Themes in Native American Tricksters

Chapter by chapter guide Abstract Introduction Conclusion Works Cited Abstract Although the Native American swindler stories are short and simple, every story embodies a whole lifestyle. At the point when placed in their scholarly setting, the conventionality of the narratives really conveys further implications. In spite of the fact that the Native American individuals don't share a bound together assortment of folklore, all the diverse swindler stories pass on life exercises of morals and standards of conduct. On this, almost all the swindler stories among the Native American individuals convey similar subjects and plot elements.Advertising We will compose a custom examination paper test on Themes in Native American Tricksters explicitly for you for just $16.05 $11/page Learn More This viewpoint makes the devious yet blessed Trickster a key figure in the Native American oral convention. Regardless of whether the character is the shriveled elderly person Coyote of the Crow clans, Ra ven in the Indian legend or even Wakdjunkaga of the Winnebago, the stories is by all accounts composed from a similar content. This examination paper looks at a portion of the significant topics and plot components found in Native American swindler stories. Presentation Although the Native American swindler accounts are short and straightforward, every story epitomizes a whole lifestyle. At the point when placed in their scholarly setting, the conventionality of the narratives really conveys further implications. Despite the fact that the Native American individuals don't share a bound together collection of folklore, all the distinctive cheat stories pass on life exercises of morals and standards of conduct. On this, almost all the cheat stories among the Native American individuals convey similar topics and plot components. This viewpoint makes the devious however blessed Trickster a key figure in the Native American oral custom. Regardless of whether the character is the shrivele d elderly person Coyote of the Crow clans, Raven in the Indian legend or even Wakdjunkaga of the Winnebago, the accounts is by all accounts composed from a similar content. This examination paper looks at a portion of the significant subjects and plot components found in Native American swindler stories. (Smith) One topic that is practically prevailing in all the American Trickster stories is Sacrifice. This is brought out in the circumstance where various characters perform magnanimous acts implied to help the entire society. In practically all the narratives, there are cases where a specific character sets out on a risky strategic is intended to profit the entire network. The repeat of this subject is intended to cause individuals to consider what they can accomplish to help humankind. (Babcock-Abrahams 150) In the story of Coyote and the Monster that is educated among the Navajo, Coyote is distressed after discovering that the beast has eaten every one of his companions. In spite of the fact that the beast can't eat him, Coyote doesn't unwind yet rather he devises an approach to free his companions. The beast chooses to persuade Coyote to remain at his home as a visitor. The ever-crafty Coyote tells the beast that he would be glad to be his visitor yet first looks for authorization to visit his companions. Without thinking about the peril in question, Coyote goes inside the monster’s stomach where he cuts the monster’s heart and he can free his companions. Coyote’s activity is a magnanimous demonstration that everybody in the general public ought to copy on the off chance that we are really ready to support mankind. (Babcock-Abrahams 160)Advertising Looking for research paper on american writing? We should check whether we can support you! Get your first paper with 15% OFF Learn More Another story that bears the subject of penance is the one educated among the Karok clan on how Coyote took fire. In this story, Coyote is a soul being who is caught up with doing his typical tasks when he sees how men who have quite recently appeared on the scene have issues during winter. During this period, the youngsters and matured individuals ordinarily bite the dust as a result of the chilly climate. Being a soul being, Coyote needn't bother with anything to warm himself throughout the winter season. At some point, Coyote happens to be going almost a human town when he hears ladies grieving their kids who have passed on throughout the winter. Moved by empathy, Coyote chooses to enable the ladies to obtain fire from the searing Fire Beings. Dismissing the creatures red hot nature, Coyote sets out on a hazardous crucial get the fire. He rallies the help of different creatures and together they devise a method of taking the fire from these creatures. All the while, the included creatures wind up languishing over their activities however they can accomplish their central goal. At long last, man can have fire for warming himself thr oughout the winter season and his kids and the matured prevent passing on from the virus. This is a finished demonstration of penance since the creatures that help in getting the fire don't remain to profit by the entire strategic. (Babcock-Abrahams 166) Another focal topic in numerous Native American stories is culture saints and transformers. In pretty much every story, a culture legend changes the world into a perfect spot and above all shows individuals how to live. The job of such a character is to help individuals in trouble and to show them exercises on ethical quality and even to make things out of nothingness. The significance of this topic is maybe to show how pioneers can help in carrying change to the general public. An exemplary case of this subject is the Wishram story that discloses how Eagle attempted to prevent individuals from biting the dust for eternity. After the passing of his youngsters, Eagle and Coyote set