People’s Attitude Towards Abortion in Australia free essay sample

People’s disposition towards fetus removal in Australia Abstract: The speculation, â€Å"It is clear that in Australia individuals are not steady of premature birth. † would be tried in the report. Its point was to uncover the current perspectives on individuals in Australia towards fetus removal, considering the present situation of various age and social foundation. A poll about supported reasons, authorization and qualities on fetus removal was built and the objective gathering would be 20 universal understudies and 20 nearby Australians. The universal understudies were for the most part Chinese, and a couple from South-East Asia. Despite the fact that most members didn't have an extremely solid position of supporting premature birth or not, when there were further inquiries regarding Pro-decision conduct and authorization of fetus removal, it was found that members were very regard of opportunity of decision, and concurred that fetus removal ought to be legitimized. Along these lines one might say that looking at the 2 sides, members were fairly strong to fetus removal. In light of the outcomes, broadened investigates covering a bigger objective gathering which could for the most part speak to various social gatherings could be led to test whether fetus removal was actually commonly worthy or not or would it be able to be sanctioned under all cases. We will compose a custom article test on People’s Attitude Towards Abortion in Australia or then again any comparable point explicitly for you Don't WasteYour Time Recruit WRITER Just 13.90/page Presentation Abortion had been a disputable issue for many years, conversations and discussions were constantly held to contend whether it ought to or ought not be proclaimed lawful. This issue was significant at record-breaking in light of the fact that the mentality towards it were for the most part affected by different significant estimations of life like profound quality, human rights and opportunity of decision, including that they were the key variables to decide if it ought to be announced lawful. â€Å"Abortion can be characterized as the ejection or expulsion of an undeveloped organism or hatchling from the uterus of the pregnant mother† (Blade, 2008). It could be partitioned into two kinds. To begin with, the â€Å"spontaneous abortion† happens when the mother’s body discharges the baby because of various reasons, generally characteristic ones (without human exertion). This report concentrated on another sort of premature birth, â€Å"induced abortion†. This was what individuals generally mean when they utilize the word fetus removal. As such, it was the â€Å"termination of pregnancy†. After the Federation in 1901, fetus removal was taken care of by the British Offenses Against the Person Act of 1861. In the demonstration, premature birth was unlawful , regardless of under what conditions. Notwithstanding, from that point forward, premature birth would be lawful at times under the law. For example, Natasha,(1998), proposed that under the McGuire administering (1986) in Queensland, fetus removal must be sanctioned when the mother was in danger that premature birth could protect her life or wellbeing. Another case that premature birth could be authorized was that if the infant would bite the dust quickly or inside a brief period. For the current enactment about it in Queensland under the Queensland Criminal Code, the perspective stayed comparable that the court would preclude fetus removal except if the moms life or wellbeing is in harm's way. However, it didn't uncover any reaction on the difference in perspectives of individuals towards fetus removal. The point of the report was to uncover the current perspectives on individuals in Australia towards premature birth, in light of the current situation of various age and social background(international understudies versus nearby Australians). It gave the idea that these days an ever increasing number of individuals were steady to fetus removal. This view would be bolstered by the outcomes from study and afterward a conversation some portion of it would be incorporated and finally the end and suggestion would be defined. Philosophy: Questionnaires about the mentalities of premature birth of individuals were utilized to gather information for the report. A subjective approach was utilized. The purpose behind picking it was on the grounds that the report concentrated more on profundity, as opposed to amount. As per the Family Health International (2005), a subjective exploration gave data about the â€Å"human† side of an issue, which was regularly conflicting. It could likewise decipher the perplexing reality or make a superior comprehension to a particular circumstance and the ramifications of the subjective information. Another significant point was that it could help recognize immaterial elements (age, sex, nationality, religion, and so on) in the report. These variables were the keys that impact a person’s mentality toward the issue. The accentuation of the poll was to comprehend participant’s angles possibly in support of premature birth, in this way 10 out of 14 inquiries were about their sentiment, the rest were 3 trait questions and 1 information question. The complete number of members was 40. There were by and large 20 worldwide understudies concentrating in Australia and 20 neighborhood Australians finished the poll. Among the members, 23 of them were female and 17 were male. In the understudy gathering, 2 of them were under or underneath 18 and 18 were at 19 years old to 30. Among the nearby Australians, 6 of them were between 31-45 and another 14 were 45 or above. A point to note was that for the universal understudies, 15 of them were Chinese. To ensure the data would be left well enough alone, no inquiries were about personality or other private data. The surveys were given out in two different ways. The primary path was to convey them at school and at homes, and another route was to circulate them through the web. Members were very intrigued to the poll as they believed that it was a disputable issue. Anyway all the while, members discovered mistook for the last open-cut off inquiry concerning the association between culture, age and premature birth as it was not required to state reasons however lines were given. Besides, because of an absence of time in finishing the poll, I. e. in 5 or 10 minutes, the information gathered may be mutilated. Results: The motivation behind the poll was to discover the perspectives of individuals in Australia towards fetus removal.

