Sydney Harbour Bridge

Australia is known everywhere throughout the globe for a few reasons. The normal delights of the nation and the untamed life are consistently on the highest priority on the rundown. In any case, when pondering Australia there are two super structures that ring a bell, The Sydney Opera House and The Sydney Harbor Bridge. In this short report it very well may be discovered little history alongside a short portrayal about the Sydney Bridge.II. Fundamental Body II. 1 History The main intends to assemble a scaffold really returns to year of 1815, however it wasn’t until 1922, in the wake of being postponed masculine in view of the WWI, that the parliament endorsed the laws for the development of this enormous structure. The genuine work didn’t start until 1924 and took 8 years, a 1400 men work power, and a few lamentable mishaps to at last completion it (Australian Government).The official opening function was on 19 March 1932, were the Premier of New South Wales should cut the lace, however a man in military dress riding a pony, cut the lace before the service started, proclaiming the scaffold opened for the sake of the individuals of Australia. II. 2 Description Also known as the â€Å"Coathanger† by numerous inhabitants of the city of Sydney, the Harbor Bridge is, until the date, the world’s biggest, however not longest steel curve bridge.This 53,000 tons structure is situated in the Sydney Harbor, joining the Central Business District (or CBD) at Dawes Point with the business and neighborhoods in the North Shore at Milsons Point (Wikipedia 2010). The scaffold is around 500 meters in length. Today conveys eight traffic paths, two rail lines, one toward every path, a person on foot pathway on the eastern side and a cycleway on the western side of the scaffold. The curve highest point is around 135 meters over the normal harbor water level. There are four arches at each finish of the curve that weren’t part of the underlying plan and they don’t really satisfy any auxiliary purpose.These structures were included last to improve the presence of the extension, yet now they were completely placed into utilization, the most celebrated being the one situated in the south east of the scaffold. This specific arch presently holds a three stories historical center with the extension history (Wikipedia 2010). III. End As can be seen the Sydney Harbor Bridge not just fills in as an intend to cross the harbor in an increasingly productive manner, yet it has gotten one of the most significant milestones of Australia, on account of its design, lovely perspectives and visitor attractions.It doesn’t matter if you’ve been there or not, when someone discusses Sydney, is practically inescapable yet to consider this structure. ?IV. List of sources Wikipedia 2010, Sydney Harbor Bridge, saw 2 December 2010,  http://en. wikipedia. organization/wiki/Sydney_Harbour_Bridge

Leadership and Influence Essay Samples - Make Your Essay Better With the Help of Leadership and Influence Essay Samples

Leadership and Influence Essay Samples - Make Your Essay Better With the Help of Leadership and Influence Essay SamplesWhy are leadership and influence essay samples so important? Well, they do more than just tell the student what is wrong with their essay or why they have written it the way they did, but how they can improve on it in various ways.I will admit that I, and many other high school students, may not be experts in English and composition, but when it comes to writing, we are as good as any. So, when it comes to writing an essay or report, we know what is needed to get a job done, and what is needed to get a job done right.The trick is to write about the job. Yes, we know that writing about the job in a great way is the best way to get a job done. But how can we do this if we are not sure where to start?When looking for leadership and influence essay samples, you need to remember one thing. They are not only for those who have to write a lot of papers. They are there for t he teachers and professors, for the writers who are already employed by the companies, and those who are seeking a way to boost their resume, create a new idea, or even inspire others.Leadership and influence essay samples are available for all types of student and professionals. This means that whether you are a student in high school or a college graduate or the younger, you can take advantage of this valuable tool.What do college graduates and those who have graduated and got jobs with large corporations do to find the best leadership and influence essay samples? Most use sites such as Get Student Essay Samples or Scholarships.com. You can find these sites just by searching for the keyword 'leadership and influence essay samples'.Get Student Essay Samples is a great place to get inspiration, brainstorming and article ideas for the leadership and influence essay samples. Scholarships.com is another site that may come in handy to college graduates and business professionals. They o ffer many different scholarship opportunities for students who have participated in college competitions, won awards, or performed well on job interviews.Get these sites for yourself and see what they have to offer. You will be surprised to see how much better your essay will be!