out on an excursion to recover their dead kids and f or all time stop the aches of death. By thinking carefully, Eagle prevails with regards to murdering Moon and safeguards the dead individuals. In any case, Coyote’s over eager nature decimates the arrangement and the outcome is that individuals wind up biting the dust until the end of time. Despite the fact that Eagle bombs in his crucial, story is an exemplary case of social courage and eagerness to get change the world. This subject is likewise present in the Navajo variant where Coyote thinks carefully to end the beast that has slaughtered his companions. (Babcock-Abrahams 170)Advertising We will compose a custom examination paper test on Themes in Native American Tricksters explicitly for you for just $16.05 $11/page Learn More Another subject that is intermittent in all American Trickster stories is that of grit. It takes dauntlessness for Coyote in the Navajo story to execute the beast and free the individuals. This topic is rehashed in the Karok story where Coyote stan ds up to the Fire Beings who monitor their fire all through to keep it from being taken by individuals. Notwithstanding the clear peril, Coyote realizes that in the event that he neglects to get the fire, individuals will continue passing on during the virus seasons. This topic is additionally present among the Menomini individuals where the Hell-jumper cautions different feathered creatures that Manabozho was executing their companions. The Hell-jumper does this paying little heed to the danger of creating red eyes for disrupting the guideline. Nonetheless, his courage protects different winged animals from the insidiousness Manabozho. (Radin 33) Although Native America has various people groups and dialects, numerous components of folklore are shared over the various locales. A male typically plays the character of the Trickster and his principle obligation is to show individuals the manner in which they ought to go. Much of the time, the cheat wants to agitate individuals and mak e issue. In many stories, the swindler is introduced as a legend and he pulls tricks that at long last assistance the entire network. A model is the place Coyote takes fire to profit individuals without himself profiting in any capacity. Another story is the place â€Å"Trickster† masks himself as a lady to guarantee that his companions don't abandon a supper. Another story from the Northwest Coast district clarifies how a specific boss took all the light, diving the entire universe into dimness. Utilizing slyness, a raven flew into the land masked as a seed and later figured out how to take the sun guaranteeing that individuals got backdrop illumination. This shows a consistency in plot component portrayal in all the tales. (Radin 37) Conclusion Although there are diverse Native American Trickster accounts, greater part of them convey similar topics. These swindler stories have been educated orally through the ages and they have figured out how to keep up their unique messag e. The subjects that are generally basic in the accounts incorporate the topic of boldness, magnanimity and change. These topics are inside and out valuable in making a prosperous society. This maybe clarifies why these stories have kept on being pertinent even in our advanced society. The consistency of the topics in all the stories can be utilized to portray the fellowship of the American society.Advertising Searching for research paper on american writing? How about we check whether we can support you! Get your first paper with 15% OFF Find out More Works Cited Babcock-Abrahams, Barbara. A Tolerated Margin of Mess: The Trickster and His Tales Reconsidered. Diary of the Folklore Institute, vol. 11, 1975: 147-186. Print. Radin, Paul. The Trickster: A Study in American Indian Mythology. New York: Greenwood Press, 1969, 30-40. Print. Smith, Jennifer. Africa Native American Trickster Folktales, 2005. Web. This exploration paper on Themes in Native American Tricksters was composed and put together by client Jameson Bell to help you with your own examinations. You are allowed to utilize it for examination and reference purposes so as to compose your own paper; in any case, you should refer to it likewise. You can give your paper here.

Compliment Responses between Male and Female Essay

Praise Responses among Male and Female - Essay Example This paper focuses on that examination of praise reaction, which was in a contractive nature between the Kuiti speakers both the male and the female was utilized to recognize the commendation reaction design between the three gatherings. The table beneath gives out an example of the interest where S represents circumstance, and afterward P represents investment, R for dismissal and ultimately A for acknowledgment. Moreover, the members were allocated unique numbers. In this manner, the numbers that goes with this truncation speaks to their alloted codes. Likewise similarly, the code may speak to kinds of methodologies at the degree of smaller scale portrayal and circumstances. This paper makes an end that this examination study exhibited the commendation reaction techniques that both the male and Female Arabians typically use. It ought to be noticed that the general model depicted in the investigation above concerning the commendation reaction is of inspirational standpoint. This is on the grounds that, diverse sexual orientation and source depicts an alternate arrangement of conventions. In any case, in spite of the fact that not spoke to above, it ought to be noticed that age is another significant factor with regards to reaction made to praises. The finding in this examination clarifies that the cross-etymological commendation reaction designs depict an alternate wonder at both the small scale and large scale levels. Outstandingly, the three gatherings followed a specific inclination request of dismissal, avoidance, and acknowledgment.