Effect of Reward Management on Employee Motivation

Impact of Reward Management on Employee Motivation In what capacity can Multi National Companies use Reward the board to propel the Employees of Different Countries? : A Case of Marriott Hotels in UK. Conceptual Workers are constantly considered as individuals who assume a fundamental job in every single association. The connection among worker and boss changes as often as possible consistently. A few ideas of workers are likewise fluctuating time by time. Presently a days representatives are having the haggling force and they are progressively worried about their individual needs and prosperity of their workplace. This thesis investigations different variables which persuades a worker to work inside an association. Worker will remain in an association just when their desires are fulfilled or in any case there is an opportunity for him/her to leave the organization. High worker turnover is a major issue in organizations today. Associations will anticipate hold just the potential key representatives who will have genuine effect to their clients and their partners. This thesis proposes an edge work to hold the representatives and to compensate those representatives for their potential by which they are taking the association to an alternate level. This examination has been advanced through writing concentrate on representative ideas, Human Resource Management and Reward the executives of workers. The information from the essential research has been investigated contrasted and confirmed and the discoveries of auxiliary research and created proposals for the powerful administration of representative in worldwide organizations. Presentation Prize administration is these days considered as a significant subject so as to accomplish the objectives of an organization. Representatives are considered as the principle factor which assumes a significant job in the association. The accomplishment of every single association is its committed representatives .Current world is loaded up with changes and rivalry. So as to make due in the present circumstance organizations ought to have workers who are faithful and master in their own field. New advances are grown continually and the organizations are anxiously attempting to make up for lost time those skilled representatives with right ability in their own regions. HR as a significant factor ought to get expanded consideration in overseeing business (Lindergen Paulson ,2008)'. Worldwide organizations are confronting expanded difficulties from all around the globe because of globalization. 1.1 Reward the board Prize framework as a rule implies the money related award on association gives its representatives as a byproduct of their labour.The expression rewards framework, incorporates material prizes, yet in addition non-material prizes. The segments of a prize framework comprise of money related prizes (essential and execution pay) and worker benefits, which together contain absolute compensation. They additionally incorporate non-monetary prizes (occasion trips, moving to huge office, acknowledgment, advancement, acclaim, accomplishment obligation and self-improvement) and in many case an arrangement of execution the board. Pay game plans are integral to the social activity as they are the most unmistakable articulation of the working connection among boss and representative. Numerous papers inspect the job of hierarchical culture that is, the interest for checking remuneration. Such examinations infer that authoritative culture puts a critical job in deciding the degree of monetary reque sts. Ongoing looks into on mechanical agitation demonstrate that reward standards of the associations both budgetary and non-money related prizes have colossal impact upon the workers and managers execution. Prize is an expansive build that can incorporate anything a representative may esteem and want that a business is capable or ready to offer in return for worker commitment. An applied qualification can be made between the three fundamental constituents of rewardtype, framework, and basis. (Henderson 1989, p.2) Chiang, Flora F.T. ; Birtch, Thomas A (2006) An exact assessment of remuneration inclinations inside and across national settings. The executives International Review Prize sort alludes to the idea of the prize itself (e.g., money related and non-budgetary; extraneous and inherent). Money related prizes incorporate direct (e.g., fundamental compensation) and backhanded (i.e., advantages and administrations) just as motivating force (e.g., variable compensation) and non-impetus (e.g., fixed compensation) classes. Non-money related prizes, then again, don't profit representatives from a financial perspective and comprise of both extraneous and characteristic prizes. Extraneous non-budgetary prizes are substantial prizes appended to the activity and are given and constrained by a firm. Models incorporate business security, advancement, status, connections, and work conditions. On the other hand, inherent prizes collect from playing out the assignment itself and are self-fortifying. Occupation challenge, assortment, and feeling of accomplishment are genuine instances of this classification. Prize framework speaks to the technique or component (e.g., position based, execution based) by which associations decide representative prize results (e.g., pay increments). Frameworks can be either execution or non-execution situated. Where execution arranged prize frameworks repay representatives dependent on how well they perform at work, non-execution frameworks remunerate workers dependent on an alternate arrangement of models, for example, rank/long periods of administration, and abilities/skills. Prize rule at that point, alludes to the premise of distribution (i.e., individual or gathering) used to decide the prize. 1.2 Marriott International Marriott International is a main, around the world, cordiality organization and has in excess of 2,300 working units situated in the U.S. what's more, 59 different nations and domains. It utilizes around 154,000 specialists. Fortune magazine has perceived Marriott as one of the 100 Best Companies to Work for in America (1997-2001), one of the Top 80 Companies for Minorities (2000), and one of Americas Most Admired Companies generally (2001). Furthermore, Sales and Marketing Management magazine has named Marriott Sales as one of the best 25 deals powers in the U.S. (1997-2000).(mariott.com thirteenth jan 09) Marriott is and consistently has been an equivalent open doors manager in all parts of work. The organization is completely dedicated to giving a decent and amicable workplace that offers equivalent treatment and equivalent open doors for every one of its partners, and where each partner is treated with suitable regard and respect. It is the companys strategy that there should be no unlawful segregation, provocation or exploitation of any partner, work candidate, clients, suppliers of administration or individual from open, regardless of whether regarding enlistment, arrangement, preparing, advantages or advancement, either straightforwardly or by implication, on grounds of race, nationality, ethnic birthplace, sexual orientation, conjugal or family status(Marriott handbook for representatives 2009) Marriott is resolved to reasonable treatment of partners and to giving preparing and headway chances to all. Marriott has an unshakeable conviction that there partners are the most significant resources for them. Marriott consistently anticipate a situation which will consistently bolsters partners development and advancement. Marriott is a notoriety for utilizing mindful, reliable partners who are moral and dependable and is consistently quick to give a home like climate and agreeable work environment connections. They generally attempt to accomplish an exhibition reward framework that perceives the significant commitments of both hourly and the board partners. There are two sorts of partners as clarified previously. Hourly partners are those representatives who are paid based on the hours they worked. In the other hand the board partners are the individuals who are paid a fixed compensation based on work content allocated to them. Marriott has been chosen for the examination as they are having representatives from everywhere throughout the world. They utilize individuals not based on ethnicity, station and religion however based on understanding. As they have workers from various pieces of the world their needs will be extraordinary. They will be anticipating various sorts of remuneration plans which will suit to their necessities and will fulfill them to remain with the association. Research has been directed by taking Marriott as the organization since they are confronting a high danger of fulfilling the requirements of workers who are having various tastes with respect to rewards which they are looking forward from the association. As expressed before, Marriott has been perceived as one of the 100 organizations to work for in America by Fortune magazine. This expresses the workers are fulfilled to a degree with the prizes which they are allocated by the association. As the prize administration assumes a job in the association it will merit doing an examination on the organization who cares and gives equivalent chances to every single worker in the association. 1.3 Current postion 1.3.1Current Policy At present Marriott don't have a current arrangement for remuneration framework to their workers. In any case, their ‘unofficial approach can be seen underneath. Be that as it may, they are thinking about remuneration the board based on â€Å"Spirit to serve†. It depends on the administration which the partner conveys to the client to keep the positive attitude of the firm. The chief will designate the name of the partner to the Human Res office as indicated by their administration. Partners name will be shown in the notification load up and once in a while this is esteemed more than cash as an individual and as a representative. 1.3.2 Current Issues a) There is no documentation for remuneration the executives strategy. b) There are right now no KPIs (key execution markers) for checking and compensating for representatives execution exercises. c) Human asset approach record is seldom given to workers or its not refreshed. d) Literature will in general be piecemeal Employee rules are a different archive to the activity with no detail

Making the most of New York COLUMBIA UNIVERSITY - SIPA Admissions Blog

Making the most of New York COLUMBIA UNIVERSITY - SIPA Admissions Blog The following entry was contributed by Erisha Suwal, a second year student at SIPA.   Erisha is working in our office this year and she, along with several other students, will be contributing posts throughout the year. ____________________ Being in New York has been one of the best experiences while at SIPA. Early last year during the General Assembly (GA) meetings at the UN, I along with three other students organized a protest to demand from the then Nepal Prime Minister that Nepal’s constitution be written on time and that the government expedite investigations on the people disappeared during Nepal’s decade-long Civil War.   It was an intense experience. I distributed pamphlets on the streets of Jackson Heights, a South Asian neighborhood in Queens, and had heated discussions with many people.   It was interesting to see that many fellow Nepali men thought that as a student in Columbia, I should become a doctor or an engineer but not get into politics. Although not all Nepalis think this way, it is a common sentiment. The foreign advisor to the then Prime Minister also called me directly to request that the protest be called off.   It was terrifying, as I was exposed to the challenges of political activism. Nonetheless, organizing the event introduced me to other Nepali political activists in New York, to institutions and informal groups that worked for justice in Nepal.   Also, because of this event, I became aware of the India China Institute at the New School.   Since then, I have attended many events on Nepal organized by the New School and even audited a class on Nepali Society and Politics. Another highlight of being in New York is my current internship with UNIFEM (part of UN Women). Prior to joining SIPA, I had limited work experience in the development field. Most of my work was in the financial sector and my development experience came from summer internships throughout my undergraduate years. Interning with UNIFEM provides an excellent opportunity to gain more work experience and to understand how the UN works from the inside. Also, as I’m interested in the political participation of women, working with UNIFEM’s Governance, Peace and Security division could not have been a better match. Between the extra activities and internships (and awesome parties) I am making the most of my time at SIPA.

