is so much richer and more powerful when you lead from behind and lead with strength. . Studying in tandem with working, whilst challenging, gave me the perfect platform to directly apply learning concepts into my business environment, the competitive landscape, and the real-estate industry as a whole. When I started the program, I was very happy in my corporate role. But my courage and aspirations grew to the point that I took on a whole new direction. Having my career coach, Joanna, as a sounding board allowed me to really be strategic and get to know myself. She coached me thro ugh all the interviews, the research, and the questions. It went in parallel with what I was doing academically and after six months everything just clicked. . I went into the EMBA knowing I had nothing to lose and Iââ¬â¢ve come out with everything. Great strength, global friends, amazing learning, mentors from professors, a job I love, and the knowledge that I can set my mind to achieve anything and with the right support and resources Iââ¬â¢ll get there.â⬠. Kashani Wijetunga British, New Zealand Sri Lankan Associate Director Senior Strategy Consultant CBRE EMBA Class of 2019 . ââ¬Å"The first time we did group work on the program, I went head-to-head with a colleague. It taught me a lot about how I see people, how people see me, and how conflict can be resolved in a kind and productive way. The best feedback you get, when delivered constructively, is the most critical because it really feeds into how you lead. Iââ¬â¢ve completely reversed my leadership styleââ¬âthe result is so much richer and more powerful when you lead from behind and lead with strength. . Studying in tandem with working, whilst challenging, gave me the perfect platform to directly apply learning concepts into my business environment, the competitive landscape, and the real-estate industry as a whole. When I started the program, I was very happy in my corporate role. But my courage and aspirations grew to the point that I took on a whole new direction. Having my career coach, Joanna, as a sounding board allowed me to really be strategic and get to know myself. She coached me thro ugh all the interviews, the research, and the questions. It went in parallel with what I was doing academically and after six months everything just clicked. . I went into the EMBA knowing I had nothing to lose and Iââ¬â¢ve come out with everything. Great strength, global friends, amazing learning, mentors from professors, a job I love, and the knowledge that I can set my mind to achieve anything and with the right support and resources Iââ¬â¢ll get there.â⬠. Kashani Wijetunga British, New Zealand Sri Lankan Associate Director Senior Strategy Consultant CBRE EMBA Class of 2019 . ââ¬Å"It was now or never. I knew that Iââ¬â¢d have likely stayed in my neighborhood for years to come if I didnââ¬â¢t take this opportunity. Iââ¬â¢d not lived or studied outside of the U.S. before. So I left my job as a global strategist at an advertising agency and moved halfway around the world. Iââ¬â¢ve come back a more culturally aware, well-versed person. Iââ¬â¢ve realized that everything is a learning experience and an opportunity for growth. Ill definitely carry this mindset with me into the future. Technology and social media allow us to be different people in several places at once. Im excited to see how I can establish myself in whatever city Ill be lucky enough to call home and still maintain deep connections with people all over the world. Iââ¬â¢m inspired by my classmates every day. Hearing some of their life stories and how getting this degree fits into their greater mission has been very humbling. My biggest challenge has been finding the ââ¬Ërightââ¬â¢ path for me. There have been rooms Ive felt like I shouldnt be in, but now Im proud to feel as though I truly belong, wherever I am.â⬠. Dwayne Logan, Jnr. American MBA Class of 2019 . ââ¬Å"It was now or never. I knew that Iââ¬â¢d have likely stayed in my neighborhood for years to come if I didnââ¬â¢t take this opportunity. Iââ¬â¢d not lived or studied outside of the U.S. before. So I left my job as a global strategist at an advertising agency and moved halfway around the world. Iââ¬â¢ve come back a more culturally aware, well-versed person. Iââ¬â¢ve realized that everything is a learning experience and an opportunity for growth. Ill definitely carry this mindset with me into the future. Technology and social media allow us to be different people in several places at once. Im excited to see how I can establish myself in whatever city Ill be lucky enough to call home and still maintain deep connections with people all over the world. Iââ¬â¢m inspired by my classmates every day. Hearing some of their life stories and how getting this degree fits into their greater mission has been very humbling. My biggest challenge has been finding the ââ¬Ërightââ¬â¢ path for me. There have been rooms Ive felt like I shouldnt be in, but now Im proud to feel as though I truly belong, wherever I am.â⬠. Dwayne Logan, Jnr. American MBA Class of 2019 . Happy New Year, Hultians! . Happy New Year, Hultians! .
