Positive nonverbal messages Essay Example for Free

Positive nonverbal messages Essay From the way we dress to the way we move, our nonverbal signals can reveal a great deal about our emotions, perceptions and intentions. When a person is talking or listening, he sends continuous messages consciously or unconsciously through his body movements, such as the way he holds his head, the angle at which he hold his body, his movements of limbs and his changing facial expressions. This kind of communication in which no verbal language is used comes under the category of non verbal communication. According to Knapp Hall (2002) non verbal communication refers to communication that is produced by some means other than words, e. g. , eye contact, body language or vocal cues. The significance of nonverbal communication, in establishing interpersonal relationships, is far greater than any one can think of. According to experts, a substantial portion of our communication is nonverbal. On the basis of its effect nonverbal communication can be classified under following three categories. 1. POSITIVE NONVERBAL COMMUNICATION Positive nonverbal messages puts the other person at ease. When a person expresses an open and positive attitude towards the person with whom he is interacting, it creates a supportive and collaborative atmosphere. Use of positive non-verbal communication helps a person to become more effective and successful. It significantly affects the level of interpersonal relationship. It also determines the overall impression people form about a person. There are several types of positive non verbal indicators. For example turning face to the sender, leaning slightly forward towards him indicate that he is interested. , Nodding to express understanding, smiling or touching the person gently are other types of positive non verbal cues. The eye contact is most effective non verbal cue to achieve the goal of gaining someone’s trust. The way one uses his body and limbs, his eyes and face, will have a major influence on how his non verbal messages are perceived. 2. NEGATIVE NONVERBAL COMMUNICATION Sometimes non verbal body movements, gestures and facial expressions generate disinterest distrust. It creates a state of confusion on the part of the receiver. The type of communication which comes under the above category is known as negative nonverbal communication. Negative nonverbal messages hampers collaborative and supportive environment. To ensure effective communication one must avoid giving such type of cues. Staring or gazing at other can create pressure and tension between the receiver and the sender. Negative facial expression, shifty eyes, too much blinking suggest deception Eyebrow muscle draws the eyebrows down and toward the center of the face if someone is annoyed. Talking to someone without maintaining the eye contact is distracting and often interpreted as insulting. If a person keeps talking on phone or keeps working on the computer during the conversation, it shows that he is not interested. 3. NEUTRAL NONVERBAL COMMUNICATION –This is the type of nonverbal communication which have neither positive or negative effect on the receiver. The type of body movements , postures and tone which have neutral effect on the receivers feelings and emotions comes under this category. It is very difficult to label any non verbal cue as neutral. People attach meaning even to a neutral message. During listening one rarely can stay silent for long, silence in some instances may be treated as neutral non verbal communication. If it lasts more than for 5-6 seconds then it turns into a negative cue. Sounds like ‘Mmm’, ‘Ah’ and ‘Hmmm’ when used in a neutral way invite learner to continue talking. CONCLUSION Sending clear nonverbal messages and understanding correctly the message send by someone, largely depends upon the way how you are perceiving the total situation, and the person with whom you are communicating. Your mind set and the environment in which the communication is taking place also determine how you interpret and react to the non verbal messages. Interpretation of the messages depends upon past experiences,feelings, attitude and socio cultural background of the receiver. Communication can be misperceived if the source and the receiver does not share common experiences and common frame of reference. REFERENCES Knapp,M. L Hall, J. A (2002) Non Verbal Communication in Human Interaction, Crawfordsville, IN : Thompson Learning Smith,T. E, Gartin B. C, Murdick, N. L, Hilton,A (2006) : Positive Indicator Of Non Verbal Communication Pearson Allyn Bacon Prentice Hall retrieved on 13th May,2010 Windle,R Warren, S Communication Skills retrieved on 13th May 2010 from http://www. directionservice. org/cadre/section4. cfm

Marks and spencers as an international retailer

Marks and spencers as an international retailer Marks and Spencer, known as M S, is one of the biggest retailers in the world. It has around 150 stores in 30 countries, including 130 franchises operating across the globe. Though it is very popular for its clothing chains in the United Kingdom, M S is also known for its multi-million pound food industry. M S also sell home furnishings, footwear and gifts other than clothing and food. In the United Kingdom alone it has 450 stores and under the trademark St. Michael, it has a chain of 294 stores. Almost all the companys overseas branches are locally franchised. M S owns the United States of Americas Brooks Brothers and King Super Markets. To meet the demands of the customers the company gets facilitated by Direct Mail. The companys core objectives of meeting the customer expectation and giving consumers easier and better access to a wide list of products. The financial services for the customers are provided by the groups financial services which comprise of the unit trust manage ment, life insurances etc. M S in recent years suffered a succession of adversities, both at home and abroad. The sales of the company have dropped. The market capitalization and stock prices reduced substantially and the overseas profits have tremendously declined. As a result the company was forced to form a marketing department in January 1999 and become more proactive and market driven. M S followed a very simple marketing philosophy for a very long time. That is to produce high quality products under a recognised brand and advertise through the word-of-mouth. But in the recent past, this advertising strategy has come under criticism as the company started losing its competitive touch. The challenge now is to develop a good marketing strategy and emerge from the slump to reposition M S as a fierce global competitor in the international arena. Internationalization Strategy of M S The internationalization of the M S began in the early 1940s. It is because the company started to feel that the domestic market has been saturated and the expansion has to come from abroad. Unlike most of the firms, M S began to export its products on the brand name St. Michael as a way to test the waters. It has been successful and the company was exporting about $1,146,000 worth of products by 1955. Externally, the members of a local labour party were suggesting nationalizing the leading domestic retailers. Sooner as a tool of diversification, some international franchising relationships were formed. This franchising allowed the company to achieve global presence with minimum political and economic risks. As the relations of the company grew with other global countries, MS choose to invest directly (FDI). MS uses various types of foreign entry around the world. But mostly the company believes in opening its own stores in major economies. It has its own stores in Belgium, Canada, France, Germany, Spain and Netherlands; and franchises in Cyprus, Israel, Bermuda, etc. when forming international alliances; it often prefers an experienced retailer in that particular country. Its first joint venture was established in Spain as it felt the cultural distance and market power of its co company will help to mitigate the political climate and behaviour of the company. Its international strategies in Spain yielded successful results which helped it to gain popularity in the global markets. Through franchising, its approach was mostly top-down. That is it has a centralised management which could not be better off in various marketing situations. Hence it was forced to change its internationalization strategies through foreign direct investment. Due to this there is a forced change in its technolog