Think Big Impressive Extracurricular Activities Examples for Highschool Students TKG

Think Big Impressive Extracurricular Activities Examples for Highschool Students We know you’re busy. Or maybe you’re not, and this article is perfect for you because you should be busy. Really busy. Sometimes we just need a little bit of creative inspiration (or a strong reminder) that colleges not only care about, but look carefully at how you spend your time outside of the classroom.   So, if you need that reminder to fill your time with activities and projects that are productive, consider this that reminder. And if you’re busy with extracurriculars, this is a good reminder to think about quality vs. quantity. Just because you’re doing a lot, doesn’t mean you’re showing your diversity of skills and interests in the best way possible.  We think that the most competitive students and applicants are those who lead, those who plan, and those who choose to spearhead unique projects that act as value-adds to one of their many communities. And no, that doesn’t necessarily mean community service. (We have a lot of opinions on community service but you can read about that elsewhere.) When we say “act as value-adds” we mean something that doesn’t just look good, but something that has actual use and meaning, that are relevant to your area(s) of interests. The reason why it’s so important to evaluate your extracurriculars from the perspective of independent contribution and leadership is that those are aspects and qualities that colleges look for in students. They want students who a) are eager and effective contributors to their academic and school communities, and b) contribute in such ways that showcase their commitment, motivation, and creativity, not to mention their work ethic and leadership skills. We’ve put together a few ideas for in-school independent project ideas that we encourage students to pursue to help them stand out. We know that you’re unique. We do. We just want to help make sure that you are maximizing your interests and capabilities and we think that independent projects are great ways to do that. W e think that doing something at or related to your school is a great place to begin because: a) it’s where you already spend a   lot of your time, and b) your school likely has resources that you can use to help get your project off the ground.  Create a community partnershipThink about it: there are lots of local organizations that are low (and reliant) on volunteers to accomplish their goals. There are also lots of willing and able students who attend your school. What better use of your time than to find a local organization that could benefit from a surge of young enthusiasm and labor and facilitate a partnership through an event or series of events. Lots of students don’t have the energy or willingness to seek out independent volunteer work (it can be scary to cold-call or cold-visit a non-profit), but surely would be willing to sign up to volunteer if it were as easy as showing up somewhere at a designated time. Do your research and find an organization that you’d be ex cited to partner with and one that aligns with your interests. For example, you could help coordinate a local blood drive, promote literacy by bringing students in to read to young kiddos, or improve geriatric mental health by coordinating a group of students to spend time with older folks at a community center or YMCA. Offer to TA a courseTake advantage of the subjects in which you’re excelling and schedule a meeting with your teacher to offer your time and energy. Many classes could benefit from having a student who is familiar with the material and who could ease the burden of office hours. We’ve had students fill a “TA” (teaching assistant)-type role for lower-level courses the year after they’ve completed and mastered the course material. The teacher might give you some extra work over the summer to prepare, but we think that it’s a great way to show academic leadership. It could also be a great use of your free periods. Create a MakerspaceMakerspaces often get bran ded as “only for engineers” when in reality, a Makerspace can be any sort of creative/productive/out-put driven workspace that you want it to be. It does not have to have a focus on electrical engineering, but with just a few supplies (for which you can fundraise to purchase), you can put together a community hub for anyone who is interested in getting involved in creating with their hands and brains. UT Austin has a seriously impressive makerspace called Texas Inventionworks that we’d suggest taking a look at for inspiration. Concordia University-Portland and USC each created resource-filled guides for putting together Makerspaces at your school.  Bottom line: look for what is missingTake stock of all of the available clubs and teams at your school and evaluate from a selfish perspective--is there enough for you, based on your highly-specific interests? If there’s something that stands out as missing, that you’d be thrilled to join if it were to exist....then get to work , because you’re going to make it happen.  Let us know if you need help thinking of something to kick-start at your school. These are just a few ideas, and every school is different. Call or email us with your specifications and interests and we’d be thrilled to do some brainstorming with you.

