Essays on writing
40 Cause And Effect Essay Topics
Wednesday, September 2, 2020
Aaron Burr1 essays
Aaron Burr1 papers Aaron Burr Jr., the child of Ester Edwards Burr and Reverend Mr. Aaron Burr was conceived on February 6, 1756 in Newark, New Jersey. He was additionally the grandson of the well known scholar, Jonathan Edwards. His dad earned his living as a minister at The Newark Presbyterian Congregation and the leader of The College of New Jersey, which later turned into the Ivy League school, Princeton University. After moving on from Princeton University at 16 years old, Burr Jr. turned into a legal advisor, in spite of the fact that his investigations were constrained to religious philosophy. Following this, he conveyed an address entitled Building Castles in the Air. These mansions, it has been stated, were lying in the West hanging tight for Burrs capability. Subsequent to resigning from the Continental Army as a field official, Burr specialized in legal matters. He was then designated as the lawyer general of New York in 1789 and filled in as a United States representative from 1791 to 1797. Be that as it may, this before long finished as he joined the Thomas Jefferson bunch drove by James Monroe in the Senate and James Madison in the House of Representatives. He served under Thomas Jefferson as the third Vice President in United States history. As the Election of 1800 moved close, Burr took the appeal to set up a perfect ticket. It would put both him and Jefferson on a similar Ballot so it would be a certain success. He would be the principal government official that exploited gathering association. In this manner, as the votes were checked, it would be that the Republicans won. During the political decision, Burr supported assets to end Indian strikes. Burr contended energetically to win the political race and was certain he was going to win. Truth be told, it was a tie among him and his running mate, Thomas Jefferson. The constituent votes specified as 73 for both Burr and Jefferson. Nonetheless, Jefferson proceeded to win the political race by choice of the House of Representatives. A lot to do with pounding Burrs fantasies about serving in the most noteworthy office, was Alexander Hamilton. He presented pe... <!
Saturday, August 22, 2020
How to graduate to business - Emphasis
Instructions to graduate to business Instructions to graduate to business Youve spent the previous three or four years composing expositions and reports, and now youre in your first expert activity and prepared to begin composing for business. In any case, does your degree have you secured? All things considered, yes and no, composes Cathy Relf. Fortunately on the grounds that youve grew great logical and hierarchical aptitudes, youll be knowledgeable in arranging your thoughts into independent areas or sections, and supporting your contentions with realities, figures and proof. The awful news is that the style and structure of scholarly composing differs massively from the style and structure youll need to embrace for proficient business composing. Though scholarly composing will in general be longwinded, far reaching and, well, somewhat dull, business composing should be vivacious, directly to the point and promptly captivating. Follow these three stages to shake off the scholastic shackles and draw out your business voice. 1. Connect with your peruser right away The greatest distinction between composing for college and composing for work is that, grinding away, no ones obliged to be intrigued. Intrigued however they clearly were, your teachers were paid to peruse your expositions. Anyway verbose the style or dubious the contention, they needed to focus on each sentence on each page, directly through as far as possible. In the expert world, nobody will do that except if you snare them in toward the beginning and keep them intrigued. You need to acquire and afterward hold your perusers consideration at each progression. Fortunately, theres a radical yet basic change you can make that will right away improve your capacity to draw in the peruser. At college, you most likely spread out the entirety of your proof and data first, and tailed them with an end toward the end. In business, you for the most part need to arrive at the point directly toward the beginning youre not talking about the theme, youre offering your master supposition and support it up with hard proof. Heres a basic, four-point recipe for catching your perusers eye and getting straight serious. an) Outline the specific circumstance Set up the shared opinion among you and your peruser, in close to a line or two. b) Describe the trigger Clarify why you are composing this now. Would could it be that has changed or should change? Once more, keep this to only a line, two at the most extreme. c) Ask an inquiry Bring up an activity orientated issue, for example, How would we forestall this?, How would we get ready for this? or then again How would we diminish the expense of this? d) Give the appropriate response Answer the inquiry with your suggestion or key discovering, giving a total arrangement in close to 25 words. Presently you have their consideration. Utilize the remainder of your archive to clarify how and why you have shown up at this suggestion. 