Analysis Of George Elton Mayo And His Work Essay - 5478 Words

Early insights around employee engagement originated with George Elton Mayo and his work at Hawthorne Works (a General Electric Company) in the 1920s. In studying human behavior, Mayo’s research challenged Taylor’s principles of scientific management by providing alternative motivation theories outside of self interest (Mayo, 1933). This opened the door for additional research on employee motivation with future work by Argyris and Likert continuing to drive understandings of the relationship between environment and worker productivity. While the book First Break All the Rules (Buckingham Coffman, 1999), helped popularize the concept of employee engagement, the first real mention of employee engagement appeared in a 1990 Academy of Management Journal article by William Kahn. Basing his initial work on Goffman, Kahn looked to further develop the concept around varying individual role attachment by extending the concept to fit organizational life (Kahn, 1990). Specifically, Kahn (1990), utilized an ethnographic, grounded theory method to better understand how experiences with various work variables including manager satisfaction, role clarity and availability of resources influenced an individual’s experience and involvement with work tasks. Kahn looked to build upon prior work by Hackman Oldham (1980) and Alderfer (1972) to enhance or undermine the individual’s motivation and sense of meaning at work (Kahn, 1990). The research premise was that 1) individualShow MoreRelatedHistory of Management Th ought - Elton Mayo1620 Words   |  7 PagesINTRODUCTION This essay covers the life and key contributions of Elton Mayo, a renowned figure in management science, and how his theories have made a significant impact in management today. BIOGRAPHY OF GEORGE ELTON MAYO George Elton Mayo was born in Adelaide, Australia on 26th December 1880. Under heavy family influence, Mayo embarked on a course in medicine. However, he failed an examination which ended his chances of having a medical career. He went on to study philosophy and psychology at TheRead MoreHuman Relation1698 Words   |  7 Pagesorganizational analysis. This is because the classical theorists neglected the human factor in the organization. The Classical theorists took a mechanical view of organization and underemphasized the sociopsychological aspects of individual’s behaviour in organization. It is this critical failure of the classical theory that gave birth to the human relations approach. Human relations theory is also known by various names like Humanistic Theory, Neoclassical Theory, etc. Elton Mayo, an American SociologistRead MoreBeneficial Management Contributions 1482 Words   |  6 PagesEvery organization begins with a dream. A dream created by entrepreneurial mind s at work. When an organization is put together a persons vision is coming to life. The same vision foreseen in their dreams is becoming a reality. 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Hofstede 1980) Masculinity vs. femininity (MAS) – Behavior and roles distributed according to gender. often renamed by users of Hofstede’s work to Quantity of Life vs. Quality of Life because one of the notable findings in the IBM studies revealed that in ‘masculine’ cultures, people value competitiveness, assertiveness, ambition, and the accumulation of wealth and material possessions whereasRead MoreWilliam Ouchi1307 Words   |  6 PagesManagement Driving Theory Test Music Theory College Professor Circuit Theory William Ouchi Search Custom Search Management Gurus Management Theories 80-20 rule Ansoff Matrix Blue Ocean Strategy Deming Cycle ERG Theory Force Field Analysis Hawtorne Effect Linking Pin Model Porter s Five Forces POSDCORB Quality Circles Socratic Problem Theory X and Y Wealth of Nations More Theories... William Ouchi William G. Ouchi (born 1943) is a researcher in the field of business management

Recommend Analyze Range Of Plans And Budgets Roberta Finance Essay - Free Essay Example

Sample details Pages: 13 Words: 3845 Downloads: 8 Date added: 2017/06/26 Category Finance Essay Type Argumentative essay Did you like this example? Those are available to Roberta to enable her to monitor and control all of her business activities. Also to discuss the external and internal factors that may influence the establishment of Robertas plans and budgets. 2. Don’t waste time! Our writers will create an original "Recommend Analyze Range Of Plans And Budgets Roberta Finance Essay" essay for you Create order Analyze the viability of an investment of an investment proposal: Will describe the proposal and the technique and will show that in-depth calculations of the viability of the investment plans available to her and also evaluate the impact of the proposals on the business and provide her with the best investment plan available for her at the end of this part. 3. Undertake research of two large public limited companies (PLC) and in that transport companies- with a view to understand the business better a performance audit of two companies have been taken and we also took the financial statements and other relevant information. We will also discuss the potential limitations of the analysis. Part 1 Roberta Kelly is currently going through the expansion period or we can say the business is growing rapidly and as the business is increasing the handling of the business is also getting tougher for Roberta. As she is the only one who has to stand there and solve all the problems t hat are coming up, though each of the business is having the manager but she fights with the problem herself. Whenever the business is in the growing period or in a starting period we actually plan things and we divide the work of the organizations into different departments. And where in which we need to recruit people. The range of plan that Roberta can look up to are as follows 1} to manage her financial data what she can do is she can create the departments within the organization and allocate the work accordingly to the department they belong. With the help of this the work would be distributed properly amongst the people and the organization and she can get the data of everything very quickly. In this case she need not take care of all the things. Like if she needs the information of the cash availability in the organization she can just ask it to the cash collection department and can see the available balance if she wants to see the sales of the company with in a peri od of time she can get that information from the sales department. Hence we will discuss all the departments that are necessary for her and the budgets that are necessary for Roberta to take care of her expanding business. A budget is an important tool of planning, controlling, motivation, and coordination. Budgets can help in Identifying the problems in business and promotes forward thinking by planning. A Distinction is made