Environmental Vocabulary for English Learners

For English-language learners, vocabulary related to environmental issues can be challenging. Tables sectioned according to types of environmental issues can help. These tables provide the word or phrase in the left column and an example of how to use the term(s) in the righthand column to provide context. Important Issues From acid rain to pollution and radioactive waste, there are many environmental issues around which discussion and debate have evolved. Students will likely hear many of these terms on the news or read about them on the internet and in newspapers. The general list of issues should prove helpful. Term or Phrase Example Sentence acid rain The acid rain ruined the soil for the next three generations. aerosol Aerosol can be extremely toxic and must be used with care when sprayed in the air. animal welfare We must consider animal welfare as we strive to create a balance between man and nature. carbon monoxide Its important to have a carbon monoxide detector in your home for safety. climate The climate of an area can change over long periods of time. conservation Conservation focuses on making sure we protect the nature we havent already lost. endangered species There are many endangered species all over the planet that need our help. energy Humans are using an ever increasing amount of energy. nuclear energy Nuclear energy has passed out of fashion after a number of serious environmental disasters. solar energy Many hope that solar energy can wean us off our need for fossil fuels. exhaust fumes The exhaust fumes from cars standing in traffic can make you cough. fertilizers Fertilizers used by huge farms can pollute drinking water for miles around. forest fires Forest fires can burn out of control and create hazy weather conditions. global warming Some doubt that global warming is real. greenhouse effect The greenhouse effect is said to heat up the earth. (non)renewable resources As we move forward, we need to become more dependent on renewable energy resources. nuclear The exploration of nuclear science has created great boons, as well as horrific dangers for humanity. nuclear fallout The nuclear fallout from a bomb would be devastating to the local population. nuclear reactor The nuclear reactor was taken offline because of technical problems. Oil slick The oil slick caused by the sinking vessel could be seen for tens of miles. ozone layer Industrial additives have been threatening the ozone layer for many years. pesticide While its true that pesticides help kill off unwanted insects, there are serious problems to be considered. pollution Water and air pollution situations have improved over the last few decades in many countries. protected animal Its a protected animal in this country. You cant hunt it! rainforest The rain forest is lush and green, bursting with life from all sides. unleaded petrol Unleaded petrol is certainly cleaner than leaded petrol. waste The amount of plastic waste in the ocean is shocking. nuclear waste Nuclear waste can remain active for many thousands of years. radioactive waste They stored the radioactive waste at the site in Hanford. wildlife We must take the wildlife into account before we develop the site. Natural Disasters From drought to volcanic eruptions, natural disasters are a big part of the environmental discussion, as this table shows. Term or Phrase Example Sentence drought The drought has gone on for sixteen straight months. No water to be seen! earthquake The earthquake devastated the little village in the Rhine River. flood The flood forced more than 100 families from their homes. tidal wave A tidal wave hit the island. Luckily, no one was lost. typhoon The typhoon hit and dropped more than ten inches of rain in one hour! volcanic eruption Volcanic eruptions are spectacular, but they dont occur very often. Politics and Action Discussion generally leads to the formation of environmental groups and actions, some positive and some negative, as this final listing demonstrates. Environmental groups are followed by a listing of verbs (or actions) related to the environment and environmental issues. Term or Phrase Example Sentence environmental group The environmental group presented their case to the community. green issues Green issues have become one of the most important themes of this election cycle. pressure group The pressure group forced the company to stop building on that site. cut down We need to cut down on pollution drastically. destroy Human greed destroys millions of acres each year. dispose (of) The government must dispose of the waste properly. dump You can dump recyclable garbage in this container. protect Its our responsibility to protect the natural habit of this beautiful planet before its too late. pollute If you pollute in your own backyard, youll eventually notice it. recycle Make sure to recycle all paper and plastics. save We save bottles and newspapers to take to recycle at the end of each month. throw away Never just throw away a plastic bottle. Recycle it! use up Hopefully, well not use up all our resources before we start solving this problem together.

Nestles Operations Management - 6329 Words