y, cultural behaviouring and regional promoting aspects. MS started to open stores in America, Far East and Europe. In different parts it has slightly different operational strategies depending upon the host countries values. In America it used acquisitions with Brook Brothers (clothing company), in Europe it has its direct stores running and in Far East, some stores were run with franchise and others through direct investment. Following a wide range of strategy reviews of its business, board of MS announced in 2001 significant changes to its strategies. The important decisions in its strategy are: Expansion in growth of profitable products. Acceleration of store renewal program Being close to the customer More intensive use of space Release value from half the property portfolio Cost cutting. MS has a wide range of returns on food products and has earned customer trust. So it decided to invest its major investment in food, home and beauty products. Its other plan was to accelerate the renewal of store renewal. Under this, it planned to refurbish more stores faster at the lower cost. It also reallocated to higher growth product areas to maximise returns per sqft. Apart from these strategic changes, it uses direct investment in global sectors which gained them a competitive advantage. Factors affecting MS strategy There are various factors which has a certain impact on the MS internationalization strategy. Of them, technology has been one of the factor in which the company was forced to change its strategy in various countries. But broadly speaking, in this fast developing technological world, technology used by Ms is been available where ever it opened its stores. A small adjustment to the technical functioning of a store is enough for the company to have its strategy working. The most important factor that has its resemblance in the formulation of internationalization strategy is geography and distance. As the marketing strategy of MS is universal, however it does not mean that it uses similar strategies in all parts of the world. There is a large effect of globalisation to the formulation of internationalization strategies. Consumers from various countries are different due to varying culture, economic development, and income level and so on. So in certain cases MS does not use its centralised operating strategies instead it combines with some other company through mergers but has its own standards running. This initial phenomenon of outsourcing and then after some recognition opening its own store had a significant upward success in MS organization. As marks and spencer is generally known for its clothing and food products, the locality of the company is very important. As MS runs its stores in different countries, transportation of the products has to be done in a prà ©cised manner such that there is no shortage. So in order to overcome this transportation and time differences, MS has its own outlets in specific countries. These outlets have immediate access to the supply of products whenever required. There are certain situations where it cannot have its own outlets due to some government policies and other factors. In these cases, marks and spencer uses its internationalization strategy of franchising. So that it has its own functionality running by other company. All these have significant impacts in the brand distribution globally. Apart from these, government trade policies also play a part in the strategy formulation. Given the growing links among nations, it is very difficult to consider domestic policy without considering international repercussions. In the case of formulating its strategy in US, bilateral negotiations are carried out covering wide range of products, services and investments. Such a policy should pursue the government to facilitate competitiveness and encourage collaboration among companies in the areas of goods and process technologies. MS is an UK company where the marketing conditions have to be emphasized by the government and the product is socially accepted. Also great emphasis is placed on efficiency by government policies. Where as in US and Far East countries, they regard individualism and the promotional appeals should be relevant to the individual to incorporate lower power distance within the market. Also the main advantage of Marks and Spencer government policy is that it had an opportunity of taking advantage of NAFTA (North American Free Trade Agreement) in US. It takes advantage of tax under this agreement and is outsourcing its products to Mexico and Canada. It also has an advantage of making economic sense in terms of logistics. The important policy priorities for the tax Policy Action Group (PAG) in the future include: The Tax Framework for Business The Value Added Tax The National Insurance Contributions M S will be benefitted over the above made policies by the government. The idea is to focus on the oversight and the management of the policy implications in indirect tax, company tax, personnel tax and customs duty. Conclusion The conventional wisdom on development of the developed companies like MS has focused on learning from mistakes. The leading MS Company showed that their high risk strategy of acquisition and direct investment can yield successful results backed up with technology, and cultural values. The insights from the study on MS suggest that overseas expansion is related to the need to improve global competitiveness in order to boost their outsourcing capabilities. No matter the distance and differences between the countries, MS has been the successful organization to open its companies in different countries and make them profitable ones. The only important aspect for it is to make a minimum number of changes to the functioning and marketing aspects depending upon the country in which it is operating in. thus from the above analysis it can be understood that the globalization strategy of MS created a new marketing paradigm in its success and also gained superior advantage and reputation irres pective of the host country policies and other factors. Hence it is clear from the strategies of an MS company that we live in a truly globalised economy where differences across countries are given little importance in development.

Sources Of Finance For Kfc Finance Essay

Sources Of Finance For Kfc Finance Essay KFC began with Colonel Harland Sanders. He discovered his penchant for cooking when he was only 9 years old. Through the years he grew up to become a personage the world knows as Colonel Sanders, founder of KFC. He reached celebrity status in 1952, when he decided to franchise his famous Kentucky Fried Chicken recipe blends of 11 herbs and spices to the rest of America. By the early 70s, that special recipe reached Malaysia. KFC Holdings owns approximately 27 Kedai Ayamas and 4 Ayamas Depots, making them the nations first branded chicken and chicken-based retain chain. KFC Holdings operates the KFC chain of restaurants in Malaysian, Singapore and Brunei (523 restaurants) and the Rasamas chain of restaurants in Malaysia (about 37 outlets). Sources of finance are where finance comes from. There are three kinds of sources which are Bank loans, Owners (share) capital and Trade credit . Finance is money which is a scarce resource. To obtain it, a business has to compete for it. Individuals, the government and other businesses all seek money to finance their needs. Those with money to lend will lend it provided the rate of return (interest), the risk and flexibility (how quickly the money can be repossessed) are consistent with their expectations. The word lend often implies to short-term; the word invest implies to long-term. Individuals or organisations that lend money, expect to get their money back, with a fixed annual return in a comparatively short time. Those who invest in a company become part-owners share holders. They expect regular payment of cash dividends (whose size varies with the companys success) plus an increase in the value of their shares. A major source of finance for many businesses is the retained profit from sales to customers. A business just starting up or one expanding rapidly has to raise its finance from other sources. There are three kind of finance question which relates the finance which the management should consider. Duration: for how long is the finance required? Cost: which source of finance is the least expensive? repayment: what level is acceptable Duration Duration depends on the reason the money is needed. No-one would take out a 25 year mortgage