The eNotes Blog Januarys Study Tip How to Beat the Winter QuarterBlues

Januarys Study Tip How to Beat the Winter QuarterBlues Winter is the cruelest of quarters. One day youre making cheerful and celebrating the new year, the following youre expected to have perused the entirety of your coursework and to ricochet back to understudy existence with the young and deftness of, well, an understudy On the off chance that you feel the winter quarter sads, attempt these brisk tips to remain roused for your classes: 1. Jazz up your apartment Modest and happy are the employable words here. In light of winters brief days and long evenings, your little space can without much of a stretch turn desolate, which thusly will influence your mind-set and how well you concentrate there. Have a go at infusing some additional light with the assistance of a reasonable box of Christmas tree lights. Itll feel like the great winter cheer never left. You can discover other apartment brightening thoughts on this Pinterest board. 2. Put resources into a light treatment box Like above, in the event that you live some place cold getting enough of the suns beams can represent the deciding moment your winter blues. Except if youre sufficiently blessed to live in the daylight express this season, you might need to put resources into a light treatment box for your desk. Mayo Clinicâ has some accommodating data on how theyre used to treat SAD (Seasonal full of feeling issue). You may likewise need to recharge the Vitamin D youll be absent with sustenance or enhancements. 3. Separate an exhausting everyday practice Indeed, schedules can be extraordinary, however in the event that you feel youre falling into a winter quarter droop on account of the everyday drudgery of classes, punctuated uniquely by all the more contemplating and eating times, get out there and discover something amusing to separate your daily practice. You could join a club, apply for a temporary position, tryout for the school play, or plan a trip with companions. Anything that gives you something energizing to anticipate is something worth being thankful for. Also, that, my companions, is the means by which you win winter. Appreciate the season!

U.S. States Ranked by Area

U.S. States Ranked by Area The United States is the universes third biggest nation by region, positioned behind Russia and Canada. Inside that enormous are 50 expresses that differ generally in zone. The biggest state, Alaska, is in excess of multiple times bigger than Rhode Island, the littlest state. Including water highlights, Alaska is 663,267 square miles. Conversely, Rhode Island is an insignificant 1,545 square miles, and 500 square miles of that is Narragansett Bay. A Big Area Does Not Mean a Big Population Texas is greater than California, making it the biggest condition of the 48 adjoining states, however estimated by populace, the rankings are switched. California is the most crowded state withâ 39,776,830 occupants, as per 2017 U.S. Evaluation gauges, while Texas had a populationâ ofâ 28,704,330. The Lone Star State might be making up for lost time, however, with a development pace of 1.43 percent in 2017 contrasted and 0.61 percent for California. At the point when positioned by populace, Alaska drops to 48th spot. Alaska Is Larger Than the Next Three States Combined By region, Alaska is huge to the point that it is bigger than the following three states joined Texas, California, and Montana-and is more than double the size of second-positioned Texas. As indicated by the State of Alaskas official site, its one-fifth the size of the lower 48 states. The Frozen North stretches around 2,400 miles east to west and 1,420 miles north to south. Counting islands, the state has 6,640 miles of coastline (estimated from point to point) and 47,300 miles of flowing shoreline.â Rhode Island Is the Smallest Rhode Island gauges only 37 miles east to west and 48 miles north to south. The states all out limit length is 160 miles. In region, Rhode Island could fit in Alaskaâ nearly multiple times. The following littlest state byâ areaâ is Delaware at 2,489 square miles, trailed by Connecticut, which at 5,543 square miles is multiple occasions the size of Rhode Island and more than double the size of Delaware. On the off chance that it were an express, the District of Columbia would be the littlest at justâ 68.34â square miles of whichâ 61.05 square milesâ is land and 7.29 square miles is water. Enormous Country West of the Mississippi The 10 biggest states by region are found west of the Mississippi River: Alaska, Texas, California, Montana, New Mexico, Arizona, Nevada, Colorado, Oregon, and Wyoming.â 7 Smallest Are in the Northeast The seven littlest states-Massachusetts, Vermont, New Hampshire, New Jersey, Connecticut, Delaware, and Rhode Island-are in the Northeast and are among the 13 unique settlements. The Ranking of States by Area in Square Miles This incorporates water includes that are a piece of that state. The Frozen North - 663,267Texas - 268,580California - 163,695Montana - 147,042New Mexico - 121,589Arizona - 113,998Nevada - 110,560Colorado - 104,093Oregon - 98,380Wyoming - 97,813Michigan - 96,716Minnesota - 86,938Utah - 84,898Idaho - 83,570Kansas - 82,276Nebraska - 77,353South Dakota - 77,116Washington - 71,299North Dakota - 70,699Oklahoma - 69,898Missouri - 69,704Florida - 65,754Wisconsin - 65,497Georgia - 59,424Illinois - 57,914Iowa - 56,271New York - 54,556North Carolina - 53,818Arkansas - 53,178Alabama - 52,419Louisiana - 51,839Mississippi - 48,430Pennsylvania - 46,055Ohio - 44,824Virginia - 42,774Tennessee - 42,143Kentucky - 40,409Indiana - 36,417Maine - 35,384South Carolina - 32,020West Virginia - 24,229Maryland - 12,406Hawaii - 10,930Massachusetts - 10,554Vermont - 9,614New Hampshire - 9,349New Jersey - 8,721Connecticut - 5,543Delaware - 2,489Rhode Island - 1,545

Entrepreneurship for Professionals-Free-Samples-Myassignmenthelp

Questions: 1.Do you truly believe that Entrepreneurs think viably? 2.Do you accept that morals and social duty ought to be a piece of an Entrepreneurship course or did the reading material writers simply remember an area for it to be politically right? 3.What energizes you about being a business person? What are your significant concerns? 4.Search the Internet for three records of effective corporate Entrepreneurship. What key components for progress are normal over these records? Which are extraordinary? 5.Why do good examples Impact the choice of individuals to become Entrepreneurs? 6.Is expanding the Entrepreneurial direction of a firm constantly something to be thankful for? Answers: 1.Yes, Entrepreneurs think efficaciously. This is on the grounds that they are inventive and are not constrained by means and objectives, however can at present consider different choices to accomplish the objective and if not functional a business person will effectively get rid of every one of those choices. I likewise think practically in light of the fact that occasionally I don't have the foggiest idea where to begin from, so I simply center around my character, Knowledge, and Network and get myself a way. This causes me to be prepared for any startling result and sets me up to take advantage of any new lucky break. Be that as it may, in class, we are instructed to think calmly on the grounds that easygoing reasoning is perfect for business visionary wannabes by defining an objective at the top of the priority list and setting out a particular arrangement towards the accomplishment of the objective. This moves us to discover better methods of actualizing the arrangement and achi eving the objective. 2.Yes, I accept that morals and social obligation ought to be an integral part of the business enterprise course for two principle reasons. In the first place, any business visionary originates from a general public like some other individual and should, accordingly, be worried about things that influence the network. Moreover, no business can work outside the general public; hence, every business visionary who originates from the network has the obligation of maintaining the business towards improving or if nothing else keeping up the state of the general public via completing exercises that don't hurt the general public. Furthermore, for functional reasons morals and corporate obligation ought to be instructed in classes. This is on the grounds that the merchandise or administrations from the business are to be offered to clients who should be pulled in first. On the off chance that the business exercises are impeding to the general public, at that point most clients would not accepting the items or administrations of the organization for by so doing they will fill they are propelling the destructive work of the business. Hence, moral and social duty is critical towards the achievement of a business person. 3.Two significant reasons energize me of turning into a business visionary. First is the present pace of joblessness. Besides, it is the longing to chip away at my own timetable. I might want to work for myself so I dont need to languish over absence of occupations yet rather make employments for some jobless individuals who can't bolster themselves. Additionally, the situation of taking requests from my supervisor over and over can be difficult, and an infringement of such exercise may prompt end. Besides, it is my craving to work when I have the psych to in light of the fact that the customary route working from 9 to 5 doesn't misuse my potential completely and on the off chance that it does, at that point, it does to the benefit of my chief. Going into business can empower me to work even around evening time from the solace of my home and furthermore carry on with a fair work life. 4.Three effective records of corporate business enterprise incorporate; Sony, Lockheed Martin, and W.L. Blood. The normal achievement factors among the three organizations are; Management support, hazard taking, authoritative structure and asset accessibility. The one of a kind achievement factor among these three is the board support since all the organizations are effective in view of a thought started by a representative and upheld by the organization with respect to good and money related help. Firms can attempt to embrace a pioneering atmosphere inside a current business, however they can't duplicate the strategies and procedures and grab the essential advantage on the grounds that the hierarchical structure of firms and the innovative condition vary generally. Moreover, the procedures of a given organization are typically licensed, and in this way its unlawful to mimic them in an alternate firm precisely. 5.Role models do influence the chance of individuals turning out to be business visionaries since they offer the declaration that somebody has attempted or been there and along these lines it is possible; in this way there is trust. I think an individual whose parent was a bombed business person is more averse to begin an individual a business contrasted with the one whose guardians were fruitful business visionaries. Be that as it may, this suspicion will rely upon the character and receptiveness of the individual. On the off chance that the individual whose guardians fizzled is friendly and can have the option to persevere through and be predictable, at that point he/she can gain from other fruitful business people. Then again, on the off chance that the individual with effective pioneering guardians does not have these qualities, at that point is more averse to act naturally utilized. 6.Yes, expanding pioneering direction is something to be thankful for, however this relies upon different explicit elements which influence execution. For example, the pace of benefit, return on capital and deals level. In the event that the innovative direction is to expand business execution with respect to productivity, help budgetary objectives in regards to income and pace of profit for capital utilized then its fitting to increment pioneering direction. Be that as it may, on the off chance that the opposite is valid, at that point the administration needs to reevaluate the move first.