NESTLE A Project on Operations Management An understanding of current production systems, the quality aspects and supply chain management of Nestle 2012 Group-5 : SANTOSH KUMAR GUPTA, JAISON JOSEPH, NANJAPPA P.B., TANUJ GOYAL, MAITREE MISHRA, ANAND S. INDIAN INSTITUTE OF MANAGEMENT ROHTAK 3/17/2012 Contents Executive Summary 3 Nestlà © 4 Brief Overview 4 History 4 Main Brands 4 Nestlà ©s Popularly Positioned Products (PPP) strategy 5 Global context 5 Key facts on Popularly Positioned Products Strategy 5 Nutrition 5 Distribution 5 Operations of Nestle 6 Milk reception and quality checks 7 Separation 7 Milk separator 8 Clarification 8 Standardization 8 Bactofugation 8 Homogenization 9 Pasteurization 9 Evaporation 9†¦show more content†¦The company is acknowledged amongst India’s ‘Most Respected Companies’ and amongst the ‘Top Wealth Creators of India’. History Nestlà © began in Switzerland in the mid 1860s when founder Henri Nestlà © created one of the first baby formulas. Henri realized the need for a healthy and economical product to serve as an alternative for mothers who could not breastfeed their babies. Mothers who were unable to breastfeed often lost their infants to malnutrition. Henri’s product was a carefully formulated mixture of cow’s milk, flour and sugar. Nestlà ©Ã¢â‚¬â„¢s first product was called Farine Lactà ©e (â€Å"cornflour gruel† in French) Henri Nestlà ©. The product was first used on a premature baby who could not tolerate his mother’s milk or other alternative products of that time. Doctors gave up on treating the infant. Miraculously the baby tolerated Henri’s new formula and it provided the nourishment that saved his life. Within a few years the first Nestlà © product was marketed in Europe. Main Brands Nestlà © expands across many different markets including beverages, ice cream, baby foods/formulas, soups, frozen foods, snacks, pet care and of course candy. Some of Nestlà ©Ã¢â‚¬â„¢s main global brands include: * Kit Kat, Butterfinger, Smarties, Crunch, Quality Street, Milkybar/Galak, Tollhouse * Nestea, Nescafà ©, Taster’s Choice, Nesquick, Carnation,Show MoreRelatedOperation Management2751 Words   |  12 PagesTABLE OF CONTENTS 1. OPERATION MANAGEMENT 3 1.1. DEFINITION OF OPERATION MANAGEMENT 3 1.2. THE ROLE OF OPERATION MANAGER 3 1.3. RELATIONSHIP OF OPERATION MANAGEMENT WITH OTHER CORE FUNCTIONS 3 2. CASE STUDIES 3 2.1. HEATHROW INTERNATIONAL AIRPORT 3 2.2. NESTLÉ UK CHOCOLATE FACTORY 3 3. MAJOR UNDERSTANDINGS OF THE STUDY 3 4. CONCLUSIONS 3 REFERENCES 3 1. Operation Management For the success of an organization, the management crew plays a major role. An organizational structure is based on differentRead MoreNestle’s Sustainable Growth in Mature Market1512 Words   |  7 PagesNestle’s sustainable growth in mature market The company establishment Nestle was first founded by Henri Neslte in the 1860s by developing and producing food products for babies who could not adapt mother’s milk. Following the success in baby food products, Henri incorporated with an Anglo-Swiss condensed milk company to develop dairy products, especially for government supply in World War I. High sensitive and quick responding to the demand of consumer, Nestle continued to create and develop newRead MoreNestle, A Swiss Company Essay949 Words   |  4 Pagesshares capital of the Alimentana S.A. Company in exchange for fifteen Nestlà © shares and fifteen Unilac shares for each of Alimentana S.A. share, so this point the name was at Nestlà © Alimentana S.A. It became Nestlà © SA in 1977 (Mergent Online). Nestlà ©Ã¢â‚¬â„¢s continues to be successful, operating in over 80 countries for over a 150 year. They are the world’s largest food and Beverage Company. Nestlà © s main headquarters are in Vevey, Switzerland In Nestlà © s business strategy, they encourage productRead MoreEvaluating The Strategic Factors And Approaches Of Nestle Company1429 Words   |  6 Pagesthis assignment is to evaluate Nestle Company industry based on the case study and comprehend how the company develops strategic intent for their business organizations following the strategic factors and approaches. I will analyze the strategic management process as firm used to achieve strategic competitiveness. In order to strengthen this assignment about Nestle, there are several methods of gathering data has been conducted, such as Core Competencies analysis and BCG Matrix Analysis. 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With the standardization of its core business processes and systems, Nestlà © would have to effectively manage and deal with certain difficulties regarding the management, organization, as well as their own technologies. Nestlà ©Ã¢â‚¬â„¢s management alone faces several challenges to deal with. Some of the problems encountered by the management are the inconsistenciesRead More Values-Based Leadership1409 Words   |  6 Pagesfor achievement and growth by acting as a coach or mentor and ensuring minimal conflicts between employees which may hinder performance. (Homrig, 2001). This leadership is clearly seen in operation in the following companies: Nestle The company’s management and leadership principles state that â€Å"people are Nestlà ©Ã¢â‚¬â„¢s most important asset.† The Nestle chief executive officer Peter Brabeck- Letmathe says that all this is embodied in the talents that the company nurtures. 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The Importance Of Drug Testing - 765 Words

The bell rings for fourth period to end and Jack is not planning on going to 5th period, he is skipping class so he can do drugs with his friends. After, he goes through the rest of the day normally, he has been doing drugs for 3 years now. Since eighth grade. Imagine if his school had drug tests. He would be trying his best to quit so he doesn’t get found out. There are many reasons drug tests are helpful for student athletes. Drug tests for student athletes are effective because they keep students safe, they improve students behavior and they are supported by the fourth Amendment. Schools use drug tests to keep students safe. â€Å"We love and we do not want to lose you† (Guilty until†¦). The schools that use drug tests are trying to keep†¦show more content†¦One example of this is â€Å"If kids have nothing to hide they won’t have any problem taking a test†¦ The kids who protest may be the ones who need to be tested the most† (Put to. ..). This represents a change in behavior because if the students will not test