Salomon is in the shadow. It is still alive but no longer occupies the centre of the corporate stage (Schmitt off, C.M., Salomon in the shadow [1976] JBL 305). - Free Essay Example

Sample details Pages: 10 Words: 2980 Downloads: 1 Date added: 2017/06/26 Category Law Essay Type Critical essay Did you like this example? Critically evaluate, with reference to relevant case law and statute, how far this statement accurately reflects the current law relating to lifting the veil of incorporation. Introduction Salomon v Salomon[1] involved the principle of separate corporate personality. This states that as a general rule a limited companys shareholders are not liable for the companys debts beyond the nominal value of their shares[2]. However, in certain situations courts have ignored this principle[3]. Courts have done this under statute, during wartime, where there is an agency or trust arrangement, where the company was a sham, or when dealing with groups of companies. Recent decisions such as Adams v Cape Industries plc[4] and Prest v Petrodel Resources Ltd[5] have reaffirmed the principle in Salomon. However, courts have still been willing to ignore the Salomon principle, most notably in Chandler v Cape plc[6]. Don’t waste time! Our writers will create an original "Salomon is in the shadow. It is still alive but no longer occupies the centre of the corporate stage (Schmitt off, C.M., Salomon in the shadow [1976] JBL 305)." essay for you Create order Salomon v Salomon Salmon v Salomon is an important case, as it established the principle that a limited company has a separate legal personality from its members. This is enshrined in s.74(2) Insolvency Act 1986, which states that in a company limited by shares, no member (or shareholder) is liable for any of the companys debts other than the amount (if any) on any unpaid shares. This is a great incentive for investors, who know that even if a limited company in which they own shares, owes millions of pounds in debts, their own personal assets are safe[7]. In Salomon a sole trader incorporated his business into a limited company. When the company failed, the liquidators argued that Salomon and the company were effectively one and the same. However, the House of Lords said that the company was a legal entity distinct from its members. Therefore, Salomon himself was not liable for the companys debts. This separation between members and company is called the corporate veil. Corporate personality means that a company can sue and be sued in its own right and be a party to contracts, and exist after the death of its shareholders[8]. This was recognised by the House of Lords in VTB Capital v Nutritek Intl Corpn[9] where Lord Neuberger said: A company should be treated as being a person by the law in the same way as a human being. Therefore, the Salomon principle remains an important part of corporate law today. Lifting the veil However, there are several exceptions to this principle. In these cases courts lift the corporate veil to make members liable for the actions of the company[10]. This undermines the notion that Salomon occupies the centre stage in corporate law today. Statute s.213 Insolvency Act 1986 states that if, while winding up a company, the companys business is carried on with intent to defraud the companys creditors, a court may order any person knowingly carrying on the business to contribute to the companys assets. This goes against Salomon, as it holds the companys members responsible for its debts. However, it requires evidence of dishonesty[11]. This is difficult to prove. s.214 Insolvency Act 1986 states that if, while winding up a company, a director ought to have seen that there was no reasonable prospect of avoiding insolvency but continued to carry on business, then a court may hold them liable. There is no need for any dishonesty. However, this only applies to directors and not shareholders. Even so, the Companies Act 2006 states that a director includes a shadow director, which includes anyone other than a professional advisor in accordance with whose directions or instructions the directors of the company are accustomed to act[1 2]. This could include a parent company if they have direct control over one of their subsidiary companies. Therefore, in a limited way, this restricts the Salomon principle where there is wrongdoing involving the company. War Courts may also ignore the corporate veil during wartime. In Daimler Co Ltd v Continental Tyre and Rubber Co (Great Britain) Ltd[13] a company was incorporated in England but the vast majority of its members were German. The House of Lords stated that whether a company was an enemy in wartime depended upon those who were in control of the company. This goes against the principle of separate corporate personality and weakens the idea that Salomon is always to be followed. Sham Courts have also ignored the corporate veil where a company is a sham designed to commit fraud or avoid an existing contractual obligation. For instance, in Gilford Motor Co v Horne[14] the defendant was a former director of a company who signed an agreement that he would not solicit his former employers customers. Instead, he and his wife incorporated another company which he used to breach the agreement. The court held that the second company was simply a cloak, or a sham and held the defendant