Tuesday, May 19, 2020
The impact of the Bretton Wood Institutions on Human...
Using a country of your choice, discuss the impact of the Bretton Wood Institutions on Human Development in Sub-Saharan Africa. Introduction The Bretton woods institutions are the International Monetary Fund (IMF) and the World Bank. They were setup at the end of the Second World War in order to rebuild the devastated post-war economy and to promote international economic cooperation. The main focus of the IMF is to maintain exchange stability by harmonising its membersââ¬â¢ monetary policies1. The aim of the World Bank, on the other hand, is to advance reconstruction and promote longterm economic growth in less developed countries2. Ghana started to work with the IMF/World Bank in the sixties. Since then most of its governments,â⬠¦show more contentâ⬠¦On top of this a so-called ââ¬ËCash and Carryââ¬â¢ policy, where the patients cannot be treated unless they have paid for all costs, is practiced in most hospitals and clinics in Ghana.9 As for education, social spending cuts mean that there are fewer funds available for schools, facilities, equipment and teachers. This lack of funds has led to an increase in class sizes, increase in school fees, and a drop in the standard of public education.10 This is particularly bad for the poorest, whose parents cannot afford to pay school fees for their children. In order to reduce government spending, the IMF/World Bank prescribe the reduction of wages in the public sector and cutting of subsidies (on food, petrol etc.). However, the reduction in subsidies has led to a rise in commodity prices. The cutting of subsidies on rice cultivation in Ghana is one example. The government once supported rice farming communities in the northern parts of Ghana so much so that they were able to produce enough rice to feed most of the population. However, cutting subsidies and opening trade barriers has ruined the Ghanaian rice farms, as they were unable to compete with heavily subsidised rice from abroad. Today as a result, Ghana imports most of its rice from Western 8 Colgan (2002), p.1 Kampfner (2001), p.1 10 Jauch (2009), p.1 9 Page 3 of 12 countries at higher prices.11 Higher prices on the one hand and lower wages on the other mean an overallShow MoreRelatedThe Impact Of Transnational Industries And Global Financial Institutions Such As The World Bank And International Monetary Fund2146 Words à |à 9 Pagesessay aims to explore and critically analyse the impact of transnational industries and/or global financial institutions such as the World Bank and International Monetary Fund (IMF) in the sub-Sahara Africa. It will explore the impact on health, economic, and environmental, political and cultural determinants on developing countries. A country in the sub-Sahara Africa region will be used as a prime example in dealing with some of the above institutions and their outcomes, and a conclusion given. INTRODUCTIONRead MoreHuman Capital Flight ( Hcf )3942 Words à |à 16 PagesIntroduction Human capital flight (HCF) or what is popularly referred to as brain drain has acquired a prominent status in the globalized context of work especially in the last twenty years among health care professionals. This prominence is as a result of global shortages in the supply of health professional (Chibango, 2013; Clark, Stewart, Clark, 2006). The shortage has exposed the crisis inherent in global health systems. The advent of the new international economic order facilitated by theRead MoreSierra Leone: From Colonialism to Neocolonialism Essay2656 Words à |à 11 PagesColonialism is a feature of European expansion that took control of territory and people across the world starting in the 16th century. The last wave of colonialism was in Africa during the late nineteenth century, and these African colonies did not gain independence until the end of World War II. Decolonization was followed by years of economic, political, and social instability that made living conditions worse for the individuals in society. In this era of globalization, the economic strengthRead MoreStructural Adjustment Programs And Its Impact On Ghana s Human Development2653 Words à |à 11 Pagesintroduction of transnational institutions such as the International Monetary Fund (IMF), World Trade Organization (WTO), and the World Bank. These institutions applied neoliberal policies with the goal of pursuing progress for the global south. These Policies were referred to as structural adjustment programs (SAPS). This paper will argue that neoliberal structural adjustment programs implemented by the IMF and the World Bank have brought a negative impact on Ghanaââ¬â¢s human development hindering economic andRead More Analysis of The World Bank Group Essay3574 Words à |à 15 Pagesstandards than during any other period in history. In developing countries, life expectances have increased from 55 to 64 years, Income per person has doubled and Infant Mortality has been reduced by 50 percent . à à à à à Despite the successes, massive development challenges remain. Three billion people live on less than 2 dollars a day and 1.3 billion live on less than one dollar a day. Over 40,000 people die each day from preventable disease. 