Health Problems Linked to Smoking Tobacco :: Papers

Health Problems Linked to Smoking TobaccoIt is a universally accepted fact that pot cig arttes or tobacco is detrimental to your health. There is an endless list of health problems that are directly ca social functiond or affected by smoking, including lung cancer, breast disease, stroke, and emphysema.Short-term effects of smoking include a significant increase in heart rate and a drop in skin temperature. Respiration rate is also increased. In novice smokers, diarrhea and vomiting may occur. Although the central nervous system is, in fact, stimulated by smoking, smokers usually feel it relaxes them. Long-term effects are mainly on the bronchiopulmonary and cardiovascular systems. Smoking is the main cause of lung cancer (related to 90% of all lung cancer cases). Other factors, notably industrial carcinogens may be involved, especially among smokers. An average smoker is ten times more likely to get lung cancer than in a nonsmoker. Smoking is estimated to be responsible for 30% of all cancer deaths. It is also associated with cancers of the mouth, throat, colon, pancreas, bladder, kidneys, stomach, and cervix, and related to 75% of chronic bronchitis cases and 80% of emphysema cases.Tobacco also affects the digestive system. Gastric and duodenal (the upper branch of the small intestine) ulcers are twice as common and twice as likely to cause death in smokers as in nonsmokers. Skin wounds may heal less quickly in smokers, partly because smoking depletes the body of vitamin C. Smokers may also have less effective immune systems than nonsmokers. Tobacco use is associated with 25% to 30% of all cardiovascular disease. Smokers have a 70% higher rate of coronary heart disease than nonsmokers, nearly twice the fortune of heart attack, and five times the risk of stroke. Tobacco use can lead to physical and psychological dependence on nicotine, particularly in cigaret smokers. The United States Surgeon Generals 1988 report states that cigarettes and other forms of tobacco are just as addicting as heroin and cocaine.People who are physically dependent on tobacco suffer a withdrawal reaction when they stop using it. Some signs of withdrawal are irritability, anxiety, headaches, sleep disturbances (insomnia or drowsiness), difficulty concentrating, decreased heart rate and increased appetite, and a craving for nicotine.

The Day I Didnt Have an Abortion :: Personal Narrative Essays

The Day I Didnt Have an Abortion   Have you incessantly stopped to ponder on the fragility of life? I had unceasingly taken life for granted and never gave much thought to how or when my life might end. Then, in June, I was awakened to the realization of just how temporary the balance of life and death can be.   I was still a young bride. Jim and I had been married for four years but had been unsuccessful in getting a family started. It was not a matter of not trying. After having experienced two miscarriages and an episode of uterine cancer within those four years, my chances of ever becoming a mother seemed to be so remote as to seem impossible. My doctors had already told me that another pregnancy was out of the question and inserted a coil (a contraceptive device that is permanently placed in the opening of the uterus) just to make sure that his orders would be heeded. He wanted to prevent any accidents.   sestet months passed and my monthly checkup s were showing that there were no new growths and no complications. Meanwhile, I was busy getting back into the working world as a subordinate accountant for a farm equipment dealer in our small northern California town. I enjoyed the work and the association with my coworkers and our customers helped to keep my mind off my unrealized mothering instincts. I found myself mothering my coworkers giving advice, lending a listening ear as well as making homemade breads, brownies and cookies for them.   Soon it was time for my one-seventh month checkup. The doctor went through his routine probing, fluid checks and questioning. All appeared to be in order. However, a few days later, he called to ask that I get hold to his office. He wouldnt say why, just that we needed to have a little chat. As I placed the phone back in its cradle, I was trembling. This moldiness mean that the cancer had returned. I felt that I had to pull myself together. If it was coming back, this soon, then my life was going to be very short. There were so some things that I had always wanted to see and/or do.

Essay --

Pour commencer mon TPE, jai d choisir mes compagnons pour former un groupe . Nous devions obligatoirement former stilboestrol groupes de trois lves, jai donc constitu un groupe avec Sarah et Manal car nous nous entendions bien et nous tions prt faire un bon travail dquipe . Ensuite nous nous sommes penchs tire le choix du sujet.A. La ralisation de notre TPEI Le choix dun sujetUne fois que nous avons form le groupe, nous sommes passs au choix du sujet de notre TPE. Pendant les premires sances, nous avons fait plusieurs recherches mais finalement notre choix sest vite port sur un thme lintelligence artificielle qui nous aurait permis de relier les SVT avec la physique et les mathmatiques . Nous avions dabord prvu de travailler sur le cerveau artificiel. Pour cela nous avons effectu des recherches sur ce sujet mais nous nous sommes rapidement rendu compte de la difficult de ce sujet, nous avons donc compltement chang notre sujet et nous avons dcid de parler des armes chimiques en S yrie. Nous avons ensuite dfini notre problmatique le dmantlement de l...

Essay --

In the 20th century, numerous ideas of the future have entertained society. Movies such as Star Wars and Back to the in store(predicate) have greatly influenced how society views the future. No one could have predicted that George Orwells 1984 legend came in first place when discussing about the present day. The primary purpose of 1984 is to paint how life exit be like under the control of a totalitarian government. This novel is way ahead of its time and gave frighteningly possible insights into the future. Currently, the people of America atomic number 18 living in this reality, which Orwell prophesied. Advancement in technology today is world changing however, it can become a breakneck weapon when left in the wrong hands. It is used as a form of distraction and control. There is a vision that, one day, there will be a monitor in every household that regularly observes peoples interest and loyalty. Even though there are no helicopters flying by and peeking through the neigh bors windows, the government manages to spy on the average Joe in a realistic manner. Many people do not believe that the American government can implement such action, but it has been achieved and is far worst than what Orwell could have imagined. The nature of the National Security agency revelations with the overhaul of Edward Snowden, who leaked top secret government information, are within the scope of the Orwellian vision of the all-seeing Big Brother.Readers of the novel are able to visualize the disastrous and unearthly world through the eyes of Winston Smith, the protagonist. The world that he inhabits is cruel and ran by a government that controls the entire population. Big Brother is an entity in the novel who is seen as the all knowing and powerful. He is said to exists however... ...om the government. There are no more anonymous masses. Jump forward to today, and it seems that the American people are openly giving away all sorts of freedoms and their right to privac y. There needs to be a balance. People need to take action. Also, Orwells points out that the government is official too much power over apparently small things such as the Patriot Act however, it is just a blueprint that will help widen the window of opportunity for the government to attain more power.Society is headed for a downfall where the government increasingly takes away civil liberties, whistle blowers and journalists are prosecuted, and truth is becomes a crime. It is difficult to see how anyone could make the claim that society is not headed closer to that direction. 1984 made a bold prediction. There are manifestly parallels between society today and Orwells book.

Use of Imagery in Daddy by Sylvia Plath Essay -- Poetry Analysis

As a modern female poet, Sylvia Plath played many roles in her art she was the fragile feminist, the confessional writer, the literary innovator. As a woman, Plath found herself with adept foot in her past and the other in an uncertain future, her present an often uncomfortable combination of the two. She was at once a daughter desperate to make her parents proud and a wife eager to please her husband an overworked, depressed teenager and a lonely, delirious nonplus a child who lost her go and an adult who lost her hope. Plaths confusion between her memories and her fantasies produced the creative inspiration that spawned much of her work the losings she suffered had the homogeneous effect. The death of her initiate became a theme in her poetry on which Plath would often spin her words. In the poem dadaism, Plath uses imagery to compare her father to a shoe, God and a vampire, to establish similarities between her father and her husband and to describe the lack of communicati on between her and her father.You do non do, you do not do/Anymore, black shoe, proclaims Plath in the opening lines of Daddy (222), introducing the world to her father, ominous in the color black and consistent in his inability to do anything for Plath anymore. This limning of the father as an shoe instead of a man also presents Plaths deft use of imagery to color the character of her father, this time with the feel of a black shoe. This image makes the father sound stifling (Slayer 1).The imagery of the black shoe is also powerful in explaining the nature of Plaths posthumous relationship with her father. Shoes usually protect the foot, provide warmth for it (Goelzhaeuser 1). Shoes in the poem, however, do not invoke the sheltering, caring ... ...ountry. However, it seems likely that she died as she lived, taken up(p) by a combination of the two, her deceased father pointing out her failures from far away in her childhood and her substitute husband becoming another(prenominal ) one of those failures from another womans apartment. The imagery of Daddy, of her father and her husband, each her protector and her abuser in one, stands a testament of words to just that. whole shebang Cited Barnard, Carolean King. Sylvia Plath. Boston Twayne Publishers, 1978. Goelzhauser, Nicola. Imagery in Sylvia Plaths Daddy. Online. http//www.geocities.com/SoHo/Studios/8984/daddy.htm. Oedipus Complex. Merriam Websters Collegiate Dictionary. 10th ed. 1993. Plath, Sylvia. The Collected Poems. Ed. Ted Hughes. NewYork Harper Perennial, 1972. Sylvia the Vampire Slayer. Online. http//members.aol.com/raisans/plath.htm. Use of Imagery in Daddy by Sylvia Plath Essay -- Poetry AnalysisAs a modern female poet, Sylvia Plath played many roles in her art she was the fragile feminist, the confessional writer, the literary innovator. As a woman, Plath found herself with one foot in her past and the other in an uncertain future, her present an often uncomfortable combination of the two. She was at once a daughter desperate to make her parents proud and a wife eager to please her husband an overworked, depressed teenager and a lonely, sick mother a child who lost her father and an adult who lost her hope. Plaths confusion between her memories and her fantasies produced the creative inspiration that spawned much of her work the losses she suffered had the same effect. The death of her father became a theme in her poetry on which Plath would often spin her words. In the poem Daddy, Plath uses imagery to compare her father to a shoe, God and a vampire, to establish similarities between her father and her husband and to describe the lack of communication between her and her father.You do not do, you do not do/Anymore, black shoe, proclaims Plath in the opening lines of Daddy (222), introducing the world to her father, ominous in the color black and consistent in his inability to do anything for Plath anymore. This depiction of the father as an shoe instead of a man also presents Plaths deft use of imagery to color the character of her father, this time with the shade of a black shoe. This image makes the father sound stifling (Slayer 1).The imagery of the black shoe is also powerful in explaining the nature of Plaths posthumous relationship with her father. Shoes usually protect the foot, provide warmth for it (Goelzhaeuser 1). Shoes in the poem, however, do not invoke the sheltering, caring ... ...ountry. However, it seems likely that she died as she lived, haunted by a combination of the two, her deceased father pointing out her failures from far away in her childhood and her substitute husband becoming another one of those failures from another womans apartment. The imagery of Daddy, of her father and her husband, each her protector and her abuser in one, stands a testament of words to just that.Works Cited Barnard, Caroline King. Sylvia Plath. Boston Twayne Publishers, 1978. Goelzhauser, Nicola. Imagery in Sylvia Plaths Daddy. On line. http//www.geocities.com/SoHo/Studios/8984/daddy.htm. Oedipus Complex. Merriam Websters Collegiate Dictionary. 10th ed. 1993. Plath, Sylvia. The Collected Poems. Ed. Ted Hughes. NewYork Harper Perennial, 1972. Sylvia the Vampire Slayer. Online. http//members.aol.com/raisans/plath.htm.

Use of Imagery in Daddy by Sylvia Plath Essay -- Poetry Analysis

As a modern female poet, Sylvia Plath played many roles in her art she was the fragile feminist, the confessional writer, the literary innovator. As a charr, Plath ground herself with one foot in her past and the other in an uncertain future, her present an often uncomfortable combination of the two. She was at once a daughter desperate to make her parents proud and a wife eager to please her husband an overworked, depressed teenager and a lonely, sick mother a claw who lost her forefather and an adult who lost her hope. Plaths confusion between her memories and her fantasies produced the creative inspiration that spawned much of her work the losses she suffered had the same effect. The termination of her father became a theme in her poetry on which Plath would often spin her words. In the poem Daddy, Plath uses kitchen rangery to compare her father to a habilitate, graven image and a vampire, to establish similarities between her father and her husband and to describe the l ack of communication between her and her father.You do not do, you do not do/Anymore, lowen shoe, proclaims Plath in the opening lines of Daddy (222), introducing the world to her father, ominous in the color black and consistent in his inability to do anything for Plath anymore. This depiction of the father as an shoe instead of a man also presents Plaths deft use of imagery to color the character of her father, this time with the shade of a black shoe. This image makes the father sound stifling (Slayer 1).The imagery of the black shoe is also powerful in explaining the nature of Plaths posthumous kindred with her father. spot usually protect the foot, provide warmth for it (Goelzhaeuser 1). Shoes in the poem, however, do not invoke the sheltering, caring ... ...ountry. However, it seems likely that she died as she lived, haunted by a combination of the two, her deceased father pointing out her failures from far away in her childhood and her substitute husband becoming another (prenominal) one of those failures from another womans apartment. The imagery of Daddy, of her father and her husband, each her protector and her abuser in one, stands a testament of words to just that.Works Cited Barnard, Caroline King. Sylvia Plath. capital of Massachusetts Twayne Publishers, 1978. Goelzhauser, Nicola. imaginativeness in Sylvia Plaths Daddy. Online. http//www.geocities.com/SoHo/Studios/8984/daddy.htm. Oedipus Complex. Merriam Websters Collegiate Dictionary. 10th ed. 1993. Plath, Sylvia. The Collected Poems. Ed. Ted Hughes. NewYork Harper Perennial, 1972. Sylvia the Vampire Slayer. Online. http//members.aol.com/raisans/plath.htm. Use of Imagery in Daddy by Sylvia Plath establish -- Poetry AnalysisAs a modern female poet, Sylvia Plath played many roles in her art she was the fragile feminist, the confessional writer, the literary innovator. As a woman, Plath found herself with one foot in her past and the other in an uncertain future, her present an often uncomfortable combination of the two. She was at once a daughter desperate to make her parents proud and a wife eager to please her husband an overworked, depressed teenager and a lonely, sick mother a child who lost her father and an adult who lost her hope. Plaths confusion between her memories and her fantasies produced the creative inspiration that spawned much of her work the losses she suffered had the same effect. The death of her father became a theme in her poetry on which Plath would often spin her words. In the poem Daddy, Plath uses imagery to compare her father to a shoe, God and a vampire, to establish similarities between her father and her husband and to describe the lack of communication between her and her father.You do not do, you do not do/Anymore, black shoe, proclaims Plath in the opening lines of Daddy (222), introducing the world to her father, ominous in the color black and consistent in his inability to do anything for Plath anymore. This depiction o f the father as an shoe instead of a man also presents Plaths deft use of imagery to color the character of her father, this time with the shade of a black shoe. This image makes the father sound stifling (Slayer 1).The imagery of the black shoe is also powerful in explaining the nature of Plaths posthumous relationship with her father. Shoes usually protect the foot, provide warmth for it (Goelzhaeuser 1). Shoes in the poem, however, do not invoke the sheltering, caring ... ...ountry. However, it seems likely that she died as she lived, haunted by a combination of the two, her deceased father pointing out her failures from far away in her childhood and her substitute husband becoming another one of those failures from another womans apartment. The imagery of Daddy, of her father and her husband, each her protector and her abuser in one, stands a testament of words to just that.Works Cited Barnard, Caroline King. Sylvia Plath. Boston Twayne Publishers, 1978. Goelzhauser, Nicola. Im agery in Sylvia Plaths Daddy. Online. http//www.geocities.com/SoHo/Studios/8984/daddy.htm. Oedipus Complex. Merriam Websters Collegiate Dictionary. 10th ed. 1993. Plath, Sylvia. The Collected Poems. Ed. Ted Hughes. NewYork Harper Perennial, 1972. Sylvia the Vampire Slayer. Online. http//members.aol.com/raisans/plath.htm.