liable. However, courts will not lift the veil if the company is set up to avoid future liabilities[15]. Some commentators also argue that these cases do not involve lifting the corporate veil at all. Mayson, French and Ryan state that even if the agency used to commit the fraud or evade the obligation had been another person rather than a company, the result would have been the same[16]. The court in Gilford recognised this by making orders against both the defendant and the company. I f this is correct, these cases do not necessarily go against Salomon v Salomon. Agency Courts have also ignored the veil where they have found an agency relationship existed. In Re FG Films Ltd[17] a company sought a declaration that it had made a British film for financial reasons. The court held that in fact the UK company was only the agent for an American company which owned the vast majority of its shares. The UK company also had no place of business and existed only so that the film could be called British. The court, therefore, lifted the veil. However, this has been criticised by commentators who note that, if this is correct, a court could infer an agency relationship merely from the act of being a shareholder[18]. Therefore, this High Court case seems to be wrongly decided, and the House of Lords decision in Salomon remains the higher authority. Trusts Courts have also ignored the corporate veil where they have found a trust relationship exists. In Trebanog Working Mens Club and Institutive Ltd v MacDonald[19] an incorporated club was charged with selling liquor without a licence. The court held that as the members owned the liquor between themselves, there was no actual sale, and the club was simply a trustee of the liquor for its members. However, this contradicts an earlier case where the opposite decision was reached[20], and commentators note that this argument is at best tenuous[21]. Therefore, this probably does not undermine Salomon. Groups Case law is more contradictory as to whether groups of companies will be treated as another exception to Salomon. In a group, the parent company can own a number of subsidiary companies and still have separate corporate personality from them[22]. Traditionally, courts have held that this is a legitimate use of the corporate form, and that each company in a group is a separate legal entity[23]. However, in DHN Food Distributors Ltd v Tower Hamlets LBC[24], Denning MR in the Court of Appeal held that a parent company and its subsidiaries were a single economic entity as the subsidiaries were bound hand and foot to the parent company, so the group was the same as a partnership. This undermines the Salomon principle. In Woolfson v Strathclyde Regional Council[25], the House of Lords disapproved of Dennings comments and said that the corporate veil would be upheld unless the company was a faÃÆ'Â §ade. The DHN case approach has become less popular since then[26]. Commentators also n ote that the DHN case is self-contradictory[27]. Denning refers to the subsidiaries as being bound hand and foot to the parent company, which implies the parent has control, but he also says they are partners, which implies they have equal power. Therefore, it seems unlikely that DHN will be followed in future, especially given the Court of Appeals later decision in Adams v Cape Industries plc. Cases that support the Salomon principle In Adams v Cape an English company was sued for the actions of one of its subsidiaries abroad. The subsidiary had caused injury to its workers through asbestos exposure. The Court of Appeal held that the parent company was not liable. The court held that the subsidiary was not a faÃÆ'Â §ade or sham as the group had been structured that way only to minimize future liabilities. The court also rejected the argument that the subsidiary was an agent for the parent company, as the subsidiary was carrying on its own business. Finally, the court held that there was no general principle that all the companies in a group should always be treated as a single economic entity. This reaffirms the Salomon principle. In fact the court in Adams stated that DHN could be explained as a matter of statutory interpretation of the regulations regarding compulsory purchases at the time, and hence it did not actually involve lifting the corporate veil. Dignam says: Gone are the wild and crazy days whe n the Court of Appeal would lift the veil to achieve justice irrespective of the legal efficacy of the corporate structure[28]. Therefore, Adams restores the primacy of Salomon v Salomon. This is supported by the recent Supreme Court decision in Prest v Petrodel Resources Ltd, where a divorced wife claimed shares in houses owned by companies in which her ex-husband was the controlling shareholder. She asked the court to lift the corporate veil and treat her ex-husband and the companies as being effectively the same. However, the court held that the veil could not be lifted without evidence of impropriety. The setting up of the companies had nothing to do with the marriage breakdown. Therefore, the court refused to lift the veil. Lord Sumption stated that the veil could only be lifted if there was a legal right against the controller of a company and the companys separate legal personality frustrated that right[29]. Also, it must be necessary for the court to lift