130 million never have the opportunity to go to school and 1Read MoreGlobalization or Glocalisation? Networks, Territories and Rescaling12782 Words à |à 52 Pagesnevertheless acutely aware of the long-standing internationalism of capitalism. ââ¬ËGlobalisationââ¬â¢ was not the buzzword then; instead there were rather more politically inspired concepts such as imperialism and neo-imperialism, neocolonialism, uneven development, the new international division of labour and the like. Many students of the time surely remember reading A.G. Frank, Cardoso and Furtado, Baran and Sweezy, Emmanuel, Samir Amin, Ernest Mandel, Baran and Sweezy, Muller or Braverman, among many othersRead MoreHow Global Economic Environment Is Affecting Internati onal Marketers?11351 Words à |à 46 PagesEconomic Downturn: The words economy and recession have become commonplace terms ever since the fall of the Lehman Brothers group in the USA. The resulting fallout has shattered many companies and left millions of people poor, jobless and homeless. The impact of this global recession has raised many questions in the minds of people. Even those who had no inkling of what the words economy and recession meant are suddenly asking questions. Unfortunately, there not many answers forthcoming, and those thatRead MoreImpact of Globalization and Bangladesh18126 Words à |à 73 PagesGLOBALIZATION AND ITS IMPACT ON BANGLADESH ECONOMY A thesis presented to the Faculty of the U.S. Army Command and General Staff College in partial fulfillment of the requirements for the degree MASTER OF MILITARY ART AND SCIENCE Strategy by RAHMAN MD FAIZUR, MAJOR, BANGLADESH M.D.S., National University of Bangladesh, 2004 Fort Leavenworth, Kansas 2005 Approved for public release; distribution is unlimited. REPORT DOCUMENTATION PAGE Form Approved OMB No. 0704-0188 Public reportingRead MoreOne Significant Change That Has Occurred in the World Between 1900 and 2005. Explain the Impact This Change Has Made on Our Lives and Why It Is an Important Change.163893 Words à |à 656 PagesTwentieth-Century Urbanization: In Search of an Urban Paradigm for an Urban World â⬠¢ Howard Spodek 53 3 Women in the Twentieth-Century World Bonnie G. Smith 83 4 The Gendering of Human Rights in the International Systems of Law in the Twentieth Century â⬠¢ Jean H. Quataert 116 5 The Impact of the Two World Wars in a Century of Violence â⬠¢ John H. Morrow Jr. 161 6 Locating the United States in Twentieth-Century World History â⬠¢ Carl J. Guarneri 213 7 The Technopolitics
Saturday, May 16, 2020
Academic Success A Student - 1251 Words
5 Academic Success Academic Success Tamara Thornton GEN/201 10/29/2015 Cheryl Jiles Academic Success As a student strive to move forward academic success and excellence, I will outline and discuss four major topics which are essential for any student to realize in order to achieve success in the field. Each topic will be briefly described with further two support points in favor of each underneath. The point is to explain what can propel a student toward realizing educational goals, achieving academic integrity by realizing its importance, efficient utilization of the university?s resources, maintain educational goals for self-development and the importance of writing process in advancing studies and career. Personal Learning Style and its Advantages A student must develop a personal learning style which effectively opens up different platforms of educational enrichment. My learning style ensures that all lectures and classes are attended with any pre-reading that must be done in order to learn comprehensively. This lets me gain an insight into any seminars or classes that I have to take and lets me probe deeper into aspects which require further study, analysis and dedication. Pre reading and any collection and perusal of data beforehand is always an advantage especially in Business studies and related subjects, as this allows a deeper understanding and further research. Also, I involve myself with a lot of post lecture or seminar research about theShow MoreRelatedStudent Motivation And Academic Success1568 Words à |à 7 Pagescontribute to the academic success of a student in college ââ¬â motivation, learning preferences/styles, socioeconomic status, whether or not the student is a first generation college student, gender , and even race. With so many factors potentially contributing or hindering a studentââ¬â¢s academic success in college; it is important for teachers to attempt to connect with students in the classroom. Adjusting instructional methods that focus on studentsââ¬â¢ learning preferences/styles can increase