Free Essays on Internet As Vehicle For Pedophiles

Web AS VEHICLE FOR PEDOPHILES and WHAT CAN WE DO? The mid-nineteen eighties end up being a verifiable time of hugeness in which innovation in the extent of PCs was quickly progressing. By nineteen-eighty four, â€Å"the area name framework was set up that lets amazon.com be amazon.com and not 208.216.182.15† . With this framework set up, the web was a rising power of data. By nineteen-eighty eight there were ninety thousand PCs connected to the web and by mid nineteen-ninety eight the quantity of host PCs developed to more than thirty-6,000,000 . Moreover, in mid nineteen-ninety three, there were fifty Web locales in the entire world and by mid 2,000 the quantity of Web destinations had developed to surpass fifty million . With this overarching headway of this data organize called the Internet, the substance of society will everlastingly be modified. In spite of the fact that there are various focal points to the Internet, concerns are inexhaustible from people in general about the contrary viewpoints emerging from the Internet. One of significant concern is pedophiles and their utilization of the innovation. Right off the bat, a â€Å"pedophile† is an individual who shows pedophilia; â€Å"pedophilia† is the sexual want coordinated towards kids . As should be obvious, the tremendous and borderless Internet is the ideal vehicle for pedophiles to work. Generally, PC systems help pedophiles to draw in others like them to trade counsel and data and discover pictures of youngsters engaged with sexual acts . To a further degree, the Internet gives a road to extraordinary pedophiles (youngster molesters) to meet with helpless kids and improve the probability of sexual maltreatment of kids . Pedophiles utilize the Internet as their essential vehicle, particularly when by nineteen-eighty six all the customary techniques for getting youngster sex entertainment had been immovably shut . This vehicle of the Internet can be separated into a few regions, includ... Free Essays on Internet As Vehicle For Pedophiles Free Essays on Internet As Vehicle For Pedophiles Web AS VEHICLE FOR PEDOPHILES and WHAT CAN WE DO? The mid-nineteen eighties end up being a verifiable time of essentialness in which innovation in the extent of PCs was quickly progressing. By nineteen-eighty four, â€Å"the space name framework was built up that lets amazon.com be amazon.com and not 208.216.182.15† . With this framework set up, the web was a rising power of data. By nineteen-eighty eight there were ninety thousand PCs connected to the web and by mid nineteen-ninety eight the quantity of host PCs developed to more than thirty-6,000,000 . Moreover, in mid nineteen-ninety three, there were fifty Web locales in the entire world and by mid 2,000 the quantity of Web destinations had developed to surpass fifty million . With this common progression of this data organize called the Internet, the substance of society will always be changed. In spite of the fact that there are various points of interest to the Internet, concerns are plentiful from the general population about the negative viewpoints emerging from the Internet. One of significant concern is pedophiles and their utilization of the innovation. Right off the bat, a â€Å"pedophile† is an individual who shows pedophilia; â€Å"pedophilia† is the sexual want coordinated towards youngsters . As should be obvious, the immense and borderless Internet is the ideal vehicle for pedophiles to work. Generally, PC systems help pedophiles to draw in others like them to trade guidance and data and discover pictures of youngsters associated with sexual acts . To a further degree, the Internet gives a road to extraordinary pedophiles (youngster molesters) to meet with powerless kids and improve the probability of sexual maltreatment of kids . Pedophiles utilize the Internet as their essential vehicle, particularly when by nineteen-eighty six all the customary strategies for getting youngster erotic entertainment had been immovably shut . This vehicle of the Internet can be separated into a few zones, includ...