the veil on p ublic policy grounds. Critics have noted that it is very unlikely that these requirements will be met[30]. Also, although Lord Sumptions comments were obiter, they have been cited with approval in other cases and are therefore likely to be authoritative[31]. However, Baroness Hale in the same case did not agree, saying that she believed there were more cases where the veil could be lifted[32]. Therefore, the judgments are contradictory. In the end, the court decided that the properties were held on resulting trust for the ex-husband and could be claimed by his ex-wife. This arguably achieves the same thing as if the court had lifted the veil. Consequently, all that can be said is that the case does not rule out ignoring Salomon in cases involving groups of companies. A new attitude? Another exception to Salomon involves tortious liability. In Chandler v Cape the claimant had also contracted an asbestos-related disease while working for a subsidiary of the parent company. This time the Court of Appeal held the parent liable in the tort of negligence. The court held that the parent would be liable if the parent and subsidiary were in the same business, the parent had superior knowledge of health and safety in that industry, the parent ought to have known the subsidiarys system of work was unsafe, and the parent ought to have foreseen that the subsidiary would rely on the parents superior knowledge. This undermines the Salomon principle. However, critics note that Cape had an unusual business organisation where it was deeply involved in the day-to-day supervision of the subsidiarys health and safety policy. Therefore, the case may turn out to be Cape specific[33]. For instance, in a later case with similar facts but concerning a different company, the Court of Appeal refused to hold the parent company liable[34]. In Chandler Lady Hale also emphatically rejected that this was a case of corporate veil lifting, saying that the parent had instead assumed a direct duty of care for the employee. In view of this, some critics state that the case may not be setting any useful precedent[35]. However, others view this clearly as veil lifting, regardless of how the court justified this[36]. These commentators believe that this suggests that the Court of Appeal is now more willing to lift the veil where there is a group of companies and it is in the interests of justice[37]. However, this was rejected in Adams v Cape. Even so, in Conway v Ratiu[38] the court again said there was a powerful argument for lifting the veil where it accords with common sense and justice. Unfortunately, this case is per incuriam as it did not refer to Adams v Cape and is probably wrong. Even so, in Lubbe v Cape Plc[39] the House of Lords were ready to lift the veil in the interests of justice in facts similar to Adams v Cape, as the foreign jurisdiction where the tort occurred was not an appropriate place to try the matter. Therefore, there is authority for lifting the veil when justice demands it. In following Lubbe, the court in Chandler v Cape achieved justice, as the victims would otherwise have been denied a remedy. This is important where the subsidiary no longer exists or has any assets[40] or with asbestos claims where the disease may not show up for many years[41]. The Supreme Court in Prest v Petrodel was also concerned with achieving justice for the claimant[42], and in the VTB case Lord Neuberger said: it may be right for the law to permit the veil to be pierced in certain circumstances in order to defeat injustice[43]. Therefore, it seems that the courts are willing to disregard the Salomon principle in some cases involving personal injury or groups of companies. This seems fair, as limited liability encourages subsidiary co mpanies to take risks, knowing that the shareholders of the parent company in effect get double protection from creditors should anything go wrong[44]. To hold otherwise would have been to deny justice to the claimant in Chandler v Cape. Conclusion The principle of separate corporate personality and the corporate veil recognised in Salomon v Salomon remains central to corporate law despite several challenges. However, there are certain exceptions when the veil will be lifted. Most notably these include under statute, during wartime, and where the company is a sham. It is less likely to be lifted where it is argued that an agency or trust relationship existed between the company and its controller. Where groups are involved, Salomon remains the starting point. However, courts have been more willing to lift the veil recently, especially where personal injury is involved or justice demands it, even if they do not say so explicitly. This seems fair, as otherwise shareholders enjoy double protection. BIBLIOGRAPHY Legislation Companies Act 2006 Insolvency Act 1986 Cases Adams v Cape Industries Plc [1990] Ch 433 (CA) The Albazero [1977] AC 774 (HL) Chandler v Cape Plc [2012] 1 WLR 3111 (CA) Conway v Ratiu [2005] EWCA Civ 1302 (CA) Daimler Co Ltd v Continental Tyre and Rubber Co (Great Britain) Ltd [1916] 2 AC 307 (HL) DHN Food Distributors Ltd v Tower Hamlets LBC [1976] 1 WLR 852 (CA) Re FG Films Ltd [1953] 1 WLR 483 (Ch) Gilford Motor Co Ltd v Horne [1933] Ch 935 (CA) Lubbe v Cape Plc [2000] 1 WLR 1545 (HL) Re Patrick and Lyon Ltd [1933] Ch 786 (Ch) Prest v Petrodel Resources