to finance the purchase of a personal HiFi. Few people would buy a house with a bank overdraft. Businesses apply the same principles of matching the purpose of finance with the source of finance. This makes sense all round. For the business it ensures that finance is guaranteed as long as it is needed. For the investor it ensures that adequate security is available for the duration of the loan as in the case of a 20 year loan secured against a property that will continue to have value for all the 20 years. Cost In general, businesses look for the cheapest source of finance. The easiest way to compare the cost of finance is to express the annual payment to lenders/investors as a percentage of the amount of finance provided. Interest on a loan can be expressed in percentage terms. So can the rate of return to shareholders. Return on investment in shares = Dividend per share, share price change since the start of year The rate of return expected by shareholders becomes the cost to the business of using this form of finance. Repayment A business should not get into a position where all of its profits are being swallowed up in interest payments. There is a real danger of borrowing too much. The same applies to individuals. Type of sources of finance: government purchase loan stock leasing venture capital hire purchase ordinary shares warrant retailed earning borrowings Ordinary Shares Ordinary shares also known as common stock or voting share is a share of stock giving stockholders the right to vote no matters of corporate policy and the composition of the members of the board of directors. Ordinary shares are issued to the owners of a company. They have a nominal or face value, typically of RM1 or 50 cents. The market value of a quoted companys shares bears no relationship to their nominal value, except that when ordinary shares are issued for cash, the issue price must be equal to or be more than the nominal value of the shares. Preference Shares Preference shares, also called preferred stock or preferred shares, is typically a higher ranking stock than common stock, and its terms are negotiated between the corporation and the investor. Preference shares usually carries no voting rights, but may carry priority over common stock in the payment of dividends and upon liquidate Preference shares may carry a dividend that is paid out prior to any dividends being paid to common stock holders. Preference shares may have a convertibility feature into common stock. Preference stockholders will be paid out in assets before common stockholders and after debt holders in bankruptcy. Terms of the preferred stock are stated in a Certificate of Designation. From the companys point of view, preference shares are advantageous in that:  · Dividends do not have to be paid in a year in which profits are poor, while this is not the case with interest payments on long term debt (loans or debentures).  · Since they do not carry voting rights, preference shares avoid diluting the control of existing shareholders while an issue of equity shares would not.  · The issue of preference shares does not restrict the companys borrowing power, at least in the sense that preference share capital is not secured against assets in the business. Loan Stock Common or preferred stock shares that are used as collateral to secure a loan from another party.  The loan will earn a fixed interest rate, much like a standard loan, and can be secured or unsecured.  A secured loan stock may also be called a convertible loan stock if the loan stock can be directly converted to common shares under specified conditions and with a pre-determined conversion rate, as with an irredeemable convertible unsecured loan stock (ICULS).   Retained Earnings Retained earnings refer to the portion of net income which is retained by the corporation rather than distributed to its owners as dividends. Similarly, if the corporation makes a loss, then that loss is retained and called variously retained losses, accumulated losses or accumulated deficit. Retained earnings and losses are cumulative from year to year with losses offsetting earnings. Retained earnings are reported in the shareholders equity section of the balance sheet. Companies with net accumulated losses may refer to negative shareholders equity as a shareholders deficit. A complete report of the retained earnings or retained losses is presented in the Statement of retained earnings or Statement of retained losses. The major reasons for using retained earnings to finance new investments, rather than to pay higher dividends and then raise new equity for the new investments, are as follows: a) The management of many companies believes that retained earnings are funds which do not cost anything, although this is not true. However, it is true that the use of retained earnings as a source of funds does not lead to a payment of cash. b) The dividend policy of the company is in practice determined by the directors. From their standpoint, retained earnings are an attractive source of finance because investment projects can be undertaken without involving either the shareholders or any outsiders. c) The use of retained earnings as opposed to new shares or debentures avoids issue costs. d) The use of retained earnings avoids the possibility of a change in control resulting from an issue of new shares. Borrowings Receiving something of value in exchange for an obligation to pay back something of usually greater value at a particular time in the future. Borrowings are divided into three terms. Short term lending may be in the form of: a) An overdraft, which a company should keep within a limit set by the bank. Interest is charged (at a variable rate) on the amount by which the company is overdrawn from day to day; b) A short-term loan, for up to three years. Medium-term loans are loans for a period of from three to ten years. The rate of interest charged on medium-term bank lending to large companies will be a set margin, with the size of the margin depending on the credit standing and riskiness of the borrower. A loan may have a fixed rate of interest or a variable interest rate, so that the rate of interest charged will be adjusted every three, six, nine or twelve months in line with recent movements in the Base Lending Rate. Longer-term bank loans will sometimes be available, usually for the purchase of property, where the loan takes the form of a mortgage. Leasing Leasing is a process by which a firm can obtain the use of a certain fixed assets for which it must pay a series of contractual, periodic, tax deductible payments. The lessee is the receiver of the services or the assets under the lease contract and the lessor is the owner of the assets. The relationship between the tenant and the landlord is called a tenancy, and can be for a fixed or an indefinite period of time (called the term of the lease). The consideration for the lease is called rent. There are two basic forms of lease: operating leases and finance leases. Operating leases Operating leases are rental agreements between the lessor and the lessee whereby: a) The lessor supplies the equipment to the lessee b) The lessor is responsible for servicing and maintaining the leased equipment Finance leases Finance leases are lease agreements between the user of the leased asset (the lessee) and a provider of finance (the lessor) for most, or all, of the assets expected useful life. Suppose that a company decides to obtain a company car and finance the acquisition by means of a finance lease. A car dealer will supply the car. A finance house will agree to act as lessor in a finance leasing arrangement, and so will purchase the car from the dealer and lease it to the company. The company will take possession of the car from the car dealer, and make regular payments (monthly, quarterly, six monthly or annually) to the finance house under the terms of the lease. Hire Purchase Hire purchase is the legal term for a contract developed in the United Kingdom. It is also called closed-end leasing. In cases where a buyer cannot afford to pay the asked price for an item of property as a lump sum but can afford to pay a percentage as a deposit, a hire-purchase contract allows the buyer to hire the goods for a monthly rent. When a sum equal to the original full price plus interest has been paid in equal installments, the buyer may then exercise an option to buy the goods at a predetermined price (usually a nominal sum) or return the goods to the owner Venture Capital Venture capital (also known as VC or Venture) is