Psychological Disorder Analysis Essay

Marla is a 42-year-old Hispanic female who comes to the psychogenic health clinic complaining of having trouble sleeping, feeling jumpy all of the time, and experiencing an inability to concentrate. These symptoms cause problems for her at unravel, where she is an accountant. As a psychiatrist I would need to diagnose Marla with the proper disorder, explain information about the diagnosis, and discuss possible treatments with her. It would be near unfeasible to make an accurate diagnosis without more information.First, I will clinically assess Marla by asking her a few questions without her realizing right away that I am trying to diagnose her from the second she enters my office. I will ease into the conversation to gain more insight before she notices what I am doing. I would like to provide a brief interview of how I would expect it to go, given the disorder that I have diagnosed. Hello, Marla. I am Joy Wardrip. Its a pleasure to meet you. Will you put me a little bit about yo urself? Marla would likely introduce herself, tell me that she is an accountant.She would go on to tell me how she has been feeling anxious for a bit and how it rightfully distracts her from her work. She would tell me how she has trouble concentrating and that too is affecting her work. She would likely be a bit emotional, perhaps tearful as she expresses her licking with the occurrence of these recent symptoms and how she would like to symptoms to be explained and to go away. She may even express how she wants to feel normal again. I understand your frustration and it is ok to feel frustrated. How long ago did you notice a change in your behavior?Marla would allow me know that she had been feeling this way for the past sestet to eight months. She would also tell me that she cant echo allthing that has happened in her life to explain the anxieties that she was feeling. She would tell me how she would like for things to go back to the way that they employ to be. How is your relationship with your p atomic number 18nts? Marla would describe a great upbringing. She would explain how she is very close to both of her parents. She would go on to describe her childhood, which was abuse and torment free. She would speak of many good memories with her parents and how she is an only child.She would go on to tell me that she was quite spoiled and had no bad memories of being a young girl. Is there any mental illness that runs in your family? Also, have you ever been diagnosed with any disorders or are you on any sheath of medication? Marla would tell me that no psychological disorders were bare in her family and that she is not currently taking any medication. She would tell me that she had only just recently went to her family doctor to discuss her symptoms and that the doctor recommended that she speak with someone to lift the root of her troubles and to explore the possibility of her having a disorder.She would tell me that is why she came to see me. What was life like before you felt the symptoms that you have described to me? Marla would respond with how she was ever so very happy, always smiling. She would tell me how she lived a worry-free life and was very social. She would discuss how she had many friends and how she enjoyed her work. She would describe herself prior to the symptoms as someone who was very optimistic and upbeat. She would thusly go on to say that she only just realized that it had been quite a while since she had gone out and dined with any of her friends.Have you suffered any type of trauma? This can include anything from your past that caused you great pain or suffering mentally or physically. This could be an accident, death of someone close to you or abuse. Marla would bring up her childhood again and remind me that it was abuse free. She would also let me know that she had never been in a car accident, aside from a fender bender which really caused no damage to herself or her vehicle for that matter. She would tell me that she had been a victim of an earthquake years ago but that it didnt seem to affect her anymore.She said that she was a bit shaken after the earthquake but that she had moved passed it almost effortlessly and that she hadnt even really thought about the incident in some time. I would like to go back to something that you mentioned earlier. You said that you hadnt gone out in a while, are their certain situations that you try and avoid because of your anxiety? Marla would explain that she didnt like going to work. That she was missing several days because she felt uncomfortable in her office.She would explain that the more that she called in the less motivated she got to go and that it was really causing a problem for her at the workplace. She would tell me that she was afraid if something didnt give, she would be fired. She would tell me how she wanted to leave while working because she felt claustrophobic, as though she needed to get some air or go short her head . You mentioned that you have been having trouble sleeping here lately. Can you tell me a little more about that? Do you know of anything that may have widen to the trouble sleeping?Marla would tell me that she had been having trouble sleeping throughout the night. She would let me know that she didnt struggle to get to sleep she just had trouble staying asleep. She would let me know that it was really irritating her and that it was affecting her at work. She would tell me that she wasnt arriving late to work but that she didnt feel that she had gotten enough rest when she got to work and that she felt very tired during the work day. Do you often have dreams that recur often or do you have nightmares often?Also, how often do you wake and remember your dreams and what do you remember about them? Marla would likely tell me that she didnt dream often, nor did she have nightmares. She might say that perhaps she doesnt remember the dreams once she has awakened. However, Marla would shar e with me that she often felt very shaken and jumpy after having waken up. Had this taken place, I may suggest that she keep a journal by her bed so that she can record anything that she remembers about her dreams and how she is feeling upon waking up.Have you ever experienced flashbacks? This is when something seems very real and the images are very clear. Perhaps you have experienced feelings similar to the feeling that you felt during the earthquake that we discussed earlier? Marla would tell me that she really struggled with flashbacks following the earthquake, but that she hadnt had any experiences with them from some time. She would tell me that it had been a few years since she had experienced them. Following the interview, I would likely diagnose Marla with Post Traumatic Stress Disorder (PTSD).I would explain to her that it is a incapacitating anxiety disorder that is experienced by people who suffer traumatic events. I will explain that these events can be related to warfa re, rape, abuse, car accidents, or in her case, an earthquake. I would explain that the traumatic event can produce many characteristic symptoms which she has described to me, such as flashbacks, inability to concentrate, insomnia, and changes in emotions. Finally, I would explain the origin of the disorder by using the cognitive model of psychology. According to this model, one must understand human race thought to understand its behavior.When people show abnormal behaviors many theorists look at cognitive problems. These problems can include illogical thinking processes and maladaptive assumptions. I would then try and help her to realize what she is doing and how she is responding to the trauma of the earthquake so that she can later focus on changing her faulty ideas and thinking processes for a form of treatment. This treatment would be achieved through a series of therapies in which I teach her to calm herself and control her emotions and behaviors (Comer, 2005).

Titles

Do magazines marketed for teenagers send the wrong message? Using at least three specific magazines for support, argue for or against the moral and honourable messages that dominate magazines directed for the teen demographic. Is it freedom of the press or harassment? Argue whether the paparazzi helps or hinders the purpose of the free press. Are grades important? Discuss whether grades argon necessary in order to keep students on track with use uping. Is homework necessary? Hazing is a problem on university campuses America could start using form round school People should have green burialNon-essential plastic surgery should be illegal for children under 18 Parents should be informed if their child is inclined birth control It has been said that Americas biggest export is pop culture. Is Hollywood a good ambassador for America? Should public schools provide more classes and internship programs for students who choose non to go to college? Are college entrance exams like the SA T or ACT good indicators of university success? Would a voucher system that allowed for more school plectron be a positive change for the Ameri squirt education system? Should parents be allowed to sumbit their teens to drug testing?Would single-sex public schools be more effective than college girl? Doctor-assisted suicide should (or should not) be legal. Every automobile driver should (or should not) be allowed to send their junk mail. Every automobile driver should (or should not) be indispensable to take a new drivers test every three years. Electroshock treatment is (or is not) a humane for of therapy. Every student should (or should not) be required to learn a foreign language. Solar power is (or is not) a viable alternate energy source. Drug addicts should (or should not) be put in hospitals for medical treatment alternatively of in prison for punishment.American workers should (or should not) be guaranteed a three-day weekend by law. All health professionals should (or sho uld not) be tested annually for HIV infections and AIDS. Self-proclaimed militia should (or should not) be about monitored by the Federal Bureau of Investigation. Assault weapons should (or should not) be out-lawed. All owners of firearms should (or should not) be required to register their weapons with the police. A two-week waiting period should (or should not) be required for anyone attempting to bargain for a firearm. The finish penalty for murderers should (or should not) be abolished.The death penalty should (or should not) be imposed on juveniles. Drug dealers convinced of distributing large quantities of drugs should (or should not receive the death penalty. The U. S. military should (or should not) be used to curb drug smuggling in the U. S. The U. S. should (or should not) cut off all foreign aid to dictatorships. Smoking should (or should not) be censor in public areas such as restaurants and airport terminals. State and local governments should (or should not) operat e lotteries and gambling casinos. The U. S. should (or should not) remain in the United Nations.Immigrations into the U. S. should (or should not) be restricted. Churches should (or should not) be required to pay assesses. Federal funding for the arts should (or should not) be provided. The present-day tax system is (or is not) unfair to middle-class and lower-income Americans. College athletes should (or should not) be required to meet the academic requirements of their schools. finish up education should (or should not) be required course in all schools as early as sixth grade. Everyone should (or should not) be required to pass a faculty exam before being allowed to graduate from high schools.Chronic moral patients should (or should not) be housed in halfway houses or residences in the community, rather than in remote mental hospitals. The President should (or should not) be limited to a single six-year term. Billboards should (or should not) be outlawed on interstate highway s. Business should (or should not) be permitted to make unsolicited telephone calls to citizens. IQ tests are (or are not) valid measures of human intelligence. Psychologists and psychiatrists should (or should not) testify in court on behalf of the not-guilty-by-reason-of-insanity plea.Regardless of income, all Americans should (or should not) be guaranteed basic medical care under a national health insurance program. Heredity is (or is not) a more powerful influence on personality development than environment. ESP is (or is not) a demonstrable scientific fact. Scientific experimentation on animals should (or should not) be outlawed. Heroin should (or should not) be legal as a pain reliever for terminally ill patients. Acupuncture is (or is not a valid medical technique. Beauty pageants do (or do not) debase women. The minimum wage should (or should not) be waived for adolescent and young adult workers.Despite their legal tax deductions and loopholes, all millionaires should (or sh ould not) be required to pay federal income tax. Police should (or should not) be allowed to set up roadblocks to isolate and arrest impaired drivers. Athletes should (or should not) be allowed to use steroids. Students need to be more vigilant and observant to avoid becoming victims of campus crime. Citizens should resist efforts being made to shut down zoos and aquariums. Steps must be interpreted to reduce contaminants in the nations water supplies. Children and teenagers need to be educated on the dangers of huffing (sniffing solvents and aerosols).Lawmakers need to pass tougher legislation to discourage the suppuration number of stalkers. Every person should stipulate that in the event of death, he or she is willing to donate organs. People of all races and ethnic groups should be conscious that overexposure to the sun can cause skin cancer, regardless of a persons skin color. Dog and cat owners should have their pets spayed and neutered. Citizens with cellular phones can he lp thwart crimes and assist in the capture of criminals. People wanting cosmetic surgery should investigate the risks before submitting to surgery.