student motivationRead MoreA Student s Academic Success910 Words à |à 4 Pagespurposefully built to help students succeed. Many campuses include a library, sports fields, computer labs, a gym, among other shops, food vendors, and resources for students. It is safe to make the claim that a college library is the most useful building on a college campus. Everything a student needs to succeed can be found in the library. From the quiet atmosphere, to the useful resources, and helpful staff and students, the library contributes a large part to a studentââ¬â¢s academic success at Cumberland CountyRead MoreFactors Affecting The Academic Success Of Students796 Words à |à 4 P agesIntroduction Student success is imperative on a national level, all the down to individual families. Parents have often wondered if their education level will affect the academic outcomes of their children. Data from the National Center for Educational Statistics stated, ââ¬Å"the education level of a parent does affect a childââ¬â¢s achievement. Children whose mothersââ¬â¢ have at least a bachelorââ¬â¢s degree tend to participate in more early education experiencesâ⬠(Centers for Public Education, 2011). AsRead MoreAchieving Academic Success For College Students912 Words à |à 4 Pagesfriends, and learn about ourselves, students like myself should never forget the real reason for attending a higher educational institution. Everyone, including myself knows that education is the knowledge of putting potential the maximum use. Throughout the semester I have been given various assignments and objectives to comprehend making and this makes it challenging. At Miami Dade College, the professors offer a variety of ways that can ensure success My academic success this semester came with beingRead MoreAcademic Success Videos : Sleep And The College Student967 Words à |à 4 PagesAcademic Success Videos: Sleep and the College Student. Academic Success Videos: Sleep and the College Student. Dartmouth University, 22 July 2011. Web. 24 Feb. 2016. . This source was produced by The Media Production Group at Dartmouth and Dr. Carl P. Thum, Director of the Dartmouth Academic Skills Center. Carl Thum himself works with students at Dartmouth University in which he provides coaching for students suffering from ADD and also leads various workshops, mini-courses, and coaching sessionsRead MoreWhat Factors Play Into Students Academic Success?1363 Words à |à 6 Pagesfirst identify the needs of my students, without having telepathy. I knew that I needed to have conversations with each one on a one to one basis to try to gauge their interests. I also understand the many demands that are put on teachers and trying to insert any time for anything other than content is virtually impossible. Yet, this is one of the most important aspects of educationââ¬âtrying to fit the needs of each of our students as best as possible. I believe that students are young adults that areRead MoreHow Obesity Affects Students Academic Success1778 Words à |à 8 PagesMYPLATE VS. FOOD PYRAMID MyPlate vs. Food Pyramid: How Obesity Affects Studentsââ¬â¢ Academic Success Toiyanna Gansit and Michelle Calamasa Leilehua High School February 24, 2015 MY PLATE VS. FOOD PYRAMID 1 Table of Contents Abstract .........................................................................................................................................2 MyPlate vs. Food Pyramid: How Obesity Affects Studentsââ¬â¢ Academic Success........................3 Analyzing MyPlate and Food Pyramid DesignsRead MoreAcademic Success Of African American Students Athletes1816 Words à |à 8 Pagesat the topic of academic success of African American student athletes you need to look at all the factors involved. The problems that African American student athletes face are much the same that all African American students at higher education institutions face but the student athletes have other stressors that the normal students do not have. Such as In addition to the daily student routine (attending classes, going to the cafeteria, and participating in social events), student athletes also haveRead MoreStudent Motivation Is Important, Not Only For Academic Success1479 Words à |à 6 PagesMotivation Being able to read is important, not only for academic success but also as a general life skill that is necessary in a literate society (McGeown, 2013). Due to its significance, it is crucial to identify ways to develop childrenââ¬â¢s reading through engagement in reading activities. Research confirms that student motivation is a key factor in successful reading (Gambrell Marinak, 2009) and without the motivation to read, even a competent student will not have the drive to read. Therefore, it isRead MoreThe Environment Shapes A Poor Student s Academic Success1545 Words à |à 7 Pageshow the environment shapes a poor studentââ¬â¢s academic success. However, the teacherââ¬â¢s attitude toward the cognitive capabilities of their students also plays a major role in shaping a studentââ¬â¢s learning. A teacher with low expectations for their students and reluctance to take responsibility for all students can contribute to low achievement (Halvorsen, 2009). In low-income schoo ls, research has shown that the dedication a teacher displays to their student, especially to the idea of responsibility,