Psychoactive Drugs - Free Essay Example

Unit 1 Short Paper Psychoactive Drugs I believe was designed to be used for medical purposes, which I also fee that people who use them are in danger of harming their body and mind. According to news briefs People like Michael Jackson and Jerald Levert also others known people have abused drugs for what reason I can only guess for depression or the stress of being celebrity. Whatever the reasons were they are no longer living due to the drug abuse, so I can only imagine the people who are not famous who are abusing drugs that we don’t hear about or read about but we know they are out there and in need of help especially the ones that are among the living. The drugs that I fear the most that are causing so many problems are alcohol, methamphetamines, Amphetamines, which include oxycontin which has become so popular on the street . Is there an addiction worst than any other addiction ? I don’t think so I feel all addictions are a problem, but I have heard that the crack cocaine is worst addiction to ever surface. Recreational drugs is illegal not really but they do effect the mind and the body then they should be illegal anything more than normal use in excessive use is illegal or done for the purpose of abuse should be illegal. A heron junkie is not lower than a person that consumes marijuana to me. Any addiction is bad and heron users also have made bad choices just as the marijuana user has to me. There are a lot of major substance abuse that I am not familiar with like ecstasy tabs, LSD which I heard about matter of fact I am not familiar with a lot of drug abuse but has been affected by marijuana users, prescription drugs, and crack cocaine. Compulsive disorders is addictive any thing done excessive is a disorder or a behavior problems that the person that is doing them should receive help. Shopping, over eating, gambling, etc. all should be looked on as an addiction.

Basic Supply Chain Strategies and Purchasing Techniques

what are the basic supply chain strategies? Explain each strategy, providing relevant examples. A supply chain strategy is frequently miss-understood with supply chain management, where supply chain actions are controlled to decrease costs, but with supply chain strategy it defines how the supply chain should function in order to compete. Supply chain strategy is an iterative method that evaluates the cost benefit trade-offs of prepared components. A well accomplished supply chain strategy results in value creation for the business. The basic supply chain strategies are many suppliers, few suppliers, vertical integration, keiretsu network, and virtual company. The many suppliers strategy has many sources per item, it has†¦show more content†¦For example buying or ordering something you want that you cannot find it in local stores off the internet. Funds transfer goes with electronic ordering because it is when money is taken from your account (with your consent) and placed into someone else’s account and vice versa you may be receiving money or transferring money to someone else’s bank account. For example you purchase an item of clothing off the internet and in order for the company who has the item of clothing to send it to you, you have to pay for the item first so you wound then proceed to means of payment where you will pay the amount asked for the item with shipping fees if any. Then the money needed for this item will be transferred from your account to the sellers account. PayPal is a company that most internet websites use. Both electronic orders and funds transters Reduces cost by reducing paperwork; also increases the speed of ordering. electronic data interchange Is the controlled transmission of data between organizations by electronic means. It is used by companies to exchange information and to transfer electronic documents and files or business data from one computer system to another computer system, for example from one trading partner to another trading partner without human involvement. EDI has replaced the fax machine and mailing list when it comes to information sharing. Using EDI,Show MoreRelatedHistory Of Green Supply Chain Management1324 Words   |  6 PagesEnvironmentally sustainable (Green) supply chain management has gained attention within the area of industry, because the environmental issue is one of the serious concern for governments. Green supply chain management is one of the key approach for Chinese manufacturing industry to achieve their market share objectives and to make maximum profit for the companies(van Hock and Erasmus, 2000). 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He does this by building and maintaining an effective executive team and by closely monitoring and comparing operational and financial results to forecasts and budgets. In addition to day to day oversight, the director must calculate an operating strategy that steers the company towards its long term objectives, taking appropriate correctiveRead MoreRiordan Manufacturing Supply Chain Design1151 Words   |  5 PagesRiordan Manufacturing Supply Chain Design Shante Moore University of Phoenix/OPS 571 â€Æ' Introduction Riordan Manufacturing is a global plastics manufacturer and industry leader in the field of plastic injection molding with locations in Georgia, Michigan, California, and their most current expansion in 2000 to Hangzhou, China. The plant located in China manufactures fans using a make-to-stock operation that uses a forecasting method to determine future demand. 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Essay on Reiss Three Year Marketing Plan - 4683 Words

1. INTRODUCTION Created in 1979 by David Reiss, Reiss is has developed into a powerful brand offering stylish clothes at affordable prices. 2006 proved to be a successful year for the organization, where it achieved  £6.8 million in operating profit and sales of  £44.5 million. Currently, it has 39 stores worldwide and is expanding rapidly. The following 3 year strategic marketing plan will demonstrate the steps Reiss need to take in order to become a dominant force in the UK and a strong international brand. Keys to success: †¢ E-business development †¢ International expansion †¢ Domestic market growth †¢ Product development †¢ Brand awareness †¢ Organization flexibility 2. SITUATION ANALYSIS 2. 1 MACRO ENVIRONMENT †¢Ã¢â‚¬ ¦show more content†¦Ã¢â‚¬ ¢ Department stores, which have a distribution of 11.7%, have seen a rise in popularity. This can be demonstrated in figure 4. o Threats †¢ Are projected to spend less because of a recent increase in interest rates, which the Bank of England increased to 5.25% on the 11th of January 2007 (BBC News). †¢ Due to inflation, they do not spend as much because of increasing utility bills and mortgages. Women mainly fuelled the booming clothing industry years ago, which was driven by the surge in personal debt, but no longer do a hasty shop, but rather think twice before they purchase clothes. †¢ Although they are more fashion conscious, they have become less brand loyal, especially with competition surging. †¢ Have become more value conscious, meaning they are keen to cheaper alternative, for example. Primark. 2.4 COMPETITOR ANALYSIS †¢ Overview o MS, the Next group, Arcadia, Matalan are market leaders in the UK, which can be observed in figure 5. o By observing figure 6, Reiss is in the range of above average value, at affordable pricing. Its close competitor is Zara, with relation to positioning. †¢ Opportunities o Next is becoming vulnerable, which could open some market share to Reiss. o Reiss has opened 39 stores in total and that is more than close competitors such as Paul Smith, Whistles, and Joseph. †¢ Threats o Marks Spencer is moving gradually moving itself towards theShow MoreRelatedR R Case Study Solution1354 Words   |  6 PagesRamp;R Introduction of Case Study Bob Reiss in 1983 observed with interest the success in the Canadian market of new game board called â€Å"Trivial Pursuit†, The sale of the game in the US tended to be approximately ten times those of sales in Canada since â€Å"Trivial Pursuit† had sold 100,000 copies .Now Reiss thought game make a boom in US market and this make a profitable opportunity for him. 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Performance Appraisal & Management Rewarding-Samples for Students