Safe medication administration Research Paper Example | Topics and Well Written Essays - 1250 words

Safe prescription organization - Research Paper Example 61). Together, these security measures lessen danger of prescription blunders, yet, these don't completely address the multifaceted nature of human factor in the mistake. In spite of the fact that tending to medicine blunders through current clinical innovations are fitting parameters in understanding security, need must be fixated on remedying inner culture in clinical practice that supports prescription mistakes into a conveying domain that advances early revision of mistakes through intentional detailing of basic blunder sources. Idea Similarities The demonstration of submitting any type of mix-ups in clinical set-up produces a lot of worry as single slip-up can prompt more terrible conditions and passing. As confirmed by Vogelsmeier, Scott-Cawiezell, and Zellmer (2007, p. 8), various elements ruin to safe drug execution, from â€Å"prescribing, archiving, apportioning, regulating, and monitoring.† In every single practical classification, poor correspondence designs usuall y showed up in each level. Indeed, even in twofold checking medicine before organization, correspondence issues may in any case happen. Shared organization against mistake is conceded as junior attendants shies from addressing senior medical attendants on defective medicine methodologies, aggravated when two partners go amiss to individual subjects during prescription checking and when programmed nursing forms dismiss further examination of reevaluating drug ideas (Armitage, 2007). As Brous (2008) concurred, correspondence needs improvement in genuine practice, and included that nursing information and aptitude capabilities, just as personnel shortages, ought to be upgraded in an authoritative domain that sustains culture of security against blunders. Correspondence, among different stressors, drive medical caretakers to improved helplessness, yet this is just a bit of man’s normally constraining abilities. Differentiations Revealed various potential arrangements have been ac quainted that guarantees with negligibly reduce, if not dispense with, human blunders in expertly conveying pharmacological operators. On a customary way, Dennison (2007) advanced innovatively upgraded technique of instructive preparing in safe meds, estimated through reasonable enhancements in performing â€Å"smart† siphons in medicine mixture. As organization stage possesses dominant part of medicine blunders, mechanical manifestations have been acquainted with block practical missteps. For DeYoung, Vanderkool, and Barletta (2009, p. 1111), antagonistic pharmacological occasions can be decreased by â€Å"bar-code-helped medicine organization (BCMA),† used explicitly at the bedside to check and help attendants to remember previous prescription exercises and fundamental medication care. Mistakes are, subsequently, forestalled as attendants are made mindful of right prescription strategies for singular patients before genuine organization. On an alternate level, steady imbuement siphons framework benefits nurture in three different ways; diminishes stresses on dose miscounts, helps trust in precisely conveying implantation specialists, and helps drug remaining burden (Rosenkoetter, et al., 2008). Capacities in effectively dispersing drugs are performed, and all medical caretakers need to do is screen it for conceivable glitch. In another innovative framework, â€Å"

Full-Length SAT Practice Tests and Where to Find Them

UPDATE: This post has been updated to reflect changes to the SAT beginning in March 2016. All of the SAT practice tests featured in this post will help you prep for the redesigned SAT. 🙂 Free Full-Length New SAT Practice Tests Now that the SAT has changed significantly many are wondering where to get practice tests. The good news is that, for the first time ever, official practice tests are available for free. The College Board (the writers of the test) has teamed up with Khan Academy to offer eight SAT practice tests that can be accessed via a link on either the College Boards website or the Khan Academy website. The not-so-good news is that, beyond these eight official practice tests, there is only one other test: a practice PSAT, which is also available on Khan Academy for free. (A special note to those who think these tests might supplement the ones found in The Official SAT Study Guide : they are actually the same exact tests!! Consider yourselves forewarned). Sources of Free SAT Tests: College Board’s Redesigned SAT Website College Board Official New SAT Practice Tests On the College Board’s website, you can print out PDFs of the eight official Redesigned SAT practice tests. You can also print out PDFs of answer explanations for each question. All tests also include a practice essay, although no explanations are provided for these. The Daily Practice App College Board also offers a free Daily Practice app with questions for the new SAT. As a pretty cool bonus, you can also use the app to take a picture of your score sheet for the official Redesigned SAT practice tests and receive an instant score. Khan