Wednesday, May 6, 2020
Frankenstein Abandonment Essay - 1166 Words
Frankenchild: Critical Analysis Paper Abandonment indicates a parentââ¬â¢s choice to have no part in his or her offspringââ¬â¢s life. This includes failure to support the child financially and emotionally, as well as failure to develop a relationship with his or her child. Sadly, parental abandonment leaves a child with doubt and uncertainty about the future. Throughout his or her life, this particular child could suffer from lasting questions of self-worth. In the opposite direction, the child could learn to resent his or her parents and remain incapable of trusting anyone. Regardless, intentional negligence of children leaves them with an unbearable pain that they must carry around for the rest of their lives. Child-care and the consequencesâ⬠¦show more contentâ⬠¦The first lesson the monster ever learned came from Victor Frankenstein. Whenever the monster turned to his master for love and comfort, he was turned away with fear. As soon as Frankenstein saw his repulsi ve countenance, he ran away into the dark of the night. Right away, the monster was denied any form of nurture that could have potentially changed the plot of the novel. After stumbling upon a few unpleasant strangers, the monster only desired acceptance from human society with the help of the cottagers: ââ¬Å"The more I saw of them, the greater became my desire to claim their protection and kindness; my heart yearned to be loved and known by these amiable creatures (Shelley, 133).â⬠Some parents such as Victor begin ignoring their children from the very beginning. If kids donââ¬â¢t receive nurture from an early age, their personalities are shaped by the way they are treated: ââ¬Å"These family disruptions are much more strongly related to feelings of fewer social supports and more negative moods and feelings (Science Blog).â⬠Without guidance from his ââ¬Å"fatherâ⬠, the monster attempted to make a place for himself into society. The monsterââ¬â¢s heroic re scue of the little girl illustrates his good heart and innocence; even though his mind was slightly disturbed, all he needed was for someone to reciprocate his love. Giving undying support to a child is detrimental to their development. Parents play a huge role in their childââ¬â¢s life and should be present as much asShow MoreRelatedFrankenstein: Abandonment, Loneliness, and Rejection1422 Words à |à 6 Pagesfaulty natures,â⬠writes the narrator of Mary Shelleyââ¬â¢s novel, Frankenstein, Dr. Frankenstein. Without a companion of some sort, people will only suffer more. However, without the supervision of parents, children altogether are greatly affected for the rest of their lives. An innately good and sympathetic creature, Dr. Frankensteinââ¬â¢s monster struggles to survive in the human world. After creating and abandoning his creature, Dr. Frankenstein is the juxtaposition of a monster, portraying humans as shallowRead MoreRejection And Abandonment Of Mary Shelley s Frankenstein1191 Words à |à 5 Pages2015 Frankenstein Essay Rejection is a hard thing to overcome. Rejection and abandonment can happen to newborn babies, children, and adults. Some babies are abandoned due to birth defects; children and adults are bullied and rejected because of the clothes they wear, their hair, face, ethnicity, and body. Some of this rejection can go too far, and can cause the one being bullied to become suicidal, or even homicidal. The theme of rejection is apparent in Mary Shelleyââ¬â¢s novel, Frankenstein. IsolationRead MorePoor Parenting Revealed in Mary Shelleys Frankenstein Essay1090 Words à |à 5 Pages Victor Frankenstein, does not live up to his role model. He lacks compassion for his creation (Madigan 3) à A predominant theme in Mary Shelleyââ¬â¢s Frankenstein is that of child-rearing and/or parenting techniques.à Specifically, the novel presents a theory concerning the negative impact on children from the absence of nurturing and motherly love.