Fool Chapter 3

THREEOUR DARKER PURPOSE15Well this is a d owny lot of goose turn out if Ive ever shew it, said I. I sat on the bastards back, cross-legged, reading the letter hed written to his father. And my lord must understand how unjust it is that I, the issue of consecutive passion, is shorn of respect and position while deference is given my half(a) pal, who is the product of a bed made of handicraft and drudgery.Its true, said the bastard. Am I not as true of shape, as sharp of mind, a Youre a whiny little wanker,16 is what you are, said I, my brashness perhaps spurred by the weight of Drool, who was session on the bastards legs. What did you think you would possibly gain by giving this letter to your father?That he might relent and give me half my brothers title and inheritance.Because your capture was a better b forth than Edgars? Youre a bastard and an idiot.You could not know, little man.It was tempting indeed, to clout the knave across the head with Jones, or better, slit his t hroat with his own sword, moreover as much as the king might favor me, he favors the order of his power more. The murder of Gloucesters son, no matter how deserved, would not go unpunished. alone I was fast on my way to fools funeral anyway if I let the bastard up in the lead his anger cooled. Id sent Shanker Mary away in hope that any wrath that fell might pass her by. I needed a threat to stay Edmunds consecrate, but I had none. I am the least powerful of all almost the court. My except influence is raising others ire.I do know what it is to be deprived by the separatrix of birth, Edmund.We are not the same. You are as common as field dirt. I am not.I could not know then, Edmund, what it is to flip my title exuviate as an insult? If I call you bastard, and you call me fool, privy we answer as men?No riddles, fool. I cant sense of smell my feet.Why would you want to feel your feet? Is that more of the debauchery of the ruling class I hear so much about? So blessed are y ou with access to the fleshs pleasures that you have to word ingenious perversions to get your withered, inbred plumbing to come to attention need to feel your feet and whip the stable boy with a dead rabbit to cipher your scurvy, libidinous itch, is it?What are you on about, fool? I cant feel my feet because theres a great oaf sitting on my legs.Oh. Quite right, sorry. Drool, lift off a bit, but dont let him up. I climbed from the bastards back and walked to the laundry doorway where he could call for me. What you want is property and title. Do you imagine that you will get it by begging?The letters not begging.You want your brothers fortune. How much better would a letter from him convince your father of your worth?He would never write such a letter, and besides, he does not play for favor, it is his already.Then perhaps the problem is moving favor from Edgar to you. The right letter from him would do it. A letter wherein he confesses his fidgetiness with waiting for his inh eritance, and asks for your help in usurping your father.Youre mad, fool. Edgar would never write such a letter.I didnt say he would. Do you have anything written in his hand?I do, a letter of credit he was to grant to a wool merchant in Barking Upminster.Do you, sweet bastard, know what a scriptorium is?Aye, its a place in the monastery where they copy documents bibles and such.And so my accident of birth is the remedy of yours, for because I hadnt even one parent to lay claim to me, I was brought up in a nunnery that had just such a scriptorium, where, yes, they taught a boy to copy documents, but for our Cimmerianer purpose, they taught him to copy it in exactly the hand that he parent on the page, and the one before that, and the one before that. Letter to letter, stroke for stroke, the same hand as a man long gone to the grave.So you are a skilled forger? If you were raised in a nunnery how is it you are a fool and not a monk or a priest?How is it that you, the son of an ea rl, must plead mercy from under the arse of an enormous nitwit? Were all Fates bastards. Shall we compose a letter, Edmund?Im sure I would have become a monk, but for the anchoress. The closest to court I would have come would have been praying for the forgiveness of some nobles war crimes. Was I not reared for the unworldly life from the moment Mother basil found me squirming on the steps of the abbey at Dog Snogging17 on the Ouze?I never knew my parents, but Mother basil told me once that she thought my mother might have been a madwoman from the local village who had drowned in the river Ouze shortly after I appeared on the doorstep. If that were so, the abbess told me, then my mother had been touched by God ( deal the Natural) and so I was given to the abbey as Gods special child.The nuns, most of whom were of noble birth, second and third daughters who could not baffle a noble husband, doted on me like a new puppy. So tiny was I that the abbess would carry me with her in her apron release, and thus I was given the name of shift. Little Pocket of Dog Snogging Abbey. I was much the novelty, the only(prenominal) male in that all-female world, and the nuns competed to see who might carry me in their apron pocket, although I do not remember it. Later, after I learned to walk, they would stand me on the table at meal metre and have me parade up and down waving my winky at them, a unique appendage in those feminine environs. I was seven before I realized that you could eat breakfast with your pants on. Still, I always felt separate from the rest of them, a different creature, isolated.I was allowed to sleep on the floor in the abbesss chambers, as she had a woven rug given her by the bishop. On cold nights I was permitted to sleep under her covers to keep her feet warm, unless one of the other nuns had joined her for that purpose.Mother Basil and I were constant companions, even after I grew out of her marsupial affection. I attended the masses and prayers with her every day from as long as I could remember. How I loved watching her shave every morning after sunup, stropping her razor on a leather strap and carefully moolah the blue-black whiskers from her reflection. She would show me how to shave the little spot under your nose, and how she pulled aside the skin on her neck, so as not to nick her Adams apple. But she was a stern mistress, and I had to pray every three hours like all the other nuns, as well as carry water for her bath, meat cleaver wood, scrub floors, work in the garden, as well as gravel lessons in maths, catechism, Latin and Greek, and calligraphy. By the time I was nine I could read and write three languages and recite The Lives of the Saints from memory. I lived to serve God and the nuns of Dog Snogging, hoping that one day I might be ordained as a priest myself.And I might have, but then one day workmen came to the abbey, stonecutters and masons, and in a matter of days they had built a cell off of one of t he abandoned passages in the rectory. We were going to have our very own anchorite, or in our case, anchoress. An acolyte so devoted to God that she would be walled up in a cell with only a small beginning through with(predicate) which she would be passed food and water, and there she would spend the rest of her life, literally part of the church, praying and dispensing knowledge to the people of the village through her window until she was taken into the bosom of the Lord. Next to universe martyred, it was the most holy act of devotion a person could perform. mundane I crept out of Mother Basils quarters to check on the progress of the cell, hoping to somehow bask in the glory that would be bestowed upon the anchoress. But as the walls rose, I saw there was no window left to the outside, no place for the villagers to receive blessings, as was the custom.Our anchoress will be very special, Mother Basil explained in her steady baritone voice. So devout is she that she will only l ay eyes on those who bring her food. She will not be distracted from her prayers for the kings salvation.She is the rout out of the king?No other, said Mother Basil. The rest of us were terminus ad quem by payment to pray for the forgiveness of the Earl of Sussex, who had slaughtered thousands of innocents in the last war with the Belgians and was bound to toast on the coals of Hell unless we could fulfill his penance, which had been pronounced by the Pope himself to be seven million Hail Marys per peasant. (Even with a dispensation and a half-price voucher purchased at Lourdes, the earl was getting no more than a thousand Hail Marys to the penny, so Dog Snogging was becoming a very rich monastery on his sins.) But our anchoress would answer for the sins of the king himself. He was said to have perpetrated some jolly-good wickedness, so her prayers must be very potent indeed.Please, Mother, please let me take food to the anchoress.No one is to see or speak to her.But someone has t o take her food. Let me do it. I promise not to look.I shall consult the Lord.I never saw the anchoress arrive. The rumor simply passed that she was in the abbey and the workmen had set the stones somewhat her. Weeks went by with me begging the abbess to allow me the holy duty of feeding the anchoress, but it was not until one evening when Mother Basil needed to spend the night alone with young sister Mandy, praying in underground for the forgiveness of what the abbess called a Smashing Horny Weekender, that I was allowed to attend to the anchoress.In fact, said the Reverend Mother, you stay there, outside her cell until morning, and see if you can learn some piety. Dont come back until morning. Late morning. And bring tea and a couple of scones with you when you come back. And some jam.I thought I would burst, I was so excited when I first made my way down that long, dark hallway carrying a coat of cheese and bread, and a flagon of ale. I half expected to see the glory of God s hining through the window, but when I got there, it wasnt a window at all, but an arrow loop, like in a castle wall, cut in the shape of a cross, the edges tapered so that the broad stone came to a point at the opening. It was as if the masons only knew one window they could put in a thick wall. (Funny that arrow loops and sword hilts, mechanisms of death, form the sign of the cross a symbol of mercy but on second thought, I guess it was a mechanism of death in itself.) The opening was barely wide enough to pass the flagon through the plate would just fit through at the cross. I waited. No light came from inside the cell. A single candle on the wall across from the opening was the only illumination. I was terrified. I listened, to see if I could hear the anchoress reciting novenas. There wasnt even the sound of breathing. Was she sleeping? What kind of sin was it to interrupt the prayers of someone so holy? I put the plate and ale on the floor and tried to peer into the darkness o f the cell, perhaps see her glow.Then I saw it. The obscure sparkle of the candle reflecting in an eye. She was sitting there, not two feet from the opening. I jumped back against the far wall, knocking over the ale on the way.Did I frighten you? came a womans voice.No. No, I was just, I am forgive me. I am awed by your piety.Then she laughed. It was sad laughter, as if it had been held a long time and then let out in almost a sob, but she was laughing and I was confused.Im sorry, mistress No, no, no, dont be sorry. Dont you dare be sorry, boy.Im not. I wont be.What is your name?Pocket, mum.Pocket, she repeated, and she laughed some more. Youve spilled my ale, Pocket.Aye, mum. Shall I fetch you some more?If you dont want the glory of my bloody godliness burning us both down, you better had, hadnt you, friend Pocket? And when you come back, I want you to tell me a story that will make me laugh.Yes, mum,And that was the day that my world changed.Remind me, why is it were not just m urdering my brother? asked Edmund. From whimpering scribblings to conspiracy to murder in the course of an hour, Edmund was a quick study when it came to villainy.I sat, quill in hand, at the table in my small flat above the great gatehouse in the outer wall of the castle. I have my own fireplace, a table, two stools, a bed, a cupboard for my things, a bunco for my coxcomb and clothes, and in the middle of my room a large cauldron for heating and pouring boiling oil upon a siege force through gutters in the floor. But for the clanking of the massive chains when the drawbridge is raised or lowered, it is a cozy den in which to pursue slumber or other horizontal sport. Best of all, it is private, with a thumping big bolt on the door. Even among the nobles, privacy is rare, as conspiracy thrives there.While that is an attractive course, unless Edgar is disgraced, disinherited, and his properties willfully given to you, the lands and title could pass to some countenance cousin, or wo rse, your father might set about trying to sire a new legitimate heir.I shuddered a bit then along with, Im sure, a dozen maidens about the kingdom at the mental vision of Gloucesters withered flanks, bared and about the business of making an heir upon their nubile nobility. They would be clawing at the nunnery door to escape the honor.I hadnt thought of that, said Edmund.Really, you, not think? How shocking. Although a unsophisticated poisoning does seem cleaner, the letter is the sharper sword. If I gave the scoundrel proper rope, perhaps he could hang for both our purposes. I can craft such a letter, subtle, yet condemning. Youll be the Earl of Gloucester before you can get dirt shoveled on your fathers still twitching body. But the letter may not do all.Speak your mind, fool. As much as Id love to silence your yammering, speak.The king favors your father and your brother, which is why they were called here. If Edgar becomes betrothed to Cordelia, which could happen before the morrow well, with the princesss dowry in hand, therell be no cause for him to resort to the treachery we are about to craft around him. Youll be left with your fangs showing, noble Edmund, and the legitimate son will be all the richer.Ill see he is not betrothed to Cordelia.How? Will you tell him horrid things? I have it on good authority that her feet are like ferryboats. They strap them up under her gown to keep them from flapping when she walks.I will see to it that there is no marriage, little man, dont you worry. But you must see to this letter. Tomorrow Edgar goes on to Barking to deliver the letters of credit and Ill return to Gloucester with my father. Ill let the letter slip to him then, so his anger has time to fester in Edgars absence.Quick, before I waste parchment, promise youll not let Edgar marry Cordelia.Fine, fool, promise youll not tell anyone that you ever penned this letter, and I will.I promise, said I. By the balls of Venus.Then, so do I, said the bastard.All right, then, said I, dipping my quill in ink, although murder would be a simpler plan. Ive never cared for the bastards brother Edgar, either. Earnest and open-faced is he. I dont trust anyone who appears so trustworthy. They must be up to something. Of course, Edmund hanging black-tongued for his brothers murder would make for a festive chandelier as well. A fool does enjoy a party.In a half-hour I had crafted a letter so wily and peppered with treachery that any father might strangle his son at the eyeshot of it and, if childless, bastinade his own bollocks with a war hammer to discourage conspirators yet to be born. It was a masterpiece of both forgery and manipulation. I blotted it well and held it up for Edmund to see.Ill need your dagger, sir, said I.Edmund reached for the letter and I danced away from him. First the knife, good bastard.Edmund laughed. Take my dagger, fool. Youre no safer, I still have my sword.Aye, which I handed you myself. I need your dagger to razor the seal off that letter of credit so I may affix it to this missive of ours. Youll need to break it only in your fathers presence, as if you yourself are only then discovering your brothers black nature.Oh, said Edmund.He gave me the knife. I performed the deed with sealing wax and candle and handed the stain back with the letter. (Could I have used one of my own knives for the task? Of course, but it was not time for Edmund to know of them.)The letter was barely in his pocket before Edmund had drawn his sword and had it leveled at my throat. I think I can assure your silence better than a promise.I didnt move. So, you lament being born out of favor, what favor will you court by killing the kings fool? A dozen guards saw you come in here.Ill take my chances. unspoiled then the great chains that ran through my room began to shake, rattling as if a hundred suffering prisoners were shackled to them rather than a slab of oak and iron. Edmund looked around and I scampered to the far side o f the room. Wind rushed through the arrow loops that served as my windows and extinguished the candle I had used for the sealing wax. The bastard spun to face the arrow loops and the room went dark, as if a cape had been thrown over the day. The golden form of a woman shimmered in the air at the dark wall. The ghost said,A thousand years of torture rule, The knave who dares to harm a fool.I could only see Edmund by the glow of the spirit, but he was moving crablike toward the door that led out onto the west wall, reaching frantically for the latch. Then he threw the bolt and was through the door in an instant. Light modify my little apartment and I could again view the Thames through the slits in the stone.Well rhymed, wisp, said I to the empty air. Well rhymed.

The revelatory dilemma presented in the play also revolves around the economic situations Nora

The theme of feminism as it relates to A Dolls House clienteles mainly Norasreactions to the alternate drives of so called domestic tranquility and the formulation of an potent identity that works outside of the domestic sphere.The revelatory dilemma presented in the play also revolves around the economic situations Nora finds herself in, linking, as many plays of the era did, concern with money to moral action, depicting Krogstad as an immoral character and linking his moral action to Nora, as others including her father do, through the use of money. Nora, Nora Just like a womanBut seriously, Nora, you know what I think about that sort of thing. No debts, no acquire. Theres something constrained, something ugly even, about a home thats founded on borrowing and debt (Ibsen 149). Mainly, from a feminist perspective, the revelatory dimensions of Noras decisions inform most of the work, in terms of her gradual shift away from the stifling domestic sphere towards a greater liberty th at is formed by an establishment of greater degrees of knowledge. As she has more revelations as a character, Nora grows to a new awareness of what was previously hidden, and manages to border these changes into perspective.Although it seems at times that she is overwhelmed, Nora is generally able to get over her knowledge and use the concealed information to some future advantage of her own. Noras form of discovery is based on her early life partly, when she was alternately dependent on her father and then her husband. She was sheltered by this transition and does not harbor a very good idea about the real world, but she also is cunning enough to negotiate for her independence, and the discovery of secrets along the way drives her towards this independence as a goal.Ibsen, H. A Dolls House. New York Penguin 1994.

High School Life Essay

Ask any striplingager today and they will tell you that they are nothing like their parents, that their parents respectable dont understand them. This may be true and this may be false, it and depends on how you look at it. Teenagers of the Rebel Without a Cause, meaning the parents of todays teens, did face a lot of the same problems and issues that we now face. Yet I am left thinking did the past teens face every(prenominal) the same problems at the same cadence as we do and were approximately of their problems not as much of a problem as it is to us.Teens from the past and present are face with problems such as domesticate, relationships, and friends. There were many teenage problems back indeed in Rebel Without a Cause and todays teenagers. Most of these problems that Jim Stark and the other teens faced were comparable, but my own belief is that these same problems were not as big of problem back when they were growing up. Lets take school and formulation for example, oh sure your parents had it too but I just dont believe that there was as much pressure upon them to gain severe grades. Also, get into a good college as there is for us.And of course with the knowledge that college is right around the corner most teens also need to work. They need to save currency for college, or a car, or to make the girl/boy of their dreams happy by taking them out on dates once in a while. Plus, all this pressure and work can build up for a teen and to most of us it seems like we never fuck off a chance to just relax and hang out with friends anymore. It relates to the movie because some of the teens do not care just about homework or going to school. The rea watchword is that was back wherefore it was easy to get a job by only having a high school diploma with no college education.But, now in our teen lives it is touchy to get a job with a high school diploma. Another thing that is different from the past from the present is the fashion that students we ar. In the past, boys wear free regular clothes and the cool guys always wear black jackets or blazers. It is similar like what a gang member usually wears right now. turf out the gangs have their baggy pants or shorts and show their underdrawers in black or white. It is weird how those kind of guys like to show-off their boxers or underwear. For the girls in the past, they all mostly put on dresses. Now girls mostly wear skirts or short shorts.Plus, girls always try to put on the sexiest clothes to wear because to get all the attention and be popular. Like in the movie, Jim Stark wears different clothes from his classmates. The reason is that he moved to a lot of different high schools because he never made any friends and doesnt fit in with the other teens. Also, in every high school he went to the teens called Jim, Chicken. Why he is called that because the teenagers see him acting like a chicken, when Jim does not extremity to get into trouble. I think back whence music for teens like, Rebel Without a Cause, probably listened to shake and roll.But now teens prefer rapping and hip hop music. Its interesting how music has changed so much in the past because teens loved to get crazy on rock and roll. I wonder how teens will react if music never came to rock and roll. Probably teens will make their own music or have to try out their parents music, which were more hip hop and dance music. Now teens today have a mix of genres they like to listen. Most teens in the present relate their music to their emotions. The reason is because they must have some problems in their lives and music helps teens release stress.Plus, I am sure that it happens to the teens in the past except not big problems compare to our teen years. I run Jim Stark and his classmates love to listen to rock and roll. Even though it does not show in the movie that they played rock and roll, but back then there was a lot of rock and roll. The teens in the early years prefer rock and roll be cause it was something they can be themselves with their friends. Sometimes parents cannot stand their teens music and tells them to turn it off or take it away from them. It is weird how in the movie, it shows parents like Jims parents how they do not care about his school issues.For instance, when Jims classmates call him chicken, he tells them to stop and be angry to his parents. Then Jims parents decide to move somewhere else again, which happen several times. Jim does not extremity that because he thinks it is going to happen all over again. So, basically Jims parents do not really help him and his life that much. But canvass to todays teens, Jims parents and other parents show more concern for each of their son/daughters education to make them successful in life. I can see that every year new parents learn from their past seeing their mom and dad on how they take care of their son or daughter.Then later on the new parents learn from their parents mistakes and become a better parent. There are things that are similar between our time and the movie, Rebel Without a Cause. One is that teens hate doing homework and waking up early for school. Teens in the past and present contest with their emotions like in relationships or family issues. Jim shows his emotions to his parents in the movie. He tells them how he feels every time when he transfers to a new school and he is not good at making any relationships or friends.The main reason is everyone calls him chicken because he is different from his classmates and they think he is afraid of them. I just want to say that I am not saying that teenagers of the past did not have their own problems, but of course they did, every single teen existent faces problems that they think is hard and that their whole world is crumbling down around them well at least once in a while. But now that they have grown up and turned into the parents of todays teenagers I feel that they put more pressure upon their own teenage chil d in devote for them to achieve more than they were able to.A common expression is, My parents are so strict, overprotective, or too involved in my life, because they dont want me making the same mistakes they did when they were my age but they need to trust me and just leave me alone. And that expression can sometimes is kind of true. But all in all I feel that our parents do understand what we, as teenagers, are going through because they did face the same problems that we face today, but maybe with just a little less pressure.