there is a chance they do not want to be tested because they have been taking drugs and they will act strange when they are being talked to. Another example is â€Å"random drug tests discourage students from using illegal substances†¦Ã¢â‚¬ (Put them...). This represents a change is the students behavior because random drug tests will change their behavior to doing drugs in school because they will get caught by the urine test. One last example of drug tests changing students behaviors of students is â€Å"...10 percent drop in drug use over the past year† (Guilty until...). This represents a behavior change because when schools introduced drug tests 10 percent of adolescents stopped using drugs because they would be scared of getting caught. Some others believe however that drug tests are bad for students behaviors because they will be rude to all their teachers because they are worried ab out the drug tests. But that can be good because then teachers will have an idea of who is doing drugs and they can try to test them further Finally the fourth Amendment supports drug testing. â€Å"Of particular concern is the the rise in use of anabolic steroids, tranquilizers, and barbiturates†¦ non-medically†(PIAC). There are many drugs being used toShow MoreRelatedThe Importance Of Drug Testing In Schools1384 Words   |  6 PagesWhy should we drug test students in schools? Some seem to think drug tests could have a negative effect on students and their relationship with their community amongst their school, while others think drug tests should definitely find their way into the school system. Really, drug tests should be implemented into all school systems. Schools aren’t looking to punish students for going on the wrong track, rather they aspire to lead them back onto the correct way. 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Corporations and Financial Markets Law

Question: Discuss about the Corporations and Financial Markets Law. Answer: Introduction This case of ASIC vs. Adler is one of the most unique cases and also it is very complicated. The facts of the case are that in the year 2000, a $ 10million loan was given to a company named Pacific Eagle Equity Proprietary Limited. This loan was given by HIH Casualty and General Insurance Limited. This abovementioned payment was neither documented nor was it secured. PEE was headed by a person named Adler. He was also the trustee of Australian Equities Unit Trust. He was a substantial shareholder of the HIH and also he was the non-executive director of the company named as the Adler Corporation Limited. Williams was the director and also the Chief Executive Officer of HIH. In the same company mentioned before, Fodera was the director and finance controller (PWC, 2008). After the receipt of the loan, PEE had become the trustee of the Australian Equities Unit Trust. This loan of $10 million was then applied to the subscription of the HIHC shares. These shares were applied for the $10 million worth of the AEUT units. The shares of HIH were bought by PEE and these were for the worth of around $3.8 million. These shares were brought on the stock market. The shares were then sold at a loss recorded for about $2 million. These were sold by PEE and purchased afterwards by it. The HIH shares were purchased by PEE and this was undertaken to defraud the people in the stock market that the company is holding good terms with the investors of the company HIH. Various shares pertaining to the unlisted index in the companies related to the technology and communication were bought by PEE. These shares were bought from Adler Corporation for $4 million. All of these investments were made at a total loss. Also payment amounting to around $2 million was given to Adler. This payment was made under the trust by the AEUT. These transactions that were being carried without the knowledge of the board as no prior approvals were taken from the board. The shareholders neither had any idea of the ongoing in the company nor were the disclosure made to the committee related to the HIHs investments. No proper documentation of the papers of the loan was undertaken or any security was given. These obligations were not fulfilled with the reason, that if fulfilled the circumstances of the company would catch everybodys attention and that is what they did not hope for (Dunford, 2005). The issue in the court was that whether Adler breached any of his duties being the director of the company and whether the provisions of the Corporations Act, 2001 were breached. The case was brought by ASIC against Adler, Williams and Fodera as they had also contravened various section of the Corporations Act, 2001. Duties/Responsibilities Breached And Why The Duties Were Breached. Under Section 180 of the Act, the duty of a director or an officer, that is associated with the company, to act with care and diligence has been mentioned (Black, 2015). This section states that the duties have to be discharged with a reasonable and standard care. Also the duty needs to be upheld diligently. Executive directors are those employees of the company that work as the full time employees. These people are engaged in the daily work activities of the company and carry various responsibilities that are special in nature. They also are very knowledgeable as they know about the daily operations that take place in a company. On the other side, the non-executive directors involve with the company on a regular basis and they do the part-time job. In the present case, the managing director of the two companies, HIH and HHIC have contravened this section as he did not fulfill his duties. He was supposed to ensure the fact that before giving any loan to PEE, he should have maintained proper safeguards. Another person named Fodera also was the finance director of the firm named HIH. He