Between short-term planning and a long term planning, alternatively known as strategic or corporate Planning. There are number of purposes of budgeting, which include: 1. Planning 2. Coordination 3. Control 4. Communication 5. Resource Allocation 6. Motivation 7. Performance Evaluation BUDGET IMPLEMENTATION As we have noted, an organizations controller plays a vital role is designing and coordinating the budgeting process. A budget may have to go through many corrections and changes in it before it has the approval of the budget committee. Once the committee approves the budget the periodic report from all the different managers of the concern department will allow the committee to keep the eye on the companys progress and attaining budget targets. Successful budget implementation depends on two main factors clear communication and the support of the top management. In general, budgets can be classified into two primary categories (Cohen, Robbins, Young,1994, p. 171): 1) Operating budgets: Operating budgets consist of plans for all those activities that make up the normal operations of the firm. The main components of the firms operating budget include sales, Production, inventory, materials, labor, overheads and RD budgets. 2) Financial budgets: Financial budgets are u sed to control the financial aspects of the business. In effect, these budgets reveal the influence of the operating budgets on the firms financial position and earnings potential. They include a cash budget, capital expenditures budget and Performa balance sheet and income statement. Service revenue budgetO P E Service overhead budget Labour Budget Selling and administrative expense budgetR A T I N G Budgeted income statement F I N Cash budget Budgeted balance sheetA N C I A Capital expenditure budgetL James Oscar mckinsey 1922 budgetory control With the help of the above figure we can clearly understand how an organization does depends on the budgets. It is indeed very necessary to allocate the funds appropriately to all the departments in the organization. The normal departments that an organization need or have are the sales department, purchase department, collection department, research and develo pment, production department. And the budgets that are necessary for Roberta are the sales budget, production budget, capital expenditure budget, cash budget, administration budget, stock budget. The above mentioned are few budgets that are basically needed in any organization. The problem Roberta is facing in her organization is that the work is not being allocated properly and she has to handle each and every thing with oneself. And to solve this she has to create the departments and for them she has to design the budget and allocate funds accordingly. Let us now go ahead and see how these departments work 1} sales department- this department takes care of the sales and with the help of that we can see whether the business is making profits and are the sales are increasing or decreasing and will help us to take the necessary steps. Ex- with the help of this department the information of the sales of the company it would be easy for Roberta to pull it up and she can have the record of the sales of the company quarterly, half-yearly, and yearly. This will help her to improve the performance of its company. 2} Accounts department- in this department all the transactions that have taken place will have an entry and this department maintains all the records of the cash inflows and outflows. Incase if there is some problem in the organization with the payment made or payment received we can just contact this department and we will get the relevant information. In this the employees do not go to the Roberta and discuss this problem they can themselves cross check it with the accounts department. In this way Roberta is not being disturbed much with such small things. Ex- if Roberta has to see the balance sheet of the organization and check the performance of the organization. This department will provide her all the information. 3} Marketing department- this department takes cares of all the marketing plans that have being designed by the company for the particular year. This is one of the important departments as all the sales of the company depends directly or we can say it as indirectly on how we market our products and services. If we have marketed our products and services in a very good manner we can gain the goodwill and we can also increase our market share as the sales increase and the people are kept aware about the products that we offer to our customers and services which we render to our customers. This departments main job is to look onto our marketing strategies and how it is being affecting on our customers as well as our competitors. Ex- If the marketing strategy that has being approved and implemented to increase the performance of the company in the current year and is not performing well we can make it out with the help of this department and hence we can design another strategy and can implement it. We can also see the cost efficiency of the strategies and choose one amongst them which will give maxim um outputs with minimum inputs. OUTSOURCING OF WORK The other thing that the Roberta can do is she can outsource the work to some other company where the other company takes care of all the transactions on her companys behalf and she can concentrate on her own business and try expanding it. She can pay the nominal amount to other company and in return they will handle its business. The main thing over here is to look for the company which is very well known in the market and has goodwill in the market. Part 2 Capital investment may be considered to be a part of capital budgeting process. It involves both the selection of long-term investments and financing of them. And these 4 different methods of capital investment will surely help Roberta in understanding and can further plan if she wants to take the project or not. Below mentioned are the 4 different types of method of capital investment. They are as follows 1. Payback period. 2. Accounting rate of return {ARR}. 3. Internal rate of return {IRR}. 4. Net present value {NPV}. These methods helps us to know whether our money has been invested properly and can get the return on investment {ROI} with the desired time and with the help of these methods we will also be able to know which type of project is beneficial for our company for instance if we have 2 or more than 2 projects to invest in .with the help of these investment methods we can check the profitability of our organization in the near future and can measure the t hreats or benefits if we have any in long run and in the short run as well .. Now I will go in little depth of all the four methods and explain it individually which make a clear picture about how these methods are different from one another and which one is best suitable for the particular organization. 