Ltd [2013] UKSC 34 (SC) Salomon v A Salomon Co Ltd [1897] AC 22 (HL) Thompson v Renwick Group Plc [2014] EWCA Civ 635 (CA) Trebanog Working Mens Club and Institutive Ltd v MacDonald [1940] 1 KB 576 (KB) VTB Capital v Nutritek Intl Corpn [2013] UKSC 5 (SC) Woolfson v Stathclyde Regional Council [1978] P CR 521 (HL) Wurzel v Houghton Main Home Delivery Service Ltd [1937] 1 KB 380 (KB) Other Sources Anon, Case Comment: Chandler v Cape Plc: is there a chink in the corporate veil? (2012) 18(3) HSW 1 A Dignam, Hicks and Goos Cases and Materials on Company Law (7th edn Oxford University Press, Oxford 2011) D French and S Mayson and C Ryan, Mayson, French Ryan on Company Law (27th edn Oxford University Press, Oxford 2010) J Fulbrook, Chandler v Cape Plc: personal injury: liability: negligence (2013) 3 JPIL C135 L Sealy and S Worthington, Company Law: Text, Cases and Materials (9th edn Oxford University Press, Oxford, 2010) L Stockin Piercing the corporate veil: reconciling R. v Sale, Prest v Petrodel Resources Ltd and VTB Capital Plc v Nutritek International Corp (2014) 35(12) Company Lawyer 363 C Taylor, Company Law (Pearson Education Ltd, Harlow 2009) Footnotes [1897] AC 22 (HL). L Sealy and S Worthington, Company Law: Text, Cases and Materials (9th edn Oxford University Press, Oxford, 2010) 51. A Dignam, Hicks and Goos Cases and Materials on Company Law (7th edn Oxford University Press, Oxford 2011) 28. [1990] Ch 433 (CA). [2013] UKSC 34 (SC). [2012] 1 WLR 3111 (CA). C Taylor, Company Law (Pearson Education Ltd, Harlow 2009) 26. Ibid 27. [2013] UKSC 5(SC) Sealy and Worthington (n2) 51. Re Patrick and Lyon Ltd [1933] Ch 786 (Ch). s.251 Companies Act 2006. [1916] 2 AC 307 (HL). [1933] Ch 935 (CA). Adams v Cape Industries Plc [1990] Ch 433 (CA). D French and S Mayson and C Ryan, Mayson, French Ryan on Company Law (27th edn Oxford University Press, Oxford 2010) 136. [1953] 1 WLR 483 (Ch). Sealy and Worthington (n2) 59. [1940] 1 KB 576 (KB). Wurzel v Houghton Main Home Delivery Service Ltd [1937] 1 KB 380 (KB). Sealy and Worthington (n2) 60. Taylor (n7) 31. The Albazero [1977] AC 774 (HL). [1976] 1 WLR 852 (CA). [1978] P CR 521 (HL). Taylor (n7) 34. French, Mayson and Ryan (n16) 145. Dignam (n3) 40. Para 35. L Stockin Piercing the corporate veil: reconciling R. v Sale, Prest v Petrodel Resources Ltd and VTB Capital Plc v Nutritek International Corp (2014) 35(12) Company Lawyer 364. Ibid, 363. Para 92. J Fulbrook, Chandler v Cape Plc: personal injury: liability: negligence (2013) 3 JPIL C138. Thompson v Renwick Group Plc [2014] EWCA Civ 635 (CA). Fulbrook (n33) 138. Dignam (n3) 46. French, Mayson and Ryan (n16) 150. [2005] EWCA Civ 1302 (CA). [2000] 1 WLR 1545 (HL). Anon, Case Comment: Chandler v Cape Plc: is there a chink in the corporate veil? (2012) 18(3) HSW 2. Ibid. Stockin (n30) 365. Para 127. Dignam (n3) 49.

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A Martian Sends a Postcard Home free essay sample

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Childhood Trauma and Substance Abuse in Adulthood Essay Example For Students

Childhood Trauma and Substance Abuse in Adulthood Essay By: Lauren Gonder CA 401 Child Advocacy II: Responses, Dr.QuandaStevenson Children are precious yet pliable beings. Children develop through their experiences both physically and psychologically. These experiences calibrate the brain and the body to prepare us for the different environments we face. If a child is brought up in a home where they are constantly being abused and/or neglected, they are programed into learning to take care of themselves. Emotional problems arise when a child is faced with abuse and/or neglect. As they grow older, they may beledto become a part ofa badcrowd, to feellike they are a part of something,or to self-medicatetoblock unwanted feelings. There has been a resurgence in the understanding of what makes a person addicted. Early childhood trauma may be the link to substance abuse in adulthood because of neurological anomalies and emotional trauma. We will write a custom essay on Childhood Trauma and Substance Abuse in Adulthood specifically for you for only $16.38 $13.9/page Order now Brain plasticity is the brains ability to change at any age, whether it be for the best or the worst. How the braindevelops and its physical structure can be affected by ones experiences, positive or negative. Positive experiences, like a nurturing upbringing, is where a child will thrive in most conditions. Negative experiences, like abuse and/or neglect, causeselevated levelsof stress and can obstruct the brains development. Not all stress is bad, though. Our brain works like a muscle and learning requires a small amount of stress. Its when the stress is too large, too often, or too erratic for one person to control. Child maltreatment effects the brainsnormalstructure that impact cognitive, behavioral, and socialattributes. Studies have proven that children who are mistreated are the causesfor thehigh levelsof stress with in turn causesdisruptions in the brainsnormalstructure. Thesedisruptions have been studied in neurological scans proving victims of trauma are vulnerable to sub stance abuse. Emotional or psychological trauma is a form of damage to the mind that occursas a result ofa severely distressing event. Neglect, loss of a parent, witnessing domestic violence, and