2. Take your cerebrum for a 16 ounces Recollect every one of those understudy evenings you spent attempting to make your useful tidbits heard over the consolidated clamor of an awful DJ, 30 tipsy companions and the call of tequila? They werent squandered. The remainder of your record ought to contain sorted out areas or parts that back up the suggestion you made in sync 1. Before you begin composing each segment, envision you had 30 seconds to tell it to a companion in a boisterous bar. Itll assist you with doing the accompanying three things normally: a) Use ordinary words and as not many as could be expected under the circumstances The more straightforwardly your peruser can get you, the better. So cross out enhance, speedy, and proclaim and supplant them with improve, quick and issue. What's more, do you truly need to state so as to, as opposed to? Would you be able to chop down in the field of to in? Is take out through and through extremely more powerful than simply dispose of? Experience your draft and evacuate any words that arent doing their fair share. The more clear your composing is, the more clear your message. b) Be dynamic, not latent When in doubt, utilize dynamic action words, as opposed to detached. It keeps your composing exuberant, immediate, individual and responsible. Simply put the practitioner toward the beginning of the sentence. So as opposed to composing it is trusted that the task will be finished in December, compose we want to finish the undertaking in December. c) Prefer action words to things Action words are more straightforward than things. So when youre altering your work, cut out nominalisations, for example, accomplish cost decreases and attempt the usage of and supplant them with lessen expenses and actualize or, basically, do. 3. Concentrate on your arranging Great arranging can have such an effect to the clearness of your archive. There are barely any things as off-putting as pages of square content. Very much organized content is kinder on the eye, simpler to explore and progressively important. a) Keep it short and straightforward Dont attempt to pack a lot into your sentences. Separate them so each sentence manages only one thought, and connection your thoughts intelligently. Its fine to begin a sentence with or potentially yet in the event that it explains your message. So also, its not irregular to see suffocatingly long passages in scholastic composition. Yet, in business composing, youll should be progressively brief. Change the length of your passages, yet make an effort not to go past five sentences in each. What's more, on the off chance that you have an especially significant sentence, dont be short of giving it a section all to itself. b) Use connecting with headings and sub-headings Utilize normal, clear headings and sub-headings to separate the content. Maintain a strategic distance from mark style headings, and rather utilize express ones that summarize the segment. This enables the peruser to discover segments generally proper to them, and furthermore makes it simple for them to allude back to applicable areas later. c) Put a projectile in it When youre composing a rundown of focuses that can represent themselves, use slugs or numbers. They will stand apart obviously superior to on the off chance that you pack them all into a section of content, and its simpler on the perusers eye. d) Would a diagram work better? When expounding on information, figures and procedures, ask yourself whether a diagram, pie outline or graph could convey a similar data all the more adequately. Keep this agenda convenient when youre composing your archives, and soon it will start to become propensity. What's more, if youd like functional preparing in applying these strategies (and some more), why not get us in to prepare your group, or book a spot on one of our High-sway business composing courses in London?
What Are Critical Lens Essay Topics?
What Are Critical Lens Essay Topics?In order to write a good critical lens essay, you need to be aware of some very important critical lens essay topics. These types of topics are very essential for students to research in order to help them in their critical thinking. By knowing the types of essays they can choose from, students will be able to tackle these topics and complete their essay.So what type of topics are there that a student can tackle in their critical lens essay? Well, a lot of things to talk about on a topic. The best way to think about it is that there are five major themes that a student can use to research on in order to help them finish their essay.The first thing that a student needs to do in order to be successful in their critical lens essay is to research on the topic. By researching on a topic, you will be able to better prepare yourself in order to master the topic. This is because you will be able to gather all of the necessary information about the topic th at you can get and you can also talk about it. As a result, you will be able to better communicate your thoughts in the essay.Students can choose from a variety of topics for their essays. The best thing about these topics is that they are some of the most popular ones that students tend to talk about and use in their essays. As a result, if you choose one of these topics, you will be able to write your essay. Plus, you can expect that the students will enjoy it as well.Now that we have covered the three main critical lens essay topics, it is time to discuss what each one of them is. The first one is called the theme. A theme is basically the thing that a student will study to prepare themselves for the topic they are going to write. This includes things like examples, but it can also include theories and more.The second one is the author's perspective. This is very important because it is the person who wrote the essay. A student should make sure that they include their own opinion on the topic in order to make their essays interesting.The third one is the thesis statement. The thesis statement will be the entire thesis of the essay. It is important that the student includes this in their essay because it is the main point of the essay.The first step that you need to take when you want to know what your essay topics are is to be familiar with the common themes that are discussed in an essay. Also, you should think about what types of topics you can discuss. By knowing what these are, you will be able to write your own critical lens essay.