Christian Evaluation of Current Approaches Essay

In the book â€Å"Reviewing Leadership: A Christian Evaluation of Current Approaches†, Banks, Robert and Bernice Ledbetter attempt to depict the procedure of authority and talk about its religious viewpoints from Christian point of view. The creators really consider various subjects and data identified with various fields to reach an appropriate determination. Additionally all through their book they likewise endeavor to guarantee that everything worth talking about has been examined giving legitimate significance to all issues of the general public. Above all else the creators underscore that the subject of initiative is a significant theme worth talking about and they investigate this theme from various view focuses. The book involves six significant sections. The principal section is about the developing enthusiasm for administration in present days. In this section the writers start from the earliest starting point making the perusers mindful of various related definitions, causes and numerous significant issues. In the second part the creators portray the distinctive Biblical viewpoints of the authority. In this section they additionally examine other past and existing points of view and attempt to give the perusers the changing situation of administration and the services of the everyday citizens. In the third section they portray distinctive developing ideas including strict degree of initiative. At this setting the writers help the perusers to accept the way that strict practices may assist with creating individuals who will significantly regard the standards of the socialized society. In the fourth part the creators strikingly depict the diverse mainstream ways to deal with initiative. Aside from the mainstream draws near, various ways to deal with administration which depend on the confidence of the individuals are likewise talked about in this piece of the book. In the following part, one of the most significant subjects, the various methods of performing authority have been talked about. In such manner the creators notice that a pioneer must be straightforward to the everyday citizens in their activity of administration. In addition the procedure of administration ought to be continued with veracity, honesty to the average citizens whom they speak to and by and by the pioneers must serve the ordinary citizens with trustworthiness. In the 6th and last section the creators portray the execution and the various results of Christian administration through investigating a few cases including the instances of Frank Buchman, Soren Kierkegaard who were driving figure in contemporary perspectives. As indicated by the writers, the book is â€Å"†¦a product of scriptural examination and reflection on our own encounters. †1 Actually, in the assessment of the essayists, the book depends on the contemporary compositions of various individuals and ends made by dissecting the lives of some commendable Christian pioneers. Over all the significant end, got from the book, is that the authority is about the general advancement surprisingly of the general public and not for the improvement of a specific gathering of individuals of society. The interrelationship among religion and legislative issues turns out to be increasingly mind boggling in present days however one thing which can’t be denied that both religion and governmental issues are for the total improvement of the general public and for lessening the sufferings of ordinary citizens regardless of their social height. So far what we have examined prompts the way that genuine initiative in legitimate execution of services or setting up a strict framework by spurring an enormous number of individuals can be of incredible assistance to build up a country. 1. Banks, Robert and Bernice Ledbetter, Reviewing Leadership: A Christian Evaluation of Current Approaches (Grand Rapids, MI: Baker Academic, 2004), 11.

You can get anything you want

You can get anything you want… Its been hectic for past few days; I had my first German vocabulary test yesterday and I had to learn like ein bazillion words for that, and Ive also been really busy working on problem sets. Itll just be another week or two before I get back in the swing of things. Incidentally, Freshman have been so adorable this week struggling through their first 5.112 and 8.01 problem sets this week, working in huge, huge study groups until the middle of the nightit makes me nostalgic for my own Freshman year. So, while Id really like to write a really long and complicated blog entry with twenty-seven eight-by-ten color glossy photographs with circles and arrows and a paragraph on the back of each one explaining what each one was, I can only offer you this news, which has me excited beyond belief right now: Alices Restaurant 40th Anniversary Massacre Tour However, the good news is that it should be a fairly eventful weekend; MIT has a student holiday on Monday that the professors always seem to forget about, so they didnt assign a correspondingly larger workload. So, check back in a few for some more a more impressive sketching of my life. Peace!

A Brief History of Cote DIvoire