Academy If you want to engage with these practice tests in a more interactive format, you can head to the Khan Academy website to take the same practice tests online (with a timer ticking). Again, these are the same exact tests you’ll find in the College Board’s other resources (which is definitely a bummer for those who think they will be getting more). Khan Academy also offers additional practice questions â€Å"approved† by the College Board if you want some extra practice. These aren’t quite the same thing as the College Board-written questions on the practice tests, but they can be a decent supplement. The Official SAT Study Guide (2016 Edition) The Blue Book Since you can find the same tests and answer explanations online for free, there isn’t much worth paying for in The Official SAT Study Guide, except maybe the intro chapters, which do include a lot of information on the structure and content of the test as well as some extra practice questions. Still, you might want to consider carefully whether it is worth your hard-earned dollars or whether you should stick with the free online resources. Magoosh Yep, thats rightyou can now get a free, full-length SAT practice test right here at Magoosh! Written by Magooshs test-prep experts, this test has everything you need to practice for test day. There are also full text AND video explanations for every single question. What more could you want? Get your free SAT practice test here! Also, dont forgetMagooshs SAT study plans can help you to integrate our test, as well as The Official Guide (or the Khan Academy Online Prep) tests into an effective SAT study schedule if you aren’t sure where to start. Redesigned PSAT Practice Test Now that the PSAT and SAT are so similar (really the only differences between them are that there are a handful more questions on the SAT versus the PSAT and the SAT’s questions are slightly harder), you can also use the College Board’s free Redesigned PSAT practice test for additional practice. Like the SAT practice tests, this downloadable PSAT also has answer explanations and a scoring sheet. Reviewing Practice SAT Tests Now that you have some SAT tests to practice with, you need to know how to review them effectively so that you can keep making progress with each test you take! Check out our video on Reviewing Your Practice Tests to learn how you can get the most out of checking your answers. You can also use our free resource, the Official SAT Study Guide, which compiles video explanations to 116 math questions from the first and second test and related free video lessons. These video explanations are also available on our so that you can ask questions and share the explanations that you find useful with friends who are also studying. Weve only done explanations for the math sections of the first two tests, so if you are interested in video explanations for other tests or other sections, let us know by leaving a reply in the comments section of this post! How to Use Official Free SAT Practice Tests in your Test Prep What I recommend students do is spread these tests out—which is obvious. But what I also advise them to do is to take each test more than once. Many think this is a terrible idea. After all, the final score won’t be an accurate reflection of your knowledge and might give you an inflated score (and even an inflated ego). The second point: you’ll already know some of the answers so how does that help you to do the same question again? The first point is accurate: you’re likely to get an overinflated score. The reason for doing a retake, however, is that you can apply the knowledge you’ve gained in between the tests. This point is a little vague so let me flesh it out a little. When you are learning grammar, let’s say, you’ll be picking up fundamentals. For instance take a look at the following sentence. The point of taking multiple standardized tests are often lost on students who must spend hours and hours hunched over an exam. If I asked you to figure out what was wrong with the underlined section, you might answer that it sounds totally fine. Though, you might also answer that something sounds weird but you can’t quite put your finger on it. Perhaps you’d go a step further and wonder if the ‘are’ should be an ‘is’. Then, over the next few weeks, you encounter many times the concept of subject-verb agreement and you learn that if you want to determine the â€Å"number† of the verb you need to ignore the prepositional phrase that comes after the subject. Here, that phrase begins â€Å"of taking multiple standardized tests†. The subject is â€Å"point†, which is singular. Therefore, ‘are’ should be ‘is’. The point here isn’t to talk grammar; it’s to show you that upon learning something new, your brain changes the way it processes information. Upon seeing the sentence again, you should able to give a logical, grammar-based reason for why ‘are’ is wrong. Did you remember the correct answer from the first time? Maybe. But this time around you can confidently get the right answer based on what you’ve learned. Additionally, you’re reinforcing the skill of recognizing subject-verb agreement errors or whatever the issue is. To be sure, you