Diary of Lady Murasaki Response Questions

Diary of madam Murasaki Response Questions 1. Drawing evidence from the text, describe Lady Murasaki. Who is she? What is all burning(prenominal)(p) to her? How important is she politically? why do you think she keeps her diary? What atomic number 18 her frustrations with life at court? How typical/atypical is she as a woman in Heian Japan? Lady Murasaki was a Japanese poet at the Imperial court and served under Empress Shoshi. She writes this diary during her experiences at court and she finds the life of a lady-in-waiting, or a servant that has loving certainty, and the events that be unfolded in court are important.She describes in her diary how she feels helpless at court and she is unhappy with her low rank in society compared to others in the Fujiwara clan which frustrates her, but makes her more inclined to write about it and keep a diary. She is a pretty typical woman in Heian Japan, but she a good deal writes about how the other court women were less educated than her and that she was stronger-willed. 2. What does the text reveal about the political world of Heian Japan? What is the role of the emperor? What is the role of the regent(postnominal)? Which is more important?How do people gain and maintain political power? What happens to those who lose political power? During the Heian period of Japan the land was controlled by family clans and whoever was the most powerful family held the most importance. Within the family there is also ranks of political power branching down from the Emperor and Empress, but most of the other ranks are all related to each other through the family clan. The Emperor is the head of the family clan is said to be in that position by a celestial right, while a regent is more of a governor addressing political issues.Both are important, but while the Emperor is the symbol of the people and their unity, the regent sparingly makes the differences in how the people get to live. 3. What does the text reveal about the role s of men in Heian Japan? How are they set? What is their role in the family, in politics, in religion, in military? How much power and what type of power do men have? What do you find surprising about what is considered important/unimportant for men during Heian Japan? Why? Men controlled the majority of society as like any culture during this time period.The military was solely live by men as was the political power, but women were allowed to be present in court and other loving events. They had a good education and if they were in a political position they learned Chinese because it was used for legal documents and record keeping. 4. What does the text reveal about the roles of women in Heian Japan? How are they identified? What is their role in the family, in politics, in religion? How much and what type of power do women have? What do you find surprising about what is considered important/unimportant for women during Heian Japan? Why?Women during this time were surprisingly b etter off than in other centuries. They were excluded from public affairs, but involved in court as we can make up ones mind in the diary. They were also educated and involved with events around the castle such as ceremonies, weddings, and poetry reciting. Women had to know how to dress correctly, but in one case they did they were expected to learn to dress very formally and elegantly. 5. What does the text reveal about kind classes and social mores in Heian Japan? What are the differences between the social classes? How does social class affect the way people live and the political power they wield?What are the social expectations for men and women? What is good behavior/what is unsuitable behavior? Does any of this surprise you? Most of Japans social class was in agriculture and lived outside the city walls and never entered the palace. Within the palace there are a separate set of social classes. The Emperor and Empress will always sit at the top of the ladder, but amongst e veryone else there are strict guidelines to follow. Passages in the diary describe the uses of colors in clothing and how some colors shouldnt be worn by certain social classes. The diary also accounts hat giving presents alter throughout social class. Nobles get the best gift and then the different ranks of courtiers, first rank organism the highest and sixth rank one of the lowest. What does the text reveal about religion in Heian Japan? What is the role of religion? What type of religion do you see represented? What are the religious concerns of Lady Murasaki? What do her religious concerns reveal about life in Heian Japan? The religion of Shintoism can be seen with the heavenly right for the Emperor to rule over the people within his family clan name and to protect the imperial family.During the birth of Fujiwara no Michinaga, towards the beginning, Murasaki writes about the Buddhist priests culmination and performing exorcisms and warding off evil. Lady Murasaki later writes that she immerses herself in reading sutras for Amida Buddha, which shows what kind of religious practices she participates in. All of these religions being present throughout the diary tells that religion is at a point of uncertainty in Heian Japan and there are many influences that come with them.