a type of private equity capital typically provided for early-stage, high-potential, growth companies in the interest of generating a return through an eventual realization event such as an IPO or trade sale of the company. Venture capital investments are generally made as cash in exchange for shares in the invested company. It is typical for venture capital investors to identify and back companies in high technology industries such as biotechnology and ICT (information and communication technology Franchising Franchising is a method of expanding business on less capital than would otherwise be needed. For suitable businesses, it is an alternative to raising extra capital for growth. Franchisors include Budget Rent-a-Car, Wimpy, Nandos Chicken and Chicken Inn Other possible alternatives can be used by KFCH KFC Holdings have been running their operation with all the types of source of finance as stated above. In order to further enhance themselves as well improving their investors relations, they can apply other kind of source to run their business KFC has not issue warrants throughout the financial year. Warrants are, in effect, options granted by the business that entitle the holder to subscribe for a specified quantity of ordinary shares, for a specified price at, or after, a specified time- usually several years following their issue. The business would usually issue the warrants in one of two ways, that is to sell them, in which case it would derive a cash inflow, or attach them to a loan stock issue as a sweetener or incentive to investors to take up the loan stock. Apart from that, KFC can even issue Employees Share Option Scheme at various options. An employee share scheme is one way to give employees a stake in your business and help  improve its performance. As employees normally have to remain with the business to get this benefit, share schemes encourage loyalty and can help you retain valued staff. They act as an incentive or reward and may also help recruitment. (Extracted from Business Link, http://www.businesslink.gov.uk/bdotg/action/layer?topicId=1074472937) In fact, KFC could even use hire purchase to source their finance. Hire purchase is referred to sales promotion device that creates customers purchasing power in the form of a fixed cost, fixed period installment loan, secured by a lien on the purchased item as the collateral. In case of capital equipment, the customer repays the loan from the earnings generated by the purchased asset (which otherwise would have remained unsold due to the customers lack of cash). During the repayment period the buyer has the possession and use but not the ownership (title) to the item. Only upon the full payment of the loan, the title passes to the buyer. Also called installment buying, it is a social innovation that expands the economy with additional income. (Extracted from Business Dictionary.com, http://www.businessdictionary.com/definition/hire-purchase.html) APPENDIX Share capital From the financial statement for the year 2008, KFC holdings issued 1,000,0000 new ordinary shares valued RM1.00 each for the year 2008 and 2007. . However, only 198,275 shares at RM 1.00 each was issued and fully paid. SHARE CAPITAL Number of Ordinary Shares of RM1 each Amount 2008 2007 2008 2007 2008 2007 000 000 RM000 RM000 Authorised At 1 January/ 31 December 1,000,000 1,000,000 1,000,000 1,000,000 Issued and fully paid At 1 January/ 31 December 198,275 198,275 198,275 198,275 Retained Earnings The percentage of net earnings not paid out  as dividends, but retained by the company to be reinvested in its core business or to pay debt. It is recorded under shareholders equity on the balance sheet. The formula calculates retained earnings by adding net income to (or subtracting any net losses from) beginning retained earnings and subtracting any dividends paid to shareholders: KFC Holdings recorded RM 316,703,000 of retained earnings in year 2008 compared to RM 257,611,000 in year 2007 for company. This shows that KFC retained their net earnings higher in year 2008 so that they can reinvest in its core business to pay its debt. Borrowings Borrowings are classified under short term borrowings and long term borrowings. KFC Holdings borrowed RM 20,000,000 in year 2008 while there were no borrowings for the year 2007 under company. On the other hand, KFCs long term borrowings amounted to RM 40,000,000 in year 2008 compared to RM 60,000,000 in year 2007. The total borrowings for the two years were RM 60,000,000 respectively. (Refer note: 26) The term loans granted to the Company are secured by the following: i First and third party charge over certain land and buildings as disclosed in Note 12(b) and Note 15 ii Deposits pledged with licensed banks as disclosed in Note 18 iii Corporate guarantee of the Company and a related company iv Debenture of a subsidiarys assets Company 2008 2007 RM000 RM000 Short term borrowings Secured Term loans 20,000 Unsecured Term loans 20,000 Long term borrowings Secured Term loans 40,000 60,000 Unsecured Term loans 40,000 60,000 Total borrowings Secured Term loans 60,000 60,000 Unsecured Term loans 60,000 60,000 Leasing KFCs leasing is analysed as long term leasehold land and short term leasehold land. The groups long term leasehold land notched RM 63,733,000 in 2008 compared to RM 63,868,000 in 2007. However, their short term leasehold land was RM 68,000 in 2008 while in year 2007, it was RM 73,000. Overall, their total leasing was RM 63,841,000 and RM 63,941,000 for the two years respectively. Leasehold land with an aggregate carrying value of RM30, 434,000 (2007: RM30, 822,000) are pledged as securities for borrowings. Group 2008 2007 RM000 RM000 At 1 January 63,941 62,687 Addition 1,830 Disposal (106) Acquisition of a subsidiary 722 Reclassification from property, plant and equipment 333 Amortisation for the year (822) (803) At 31 December 63,841 63,941 Analysed as: Long term leasehold land 63,773 63,868 Short term leasehold land 68 73 63,841 63,941 INCOME STATEMENTS FOR THE YEAR ENDED 31 DECEMBER 2008 Group Company Note 2008 2007 2008 2007 RM000 RM000 RM000 RM000 Revenue 3 2,179,788 1,730,371 97,220 88,000 Cost of sales 4 (1,064,548) (770,048) Gross profit 1,115,240 960,323 97,220 88,000 Other income 22,615 22,797 30,210 26,972 Administrative expenses (118,670) (109,061) (28,757) (22,713) Selling and marketing expenses (837,547) (712,109) Other expenses (6,622) (24) (2,310) (26,229) Operating profit 175,016 161,926 96,363 66,030 Finance costs 5 (7,559) (11,302) (2,887) (5,823) Profit before tax 6 167,457 150,624 93,476 60,207 Income tax expense 9 (47,107) (45,081) (9,522) (23,437) Profit for the year 120,350 105,543 83,954 36,770 Attributable to: Equity holders of the Company 118,535 1 04,269 Minority interests 1,815 1,274 120,350 105,543 Earnings per share attributable to equity holders of the Company (sen): Basic, for profit for the year 10 59.8 52.6 BALANCE SHEETS AS AT 31 DECEMBER 2008 Group Company Note 2008 2007 2008 2007 RM000 RM000 RM000 RM000 Assets Non-current assets Property, plant and equipment 12 615,059 529,658 19,750 19,908 Investments in subsidiaries 13 354,250 353,590 Investment properties 14 898 2,000 585 Prepaid land lease payments 15 63,84 1 63,941 Intangible assets 16 69,835 68,063 Other investment 17 4,500 Fixed deposits 18 6,324 6,324 749,633 674,486 374,000 380,407 Current assets Inventories 19 158,474 112,312 Trade and other receivables 20 128,112 78,972 222,742 156,642 Other investment 17 20,203 Cash and bank balances 21 97,985 140,358 6,797 11,826 404,774 331,642 229,539 168,468 Total assets 1,154,407 1,006,128 603,539 548,875 Equity and liabilities Equity attributable to equity holders of the company Share capital 22 198,275 198,275 198,275 198,275 Other reserves 23 47,705 50,963 22,080 26,560 Retained earnings 24 446,178 352,783 316,703 257,611 692,158 602,021 537,058 482,446 Minority interests 10,232 6,920 Total equity 702,390 608,941 537,058 482,446 Non-current liabilities Retirement benefit obligations 25 3,313 3,758 Borrowings 26 65,944 110,907 40,000 60,000 Deferred tax liabilities 27 31,602 25,036 107 444 100,859 139,701 40,107 60,444 Current liabilities Retirement benefit obligations 25 623 Borrowings 26 75,111 12,080 20,000 Trade and other payables 28 275,424 242,110 6,374 5,985 Current tax payable 3,296 351,158 257,486 26,374 5,985 Total liabilities 452,017 397,187 66,481 66,429 Total equity and liabilities 1,154,407 1,006,128 603,539 548,875

Should Surrogate Motherhood be Allowed? Essay -- essays research paper