don’t want to take the same test within two weeks. But if you wait about a month, much of the test will seem new. And that’s mainly because your â€Å"SAT brain† will have grown in that time. What about SAT Practice Tests from Test Prep Companies? If you are prepping for the long haul, or if you are a tutor wondering which tests to give your students over an SAT summer course, you will need more than the eight tests offered above, regardless of repeats. The Princeton Review, Kaplan, and Barron’s each have practice tests. Before you get excited, I should warn you that there are significant downsides of taking these tests. Simply put the material is some a poor imitation of the real thing. Sure, you’ll get practice but you really won’t be prepping your brain for the rigors of the real test. It is sort of like jogging 5 miles on a treadmill, a bottle of water in front of you, and a fan blowing a gentle breeze in your phase. The actual test is more like running 5 miles up a windy summit, rain pelting your face. Besides complexity another issue is that the questions in these books were not tested on students. I know, that conveys a sense of a mad scientist in a laboratory, the students serving as hapless rodents. It’s not nearly as nefarious, though. Each SAT has an experimental section that determines the validity of question based on the difference between the percentage of high-scoring students (they’ll know this based on the score you get on the other sections) and the percentage of low-scoring students who miss a question. If low-scoring students do as well on a question as high-scoring students, then the question is not very good. If high-scoring students perform much better on a question than do lower-scoring students, then that is a sign that the question is valid. To the best of my knowledge, none of the questions in these books are vetted in this way. With that caveat out of the way, it is true that some second party publishers do a better job than others. To get a sense of how this shakes down, you’ll want to check out my Best SAT book review post. The short of it? Barron’s is the best of the big publishers so if you have to choose practice tests from one company that should be the one. And now that you have the best practice test resources, its time to schedule your best SAT test date.

Educational Philosophy Traditional And Progressive Style

Johnny Driza Professor Gee ENG 220 27 February 2017 Educational Philosophy From their initial approaches to their ultimate goal, the traditional and progressive style differ in almost every category. While the progressive style is widespread and used in a greater percentage of the world, both it and its counterpart, progressive education, are rooted in the ides of John Dewey, an American education reformer and philosopher. The traditional style sees school more as a preparation for life and focuses less on the individual more than it does on wave after wave of passive absorbers of information and authority. The progressive style views schooling as a sort of â€Å"stepping-stone† in life, a part that we use to further ourselves and our†¦show more content†¦The teacher is the source of information and authority and the linear learning that takes place in the program will be regulated by exam results that test on factual accumulation and skill mastery (Bonstingl). There is a set program in which decisions have been admini stratively made and there is little room to question or ponder the reasons why you are doing something because all that is necessary is memory and eventual recitation. Success in this type of style is determined through attaining higher scores than one’s peers through achieving the most correct answers on a given assessment. This type of approach does a great deal in terms of aiding the growth of the student’s crystallized intelligence, specifically with regards to their linguistic and logical-mathematical capabilities (Coe, Higgins, Aloisi, Elliot). It is rooted in old studies that have found that learning is aided the most by asking questions over and over and spacing out practice to simultaneously prepare a student for an upcoming exam. The goal of traditional style of teaching is not necessarily to teach and train multiple types of intelligence but rather to indirectly guide the student and have them obtain by-products while studying for academic mastery (Cothran) . In progressive education, the age old teacher-student dynamic is cast aside as the person whom was once known as the sole authority takes more of an aiding and facilitative role. School is a part of life inShow MoreRelatedJohn Dewey s Theory Of Evolution1099 Words   |  5 PagesAbstract This research is on the background of John Dewey (1859-1952), his theories, his influences and the impact that his research had on the educational systems across the United States. Functionalism, Pragmatism and Individualism are looked at, as well as Darwin’s Theory of Evolution. It also goes into the impact that Dewey’s theories had on the educational system as it is viewed during John Dewey’s lifetime and today. John Dewey (1859-1952) was born in Burlington, Vermont in 1859. He graduatedRead MoreProgressive Education Essay1318 Words   |  6 Pagesyou, words and ideas can change the world.