Question: You are expected to design a reward scheme for UzElectron LLC, a store marketing ENCOM Local Manufacturing Company household appliances on Credit Payment terms, which is launching its operations January 1, 2018. Answer: Introduction In our todays economic world, competition plays a primary role in any business that operates in a free market. The behavior in leadership is core when it comes to the issue of engaging the employees. Involving the employees leads to easier goal achievement since all the workers of a given company have a central goal known to them and hence they strive towards achieving it. An upcoming business has identified a potential market for appliances and hence needs to enter the market. This paper will be visiting the strategies that UzElectron should put in place so as to succeed in its plans and objectives. Overview The leaders in UzElectron will need to make sure that the employees are engaged by making sure that they: Avail a friendly work zone between the workers in UzElectron and the management. Inspire confidence in the future of the business. The latter will be done by encourage the doing more and having less policy(Noe, 2012). Encouraging upward communication with the senior officials. The latter will be meant to bring openness and a situation whereby workers will feel free.it will be the duty of the leaders of UzElectron to make the workers feel that they know everything about their company. To instill high levels of engagement in employees, the UzElectron leaders should be able to understand that their behavior matters a lot in the instillation of high levels of engagement of the employees(Pfeffer, 2013). Internal relationship and training of workers In the workplace that exists today, the performance interrelationship and the duties performed by the management have become a key factor of consideration as far as the performance of an organization is concerned. Businesses have put more pressure on the stakeholders for them to remain active and hence see their survival in the entire market(Noe, et al., 2014). The UzElectron Company is one of these companies that will need to maintain high levels of interrelationship between the business management and the goals of the business with an aim of being efficient and good enough to execute better business strategy. The latter will result to business survival in the market. The human resource professional have a deeper understanding of optimal management system and hence they come across numerous obstacles. Performance management does not only involve the employee performance appraisal but involves many more issues. An appraisal that is properly constructed includes the all year round dialogue(Clarkson, 2014). For the UzElectron performance management to be effective enough, the managers will be required to: Align the particular employee day to day activities with the objectives of the business Give visibility and also the clarification accountability which is related to the goals of UzElectron business Provide a documentation that is required for legal purposes and also for the matter of decision making(Cascio Aguinis, 2014). Make sure that there is a trainer who visits the company regularly to oversee that the workers are updated on the existing technology. They also have to play the following roles for a good performance of UzElectron: Deliverance of regular job feedback. Set and communicate clear performance expectations. Job Analysis and Evaluation The Grading Approach For any pay to be effective enough, it should be tied within the performance. A time based pay will also increase the motivation of the workers in UzElectron and hence increase their performance. Equity in payment. Workers expect to be paid an amount that will cater for the basic needs, have some cash for recreation and then have some cash to keep up with issues to do with inflation. After some time, the workers will want to have the kind of pay that will cater for the retirement benefits. For the case of UzElectron, the company will be small since it will be just in its initial stages, the manager will have to consider squeezing some cash to have the workers feel motivated by paying them money that they would feel is able to cater for their expenditure and also enable them to save(Edgren, 2012). The business stakeholders will also involve the workers in the meetings so that they feel that they belong there and this will lead to the workers doing their job happily. Given that the latter would be put into consideration, the workers will just equalize their pay with the work they do and hence good pay will mean good performance and hence good sales. The business also needs to have different positions for the smooth running and allocation of duties. The following staffs should be identified in the UzElectron Gatekeeper Sales subordinate Sales administrator Manager Due to the variation in job positions, there are some variations in salaries and this will be shown in the table below. ? of Grade Total scores Job position Category of personnel salary for one employee Number of workers Overall expenditure ONE 10-40 Gatekeeper Support staff 200 000 1 500, 000 TWO 40-90 Sales subordinate Junior staff 400 000 4 1,600, 000 THREE 90-150 Sales Administrator Senior staff 600 000 1 600, 000 FOUR 150-210 Manager Administrative staff 1,900, 000 1 1,900 000 Determination of Job Positions Job performance Some individuals have outstanding job performances. In a case whereby there are employees who have an outstanding performance in UzElectron, then they will be rewarded accordingly as this will motivate them to work harder towards achieving greater performances(Carevi?, et al., 2014). Level of employment The kind of a job that is performed in UzElectron will also lead to the disparities in the pay among the workers. Workers will be paid differently from managers simply because of their levels of employment. Labor demand and supply The last thing to consider in UzElectron when giving out salary is the labor demand and supply(Cascio Aguinis, 2014). If the demand for labor is very high, then UzElectron will have to pay the workers a salary that will be slightly higher than their counterparts with an aim of retaining them. With time, the company will consider introducing the promotion pay as people will have to be promoted. Performance appraisal and Management rewarding Different organizations have different processes of reward management. For the case of UzElectron, the company will be required to hire the employees that meet the requirements and then it would go ahead to look at the kind of performance they will be giving out(Conger Kanungo, 2012). The company will need to observe whether the workers have the skills or they need training. The remaining task will be the kind of rewards that the business would give to the employees. After giving out the rewards, it is the duty of the leader to analyze the effects of the reward on the future life of the business. Having a payroll management will help a lot in UzElectron. Payroll management is a term that is used to refer to the tactics of administering the salaries of employees in any given organization. The activities that come up here include the calculation of the salaries of the employees, the deduction of taxes and the disbursement of the wages too. The administration of the salaries of all the employees is not an easy task. The Human resource together with the finance department are required to work together with an aim of calculating and also disbursing the salary to the employees(Conger Kanungo, 2012). Due to the latter reasoning, the payroll management can be subdivided to payroll accounting and payroll administration. Through the employment of the different methods of job e valuation in UzElectron, the business will be able to determine the relevant content and give a value determination of the positions and the equitable compensations which are competitive too(Conger Kanungo, 2012). The content of a job is evaluated on the bases of the type of the job, the skills and the knowledge that is required. The following three kinds of job content should be evaluated in UzElectron Ranking This method will be used to rank each position in the organization from the highest to the lowest. Here, each job is assigned to a particular rank depending on the overall value and the complexity in an organization. The hierarchical flow of in an organization is a good example of the rank method. This method is suitable to the small businesses since it is very simple. This would hence be suitable for UzElectron(Conger Kanungo, 2012). However, it is not easy to maintain in more complex companies. Classification This classification method uses categories or classes of similar jobs. Good example of this include the managerial and the executive, skilled and the semi-skilled. This method goes well with big companies and hence it will not be advisable for UzElectron to adopt it. Point job evaluation The points work assessment strategy utilizes a built up scale - whether tweaked or following a format - of key occupation factors and related most extreme focuses for each position inside your association. Cases of variables incorporate abilities, responsibility and exertion. Each factor may have sub-factors; aptitudes, for example, may incorporate sub-factors, for example, instruction and preparing. When you have endorsed your association wide factors and built up a point outline, evaluate each position entirely(Clarkson, 2014). Occupations are at long last positioned in view of aggregate number of focuses, from most astounding to least, and pay is allotted as needs be. Employments with comparable point adds up to by and large have comparative pay scales. Conclusion For any company that needs to establish itself, following the above structure is essential. The company should be able to employ the workers who have the technical. The employees should also be appraised in accordance to their qualification and performance. Once the above has been met, it will be easy to survive in the market. References Carevi?, M., Ki, P. Kuhta, F., 2014. Minimum Wages as an Obstacle to the Free Provision of Services. 3(1) ed. s.l.:Croatian Yearbook . Cascio, W. F. Aguinis, H., 2014. Applied psychology in human resource management.. s.l.:s.n. Clarkson, M. E., 2014. A stakeholder framework for analyzing and evaluating corporate social performance. Academy of management review. 20(1) ed. s.l.:s.n. Conger, J. A. Kanungo, R. N., 2012. The empowerment process: Integrating theory and practice.. s.l.:s.n. Edgren, G., 2012. Fair labour standards and trade liberalisation.. s.l.:Int'l Lab. Noe, R. A., 2012. Gaining a competitive advantage.. Irwin: McGraw-Hill. Noe, R. A., Hollenbeck, J. R., Gerhart, B. Wright, P. M., 2014. Gaining a competitive advantage.. Irwin: Mcgraw Hill. Pfeffer, J., 2013. Producing sustainable competitive advantage through the effective management of people. The Academy of Management Executive, Volume 9(1), pp. 34-56

What Factors Determine the Vote an Example of the Topic Government and Law Essays by