Surrogate Motherhood is when one women carries to term the fertilized egg of another woman. This procedure is chosen by married couples who can not conceive a child in the â€Å"natural way†. In some occasions the mother may be able to produce an egg, but has no womb or some other physical problem which prevents her from carrying a child. Whether or not the husband can produce a large amount of sperm is not a problem. Once the egg and sperm are combined in a petri dish fertilization is very likely to occur. The couple will then choose a surrogate mother and make an agreement in which she will carry the baby and release it to the genetic parents after the birth. There are four different kinds of surrogacy arrangements. Total Surrogacy is when the woman bears a child that has been formed from the gametes of another woman and man and implanted in her body. Partial Surrogacy occurs when the birth mother contributes the ovum and the sperm is introduced by artificial insemination. She is a biological parent of the child. Commercial Surrogacy means a business-like transaction where a fee is charged for the incubation period. Lastly, there is a Non-Commercial Surrogacy in which there is no formal contract or any payment to the birth mother. It is usually an arrangement between close friends or family members.(1-10) There is no federal policy on the issue of surrogacy, all fifty states have been left to decide theses issues themselves and create their own policies. The majority of the states have not yet legislated on this subject. Those states that have taken positions differ greatly from one another, such as California and Virginia, who have taken opposing viewpoints California is the state that is the most sympathetic to the genetic parents. Under California law surrogacy agreements are enforceable and the genetic parents are given all legal parental rights to the child. In Virginia, all legal parental rights to the child are given to the surrogate mother. Who is the legal mother? In the case of Johnson v. Calvert, in Virginia, the surrogate mother was found to be the legal mother of the child. If this case would have taken place in California, the biological mother is the legal mother. So it really depends on which state the act of surrogacy is taking place to name the legal mother. Are contracts for surrogate motherhood enforceable under American law? Again, i... ... both expert medical and psychological evaluations. Another major question that arises is whether or not the commissioning parents have the right to tell surrogate mother how to live? Can the couple ban smoking, control alcohol, and other substance intake? These issues need to be taken into mind before choosing a surrogate mother and needs to be stated in the contract.(1-2) In conclusion, surrogate motherhood raises many legal and ethical dilemmas, especially that of who the legal mother is. Surrogate motherhood dramatically alters society norms and creates many different legal viewpoints. But no matter which legal body is dealing with this issue, they all face the same moral and ethical dilemma: that a child born out of surrogacy has a bond with both the genetic mother and the surrogate mother. The bond between these two women and this child is permanent and cannot be changed by law. The law can only govern which woman has the legal right to raise the child. Works Cited Centre Points, Volume 1, No. 1, Article #2, Surrogate Motherhood and its Human Costs, Suzanne Rozell Scorsone, Ph.D. ;1-2 Johnson v. Calvert, 5 Cal. 4th 84, 851p.2d 776, 19 Cal. Rptr. 2d 494 (1993); 1-10

Progression and the Structure of The Blue Hotel :: Blue Hotel Essays

Progression and the Structure of The Blue Hotel In his essay, Robert F. Gleckner discusses progression, as it is related to the structure of "The Blue Hotel." He follows the progression of power and control in the story, as it shifts to different characters. Gleckner also follows the progression of the storm outside and how it symbolizes a natural force that will always be more powerful than human control. In the beginning of "The Blue Hotel," Scully has the power, as he "practically makes [his three guests] prisoners. They are "conducted" into the Blue Hotel. At this time the Swede feels weak and nervous in the unfamiliar territory and scared of "The West." Scully shows his power over the paranoid Swede by saying, "If anybody has troubled you I will take care of him. This is my house. You are under my roof, and I will not allow any peaceable man to be troubled here." As the story progresses, Scully loses control, and the power shifts to the Swede. Gleckner states, "With his final gesture of warm comradeship, the offer of his private whiskey, Scully loses control completely. . .the Swede regains control of himself and will now try to extend it, like Scully, to all men." When they return to the card game the Swede shows his control subtly by sitting where he wants and getting his own drink. Scully tries to regain his control by talking about the guests "under his roof," but the Swede continues to exert his power by insisting on another game High-Five. During this next game, control shifts between characters. Gleckner writes, "the cowboy and the Swede whack the board in violent control; Johnnie cheats to control; the Easterner allows the others to control by remaining silent." During the fight as well, each character tries to gain control, "Scully by refereeing, the cowboy by restraining the Swede, the Easterner by pleading to end the fight, all thr ee of them by cheering." As these shifts of control occur, Gleckner analyzes the storm. He writes about how "Crane suggests a greater force imminent, ready to take over at any moment. . .The storm takes over, dashing the cards 'helplessly' against the wall, ripping words away from the lips of Scully and the Swede, overshadowing and surrounding the entire fight." Gleckner believes Crane is showing that even as the human characters fight for control, there will always be a more powerful natural force.

Lt. Colonel Jay R. Jensens six Years In Hell :: essays research papers

Lt. Colonel Jay R. Jensen's "Six Years In Hell" The book I have chosen to read for this review is one entitled "SIX YEARS IN HELL." It is a book written by one Lt. Colonel Jay R. Jensen in a first person manor. He was a military pilot who flew over Vietnam and was captured and taken as a POW. This book covers his time in the military before hand describing the daily procedures etc. of his military life. The author graduated from Jordan High School in Sandy, Utah in 1949. He then joined The Utah Air National Guard during the Korean war. Mr. Jensen was on active duty for 20 months, after which he attended Brigham Young University. He graduated with a B.S. degree in Accounting and majors in Banking and Finance. After college he obtained the rank of cadet Colonel in the Air Force ROTC. Lt. Colonel Jensen was well decorated after his retirement in 1978 that concluded 28 years of service. His decorations included: Two Silver Stars, Legion of Merit, Bronze Star with V for Valor, Air Medal, two Purple Hearts, Presidential Unit Citation, Air Force Outstanding Unit Award with two Oak Leaf Clusters, POW Medal, Good Conduct Medal, National Defense Service Medal with Oak Leaf Cluster, Vietnam Service Medal with 14 Bronze Campaign Medals, Air Force Longevity Award (for over 24 years), Armed Forces Reserve Medal with Hour Glass Device (for 20 years), Small Arms Expert Marksmanship Ribbon, Vietnam Cross for Gallantry with Device, and Republic of Vietnam Campaign Medal. All these decorations and the time spent in the military I believe more than present his qualifications for writing this book. This book that he was so qualified to write I must bend to say was rather well written. The author took time to explain everything individually and even those things that seem quite trivial were given careful explanation. If there was something that the author felt was not apparent or was not to be taken at face value he footnoted it at the bottom of the page. These footnotes were especially helpful for those of us readers who may not be that "militarily inclined." I particularly enjoyed the story of Roscoe the base's mascot which was probably one of the longest examples of footnoting throughout the book. The book is written from the perspective of the author at the time he experienced it. The descriptions are so well written that one can almost see or relate to what is being described, but as time progresses you can tell the author's moods change as the mode of descriptions differs.