† Typically, students do not hear enough of this type of passion in a traditional classroom. However, a progressive classroom, be it a cave or college can inspire students to memorize facts, not because they have to, but rather because they want to for the betterment of humanity. Society desperately needs students educated in a progressive style because America needs students who realize learning never stops. Today’s students and tomorrow’s professionalsRead MoreWhat Values From Traditional And Progressive Philosophies Complement Each Other868 Words   |  4 Pagesidentifiable philosophies that answer these questions: Traditional, Progressive, Existential and Critical Theory. However, they are often taken to the absolute and extreme. I firmly believe that taking both the main val ued approaches from the Traditional and Progressive Philosophies provides strong disciplinary focuses and knowledge integration. The combination of the two philosophies allows for a positive insight to all educational philosophies. Keeping the mind open to these philosophies allow forRead MoreThe Five Basic Principles Of Humanistic Education1318 Words   |  6 Pagesencourages students to work for short term results and prevents true knowledge that remains long after instruction. The fourth humanistic principle believes that both emotional feelings and knowledge are important to the learning process, unlike traditional educators, humanistic teachers do not separate the cognitive and affective domains (Principles, n.d.). Finally, humanistic educators insist that schools provide learners with a safe and secure environment to promote the learning process (PrinciplesRead MoreProgressive Theory Of Progressive Education961 Words   |  4 PagesProgressive Learning Theory in the US John Dewey’s Progressive Learning Theory is defined as any various reformist educational philosophies and methodologies since the late 1800s, applied especially to elementary schools, that reject the rote recitation and strict discipline of traditional, single classroom teaching, favoring instead more stimulation of the individual pupil as well as group discussion, more informality in the classroom, a broader curriculum, and use of laboratories, gymnasiumsRead MoreReflection On Progressivism1379 Words   |  6 PagesAfter completing the survey in the Introduction to Teaching textbook, I learned that my philosophy of education closely correlates with the views of progressivism. My understanding of this philosophy highlights the child as a whole and the importance of active learning that readies students for the world ahead of them. Progressivists also believe that experiences are a large part of a students learning which is why active learning is so common allowing students t o learn about themselves and learnRead More My Educational Philosophy Essay1196 Words   |  5 PagesMy Educational Philosophy Let experience be your teacher. Let challenges be the test of life! ~Unknown Education is an experience that without a doubt no one can avoid at least for a while. While this process should be positive sometimes it can seem more negative. People should not look back at their education and perceive it as a â€Å"bad† thing or a waste of time. Logically one would think that a person is entitled to their own opinion; however, the opinion of one’s education should neverRead MoreUnderstanding The Current Epistemological Understanding1627 Words   |  7 Pagesresearched and proven to be true. For example, when teaching science or math (or really any subject), I will use methods, formulas, equations, etc. that have been used for numerous years before me. This would demonstrate a sense of empiricism within my educational pedagogy and teaching methods. Moreover, when it comes to implementing Biblical principles into my classroom, I can be confident that what I am teaching is accurate, true, and unchanging. The Bible is absolute truth and the basis for righteous livingRead MoreMy Personal Philosophy Of Education1335 Words   |  6 Pages I tested into a progressivism teaching style in the â€Å"Finding Your Philosophy of Education Quiz.† While I enjoyed learning about the different philosophies and psychological influences of teaching, I prefer constructivism, social reconstruction, and progressivism due to their student-centered learning, hands-on or project based learning style, while making efforts to improve the world around them. I will be discussing why I chose progressivism, social reconstruction, and constructivism as my preferencesRead More My Personal Philosophy of Education Essay690 Words   |  3 PagesMy Personal Philosophy of Education Without education, society as we know it would cease to exist. Formal education is what has made our country and other industrialized nations great. Thus, as a future educator, I anticipate the opportunity to assist in the molding of future generations by imparting essential knowledge. The famous philosopher and educator, John Dewey, once said, Education is the process of living through a continuous reconstruction of experience. It is the

Ratio Analysis Analysis And Interpretation Of Financial...