Friday, August 21, 2020
Personal Goals HCS/301
Individual Goals HCS/301 February 14, 2011 Abstract In this paper I will talk about my own objectives that I have reached and keep on making progress toward. All things considered, I have numerous achievements, for example, humanitarian effort, keeping up my family, learning new nursing positions, beating my own medical problems, and subscribing to return for an advanced education and further profession improvement. Having been in the clinical field for more than twenty years, I have seen numerous advances in healthcare.With the changing clinical calling I have gone to the acknowledgment so as to comprehend the various parts of nursing, it is pivotal for me to keep on endeavoring towards new objectives in my nursing calling. My objectives have had an effect on my nursing vocation and the different ways I have tested, I have come to perceive the significance of understanding that with information and insight I have developed in my encounters. Individual Goals Growing up as a lone youn gster, I understood at a youthful age that I had numerous chances to explore.When I was youthful I generally put others first. I went through numerous hours with relatives whom were medical attendants. I appreciated them for their commitment to the wellbeing and prosperity of others. Having been demonstrated bunches of affection and responsibility for an incredible duration is the motivation behind why I chose to help other people. At the point when I was fifteen I started chipping in at my nearby network medical clinic. This emergency clinic is the place I stay working today. As a youngster, I decided to move in the direction of a profession in nursing. My first objective I picked was to be a volunteer at the hospital.This was the start of my duties to the network. As indicated by The Journal of Educational Psychology, there are Mastery objectives and Performance objectives. Dominance objectives are inspired through individual want while execution objectives are worried about seemi ng competent and serious to other people (Educational Psychology, 2006, p. 354). Execution objectives concern me since I have the impact and inspiration of my family. Through numerous encounters I have discovered that individual objectives are reachable. All you need is difficult work and determination.This regularly requires an expanded remaining task at hand, which prompts expanded pressure. Remembering these contemplations can assist me with accomplishing my short and long haul objectives. Objectives to me run from high need to low need. With my proceeding with want for an advanced education this is the place I am today. I have decided to go to The University of Phoenix for a Bachelor of Science certificate in Nursing. Transient objectives for me start with getting however my every day errands. I have discovered that keeping an organizer is a significant instrument; this causes me with my time the executives and organizes my present moment goals.As a Registered Nurse working all day with a group of five, arranging is constantly important to keep my life reasonable. Getting however family obligations, charges, school, schoolwork and baseball practices can get overpowering. The idea of having sufficient opportunity to prepare or even appreciate suppers appears to be incomprehensible. Shockingly, I have been living with Systemic Lupus throughout the previous six years, which has comprised of unending medical checkups and lab work. This has been a huge excursion for my family and I. My objectives during this time have been to diminish pressure and improve my wellbeing through exercise and meditation.Ultimately, I need to keep on keeping up lower levels of pressure and accomplish an ideal wellbeing level to arrive at my objectives. Twenty years prior I moved on from Golden West Community College with my Associate Degree in Nursing. This was a significant battle and a mind-boggling experience for me. My family was youthful and there were numerous incalculable tir ing hours engaged with request to accomplish my objective of turning into a Registered Nurse. Turning into an enrolled nurture was an extraordinary achievement and an astounding achievement for me. Moving on from school was a stage towards my own dedication to my future patients.Upon fruition of my Associate Degree in Nursing, I was recruited as Registered Nurse in the Medical/Surgical unit. Following a while as a rehearsing medical attendant, my chief urged me to accept the open door to turn into a charge nurture. This was an aspiration of mine from the earliest starting point. I realized I had the capacities to assume responsibility and lead a group. With the information and qualities of my senior medical caretakers, I started to build up my initiative aptitudes. Tuning in and taking part as a colleague helped me gain from my individual medical caretakers as they imparted their encounters to me.I was never too glad to even think about listening or learn. I have kept on outstanding along these lines all through my nursing profession. This has been helpful to me since I can lead and tune in to a group. From the earliest starting point I understood that the key components were correspondence and cooperation. My objectives expanded from that point, and I realized I needed to take further classes so as to build up my abilities. I got affirmed in Advanced Certified Life