Our knowledge of the early history of the region now known as Cà ´te dIvoire is limited—there is some evidence of Neolithic activity, but mush still needs to be done in investigating this. Oral histories give rough indications of when various peoples first arrived, such as the Mandinka (Dyuola) people migrating from the Niger basin to the coast during the 1300s. In the early 1600s, Portuguese explorers were the first Europeans to reach the coast. They initiated trade in gold, ivory, and pepper. The first French contact came in 1637—along with the first missionaries. In the 1750s the region was invaded by Akan peoples fleeing the Asante Empire (now Ghana). The established the Baoulà © kingdom around the town of Sakasso. A French Colony French trading posts were established from 1830 onwards, along with a protectorate negotiated by the French Admiral Bouà «t-Willaumez. By the end of the 1800s, the borders for the French colony of Cà ´te dIvoire had been agreed with Liberia and the Gold Coast (Ghana). In 1904 Cà ´te dIvoire became part of the Federation of French West Africa (Afrique Occidentale Franà §aise) and run as an overseas territory by the Third Republic. The region transferred from Vichy to Free French control in 1943, under the command of Charles de Gaulle. Around the same time, the first indigenous political group was formed: Fà ©lix Houphouà «t-Boignys Syndicat Agricole Africain (SAA, African Agricultural Syndicate), which represented African farmers and landowners. Independence With independence in sight, Houphouà «t-Boigny formed the Parti Dà ©mocratique de la Cà ´te dIvoire (PDCI, Democratic Party of Cà ´te dIvoire)—Cà ´te dIvoires first political party. On 7 August 1960, Cà ´te dIvoire gained independence and Houphouà «t-Boigny became its first president. Houphouà «t-Boigny ruled Cà ´te dIvoire for 33 years, was a respected African statesman, and on his death was Africas longest-serving president. During his presidency, there were at least three attempted coups, and resentment grew against his one-party rule. In 1990 a new constitution was introduced enabling opposition parties to contest a general election—Houphouà «t-Boigny still won the elections with a significant lead. In the last couple of years, with his health failing, backroom negotiations attempted to find someone who would be able to take over Houphouà «t-Boignys legacy and Henri Konan Bà ©dià © was selected. Houphouà «t-Boigny died on 7 December 1993. Cà ´te dIvoire after Houphouà «t-Boigny was in dire straits. Hit hard by a failing economy based on cash crops (especially coffee and cocoa) and raw minerals, and with increasing allegations of governmental corruption, the country was in decline. Despite close ties to the west, President Bà ©dià © was having difficulties and was only able to maintain his position by banning opposition parties from a general election. In 1999 Bà ©dià © was overthrown by a military coup. A government of national unity was formed by General Robert Guà ©i, and in October 2000 Laurent Gbagbo, for the Front Populaire Ivoirien (FPI or Ivorian Popular Front), was elected president. Gbagbo was the only opposition to Guà ©i since Alassane Ouattara was barred from the election. In 2002 a military mutiny in Abidjan split the country politically—the Muslim north from the Christian and animist south. Peacekeeping talks brought the fighting to an end, but the country remains divided. President Gbagbo has managed to avoid holding new presidential elections, for various reasons, since 2005.

Essay about The Nullification Crisis - 1585 Words

February 22, 2013 The Nullification Crisis The Nullification Crisis was a revolt by the citizens against Andrew Jackson and the Union, whereby they sought liberty and the state of being free, including various social, political, and economic privileges. This attempt to revolt against Jackson failed, and their seceding from the country was not granted. In these efforts to secede, they sought liberty and worked together as a state to gain what they believed to be free and include various privileges they rightfully have. The Nullification Crisis displayed the attempt of the citizen’s to achieve the securing of the blessings of liberty, yet the citizen’s attempt failed. In 1819, Andrew Jackson was elected as President of the United States.†¦show more content†¦He pleaded Henry Clay, an old friend, to draft a solution with him. Clay developed a compromise proposal, which lowered the high tariffs by ten percent over eight years. The Compromise Tariff of 1833 barely passed through Congress, but it significantly changed the tariff. These new rates were not nearly as low as the Southerners had hoped they would be, but it was a better compromise than the Force Bill had offered. South Carolina’s legislature voted to recede their efforts to nullify the tariff acts, but they did attempt to nullify the Force Bill. Even though their nullification of the Force Bill was insignificant, it allowed South Carolina to feel slightly victorious. Therefore, it is apparent that it is the citiz en’s job to secure the blessings of liberty. The citizen’s began to take action to secure their blessings of liberty prior to the Nullification Crisis, when they attempted to pass the Tariff of 1828 through Congress in hopes to aid Jackson’s re-election. Due to Jackson’s popularity, he was re-elected even without the help of the tariff. Yet the tariff was passed in 1828, and the citizen’s made a firm effort to nullify the tariff as soon as it was enacted. They believed they had the right to nullify the tariff, which sought their own privileges in liberty. The citizens further pushed for the nullification by trying to pass this though South Carolina’s legislature, but another group of citizens seeking to secure theirShow MoreRelatedThe Nullifying Crisis : The Causes Of The Nullification Crisis1552 Words   |  7 Pages The Nullification Crisis of 1832 is one of the crises that would eventually lead to the Civil War. Following the suffering o f an economic downturn throughout the 1820s, the United States government passed several new tariffs. When the Tariff of 1828 was passed by the