having a family member who suffers from a mental illness are just a few of the occurrences thatpromote emotional trauma. The study of Adverse Childhood Experiences (ACE) was studied and proven that different stress-producing experiences that occur during childhood are the explanations of substance abuse and other forms of impulsive disorders. The study calculated the amount of ACEs a person endured, and depending on the quantity of experiences, the greater the probability of becoming an alcoholic or intravenous drug user. The experiences that are extremely traumatic for children are much less traumatic for adults. Children are limited in their ability to make contextual interpretations, lack a frame of reference, and have difficulties making sense of these experiences. Significant occurrences have a last ing effect on children and are more likely to linger. Children are supposed to be able to rely on their loved ones for support, but when a childs loved ones are the center of the abuse, neglect, or other trauma, family support is not an option. When a person is faced with a difficult situation and has no one to turn to, they will use alcohol or drugs to lessen the effects of being victimized. Self-medication is also modeled from a potential family members substance abuse. Having a substance abuse problem on top of early traumatic eventsonly makes recovery that much harder. Having a working knowledge of the events that lead up to substance abuse can better assist medical professionals in the recovery of these dual-disorders. In addition, knowing that early childhood traumatic experiences provoke substance abuse and other reckless addictions, the federal and state institutions, andsocietyas a whole, canwork towards preventing child maltreatment. Parents need to be aware of their stresses in knowing that they can be the defining factor in how their childs brain develops. Putting a stopto child maltreatment can reduce the amount of people who develop substance abuse disorders and in turn reduce other contributing factors that hinder society. Bibliography BIBLIOGRAPHYFelitti, V. J. (2004, February 16). The Origins of Addiction: Evidence from the Adverse Childhood Experiences Study.ACE Study Article. Retrieved from http://www.nijc.org/pdfs/Subject%20Matter %20Articles/Drugs%20and%20Alc/ACE%20Study%20-%20OriginsofAddiction.pdf Gregorie, C. (2016, January 27). Why This Doctor Believes Addictions Start In Childhood. The Huffington Post. Retrieved from http://www.huffingtonpost.com/entry/gabor-mate-addiction_us_569fd18ae4b0fca5ba76415c NCTSN. (2008, June). Making the Connection: Trauma and Substance Abuse. Retrieved from http://www.nctsn.org/sites/default/files/assets/pdfs/SAToolkit_1.pdf OLeary, D. (2017). The Unfortunate Connection Between Childhood Trauma and Addiction in Adulthood. Retrieved from http://www.dualdiagnosis.org/unfortunate-connection-childhood-trauma-addiction-adulthood/ Putnam, F. W. (2006). The Impact of Trauma on Child Development.Juvenile and Family Court Journal, 1-11. .ue0bcdc1cb8583e95f406db69887ddf46 , .ue0bcdc1cb8583e95f406db69887ddf46 .postImageUrl , .ue0bcdc1cb8583e95f406db69887ddf46 .centered-text-area { min-height: 80px; position: relative; } .ue0bcdc1cb8583e95f406db69887ddf46 , .ue0bcdc1cb8583e95f406db69887ddf46:hover , .ue0bcdc1cb8583e95f406db69887ddf46:visited , .ue0bcdc1cb8583e95f406db69887ddf46:active { border:0!important; } .ue0bcdc1cb8583e95f406db69887ddf46 .clearfix:after { content: ""; display: table; clear: both; } .ue0bcdc1cb8583e95f406db69887ddf46 { display: block; transition: background-color 250ms; webkit-transition: background-color 250ms; width: 100%; opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #95A5A6; } .ue0bcdc1cb8583e95f406db69887ddf46:active , .ue0bcdc1cb8583e95f406db69887ddf46:hover { opacity: 1; transition: opacity 250ms; webkit-transition: opacity 250ms; background-color: #2C3E50; } .ue0bcdc1cb8583e95f406db69887ddf46 .centered-text-area { width: 100%; position: relative ; } .ue0bcdc1cb8583e95f406db69887ddf46 .ctaText { border-bottom: 0 solid #fff; color: #2980B9; font-size: 16px; font-weight: bold; margin: 0; padding: 0; text-decoration: underline; } .ue0bcdc1cb8583e95f406db69887ddf46 .postTitle { color: #FFFFFF; font-size: 16px; font-weight: 600; margin: 0; padding: 0; width: 100%; } .ue0bcdc1cb8583e95f406db69887ddf46 .ctaButton { background-color: #7F8C8D!important; color: #2980B9; border: none; border-radius: 3px; box-shadow: none; font-size: 14px; font-weight: bold; line-height: 26px; moz-border-radius: 3px; text-align: center; text-decoration: none; text-shadow: none; width: 80px; min-height: 80px; background: url(https://artscolumbia.org/wp-content/plugins/intelly-related-posts/assets/images/simple-arrow.png)no-repeat; position: absolute; right: 0; top: 0; } .ue0bcdc1cb8583e95f406db69887ddf46:hover .ctaButton { background-color: #34495E!important; } .ue0bcdc1cb8583e95f406db69887ddf46 .centered-text { display: table; height: 80px; padding-left : 18px; top: 0; } .ue0bcdc1cb8583e95f406db69887ddf46 .ue0bcdc1cb8583e95f406db69887ddf46-content { display: table-cell; margin: 0; padding: 0; padding-right: 108px; position: relative; vertical-align: middle; width: 100%; } .ue0bcdc1cb8583e95f406db69887ddf46:after { content: ""; display: block; clear: both; } READ: Essay Paper For The Chocolate War Sack, D. (2012, March 22). Emotional Trauma: An Often Overlooked Root of Addiction. Retrieved from https://blogs.psychcentral.com/addiction-recovery/2012/03/emotional-trauma-addiction/ Szalavitz, M. (2011, September 25). How Childhood Trauma Creates Life-long Adult Addicts. Retrieved from https://www.thefix.com/content/trauma-and-addiction9180