Contract Law

Introduction In directlys sparing climate businesses often exert technical imperativeness during melt off talks stages. This is a conventionalism part of the process and parties to a crusade generall(a)y know when hug being exerted is fairnessful. Although thither is a difference in the midst of commercial negotiation and illicit pressure, it is often thorny to distinguish between the two. pushmore, because frugalalal imprisonment john a elevate from pressure that is non in itself unlawful, parties may be unconscious(predicate) that the pressure they be subjecting a fellowship to a attempt is materially economic manacles. Despite this, if a court finds that whizz party to a pin down has exerted illegitimate pressure on an early(a) party, the innocent(p) party may be competent to establish a charter of economic duress. Given how equivocal the economy is at present, hard negociate is a common form of negotiation, though it is vital that businesses are aw are of the risks when exerting pressure that is likely to be deemed illegitimate. It is ill- be how this distinction go off be make, nonetheless, which suggests that further lucidity is necessary inwardly this area. This study intends to explain the developments that turn out taken place in the ism of economic duress and why the courts perceived a desire for a more robust approach in light of the Williams v Roffey Brothers and Nicholls (Contractors) Ltd 1991 1 QB 1 fount. gyves bonds is a common law defensive measure that allows a withdraw to be set aside in instances where one party has been subjected to force or pressure from the other party to enter into the conjure. Duress has been defined as making someone do something against his leave, or making someone bring about an misbranded act, by using threats, coercion or other illicit means (Dictionary, 2014 1). Duress is basically the use of unlawful means to force another to perform an act by either threatening them or performing an act of violence. The party claiming duress volition be required to show that they did not discombobulate a choice but to enter into the decoct (Cserne, 2009 57). frugal duress, on the other hand, is a fairly new phenomenon that is becoming an important tool for find out whether a shorten that has been entered into is enforceable or not. economical duress happens when a souls economic interests are damaged from being forced or coerced into enter into a contract. This type of duress has been defined as the unlawful use of economic pressure and/or threats intended to overcome the free depict of a person, in edict to force him or her to an involuntary agreement or to do something that he or she would not otherwise do (Business Dictionary, 2014, 1). frugal duress is essentially a contract law defence that allows a person to dispute the formation of a binding contract by parameter that that they were forced to enter into the contract. Previously, parties to a contract could only(prenominal) rely on the doctrine of love for protection when they were being subjected to economic duress. Consideration is the price that one party willing pay for another partys covenant (Card et al 2003 63) Collins v Godefroy (1831) 1 B&Ad 950. The doctrine of rumination does not allow parties in a contract to insist on further payments to perform tasks they are already required to perform under the contract simply because they are in a stronger bargaining position Stilk v Myrick (1809) 2 Camp 317.Economic Duress and Commercial advertiseureIt is now widely accepted by the courts that undue commercial pressure give the gate gist to duress. The doctrine of economic duress has evolved signifi stoptly from various trade union terminations including cosmos Tank enraptures v International Workers Federation (The Universe observation post) 1983 1 AC 366 and Dimskal Shipping v International Works Federation (The Evia Luck) 1992 2 AC 152. In The Universe S entinel, a trade union, which had b droplisted a send, forced the owner to provide payment before they would remove the ship from the black list. As in that respect would have been disastrous consequences if the ship could not sail, the owner made the payment. Because the ship owner had no other concrete choice but to make the payment, he later brought a successful claim for the recovery of the money by establishing economic duress. Similarly, in The Evia Luck a trade union insisted that a ship owner signed various contractual documents so that his ship could sail, which was found by the court to be a form of economic duress. In order to make an economic duress claim, there are a number of elements the claimant will need to be established. These are a) that the pressure was illegitimate b) that the pressure was a signifi undersidet cause that induced the claimant to enter into the contract and c) that the applicative effect of the pressures means that the claimant has no other choice but to enter into the contract (Ohrenstein, 2013 2). The claimant will be entitled to avoid the contract and claim restitution of any monies that have been paid under it if these elements can be established. In deciding what amount to illegitimate pressure, the court will take a range of factors into cipher.For example, in DSND Subsea Ltd v oil colour Geo Services ASA 2000 EWHC 185 it was made glide by that the court will be required to consider whether the breach of contract was an actual or threatened breach whether the person whom exerts the pressure has acted in good or bad assurance whether the claimant had any real or practical preference but to give in to the pressure whether the claimant fended at the time and whether the claimant sought to rely on the contract. unmatchable of the most successful forms of economic duress is a threat to breach a contract. In Siboen and The Sibotre 1976 1 Lloyds rep 293 charterers of two ships threatened to see to it their cha rterparties by refusing to pay the agreed charter straddle if the rate was not lowered. The owners of the ships had been informed that the charterers had no substantial assets and that the charterers would otherwise go into liquidation if the charter grade were not lowered. This information was not actually admittedly but it caused the owners to reduce the rates neertheless. It was found that economic duress could apply to this situation as all of the relevant factors were present. Since this decision, the courts seem to have accepted that economic duress is coercive and then worthy of the same relief as duress to the person or property (Chen-Wishart, 2012 316).In spite of this, the practical diligence of economic duress has been subject to ofttimes confusion and it has been questioned when, if ever, renegotiations should be enforced. It would seem, under the doctrine of consideration, that renegotiations can never be enforced on the basis that no additional consideration sup ports the promise to pay more or accept less (Chen-Wishart, 2012 316). Under the promissory estoppel doctrine, the promise to pay the same for less can be enforced in limited circumstances, though this does not apply if illegitimate pressure has been exerted. Therefore, if it can be demonstrated that illegitimate pressure has been use to the renegotiation of a contract, that contract will not be enforceable. Because commercial contracts are extremely competitive, it is likely to be the case that some form of pressure will always be applied. Though the question to be determined is whether the pressure that has been applied is legitimate or not. This is likely to be extremely troubleatic and thusly cause a great deal of complexity for the courts. As exemplified in the cases above, threats to blacklist a ship and refuse its release may constitute duress. Further examples of where economic duress has occurred can be seen in the cases of North Ocean Shipping Co Ltd v Hyundai twist Co L td 1979 QB 705 and Pao On v Lau Yiu foresighted 1979 UKPC 17 where threats to terminate a contract in the absence of a renegotiation is also illegitimate unless it can be legally justified. What will be deemed legally justified is largely a matter to be determined based upon individual facts and circumstances, though there is likely to re principal(prenominal) a lot of confliction in this area. In Williams v Roffey Brothers Ltd 1991 EWCA Civ 5 the Stilk case was severely limited by the courts. Here, the consideration requirement was extend to include practical acquires and thereby covered the promise to perform an existing contract.Here, a number of contractors promised to refurbish 27 flats with a sub-contractor performing the carpentry. Before the flats were finished, the sub-contractor make that he had under-priced the contract and was resultantly facing financial concentratedy. The main contractors offered the sub-contractor a financial inducement to finish the contract o n time. It is trite law that consideration is needed for a party to that contract to be able to sue on it. Since the sub-contractor was doing no more than he was already bound to do under the contract, consideration was lacking. Surprisingly, it was held by the court that because the contractors had received a benefit from the sub-contractor, in that they avoided the penalty clause of the main contract, the sub-contractors claim was successful. This did not mean that consideration was present as the benefit did not move from the promisee, although there was a clear departure from the orthodox principle of consideration principle. The doctrine of consideration maintains that a contract will not be supported by the act of an existing duty unless that duty exists by virtue of a third party contract (Noble, 1991 141). This decision conflicts with the decision in Stilk which demonstrated that consideration needs to be of economic value to be deemed good consideration and that it needs to move from the promise as also shown in White v Bluett (1853) 23 LJ Ex 36 Thomas v Thomas (1842) 2 QB 851 Shadwell v Shadwell (1860) 9 CBNS 159 and Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295). It has also been argued by Cheshire et al that the time has come to recognise formally the alternative definition of consideration and admit that the rationale behind the refusal to enforce some types of consideration is axenic policy (Cheshire et al 2012 77).Arguably, it appears that the consideration principle is rather outmoded and in need of repair so that a more robust approach to economic duress can be taken by the courts. At present, much confusion arises as to when economic duress can be used as a defence. Judges thus need to err on the side of caution to restrain commercial pressure being mistaken for economic duress and vice versa. Still, as stressed by the court in Adam v Opel Gmbh v Mitras automotive 2007 EWHC 3481 the list of matters to be considered in assessing legi timacy is not exhaustive, and the weight to be attached to each of them will depend on the facts of the individual case. Furthermore, it was also verbalize in the case that the decision to be made will involve some element of value judgement when considering whether the pressure that was exerted on the claimant crossed the confines from that which must be accepted in normal robust commercial bargaining. It is clear from the decision in this case that the courts have made some attempts to provide clarity in this area and that each case will be decided on its own facts. In the more recent case of Kolmar stem AG v Traxpo Enterprises Pyt Ltd 2010 EWHC 113 it was evidenced that a contract variation between a supplier and a customer will unlikely amount to duress if the supplier is unable to perform a contract as a result of financial difficulties that will cause the supplier to become insolvent. Another problem that arises when it comes to economic duress is whether lawful admit can amount to illegitimate pressure. Whilst it is possible, it is also extremely rare as shown in CTN Cash and Carry Ltd v Gallaher Ltd 1993 EWCA Civ 19 GMAC Commercial Credit Ltd v Dearden 2002 altogether ER (D) 440 (May) and Wright v HSBC Bank plc 2006 EWHC 930 QB. Consequently, economic duress will continue to pose many problems as there will always be a debate as to whether particular circumstances may or may not give rise to a claim for economic duress. Because of the uncertainty within this area, it is evident that a more robust approach needs to be taken so that great clarity and consistency can be provided. Economic duress has also been criticised for being agent-led, thereby meaning that a lack of causation will prevent a successful claim from being made. In Pao On v Lau Yiu Long 1979 UKPC 2 it was pointed out by Lord Scarman that in deciding whether causation was present, it will need to be considered whether the claimant a) protested b) had a practical alternative open to him c) received independent advice and d) acted promptly. This decision has been criticised for being inconclusive and failing to take into account the fact that claimants may not think that there is any point in protesting. This was recognised by Chen-Wishart when it was argued that these factors are inconclusive. The victim may not protest because he sees no point in it or he may not wish to antagonise the coercing party whose performance he needs (Chen-Wishart, 2012 318). It is clear that the facts and circumstances of each case will be the determining factor as to whether the claimant has suffered economic duress or not. Because of the uncertainty that exists in this area, however, it is often difficult for those entering into commercial contracts to acknowledge that they are exerting pressure that is considered illegitimate, especially when there is a possibility that lawful pressure will also be overt of amounting to economic duress. As a result of this, teenage warns agains t exerting commercial pressure that the courts may possibly consider economic duress Abusing your upper hand can leave the strong open to claims (Young, 2012 23). Conclusion Overall, whilst the doctrine of duress is well established in English law, the doctrine of economic duress still remain largely uncertain. This generally arises from the difficulty of distinguishing between legitimate and illegitimate economic duress. As such, it is up to the courts to decide when a persons economic interests have been damaged from being forced or coerced into entering into a contract. Hence, the court will be required to consider whether the re-negotiation of the terms of the contract were lawful and whether the person being subjected to the economic duress, should be entitled to blot out the contract that they entered into. This is an important defence in ensuring that parties to a contract have equal bargaining power. Nevertheless, the practical application of economic duress has been subje ct to much confusion over the years, which may result from the reasoning that has been provided by the courts. There appears to be a lack of consistency that is being provided, which highlights the need for future reform to this area. Whilst there is a difference between commercial negotiation and illegitimate pressure, it has proven extremely difficult to distinguish between the two, especially since lawful conduct can also amount to illegitimate pressure. In order to provide clarity to this area, it seems as though a more robust approach is therefore needed by the courts.ReferencesBusiness Dictionary. (2014) Economic Duress, Online Available http//www.businessdictionary.com/definition/economic-duress.html 07 July 2014.Card, R. Murdoch, J. and Murdoch, S. (2003) Estate Management virtue, OUP, 6th Edition.Carr, N. (2011) travel the Line The Balance Between Legitimate negotiation and Economic Duress, Available Online 07 July 2014.Chen-Wishart, M. (2012) Contract rightfulness, Ox ford University Press.Cserne, P. (2009) Duress in Contracts An Economic Analysis, Contract Law and Economics, Volume 6, second Edition.Furmston, M. P. Cheshire, G C. and Fifoot, C H. (2012) Cheshire, Fifoot and Furmstons Law of Contract, Oxford University Press London.Dictionary. (2014) Duress, Online, Available http//www.yourdictionary.com/duress 07 July 2014.Noble, M. (1991) For Your Consideration, New Law Journal, Volume 141, Issue 1529.Ohrenstein, D. (2013) Key Developments in Contract Law Economic Duress, Radcliffe Chambers, Online Available http//www.radcliffechambers.com/media/Misc_Articles/Key_Developments_in_Contract_Law_-_Economic_Duress_2013.pdf 07 July 2014.Young, A. (2012) When Pressure Turns to Duress, Construction Law Journal, Volume 23, Issue 5.Cases Adam v Opel Gmbh v Mitras Automotive 2007 EWHC 3481Collins v Godefroy (1831) 1 B&Ad 950CTN Cash and Carry Ltd v Gallaher Ltd 1993 EWCA Civ 19Dimskal Shipping v International Works Federation (The Evia Luck) 1992 2 AC 15 2DSND Subsea Ltd v Petroleum Geo Services ASA 2000 EWHC 185GMAC Commercial Credit Ltd v Dearden 2002 solely ER (D) 440 (May)Kolmar Group AG v Traxpo Enterprises Pyt Ltd 2010 EWHC 113North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd 1979 QB 705Pao On v Lau Yiu Long 1979 UKPC 17Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295)Shadwell v Shadwell (1860) 9 CBNS 159Siboen and The Sibotre 1976 1 Lloyds Rep 293Stilk v Myrick (1809) 2 Camp 317Thomas v Thomas (1842) 2 QB 851Universe Tankships v International Workers Federation (The Universe Sentinel) 1983 1 AC 366White v Bluett (1853) 23 LJ Ex 36Williams v Roffey Brothers and Nicholls (Contractors) Ltd 1991 1 QB 1Wright v HSBC Bank plc 2006 EWHC 930 QBContract LawIntroduction In todays economic climate businesses often exert commercial pressure during contract negotiation stages. This is a normal part of the process and parties to a contract generally know when pressure being exerted is lawful. Although there is a difference betwee n commercial negotiation and illegitimate pressure, it is often difficult to distinguish between the two. Furthermore, because economic duress can arise from pressure that is not in itself unlawful, parties may be unaware that the pressure they are subjecting a party to a contract is actually economic duress. Despite this, if a court finds that one party to a contract has exerted illegitimate pressure on another party, the innocent party may be able to establish a claim of economic duress. Given how uncertain the economy is at present, hard bargaining is a common form of negotiation, though it is vital that businesses are aware of the risks when exerting pressure that is likely to be deemed illegitimate. It is unclear how this distinction can be made, nonetheless, which suggests that further clarity is needed within this area. This study intends to explain the developments that have taken place in the doctrine of economic duress and why the courts perceived a need for a more robust approach in light of the Williams v Roffey Brothers and Nicholls (Contractors) Ltd 1991 1 QB 1 case.DuressDuress is a common law defence that allows a contract to be set aside in instances where one party has been subjected to force or pressure from the other party to enter into the contract. Duress has been defined as making someone do something against his will, or making someone perform an illegal act, by using threats, coercion or other illicit means (Dictionary, 2014 1). Duress is basically the use of unlawful means to force another to perform an act by either threatening them or performing an act of violence. The party claiming duress will be required to show that they did not have a choice but to enter into the contract (Cserne, 2009 57). Economic duress, on the other hand, is a fairly new phenomenon that is becoming an important tool for determining whether a contract that has been entered into is enforceable or not. Economic duress happens when a persons economic interests are damaged from being forced or coerced into entering into a contract. This type of duress has been defined as the unlawful use of economic pressure and/or threats intended to overcome the free will of a person, in order to force him or her to an involuntary agreement or to do something that he or she would not otherwise do (Business Dictionary, 2014, 1). Economic duress is essentially a contract law defence that allows a person to dispute the formation of a binding contract by arguing that that they were forced to enter into the contract. Previously, parties to a contract could only rely on the doctrine of consideration for protection when they were being subjected to economic duress. Consideration is the price that one party will pay for another partys promise (Card et al 2003 63) Collins v Godefroy (1831) 1 B&Ad 950. The doctrine of consideration does not allow parties in a contract to insist on further payments to perform tasks they are already required to perform under the con tract simply because they are in a stronger bargaining position Stilk v Myrick (1809) 2 Camp 317.Economic Duress and Commercial PressureIt is now widely accepted by the courts that undue commercial pressure can amount to duress. The doctrine of economic duress has evolved significantly from various trade union decisions including Universe Tankships v International Workers Federation (The Universe Sentinel) 1983 1 AC 366 and Dimskal Shipping v International Works Federation (The Evia Luck) 1992 2 AC 152. In The Universe Sentinel, a trade union, which had blacklisted a ship, forced the owner to provide payment before they would remove the ship from the black list. As there would have been disastrous consequences if the ship could not sail, the owner made the payment. Because the ship owner had no other practical choice but to make the payment, he later brought a successful claim for the recovery of the money by establishing economic duress. Similarly, in The Evia Luck a trade union in sisted that a ship owner signed various contractual documents so that his ship could sail, which was found by the court to be a form of economic duress. In order to make an economic duress claim, there are a number of elements the claimant will need to be established. These are a) that the pressure was illegitimate b) that the pressure was a significant cause that induced the claimant to enter into the contract and c) that the practical effect of the pressures means that the claimant has no other choice but to enter into the contract (Ohrenstein, 2013 2). The claimant will be entitled to avoid the contract and claim restitution of any monies that have been paid under it if these elements can be established. In deciding what amount to illegitimate pressure, the court will take a range of factors into account.For example, in DSND Subsea Ltd v Petroleum Geo Services ASA 2000 EWHC 185 it was made clear that the court will be required to consider whether the breach of contract was an act ual or threatened breach whether the person whom exerts the pressure has acted in good or bad faith whether the claimant had any real or practical alternative but to give in to the pressure whether the claimant protested at the time and whether the claimant sought to rely on the contract. One of the most successful forms of economic duress is a threat to breach a contract. In Siboen and The Sibotre 1976 1 Lloyds Rep 293 charterers of two ships threatened to break their charterparties by refusing to pay the agreed charter rate if the rate was not lowered. The owners of the ships had been informed that the charterers had no substantial assets and that the charterers would otherwise go into liquidation if the charter rates were not lowered. This information was not actually true but it caused the owners to reduce the rates nevertheless. It was found that economic duress could apply to this situation as all of the relevant factors were present. Since this decision, the courts seem to ha ve accepted that economic duress is coercive and therefore worthy of the same relief as duress to the person or property (Chen-Wishart, 2012 316).In spite of this, the practical application of economic duress has been subject to much confusion and it has been questioned when, if ever, renegotiations should be enforced. It would seem, under the doctrine of consideration, that renegotiations can never be enforced on the basis that no additional consideration supports the promise to pay more or accept less (Chen-Wishart, 2012 316). Under the promissory estoppel doctrine, the promise to pay the same for less can be enforced in limited circumstances, though this does not apply if illegitimate pressure has been exerted. Therefore, if it can be demonstrated that illegitimate pressure has been applied to the renegotiation of a contract, that contract will not be enforceable. Because commercial contracts are extremely competitive, it is likely to be the case that some form of pressure will a lways be applied. Though the question to be determined is whether the pressure that has been applied is legitimate or not. This is likely to be extremely problematic and thus cause a great deal of complexity for the courts. As exemplified in the cases above, threats to blacklist a ship and refuse its release may constitute duress. Further examples of where economic duress has occurred can be seen in the cases of North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd 1979 QB 705 and Pao On v Lau Yiu Long 1979 UKPC 17 where threats to terminate a contract in the absence of a renegotiation is also illegitimate unless it can be legally justified. What will be deemed legally justified is largely a matter to be determined based upon individual facts and circumstances, though there is likely to remain a lot of confliction in this area. In Williams v Roffey Brothers Ltd 1991 EWCA Civ 5 the Stilk case was severely limited by the courts. Here, the consideration requirement was extended to include practical benefits and thereby covered the promise to perform an existing contract.Here, a number of contractors promised to refurbish 27 flats with a sub-contractor performing the carpentry. Before the flats were finished, the sub-contractor realised that he had under-priced the contract and was resultantly facing financial difficulty. The main contractors offered the sub-contractor a financial inducement to finish the contract on time. It is trite law that consideration is needed for a party to that contract to be able to sue on it. Since the sub-contractor was doing no more than he was already bound to do under the contract, consideration was lacking. Surprisingly, it was held by the court that because the contractors had received a benefit from the sub-contractor, in that they avoided the penalty clause of the main contract, the sub-contractors claim was successful. This did not mean that consideration was present as the benefit did not move from the promisee, although there was a clear departure from the orthodox principle of consideration principle. The doctrine of consideration maintains that a contract will not be supported by the performance of an existing duty unless that duty exists by virtue of a third party contract (Noble, 1991 141). This decision conflicts with the decision in Stilk which demonstrated that consideration needs to be of economic value to be deemed good consideration and that it needs to move from the promise as also shown in White v Bluett (1853) 23 LJ Ex 36 Thomas v Thomas (1842) 2 QB 851 Shadwell v Shadwell (1860) 9 CBNS 159 and Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295). It has also been argued by Cheshire et al that the time has come to recognise formally the alternative definition of consideration and admit that the rationale behind the refusal to enforce some types of consideration is pure policy (Cheshire et al 2012 77).Arguably, it appears that the consideration principle is rather outmoded and in need of reform so that a more robust approach to economic duress can be taken by the courts. At present, much confusion arises as to when economic duress can be used as a defence. Judges thus need to err on the side of caution to prevent commercial pressure being mistaken for economic duress and vice versa. Still, as stressed by the court in Adam v Opel Gmbh v Mitras Automotive 2007 EWHC 3481 the list of matters to be considered in assessing legitimacy is not exhaustive, and the weight to be attached to each of them will depend on the facts of the individual case. Furthermore, it was also stated in the case that the decision to be made will involve some element of value judgement when considering whether the pressure that was exerted on the claimant crossed the line from that which must be accepted in normal robust commercial bargaining. It is clear from the decision in this case that the courts have made some attempts to provide clarity in this area and that each case will be decided on it s own facts. In the more recent case of Kolmar Group AG v Traxpo Enterprises Pyt Ltd 2010 EWHC 113 it was evidenced that a contract variation between a supplier and a customer will unlikely amount to duress if the supplier is unable to perform a contract as a result of financial difficulties that will cause the supplier to become insolvent. Another problem that arises when it comes to economic duress is whether lawful conduct can amount to illegitimate pressure. Whilst it is possible, it is also extremely rare as shown in CTN Cash and Carry Ltd v Gallaher Ltd 1993 EWCA Civ 19 GMAC Commercial Credit Ltd v Dearden 2002 All ER (D) 440 (May) and Wright v HSBC Bank plc 2006 EWHC 930 QB. Consequently, economic duress will continue to pose many problems as there will always be a debate as to whether particular circumstances may or may not give rise to a claim for economic duress. Because of the uncertainty within this area, it is evident that a more robust approach needs to be taken so tha t greater clarity and consistency can be provided. Economic duress has also been criticised for being causation-led, thereby meaning that a lack of causation will prevent a successful claim from being made. In Pao On v Lau Yiu Long 1979 UKPC 2 it was pointed out by Lord Scarman that in deciding whether causation was present, it will need to be considered whether the claimant a) protested b) had a practical alternative open to him c) received independent advice and d) acted promptly. This decision has been criticised for being inconclusive and failing to take into account the fact that claimants may not think that there is any point in protesting. This was recognised by Chen-Wishart when it was argued that these factors are inconclusive. The victim may not protest because he sees no point in it or he may not wish to antagonise the coercing party whose performance he needs (Chen-Wishart, 2012 318). It is clear that the facts and circumstances of each case will be the determining facto r as to whether the claimant has suffered economic duress or not. Because of the uncertainty that exists in this area, however, it is often difficult for those entering into commercial contracts to acknowledge that they are exerting pressure that is considered illegitimate, especially when there is a possibility that lawful pressure will also be capable of amounting to economic duress. As a result of this, Young warns against exerting commercial pressure that the courts may possibly consider economic duress Abusing your upper hand can leave the strong open to claims (Young, 2012 23). Conclusion Overall, whilst the doctrine of duress is well established in English law, the doctrine of economic duress still remains largely uncertain. This generally arises from the difficulty of distinguishing between legitimate and illegitimate economic duress. As such, it is up to the courts to decide when a persons economic interests have been damaged from being forced or coerced into entering into a contract. Hence, the court will be required to consider whether the re-negotiation of the terms of the contract were lawful and whether the person being subjected to the economic duress, should be entitled to rescind the contract that they entered into. This is an important defence in ensuring that parties to a contract have equal bargaining power. Nevertheless, the practical application of economic duress has been subject to much confusion over the years, which may result from the reasoning that has been provided by the courts. There appears to be a lack of consistency that is being provided, which highlights the need for future reform to this area. Whilst there is a difference between commercial negotiation and illegitimate pressure, it has proven extremely difficult to distinguish between the two, especially since lawful conduct can also amount to illegitimate pressure. In order to provide clarity to this area, it seems as though a more robust approach is therefore needed by th e courts.ReferencesBusiness Dictionary. (2014) Economic Duress, Online Available http//www.businessdictionary.com/definition/economic-duress.html 07 July 2014.Card, R. Murdoch, J. and Murdoch, S. (2003) Estate Management Law, OUP, 6th Edition.Carr, N. (2011) Walking the Line The Balance Between Legitimate Negotiation and Economic Duress, Available Online 07 July 2014.Chen-Wishart, M. (2012) Contract Law, Oxford University Press.Cserne, P. (2009) Duress in Contracts An Economic Analysis, Contract Law and Economics, Volume 6, 2nd Edition.Furmston, M. P. Cheshire, G C. and Fifoot, C H. (2012) Cheshire, Fifoot and Furmstons Law of Contract, Oxford University Press London.Dictionary. (2014) Duress, Online, Available http//www.yourdictionary.com/duress 07 July 2014.Noble, M. (1991) For Your Consideration, New Law Journal, Volume 141, Issue 1529.Ohrenstein, D. (2013) Key Developments in Contract Law Economic Duress, Radcliffe Chambers, Online Available http//www.radcliffechambers.com/me dia/Misc_Articles/Key_Developments_in_Contract_Law_-_Economic_Duress_2013.pdf 07 July 2014.Young, A. (2012) When Pressure Turns to Duress, Construction Law Journal, Volume 23, Issue 5.Cases Adam v Opel Gmbh v Mitras Automotive 2007 EWHC 3481Collins v Godefroy (1831) 1 B&Ad 950CTN Cash and Carry Ltd v Gallaher Ltd 1993 EWCA Civ 19Dimskal Shipping v International Works Federation (The Evia Luck) 1992 2 AC 152DSND Subsea Ltd v Petroleum Geo Services ASA 2000 EWHC 185GMAC Commercial Credit Ltd v Dearden 2002 All ER (D) 440 (May)Kolmar Group AG v Traxpo Enterprises Pyt Ltd 2010 EWHC 113North Ocean Shipping Co Ltd v Hyundai Construction Co Ltd 1979 QB 705Pao On v Lau Yiu Long 1979 UKPC 17Scotson v Pegg (Scotson v Pegg (1861) 6 H & N 295)Shadwell v Shadwell (1860) 9 CBNS 159Siboen and The Sibotre 1976 1 Lloyds Rep 293Stilk v Myrick (1809) 2 Camp 317Thomas v Thomas (1842) 2 QB 851Universe Tankships v International Workers Federation (The Universe Sentinel) 1983 1 AC 366White v Bluett (1853) 23 LJ Ex 36Williams v Roffey Brothers and Nicholls (Contractors) Ltd 1991 1 QB 1Wright v HSBC Bank plc 2006 EWHC 930 QB