Congress of the United States on May 19, 1828, it sparked the debate over states’ rights and highlighted the growing sectional difference between the South and the North in America. That Tariff of 1828 raised taxes on imported manufacturedRead MoreThe Nullification Crisis and Its Effects on the United States639 Words   |  3 Pages The Nullification Crisis, which transpired under Andrew Jackson’s administration created a controversy not only during its time, but also in the years to follow and ultimately was one of the many causes of the Civil War years later. The Nullification crisis soon developed in the early 1830’s when the state of South Carolina began to have issues with the protective tariff (which was designed to protect the industry in the northern United States by taxing imports). At this point in history,Read MoreJackson vs. Calhoun and the Nullification Crisis1420 Words   |  6 Pagesthe Nullification Crisis. Nullification is the refusal of a state to recognize a federal law within its boundaries and deem that law unconstitutional. In this case, South Carolina, led by John C. Calhoun, refused to recognize the protective tarif fs in 1828, and 1832, saying that they benefited the North and injured the South. At this point in time, the American system of government was fairly new and the struggle between state and federal power was in full swing. Towards the end of the crisis, CalhounRead MoreWhat Really Caused The Nullification Crisis Of The South Carolina Economy1238 Words   |  5 Pagesbelieved that if he developed the Theory of Nullification people in his home state would view him differently. The Theory of Nullification is the idea that states (unions) have the rights to void any law that is created by the government that is seen unconstitutional. States are the foundation of the Union, so they have the power to refuse any unconstitutional laws, and really states usually have the final say. What really caused the Nullification Crisis were many series of Protective Tariffs. ProtectiveRead MoreWhat Really Caused The Nullification Crisis Of The South Carolina Economy990 Words   |  4 Pagesbelieved th at if he developed the Theory of Nullification people in his home state would view him differently. The Theory of Nullification is the idea that states (unions) have the rights to void any law that is created by the government that is seen unconstitutional. States are the foundation of the Union, so they have the power to refuse any unconstitutional laws, and really states usually have the final say. What really caused the Nullification Crisis were many series of Protective Tariffs. ProtectiveRead MoreEssay on state nullification1569 Words   |  7 PagesImpact of a State’s Right to Nullification nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;nbsp;Impact of a State’s Right to Nullification nbsp;nbsp;nbsp;nbsp;nbsp;The impact of a state’s right to nullification can ultimately cause a great deal of damage to the country that it resides in. To describe the impacts one would need to take a look back into history when the Nullification Crisis took place. South CarolinaRead MoreThe Tariff Laws782 Words   |  3 Pagesincluding Calhoun, the vice president and a politician from South Carolina. Later he wrote a nullification doctrine to express his opinions on the tariff. The nullification crisis greatly affected the growth of states’ rights over federal power. Because of the nullification crisis in South Carolina there were even thoughts of secession in the early 1830’s. â€Å"The Nullification Crisis was a sectional crisis during the presidency of Andrew Jackson that arose when the state of South Carolina attemptedRead MoreThe Era Of The Middle Class882 Words   |  4 Pagesthe people and not wealthy elites. He felt it was better for the country on bring in new fresh faces. Giving out political jobs as rewards became known as the â€Å"spoils system.† Another political reform on the table Jackson had to fix was the Nullification crisis. Jacksonian supporter’s main goal was to ruin John Quincy Adams presidency. They were still angered at his victory over Andrew Jackson in the 1828 election. The plan was to push a bill through Congress that would impose taxes on solely manufacturedRead More Andrew Jackson : True American Essay1579 Words   |  7 Pagesprides itself upon today. His Presidency was plagued with controversy, but President Jackson used his power as President to unite a sometimes-divided nation and establish a precedent of power for future American leaders. States rights, the nullification crisis, the spoils system, Indian removal and banking policies were all controversies which brought forth strong rivalry and resentment throughout his years as president, but Jackson’s strong will and assertiveness got our country through these timesRead MoreThe Era Of The Common Man1011 Words   |  5 Pagessomething Ja ckson liked to approve of nor let happen at all. The Nullification Crisis with John C. Calhoun shows how opposed Jackson is to reforms. In 1828, Calhoun created the nullification doctrine that held the idea that states should have the rights to nullify unconstitutional laws. Calhoun wanted to use the doctrine to nullify the 1816 tariffs that he believed stagnated the South Carolina economy. In 1832, the nullification became a crisis when South Carolinians protested over a congressional bill

Resistance of Change in Chinese Society in the Beginning of 20’s Century Free Essays