What Factors Determine the Vote The recent victory of Barack Obama in the United States Presidential Election of 2008 is one of the biggest issues among many other big events that have occurred in America this year. This years election was even more controversial because of the racial issue, which they barely, if at all, had in previous elections. During the course of the campaigns, other candidates may have mentioned the racial difficulties in their speech or public pledge, but no candidate ever represented him-self as a minority. Need essay sample on "What Factors Determine the Vote" topic? We will write a custom essay sample specifically for you Proceed The idea of having a Black President was unthinkable and unimaginable ten years ago. Yet, it must be pointed out that it was only achievable because America is blended by multi-ethnicity, which means America is like a melting pot, where all different races and cultures are mixed in one particular land, often called a country of immigrants. Many other countries aside from than the United States were and still likely to deny minorities as their presidents. This recent success, however, brings into mind the factors that are important for the voters and the issues that are important to them. Given the economic crisis that the United States is experiencing right now, it is clear that one of the most important issues concerns the economy. Many voters are carefully scrutinizing the platforms of these candidates and finding out whether or not they have the interests of the voters at heart. It is oftentimes not enough that these candidates support the voters on the issues but that their plans will be effective because as research has shown all the candidates try to cater to the interests of the majority. The key therefore lies in the policy implementation measures and the manner by which they can achieve these promises. As such, the economic crisis has brought about several challenges for the candidates as they propose their own economic agendas and try to deal with the scenario. It is here that the voters need to choose wisely. The psyche of the voter now no longer concerns itself with the effect of the plan in so much as the political will of the candidate and if such is able to make true on the campaign promises. Though the electorate is much wiser these days, there are still a few issues and factors that cannot be discounted. Another important aspect in any election is the race issue, especially in the United States of America which has several minorities who, put together, are arguably a majority. There is a five percent Asian American population in the United States. However, only two to three percent of those Asian Americans voted during the 2004 election, when George W. Bush was elected again for the president. In the 2004 presidential election, 44% voted George Bush and the rest voted for John Kerry. Since 1996, many Asian Americans are slightly inclined to the Democrats, instead of the Republicans. During George Bushs term, the federal court system appointed an Asian American judge, Kiyo Matsumoto, as a federal judge and this was the second time that Asian American became a federal judge. Sen. Charles Schumer says her appointment to the bench will help close a gender gap in the federal judiciary. Janelle Staci Wong, an expert on ethnicity and politics, political participation and public opinion research, said Further depressing Asian American participation is the fact that only 20 percent of all Asian Americans (compared with 40 percent of non-Latino whites) lived in states considered battlegrounds in 2000 and 2004,, which means that the population of Asian Americans is important but not crucial as the places where all those Asian Americans live. Asian Americans, however, are well known for their unity and their block voting mentality. This resulted from the 1965 immigration reform as well as changes in the nations sociopolitical structure due primarily to global and domestic economic restructuring and neoconservative policy orientation that emerged in the 1970s and became entrenched in the following decade. (Pg.171, What Ties That Bind?), which means Asian American immigrants are not gathered because they share similar cultures or backgrounds, its because of their hatred of racial discrimination among Asian Americans. As such, while platform and political agenda may play an important role in determining the vote of America being able to cater to the races and the minority issues remains to be the most important factor in determining the vote of America. It is not argued that there are other important considerations but it seems that it is still race and the protection of the interests of these minorities that matters. The victory of Barack Obama proves, if anything, that America is a more mature voter these days but it cannot deny the fact that sometimes the minority has a louder voice that the majority listens to. References: Davenport, Christian. State Repression and the Domestic Democratic Peace Cambridge University Press (2007) Leonard Leo, James Taranto, and William J. Bennett. Presidential Leadership: Rating the Best and the Worst in the White House. Simon and Schuster, June, 2004, hardcover, 304 pages, ISBN 0-7432-5433-3 Lijphart, Arend. Patterns of Democracy. Government Forms and Performance in Thirty-Six Countries Yale University Press (1999) Peabody, Bruce G.; Gant, Scott E. (1999). "The Twice and Future President: Constitutional Interstices and the Twenty-Second Amendment". Minnesota Law Review (Minneapolis, MN: Minnesota Law Review) 83 (565).

Business environment case study - Business Advice for Hugos Hats

Business environment case study - Business Advice for Hugos Hats Assumptions: Hugo's Hats produces fashion hats for both male and female customers, price per hat  £100. Trades as a Private Limited Company and started trading as an e-business in 1995.Market Structure is the degree of competition the business faces. There are four market structures as illustrated in figure 1.Figure 1Perfect competition is a theoretical model, it does not exist. It is assumed that there are many buyers and sellers, the goods being sold are homogeneous and there is perfect knowledge in the market.Monopolistic competition is when goods are slightly differentiated in some way, either by advertising or branding or by local production.Oligopoly is when a few suppliers dominate the market.Monopoly is when one supplier dominates 25% or more of output.The following are the main characteristics of Monopolistic competition in which Hugo's Hats are competing:There are quite a large number of firms, as a result, Hugo's hat has only a small share of the market and, therefore, i ts actions are unlikely to affect its rivals to any great extent.Perfectly elastic demandThere is freedom of entry of new firms into the industry. If any firm wants to set up a business of making hats, it is free to do so.Product Differentiation: Hugo's Hats are producing hats and providing customer service that is in some way different from its rivals. The demand curve is downward sloping, i.e. elastic, as customers are given more choice from different suppliers in the market.Profits are maximised: In the short run, Hugo's Hat are producing where marginal costs (change in total costs from one extra hat produced) equals marginal revenue (change in total revenue from selling one more hat).Total cost equals total of variable costs and fixed costs.Total revenue is quantity sold, Q multiplied by price, P.

Planning in Organisation for Creative Workforce Essay

Planning in Organisation for Creative Workforce - Essay Example This suggests that most of the organisations fail to utilise its workforce due to lack of planning leading to employee dissatisfaction. An employee who does not find any motivation into the job he performs, learns nothing out of the routine work, is not rewarded for any outstanding performance, and sees no challenge in his job is less likely to be motivated to work enthusiastically and perform at his best. Bramham (1987) propounds the most important aim of human resource planning in an organisation to foresee future need for employees not only in quantitative terms but also in qualitative manner such as the skills, calibre, performance and attitude required for particular types of jobs. Dessler (1999, p2) says that human resource management is all about devising policies and strategies for the employees working in the organisation. It includes selecting, training, evaluating, appreciating and providing convenient working environment for the employees. It shows that planning for creative workforce is very crucial for the survival and success of an organisation. The organisations use planning to select the kind of personnel it needs, motivate them and retain them towards future enhancement of organisational objectives. The organisations plan to realise organisational needs for workforce in future and take calculated steps to retain its employee through various means. In fact, human resource planning does not only enable an organisation to retain its employees but also to 'treasure' them so that they can gain more creative and efficient workforce. The use of planning by organisation to gain more creative workforce... Planning is the most important aspect of organisational management. Workforce planning is the key to acquire the kind of people the organisation needs and to retain them through various motivating factors such as salary, promotion, job security, learning opportunities, performance appraisals etc. It shows the criticality of organisational planning concerning human resource. Every organisation needs to plan in a proactive manner the labour needs that will arise in future. It will ensure that the organisation strives to attain the employees with suitable skills and attitude to train them for upcoming change. In this way, the organisation will have the 'right team' prepared for challenges when the time actually comes. Mullins (1996) maintains that human resource planning if done in an efficacious manner can enable the organisation to take imperative steps for the enhancement of employee productivity level at the right possible time. It assists the organisation in meeting all the necessary human resource requirements from hiring to firing in a systematic way. This reflects that human resource planning makes an organisation realise the factors undermining the productivity and calibre of its employees keeping them from achieving organisational objectives before it becomes too late. Most of the organisations do not actually plan to acquire highly qualified and skilled labour force, but most often to retain the employees on whom the organisation has already exerted substantial money and time. It mirrors that organisation will risk the creativity of its workforce if it does not properly plan for the development of its employees. Mathis (1997, p314) suggests that, â€Å"development can be thought of bringing about capacities that go beyond those required by the current job†¦As such, it benefits both the organisation and the individual’s career†.