Impact of Organizational Support for Career Development

life outgrowth Inter national Emerald oblige The impact of organisational incarnate for life knowledge on occupational group gladness Belinda Renee Barnett, Lisa Bradley Article information To acknowledgment this muniment Belinda Renee Barnett, Lisa Bradley, (2007),The impact of organisational keep for occupational group growing on vocation joy, C arr ontogeny International, Vol. 12 Iss 7 pp. 617 636 Permanent link to this document http//dx. doi. org/10. 108/13620430710834396 D testify implike on 18-09-2012 References This document contains references to 40 separate documents Citations This document has been cited by 17 other documents To copy this document emailprotected com This document has been down pissed 7990 times since 2007. * Users who downloaded this Article in like manner downloaded * Jyotsna Bhatnagar, (2007),talent commission strategy of employee engagement in Indian ITES employees key to holding, Employee Relations, Vol. 29 Iss 6 pp. 640 663 http// dx. doi. org/10. 1108/01425450710826122 autonomic nervous system De Vos, Koen Dewettinck, Dirk Buyens, (2008),To move or not to move? The alliance amongst course worry and preferred occupational group moves, Employee Relations, Vol. 30 Iss 2 pp. 156 175 http//dx. doi. org/10. 1108/01425450810843348 Marilyn Clarke, Marg art Patrickson, (2008),The new coven ant of employability, Employee Relations, Vol. 30 Iss 2 pp. 121 141 http//dx. doi. org/10. 1108/01425450810843320 Access to this document was granted by guesss of an Emerald subscription provided by UNIVERSITY OF GUJRAT For Authors If you would like to write for this, or any other Emerald publication, then please theatrical role our Emerald for Authors service.Information about how to consider which publication to write for and submission guidelines are available for all. Please visit www. emeraldinsight. com/authors for much than(prenominal) information. About Emerald www. emeraldinsight. com With over forty age f amiliarity, Emerald Group Publishing is a pass oning independent publisher of spheric investigate with impact in business, society, public policy and direction. In hail, Emerald publishes over 275 journals and more than 130 sacred scripture series, as well as an ex ten-spotsive clench of online products and services. Emerald is both COUNTER 3 and TRANSFER compliant.The agreement is a partner of the Committee on Publication Ethics (COPE) and withal sketchs with Portico and the LOCKSS initiative for digital archive preservation. *Related content and download information correct at time of download. The stream egression and full text archive of this journal is available at www. emeraldinsight. com/1362-0436. htm The impact of organisational patronize for move training on go happiness Belinda Renee Barnett Queensland Rail, Sandgate, Australia, and declare for travel development 617 Received December 2006 Revised July 2007 true August 2007Lisa Bradley School of Manage ment, Queensland University of Technology, Brisbane, Australia Abstract Purpose The conclusion of this write up was to examine the relationship in the midst of organisational contribute got for charge development (OSCD) and employees life story ecstasy. Based on an all-encompassing work of loving cognitive line of achievement theory (SCCT) and an integrative sit down of pro circulateive behaviours, the study proposed that life history focus behaviours would mediate the relationship between OSCD and occupational group felicity, and between proactive reputation and locomote happiness.Design/methodology/ betterment Public and private domain employees (N ? 90) participating in biography development activities completed a survey regarding their proactivity, OSCD, flight counselling behaviours and life story contentment. Findings OSCD, proactive temper and rush precaution behaviours were all lordlyly cogitate to move satisfaction and go worry behavi ours mediated the relationship between proactive disposition and travel satisfaction. There was no be put up for the go trouble behaviours mediating between OSCD and life story satisfaction.Research limitations/implications This study provided incarnate for the extended SCCT put by examination a subset of its proposed relationships using a cross-sectional approach. The sample surveyed (employees participating in line of achievement development activities) and the magnanimous proportion of full-time employees, whitethorn limit the generalisability of the ? ndings. Future longitudinal interrogation could more fully sieve the relationships proposed by the extended SCCT gravel and include a greater epitomiseation of part-time and casual employees. thinkable implications The results suggest that there are bene? s for organisations and oneness-on-ones investing in life history development.. First, from an organisational horizon, investing in OSCD whitethorn enhance employees calling satisfaction. Second, employees whitethorn enhance their own travel satisfaction by participating in locomote focussing behaviours. Originality/value This study integrated the cryions of twain fabrics (an extension of SCCT and a model of proactive behaviours) to test the in? uence of purlieual (OSCD) and person difference (proactive personality) varyings on race satisfaction. Exploring how organisational and single(a) shiftings together in? ence rush satisfaction provides a more balanced approach to supposititious development. Keywords calling satisfaction, valet imagination focal point, Employee development, calling precaution Paper type Research paper Changes in the economic, technological and business environment during the last dickens decades have signi? depository financial instituti still impacted peoples occupational group attitudes and experiences (Hall, 2002 Pinnington and Lafferty, 2003). These environmental transposes have gui ded to the life story Development International Vol. 12 zero(prenominal) 7, 2007 pp. 617-636 q Emerald Group Publishing Limited 1362-0436 DOI 10. 1108/13620430710834396CDI 12,7 618 establishment of a new psychological contract the reciprocal obligations held by employees and employers (Hall, 2002). The predominance of organisational restructuring, de-layering and downsizing has brookd to a more ? exible or boundaryless(prenominal) move environment with expectations that individuals go away self-manage their callings, rather than rely on organisational direction (Arthur et al. , 2005 Kossek et al. , 1998). Concurrently, tight tire markets in Australia and other developed countries challenge organisations in bring ining, motivating and retaining employees.Australia is currently experiencing record low un custom rates with labour shortages crosswise umpteen industries, including the trades, engineering and knowledge sectors. In this competitive environment, where it is increas ingly dif? frenzy and costly to attract employees with the necessary skills, organisations move out up to convince employees that their organisation provides more opportunities, challenges and rewards than their competitors. This aim usher out be particularly challenging when the traditional rewards offered as part of the old psychological contract, much(prenominal) as structured go paths and hypothesize stability, are more dif? ult for organisations to provide due to the more dynamic environment in which many organisations now operate. Therefore, organisations are seeking creative ways to address this attraction, motivation and retention challenge (Erdogan et al. , 2004 Heslin, 2005). single way that organisations may meet this challenge is to oppose employees to develop their own line of achievements and amplification their travel satisfaction. This approach is unvarying with the recommendation that organisations perform a new houseive, rather than directive, role i n enabling their employees passage conquest (Baruch, 2006).This study proposes that organisations can adopt strategies to enhance employees career satisfaction and so potentially increase the organisations ability to attract and retain these employees. While one commission of this study is on the role that organisational support can play in employees career satisfaction, it is important to in like manner consider the role that individuals play in their own career conquest, particularly given over the trend towards more individualistic career charge in the last few decades (Baruch, 2006).Exploring the impact that organisational and individual difference variables have on career satisfaction will result in a more super sagaciousness of these relationships and similarly offers the opportunity to merge the two, frequently distinct perspectives provided by (worker-foc apply) vocational psychology and (employer focused) organisational psychology ( bring and Brown, 2006). An exte nded model of Social cognitive career theory (SCCT) has re pennyly been proposed which predicts how contextual and individual personality, cognitive and behavioural variables predict vocational satisfaction (Lent, 2004, 2005 Lent and Brown, 2006).To date, versions of this extended model have only examined the academician satisfaction of college educatees (Lent et al. , 2005) and there is a strong need for further study with apply workers (Lent and Brown, 2006). Therefore, this study will look for the relationship between an environmental support variable, organisational support for career development (OSCD) and employee career satisfaction.In addition, a mediating relationship proposed by SCCT, via participation in ending directed activities (individual career watchfulness behaviours) will be explored. Since this recently extended model of SCCT emphasises an approach to combine personality and environmental perspectives, previous studies of university students tested how extr aversion and validatory affect ? t the model (Lent et al. , 2005). The current study builds on past investigate by exploring how another important personality variable (proactive personality) impacts career satisfaction.By incorporating the predictions of the model of proactive behaviours (Crant, 2000), and the extended SCCT model (Lent and Brown, 2006), this study will also explore whether career counsel behaviours mediate the relationship between proactive personality and career satisfaction. greater understanding about the mediating mechanisms by which environmental and personality variables impact career satisfaction will contribute to a more comprehensive understanding of career satisfaction and support the development and examination of the extended SCCT model.Organisational career counselling is a risk caution process (Baruch, 2006). Therefore, examining the relative contribution that OSCD makes to employee career satisfaction can assist organisations in determining whet her investment in supporting employee career development will derive adequate bene? ts and modify organisations to better design career development strategies to achieve desired outcomes. From an employee perspective, understanding how personality, behavioural and environmental factors do work together may offer the opportunity to assist people to become as satis? d with their careers as nature and environmental factors support (Lent and Brown, 2006). Figure 1 presents a favorable cognitive model aimed at understanding vocational and educational satisfaction (Lent and Brown, 2006). The model predicts paths by which social cognitive variables (e. g. self-ef? cacy, goals) function conjointly with personality and environmental variables to impact work satisfaction (Lent and Brown, 2006). The model extends upon SCCT, which was originally developed to explain stake development, choice and work in career and educational domains (Lent et al. , 1994).Exploration of this recently develo ped model of SCCT can contribute to the literature by helping to achieve integration on two trains (Lent and Brown, 2006). These levels of contribution will be set forth next. Support for career development 619 Figure 1. A process model of work satisfaction that highlights theorized interrelations among personality, cognitive, behavioural and environmental variables CDI 12,7 620 The ? rst way that this model of SCCT can contribute to the literature is to help unify the ofttimes disparate perspectives of organisational and vocational psychology (Lent and Brown, 2006).While organisational and vocational psychology lookers focus on work satisfaction, it is often with assorted perspectives. For example, vocational psychology tends to be clearly focused on the individual and work satisfaction is treat as an end in itself, or as a component of work adjustment (Lent and Brown, 2006 Russell, 1991). Organisational psychology, alternatively, tends to focus more on the organisational con instalments of work satisfaction, such(prenominal) as productivity, engagement and turnover (Lent and Brown, 2006).These differing perspectives have led to for the to the highest degree part distinct literatures, with concerns that investigateers will reinvent areas of inquiry if they do not draw together learning from dual disciplines (Baruch, 2006 Lent and Brown, 2006 Russell, 1991) Therefore, exploring this extended SCCT model can contribute to the literature by developing closer links between vocational and organisational psychology perspectives on work satisfaction (Lent and Brown, 2006).Exploring this SCCT model can also contribute to building a more comprehensive understanding of work satisfaction by considering how cognitive, behavioural, personality and environmental factors jointly impact work satisfaction (Lent and Brown, 2006). By incorporating frequently studied correlates of work satisfaction into a few, broader conceptual categories, this extended model of SCCT a ttempts to balance comprehensiveness and simplicity in explaining the multiple in? uences on work satisfaction.While the bivariate relations contained in this model have received study, this extended model of SCCT provides a theoretical logic for predicting how these variables may function together. Since study of the extended SCCT model has focused on student samples to date (Lent et al. , 2005), this current study will also contribute to the literature by exploring how a subset of the relationships proposed by this SCCT model applies to employed workers, as recommended by Lent and Brown (2006).This study also incorporates theoretical predictions from the model of proactive behaviours (Crant, 2000) from the management literature. This model considers the antecedents (individual differences, such as proactive personality, and contextual factors, such as OSCD) and consequences (such as career victor) of both general and context-speci? c proactive behaviours (Crant, 2000). The model shares similarities with SCCT, in its perspective that employees take an active role in their careers they initiate behaviours and create favourable facts to achieve personal goals and career success (Crant, 2000).Similar to the predictions of SCCT (Lent, 2005), the model proposes that people are more liable(predicate) to take actions to achieve their goals if they have access to environmental (organisational) support and resources germane(predicate) to the pursuit of these goals. Integrating the predictions from the psychological and managerial literature also builds on the recommendations of (Baruch, 2006) who urged researchers to analyse careers from a broad, multi-disciplined approach, rather than from a circumscribed, single discipline perspective. The key elements of the model proposed in this study and its predicted pathways will be described next.The model outlined in Figure 2 integrates some of the predictions of the extended SCCT model (Lent and Brown, 2006) and the pr oactive behaviour model when applied to the career domain (Crant, 2000). The key classes of variables that comprise this model include career satisfaction OSCD organisational support for career development proactive personality and career management behaviours. Support for career development 621 Figure 2. Integrated model of proactive behaviours Key model elements move satisfaction ( intrinsic career success) While traditionally a career was considered to be con? ed to professionals or those who advanced done organisational hierarchies, today the term career is more broadly applied and is commonly considered to be the lifelong sequence of role-related experiences of individuals (Hall, 2002). Building on this de? nition, career success can be de? ned as the positive psychological and work-related outcomes accrued as a result of ones work experiences (Seibert and Kraimer, 2001, p. 2). Distinction has been made between accusing and ingrained indicators of career success.Objective career success refers to the work experience outcomes, such as status, promotions and salary, that are designly observable (Seibert and Kraimer, 2001). Traditional career research focused predominantly on documentary measures of career success (Gattiker and Larwood, 1988). This focus was consistent with the predominance of hierarchical organisations where employees career success was largely de? ned by promotion, rank and retention (Hall and Chandler, 2005). Measuring only objective criteria of career success, however, is de? ient, since people also value subjective outcomes such as development of new skills, work-life balance, challenge and purpose (Gattiker and Larwood, 1988 Heslin, 2005). Also, having achieved objective career success does not necessarily mean that people are satis? ed with their career (Hall, 2002). Lastly, some objective career success measures appear less relevant today, since organisations are more constrained in providing these opportunities (Heslin, 2005) . One way to deal with the limitations of de? ning and measuring career success using objective criteria is to supplement these with measures of subjective career success.Subjective career success Subjective career success refers to individuals evaluation of their career progress, accomplishments and anticipated outcomes, relative to their own goals and aspirations (Seibert and Kraimer, 2001). The change in focus to subjective career success, where the criterion for success is internal rather than external, is also consistent with the change in the career context where individuals are pass judgment to self-manage their own careers rather than rely on organisational direction (Hall and Chandler, 2005 Hall and Mirvis, 1995). CDI 12,7 622Subjective career success has most often been operationalised as romp satisfaction or career satisfaction (Erdogan et al. , 2004 Heslin, 2003 Ng et al. , 2005 Seibert and Kraimer, 2001). For example, in a recent review of career success studies, 20 o ut of a total of 49 studies operationalising subjective career success included measures of career satisfaction and 11 studies included measures for job satisfaction (Arthur et al. , 2005). Alternatively, a recent meta-analysis included only studies measuring career satisfaction to operationalise subjective career success (Ng et al. 2005). While there appears little general consensus about the relative merits of both measures, one perspective considers job satisfaction as an inadequate measure of career success, since subjective career success indicates satisfaction over a longer