Resistance of Change Ding Ling’s â€Å"A Day†, Lu Xun’s â€Å"A Madman’s Diary,† and Yu Dafu’s â€Å"Sinking† are all works that have been written in the time of a crucial change in China. Although the stories are fictional, the writers manage to reflect and correlate their characters to the current state of their homeland. Reading the listed works we see that its characters possess many common traits such as suffering, humility, depression, and much love and patriotism for China. We will write a custom essay sample on Resistance of Change in Chinese Society in the Beginning of 20’s Century or any similar topic only for you Order Now The authors use character’s personal difficulties, to illustrate how complex it is for China to abolish its conservative, deep-rooted, traditional ways for new ones. In â€Å"The Diary of a Madman† by Lu Xun, we see a character that is in a state of constant paranoia. He is considered to be a madman by his immediate society that is greatly influenced by old Chinese morals and traditions of imperialism and Confucianism. He believes that his social circle practices cannibalism and sooner or later he will be eaten. On numerous occasions he questions the reasons behind this immoral practice which he believes is real. Although his actual perceptions of his surroundings might be erroneous in reality, we notice a valid metaphoric meaning in his view; cannibalism as suppression of people. He doesn’t understand why people are not willing to give up their old customs of cannibalism. He claims that some who used to practice cannibalism in the past realized its immorality and stopped, yet most continue to live by old traditions. He argues immorality of old traditions should be exemplifying the west as a By illustrating this inability of social change the character demonstrates the society as one of great tradition. The character’s desire for change illustrates the revolutionary times that China was undergoing at the time. He wanted the Chinese society to abandon its traditional beliefs which were constraining their liberality. Order, discipline, and oppressive imperial traditions of their background influenced by Confucianism strongly shaped their beliefs and habits, making it difficult to accept new modern principles. The character feels helpless while observing his society’s challenge to change. Although we see the character’s distress, his connection and love towards China is illustrated in his last words of the diary. Declaring to â€Å"Save the Children†, the character conveys his patriotic beliefs in times of agony. We see that regardless of social resistance to change the characters’ hope of a better future for China persists, illustrating the great patriotism that is integrated in Chinese society and culture. In Ding Ling’s story â€Å"A Day,† we also see a character whose emotional state correlates to her surrounding society. In the story, a young woman lives in a poor part of a metropolis city, â€Å"under the jurisdiction of a few imperialist nations†(12). She despises this split society, which is made of â€Å"fat bellied† capitalists and the filthy poor working class that labors for the former. Observing the miserable working class routinely occupied in their â€Å"back-breaking† tasks makes her feel depressed. She pities them and wishes she could help them realize that they deserve a better living. She thinks that if only she could influence those people, to open their eyes to a better future, she would improve their lives. She makes an attempt to improve her maid’s way of thinking, trying to melt her gloom, but soon feels anguished herself. When she considers people’s â€Å"ignorant ways of thinking and their purely selfish desires† she hopelessly gives up. The lives of those people are wretched and their minds are numbed, they are stripped of all hope and ideas as they eke out a living from one day to the next†. She sees her society suffering in this â€Å"meaningless existence† and not being able to change. This resistance to change irritates her greatly. She realizes that the mentality of these people is degraded by imperialisti c domination for many years and is difficult to abandon. Those similar self degrading traits can also be detected in the character. Her immediate company that visits her daily takes advantage of her humbleness and overwhelms her with their sentiments regarding the ills of China. Her submissiveness restrains her desire to argue her position and take any measures. Depressed, she wants to isolate herself from everybody and sink in her daydream; the only delight of her day. We see a reflecting relationship between society and the character. Society makes her depressed and she is hopeless of change. Dreaming about a better life, she is still not able to take any actions that would help her break through this cycle of misery. While in the past two stories, we see characters that were disturbed by difficulties of change in their societies, in â€Å"Sinking† by Yu Dafu the main character is troubled by his personal complexities. Various emotional problems such as loneliness, hatred, fear, sexual frustration, paranoia, and other self degrading traits lead him to a suicide. A Chinese native and a patriot, he is influenced by Chinese traditional morals and beliefs that suffocate his desire to acquaint to a new environment in Japan, where he attends school as a foreign student. Discipline and order induced in him by Confucianism of imperialistic China restrain his adaptation in this new liberal setting. We see that his relationship with his new society is hurting because of his long-established morality. He feels that his schoolmates reject him, but his paranoiac attitude and reserved appearance prevent him from making any friends. Failing to make an attempt to connect with the Japanese students, whom he considers his enemies, he loathes them even more. He is resentful that his beloved China is in