à To demonstrate this theory, Shelly focuses on Victor Frankensteinââ¬â¢s experimenting with nature, which results in the life of his creature, orRead MoreFrankenstein Literary Analysis Essay903 Words à |à 4 PagesFrankenstein Literary Analysis Friends will determine the direction and quality of your life. Loneliness is a battle that all people will once face at a certain point in their life; it is how they handle it that determines the outcome of that battle. In Mary Shelleys Frankenstein loneliness is the most significant and prevailing theme throughout the entire novel. Shelley takes her readers on a wild journey that shows how loneliness can end in tragedy. Robert Walton is the first characterRead MoreNature Vs. Nurture in Mary Shelleyà ´s Frankenstein1008 Words à |à 4 Pageswas coined, Mary Shelleyââ¬â¢s 1818 novel, Frankenstein, explored the idea of nature vs. nurture in the context of creation. The greatest exemplification of Nature vs. Nurture in Frankenstein is explored in the fate of the Creature, who begins his life a seemingly pure creation but eventually involves himself in violent revenge against his creator, Frankenstein. The examination of the Creatureââ¬â¢s character must include an overall evaluation of the role Frankenstein had in his life, or lack there of. WithinRead MoreMary Shelley s A Vindication Of The Rights Of Women1131 Words à |à 5 PagesThe notion of what it means to be human is heavily addressed in Mary Shelleyââ¬â¢s Frankenstein, as Victor Frankenstein, the eponymous character, produces a creature that resembles a human in both an internal and external sense. Despite the creatureââ¬â¢s obvio us human-like qualities, society rejects him continuously. To some extent, this blatant disregard resembles the difficulties that accompanied the feminist movement. Mary Shelleyââ¬â¢s mother, Mary Wollstonecraft, wrote A Vindication of the Rights of WomenRead More Look at the significance of chapter five to the novel as a whole.1126 Words à |à 5 Pageseffect of the writerââ¬â¢s language to describe setting, character and what it shows about social and historical influences. Frankenstein is a Victorian novel written in the gothic genre. It is about a man, Victor Frankenstein, giving life to an inanimate being and abandoning it. The monster then seeks revenge and the love of what he believes to be his mother, Frankenstein. The author, Mary Shelley, wrote the book at the age of nineteen but was not able to get the book published at first, asRead MoreThe Real Monster in Frankestein by Mary Shelley1000 Words à |à 4 PagesIn most readersââ¬â¢ minds, there seems to be no doubt as to who the real monster is in Frankenstein. The definition of the word ââ¬Å"monsterâ⬠is ââ¬Å"any fictional creature, usually found in legends or horror fiction that is often hideous and may produce fear or physical harm by either its appearance or its actionsâ⬠(Powell, 182). The creature that Frankenstein created was not only physically hideous but also murdered many innocent human beings. However, when we look beyond his physical appearance and startRead MoreThe Cruelty Of Mary Shelley s Frankenstein1508 Words à |à 7 Pageshumans still persecute others who are different. All in all, the exclusion is a form of bullying. In her novel Frankenstein, Mary Shelley exemplifies these phenomenas of human behavior, when she shows the maltreatment Frankensteinââ¬â¢s monster is giv en for his unattractive physical features and how he attempts to communicate with others in order to terminate his isolation. Victor Frankenstein, engulfed in the dedication of creating a god like image of himself, resurrects life into a eclectic dead bodyRead MoreFrankenstein Essay1176 Words à |à 5 Pagesthat Mary Shelley, the author of Frankenstein, was part of a family of famed Romantic era writers. Her mother, Mary Wollstonecraft, was one of the first leaders of the feminist movement, her father, William Godwin, was a famous social philosopher, and her husband, Percy Shelley, was one of the leading Romantic poets of the time (Frankenstein: Mary Shelley Biography.). What most people do not know, however, is that Mary Shelley dealt with issues of abandonment her whole life and fear of giving
The Decision Making Process Of Consumers Essay - 1679 Words
Introduction One of the important objective of marketers is to identify and understand the purchase decision maker. Understanding them helps the marketers in various fields from product manufacturing process to developing a good marketing strategy. The focus of the review of the research is to understand the decision making process by focussing on family buying decision or role of gender in family buying decision. Over the last few years, the pattern of family has changed a lot. Changing are occurring in role of woman in the society, future perspectives, and size of family etc. Men and Woman because of their distinctive childhood and socialization and other social, organic and mental variables diverse sorts of conduct at different circumstances. Whether it is choice making in individual life or expert life, whether it is about shopping or consuming, both the sexual orientations are totally diverse at each phase of choice making. Decision making process of consumers is depends on different factors which includes social, psychological and personal factors. The buying behaviour in different products varies according to different situation, benefits and persons involved. The goal of marketing is always the same ââ¬â to