Non-directive interviews Essay Example

Non-directive interviews Essay There are a number of different research methods I can use for my primary research, but I have decided that the methods that will benefit my research are: questionnaires, non-directive interviews and structured interviews I am going to begin with a pilot study before going onto my interviews. By doing this I should be able to obtain some valuable information which I will be able to put into numerical form e.g. pie charts, statistics and percentages.This is a big advantage as I will be able to compare data easily and it will give me a better understanding of what teenage girls feel about the pressures of dieting. Questionnaires are also a cheap, efficient and fast method for obtaining large amounts of information, which is helpful to me, as I do not have much time to carry out my primary research. Potentially, information can be collected from a large portion of a group, but this potential is not often realized as returns from questionnaires are usually low.For example, postal questionnaires are a relatively inexpensive method of obtaining information but often only a very small percent of the sample return them and those who do often have a special reason for doing so which makes the results untypical as a whole. We will write a custom essay sample on Non-directive interviews specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Non-directive interviews specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Non-directive interviews specifically for you FOR ONLY $16.38 $13.9/page Hire Writer This is why I have decided not to send postal questionnaires but to give them to girls at my school instead, this way I will be able to make sure that everyone returns their completed form to me. I am going to use random sampling in order for my results to be more representative of teenage girls as a whole. I will go through a register for each year group from years 7-13 and cross of every third name until I have ten names from each year. I will then give each person a questionnaire to fill out.However, there are some disadvantages of using questionnaires in my study. Respondents may answer superficially especially if the questionnaire takes a long time to complete, so I will make sure that the common mistake of asking too many questions is avoided. Great care must also be taken when wording the questions so there is no bias, or words that some people may misinterpret or not understand. If this happens my results may not be as representative or accurate as they could be. I will also avoid including open-ended questions as these can generate large amounts of data that can take a long time to process and analyse.Some girls may not be willing to answer some of the questions as my project is on quite a sensitive topic, especially for girls. So I will ask them to reply honestly and tell them that the questionnaire is anonymous. My second research method is unstructured interviews. With non-directive interviews there are few problems of misunderstanding or misinterpretation and the interviewee is not restricted to set questions like in questionnaires, they can really say how they feel. The respondent is in control of the content of the interview and is free to explore any aspect of the topic they want. This will give me a more in-depth and detailed insight into the real thoughts and feelings of the interviewee.However, there are a few disadvantages with using this method. By using an unstructured interview it is difficult to generalise as it is a small sample, and in my case only one persons opinion. This also makes it harder to analyse or make any generalisation that all girls feel the same way as the respondent does. There could also be interviewer bias which is quite a big disadvantage. I could in some way influence or direct the answers given by the interviewee, therefore the respondent may change their answer according to the type of question given. But if I am careful with how I phrase and say my questions, I should be able to avoid any interviewer bias.My third research method is structured interviews. The advantage of structured interviews is that they allow the exploration of specific topics, while allowing people to tell the interviewer what they think is important. I am going to video- tape the opinions of five teenage girls on dieting and the media. I aim to find out if they feel pressured at all by the media to be slim and how far they have taken dieting in order to achieve this media image of the perfect female body. I think it will be interesting to see how their answers compare and differ by asking the same questions to five different girls.Structured interviews give the respondent the chance to speak for themselves about the topic and the chance to clarify complex questions. However success depends on the skill of the interviewer, but I will spend time making sure that the questions I ask will be beneficial to my project. Another disadvantage is that I may give out unconscious signals to the respondent