Ratio analysis is used to describe the important relationship that lies between figures based on line items in financial statements like the balance sheet, profit and loss account, and a budgetary control organization. Ratio analysis is a technique of analysis and interpretation of financial statements. It helps in evaluating the financial position and performance of the firm, ratio analysis also allows firms to compare their operational or financial performance to another firm or the industry standard. This essay will firstly discuss the purpose of financial ratios, its users and how it is applied. It will then move on to discuss the signification and limitations of ratio analysis. Furthermore, a discussion about the usefulness of specific ratios will be held using the 2013 annual report of easy jet. Lastly, my own views on the issues of financial statements, specifically financial ratios will be presented. With the help of financial statements that arise by the firm, analytical methods can be used to get information about the course of the business and the economic state. By calculating a small number of ratios it is possible to develop a clear picture of the position and performance of a firm (P.Atrill and E.Mclaney 2013). Financial ratios have two main users, management and inventors. Management uses financial ratios to analyse, control and determine the performance of their company. This will allow companies to improve in the areas where they are weak. On the otherShow MoreRelatedFinancial Performance Analysis1727 Words   |  7 PagesLITERATURE Financial statement analysis is the process of examining relationships among financial statement elements and making comparisons with relevant information. It is a tool in decision-making processes related to stocks, bonds, and other financial instruments. Analysis of financial statements provides valuable information for managerial decision. Financial analysis is commonly called analysis and interpretation offinancial statement. Analysis of financial statements means establishingRead MoreRatio Analysis in Decision Making for Health Care Organization841 Words   |  4 PagesRation analysis Financial statements paint a picture of financial health of an organization. Important aspects of the financial statement of a health care organization are ratios. Analysis of ratios show how two numbers relate or compare to one another. Ratios are a way for organizations to make comparison. These comparisons not only encompass what is happening presently but can also be used to make comparisons about numbers and ratios over time. Ratios are a way for organizations to compare themselvesRead MoreScope of the Study1611 Words   |  7 Pagesproviding an insight into the financial position by comparing the Balance Sheet of Auto Syndicate Private Ltd. This study confined to five years data from annual reports 2006-2010, financial statements and other records of the Auto Syndicate Private Ltd. OBJECTIVES OF THE STUDY: The study is undertaken with the following objectives * To study the liquidity position of the company. * To analyze the financial performance of the company. * To predict the general financial position and profitabilityRead MoreTraditional Financial Reporting and its Limitations962 Words   |  4 PagesIntroduction In a more general term, financial statement states the details of an organization, entity and business financial activities. It provides information about the financial performance, position as at a given date, changes in financial position, etc., that are useful for economic decision. 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TheseRead MoreFinancial Performance Review and Objective1405 Words   |  6 Pages A STUDY ON FINANCIAL PERFORMANCE OF MATHRUBHUMI PRINTIONG amp; PUBLISHING COMPANY LIMITED, CALICUT COMPANY PROFILE Mathrubhumi  is one of the front-runners among the Malayalam newspapers. The first copy of Mathrubhumi  was published on 18th of March 1923K. P. Kesava Menon, the prominent freedom fighter, as Editor and K. Madhavan Nair as Managing Director of it.In the beginning, the paper was published a week and had just one edition from Kozhikode (Calicut).Now with fourteen editions, includingRead MoreFinancial Performance Review and Objective1419 Words   |  6 Pages A STUDY ON FINANCIAL PERFORMANCE OF MATHRUBHUMI PRINTIONG amp; PUBLISHING COMPANY LIMITED, CALICUT COMPANY PROFILE Mathrubhumi  is one of the front-runners among the Malayalam newspapers. The first copy of Mathrubhumi  was published on 18th of March 1923K. P. Kesava Menon, the prominent freedom fighter, as Editor and K. Madhavan Nair as Managing Director of it.In the beginning, the paper was published a week and had just one edition from Kozhikode (Calicut).Now with fourteen editions, includingRead MoreFinal Term CheatSheet21135 Words   |  5 PagesComparative