failed to take up his duties as he did not pay heed to the importance of discussion which was to be had in lieu of the loan that was to be given to PEE. No disclosure of the intention was made by either of them. Under section 180(2) of the Act the business judgment rule has been mentioned. This section states that the director or any officer who makes the rule mentioned above would not be held liable in case he has made that judgment in which all the elements could be easily depicted. He would not be liable for the judgment under any common law or duties under equity, that is, duties pertaining to care and diligence (Hooper, 2011) . There must not be any personal interest of the person making the judgment. Good faith is to be mandatorily established. The directors get a safe protection due to this rule and therefore they can be protected from any personal liability too (Langford, and Ramsay, 2017). However, any of the three directors cannot take the plea of this defense as no proper safeguards were undertaken and Ader had a personal interest in the subject matter of the transaction. Section 181 of the Act states regarding the statutory duty to act in good faith and also regards must be had to the exercise of powers for a purpose that is proper (Redmond, 2013). In the present case, Adler had also contravened the section 181 wherein he had used all the transactions of HHIC, HIH and also PEE for the purpose that was not proper. Section 182 was also violated as there was an improper use of the position in this case (Redmond, 2013). This section mentions that those officers and employees of the company who do not properly use their powers or use them to gain the advantage for their own sake should be restricted. The court held that Adler had also contravened this provision of the Act as the transaction that was undertaken that is the loan of $10 million was given to PEE, however, afterwards this loan was itself used by him for his personal interest. The interest pertained to the fact that this arrangement of loan was undertaken to acquire the shares of HIH on the stock market. This led to increase in the price of the shares and helped his company, Adler Corporation to dispose of the shares before PEE could. PEE had incurred great losses due to this and therefore it had to resell those shares at a low price. Section 183 was also violated under this case. Section 183 stated regarding the duty of the director, to not to use the confidential information which he gets by virtue of his position. This kind of information is known as the insider information and therefore it can be used by a person in order to be benefitted by it (Gibson and Brown, 2012, pp. 254 to 265) Ciritcal Analysis of the Judgment All the three, Adler, Fodera and William were penalized heavily and had to pay compensation. Alder and Williams were disqualified too however Fodera was not (Rogers, 2017). It was upheld in this case that the directors should uphold their duties while dealing during the course of the employment. Firstly, the interest should be fully disclosed by them (Law Handbook, 2017). Also they should abide by the structure of the corporation that is the way mechanism selected has to be reported. They should abide by the arms length principle. Also one more thing has to be ensured that is conflicts should be avoided to the maximum level. According to Section 9 of the corporations Act, 2000, a director of the company is the person who is appointed for that position (Companydirectors, 2016). People who are not appointed in a proper manner can also hold this position. The duties of the director are coherent with their duties towards the shareholders. Therefore, the protection is to be awarded to the shareholders from the risk of the directors. They should not be defrauded or their interests should not be used for directors personal interests. Also officers of a corporation are included under the definition of the directors. These refer to the various executives who hold the positions at a senior level. A director could be the person who makes such decisions that affect the company at a substantial level. In this case, the director of HIH, Adler was an officer of the wholly owned subsidiary and this could be related to the definition of directors given under the section 9 mentioned above. He was not appointed in a proper manner but did play the role of the director. He was the one who, had participated in the decision making which affected the stakeholders of the company. Also he was one of the members of the investment committee of the HIH. The directors had contravened the duties which have been laid down under the Section 180, 180(2), 181, 182 and 183. As mentioned above these duties, were not fulfilled by the directors and therefore they were liable. According to section 180, no due care and diligence was taken by the directors of the company. According to Section 180(2), in the present case, the court had stated that all of the three directors had breached their duty of care under this section (Pearcewebster, 2017). This rule could be of no defense as Adler could not satisfy the fact that they did not have a personal interest in the investment of around $10 million that was made to PEE by HIHC. Williams also could not be protected under this rule as he did not uphold proper safeguards before giving the loan and also he had material interest in the transaction and he did not present any evidence that the judgment taken by him was in good faith. Fodera, cannot hide behind the veil of business judgment rule as the tran saction pertaining to PEE was not mentioned by him to the board of HIH or the investment committee. It was not a business judgment as per this section (Legg and Jordan, 2014, pp. 407). Also, according to Section 182, Adler could be said to have misused his position