time frame and wider range of outcomes, such as sense of purpose and work-life balance, than job satisfaction (Heslin, 2005). We will use career satisfaction in this study. Career satisfaction measures the point to which individuals believe their career progress is consistent with their own goals, values and preferences (Erdogan et al. 2004 Heslin, 2003 Seibert and Kraimer, 2001). Career satisfaction is of ten thrifty using the career satisfaction scale developed by Greenhaus et al. (1990). The vast majority of studies measuring career satisfaction use this scale. For example, of the 20 studies measuring career satisfaction in the review article referred to above, 14 studies used the career satisfaction scale (Arthur et al. , 2005) as we will do in the current research. Organisational support for career development Organisational support for areer development (OSCD) is also called organisational career management or organisational sponsorship and refers to the programs, processes and assistance provided by organisations to support and enhance their employees career success (Ng et al. , 2005 Orpen, 1994). The variable has been so named in this study to be consistent with the new supportive and enabling role proposed for organisations, rather than the traditional command and subdue approach interpreted in the past (Baruch, 2006).Referring to the extended SCCT model (Lent and Brown, 20 06), OSCD belongs to a class of environmental support and resources variables that are speci? cally relevant to the pursuit of an individuals career goals. OSCD comprises formal strategies (including career planning, study and assessment centres) and informal support such as providing mentoring, coaching and networking opportunities (Hall, 2002 London, 1988 Sturges, Guest, Conway, and Davey, 2002).Proactive personality Proactive personality or disposition is a invariable individual difference construct that differentiates individuals establish on the consummation to which they take action to in? uence their environment. great deal with a proactive disposition tend to identify opportunities and act on them, persevering until meaningful change occurs in their environment (Crant, 2000). Proactive personality has demonstrated signi? camber positive relationships with career satisfaction and career management behaviours (Chiaburu et al. , 2006 Seibert et al. , 2001).Career managemen t behaviours Career management behaviours are the actions that individuals take to achieve their career goals. These behaviours occur when individuals choose to initiate and intervene in their career situation in such a way that the individual acts in a desired direction, rather than responding passively to an imposed change (Crant, 2000). These behaviours are referred to alternatively as career enhancing strategies (Nabi, 2003), context-speci? c proactive behaviours (Crant, 2000) and career goal-directed activities (Lent, 2004).These behaviours include career exploration and planning, skills development, networking and promoting ones achievements (Claes and Ruiz-Quintamilla, 1998 Kossek et al. , 1998 Nabi, 2000, 2003 none, 1996 Orpen, 1994). Pathways to career satisfaction The model outlined in Figure 2 proposes that contextual or environmental factors (such as OSCD) can in? uence the career satisfaction of employees by enhancing employees participation in career management behavi ours. The model also proposes that stable individual differences, such as proactive personality, also in? ences career satisfaction via career management behaviours people with a proactive disposition are more probable to engage in career management behaviours and be more satis? ed with their careers. Each of the paths proposed in the model will now be discussed. OSCD and career satisfaction A goal-speci? c environmental support and resource, such as OSCD, which provides social and material support for ones personal goals, is apparent to be a signi? cant predictor of career satisfaction (Lent and Brown, 2006).Conversely, the absence of such supports, or aim of contextual obstacles, is seeming to impede goal progress and reduce satisfaction. This direct link to career satisfaction is predicted in the extended model of SCCT (Lent and Brown, 2006), and in this studys model. To date, the evidence about the amount of variance in career satisfaction explained by OSCD is mixed (Ng et a l. , 2005). This variability could partly be explained by the lack of empirical research testing theoretical models that uniquely predict subjective career success (Ng et al. 2005 Seibert et al. , 2001 Wayne et al. , 1999). For example, many studies examining the in? uence of OSCD on career success make similar predictions for both objective and subjective career success and control for variables that have a greater relationship with objective than with subjective career success. Lack of research which makes this attribute is of particular concern, since recent meta-analytic results suggest that there is a signi? cant difference between the predictors of objective and subjective career success (Ng et al. , 2005). Speci? ally, OSCD (including career sponsorship, supervisor support and training and development opportunities) and stable individual differences (such as proactive personality) were more strongly related to career satisfaction than to salary and promotion, measures of obj ective career success (Ng et al. , 2005). Support for the relationship between OSCD and career satisfaction was provided in two recent meta-analyses (Allen et al. , 2004 Ng et al. , 2005). Signi? cant positive relationships were ground between mentoring and employee career satisfaction, with stamp sizes ranging from 0. 1 to 0. 29 across up to ten studies (Allen et al. , 2004). Signi? cant effect sizes ranging from 0. 38 to 0. 46 were also put together between OSCD (career sponsorship, supervisor support and training and development opportunities) and career satisfaction across up to 18 studies (Ng et al. , 2005). Analyses showed however, that the meta-analytic correlations between self-report measures were signi? cantly higher than correlations between self-report and objective measures, suggesting that percept-percept bias may be in? ating these correlations (Ng et al. 2005). Support for career development 623 CDI 12,7 624 Moderate support for a positive relationship between OSC D and employee career satisfaction was also represent in two cross-sectional studies, comprising employees from private and public sector organisations in the United Kingdom and Israel (Orpen, 1994 Pazy, 1988). In both studies, the souvenirs developed to represent characteristics of an effective organisational career management system loaded on three factors career management policies, employee career development and career information.Together, theoretical predictions and empirical ? ndings lead to the studys ? rst conjecture H1. OSCD will be positively related to career satisfaction. Career management behaviours and career satisfaction Participating in career management behaviours that are directed at achieving personally valued goals in the career domain are also expected to promote an individuals career satisfaction and success (Crant, 2000 Lent and Brown, 2006).Pursuing personally relevant goals is a key way that people can contribute to their own wellbeing and enables the exercise of personal agency in career satisfaction. To the extent that an individual can set and work towards their own goals and perceive that they are making progress, they are capable of promoting their own career satisfaction (Lent and Brown, 2006). Meta-analytic support also exists for the positive relationship between individual career management behaviours and career satisfaction (Ng et al. , 2005). Signi? cant effect sizes of 0. 33 and 0. 8 were found respectively for career planning and employee networking behaviour on career satisfaction across up to eight studies (Ng et al. , 2005). While most studies exploring these relationships are cross-sectional, there is also support for the positive impact of career management behaviours on subjective career success three years later(prenominal) (Wiese et al. , 2002). Wiese et al. (2002) surveyed 82 young German adults (age range 28 to 39 years) employed in a range of professions including physicians, lawyers, scientists, bank emp loyees, hotel managers and police of? ers The study measured participants career management behaviours and their subjective success in the work domain (career satisfaction) at conviction 1 and three years later. Participants career management behaviours at Time 1 predicted 14 per cent of the variance in participants career satisfaction three years later, later(prenominal) controlling for career satisfaction at Time 1. Career management behaviours at Time 1 however, did not predict signi? cant additional variance in career satisfaction when career management behaviours at Time 2 were also considered.The predictions of SCCT and the model of proactive behaviours, supported by these meta-analytic and longitudinal results, lead to the studys second hypothesis H2. Career management behaviours will be positively related to career satisfaction. Mediating role of career management behaviours between OSCD and career satisfaction The extended model of SCCT predicts that in addition to a dir ect relationship between OSCD (goal speci? c environmental resources) and career satisfaction, OSCD may also indirectly impact satisfaction via goal pursuit (career management behaviours) (Lent and Brown, 2006).The model of proactive behaviours also predicts that the presence of contextual factors, such as organisational support and resources, will facilitate an individuals proactive career behaviours and career success (Crant, 2000). While there is indirect support for the impact of OSCD on individual career management behaviours (Kossek et al. , 1998 nary(prenominal), 1996), empirical evidence for the mediating role of career management behaviours between OSCD and career satisfaction is limited (Nabi, 2003). For example, in two recent studies of university students conducted by the same research team (Lent et al. 2005), one study found support for this mediating relationship, while the second study did not. In the ? rst study of 177 students, signi? cant relationships were found between environmental resources and academic goal progress and between goal progress and domain satisfaction for both the academic and social domain. In the second study of 299 students a strong predictive relationship was found between goal progress and satisfaction, but not between environmental support and goal progress (Lent et al. , 2005).Nevertheless, based on the predictions of SCCT and the integrated model of proactive behaviour, it is expected that individuals will be more likely to take actions to achieve their career goals and career satisfaction if they have access to organisational (environmental) support and resources to pursue these goals (Crant, 2000 Lent, 2005). This leads to the third gear hypothesis H3. Career management behaviours will mediate the relationship between OSCD and career satisfaction. Proactive personality and career satisfaction According to the model of proactive behaviour (Crant, 2000), an individuals disposition or personality will also in? ence the extent to which they take the initiative to engage in career management behaviours and achieve career satisfaction. Therefore, this suggests that individuals with proactive dispositions are more likely to engage in career management behaviours and experience greater career satisfaction than individuals with lower proactive tendencies. A recent meta-analysis found that proactive personality was strongly related to career satisfaction with an effect size of 0. 38 found across three studies with over 1,000 participants (Ng et al. 2005). Signi? cant relationships between proactive personality, career management behaviours and career satisfaction were also demonstrated in a longitudinal study, which will be outlined next. A study canvass the career behaviours and strategies of 496 full-time employees found that proactive personality explained additional variance in career satisfaction, after controlling for several demographic, human capital, organisational, motivational and indust ry variables (Seibert et al. , 1999).Two years later, the researchers found that the relationship between proactive personality and career satisfaction was mediated by innovation, political knowledge and career management behaviours (de? ned as career initiative) (Seibert et al. , 2001a). While the recently extended SCCT model does not refer to proactive personality speci? cally, it does predict that personality and affective traits will impact satisfaction directly as well as via cognitive appraisals of self-ef? cacy and environmental supports (Lent and Brown, 2006).An additional theoretical pathway suggested is that certain personality traits may affect satisfaction through behavioural means the example given suggests that highly conscientious workers may be more likely to set, pursue and make progress towards personal goals (Lent and Brown, 2006). Similarly, it follows that highly proactive workers may be more likely to engage in career management behaviours to achieve career goa ls and satisfaction. The similar Support for career development 625 CDI 12,7 predictions of SCCT and the proactive behaviour model, supported by meta-analytic and longitudinal results, lead to the following hypotheses H4.Proactive personality will be positively related to career satisfaction H5. Career management behaviours will mediate the relationship between proactive personality and career satisfaction. 626 Control variables To more appropriately determine the unique in? uence of OSCD and proactive personality on career satisfaction, the study will also control for human capital variables (organisational kick upstairs and education level), which have been found to be related to career satisfaction (Ng et al. , 2005 Seibert and Kraimer, 2001 Wayne et al. 1999). The study will explore the in? uence that environmental and individual variables (OSCD, proactive personality and career management behaviours) can provide to employee career satisfaction and examine the mechanisms by whi ch these relationships operate. This study therefore builds on recommendations to contribute a more balanced, integrative perspective to the study of careers (Baruch, 2006 Lent and Brown, 2006). Method Sample The participants were 90 employees from a range of private and public sector organisations.A questionnaire was completed by 77 public sector employees and 21 postgraduate business students. 8 of the postgraduate students inform that they were currently unemployed, so they were removed from the analysis, leaving a total of 90 respondents. Of the stay respondents, 64 per cent were female. The majority of respondents were aged between 31 and 50 years (72 per cent), with 17 per cent under 30 years and 11 per cent aged over 51 years. Most of the respondents (53 per cent) were employed with their current organisation less than ? e years, with 14 per cent having organisational tenure of six to ten years and 33 per cent over 11 years. Most of the respondents (93 per cent) were employ ed full-time, with 56 per cent employed in administrative and professional roles, and 40 per cent in a managerial capacity. Educational level was high, with 86 per cent of respondents having completed either undergraduate or postgraduate tertiary study. Measures All the study variable scales were measured on a ? ve-point scale which ranged from strongly agree (1) to strongly disagree (5).Scores were reversed such that higher scores re? ected higher standing on the construct measure. All the scores for each of the items were averaged to obtain an overall measure for each of the variables. Organisational support for career development Respondents rated a ten-item organisational career management scale (Sturges et al. , 2002), indicating the extent to which they perceived OSCD. Five of the items were modi? ed slightly to re? ect a more supportive, rather than directive organisational relationship with employees. In a previous study (Sturges et al. 2002), six of the ten items loaded on formal OSCD (e. g. I have been given work which has developed my skills for the future) and four items loaded on informal OSCD (e. g. I have been encouraged to obtain a mentor to help my career development). In the previous longitudinal study, the formal OSCD subscale achieved an internal amity reliability of 0. 77 at both time 1 and time 2, one year apart and the informal OSCD subscale achieved an internal consistency reliability of 0. 80 at time 1 and 0. 81 at time 2 (Sturges et al. , 2002).Refer to bow I for the internal consistency reliabilities for all the current study variables. Proactive personality Proactive personality was assessed with a ten-item trim version of Bateman and Crants (1993) 17-item Proactive Personality scale. Seibert et al. (1999) presented evidence of the validity and reliability of the shortened scale, with the scale having demonstrated an internal consistency reliability of 0. 85 (Seibert et al. , 2001a). Respondents indicated their level of agreemen t with each of the statements (e. g. I am constantly on the lookout for new ways to improve my life).Career management behaviours Since the authors research did not identify one scale that examined as comprehensive a range of career management behaviours as desired, items from two scales were used. The ? rst scale measured career planning using six items developed by Gould (1979). This scale has demonstrated internal consistency reliability above 0. 7 in previous studies (Gould, 1979 Wayne et al. , 1999). Participants reported the extent to which they had career goals and plans (e. g. I have a strategy for achieving my career goals). Three items were stated in the opposite direction and were reverse scored.The second scale measured career self-management behaviours using 16 items (Sturges et al. , 2002). Respondents indicated the extent to which they engaged in networking (e. g. I have arranged to be introduced to people who can in? uence my career), visibility behaviour (e. g. I ha ve made my direct supervisor aware of my accomplishments), skills development (e. g. I have read work-related publications in my spare time) and mobility-oriented behaviour (e. g. I have made plans to kick the bucket this organisation if it cannot offer me a rewarding career). Internal consistency correlations above 0. were achieved for all of these subscales in a previous study (networking (0. 74), visibility (0. 69-0. 8) and mobility (0. 76-0. 78)), except for skills development (0. 56-0. 63) (Sturges et al. , 2002). Career satisfaction Career satisfaction was measured using the ? ve-item career satisfaction scale, which has demonstrated an internal consistency correlation of 0. 86 (Greenhaus et al. , 1990). Respondents indicated their level of agreement with each of the statements (e. g. I am satis? ed with the progress I have made toward shock my overall career goals).Control variables Respondents demographic and human capital information was collected with single item questio ns for gender, age, highest level of education completed, organisational tenure, work type (e. g. technical, professional, managerial) and employment status (full-time, part-time, casual). Support for career development 627 CDI 12,7 628 Variables 3. 