Support and Pediatric Advanced Life Support, and following three years of this experience my next objective was to progress into Pediatric nursing.I was extended to an employment opportunity on a Pediatric Oncology floor at Loma Linda University Medical Center, Childrenââ¬â¢s Hospital. I became chemo ensured and started working with pediatric disease patients. I tested myself into working in basic consideration pediatric oncology. This was a very enthusiastic involvement with my nursing vocation. Having remained on that unit for four and a half years, I was eager for another objective. I wandere d out for another experience and went after a recuperation room nurture job at Placentia Linda Hospital. While working in the recuperation room, I at that point prepared to turn into a working room nurse.My administration and authoritative abilities got evident; I was then advanced into a charge nurture position. I kept on needing to become familiar with initiative so I accepting a situation as an associate director at another non-set up medical procedure community. This objective was by a wide margin the most energizing for me. It demonstrated me another segment of nursing and administration. As, Ivey Business Journal portrayed, the motivation behind learning an objective is to invigorate oneââ¬â¢s creative mind, to take part in revelation and to ââ¬Å"Think outside of the boxâ⬠(Ivey Business Journal, 2006, p. 1).Not just did I need to consider perfect patient consideration, I must be an executive of a group, manage funds, and be in direct line of fire of the doctors who possessed the office. Following three and a half long stretches of developing and extending my insight into organization, just as being a patient consideration advocate, my thankfulness for my calling has become fonder and I am prepared to seek after a more significant level of the executives. In the long run, I might want to turn into an executive of medical procedure administrations. This will permit me to turn out to be a piece of an arranging group, decline my feeling of anxiety, and give a superior personal satisfaction for my family and myself.In end, I have come to understand that the calling I have picked has given me an extraordinary feeling of pride. I have achieved numerous objectives up to this point in my nursing profession, yet anticipating accomplishing more. I began as a volunteer, and in the long run turned into a charge nurture where I keep on exceeding expectations. Rogers (2007) expressed, ââ¬Å"Even if youââ¬â¢re in good shape, youââ¬â¢ll get run over in the event that you simply sit thereâ⬠(p. 95). I have decided to keep testing myself in my profession by growing better approaches to lead, oversee, and tune in to my friends. The promise to expand my instruction has brought new goals.These objectives include: getting my Bachelor of Science qualification in Nursing and to keep growing new procedures to upgrade my capacities as a group head and further development to a chief position. References Mestas, M. , Urdan, T. (2006). The objectives behind execution objectives. The Journal of Educational Psychology,Vol. 98(2), 354-365. Latham, G. , Seijts, G. P. (2006). Learning objectives or performing objectives: Is it the excursion or the goal? Ivey Business Journal, Vol. 70(5), 1-6. Diocesan, J. , Carter, C. , Katz, J. R. , Lyman, S. (2006). Qualities, Goals,Time, and Stress. The Keys to Nursing Success, 95.
The Linked History of the Flashlight and the Battery
The Linked History of the Flashlight and the Battery The electric lamp was designed in 1898 and protected in 1899. The scriptural statement let there be light was on the front of the 1899 Eveready list promoting the new flashlight.â Eveready Founder Conrad Hubert In 1888, a Russian immigrantâ and innovator named Conrad Hubert established theà American Electrical Novelty and Manufacturing Company (later renamed Eveready). Huberts organization produced andâ marketed battery-controlled curiosities. For instance, ties and vases that lit up. Batteries were as yet an oddity around then, at that point as of late acquainted with the customer showcase. David Misell, Inventor of the Flashlight A spotlight by definition is a little, versatile light typically fueled by batteries.à Whileà Conrad Hubert may have knownâ the electric lamp was a brilliant thought, it was not his. English innovator David Misell, who was living in New York, licensed the first electric lamp and offered those patent rights to the Eveready Battery Company. Conradà Hubert initially met Misellâ in 1897. Intrigued with his work,à Hubertà purchased all of Misells past licenses identified with lighting, Misellsâ workshop, and his then-incomplete development, the cylindrical electric lamp. Misells patent wasâ issued on January 10,à 1899.à His convenient light wasâ designed in the now recognizable cylinder shape and utilized three D batteriesâ placed in a line, with a light toward one side of the tube.â Victory Whyâ was the electric lamp called a spotlight? The principal spotlights utilized batteries that didn't keep going long. They gave a glimmer of light, as it were. In any case, Conradà Hubert kept on improving his item and made the electric lamp a business achievement. It helped make Hubert aâ multi-mogul, andà Eveready an enormous organization. Source: Utley, Bill. History of the First Tubular Flashlight. CandlePowerForums, May 20, 2002.