as the director of the two companies for his own interest. Williams was no less in gaining utmost advantage from his position as a director and he breached his duties. He tried to fetch unjust enrichment from the companies named HIH and HIHC. Also the court found out that Adler as a director of PEE had misused his position. He acquired a number of unlisted capitals and these he had got at the rate of the cost price. He did not have to obtain any of the independent valuations of these and got it at a lesser rate from the Adler Corporation itself. Adler knew at that time that each of the businesses were in losses and would finally collapse. Still he tried to exclude himself and the corporation from these kinds of business operations, that were not commercially viable (Company Directors, 2004). Section 260A of the Corporations Act,2001 states about the financial assistance. This section states that if any of the companies gives any assistance, at a financial level, to a person who would buyback his own shares, then this would be held prejudicial to the interests of all the stakeholders of the company (Plessis, McConvill and Bagaric, 2005, pp..125) Hence this is restricted under this section. Adler, in the present case, had contravened this section. HIHC was prejudiced as financial assistance was provided to PEE and therefore due to this financial assistance, shares were acquired in HIH. The entry into the unit trust arrangement was made subsequently and the trust deed lacked any proper safeguards. Also, the arrangement that was made was contentious. HIHC acquired various rights under the transaction. However, these were deceptive as the rights were materially of a lesser value as against the advance of $10million that was made. This kind of arrangement was made knowingly so as to deceit the stakeholders of the company and therefore the transaction made were wholly one-sided (Cassidy, (eds.) 2006, pp. 133-134). Arms length exception was also used in this case. Section 208 of the Act states that whenever a company seeks to give financial benefit to a party that was related to it then, the approval of the shareholders is needed (Minterellison, 2011). However, the arms length principle is an exception to it. The terms of the $10 million payment were not made according to this principle and this therefore violated Section 208. The terms were not consonant with the principle as these were not at all adequate and therefore did not protect the interests of the company. Also no reports of the independent experts were taken into account. No proper mechanism or method was established by which it could be shown how the money was to be spent by the HIH. References Minterellison, 2011. Why A Policy On Related Party Transactions Makes Good Business Sense, [ONLINE] Available At: Http://Www.Minterellison.Com/Pub/NL/201109_Chqd/ [Accessed On 4 Jan 2017] Redmond, P. 2013. Corporations And Financial Markets Law, (6th Ed), Sydney: Thomson Reuters, P. 432. Black, S., 2015. The Responsibilities of Becoming A Director, [ONLINE] Available At: Http://Www.Codea.Com.Au/Publication/The-Responsibilities-Of-Becoming-A-Director/?Utm_Source=MondaqUtm_Medium=SyndicationUtm_Campaign=View-Original [Accessed On 4 Jan 2017] Company Directors, 2016. What Are The Duties Of Directors? [ONLINE] Available At: Http://Www.Companydirectors.Com.Au/Membership/The-Informed-Director/What-Are-The-General-Duties-Of-Directors [Accessed On 4 Jan 2017] Law Handbook, 2017. General Duties of Directors - Corporations Act 2001 (Ctth), [ONLINE] Available At: Http://Www.Lawhandbook.Sa.Gov.Au/Ch05s01s03s02.Php [Accessed On 4 Jan 2017] PWC, 2008. A Guide To Directors Duties And Responsibilities For Non-Listed Public Companies And Proprietary Companies In Australia, [ONLINE] Available At: Http://Etraining.Communitydoor.Org.Au/Pluginfile.Php/608/Course/Section/95/Guidedirectors_Apr08.Pdf [Accessed On 4 Jan 2017] Gibson, B. And Brown, D., 2012. Asics Expectations Of Directors, UNSW Law Journal, 35(1), Pp. 254 To 265. Legg, M. And Jordan, D.,2014. The Australian Business Judgment Rule After Asic V Rich: Balancing Director Authority and Accountability, Adelaide Law Review, 34, Pp. 407. Langford, R., T. and Ramsay, I., M. 2017. Conflicted directors: What is required to avoid a breach of duty? [ONLINE] Available At: https://law.unimelb.edu.au/__data/assets/pdf_file/0006/1709502/13-Conflicteddirectors-whatisrequiredtoavoidabreachofdutyJnlEquity20142.pdf [Accessed On 4 Jan 2017] Hooper, M., 2011, The Business Judgment Rule: ASIC v Rich and the reasonable-rational divide, [ONLINE] Available At: https://epublications.bond.edu.au/cgi/viewcontent.cgi?article=1021context=cgej [Accessed On 4 Jan 2017] Rogers, P.,2017. Ethical Obligations And The Manager: Case Studies, [ONLINE] Available At:https://legal.thomsonreuters.com.au/product/AU/files/720502412/chapter_13.2_case_studies.pdf [Accessed On 4 Jan 2017] Dunford J., 2005. The Adler judgement, , [ONLINE] Available At: https://www.smh.com.au/news/Business/The-Adler-judgement/2005/04/14/1113251721186.html [Accessed On 4 Jan 2017] Cassidy, J.,(eds.) 2006, Concise Corporations Law, (5th edition) New South Wales: Federation Press, pp. 133- 134. Plessis, J.D., McConvill, and J., Bagaric, M., 2005. Principles of Contemporary Corporate Governance, New York: Cambridge University Press, pp. 125. Pearcewebster, 2017. Directors Duties of Skill, Care and Diligence, [ONLINE] Available At: https://www.pearcewebster.com.au/commercial-law/commerical-law directors-duties/ [Accessed On 4 Jan 2017] Company Directors, 2004. The AdlerWilliams cases on appeal Law Reporter [ONLINE] Available At: https://www.companydirectors.com.au/director-resource-centre/publications/company-director-magazine/2000-to-2009-back-editions/2004/february/the-adlerwilliams-cases-on-appeal-law-reporter [Accessed On 4 Jan 2017]