analysis: Evaluation of consecutive financial statements to examine direction, speed, extent of any trend(s) Common size analysis: Evaluation of internal makeup of financial statements, and/or financial statement accounts across companies Common size income statement as a percentage of revenue Common size balance sheet as a percentage of revenue Ratio analysis: Evaluates relation between two or more economically important items. Prior Accounting analysis is important Interpretation is keyRead MoreThe Financial Status Of A Company1548 Words   |  7 PagesThe financial status of a company is a high priority for internal personal such as managers and external personal such as stockholders. The reason being that by developing financial statements and ratio analysis it allows all users to see the current and future status of a company’s financial state. Financial statements are beneficial, but have certain limitations that may cause issues, if unknown, when the company or individuals use them. This paper will discuss the benefits of ratio analysis andRead MoreFinancial Statements: Industry Comparison1557 Words   |  7 PagesFinancial Statements: Industry Comparison University of Phoenix BSA 500: Business Systems I Instructor: May 28, 2007 Financial Statements: Industry Comparison More often managers are exposed to financial data and the need exists to develop knowledge and understanding of financial accounting concepts and principals. Nearly all companies prepare financial statements of some type and the complexity of those statements will vary. The analysis and interpretations of financial statements

Clerical or Managerial Then Such Employeesâ€Myassignmenthelp.Com

Question: Can Computers Pty Ltd rely on the restrain clause that is imposed by it on Chu? Can Computers Pty Ltd pierce the veil of System Pty Ltd and consider Chu to be violation of the restrain clause? Answer: Introducation When any employer employs any person at any post, whether it is operations, clerical or managerial, then, such employees is acquainted with the working of the company. But, the knowledge that is attained by such persons is at risk when such persons leave the job of the employer. In order to preserve the self interest and the confidentiality and the business, the employers are allowed to restrain the acts of such employees or officers.[1] This can be done when an employer while making the contract of employment incorporates a restrain clause according to which the employee or officer is not permitted to trade in the same business or to solicit employees or to act in certain way for a certain amount of time or at certain place. In Buckley v Tutty[2] and Peters(WA) Ltdv PetersvilleLtd[3], such restrain clauses are held to be valid because the same are established to protect the legitimate interest of the employer, to preserve the business, to secure the good will and reputation of the employer which he has built over the years.[4] But, when the restrain clause is not justified, that is when the clause is too long or when the restrain is illegal or which curtails the working capacity of the employees, then, such restrains are not permitted in law. In Spencer v Marchington[5], it was held that the restrain was for a 25 miles which is too wide and maximum restrain of 20 miles is justifiable. Further, in Briggs v Oates[6], the restrain of five years was held to be too long and was declared invalid. The restrain must be logical and must only preserve the legitimate interest of the employee in order to hold the same valid in law. any restrain clause which is too long in duration is found to be not justified in law.[7] Further, when a company is established then it is artificial person in law and attains a feature of separate legal entirety which simply submits that a company is an independent body and cannot be associated with its employees of officers. It has the capacity to enter into contracts, to sue, to hold property independently. The acts of the company are in its own name and the officers cannot be held liable for the same. In Salomon v Salomon Co[8], the court held that once a company is formed then its officers are not to be treated alike with the company. The company is separate and must not be associated with the acts of its officers.[9] But, many a times, a company is formed in order to deceive people. For instance, to commit fraud, fabrication, agony, etc,. In such situation, the courts are willing to price the veil of the company and the acts of the company are considered to be the acts of the officers and they are then held personally liable for the same. In Gilford MotorCo Ltd v Horne[10], an ex officers wife formulates a company and solicits the clients of the officers company. Though the officer was not the director of the new company but the court pierce the veil and held that the officer is in fact the owner of the company with the main aim to solicit the clients of his previous company. Thus, to avoid any kind of fraud the veil of the company can be pierced so as to avail justice.