Sunday, June 28, 2020
Oil Paint on Fiberboard The Homage to the Square Arts - 1100 Words
Oil Paint on Fiberboard: Describing the Homage to the Square Arts (Research Paper Sample) Content: Name TutorCourse Date Artist: Josef AlbersDate: 1964Medium: Oil paint on fiberboard.Title: study of Homage to the Square.Homage to the SquareAn artist work is a sculpture, painting, photographs, drawings, and others that are made to be attractive and to express a key idea or a feeling. Art is not information but rather revelation, its an expression and not a description, and its not a repetition or an imitation but rather a creation. The importance of a physicality of the artwork has been destabilized since the conversion to intellectual labor from manual labor with the commencement if readymade. The artist motive is on the creativity of the work and not in the result of that investigation. The purpose of the hand of an artist has turned to be that of insertion, collection and selecting. Although the intention of this paper was to focus this discussion on current and contemporary art like installation, impermanent or short-lived artworks, and new means artworks, because in most cases they are particularly difficult for maintenance ethics and methodology. The paper aims at discussing the original intent in the concept of Homage to the Square which has taken on different meanings and value over time and the artist general ideas in the creation of this art context is a topic of contention. Homage to the Square (1951) was the work of Josef Albers. In 1949, Albers left Black Mountain College where he was serving as the chair of Design Department at Yale University for eight years and taught Richard Anuszkiewicz and Eva Hesse. While lecturing in Yale University, Albers began his most famous body of work, the series Homage to the Square, an exercise on the optical effects of color within the confines of a uniform square shape (Max 71). In 1950, he began working towards the project that would become his signature series, the Homage to the Square. Josef Albers was influential in getting the tenets of European modernization, for the most part thos e linked with the Bauhaus, to America. His heirloom as an instructor of artists, as well as his wide ranging hypothetical work suggesting that color, rather than form, is the most important medium of pictographic language 1 ,intensely influenced the improvement of contemporary art in the United States during the 1950s and 1960s. He argued that instead of art he has taught philosophy and technique to him was a big word, he never taught how to do the painting and rather all his doings was aimed at people to see. In his Homage to the Square artwork, his unceasing continuous devotion to a single aspect of painting reflects his opinion that perception is only accomplished through sustained tirelessly trying and critical repetition (Robert 54). This initial work demonstrates his basic methodology an approach on seeing the sights of the flexibility of human view as well as their perception, and the kind of visual and psychosomatic2special effects that colors on its own can yield dependent on their position, closeness and proximity.Until his death in 1976, he came up with creative ideas and produced more than hundred variations on the simple of compositional scheme of at least three to four squares, which were set inside each other, with the squares a little settling towards the lowest part of the edge. Initially the work appeared to be a very narrow conceptual framework, later shown itself as one of the astonishing perceptual complexity (Smith 87). In 1965, Josef Albers wrote of the series; he argued that they are all of altered palettes3 and later to talk of different climates. Albers chose a solitary, recurrent symmetrical figure, which he claimed was devoid of imagery and symbolism, to steadily investigate with the relativeness of color, how it deviates through association, placement, and interaction with other colors, producing the impression of attraction, movement, resistance and weight. The objective of the color chosen for use in the art work as well as thei r order is of interaction that influences and changes each other forth and back. Thus, the character and feelings change from painting to painting without extra addition of hand writing characters or the textures. In his earlier homochromatic and linear readings, this sequence discovers the possible of static two-dimensional means to invoke energetic three dimensional spaces (Weiner 167). However, the fundamental proportioned and quasi concentric arrangement or order of squares remains the same in all portrait paintings in quantity and placement. These identical squares categorize themselves, bond and separate in many altered ways. Albers theories and arts were broadly dispersed to generations and peer groups of artists and in the faculty of art school through his trainings and instructions at the Bauhaus, Black Mountain College, and Yale University, and they offered the theoretic basis during and after the age of Abstract Expressionism for the improvement of non-objective art. His work on this project exemplifies his experimentations with non-traditional resources and methods. The mechanical methodology of producing such glass pieces permitted him to attain the discipline and objectivity that he considered essential to generate nonrepresentational systems. The Homage to the Square series is also differentiated by the sensibly documented writings of ...