65 3. 31 3. 52 3. 50 0. 08 0. 42 0. 22 20. 02 0. 16 20. 08 2 0. 28 0. 27 2 0. 08 0. 35 0. 15 0. 07 0. 02 2 0. 22 2 0. 17 0. 49 0. 77 0. 54 0. 72 circumvent I. Correlations between variables of interest M SD 1 2 3 4 5 6 7 8 0. 5 2 0. 19 2 0. 18 2 0. 32 2 0. 22 2 0. 17 2 0. 03 (0. 86) 0. 04 0. 55 0. 23 (0. 90) 0. 16 0. 27 (0. 88) 0. 35 (0. 87) 1. 2. 3. 4. 5. 6. 7. 8. Gender eld group Education level advance Proactive personality OSCD Career management behaviours Career satisfaction Notes correlations greater than 0. 28 are signi? cant at p , 0. 01 those greater than 0. 21 are signi? cant at p , 0. 05 internal consistency reliability for variables shown in brackets () nominal or ordinal scales used to measure variable, t herefore mean and standard deviation not reportProcedure Public sector employees participating in internal and cross-agency career development programs were invited to complete the questionnaire during workshops, while the postgraduate business students were invited to complete the questionnaire during university classes. (The authors approached these organisations and their respective employees/students because it was expected that they would be more interested in the studys variables of interest and subsequent results, and therefore, be more likely to participate in the study. Respondents were told that the aim of the survey was to research their career attitudes and perceptions about organisational career development. A cover letter provided background information regarding the purpose and nature of the study and emphasised con? dentiality, anonymity and voluntary participation. Participants either returned the questionnaire in an envelope at the end of the session or returned it in a reply-paid envelope addressed to the authors university address. To ensure anonymity, respondents were not asked to provide their names or any other identifying information.Participants were encouraged to participate by receiving a small incentive (such as a chocolate take out and/or being eligible to win a movie/meal voucher). The vouchers were awarded at the end of workshops, during which participants were given time to complete the questionnaire. Respondents who returned a completed questionnaire at the end of the workshop received a raf? e tatter. A winning ticket was then drawn from the collection of ticket butts, and the respondent with the matching ticket was given the voucher.These small incentives and the strategy used for approaching participating organisations may have resulted in the comparatively high response rate of approximately 50 per cent. Results Means, standard deviations and internal reliability for the variables of interest are shown in evade I. An exp loratory factor analysis showed that the formal and informal OSCD items loaded on one factor, accounting for 53 per cent of the variance in the factor structure. All the OSCD items were therefore averaged to form a composite OSCD score, with an internal consistency reliability of 0. 90.An exploratory factor analysis of the career management behaviours found that all items (except for the two mobility-oriented items and one networking item) loaded above 0. 30 on the ? rst factor, accounting for 30 per cent of the variance in the factor structure. A composite career management behaviour score was careful by averaging all the items loading above 0. 30 on the ? rst factor, with an internal consistency reliability of 0. 88. The networking item and two mobility-oriented items were removed from further analyses. All the remaining scales obtained internal consistency reliability above 0. 5 (refer shelve I). The public sector and postgraduate business student samples were analysed to deter mine differences on demographic variables. The only signi? cant differences were that the university respondents were less likely to be female (x 2 ? 1? ? 752, p , 001) and tended to be younger (x 2 ? 3? ? 1386, p , 001) than the public sector respondents. cod to there being only minor differences, the two cohorts were combined into one sample. Support for career development 629 CDI 12,7 630 Hypothesis testing H1 to H5 were analysed by conducting hierarchical egression analyses on career satisfaction. The data were checked for lose data and outliers. One multivariate outlier was identi? ed and removed from the analysis. The number of control variables used in the throwback analyses was contained to meet the recommended ratio of respondents to predictor variables (Tabachnick and Fidell, 1989). H1 and H2 proposed that OSCD and career management behaviours would both be positively related to career satisfaction. afterwards controlling for education level and tenure, OSCD predicted an additional 8 per cent variance in career satisfaction (? 028, p , 001), F? 1 85? ? 757. Therefore, H1 was supported. H2 was also supported. Career management behaviours predicted an additional 9 per cent variance in career satisfaction, after controlling for education level and tenure (? ? 033, p , 001), F? 1 85? ? 897. H3 proposed that career management behaviours would mediate the relationship between OSCD and career satisfaction (refer Table II). The ? rst condition of mediation (as described by Baron and Kenny, 1986) requires that the independent variable, OSCD, relate to the mediating variable, career management behaviours.In the ? rst comparison (refer compare 1, Table II), OSCD was not signi? cantly related to career management behaviours (? ? 019, p ?. 005, ns). H1 represented the second condition, which was met (refer equation 2, Table II), In the third equation, (refer equation 3, Table II), career satisfaction was regressed on the mediating variable (career managemen t behaviours) on with the independent variable (OSCD). The effect of OSCD on career satisfaction remained signi? cant (? ? 023, p , 005) and career management behaviour was also signi? cantly related to career satisfaction (? 028, p , 005). For the third condition to be met, the effect of OSCD on career satisfaction would need to decrease signi? cantly. The ? rst and third conditions of mediation were not met, suggesting that career management behaviours do not mediate the relationship between OSCD and career satisfaction. Therefore H3 was not supported. H4 proposed that proactive personality would be positively related to career satisfaction. After entryway the control variables (education level and tenure), proactive personality predicted 4 per cent additional variance in career satisfaction (? 021, p ? 005) F? 1 85? ? 383 (refer equation 2, Table III). Therefore, H4 was supported. pendant variable First equation CMB Second equation CSat Third equation CSat b b b 0. 31 * * 20. 13 0. 11 * * 0. 19 0. 14 * * 0. 04 0. 10 20. 15 0. 05 0. 28 * * 0. 09 * * 0. 08 * * 0. 10 20. 15 0. 02 0. 23 * 0. 28 * 0. 14 * * 0. 14 * * Variable Step 1 Education level Tenure Adjusted R 2 Step 2 OSCD Career management behaviours Adjusted R 2 DR 2 Table II. Mediating role of career management behaviours between OSCD and career satisfaction Notes *p , 0. 05 * *p , 0. 01 * * *p , 0. 01 Variable Step 1 Education level Tenure Adjusted R2 Step 2 Proactive personality Career management behaviours Adjusted R2 DR 2 Dependent variable First equation CMB Second equation CSat Third equation CSat b b b 0. 31 * * 20. 13 0. 11 * * 0. 53 * * * 0. 36 * * * 0. 25 * * * 0. 10 20. 15 0. 02 0. 21 0. 05 0. 04 0. 10 20. 15 0. 02 0. 06 0. 29 * 0. 09 * 0. 09 * Support for career development 631 Table III. Mediating role of career management behaviours between proactive personality and career satisfaction Notes p=0. 05 *p , 0. 05 * *p , 0. 01 * * *p , 0. 001H5 predicted that career management behaviou rs would mediate between proactive personality and career satisfaction. In the ? rst equation, proactive personality was a signi? cant predictor of career management behaviours (? ? 053, p , 0001) F? 1 85? ? 3498 (refer equation 1, Table III), meeting the ? rst condition. H4 represented the second condition of mediation which was also met. Both proactive personality and career management behaviours were entered in the third equation (refer equation 3, Table III). While career management behaviour was positively related to career satisfaction (? ? 029, p , 005) F? 2 84? 455, proactive personality was no longer statistically signi? cant (? ? 006, p . 005, ns), meeting the third condition, Moreover, the indirect path linking proactive personality and career satisfaction through career management behaviours was signi? cant (Sobel test, z ? 211, p , 005). This suggests that career management behaviours fully mediated the relationship between proactive personality and career satisfaction, providing support for H5. Discussion This study explored the contribution that organisations and employees can make to their career satisfaction and the mechanisms by which these relationships occur.This was achieved by testing a subset of the relationships proposed by an extended model of SCCT (Lent and Brown, 2006) and an integrative model of proactive career behaviours (Crant, 2000). The study explored how proactive personality, OSCD and individual career management behaviours relate to career satisfaction. Consistent with previous research (Ng et al. , 2005 Seibert et al. , 2001a), this study found that proactive personality was signi? cantly positively related to career satisfaction. The study also found that career management behaviours mediated the relationship between proactive personality and career satisfaction.These results support the model of proactive behaviours, which suggests that highly proactive individuals are more likely to achieve greater career satisfaction th an less proactively accustomed individuals, by engaging in proactive career behaviours (Crant, 2000). The results also support the theoretical proposition by Lent and Brown (2006) that speci? c personality traits (proactive personality) impact satisfaction via behavioural means (career management behaviours). CDI 12,7 632 After controlling for education level and tenure, OSCD explained a moderate 8 per cent variance in career satisfaction.This result supports the premise made by the extended SCCT model that access to goal-relevant environmental resources will be directly related to satisfaction (Lent and Brown, 2006). This ? nding also supports this studys proposal that organisations can in? uence their employees experience of career success by supporting their employees career development. Individual career management behaviour (comprising career planning, networking, skills development and visibility) was also positively related to career satisfaction.After controlling for educat ion level and tenure, individual career management behaviour explained 9 per cent additional variance in career satisfaction. This ? nding is consistent with SCCT and the model of proactive career behaviours, since it supports the proposal that individuals taking proactive actions to achieve their career goals (engaging in career management behaviours) are more likely to experience career satisfaction (Crant, 2000 Lent, 2005). The proposal that individual career management behaviours mediated the relationship between OSCD and career satisfaction received no support, due to a non-signi? ant relationship between OSCD and career management behaviours. This ? nding is inconsistent with the extended SCCT model, which predicts that environmental resources may impact satisfaction indirectly via their impact on goal-directed activities. The relationship between contextual factors, such as OSCD, and individual career management behaviours has received mixed empirical support. For example, Le nt et al. (2005) found two different outcomes from their two different studies. The ? rst study of 177 students found a signi? ant relationship between environmental supports and resources and student progress towards their academic goals. The second study of 299 students found no direct relationship between these variables. A possible story for this studys results is that individual difference variables, such as proactive personality, moderate the relationship between OSCD and career management behaviours. Given that individuals with a proactive disposition are relatively unconstrained by situational forces (Crant, 2000) it is likely that highly proactive people will engage in career management behaviours independent of the OSCD they perceive.This study possibly suffered from a restriction of range in this independent variable, since the studys respondents (employees participating in career development programs and/or further study) are more likely to have highly proactive disposi tions, and therefore engage in career management behaviours independent of their perceived OSCD. This explanation is supported somewhat by the relatively high mean score for proactive personality (3. 65 on a ? ve-point scale).Another possible reason for career management behaviours not mediating between OSCD and career satisfaction is that there are additional environmental supports and resources (such as those outside the organisation), individual difference or social cognitive variables impacting individuals career management behaviours which were not explored in this study. Theoretical implications This study contributes to the existing literature by exploring how environmental aspects (OSCD) and an individual difference variable (proactive personality) together impact career management behaviours and career satisfaction.Few studies have simultaneously investigated the impacts of these variables on career satisfaction before, and doing so responds to recommendations to balance bo th organisational and individual perspectives in theoretical development and facilitate integration of the organisational and vocational psychology perspectives (Baruch, 2006 Lent and Brown, 2006). This study builds on previous research which tested the extended SCCT model with university students (Lent et al. , 2005), by exploring the application of a subset of its proposed relationships with employed workers.This study also integrate conceptual predictions and empirical ? ndings from the management literature (Seibert et al. , 2001a) to test the applicability of another personality variable, proactive personality, in the extended SCCT model. Previously, positive affect and extraversion have been tested in the SCCT model (Lent et al. , 2005). The ? nding that career management behaviours mediated the relationship between proactive personality and career satisfaction provides support for the extended SCCT models prediction that personality traits may affect satisfaction via behavio ural means (Lent and Brown, 2006).Together with the signi? cant positive relationship between OSCD and career satisfaction, this study provides support for the application of some of the extended models proposed relationships to employed workers. The study also has practical implications, which will be reviewed next. Practical implications While causation can not be proven, this study suggests that employees proactive personality, via their career management behaviours, and OSCD are signi? cantly related to employee career satisfaction. This suggests two different strategies for organisations to facilitate employees career satisfaction.The ? rst strategy involves recruiting employees with proactive dispositions. While this may be more dif? cult given the tight labour market experienced currently in Australia, and many other countries, it may be possible in some countries or in some industries. The second strategy involves enhancing employees perceptions of OSCD by providing both for mal programs and informal support for employee career development. The signi? cant positive relationship between career management behaviours and career satisfaction suggests that individuals bene? personally from engaging in these behaviours. Therefore, this ? nding suggests that OSCD initiatives that promote the individual bene? ts associated with career management behaviours and encourage employees to engage in these behaviours, may experience most success in facilitating employee career satisfaction. adopt limitations As with all cross-sectional studies, causality between OSCD and career satisfaction can not be proven. Questionnaires were completed at one point in time by respondents, so the results are also subject to common method and common source bias.As discussed above, the sample surveyed (employees participating in career development activities) is likely to be more proactively inclined than the general population, which may have restricted the range of study and limit t he generalisability of the results. A large proportion of the study respondents were educated to tertiary level and employed full-time, which may also limit the generalisability of the ? ndings, particularly given the increasing participation in part-time and casual employment in Australia. The use of the career satisfaction scale to measure subjective career success may be another limitation of the study.While this standardised scale is used widely and obtains acceptable levels of internal consistency (Greenhaus et al. , 1990), it may be a de? cient measure of the subjective career success construct. The career satisfaction Support for career development 633 CDI 12,7 scale includes items (such as satisfaction with income and advancement goals) which may not be the most important criteria used by individuals to assess their career success (Heslin, 2005). Future research Future research could be conducted with a greater representation of part-time and casual employees, and with great er variability in individual differences, such as roactive personality. Exploration of the broader relationships proposed by SCCT on a longitudinal basis could build our understanding of the nature of the relationships between individual differences, environmental, social cognitive and behavioural predictors of subjective career success. Future research could also explore the types of career management behaviours that are most valuable for. achieving important career outcomes for employees. Greater understanding of these relationships could lead to the design of interventions that better facilitate employees experience of career success.Conclusion This study proposed that organisations may potentially attract, motivate and retain employees by supporting their employees career development. The results indicated that OSCD and employee participation in career management behaviours are positively related to employee career satisfaction. These results suggest that OSCD initiatives promot ing the bene? ts associated with career management behaviours and supporting employees to participate in these behaviours may experience the most success in facilitating employee career satisfaction. References Allen, T. D. , Eby, L.T. , Poteet, M. L. , Lentz, E. and Lima, L. (2004), Career bene? ts associated with mentoring for proteges a meta-analysis, Journal of Applied Psychology, Vol. 89, pp. 127-35. Arthur, M. B. , Khapova, S. N. and Wilderom, C. P. M. 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