Reviews of the Articles about Global Problems Essay

Reviews of the Articles about Global Problems - Essay Example Soil, which is composed of organic and inorganic components, is an integral part of terrestrial life and many organisms including humans are greatly dependent on this vast resource. The organic or living components which are constituted by thousands of microbes, fungi, nematodes, mites and gophers play a vital role in maintaining soil health and fertility. The organic wastes that are present in the soil are processed by the soil microflora and the resulting nutrients are made available for the plants. Ground water is filtered and cleaned by the soil matter and soil also helps to retain atmospheric dust and other pathogens thereby contributing to cleaner air. Soil is also a major determinant of atmospheric carbon dioxide levels. Man-made activities such as plowing and soil changes due to erosion and neglect can result in the release of excessive amounts of carbon dioxide in to the atmosphere. Agricultural practices such as tillage can deprive the soil of essential organic nutrients an d the addition of fertilizer chemicals, pesticides and herbicides further deplete the soil nutrients. The large number of concrete layered on top of the soil in urban areas, heavy machines and pollution cause extensive and at times irreversible damages to soil life. The desert conditions in Africa are mainly due to extensive grazing and agriculture which has resulted in degradation of the top soil. The author further adds that unhealthy soil can also cause several human diseases. The increasing global warming poses a great threat to the biodiversity of the soil which can be adversely affected even with the slightest change in temperature and moisture. The author has also included the views of soil experts Eric B. Nelson and Diana H. Wall who respectively believe that soil... The essay "Reviews of the Articles about Global Problems" analyses eight articles by eight different authors about such global problems as like the effect of increasing carbon dioxide quantities on global warming, threats to soil life from globalization and industrialization, the harm of pesticides to the environment and the effect of technological advancements on humanity. For example, the article â€Å"The hidden world under our feet† by Jim Robbins focuses on soil life and the numerous threats that it faces due to globalization and industrialization around the world. Soil, which is composed of organic and inorganic components, is an integral part of terrestrial life and many organisms including humans are greatly dependent on this vast resource. The organic or living components which are constituted by thousands of microbes, fungi, nematodes, mites and gophers play a vital role in maintaining soil health and fertility. Another article â€Å"A Change in temperature† by Justin Gillis analyses the effect of increasing carbon dioxide quantities on global warming. Recent findings suggest that global temperature change is a more slow process and humans would be able to adapt to these changes. The major issue under consideration is about the sensitivity of the climate to increasing carbon dioxide concentration in the atmosphere. Earlier in the 19th century, Svante Arrhenius estimated the earth’s average temperature to increase by nine degrees Fahrenheit, though, now it is likely to be between three to eight degrees Fahrenheit.

Country blues Essay Example for Free

Country blues Essay Blues evolved from an unaccompanied vocal music and oral tradition of African-American slaves and rural blacks in to a wide variety of styles and subgenres with regional variations across United States and later Europe and Africa. The musical forms and styles arose in the same region during the nineteenth century in the southern United States The country blues has been given several names such as folk blues, rural blues, backwoods blues, or down home blues. Blues is a choral and instrumental form of composition which is based on the use of the blue notes. This style originated in the Africa – American (Black Americans) communities of the United States. This kind of music transverse wide range of emotions and musical style . feeling blue is expressed in songs whose verses laments injustice or express longing for better life lost loves, jobs, and money. The central concept of blues performance is to be able to enable one to overcome sadness and lose the blues. Historically, the blues’ popularity coincides with the rise of the commercial recording industry, the introduction of race records aimed at black record –buyers after the year 1920, and the emigration of the black- Americans from the rural south to the modern urban North. (Philip, 1999) The country blues is usually considered to be an earlier form of the genre was first record in the mid-1920s . to day, there are several regional styles of country blues, which includes delta blues from the Mississippi delta. Texas blues and piedmont blues from the southeast . originally, country blues was usually recorded by a single singer, accompanied on the guitar or piano, with perhaps an accompanying harmonica, simple percussion. Starting year of 1930s, blues musicians fell under the influence of the urban cultures thus including the music and jazz. After the Second World War, the instruments were improvised hence electrified one were now in use . these included saxophones and amplified harmonicas. Especially in Chicago which is a prominent centre of blues recording Country blues were constructed from a much more diverse fluid musical field participated in by black and some white people. The use of blue notes and the performance of call-and response pattern in the music and lyrics art h indicators of African influences. The blues influenced the Americans and westerns popular music and then become integrated n to the genre of jazz, bluegrass, rhythm and blues, rock and roll, hip- hop and other popular music form. There are a few characteristics common to all blues due to the integration of other forms of music . some of the characteristic that were present long before the creation of the modern blues are cal –and response shouts which were functional expression. This was heard in slave fields shout sand holler, expanded into simple solo song laden with emotional content. The blues is nowadays known and seen musical style for both Europeans harmonic structure and the West Africa. Call-and responds tradition, transformed into interplay of voice and guitar. (Philip, 1999) The diddled bow ,which is a homemade one- stringed instrument was found in parts of America south in the early twenties century and Are African derived instrument that has assisted in the transferring of African performance techniques into the early blues instrumental vocabulary. also in the continued development of the blues music ,they adopted elements from Ethiopian and negro, including instrumental and harmonic accompaniment . he blues were loosely relate to ragtime but they preserved better the original melodic pattern of African music. ’ blues songs nowadays show many different structures which are based on tonic dominant chords and subdominant chords. These are all common in music the standard 12-bars is now recognized and documented form of blues from oral history and sheet music in African American communities through region along the lower Mississippi river. Original lyric form if blues was a single line repeated four times. The current most common structure is the repetition off one line once and this is followed by a single line conclusion. Early blues often were in the form of lose narrative where the singer expressed his or her personal woes in a world of harsh reality like a lost love, the cruelty of police officers, oppression at the hands of white folk, and hard times therefore the most oldest blues are records of gritty realistic information’s as it is in contrast with much popular music recorded at the time. Studies shows that the origin of blues spirituals was inside the exposure of slaves to their whites hence gospels origination. (Tony, 2004) The development of the blues was also triggered by the acculturation of the ex-slave population there was however ,essential africannesss in many aspects of the blues expression the social economic reasons for the appearance of the blues is that there was a transition from the slavery to sharecropping ,small-scale agricultural production and the blues have acted as a source of encouragement to them through the relief of third burdens through the interest that other communities have development, they get encourage to be the pioneers of impacting and framed kid f music thus they used in themes way in advertisements. The early 1900s development from group performance to more individualized style was associated with the newly acquired freedom of the enslaved people and again there was, according to Lawrence, there was a direct relationship between the national ideological emphases upon the individual teaching. Such developments were increased due to high perfumers had brought African-American music to new audiences both within the u. s and abroad. Great performers’ in19960s like John Lee Hooker continued to perform at enthusiastic audiences thus inspiring new artists in the traditional blues. Many compilations of classical prewar blues were published and together with music festivals, these brought blues to new audiences. White audiences’ interest in the blues also increased due to Chicago based movement in 1980s, blues to The resent both traditional and new genres are still being popular blue styles forms ,melodies and the blues scale have given a profound impact to the black community and the world ethnic groups as whole . First, these blue musical styles, forms and melodies have influenced many other genres of music. their scale has been everywhere in the popular music forms and informs many modal frames especially the ladder of the thirds used in the music . blues are also used by the community to pass their message to oppressors which I believed has lead the release of slave and the total banning of slavery and racism in the United State. (Davis, 1995) The most important direct predecessor of the blues was the spiritual, a form of religious song with its roots in the camp meeting of the great awakening of the early 19th century. So blues songs Spirituals were passionate song forms, which convey to listeners the same feeling of rootless ness and misery as the blues. This acts as a reminder of there past historical events hence their pasts grieves, . i. e. , Spirituals, however, were less specifically concerning the performer, instead about the general loneliness of mankind, and were more figurative than direct in their lyrics. Despite the earlier differences of the African- Americans and the Americans races have been brought together to interact by the interesting blues music. Blues have played important role of bring unity between the two enemies. The blues form styles acts as way of maintaining the vulture of Africans. This is evidence from the past records which still are much thrilling to many musicians. Though the different forms of blues are similar enough that they can not be easily separated many spirituals would probably have been called blues had that word been in wide use at the time. The social and economic reasons for the appearance of the blues are also important factors. This is because they brought a change in the economic development through the emergence of publishing industry. Blues has evolved from an unaccompanied vocal. Music of poor black laborers into a wide variety of styles and subgenres, with regional variations across the United States and this has been commercialized. (Davis, 1995) References Davis, F. (1995): the History of the Blues. New York: Hyperion Garofalo, R. (1997): Rockin Out: Popular Music in the USA. Allyn Bacon Lawrence W. L. (1977): Black Culture and Black Consciousness: Afro-American Folk Thought from Slavery to Freedom, Oxford University Press Philip, V. B. (1999): Immigrant, folk, and regional music in the twentieth century, in The Cambridge History of American Music, ed. David Nicholls Cambridge University Press Tony, B. (2004): Afro-Blue: Improvisations in African American Poetry and Culture University of Illinois Press