1. Payback period the number of years it takes the cash inflows from a capital investment project to equal the cash outflows {Corina Pentland, course material 2010} Payback period is measured in term of the net cash flows. We take the total cost of investment which we call it in a financial management language as capital. In this method our basic concern and the main information we need is to see the cash inflows and the cash out flows. In other words we see the amount that has been recovered in a particular year and how much more is yet to be recovered. If we have two or more than two projects we can measure when we can recover the amount invested in the project with the help of payback period and we can which of the two projects is beneficial of our organization and which one is suitable for us to invest our money into . THe earlier the payback period from the project or the business is supposed to be the better to invest into. And in the context of Roberta getting the proposal of overtaking its one of the suppliers business and the amount she is expected to invest in this project is 1300000 and as per the calculations done according t o the payback period method she will start making profits after fourth year and before the start of sixth year that is somewhere in fifth year. In fifth year she will get back her money that she has invested in the project. So according to me if Roberta has been thinking about the future and she is more concern about running the business and investing the money into that project in respect of the long run basis then it is good enough. Because whenever a business is been started the person who starts the business or the organization who starts the business knows very well that they cant get the immediate profits and they plan their strategies of the business accordingly and which helps them to serve better over a period of time . As per the question the Roberta had been approached by Sunil Patel to sell his transport maintenance business and he asked Roberta if she is interested in an acquisition. As the Initial Cost is being given  £1.3m and she is going to save  £200,000 per annum and Sunil has provided a five-year budget i.e. Year 1  £80,000 Year 2  £90,000 Year 3  £100,000 Year 4  £110,000 Year 5  £120,000 Therefore as the Roberta is going to save  £200,000 per annum Then the cash flow for the five years is Years Cash Flow Cumm. C.F Year 0 1,300,000 1,300,000 Year 1 280,000 1,020,000 Year 2 290,000 730,000 Year 3 300,000 430,000 Year 4 310,000 120,000 Year 5 320,000 200,000 Therefore the Pay Back period is in the 5th year Cumm. Cash Flow is 200,000 If assume that cash=profit Average Profit =  £200,000/5 =  £40,000 Capital Employed =  £1,3 00,000 2. Accounting rate of return Accounting rate of return compares the profit of a project with the capital invested in it. {Corina Pentland course material 2010} The accounting rate of return is very much similar to ratios. The main benefit of using the accounting rate of return is that is very easy to understand and to calculate as well. In ARR we take all the installments and then calculate the profits i.e. average annual profit. In this all the cash flows are used and taken into consideration. The ARR mainly focuses on profit. And higher the ARR the higher are the profits of the organizations. The main disadvantage of ARR according to me is that it doesnt take the time value of money. Because money value depreciates over a period of time it always needs the return of the investment continuously for example if I would have saved the money 1000 GBP in 2000 and now if I take it out and spend that 1000 GBP on purchasing something I would get only few things when compared to the money if I have spend it in the year 2000 so what is happening here the value of money id depreciating. And in ARR it also doesnt take much of time into consideration and if Roberta is ready to invest her money for a long period of time then it is useful for her. As in the case mentioned Roberta doesnt have any other projects as an option if she wanted to invest in. if she had any then we could have calculated the ARR of both the projects and suggested her with the best one between the two . In this project the average annual profit according to the calculations made is 40000 and the calculated ARR percentage is 3.0769 and which may increase over a period of time. A.R.R = Average Profit/Capital Employed x 100 Average profit = 200,000/5 = 40,000 Therefore, A.R.R = 40,000/13, 00,000 x 100 = 0.0307692100 A.R.R = 3.0769% 3. Internal rate of return {IRR}- an alternative method of investment appraisal based on discounted net cash flow is known as internal rate of return. However, instead of discounting the expected net cash flows by a predetermined rate of return, the IRR method seeks to answer the following question: What r ate of return would be required in order to ensure that the total NPV equals the total initial cost? In theory, a rate of return that was lower than the entitys required rate of return would be rejected. In practice, however, the IRR would only be one factor to be taken into account in deciding whether to go ahead with the project or not. {Accounting for non-Accounting students 5th edition 2001 from J.R.DYSON pg no 409} The rate of return on an investment seeks to determine the rate of return needed to ensure PV equals the initial cost: NPV = 0. {Corina Pentland course material 2010}. The internal rate of return basically gives you the rough idea of the return that we get on our investment. But it helps you compare the data and which is very helpful for the organization. With the help of IRR we can take effective decisions for our organization. In this case we use more than two discount rates to get the better picture for our returns on our investment. This is called trial and error method. In the case of Roberta investing in the project and the project is expected to be 1,300,000. If the company expects the rate of return of 5%, the project will not be accepted as its NPV is negative however the required rate of return is 4%, the project will be accepted, because the NPV is positive. The project will be profitable provided that the company does not require a rate of return in excess of 4%. In this we assumed another different percentage and then we are going to calculate, I am going to take 4% difference. Years N.C.F 4% diff. P.V Year 1  £ 280,000 0.962 269,360 Year 2  £ 290,000 0.925 268,250 Year 3  £ 300,000 0.889 266,700 Year 4  £ 310,000 0.855 265,050 Year 5  £ 320,000 0.822 263,040 Total 1,332,400 Less Cost 1,300,000 (32,400) I.R.R = +rate+ (+NPV/the two NPVs added together x range of rates) Therefore, I.R.R. = 4 + (32,400/32,400+5,200) x 1 = 4 + (32,400/37,600) x 1 = 4 + 0.861 x 1 I.R.R. = 4.861 4. Net present value {NPV} the Net present value method recognizes that cash received today is preferable to cash receivable sometime in the future. {Accounting