satisfy consumer and meets his expectation. By examining the sociological dimensions that how different families make buying decisions, the marketer can understand easily and can handle according to theShow MoreRelatedThe Consumer Decision Making Process1706 Words à |à 7 Pagesuse a lot of strategies to make the consumer purchase their brand over various other competitors. But what is it exactly that happens inside the head of the ââ¬Ëkingââ¬â¢ that the marketers are always so interested in? What process does a consumer follow towards making a purchase that reduces the level of his cognitive dissonance? Letââ¬â¢s have a look. Need Recognition This is the first stage of the consumer decision making process (Solomon et al 2010), when a consumer recognises that there is a differenceRead MoreConsumer Decision Making Process1577 Words à |à 7 PagesThis piece of work is about consumer behavior on electric vehicle which included the five stages of consumer decision making process such as Need Recognition, Information Search, Evaluation on Alternative, Purchase Decision, and Post-purchase decision. Lastly, the five different concepts which made up by social cultural factors and individual factors. 2.0 Five Stages of Consumer Decision Making Process 2.1 Need Recognition A problem is recognized when consumer found out a difference betweenRead MoreConsumer Decision Making Process2329 Words à |à 10 Pages2Extensive problem solving and perception 3 2.3 Consumers accept satisfactory decision 3 2.4 Motivation 3 2.5 Physiological field 4 2.6 Implication for marketers 4 3 Passive view 4 3.1 Characteristics 4 3.2 Arguments 4 4. Emotional view 5 4. 1 Characteristics 5 4.2 Consumer decision making process 5 4.3 Offers for emotional view 5 4.4 Implication 5 4.5 Effective Communication 5 5. Cognitive view 6 5.1 Characteristics and decision making 6 5.2 Relevance 6 5.3 Cross-cultureRead MoreThe Consumer Decision Making Process2218 Words à |à 9 PagesFIGURE 2.4 Consumer future decision-making process (Fotis, 2015; Moutinho, 1987) The value of influence is also a crucial element in understanding consumer purchase decision. Brown and Hayes (2008) interpret influence as ââ¬Ëthe action of creating a conductive environment which shapes other consumersââ¬â¢ perspective on a particular matterââ¬â¢ and ââ¬Ëthe ability to alter a person, item or routeââ¬â¢. A book published by James Duesenberry in 1949, who is the first to embrace the term ââ¬Å"consumer behaviourâ⬠, focusingRead MoreConsumer Decision Making Process2217 Words à |à 9 PagesINTRODUCTION We all have to make choices. One of those most important decisions made in our life are based on the market - buying goods. No one buy goods unless they have a problem, a need or a want. The Consumer Decision Making Model can be applied with any economics decision you have to make. The goal in creating this model was to analyze how individuals sort through facts and influences to make decisions that are logical and consistent for them. Think like an economist with this convenient toolRead MoreThe Consumer Decision Making Process1923 Words à |à 8 PagesIntroduction Consumer behaviour examines how individuals acquire, use and dispose of company offerings (Noel 2009). Acquiring a product or service is not the only consideration of consumer behaviour but the various stages and processes before these offerings are bought. In this essay I will be analysing a television purchase I made from Argos using the consumer decision making process and concluding with a justification in the context on consumer decision-making process. The consumer decision-making processRead MoreThe Decision Making Process Of The Consumer1950 Words à |à 8 Pagesstates that each person seeks to maximize their own gains. Putting that in context with a low self-control, one can identify that an offer should be fair since the key demographic might reject an unfair offer out of altruism. The decision making process of the consumer is a quick and intuitive one [See Appendix A]. In order to start advertising a change needs to happen in the eating habits. The strategy is to spread the word, create a buzz and sell an experience. In order to spread the word aboutRead MoreConsumer Behaviour And Decision Making Process Essay1264 Words à |à 6 Pagesliterature based on the order of the objectives. The literature review is on purchase intention, financial capability, and social factors, consumersââ¬â¢ attitudes and online buy. While analysing the literature, contributions, weaknesses and gaps in the existing literature were identified. 