Critically discuss the extent to which the duty to make reasonable adjustments has eliminated discrimination and inequality of opportunity faced by disabled individuals

Introduction The Government described the duty to make reasonable adjustments as â€Å"a cornerstone of the [Equality] Act and requires employers to take positive steps to ensure that disabled people can access and progress in employment.† On the face of it, this should have resulted in a decrease of disability discrimination in the UK, unfortunately has not been the case. This essay will critically discuss the extent to which the introduction of reasonable adjustments has been successful in the UK, and whether or not the duty to make reasonable adjustments has eliminated discrimination and inequality of opportunity faced by disabled individuals. This essay will focus upon disability and employment as its main point of reference to highlight any discrepancies between non-disabled and disabled people in the workplace. Background to the Equality Act 2010 Disability is defined in the Equality Act 2010 in Section 6(1) as meaning a physical or mental impairment, which adversely affects normal day-to-day activities, with the adverse effect needing to be substantial. Instead of a list of disabilities that are capable of this definition, the Act has given a broad definition, which the disability would have to adhere to if a Claimant is to be successful in their claim. Whether or not a person is disabled is often the first hurdle for an Applicant and can be the most contentious in employment litigation. Discrimination is defined in the Act as when, â€Å"A person (A) discriminates against another (B) if, because of a protected characteristic, A treats B less favourably than A treats or would treat others.† Prior to 2010, the Disability Discrimination Act 1995 was the leading statute in this area, ensuring employers were under a duty to make reasonable adjustments for their disabled employees. The House of Lords in Archibald v Fife Council stated that, â€Å"The DDA does not regard the differences between disabled people and others as irrelevant. It does not expect each to be treated in the same way. The duty to make adjustments may require the employer to treat a disabled person more favourably to remove the disadvantage, which is attributable to the disability. This necessarily entails a measure of positive discrimination.† This case was the first substantial case to be litigated on the basis of making reasonable adjustments. The employee had been dismissed on the bas is that they could no longer fulfil their job duties following an operation. This was a discrimination claim and the House of Lords held that there had been a failure by the employer to make reasonable adjustments. Current Law As the law currently stands, the duty to make reasonable adjustments is found in Section 20 of the Equality Act 2010, which states that this duty is comprised of three requirements found at section 20(3), (4) and (5). Firstly, where an employer’s â€Å"provision, criterion or practice of A’s puts a disabled person at a substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled,† then the duty arises. Secondly, it also arises if the disabled person has a physical feature which puts him at a substantial disadvantage and thirdly, without an auxiliary aid, the disabled person would suffer from an inequality of opportunity. Overall, the duty arises when, without such adjustments, the disabled person would be put in a severely disadvantaged position when compared to their non-disabled colleagues. The law imposes upon employees a duty to take reasonable steps to ensuring that the adjustments made would avoid this disadvanta ge. It is interesting to note that the duty on employers to make reasonable adjustments to disabled individuals extends to contract workers and other temporary members of staff such as trainees. This should provide adequate protection from disability discrimination as it extends to all staff but this does not necessarily suffice. Section 20(7) of the Act states that employers are not permitted to charge disabled employees for the costs in making any reasonable adjustments. This is arguably a very important section of the Equality Act as it ensures that disabled individuals are not penalised and bearing the costs themselves for any adjustments to make. It is fair to say that without such protection, the opportunity for discrimination in this way would have been rife in the workplace. Therefore, the duty on employers to make reasonable adjustments is a positive step forward to eliminating disability discrimination in employment. The requirement for equal opportunities for all employee s extends to the recruitment policies of an organisation as well. This will include ensuring that the job advertisement and description is adequately detailed about what is required of the job, yet at the same time making no discriminatory claims. If applicants have to complete an application form then it should be available in different forms to accommodate all disabled people, such as an option in braille. When individuals are invited for interview, all reasonable adjustments should be made to welcome them and assist them on the day, such as having the interview on the ground floor if the applicant is a wheelchair user. The recruitment committee should, ideally, have an equality and diversity officer within the human resources team to ensure compliance with their legal duty of no discrimination against disabled people. When selection tests form part of the recruitment process, applicants with dyslexia or other conditions, should be given longer to read and answer the questions to ensure a fair process. If an applicant is offered the job, then discussions should take place as to what steps and measures should be given to enable the individual to work in a comfortable environment. On the other hand, if an individual is not suitable for the position, then reasons why they were deemed not suitable should be recorded. There should be no evidence of discrimination in these reasons as this could potentially form the basis for a discrimination claim. Reasonable Adjustments The importance of making reasonable adjustments was emphasised by a previous Parliamentary Under-Secretary of State for Education and Employment, who advised that local authorities, â€Å"will be able to do virtually anything to encourage and enable disabled people to work for them, as long as they appoint the person who is most suitable for the job after they have made reasonable adjustment †¦ there is no maximum for such adjustments. If a local authority is prepared to invest vast sums of money in making provision so that a disabled person is suitable for a job, that is up to the authority, and it has that privilege†. The Tribunal in Wynn v Multipulse Electronics Ltd also considered this, where the job applicant was not interviewed on â€Å"health and safety† grounds because of his disability. The Tribunal found that the applicant had the requisite skills and experience for the job, but had been initially rejected as the small company decided that they did not ha ve the resources/finance to make the necessary reasonable adjustments. The Tribunal rejected this reasoning and decided that the company had not made a sensible consideration for the reasonable adjustments, including the fact that the Government provided support for work initiatives and, on this basis, they were successfully sued for disability discrimination. The duty to provide reasonable adjustments to disabled workers has provided the individuals with the statutory vehicle to pursue litigation to alleviating disability discrimination. It is an important outcome from the legislation. Reasonable adjustments can be temporary and can include improvements to the workplace to enable disabled employees to access their workspace and to be able to do their job correctly. This is often seen by the providing of ramps to work premises to assist wheelchair users. There is also the option of delegating certain parts of the job to temporary staff. By allowing disabled people the option of flex ible working hours and by granting them leave of absence for medical appointments etc, employers would be satisfying their legal duty of reasonable adjustments. This ties nicely with the opportunity of