[11] The relevant law is applied to the facts The law dealing with piercing the corporate veil of the company and the applicability of restrain clause is now analyzed on the given facts and scenario. Issue 1 Chu was working with Computers Pty Ltd for past five years at the position of operations manager. Because of his managerial post, Chu is in constant touch with the clients of Computers Pty Ltd and is thus very well aware of their identities. Considering the knowledge and confidential informations that are attained by Chu while working with Computers Pty Ltd, the Computers Pty Ltd has incorporate a restrain clause in the employment clause of Chu that he is not allowed to work in dealing with the retails of hardware and software of selling computer for next two years (after he cases to be the manager) within New South Wales. It is submitted that the restrain imposed by Computers Pty Ltd on Chu is valid because the same is only for two years and the length of such a restrain is valid and is rightly established in Briggs v Oates. Also, Computers Pty Ltd is aware that the information attained by Chu is very confidential and if the same is used by him to solicit the employee of the company then it is against its legitimate interest and will also trash its goodwill and business. So, as per Buckley v Tutty and Peters(WA) Ltdv PetersvilleLtd, the restrain clause is also valid of business, interest and confidentiality of Computers Pty Ltd. So, the clause is valid. Issue 2 Now, after leaving the job with Computers Pty Ltd in March, Chus wife in April established a company in the name of System Pty Ltd. the main of the business of System Pty Ltd was same with that of Computers Pty Ltd, that is, they were also dealing in the retail of computer softwares and hardware. The System Pty Ltd was also soliciting the customers of Computers Pty Ltd who are within the knowledge of Chu. Though Chu was not in the board of directors of System Pty Ltd, but, the only director of the company was the wife of Chu. The facts of the case are very similar to the facts of Gilford MotorCo Ltd v Horne. It is submitted that it is rightful in piercing the veil of the company at this stage because System Pty Ltd was established after a month when Cu resign with Computers Pty Ltd. System Pty Ltd was also soliciting the Computers Pty Ltd clients and was also dealing in the same business. The main aim of forming System Pty Ltd was only so that Chu can escape from the restrain clause that is imposed by Computers Pty Ltd on Chu. So, Chu has very cleverly in order to avoid the repercussion of the restrain clause has established the company in his wife name and is dealing with all stuffs that he is prohibited to do under the restrain clause. Concluding remarks Since, the restrain clause is only for two years and only prohibiting the trade in New South wale, thus, the clause is valid and can be enforceable against Chu. Also, the company System Pty Ltd was only made by the wife of Chu so that Chu can avoid the restrain clause that is imposed upon him. Thus, the veil should be pierced and the company and Chu must be considered as same and Chu must be held liable for violating the terms of the restrain clause. References Books/Articles/Journals BROOKS, ADRIAN , The Limits Of Competition: Restraint Of Trade In The Context Of Employment Contracts [2001] UNSWLawJl 27. Caffrey, A. Bradford., Guidebook to Contract Law in Australia (CCH Australia, 1991). Latimer, Paul, Australian Business Law 2012 (CCH Australia Limited, 2012). Tomasic Roman, Stephen Bottomley and Rob McQueen, Corporations Law in Australia (Federation Press, 2002). Case laws Briggs v Oates[1990] IRLR 473 Buckley v Tutty- [1971] HCA 71. Gilford MotorCo Ltd v Horne [1933] Ch 935 Peters(WA) Ltdv PetersvilleLtd [2001] HCA 45. Salomon v Salomon Co [1897] AC 22. Spencer v Marchington [1988] IRLR 392 [1] Bradford. A. Caffrey, Guidebook to Contract Law in Australia (CCH Australia, 1991). [2] Buckley v Tutty- [1971] HCA 71. [3] Peters(WA) Ltdv PetersvilleLtd [2001] HCA 45. [4] Paul Latimer, Australian Business Law 2012 (CCH Australia Limited, 2012). [5] Spencer v Marchington [1988] IRLR 392. [6] Briggs v Oates[1990] IRLR 473. [7] ADRIAN BROOKS, The Limits Of Competition: Restraint Of Trade In The Context Of Employment Contracts [2001] UNSWLawJl 27. [8] Salomon v Salomon Co [1897] AC 22. [9] Roman Tomasic, Stephen Bottomley and Rob McQueen, Corporations Law in Australia (Federation Press, 2002).Top of Form Bottom of Form [10] Gilford MotorCo Ltd v Horne [1933] Ch 935. [11] Michael Adams, Essential Corporate Law: Second Edition (Cavendish Australia, 2002).