Custom Essays: Ophelia as a Sexual Being -- GCSE English Literature Cou

Ophelia as a Sexual Being in Hamlet      Ã‚  Ã‚  Ã‚   In Elaine Showalter's essay, "feminist criticism allows Ophelia to upstage Hamlet [and] . . . brings to the foreground . . . the cultural links between femininity, [and] female sexuality" (221). In most of his plays, William Shakespeare has many women in secondary roles, only filling dead space or causing strife between men. During Shakespeare's time, thoughts of women bordered on weak and deceitful images, leading to the idea of frail, yet conniving creatures. In Hamlet, the character Ophelia uses her sexual prowess as a source of power when dealing with the opposite sex. As she weaves her way through the background of the play, she affects the men greatly to become a main focus when critiquing the literary work. Interpretations of Ophelia vary based on the experts' view of sexual importance. The influence she has over Hamlet's emotions and desires affects the outcome of their faltering relationship and Hamlet's sanity. Viewing Ophelia as a sexual being, one can sur mise that she embodies the very essence of female sexuality. Kenneth Branagh's 1996 film version of Hamlet portrays Ophelia as a siren: natural, beautiful, and the perfect object of male desire. In Elaine Showalter's essay and Kenneth Branagh's film, the representation of Ophelia gives strong evidence regarding the sexuality Ophelia emanates and her effect on the men surrounding her despite her five short scenes in the play. Ophelia's overzealous sexuality, uncommon in those "moral" days, constitutes an image of madness and impropriety ending in her tragic death by her own hand.    With the strong sexuality Ophelia radiates, even her brother Laertes cannot resist her charms. Speaking with Ophelia, Laertes warns h... ...h her fire and passion. William Shakespeare produces this female character, which becomes the most important heroine in all of his literary works. As a symbol for women everywhere, Ophelia depicts the importance of using the power one has to make a difference in one's own life.      Works Cited Hamlet. Dir. Kenneth Barnagh. Perf. Kenneth Branagh, Kate Winslet, Brian Blessed, Richard Briars, Julie Christie, Billy Crystal, Derek Jacobi, Michael Maloney. Castle Rock, 1996. Showalter, Elaine. "Representing Ophelia: Women, Madness, and the Responsibilities of Feminist Criticism." Hamlet. Ed. Susanne L. Wofford. Boston: Bedford Books of St. Martin's Press, 1994. 220-238. Wofford, Susanne L., ed. Case Studies in Contemporary Criticism, William Shakespeare: The Tragedy of Hamlet, Prince of Denmark. Boston: Bedford Books of St. Martin's Press, 1994.   