for non-Accounting students 5th edition 2001 from J.R.DYSON pg no 407} In NPV method we calculate the annual net cash flows expected to arise from the project. With the help of NPV method we will be in a position to know whether the business is going to make profits with the given figures and the given time or not. And if the NPV is positive we can accept the project and can go ahead and invest the money in that project and if the NPV is negative then it risk investing in that project as it will not give to profits in the given period and you might have to wait for some more time. And NPV also undertakes the time value into consideration which is very beneficial for the organization. And in the above project Roberta should not take this project according to the NPV method the NPV is negative and she has to wait for the some more time to cover her invest and start earning the profits. Years N.C.F 5% diff. P.V Year 1  £ 280,000 0.952 266,560 Year 2  £ 290,000 0.907 263,030 Year 3  £ 300,000 0.864 259,200 Year 4  £ 310,000 0.823 255,130 Year 5  £ 320,000 0.784 250,880 Total 1,294,800 Less cost 1,300,000 (5200) As per the N.P.V is (5200), which is not good for the company because it is negative. Company is not going to repay their cash in the 5-year period. PART 3 RATIO ANALYSIS Company Name British airways A PROFITABILITY RATIOS 2009 2008 1 Net Profit Margin {net profit(before tax and interest)/turnover}X100 4.46% 10.53% 2 Return on Net Assets or Capital Employed {net profit (before tax and interest)/capital employed(net assets)}x100 21.72% 28.26% 3 Gross Profit Margin (gross profit/turnover)x100 2.45% 10.03% B LIQUIDITY RATIOS 4 Current Ratio Current assets/current liabilities 0.566 0.890 5 Quick Ratio or Acid test Ratio Current assets stock/ current liabilities 0.535 0.858 C EFFICIENCY RATIO 6 Debtors turnover (debtors/turnover)x365 21.51 24.42 7 Stock turnover Ratio Cost of sale/average stock 73.40 70.35 8 Creditors turnover Ratio (creditors/turnover)x365 113.49 119.82 D GEARING OR LEVERAGE RATIOS 9 Total debt Ratio total liabilities/total assets 0.823 0.711 10 Debt Equity Ratio total debt/total equity 2.437 1.391 11 Gearing Ratio Long term liabilities/equity shareholders fund 2.733% 1.482% E INVESTEMENT PERFORMANCE RATIOS 12 Earnings Per Share Net profit(after tax and preference dividends)/no of ordinary shares 32.6 61.9 RATIO ANALYSIS COMPANY NAME EASY JET A PROFITABILITY RATIOS 2009 2008 1 Net Profit Margin {Net Profit (before tax and interest)/Turnover} x 100 2.051% 4.664% 2 Return on Net Assets or Capital Employed {net profit (before tax and interest)/capital employed(net assets)}x100 4.18% 8.62% 3 Gross Profit Margin (gross profit/turnover)x100 2.25% 3.85% B LIQUIDITY RATIOS 4 Current Ration Current Assets/Current Liabilities 1.39 1.54 5 Quick Ratio or Acid Test Ratio Current Asset Stock/ Current Liabilities 1.326 1.326 C EFFICIENCY RATIOS 6 Debtors turnover (Debtors/Turnover) x 365 33.09 36.59 7 Stock turnover ratio Cost of sales/Average Stock 19.44 11.65 8 Creditors turnover Ratio (Creditors/Turnover) x 365 102.74 100.87 D GEARING OR LEVERAGE RATIOS 9 Total debt Ratio Total liabilities/total Assets 0.644 0.587 10 Debt-Equity Ratio Total Debt/Total Equity 0.997 0.709 11 Gearing Ratio Long Term Liabilities/ Equity Shareholders Fund 0.997% 0.997% E INVESTEMENT PERFORMANCE RATIOS 12 Earnings Per Share Net profit(after tax and preference dividends)/no of ordinary shares 16.9 19.8 Profitability ratios: Gross profit margin and net profit margin ratios are used to make sure that managers, owners, employees and potential investors know the profitability of the above mentioned two companies. According to the calculations net profit margin of British airways for 2009 is 4.46% and in 2008 it was 10.527%. As the economic recession that has hit many countries in the world UK is one of them and many business have being facing losses but it was not with the easy jet its net profit margin was not effected too much, in 2008 it was 4.6639% and in 2009 it was 2.051% . Both the companies have faced losses due to the economy slow down but easy jet managed to incur less losses than British airways. Liquidity ratios:- liquidity is the one of the key factor for any business. As the need of money may occur any time so the business owners should be in a positio n to get the money and should have the availability of money. The current ratio of British airways for 2009 is 0.566%and that of easy jet is 1.39% and the current ratio of British airways in 2008 it was 0.89% and that of easy jet is 1.54%. According to the percentages derived we can see that easy jet has more cash availability than British airways. Efficiency ratios: The British airways debtors turnover in 2009 was 21.51% but in 2008 it was 24.42% and the creditors turnover in 2009 was 113.49% which is too high and that of easy jet the debtors turnover ratios was 33.09% and their creditors 102.74%. If we make the comparison of the ratios of easy jet and British airways the ratios of easy jet are very good. Gearing ratios: The gearing ratios for British airways were 2.73% in 2009 and in 2008 it was 1.482%. And for easy jet it was 0.997 and 0.709. According to the ratios the British airways is highly geared and it would very difficult for them to borrow money from the potentia l market. And for the easy jet it is very good because they still have people and institutions in the market to borrow money from. Investment performance ratios: The earning per share ratio of British airways in 2009 was 32.6 per share and that of easy jet shares are 16.9 per share. The earnings per share ratio of British airways is good. But after the hit of economic slowdown the British airways were struck badly because the earning per share ratio for them in 2008 was 61.9 per share and that of easy jet shares it 19.8 per share . Hence the easy jet didnt got struck too badly in the economic slowdown and have managed to incur less losses. CONCLUSION Looking at the above profitability shets we can say that easy jets performance is better than the British Airways. Easy jet has a safer capital structure than British Airways. Both to creditors and the debtors it has a strong debt paying ability and low debt risk in the long run. British Airways can improve its ratio by reducing its long term borrowing. However, we should also be aware of the limitations of the ratio, such as price changing, window dressing, lack of qualitative information, etc and make adjustments necessary. REFLECTIVE STATEMENT From the above assignment of financial management given by Corina Pentland i have learned how to analyze the companys profitability and also how to use the accounting tools and techniques to analyze the profitable project suitable for the particular organization. It has being a wonderful experience to read various books of financial management to complete this assignment and have learned many things about accounting which i was not aware of.