time of chaos while Japan is thriving and that distances him from his surroundings even more. He is sexually frustrated and unable to connect with girls. He tries to physically ease his frustration but feels sickened and considers it to be immoral. Having been influenced by Confucian tradition, he constantly tries to discipline and improve himself, yet his attempts are always overwhelmed by new desires and beliefs. Influenced by western literature, he finds peace when he recites poetry written by romantic writers and spends his sole time appreciating nature. This aspiration of western culture and liberal thinking constantly competes with the previous morality of the character. His personal conditions and experiences represent, and are the effects of, the undergoing struggles of Chinese society during the time of political chaos. After the overthrow of the Qing Dynasty, China did not have a real government. The society feels rejected, because other countries are not willing to step in and help establish a new administration. Although people anticipate a new liberal government, soon another Emperor takes office. Moral and traditional philosophy infiltrated by Confucianism made the Chinese culture humble and fearful just like the character’s personality. While manifesting many strong feelings of hate, sorrow, and frustration, the character is unable to take any measures to change his perceptions. In the end of the story the character commits suicide, stating; â€Å"O China, My China, you are the cause of my death! I wish you could become rich and strong soon!†¦ Many, many of your children are still suffering. † We can see that regardless of all the struggles he went through, the character is a great patriot of his country, and while he does not see any hope for his own healing, his sorrow and death symbolizes his hope for his Country and future generations. Contradiction We see that the characters in all three stories have various emotional and psychological traits that reflect China in its time of turmoil. We also see that all characters ultimately demonstrated great patriotism towards their country. In order to understand the reasons behind those qualities we have to observe a number of factors from authors’ perspective. Lu Xun, Yu Dafu, and Ding Ling were all authors that were greatly influenced by the revolutionary times in China and their stories illustrate, in part, their own feelings towards their society. The overthrow of the emperor, in the beginning of twenties century brought a new wind of change. People started to believe that new times are about to form. Western culture and political approach started to inspire people to believe that a better future is around the corner. The characters in our stories help us better to understand the circumstances and the condition of Chinese society in those crucial times. At first we observe Lu Xun’s â€Å"A Diary of a Madman† in which we see a man that is perceived as a madman by his society. Although in the story it might be so, we can identify a certain metaphor that symbolizes the character’s wisdom. While cannibalism was actually practiced in some instances in Imperial China, Lu Xun drew a picture that resembled the old imperialistic China that suppressed its society, â€Å"eating† their liberty. Imperialism vanished by the time all three stories have been written, yet society is still unable to change their old mentality. This resistance to change because of old settled-in traditions can also be seen in both â€Å"A Day† and â€Å"Sinking. And yet Ding Ling, similar to Lu Xun, in her story portrays mainly the difficulties of social change, Yu Dafu illustrates them on an individual that is also infected with old traditions overpowering his wish for change. Society formulates individuals that in turn makeup the former. The relationship between them is inevitable. It appears that all authors conveyed their personal outlook of their society through their stories. Resistance to change might have been the most difficult obstacle China had to overcome for a better tomorrow, and the offered stories showed us the disturbances of individuals in relation to their society. How to cite Resistance of Change in Chinese Society in the Beginning of 20’s Century, Papers

Principles of Contemporary Corporate Governance †MyAssignmenthelp

Question: Discuss about the Principles of Contemporary Corporate Governance. Answer: Introduction The case of Australian Securities and Investments Commission v Adler (2002) 168 FLR 253, 364; 41 ACSR 72, acts as a reminded to all the directors and the companies, that they have the responsibility of making certain that there is a need for an effective corporate governance framework (Hooper, 2011). This framework is needed to protect the companies from any improper actions, which can be taken by the director of such a company. There is a need to have ample amount of checks and balances to guarantee that the system is not breached or bypassed with ease (Paolini, 2014). This was a very complicated, yet unique case, involving the breach of a number of duties covered in the governing act of Corporations Act, 2001 (CA). Some of the duties breached in this case were related to the duty of care and diligence, duty to not use the information in an improper manner, and the duties of the director (Baxt, 2005). In the following parts, this case has been discussed using the IRAC format. Though, before that is carried on, a discussion has been made on the background of this case. In this particular case, an undocumented and unsecured payment to the amount of $10 million loan was made by HIHC (HIH Casualty and General Insurance Ltd) to PEE (Pacific Eagle