Friday, May 29, 2020
Law Essay Example about Muslim Faith - Free Essay Example
A. Maria Haines has recently converted to the muslim faith and has now insisted on wearing the appropriate religious dress which requires Maria to wear clothing revealing only her eyes. Customers have refused to deal with her Maria is the sole Receptionist as BIS and they have told her that they will have to terminate her contract. If BIS decides to terminate Marias contract, then it is likely that she will commence proceeding against BIS for unfair dismissal, pursuant to section 94(1) of the Employment Rights Act 1996 (as amended). It is likely that the primary basis for her claim will be that her right to freedom of religion, under Article 9 of the Human Rights Act 1998, has been infringed by her employers decision to dismiss her for wearing her religious head veil. Article 9(1) of this Act provides that, ââ¬Å"Everyone has the right to freedom of thought, conscience and religion; this right includes freedom to change his religion or belief and freedom, either alone or in community with others and in public or private, to manifest his religion or belief, in worship, teaching, practice and observance.â⬠(Art. 9(1) HRA 1998) Maria will likely argue that in wearing a veil she is publically manifesting her religion in practice and observance. She may even try to rely upon the recent House of Lords decision in the case of R (Begum) v Governors of Denbigh High School [2006] UKHL 15 to support this argument. By virtue of section 98(1) of the Employment Rights Act 1996, the burden of proof will rest upon BIS to satisfy the Tribunal, on the balance of probabilities, that the dismissal was not unfair. Maria may also argue that BIS has unlawfully discriminated against her on grounds of her religion and belief, in accordance with regulation 3 of the Employment Equality (Religion or Belief) Regulations 2003. Her argument would likely be that, in dismissing her, BIS treated her ââ¬Å"less favourably than [it] treats or would treat other persons.â⬠(Reg. 3(1)(a) EE(RoB)R 2003) There are several aspects to this claim which present opportunities for BIS to mount a successful defence to these claims: The first argument that BIS might make is that the dismissal in question was not unfair, because the reason for her dismissal ââ¬Å"relates to [her] capabilityâ⬠¦ for performing work of the kind which [she] was employed by BIS to do.â⬠(s.98(2)(a) ERA 1996) There is clear evidence here that Maria could not continue as receptionist, because BISs customers refused to have any further dealings with her, due to her insistence on covering her face with a religious veil. BIS can argue that Marias rights under Article 9(1) of the Human Rights Act 1998 are not absolute because they are qualified by Article 9(2) of that same Act, which provides that, ââ¬Å"Freedom to manifest ones religion or beliefs shall be subject only to such limitations as are prescribed by law and are necessary in a democratic society in the interests of public safety, for the protection of public order, health or morals, or for the protection of the rights and freedoms of others.â⬠(Art. 9(2) HRA 1998) BIS can argue that its right to run an effective business is one of the rights against which Article 9 must be weighed and that this latter right must prevail. There is recent and good judicial authority for this proposition; namely, in the case of Copsey v WWB Devon Clays Ltd [2005] EWCA Civ 932 which applied the earlier case of Stedman v United Kingdom (1997) 23 E.H.R.R. CD 168. Mar ia might try to rebut this argument and distinguish these authorities on the basis that, in those cases, the employees in question refused to accept offers of alternative employment, although the success of this argument will depend upon whether or not it was viable for BIS to make such an offer in this case. In light of the fact that BIS is only a small company, it may well be the case that there did not, at the time of dismissal, exist any other vacancies for which Maria would have been suitably qualified. BIS might also try to argue, in light of the fact that Maria has only recently converted to Islam, that her religious beliefs are not sufficiently cogent, serious or important to warrant her reliance on Article 9 of the Human Rights Act 1998; while the success of this argument will fall on the Courts interpretation of the facts, there is judicial authority, at least at the European level, that lack of real or strong religious belief precludes the operation of Article 9 of the European Convention on Human Rights 1950 (Campbell and Cosans v United Kingdom (1982) 4 EHRR 293). A similar argument to this that BIS might try to rely upon is that Maria, in wearing a head veil, was not manifesting her religious beliefs, but was merely motivated to wear religious dress by those beliefs; again, there is judicial authority at the European level to support the validity of this argument (Arrowsmith v UK (1978) 3 EHRR 218). BIS can distinguish the decision handed down by the House of Lords in the case of R (Begum) v Governors of Denbigh High School [2006] UKHL 15 on the basis that this case concerned the treatment of a