Disadvantages of Internet Free Essays

The disadvantages of internet uses for children Today, internet is one of the most powerful tools through the world because it is a collection of various services and resources for people to search. But, even though it provides the massive benefits, the disadvantages of internet uses are also concerned by most parents to their children for seeing the possible cab consequences happening through different areas. First, some parents do not realize the dangers involved when their children log onto the internet. We will write a custom essay sample on Disadvantages of Internet or any similar topic only for you Order Now When children are online, thing can easily be lured to a harmful person and as the result, there have been many cases where children have been convinced to meet people they have talked to online. In fact, the stories seem to come out every week and the children lured into something foolish, dangerous, or even deadly online that cause to violence and make the example for children practically following the figure. Whenever they got it, they will do it and share it to others without reasonable behavior with bad attitude from what they have learned in internet. Second, we have seen that some children are interested in gambling.When they have the free time they search and play the new games which are attractive, especially violence games because it can easily make them cheerful and enjoyable to play online. Most of them have spent much time to search from the net without considering and communicating to other in term of doing something friendly. Children are learning to read and write wit h computer games instead of homemade flash cards. They are reading their bedtime stories online instead of in bed with their parents. Slowly traditions are being broken and the computer is becoming a child’s learning tool.Many parents are buying computer learning games instead of board games and pop-up books. Third, most important learning step for children is interaction with others. If they are sitting in front of the screen all day, they do not learn to share, wait their turn, or even something as simples as manners. Children need to be in contact with other children, adults, and animals. They need to experience things first hand not off a computer screen. They even abandon studying by sharing online unrespectable incurable of internet uses. Furthermore, when they become addicted, they actually each to bad circumstances to distinguish ad take out of their attraction on the net. This condition will have difficulty to advise their children’s behavior. Fourth, frequent and prolonged computer sessions may pose physical health risks for children. The most frequently cited are visual strain, harmful effects of radiation, and posture and skeletal problems. In the case of unnormal usage and unnormal operating conditions, however, research has shown that computer monitors are not safe and does not compromise the health of our eyes and that computer monitors emit the problem or harmful radiation.The children will impact these kinds health problem and can reach to further physical reaction. The last, children may also received pornography online by mistake; therefore, causing concern among parents everywhere. When children log on to the computer their innocence is noticeable. Whether surfing the net, reading, or using email, children can be exposed to extremely inappropriate material. Pornographic site tends to make sure they are the first site to the listed in search areas and children come across the site easily. Children are an easy target for adults who pose to be other children with similar interests.Sexual offenders often chat online with children and then make plans to meet them or slowly filter information about them. In this area, children are interested and sometime do following by leading to further misconduct to social which is not available to recognize morally. They fact with sexual relationship to each others in term of interest behavior and bad attitude cruelly base online surfing and learning that is the big case reaching to worse action in all condition In conclusion, the internet use is not considered to advantages only, but also taken into account to disadvantages to children who are the most suffered one from it.The internet has given the problems dangerously with something new, such as gambling, interaction, physical health risks, pornography, and others interesting programs online. These have changed children’s attitude in different ways which need effective observation from parent to prevent of the dangers, by guiding and guarding their children about what is online and might happen online. How to cite Disadvantages of Internet, Papers

Refinancing and Workouts of Financially Distressed

Question: Discuss about the Refinancing and Workouts of Financially Distressed. Answer: Introduction: In this report we discuss the Australian case which involves breach of directors duties and officers duties under section 181 of the Corporation Act 2001. Case law which we choose is Bell Group LTD (in liq) v westpac banking corp (no 9) (2008) 225 FLR". Recently, the Western Australian Court of Appeal give its judgment in this case in which appeal is filed by the consortium of banks against the decision of Justice Owens in The Bell Group Limited (in liq) v Westpac Banking Corporation [No. 9] 2008 WASC 239. In the history of Australia this case is the longest and expensive case, and the judges, Lee, Drummond and Carr AJJA reach different conclusions and they provide different reasons for their conclusion. In this report, first we state the brief introduction of the case, and we also outline the duties and responsibilities of directors and officers that are breached and reasons for breaching the duties. In last we analyze the decision made by court or tribunal, and also the reason of decision take by court in relation to Corporation Act 2001. Subsequently this report is concluded at last. The Bell Group Limited (in liq) v Westpac Banking Corporation: Bell Group of Companies was the subsidiary of the Bell Group Limited (in liquidation). Bond Corporation Holding Limited controlled it from August 1988. There are number of banks in Australia which give facilities to the Bell Group of Companies, and facilities provided by these banks were independent, unsecured but these facilities are supported by pledge agreements which are negative. Bell Group of Companies has similar arrangements with the financial institutions set up in overseas. In 1980, Bell Group because of its high borrowings decided to sale its assets for the purpose of reducing its debts. In mid-1989 debts owned by the company to the Australian banks are too high, and company is not able to repay its debts and later on company restructure its facilities. In 1990 January Bell Group of Companies entered into number of transactions continuously and these transactions are related to refinancing and security documents. These transactions result in taken over security of valuable assets of Bell Group by banks (HWL Ebsworth, 2012). Almost after15 months provisional liquidator was appointed in Bell Groups, and banks started to precede the securities on the assets of the company and recover almost $283 million. In 1995, liquidators start proceedings against the banks, and they challenge the refinancing transactions and their validity. The main purpose of these proceedings was to recover the proceeds of the realization. Liquidators stated at the time of execution of transaction, the directors of the Bell Group of Companies knows or might be know that main companies of Bell Groups were insolvent, and they also stated that this conduct of directors result in breach of their duties. In their defense banks stated that the Bell Group of Companies were not insolvent at the time of execution of transaction, and in case if companies are insolvent then also banks were not aware about this. In first hearing Owens J made decision in favor of liquidators and found that: By entering into the transaction directors of the company breach their fiduciary duty towards the company and does not act in the best interest of the company and in such way which is for an improper purpose. It is wrong that banks are not aware about the breach of fiduciary duties by the directors of the company by executed the transactions which satisfied the first limb in Barnes v Addy. There is no liability on the banks for equitable fraud which was result of transactions and because of which one class of creditors gets preference over other cast of creditors. It was not necessary for the court to find whether intention of Bell Companies is to defraud, delay and hinder the creditors under section 121 of the Bankruptcy Act 1966 (Dibbs Barker, 2008). Breach of directors duties: Before discussing the breach of duties and responsibility by directors in this case, it is necessary that we understand the duties of directors stated in section 181 of the Corporation Act 2001: Clause (1) of this section states that it is the duty of the directors and other officers of the company that they must exercise their powers and discharge their duties in good faith or in the best interest of the company, and for proper purpose. Clause (1) of this section is the civil penalty provisions under section 1317E. Clause (2) of