Breach of Employment Contract Essay

The case involves a claim that Baril, the appellant, was dismissed by Aiken Regional Medical Centers, the Hospital where she previously worked, and such dismissal constitutes a breach of the employment contract between Baril and the Hospital. The contract the parties were referring to was the â€Å"Associate Handbook† she received from the Hospital, which contained the personnel polices of the Hospital that governed her employment. Baril was terminated for making a call through the Hospital’s toll-free number, as a result of which he was deemed to have committed a violation of the Hospital’s rules and policies, which merited her immediate termination. Baril argues that the Hospital itself breached the employment contract by unjustly terminating her employment. The Court of Appeals of South Carolina began its discussion by stating that the general rule on employment contracts is that contracts of employment are â€Å"at-will† contracts. This means that the contract is terminable at the pleasure of either party, at any time, regardless of the existence or non-existence of a justifiable ground for the termination. However, the existence of an employee handbook is recognized as an exemption to the general rule. Such a handbook may create an employment contract, depending on the terms stated therein. Where the handbook contains ambiguous clauses such as disclaimers, the issue of whether it could constitute an employment contract has to be determined by a jury, and not by summary judgment. The court noted that while the handbook explicitly states that it does not change the nature of the employment contract as an at-will contract, it does provide strict procedures to be followed in disciplinary cases such as the one where Baril is concerned. Thus, the Hospital’s procedures and practices give rise to more than one reasonable inference concerning the creation of an employment contract. Concomitantly, we find the trial court erred in granting summary judgment on the issue of whether Hospital’s policies found in its employee handbook, amendments, and actual practices created an employment contract between Baril and Hospital. The court also determined that the employment contract established by the Hospital’s practices and procedures requires that there be an existing just cause for termination. The criterion for determining justness in the termination of Baril’s employment rests on the existence of a â€Å"reasonable good faith belief that sufficient cause existed for termination. † Weighing the arguments of both Baril and the Hospital, the court concluded that reasonable minds could differ as to the whether there was good or bad faith in the Hospital’s termination of Baril’s employment. Therefore, the case could not have been settled using the rules on summary judgment. Attached: Case: http://www. sccourts. org/opinions/HTMLfiles/COA/3561. htm THE STATE OF SOUTH CAROLINA In The Court of Appeals Marolyn L. Baril, Appellant, v. Aiken Regional Medical Centers, Respondent. Appeal From Aiken County Rodney A. Peeples, Circuit Court Judge Opinion No. 3561 Heard October 8, 2002 – Filed October 28, 2002 REVERSED and REMANDED Herbert W. Louthian, Sr. , and Deborah R. J. Shupe, both of Columbia, for Appellant. Richard J. Morgan and Reginald W. Belcher, both of Columbia, for Respondent. ANDERSON, J. : Marolyn L. Baril appeals the Circuit Court’s order granting summary judgment to Aiken Regional Medical Centers (Hospital) on Baril’s action for breach of employment contract. We reverse and remand. FACTS/PROCEDURAL BACKGROUND Baril joined Hospital’s nursing staff in 1986. She earned a master’s degree in nursing administration from the University of South Carolina in 1990. The following year, Baril was named director of Hospital’s emergency department. Baril resigned from that position for personal reasons in 1992, but continued as a staff nurse in the emergency department. Holly Martinez de Andino eventually succeeded Baril as director of Hospital’s emergency department. John Arnold [1] and Martinez de Andino indirectly supervised Baril. In early 1993, Baril began teaching nursing classes on a part-time basis at the University of South Carolina’s Aiken campus (USC-Aiken). She joined the faculty on a full-time basis later that year. Baril received an â€Å"Associate Handbook† from Hospital in May of 1997. She signed an acknowledgment form provided by Hospital, indicating she would familiarize herself with the handbook and that she understood the handbook â€Å"constitute[d] the personnel policies of [Hospital] and that [she was] governed by them. † The handbook and acknowledgment form contained disclaimer language: Please Read! Important Employment Information The information contained in this booklet is designed to serve only as a reference to Aiken Regional Medical Centers policies and procedures. Aiken Regional Medical Centers reserves the right to amend this guide as necessary at any time, with or without prior notice. Current hospital policies and procedures will apply in all cases. Please remember that this booklet does not constitute a contract between you and Aiken Regional Medical Centers. Employment at Aiken Regional Medical Centers is on a voluntary basis and either you or the Facility may terminate this employment relationship at any time with or without reason or prior notice. No associate of Aiken Regional Medical Centers has the right to make verbal promises or commitments which may create a contract and thereby alter the â€Å"employment at will† relationship. (Emphasis added). Additionally, the handbook’s â€Å"Recruiting and Hiring† section included similar language: In no event shall a hiring of an associate be considered as creating a contractual [re]lationship between the associate and the Facility; and, unless otherwise provided in writing, such relationship shall be defined as â€Å"employment at will,† where either party may dissolve the relationship. (Emphasis added). However, the acknowledgment form states that â€Å"the information in [the] handbook is subject to change/revision† and â€Å"any change will be communicated through the usual channels. † The handbook incorporated a detailed, progressive disciplinary procedure. Two categories of offenses were specifically identified. The categories were bifurcated: (1) actions meriting immediate termination; and (2) actions warranting termination for continuous violations. In July of 1998, Martinez de Andino disciplined Baril for allegedly slamming a door in Arnold’s face and disagreeing with Hospital’s management regarding a management issue. [2] Baril was first suspended and later given a â€Å"final† written warning. Yet, the handbook’s procedure mandated use of a â€Å"final† written warning only after two previous warnings. Baril had not previously been warned or disciplined. Baril asked Hospital to change her work status from full-time to part-time in November 1998. She continued to teach full-time at USC-Aiken. Baril initiated a grievance pursuant to Hospital policy. Hospital’s chief executive officer, Richard H. Satcher, investigated Baril’s complaint and found sufficient cause to purge the disciplinary action from Baril’s employment file. As a condition to purging her employment file, Satcher required Baril and Martinez de Andino to meet with Hospital’s director of human resources, Richard Lowe, and director of nursing, Mary Ann Angle. The purpose of the meeting was to â€Å"clarify understandings and expectations† regarding Baril and Martinez de Andino’s working relationship. In January of 1999, Baril met with Martinez de Andino, Lowe, and Angle to discuss problems between Baril and Martinez de Andino. During the meeting, Baril expressed concern that Martinez de Andino had targeted Baril for termination which Martinez de Andino intended to accomplish using the disciplinary procedure. Lowe responded that Hospital had updated pertinent portions of its employee handbook to prevent the disciplinary procedure from being abused to eliminate employees and to ensure that it would only be used to positively impact its employees. Lowe delivered a copy of the new policy to Baril. Regarding its purpose, the policy stated: To set standard operating procedures in order to ensure that all associates are fully aware of the conduct expected of them. This policy will also ensure fair and consistent treatment to associates if violations of these standards of conduct occur. This policy is based on the concept of increased severity in disciplining associates who repeatedly violate hospital rules while performing work for the hospital or while on hospital premises. Written counselings are given for initial, minor infractions of rules; if the infractions continue harsher discipline is enforced. However, situations which are so serious that they require immediate stern disciplinary action will not follow a progressive concept. [Hospital] reserves the right to administer disciplinary action as it deems appropriate for the circumstances involved. (Emphasis added). The new policy provided: â€Å"Discipline is an instrument for changing unacceptable performance or behavior, and for providing motivation and encouragement for disciplined associates. † The new policy described four general categories of disciplinary offenses, ranging in degree of seriousness from greatest (critical offenses) to least (minor offenses). The category of â€Å"critical offenses† included actions that constituted â€Å"serious violations of rules or associate misconduct which justify immediate termination without regard to the associate’s length of service or prior conduct. † The new policy contained various examples of critical offenses. It specified in section 2. 2. 2 of HR116 that actions of â€Å"[d]ishonesty, fraud, theft (regardless of the amount), [or] unauthorized removal of hospital property† were examples of critical offenses. At the end of the meeting, Baril and Martinez de Andino signed a document identifying â€Å"expectations† concerning Baril’s and Hospital’s obligations to each other. The details of the document consisted of expectations related to performance and communications. On July 6, 1999, Baril suffered injuries when a cabinet fell on her while at work. She immediately sought treatment for injuries involving muscle strain, subperiosteal hematoma, and an impinged nerve. Baril filed an accident report and claim for Workers’ Compensation benefits at the time of the accident. Four days after her accident, on July 10, 1999, Baril traveled to Tacoma, Washington, for a vacation. When Baril arrived, she received a telephone message indicating Hospital called her sister in an effort to contact Baril. In response, Baril called Hospital on its toll-free number and asked to speak to someone in her department. After a brief conversation with a coworker, Baril asked the coworker to transfer her call to her sister’s home in Aiken. Baril informed her sister that she had arrived in Washington safely, and asked why Hospital wanted to talk to her. Baril’s sister offered to call Hospital to ask why it had contacted her to try to reach Baril. However, Baril declined her sister’s offer. According to telephone company records, the call lasted thirty-two seconds. No evidence exists in the record concerning the cost of the call or whether Hospital sustained any economic loss as a result of the call. Baril returned from vacation on July 17, 1999. When she reported to work the following day, Baril was told to meet with Arnold and Martinez de Andino. At the meeting, Baril learned that by using Hospital’s toll-free number for personal use, she violated section 2. 2. 2 of Hospital Policy HR116, which cites â€Å"[d]ishonesty, fraud, theft (regardless of amount), unauthorized removal of hospital property,† as â€Å"critical offenses† justifying immediate termination. Baril offered to pay for the telephone call, but Arnold refused to accept payment and informed her she was being terminated. Baril exited the premises a short time thereafter. Baril filed this cause of action averring (1) Hospital created a contract of employment between Baril and itself through its written employee handbook, its amendments to the handbook, and its conduct regarding the handbook’s policies, particularly the mandatory language of the disciplinary procedure in HR116 and verbal assurances provided by Lowe during the January 1999 meeting; (2) Hospital breached the contract between Baril and itself by wrongfully terminating her; and (3) Hospital violated S. C. Code Ann.  § 41-1-80 (Supp. 2001) by terminating Baril in retaliation for filing a Workers’ Compensation claim. Baril sought $403,508 in actual damages, plus costs and other just and proper relief. Hospital answered, generally denying Baril’s allegations and claiming it â€Å"acted in good faith† when dealing with Baril’s discipline and termination. Hospital specifically asserted that Baril was an at-will employee throughout her employment with Hospital, and denied the existence of an employment contract. Hospital further claimed that, even if any employment contract existed, Hospital never breached it and that Baril’s discharge was not wrongful. Hospital cited Baril’s own conduct as the source of â€Å"any and all of the employment actions that [Hospital] took against [Baril]. † Additionally, Hospital maintained that Baril â€Å"failed to meet [Hospital’s] established work standards, stole [Hospital’s] time and possibly money when making an impermissible telephone call, and violated at least one of [Hospital’s] specific written Company policies for which [Hospital’s] action was a stated remedy of the violation. † Finally, Hospital contended Baril failed to mitigate any damages she might have sustained. Hospital moved for summary judgment, arguing no material issues of fact existed and Hospital was entitled to judgment as a matter of law. The Circuit Court conducted a hearing on the motion and issued an order finding: (1) Hospital’s policies did not constitute an implied employment contract as a matter of law, even when viewed in the light most favorable to Baril; (2) even if Hospital’s policies constituted an implied employment contract, Hospital’s actions did not breach the contract because it acted pursuant to the express terms of the alleged contract and because Baril’s interpretation of the alleged contract was â€Å"strained and unreasonable and would have led to absurd consequences†; (3) Hospital did not breach any alleged contract because on the date Hospital terminated Baril it had a â€Å"reasonable, good faith belief that, pursuant to the language of HR 116, it had sufficient and just cause to terminate [Baril’s] employment†; (4) Baril failed to establish a retaliation claim because she â€Å"based this cause of action merely upon her own self-serving, unsup ported opinions and the temporal proximity between the filing of her workers’ compensation claim and her termination of employment†; and (5) Baril failed to mitigate her damages because she â€Å"did nothing to seek employment or mitigate damages in any way. † The Circuit Court dismissed all of Baril’s claims with prejudice. STANDARD OF REVIEW When reviewing the grant of a summary judgment motion, the appellate court applies the same standard which governs the trial court under Rule 56(c), SCRCP: summary judgment is proper when there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law. Fleming v. Rose, 350 S. C. 488, 567 S. E. 2d 857 (2002); Ferguson v. Charleston Lincoln Mercury, Inc. , 349 S. C. 558, 564 S. E. 2d 94 (2002). In determining whether any triable issue of fact exists, the evidence and all inferences which can reasonably be drawn therefrom must be viewed in the light most favorable to the nonmoving party. Faile v. South Carolina Dep’t of Juvenile Justice, 350 S. C. 315, 566 S. E. 2d 536 (2002); McNair v. Rainsford, 330 S. C. 332, 499 S. E. 2d 488 (Ct. App. 1998). If triable issues exist, those issues must go to the jury. Young v. South Carolina Dep’t of Corrections, 333 S. C. 714, 511 S. E. 2d 413 (Ct. App. 1999). Summary judgment is not appropriate where further inquiry into the facts of the case is desirable to clarify the application of the law. Vermeer Carolina’s, Inc. v. Wood/Chuck Chipper Corp. , 336 S. C. 53, 518 S. E. 2d 301 (Ct. App. 1999). All ambiguities, conclusions, and inferences arising from the evidence must be construed most strongly against the moving party. Bayle v. South Carolina Dep’t of Transp. , 344 S. C. 115, 542 S. E. 2d 736 (Ct. App. 2001). Even when there is no dispute as to evidentiary facts, but only as to the conclusions or inferences to be drawn from them, summary judgment should be denied. Hall v. Fedor, 349 S. C. 169, 561 S. E. 2d 654 (Ct. App. 2002). Moreover, summary judgment is a drastic remedy which should be cautiously invoked so no person will be improperly deprived of a trial of the disputed factual issues. Lanham v. Blue Cross and Blue Shield, 349 S. C. 356, 563 S. E. 2d 331 (2002); Trivelas v. South Carolina Dep’t of Transp. , 348 S. C. 125, 558 S. E. 2d 271 (Ct. App. 2001). ISSUES I. Did the Circuit Court err in granting summary judgment on the issue of whether Hospital’s written policies and actual practices created an employment contract between the parties? II. Did the Circuit Court err in granting summary judgment on the issue of whether Hospital’s actions in terminating Baril’s employment breached a contract between the parties? III. Did the Circuit Court err in granting summary judgment on the issue of whether Baril acted reasonably in attempting to mitigate her damages? LAW/ANALYSIS I. Existence of Employment Contract Baril maintains the Circuit Court erred in granting summary judgment because, viewing the evidence in the light most favorable to Baril as the nonmoving party, material issues of fact exist concerning whether Hospital’s written policies and actual practices created an employment contract between Baril and Hospital. We agree. South Carolina recognizes the doctrine of employment at-will. Prescott v. Farmers Tel. Coop. , Inc. , 335 S. C. 330, 516 S. E. 2d 923 (1999). This doctrine provides that a contract for permanent employment is terminable at the pleasure of either party when unsupported by any consideration other than the employer’s duty to provide compensation in exchange for the employee’s duty to perform a service or obligation. Id. â€Å"At-will employment is generally terminable by either party at any time, for any reason or no reason at all. † Prescott, 335 S. C. at 334, 516 S. E. 2d at 925. However, an employer and employee may contractually alter the general rule of employment at-will, thereby restricting the freedom of either party to terminate the employment relationship without incurring liability. See Small v. Springs Indus. , Inc. , 292 S. C. 481, 357 S. E. 2d 452 (1987). For example, an employee handbook may create a contract altering an at-will arrangement. Id. Because an employee handbook may create an employment contract, the question of whether a contract exists is for a jury when its existence is questioned and the evidence is either conflicting or admits of more than one inference. Conner v. City of Forest Acres, 348 S. C. 454, 560 S. E. 2d 606 (2002) (stating summary judgment is inappropriate in most instances when handbook contains both a disclaimer and promises). The presence of promissory language and a disclaimer in the handbook make it ambiguous and subject to more than one interpretation. [3] See Fleming v. Borden, 316 S. C. 452, 450 S. E. 2d 589 (1994) (stating that a handbook containing both a disclaimer and promissory language should be viewed as inherently ambiguous). Here, the handbook states that it does not operate to change the at-will nature of employment to a contractual relationship. However, the handbook’s procedures concerning progressive discipline, discharge, and grievance are couched in mandatory terms, including assurances that the procedures will be followed. As to Lowe’s statements regarding the new disciplinary policy, Baril testified: Richard Lowe told me, guaranteed me that the new disciplinary policy was put into effect for exactly that reason because I told Richard, I said, you know, I have been a manager, and you can use a disciplinary procedure to try to eliminate people or try to help people grow and have positive behaviors and goals and grow. And Richard Lowe said that is what that policy is for, is to help you, and that is what is going to be happening from this point forward, and I felt that that was a guarantee, was a contract, a verbal contract that I would be treated equitably, that I would be—that I would not be targeted any further, that the grievance was over, and we were to go forward. And so I felt at that time that that was a contract that was made . . . . Thus, the court concluded that the procedures and practices established by the Hospital was more than sufficient for it to arrive at the conclusion that an employment contract was created between the parties. II. Hospital’s Actions in Terminating Baril’s Employment Baril claims the Circuit Court erred in granting summary judgment because, viewing the evidence in the light most favorable to Baril as the nonmoving party, material issues of fact exist regarding whether Hospital’s actions in terminating her employment breached an employment contract between Hospital and Baril. We agree. When an employment contract only permits termination for cause, the appropriate test on the issue of breach focuses on whether the employer had a â€Å"reasonable good faith belief that sufficient cause existed for termination. † Conner v. City of Forest Acres, 348 S. C. 454, 464, 560 S. E. 2d 606, 611 (2002) (emphasis added). â€Å"[T]he fact finder must not focus on whether the employee actually committed misconduct; instead, the focus must be on whether the employer reasonably determined it had cause to terminate. † Id. at 464-65, 560 S. E. 2d at 611. a. Reasonable Good Faith In the January 1999 meeting, Baril expressed concern that Martinez de Andino disliked her and would use Hospital’s disciplinary process to terminate her. Lowe responded that Hospital had updated pertinent portions of its employee handbook to prevent the disciplinary procedure from being abused to eliminate employees and to ensure that it would only be used to positively impact its employees. Nevertheless, reasonable minds could disagree as to whether Hospital proceeded to act in reasonable good faith by using the disciplinary policy to immediately terminate Baril for using the toll-free line to transfer one possibly business-related telephone call to Baril’s sister for thirty-two seconds. Additionally, our Supreme Court has held that summary judgment should not ordinarily be used to resolve the question of whether an employer acted under a reasonable good faith belief that sufficient cause existed for termination. Conner, 348 S. C. at 465, 560 S. E. 2d at 611-612. Viewing the evidence in the light most favorable to Baril, we find that reasonable minds could differ as to whether Hospital acted with good faith in terminating Baril. b. Sufficient Cause Hospital alleges it followed its disciplinary policies in terminating Baril. Hospital contends Baril’s request that her call on Hospital’s toll-free line be transferred to her sister’s private residence constituted an act of â€Å"dishonesty, fraud, theft (regardless of amount), unauthorized removal of hospital property. † Thus, Hospital avers Baril demonstrated violation of a â€Å"critical offense† meriting immediate termination. However, Hospital never announced a policy against use of its toll-free telephone line by employees for personal or private business, although the written materials of Hospital purported to communicate policies and changes to Hospital employees. Furthermore, Baril declared that other Hospital employees had engaged in similar behavior without Hospital’s objection, thereby raising the possibility that Hospital tacitly condoned the practice. Assuming, arguendo, that Hospital rightfully concluded such employee use of its toll-free telephone lines for private purposes constituted dishonesty, fraud, or theft sufficient to merit immediate termination under its policy, evidence exists that Baril’s telephone call to her sister originated in matters related to her employment at Hospital. Moreover, Hospital failed to produce any evidence that it suffered a loss related to the telephone call. In addition, Hospital rejected Baril’s good-faith efforts to compensate Hospital for any loss it may have sustained for the thirty-two second call, although Hospital’s undisputed practice was to permit employees to reimburse it for private long-distance telephone calls. The Circuit Court determined â€Å"no evidence showed or even suggested that [Baril] ever reimbursed or attempted to reimburse Hospital for any of these calls. † A cursory reading of the record contradicts this finding. First, the phrase â€Å"any of these calls† wrongly implies that Baril made more than one call, contrary to undisputed evidence that she only made one call at issue. Next, the record is replete with testimony from Baril and Lowe that Baril immediately offered to reimburse Hospital for any expenses related to the telephone call. Hospital maintains Baril abused her authority by ordering a subordinate to transfer the telephone call outside the Hospital. Yet, the record contains no evidence that Baril had any subordinates at the Hospital at the time she placed the call. In fact, the employee whom Baril asked to transfer the call was only considered a subordinate by the trial court because she had previously been one of Baril’s nursing students. Viewing the evidence in the light most favorable to Baril, we conclude her actions constituted a mere peccadillo at worst and that reasonable minds could differ concerning whether Hospital terminated Baril with just cause. III. Mitigation of Damages Baril claims the Circuit Court erred in granting summary judgment because, viewing the evidence in the light most favorable to Baril as the nonmoving party, material issues of fact exist concerning whether she made reasonable efforts to mitigate her damages. We agree. A party injured by the acts of another is required to do those things a person of ordinary prudence would do under the circumstances, but the law does not require him to exert himself unreasonably or incur substantial expense to avoid damages. McClary v. Massey Ferguson, Inc. , 291 S. C. 506, 354 S. E. 2d 405 (Ct. App. 1987). Whether the party acted reasonably to mitigate damages is ordinarily a question for the jury. Id. Baril did not seek other employment throughout this litigation. However, she attempted to justify her behavior. First, she testified she did not want to reveal to potential employers that she had been fired. Second, she testified that there were no other hospitals with emergency rooms in or near Aiken, where she resided. Thus, she would have been forced to either commute or relocate in order to perform similar work. Baril did not want to relocate because she had a home and family in Aiken, where she taught college classes on a full-time basis. Baril speculated that a lengthy commute would interfere with her teaching career. Considering the evidence in the light most favorable to Baril, reasonable minds could disagree over whether she made reasonable efforts to mitigate her damages. The trial court should have allowed this question to be resolved by a jury. CONCLUSION Accordingly, the trial court’s decision is REVERSED and REMANDED. CONNOR and STILWELL, JJ. , concur. [1] John Arnold’s specific job title is unclear in the record, which indicates he operated in a supervisory capacity similar to that of Martinez de Andino. [2] Shortly before Martinez de Andino initiated the July 1998 disciplinary action against Baril, a dispute arose between them concerning Martinez de Andino’s decision to hire paramedics to perform nursing functions in the emergency room. Baril learned from the South Carolina Department of Health and Environmental Control that South Carolina law prohibited paramedics from performing some of the functions that Martinez de Andino intended for them to perform. Baril conveyed this information to Martinez de Andino, who told Baril to â€Å"deal with it. † Baril contends Martinez de Andino resented Baril’s input, leading to a souring of their relationship that motivated her to seek Baril’s termination. [3] Baril and Hospital clearly disagree about the existence of a contract.

Phishing An Example Of Social Engineering Techniques...

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