job-share. Before starting their role, employers should ensure that disabled people have had the requisite training for their role and correctly understand what is required of them. Employees should have the right equipment in order to complete their duties and this can include specially formatted computers for those with hearing and speaking difficulties. The statute has ensured that employers should take into consideration and take action into the above, and this on the face of it should be sufficient to combat discrimination to provide all employees with equal opportunities at work. Section 21 of the Equality Act 2010 states that it is against the law for an employer to fail to comply with this duty and they can face a discrimination claim if a breach has occurred. Notwithstanding this, Part 3 of Schedule 8 of the Act allows employers the defence that if they lacked knowledge of the disability then they cannot be sued for any lack of action on their part. This is arguably a fair section in the Act as the legal duty on employees has to be reasonable and employers cannot be expected to act if they were unaware of the disability. This is especially so when there is no legal duty on employees to report their disability to their employers. Although, if at interview the person’s disability is obvious at first sight, for example a wheelchair user, then the defence will not be permitted. Similarly, employers are permitted to ask such questions at interview and/or through an application form as to whether reasonable adjustments would be necessary for interview etc. It is argued that organisations that subscribe through these methods are adequately protecting themselves against potential disability discrimination claims. This may be more difficult for current em ployees whose conditions develop during their employment. The most common example is when an employee is suffering from depression and does not exhibit any outward symptoms. The question for the Tribunal is whether or not the employer ought reasonably to have known about the disability. These questions are arguably fair restrictions on the duty to make reasonable adjustments that should not prevent a clear case of disability discrimination. Approach by the Employment Tribunal If successful, Claimants can be awarded substantial fines by the Employment Tribunal, which should, in principle, lead to adequate deterrence to prevent further discrimination by organisations. Despite this, it is not necessarily the case as numerous claims have occurred every year since the introduction of the Equality Act 2010, thereby highlighting the large numbers of discrimination occurring in the workplace. Although, this figure is not truly representative as a number of employees do not take their case to the Tribunal, and it is worrying that the current figure may hide more discrimination in the UK. The lack of cases being taken to the Tribunal may be accounted for the rise in costs to take such action that is largely preventing claimants from pursing their claims. Those in the legal profession have voiced their concerns over the Government’s cuts in legal aid to this area and rising costs. Whilst the statue has in place the duty to make reasonable adjustments, if peop le cannot take their cases to Tribunal, this will severely reduce the deterrence and enforcement impact of the duty. The question of whether or not the adjustments made were ‘reasonable’ is assessed objectively by the Employment Tribunal: â€Å"The question of whether any reasonable adjustments were required †¦ depends on an objective assessment of what could be done to ameliorate the disadvantage in fact created.† The objective nature of the test was reinforced by the case of Tarbuck v Sainsbury Supermarkets Ltd and this remains under the Equality Act 2010. When deciding whether or not the employer has taken ‘reasonable’ measures, the Tribunal will consider factors, such as effectiveness and questioning whether it was a practical move. For example, by providing a blind employee with a computer formatted with braille, is both an effective and practical move to assisting the employee. Costs are a very important consideration and this will depend on a number of factors, such as the resources available to the organisation. It is common sense that a bigger company with more disposable income will be expected to have contributed more to the reasonable adjustments than a smaller company. Notwithstanding this, it is no justification for the employer to say that they could not afford the adjustments required to enable the disabled person to work. It is their legal duty to comply and the Government have providing numerous ways of funding these adjustments. Therefore the legal duty should be complied with and it should have initiated a sharp decrease in the instances of disability discrimination. In Tribunals today, the most popular test is that of The Secretary of State for Work and Pensions v Wilson, where the EAT held that firstly employers have to ask themselves whether the adjustment would overcome the disadvantage the disabled person is currently facing. If this is answered affirmatively, then the Tribunal considers whether or not it was practicable to take these steps. By assessing practicality, the Tribunal will consider the company’s resources and finances to ensure a fair decision is reached. Therefore a smaller company cannot have the defence of saying that they cannot afford to employ a disabled person. On this basis, the legal duty should be alleviating disability discrimination as it applies to all businesses. Academic Commentary Academics such as Anna Lawson point to the fact that disability is the only protected characteristic whereby an employer is under a reasonable adjustment duty. The UK is not unique in this respect, as the same situation is found in the EU and international law. â€Å"There have been calls for a more expansive approach which would extend such duties to religion or to other characteristics more generally. There was, however, surprisingly little discussion of such a possibility in the lead up to the Equality Act. Such a discussion might have been helpful in identifying whether disadvantages often associated with other protected characteristics require the flexibility of response of a reasonable adjustment duty or can be more effectively tackled through specific schemes (such as those applying to flexible working and parental leave).† From this academic perspective, it is fair to say that the legal duty on employers is a positive development in removing discrimination from disable d people. In this article, Lawson is such a supporter of the concept that she campaigns for its existence in other protected characteristics such as religion. This is because failing to comply with the duty to make reasonable adjustments is a form of discrimination in Employment law and the same cannot be said for other protected characteristics. On this viewpoint, it is strongly suggested that disabled people face higher protection than others in this regard. One of the many positives of the legal duty is that it, â€Å"If an employer has failed to make a reasonable adjustment which would have prevented or minimised the unfavourable treatment, it will be very difficult for them to show that the treatment was objectively justified.† However, one of the major problems with discrimination affecting disabled people is that, even if an employer complies with his duty to make reasonable adjustments, they can still treat the disabled employee unfairly on the basis of their disabili ty. For example, an employer may change an employee’s working hours to ensure they attend medical appointments, but that does not prevent them from dismissing the employee on the ground of absence from work. From an objective perspective, the legal duty on employees to make reasonable adjustments for disabled workers has resulted in an increase in the number of disabled people in employment. This can be viewed as a positive step forward in support of disabled people in the workplace. Yet this has occurred with at the same time as an increase in the number of disability discrimination claims. Given the high number of claims, it is at least arguable that reform of the law is required to provide stronger deterrence against disability discrimination. Case Law The case law in this area is interesting and provides valuable assistance in examining whether or not adjustments have eliminated discrimination and inequality of opportunity faced by disabled individuals. The case of Wilson v DWP provides a useful insight into the attitudes of the Tribunal and the way that disability discrimination law has developed, as the Tribunal was seen to be making a substantial award as a mark of deterrence. The case of O’Hanlon v Commissioner for HM Customs said that, â€Å"It will be a very rare case indeed where the adjustment said to be applicable here, that is merely giving higher sick pay than would be payable to a non-disabled person who in general does not suffer the same disability related absences, would be considered necessary as a reasonable adjustment†¦although we do not rule out the possibility that it could be in exceptional circumstances.