Equity Pty Ltd). Adler controlled this company PEE ad this in turn, was the trustee of AEUT (Australian Equities Unit Trust). Alder was both the substantial shareholder of HIH and the non-executive director through the Adler Corporation Limited. PEE became AEUTs trustee after the loan was received by it. Afterwards, the $10 million loan to PEE by HIHC was applied for the subscription of HIHC, for $10 million worth of AEUT units (Justis, 2017). A purchase was made by PEE for the shares of HIH, which were listed on the stock market, to the value of $4 million. And these shares of HIH were then sold by PEE at a loss of $2 million. The shares of HIH were purchased by PEE to give an untrue impression to the entire stock market that the investors of HIH were gaining due to the good work being varied on in the company. A purchase was also made by PEE from Adler Corporation towards their unlisted shares worth $ 4 million, of the technology and communication companies. This entire purchase was a complete loss based investment (Australian Institute of Company Directors, 2017). Under the trust, a value of $ 2 million was given by AEUT to Adler. However, the board had no knowledge about these transactions and an approval of the shareholders was also not done. This was in addition to an absence of disclosure to the board, along with the same to the investment committee of HIH. There was also a lack of the proper documentation and security for the loan given. The rationale for the absence of these was to avoid an attention being drawn by the other directors of HIH (Cassidy, 2006). Whether there has been a breach of directors duties on part of Adler, and other directors and officers, or not? Section 9 of the Corporations Act, 2001 (Cth) defines who can be deemed as a director of the company. As per this definition, an individual who is appointed to work as a director or an alternative director, irrespective of the name given to their position, is a director of the company. Even though an individual may not be appointed as a director, they can still act as the director of the company. This is the case of de factor director, where the individual acts in the directors position; or the shadow director, on whose instructions, the board is accustomed to act. There has to be an existence of the duties of directors to hold the individual responsible and to safeguard the shareholders. The officers of the company are also defined through this section, and involve such executives, who hold the senior position in the company, at the board level. They have the power of affecting the business of the company, either wholly or partly. And hence, have the same duties as the directors of the company (Federal Register of Legislation, 2017). Section 180(1) of CA puts forward the duty on the directors, along with the other officers of the company to use their authority and discharge their obligations in a manner which shows diligence and care, which any prudent individual would undertake in similar situation and with similar position. The executive directors of the company are involved in the daily management of the company. Hence, they have special responsibilities in their position; along with that they have a knowledge pertaining to the companys operations. Alternatively, the non-executive directors indulge in part time work for the company and have regular, but not daily based involvement with the company (Australasian Legal Information Institute, 2017a). Section 180(2) of this act provides that the directors, along with the other officers of the company, when make a business judgment rule, cannot be held accountable for the judgment undertaken by them as per the equitable, statutory or common law duty of care and diligence, where the elements can be easily established. These elements relate to taking the decision for a proper purpose and in good faith, where there is an absence of material personal interest in the issue of judgment. Moreover, there is a need to be informed about the matter on which the decision is being taken and undertaking the reasonable steps to ensure that the decision is reasonable and that the decision is in the best interest of the company (WIPO, 2015). Through these provisions, the directors are given a protection from the personal liability in the matter where they have taken a business judgment in best interest of the company and in good faith. The rationale behind the same is that certain decisions may turn out to be loss making and other as profit making, even when both are made in a rational and honest manner (Gonski, 2015). Section 181 of this act puts a statutory obligation on the directors, along with the other officers of the company, to act in the best interest, good faith and for proper purpose, while using their authority and discharging their obligations (Armstrong Lawyers, 2007). For establishing what can be deemed as interest, good faith or the proper purpose, the approach of a reasonable individual in same situation is undertaken. For instance, when a conflict of interest occurs and the directors deals with the matter on behalf of the company also, and fails to disclose the material interest, a breach of this section would take place (ICNL, 2017). As per section 182 of CA, the employees and the officers are prohibited from using the position in the company, which is detrimental for the company or which results in an advantage being gained for them or for someone else. Section 183 contains the provisions regarding the proper use of information. as per this section, the officers and directors of the company are forbidden from making a misuse of the information of the company which is