2.2. Theoretical review While consumers/buyers have existed for thousands of years, consumer behaviour research really began after World War II. It was established as a unique field of study during the 1960s (Engel, BlackwellRead MoreConsumer Decision Making Process Essay1449 Words à |à 6 PagesConsumer Decision Making Process A key factor in successfully marketing new/existing products or implementing a product Extension is a thorough understanding of the motivation, learning, memory, and decision Processes that influence consumers purchasing behavior. Consumer purchasing behavior theories have found their way into managerial decision making to help companies more effectively develop and launch new products, segment the market, determine market entranceRead MoreAnalysis of Consumer Decision Making Process1581 Words à |à 7 PagesIntroduction Consumer decision making process is a list of steps that are carried out by consumers concerning to a potential market transaction, before, during and after the purchase of a product or service. The process includes identifying the problem, collecting information, evaluating the alternatives, making the purchase decision and evaluating post purchase. Generally, decision making is theà cognitive processà of selecting a course of action from among multiple options. As a consumer, I find that
aikido Essay Example For Students
aikido Essay Aikido is a Japanese martial art currently practiced throughout the world. Behind thepowerful catapulting throws and immobilizing locks and pins of Aikido lie some verysimple principles: remove yourself from the direct line of your enemys attack, andthrough the absorption and deflection of the force of the attack, your enemy is taken outof balance and defeated by the energy of his or her own aggression. Aikido does not use strength against strength, but stresses body and mindrelaxation to direct the opponents force away. Because its main purpose is not to takethe offensive in injuring or harming the opponent, Aikido has often been called anonviolent martial art. In daily practice, the student of Aikido seeks to achieve the firmness, stability,sobriety and elegance which make Aikido one of the most powerful and beautiful ways ofartistic expression, while conserving its potential as one of the most devastating offers ofself-defense. Aikido may be practiced by all people regardless of a ge, sex, religion, or previousathletic ability. Systematic Aikido practice leads to increased aerobic capacity and tooverall body conditioning through both flexibility and strength training. The general philosophy of Aikido makes extensive use of the concept of Ki. The name Aikido can be translated as the way of harmony of Ki. Exactly what Ki is isa somewhat controversial issue. Aikido is one of the more spiritual martial arts and hasbeen referred to as moving Zen. Ai- come together or to harmonize Ki- the spirit ofthe universe Do- the way Ki is the force behind all things. Everything in the universe has Ki. Ki is the essence of our world. It is the basis ofall matter, every phenomenon, emotion, sense, direction, will, consciousness andconscience. Ki is also an energy which can be very useful in our daily lives when usedproperly. Ki is our life force which keeps us alive. Ki is the binding force of our mind andbody. We can be very efficient if we unify our mind and body. However, it is ratherdifficult to maintain the oneness of mind and body throughout our daily lives withoutsomething to bind them together. As electricity keeps the computer and the robotworking together, Ki keeps the mind and the body working in sync. Some believe that the physical entity Ki simply does not exist. Instead, the spirit,the intention, the bio-physico-psychological coordination through relaxation andawareness are concepts being used in the teaching. One must first learn to control oneselfbefore attempting to harmonize and control others. Without a good balance and controlof oneself, one can neither avoid an attack nor apply an effective technique on others. It isthrough self-control that one can learn to enjoy a harmonious way of life. In order to harmonize with the laws of nature, we must first learn to develop andmaintain the right attitude of training. We must always keep the attitude of becoming onewith every situation. This is an attitude of respect for all things at all time s. Regardless ofthe situation, friend or foe, one must always be ready to harmonize. The right attitudegreatly affects the efficiency of the action. It is not how strong, but rather how correctyou are that counts. This concept of mind-body connection will make it possible foranyone regardless of age or sex to perform the arts efficiently. There are Four keys to body and mind unity. First, Calmly let your mind settle atan imaginary point about two inches below the navel. Second, relax your entire body tothe point where you are able to maintain complete control of yourself by keeping calmnessof mind and body between tenseness and limpness. Third, naturally allow the gravitationalpull to settle your entire body down to where it should settle. Lastly, think positively andbe ready for action with a calm and flexible mind without referring to excessive physicalstrength. 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