† Therefore, in exceptional circumstances this could form part of the employer’s legal duty to make reasonable adjustments for disabled people to alleviate any disadvantages or inequality of opportunity. The Tribunal in Nottinghamshire County Council v Miekle echoed this, where the employee was awarded full sick pay for her leave of absence from work. But, this was namely because the failure to make reasonable adjustments was the reason for the employee’s absence, there was a causal connection that assisted her claim. Therefore, this should provide sufficient protection for disabled people from discrimination in the work place. Although, successful cases against employers have been found in cases, such as Burke v Clinton Cards. In this case, a female employee was diagnosed with cancer and despite her employer being aware of her condition, she received an increased workload and the work was not suitable for her. The Tribunal found that her employer had not complied with their legal duty to provide reasonable adjustments, such as a lighter workload or job d uties more suitable to her condition. Both of these measures could have been easily implemented and it only highlights the lack of action by the employer. Therefore, the Tribunal awarded the employee ?10,000 in compensation for her discriminatory treatment. This shows that the Tribunals are willing to find actions of disability discrimination and are doing their part to significantly reduce disability discrimination at work. In the case of Chief Constable of South Yorkshire police v Jelic, the Employment Appeals Tribunal upheld the ruling by the trial Tribunal that the employer had failed to make reasonable adjustments for the disabled employee. The EAT ruled that it would have been a reasonable measure to have allocate the employee’s duties to another police officer in order to assist them. Job sharing and allocating of responsibilities is an important delegation decision for the employer and the Tribunal views it as a reasonable action to take in the circumstances views it. The relatively simple nature of such an action is arguably strong evidence of the continual presence of discrimination against disabled people by employers. The fact that it is against the law to do so does not appear to be an adequate deterrent against discriminatory behaviour. In the media, there have been a couple of high profile cases involving disabled people and the lack of reasonable adjustments. One of the most controversial cases, which showed an apparent discrimination case that shocked the nation, was the female employee at Abercrombie & Fitch. The woman had had her arm amputated and as a result, the employer said it was not a sight that customers should have to see whilst they were shopping. Instead, of making reasonable adjustments to accommodate this, the female employee was sent to the stockroom. The Tribunal and most reading the case were appalled with the behaviour and attitude of the employer. This was reflected in the award the Tribunal provided to the employee. The high profile nature of such claims should act as sufficient deterrence but this case shows that it has been successful at this. Therefore, more is required in order to reduce discriminatory actions against disabled work to allow everyone to be treated equally at work. Conclusion The statute provides that the employer has an important duty to take reasonable practicable steps to ensure that their employees are protected from any risk of harm. This is extended when the situation concerns disabled people as employers must go one step further to make sure that the work and their work premises do not prohibit their ability to do their job. On the face of it, it is clear that the duty to make reasonable adjustments has, to some extent, eliminated discrimination and inequality of opportunity faced by disabled individuals. The same problem applies across the law of discrimination as protection is only granted to the individual if their condition meets the definition of ‘disability.’ It is arguably a complex definition that should be given wider scope to ensure adequate protection for all disabled people in the UK against discrimination. The high number of hurdles a claimant has to jump over to be successful in this litigation is a worrying concern for s ome academics, as they propose that even more has to be done in this area to alleviate disability discrimination in the workplace. As one academic, who campaigns for a reform in the law, says: â€Å"The requirement of knowledge reinforces the reactive nature of the reasonable adjustment duty and likewise places no obligation on employers to consider adjustments until they are confronted either by an applicant, or employee whom they know, or ought to know, to be disabled and to be exposed to a substantial disadvantage as a result of their provisions, criteria, practices or physical features.† Also, the vast number of cases being heard by Employment Tribunals nationally shows that the law is not acting as deterrence to employers. Instead, it may be advisable that reforms do occur in the law to ensure that disabled people have the same opportunities that are open to all. Bibliography Articles Employment Law Bulletin, ‘Disability Discrimination Act 1995’ (1996) 2 Anna Lawson, ‘Disability and employment in the Equality Act 2010: opportunities seized, lost and generated† Industrial Law Journal (2011) 359 Stephen Bunbury, ‘The Employer’s Duty to make Reasonable Adjustments. When is a reasonable adjustment not reasonable?’ International Journal of Discrimination and the Law 2009, Vol.10, pp. 111-131 Books Ian Smith & Aaron Baker, ‘Smith & Wood’s Employment Law’ (11th ed, OUP, 2013) Cases Archibald v Fife Council [2004] IRLR 651 Burke v Clinton Cards October 2010, ET/2900622/09 Chief Constable of South Yorkshire police v Jelic [2010] UKEAT 0491/09/2904 Nottinghamshire County Council v Miekle [2004] EWCA Civ 859 O’Hanlon v Commission for HM Customs [2006] IRLR 840 Tarbuck v Sainsbury Supermarkets Ltd [2006] IRLR 664 The Secretary of State for Work and Pensions v Wilson UKEAT/0289/09 Wilson v DWP [2010] EAT/0289/09 Wynn v Multipulse Electronics Ltd 22 October 2007, Case Number: 2301416/07 Government Report Equality of Human Rights Commission, ‘Equality Act 2010 Code of Practice’ Legislation Disability Discrimination Act 1995 Equality Act 2010 Website Rebecca English (The Daily Mail) â€Å"I was banished to the stockroom, says disabled shop girl now suing Abercrombie & Fitch for discrimination† available at http://www.dailymail.co.uk/news/article-1192674/I-banished-stockroom-says-disabled-shop-girl-suing-Abercrombie–Fitch-discrimination.html accessed 9 May 2014 Equality & Human Rights Commission ‘Reasonable adjustments’ http://www.equalityhumanrights.com/advice-and-guidance/education-providers-schools-guidance/key-concepts/reasonable-adjustments/ accessed 13 May 2014 Gov.uk, ‘Reasonable adjustments for disabled workers’ https://www.gov.uk/reasonable-adjustments-for-disabled-workers accessed 13 May 2014 HSE ‘The law’ http://www.hse.gov.uk/disability/law.htm accessed 13 May 2014 Samira Shackle (NewStatesman) ‘How legal aid cuts are harming the voiceless and most vulnerable’ (13 January 2014) http://www.newstatesman.com/politics/2014/01/how-legal-aid-cuts-are-h arming-voiceless-and-most-vulnerable accessed 13 May 2014 Xpert HR, ‘Disability discrimination awards 2011/12’ http://www.xperthr.co.uk/quick-reference/disability-discrimination-awards-201112/114296/ accessed 9 May 2014