this section states that if any person contravenes clause 1 then he also contravenes this clause also. This section is also the civil penalty provisions under section 1317E (Corporation Act 2001, n.d.). In this case, plaintiff alleged that directors of the company breach their duties towards the company and do not act in the best interest of the company, and they also exercise their power for the purpose which is not proper and they are not able to avoid the conflict of interest. They argued that directors of the company: Not able to analyze the impact of the refinancing transactions on the company, creditors and future creditors of the company, and shareholders of the company. Directors decided to enter into refinancing transactions on the behalf of each company which result in making each company liable for the debts of BGF or BGUK to the banks, and both these companies are on the stage of insolvency at that time. Before entering into refinancing transactions only these two companies are liable towards the bank but now each company of Bell Group is liable. Directors take these steps to protect their position in TBGL and their financial interest in BCHL and other companies of Bond, and these steps was in conflict with their duties under section 181 of corporation act 2001 to the Bell Group of companies (Alert, 2010). The court held in this case directors breach their fiduciary duties by granting security in these circumstances. The duty breached by director was duty under section 181 that is to act in good faith and in the best interest of the company. Justice Owen considers to whom directors owned the duty, and judge found that duty is owned to the company itself not merely to the shareholders of the company. Justice Owen also held that it is necessary that directors of the company while discharging their duties is also take into account the interest of creditors of the company. His Honour's states that interest of the creditor must be take into account before the insolvent condition of the company. Court held that it is necessary to determine the duties of directors to act in good faith and in best interest of the company then this must be determine subjectively. In other words court must consider the state of mind of directors, and does not impose any analyzes which is objective in nature (Flannery, 2008). The last issue considered by Justice Owen was whether in discharging their duties to act in good faith and in best interest of the company of the relevant company, directors does not take into account the interest of whole group and only limit their duties to that particular company only. Its necessary that directors of the company must balance the interest of the company as well as interest of the group. The next question is whether directors breach their duties and answer is yes directors breach their duties to act in good faith and in best interest of the company. A director of the company does not consider the interest of the whole group but only consider the interest of the Bell Group such as that company on the assets of which security has been provided were insolvent at that time but directors of the company are not aware about the actual insolvency but they had knowledge of the chances of insolvency. Therefore it is clear that interest of each specific company involve the interest of unsecured creditors of the company (Hargovan Harris, n.d.). Before the refinancing transactions only specific numbers of companies are liable towards the financiers but after this decision of directors all companies which grant securities over their assets are liable towards the companies. These transactions are also not in the interest of unsecured creditors of each company because after these transactions financier has preferential rights over the assets of the companies. In other words, each individual company has incurred liability without obtaining any benefit. Some directors also enter into transaction with the aim to reduce likelihood of Bond Corporation Holdings Limited which has been on the situation of insolvency, and this act result in breach of their duty to act for the proper purpose. Lawyers of the company argued that minutes related to directors meeting must take into consideration to find out the reason for which directors of the company entered into transaction, and also set out the purpose of directors. Justice Owen does not give any importance to the minutes and said that in his view documents recorded I the meeting does not recorded exact facts for entering into transactions (Allens, 2009). Decision made by court/tribunal: In this case, there are four sets of decisions which have separate reasons, and these four sets includes decision given by trial judge that is Owen J and decision given by Lee, Drummond and Carr AJJA on appeal. This case involves number of legal issues such as equitable fraud, contractual obligations and rules stated in Barnes v Addy. In this High Court of Australia granted the special leave to appeal (Clark, 2010). Owen J in his decision held that at the time of refinancing transactions companies of Bell Group are insolvent, and banks held that they know if refinancing was not done then this group might be gone into liquidation. However, judge held that there are number of other options for restructuring which company can choose and there are not only refinancing agreement is the only option. Owen j also held that conduct of the bank was also prejudiced for the creditors of the company which are external because bank took securities over the assets of the company on which before these transactions there was no security. Later on, all the banks file appeal to the Western Australian Court of Appeal against the decision of the trial judge on 144 grounds. All three judges in the appeal confirmed the liability of the bank but also give slight different decisions with different reasons to the bank. Lee AJA agreed with the decision of trial judge and held that it is necessary that court consider whether directors acted in good faith or in the best interest of the company or not. Drummond AJA takes different approach and check whether court accesses the interest of the creditors of the company or not and whether they accessed objectively. Carr AJA held that Owen J consider the interest of creditors and determine the business decisions on the basis of creditors interest, and they also consider the duties of directors in respect of shareholders only. Both the trail judge and the judges on appeal held that directors of the company did not consider the interest of other creditors and only consider the interest of bank (Austlii, 2012; Austlii, 2013). Conclusion: In this report we state the legal issues raised in the case the Bell Group Limited (in liq) v Westpac Banking Corporation [No. 9] 2008 WASC 239. The above case imposes number of duties on the directors and the banks which they originally ignored. Especially for banks because banks obtain the securities then these securities were declared invalid and returned the proceedings of securities to the company, creditors and shareholders. There are number of legal issues are raised in this case which are set out in appeal and these issues are reviewed by the High Court of Australia. At last we conclude that it is necessary that directors of the company act in good faith and in the best interest of the company, and directors of the company must take into account the interest of all creditors not only single creditor of the company. References: HWL Ebsworth, (2012). The Bell Court of Appeal Decision. Retrieved on 16th December 2016 from: https://www.hwlebsworth.com.au/latest-news-a-publications/publications/insolvency-and-securities-enforcement/item/767-bell-round-2.html. Dibbs Barker, (2008). Bell Group Limited Decision. Retrieved on 16th December 2016 from: https://www.dibbsbarker.com/publication/Bell_Group_Limited_Decision.aspx. Corporation Act 2001- s181. Alert, (2010). REFINANCING AND WORKOUTS OF FINANCIALLY DISTRESSED COMPANIES: Lessons from The Bell Group Ltd (In Liquidation) v Westpac Banking Corporation. Retrieved on 16th December 2016 from: https://cornwalls.com.au/media/30115/article_feb%202010_bell%20group.pdf. Flannery, (2008). The Bell Tolls: Directors Duties and Financiers. Retrieved on 16th December 2016 from: https://www.mondaq.com/australia/x/71924/The+Bell+Tolls+Directors+Duties+And+Financiers. Allens, (2009). Restructuring Insolvency. Retrieved on 16th December 2016 from: https://www.allens.com.au/pubs/insol/foinsol14sep09.htm. Hargovan, A. Harris, J. Before the High Court For Whom the Bell Tolls: Directors Duties to Creditors after Bell. Retrieved on 16th December 2016 from: https://sydney.edu.au/law/slr/slr_35/slr35_2/433_Harris_Hargovan.pdf. Clark, M. (2010). Westpac Banking Corp v Bell Group Ltd (in liq). Retrieved on 16th December 2016 from: https://blogs.unimelb.edu.au/opinionsonhigh/2014/04/10/bell-group-case-page/. Austlii, (2012). WESTPAC BANKING CORPORATION -v- THE BELL GROUP LTD (IN LIQ) [No 3] [2012] WASCA 157 (17 August 2012). Retrieved on 16th December 2016 from: https://www.austlii.edu.au/au/cases/wa/WASCA/2012/157.html. Austlii, (2013). Westpac Banking Corporation Ors v The Bell Group Ltd Ors [2013] HCATrans 85 (23 April 2013). Retrieved on 16th December 2016 from: https://www.austlii.edu.au/au/other/HCATrans/2013/85.html.