student in compulsory full-time education. Both Brooke LJ and Mummery LJ both explicitly declared in this case that the principles in operation were not the same as those applicable in the employment context (Sandberg, 2009:272). In regard to the argument that BISs dismissal constitutes discrimination under regulation 3 of the Employment Equality (Religion or Belief) Regulations 2003: BIS can argue that, in light of the reaction of its customers to Marias head veil, requiring her to remove the veil during working hours became a genuine and proportionate occupational requirement, in accordance with regulation 7(2) of the 2003 Regulations (Nairns, 2007:93). In conclusion, so long as BIS can satisfy the Court that it was not in a position to be able to offer Maria any alternative employment, where she would have been able to continue wearing her religious dress, then it is highly unlikely that any of Marias claims will be successful. B. Josie Rimson has been employed in BIS cafeteria to prepare staff meats. She has noticed that some of the meats and sauces are out of date, but, having raised the issue, was told: ââ¬Å"Your job is to make the meals, just get on with itâ⬠. She has now heard that some staff are off sick with suspected food poisoning and she is afraid she will be blamed. Repeated complaints to Senior Managers at BIS have been rejected so now she has reported the problem to Bramley Council. An item on the matter has now appeared in the Bramley Gazette. BIS has decided to discipline her, and have warned that she may be dismissed. The main issue here is whether or not a dismissal of Josie by BIS would be deemed unfair under the Employment Rights Act 1996, as amended by the Public Interest Disclosure Act 1998, an Act which inserted into the 1996 Act clause 103A, which provides that, ââ¬Å"An employee who is dismissed shall be regarded for the purposes of this Part as unfairly dismissed if the reason (or, if more than one, the principal reason) for the dismissal is that the employee made a protected disclosure.â⬠(s. 103A ERA 1996; s. 5 PIDA 1998) The term ââ¬Ëprotected disclosure is defined by sections 43A and 43B of the Employment Rights Act 1996 (as amended) as, ââ¬Å"â⬠¦any disclosure of information which, in the reasonable belief of the worker making the disclosure, tends to show one or more of the followingââ¬â (â⬠¦) (b) that a person has failed, is failing or is likely to fail to comply with any legal obligation to which he is subject, (â⬠¦) (d) that the health or safety of any individual has been, is being or is likely to be endangered (â⬠¦) (f) that information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed.â⬠(s. 43A 43B ERA 1996) In the present case, it is reasonably clear, on the facts, that the reason Josie reported this matter to the Bramley Gazette was because she felt that her Senior Managers were trying to conceal or, at least, disregard the possibility that the instances of staff poisoning were the result of their consuming out of date food in the staff canteen, in which case section 43B(f) of the Employments Rights Act 1996 would likely be deemed satisfied. It may also be the case that Josie felt, in light of the despondence of BISs senior managers, that unless she reported this incident to the Bramley Gazette, the events giving rise to these incidences of food poisoning would repeat themselves in the future, in which case section 43B(d) of the Employments Rights Act 1996 would likely be deemed satisfied. If the Tribunal is satisfied (1) that Josie ââ¬Ëreasonably believed that there had been malpractice on the part of her Senior Managers (Babula v Waltham Forest College [2007] EWCA Civ 174); and, (2) that Josies disclosure was the reason for her dismissal (Kuzel v Roche Products Ltd [2008] EWCA Civ 380), then it is highly likely that Josie will be able to bring a successful claim against BIS for unfair dismissal. BIS might try to argue that Josie is being dismissed for gross negligence, in preparing staff meals using foods which were out of date , and that when the Senior Managers told her ââ¬Å"Your job is to make the meals, just get on with it,â⬠they were merely reminding her that it is within her job capacity to make decisions in regard to which food stuffs to use and which to discard. While this argument might have had some merit if Josies Senior Managers had commenced disciplinary proceedings afte r Josie admitted that the recent outbreak of food poisoning was potentially attributable to her having served out of date food stuffs in the staff canteen, the fact that such proceedings were only initiated after the article was published in the Bramley Gazette, renders this version of events highly improbable. C. Harriet Jameson has recently returned from sick leave following a serious car accident, which required her to have extensive surgery for major facial injuries. The surgery left her with very visible red scarring on her face. BIS has interviewed her and suggested removing her from her post as Manager of the company creche because the children of the employees have refused to attend: they have been having nightmares, and this is affecting attendance of the female employees