which may lead them to change their reply. Another problem is that I might only follow up my areas of interest there fore restricting the respondents answers. These interviews can also be very time consuming, so I have only decided to interview five people for my study.There are some types of primary research which I have decided not to use. Methods such as longitudinal studies and participant observation would require a great amount of time which I would like to have, but have not got enough time to carry out properly. A longitudinal study is an ideal way of understanding social life at one point in time, but in order to understand social life in the present it is essential to see it as a development from the past. This method requires a picture of social life over a long time which is not possible for me to do.With participant observation the number of people observed is small therefore generalisations are not possible. This method would not be very useful to my project either, as it would be hard to observe peoples eating habits without asking personal questions about weight etc and many people would find covert observation for my topic unethical. A case study could be a good source of primary data for me to use as they can give a more detailed picture than research based on large samples. However, as they are seen as one off examples they cannot be seen as representative. They are also quite time consuming. I am confident that my chosen research methods will provide me with some valuable information from which I can analyse and draw a conclusion from.

PSAT Test Dates 2015

PSAT Test Dates 2015 SAT / ACT Prep Online Guides and Tips The PSAT test dates of 2015 have come and gone, but they are not forgotten - especially for students aiming to become National Merit Finalists. This guide will go over the exact PSAT test dates in 2015, as well as discuss how test-takers can make the most of their PSAT score reports today. If you’re looking for future PSAT test dates, then check out this guide instead. If you’re in the right spot, then read on to learn about how the PSAT testing schedule works for participating students. What to Know About PSAT Test Dates Unlike many other standardized tests, like the SAT or ACT, you don’t choose when you take the PSAT. Instead, your high school registers juniors and chooses the test date from two options in October. If you’re a ninth or tenth grader who wants to take the PSAT, then you have to ask your school counselor to sign you up. College Board gave schools two choices for test dates in 2015, a primary and an alternate. Both test dates fell on a weekday, on a Wednesday to be exact. Most schools administered the PSAT on the primary test date. Below are the exact dates for the primary and alternate testing dates for the PSAT in 2015. PSAT Test Dates in 2015 Schools administered the PSAT on one of these two test dates in 2015. Primary test date: October 14, 2015 Alternate test date: October 28, 2015 Most schools held the PSAT on October 14, 2015. The only exception would be if the school had a scheduling conflict that day and had to go with the alternate test date. Once students took the PSAT, they waited a few months to get back their scores. For juniors, October is the month of pumpkins, pie, and the PSAT. When Did 2015 PSAT Scores Come Out? Scores from the 2015 PSAT came out on January 7th, 2016. On that date, students could sign into their College Board accounts and view their score reports. Counselors actually had access to the scores one day earlier, on January 6. In addition to online score reports, students got paper score reports around January 29. Forstudents who took the PSAT in 2015 or who will be taking it in the future, why are PSAT scores important? Why Are PSAT Scores Important? PSAT scores are important for two main reasons. First, they give you essential feedback about your skills as a test-taker, and you can use that feedback to prepare for the SAT. Secondly, PSAT score reports tell any juniors who took the test whether or not they will qualify for National Merit distinction and scholarships. Let’s take a closer look at both of these functions of your PSAT scores. 1. Practice and Feedback for the SAT The PSAT and SAT are very similar tests, so your score report on the PSAT can help you figure out how to improve for the SAT. Both tests have Reading, Writing and Language, and math sections. The main difference is that the PSAT doesn’t have an essay section. Your PSAT score report will give you detailed feedback on your performance. You should take time to look at your results and pinpoint your strengths and weaknesses. If you struggled on the math section, for instance, then you can focus especially on math as you get ready for the SAT. By figuring out where you lost points, you can make efforts to get those kinds of questions right for next time. Your score report can also prompt you to reflect on the test-taking experience. Did you find yourself running out of time? Would you benefit from trying new test-taking strategies, like process of elimination on vocabulary questions? If you took the PSAT in 2015 and are still planning to take the SAT, you should carefully consider your PSAT score report and use it to design your SAT prep plan. Your PSAT score report gives you useful feedback on your skills as a test-taker. You can