detrimental for the company or which results in an advantage being gained for them or for someone else (Plessis, Hargovan and Bagaric, 2010). Section 208 of CA provides that an approval of shareholders is needed when a financial benefit is discharged towards a related party. The only exception is when the same is done at arms length (IMF, 2012). In this particular case, Adler is the director of the company as per the definition given in section 9 of the act, even though he had not been appointed as being an officer or director of the company. The decision making on part of Adler can be seen from his role in the subsidiary, the holding as being the director and as being the investment committees member and his decisions impact the business of the company. He was constantly informed about the fundamental of the business, which made him the director of the company (Australasian Legal Information Institute, 2017b). William was the HIH and HIHCs managing director and there was a contravention of provisions of 180(1) on his part. This is because he failed to protect HIHC while the loan was being given to PEE. HIHs finance director Fodera breached this section as he did not discuss the proposal for giving the loan to the amount to $ 10 million to PEE, or to the investment committee and board of HIH. So, being the executive directors of the company, there was a breach on part of William and Fodera, as they both fell short in carrying their role in a proper manner (Australasian Legal Information Institute, 2017b). Regarding section 180(1), there had been a breach on part of Williams, Fodera and Adler as they failed to take the requisite care. Moreover, reliance could not be made by the three of them as per section 180(2) of this act. This is because for Adler, this rule could not be applied on him. The reasons for this being his conflict of interest position, due to the decision for investing $10 million in PEE from HIHC. For Williams, this rule could not defend him as there was a failure on his part, to make certain that the proper safeguards had been applied and there was no business judgment undertaken by him for satisfying section 180(3). Even if the same is considered as a business judgment, the presence of material personal interest renders it useless. He failed to act for a proper purpose or in good faith to satisfy the obligation of section 180(2) (a) (Armstrong Lawyers, 2007). Fodera also cannot use this defense as he failed to refer transaction undertaken between PEE and HIH to the b oard or investment committee of HIH (Australasian Legal Information Institute, 2017b). In this case, there was also a contravention section 181(1) as Adler did not discharge his obligations or use his authority in good faith of the company, or in the best interest of the same. This is evident from the transactions which took place in PEE, HIH and HIHC, where there was an improper use, for his personal interest (Australasian Legal Information Institute, 2017b). There was also a contravention of section 182 here on part of Adler. This stemmed from the arrangement made to HIHC to PEE regarding the $10 million loan, which was later on used for making an acquisition of the shares of HIH from the stock market. The sole purpose of undertaking this transaction was to support the increase of price in the shares of HIH and to later sell the same owned by Adler Corporation, before these could be sold off by PEE. This resulted in a total loss of investment on part of PEE regarding the share of HIH (Australasian Legal Information Institute, 2017b). Adler has made an improper use of his position by being HIHs and PEEs director, and the officer of HIHC for putting Adler Corporation in an advantageous position. There was also a breach on part of Williams for being director in HIHC and HIH as per section 182 for helping Adler in putting Adler Corporation in an advantageous position. The reason was that the loan payment was made in absence of the approval of investment committee of HIH, which was required on his part as per the investment guidelines of HIH (Australasian Legal Information Institute, 2017b). Adler wrongly used his position as being PEEs director for the acquisition of unlisted capital from Adler Corporation at a cost price where an independent valuation was not taken for these ventures. Due to the success of these transactions, both Adler Corporation and Adler were able to exclude themselves from the business operations which could be deemed as commercially unviable. Adler was aware about the cash flow problems which were being faced by these businesses and that each one of these had a major risk of collapsing ultimately. There was also a failure on part of Adler to disclose his personal interest to the board of Williams and Fodera. There was also a misuse of the information of the company, so section 183 was also breached (Australasian Legal Information Institute, 2017b). The transaction undertaken by Adler did not attain a shareholder approval as per section 208 of this act. Also, the same could not fulfill the exception of being at arms length. Hence, all three, i.e., Fodera, Adler and Williams breached this section of the act too (Segalla, 2017). Conclusion To summarize, the directors and other offices, in this case, failed to fulfill the provisions of the CA. And hence, deserve appropriate penalties, as levied by the court of law. References Armstrong Lawyers. (2007) Directors Duties. [Online] Armstrong Lawyers. Available from: https://www.vcta.asn.au/documents/item/400 [Accessed on: 30/04/17] Australasian Legal Information Institute. (2017a) Corporations Act 2001. 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