at work. Harriet has refused her relocation to the personnel Department, claiming discrimination. The main issue which falls for determination here is whether or not Harriet, if dismissed from her position as Manager of the company crà ¨che, will be able to mount a successful claim against BIS for unfair dismissal. We have been told that Harriet is claiming that she is being discriminated against on the basis of her facial disfigurement. However, in order for this argument to have legal validity, it is necessary that Harriet can satisfy the Tribunal that her facial scarring qualifies her for protection under the Disability Discrimination Act 1995. For the purposes of this Act, a ââ¬Ëperson with disability is defined as follows: ââ¬Å"â⬠¦ a person has a disability for the purposes of this Act if he has a physical or mental impairment which has a substantial and long-term adverse effect on his ability to carry out normal day-to-day activities.â⬠(s. 1(1) DDA 1995) While there is no doubt that Harriets purported disability is physical in nature, in order for her to argue that it is a qualifying impairment, she must satisfy the Tribunal that it is having substantial adverse effects, that those substantial adverse effects will likely remain for the long-term and that they affect her ability to carry out normal day-to-day functions or activities (Department for Work and Pensions, 2005:3). The Guidance issued by the Secretary of State on the definition of disability, pursuant to section 3 of the Disability Discrimination Act 1995 confirms that, with some limited exceptions (e.g. for self-inflicted scarring, piercing or tattoos), bodily scarring or disfigurement will be deemed to have substantial adverse effects on a persons ability to undertake normal day-to-day activities (Department for Work and Pensions, 2005:6; Adams, 2008:375). To satisfy the ââ¬Ëlong-term criterion of the 1995 Act, the scarring must either have been present for 12 months or be likely to remain for that period (Adams, 2008:375). In this present case, while the s urgery was only recent, it seems likely, due to its severity, that the scarring will remain for at least this length of time. Having established that Harriet qualified for protection under the Disability Discrimination Act 1995, it is now necessary to consider whether or not she has been discriminated against on the basis of her disability. ââ¬ËDiscrimination is defined by section 5 of the 1995 Act: ââ¬Å"For the purposes of this Part, an employer discriminates against a disabled person ifââ¬â (a) for a reason which relates to the disabled persons disability, he treats him less favourably than he treats or would treat others to whom that reason does not or would not apply; and (b) he cannot show that the treatment in question is justified.â⬠(s. 5(1) DDA 1995). While it is certainly the case that BIS has asked Harriet to accept a lateral move on the basis of her disability, BIS will seek to show that this did not constitute discrimination because it was not approp riate for her to remain working with children, in light of the effect that her disfigurement has had on them, in practice. In the opinion of this author, BIS has acted reasonably and proportionately in asking Harriet to relinquish her role as Manager of the company crà ¨che and to accept an alternative employment position in the company. As Adams (2008:367) argues, albeit in a slightly different context, ââ¬Å"An employerâ⬠¦ may be justified in refusing to employ as a model for cosmetics someone who suffers from a disfiguring scarringâ⬠¦Ã¢â¬ In conclusion, if Harriet refuses to accept BISs offer of alternative employment, BIS will be entitled to terminate her contract, without fear of any legal repercussions under the Employment Rights Act 1996 or the Disability Discrimination Act 1995. References/ Bibliography The Employment Rights Act 1996. The Employment Rights Act 2002. The Employment Equality (Religion or Belief) Regulations 2003. Stedman v United Kingdom (1997) 23 E.H.R.R. CD 168. The Human Rights Act 1998. Copsey v WWB Devon Clays Ltd [2005] EWCA Civ 932. The European Convention on Human Rights 1950. Campbell and Cosans v United Kingdom (1982) 4 EHRR 293. Arrowsmith v UK (1978) 3 EHRR 218. R (Begum) v Governors of Denbigh High School [2006] UKHL 15. Sandberg, R., 2009. The Changing Position of Religious Minorities in English Law: The Legacy of Begum. In RD Grillo (ed.), Legal Practice and Cultural Diversity, Ch. 14. Aldershot: Ashgate Publishing Limited. Nairns, J., 2007. Employment law for business students. 3rd edition. London: Pearson Education Publishing. The Public Interest Disclosure Act 1998. Babula v Waltham Forest College [2007] EWCA Civ 174. The Disability Discrimination Act 1995. Kuzel v Roche Products Ltd [2008] EWCA Civ 380. Department for Work and Pensions, 2005. Disability Discrimination Act consultation document: guidance on matters to be taken into account in determining questions relating to the definition of disability. London: The Stationary Office. Adams, A., (2008). Law for business students. 5th edition. London: Pearson Education Publishing.
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