use that insightas you get ready for the SAT. 2. National Merit Distinctions and Scholarships If you took the PSAT as a junior, then you’re in the running for National Merit distinction and scholarships. The top 3% to 4% of scorers werenamed Commended Scholars, while students who score in the top 1% werenamed Semifinalists and couldmove on to become Finalists and win scholarship money. National Merit Scholarship Corporation hasn’t released its exact state-by-state cutoffs yet, but we can estimate the cutoffs based on data from past years. About a year after they took the PSAT in 2015, about 16,000 students across the country foundout if they achieved Semifinalist status. If you were one of those students who took the PSAT in October 2015, how can you make the most of your PSAT score report now? Make the Most of Your PSAT Score Report If you’re still planning to take the SAT, then your PSAT score report can help you design a study plan. Look closely at the sections where you excelled and the sections where you could use some improvement. Think about what skills you can work on to get better as a test-taker, whether you need to review specific concepts or practice time management. As you study for the SAT, try to identify and target your weak areas. Gather lots of practice questions, time yourself, and score your practice tests. Continue to measure your progress with your practice test score reports, just as you did with your PSAT score report. By taking time to analyze your PSAT and SAT practice test score reports, you can root out your weak areas and gaugeyour progress as you work toward your target SAT scores. In closing, let’s go over the key points you should remember about the PSAT in 2015, how it was administered, and how you can make the most of your PSAT score report now. Use your PSAT score report to target your weak areas and improve for the next test you take. PSAT in 2015: Key Takeaways Most schools administered the PSAT on Wednesday, October 14, 2015. Juniors automatically tookthe test and competed for National Merit distinction. Younger students couldalso request to take the test, and they coulduse the experience as practice for the junior year PSAT and the SAT. If you took the test in 2015, then you got your scores online on January 7th. Whether you’re competing for National Merit or prepping for the SAT, you can gain valuable insight from your PSAT score report. Take time to analyze your performance, figure out your strengths and weaknesses, and reflect on the experience to get ready for the SAT. What’s Next? Are you preparing to take the SAT? Check out our ultimate SAT prep guides for the Reading, Writing and Language, and Math sections of the SAT. Did you take the PSAT as a younger student in 2015? If you're aiming for top scores when you take the test as a junior, check out this full guide to getting a perfect score on the PSAT. Have you started taking steps to apply to college? For a full overview of the entire college application process, check out this comprehensive guide. Want to improve your SAT score by 160 points or your ACT score by 4 points?We've written a guide for each test about the top 5 strategies you must be using to have a shot at improving your score. Download it for free now:

Relationship marketing Essay Example | Topics and Well Written Essays - 3000 words

Relationship marketing - Essay Example It also entails additional risk when compared to domestic marketing. Many factors like culture, statutory obligations, working styles and environment, availability of technology and skilled manpower, and a host of other factors have to be taken into account. This paper is a study of relationship marketing in the context of retail trade in international markets. In the process it will provide a broad outlook on the various factors that a company has to take into account to be successful in international markets. Baker quoting Moller and Wilson defines this concept as â€Å"understanding, creating, and managing exchange relationships between economic partners, manufacturers, service providers, various channel partners, and final consumers† (Baker 2003, 33). In effect relationship marketing is just not about having profitable and mutually beneficial relationships between the retailer and the end consumer. Christopher et al, states that there are six different markets to be analyzed, referred to as the ‘six market domains’. They are customer, recruitment, referral, internal, influence, supplier & alliance markets (Christopher, Payne & Ballantyne 2002, 202). Most of these terms are self-explanatory and hence some examples of a couple of markets is given here. According to the authors, Mercedes, Rolex, and Dell are examples of products that benefit from referral sales. Influence markets are those where a company needs to exert influence on a person, organization, trade unions , or even government. The authors illustrate this with the example of how Johnson & Johnson managed the Tylenol disaster. The company managed to save its international reputation through practical and effective steps. International marketing can have different dimensions or approaches. According to Doole & Lowe, companies can just market their products internationally which is the simplest form of such marketing. In a more complex approach, companies set up their own manufacturing, and