Thursday, September 3, 2020

Supply chain management in Starbucks and its impact on company performance Free Essays

Presentation †BACKGROUND: Flexibly chain the board has become an interesting issue in the course of recent years. Before diving into the subtleties, we have to characterize what flexibly chain the board is. Despite the fact that it has been proposed that there is little concession to a definition for flexibly chain the executives (Burgess et al, 2006), one definition we could utilize could be the fundamental, vital coordination of the customary business capacities and the strategies over these business capacities inside a specific organization and across organizations inside the gracefully chain, for the reasons for improving the drawn out exhibition of the individual organizations and the gracefully chain overall (Mentzer et al. We will compose a custom paper test on Gracefully chain the board in Starbucks and its effect on organization execution or on the other hand any comparative point just for you Request Now , 2001, p. 18). Organizations currently comprehend the significance of flexibly chain the board superior to the earlier decades. In starbucks for instance, with the expansion of operational expenses followed by the therapist of deals, they put energetically a flexibly fasten system so as to lessen their expenses and keep up their competiveness in the market. A viable flexibly chain the executives could affect on the organisation’s budgetary execution: gainfulness, liquidity, and efficiency or resource usage (Christopher, 1998). A genuine distinction â€Å"through the client esteem that is made by unrivaled service† (Christopher and Peck, 2003, p. 46) could likewise be produced from an effective flexibly chain the executives. To get to that pleasant cup of starbucks espresso, it takes a smooth run of the gracefully chain to get that going. The primary explanation is the way that the excursion from bean in South American or African homestead to a cup in a starbucks café is a cleared with impediments. Espresso and other related items are to be effectively provided from various pieces of the world and passed on to the 16,700 starbucks bistros, which are visited by around 50 million customers in 51 nations consistently. Anyway in 2008, confronted with the expanding expenses of its working, the diminishing of its incomes, and when the expenses of its American gracefully chain office went from $750 million to over $825 million, they began understanding that the company’s flexibly chain the executives all in all was not successfully conveying its crucial. One explanation could be the high rhythm at which starbucks was opening branches all around the globe with their gracefully fasten thinking that its difficult to stay aware of that pace. As indicated by Peter D. Gibbons, who is starbucks official VP of worldwide gracefully chain tasks, the company’s development has been so quick and in a brief timeframe that even the flexibly chain essential guidelines were not set up. The immediate aftereffect of that dismisses the expansion of the expenses of the flexibly chain activities as a rule. To get the connection among expenses and execution here back in flawless synchronization, numerous terri tories must be taken a gander at. As indicated by Porter (1980), the two fundamental serious methodologies are cost favorable position and separation. A very much drove lessening costs plan make costs preferences, while a superior degree of customization and administration will in general lift the benefit. One of the issues with starbucks flexibly chain was the conveyance time. This last could be unraveled with a superior standard of administrations through efficient request catch, by ensuring that the various fixings or materials are consistently accessible etc†¦ Supply chain the executives produces separation â€Å"through the client esteem that is made by unrivaled service† (Christopher and Peck, 2003, p. 46). Also, what's more, there is a solid connection between expanded degrees of administration and increments in deals volume and client upkeep (Parasuraman et al, 2004). This would simply demonstrate that a compelling advancement on the flexibly chain would directly affect reducing expenses with stil l a decent client support. Such activity is intended to decrease the business cost duties which would emphatically affect on the benefit of the organization. An activity like this would fuse: Decreasing stock holding costs through improved stock administration (Stapleton et al, 2002) Distinguishing and dispensing with non-esteem including gracefully chain exercises (Hines and Rich, 1997) and the various costs identified with them. The stock part of the gracefully chain the executives is extremely pivotal. A huge decrease of the stock would improve resource adequacy and abuse. Less inventories additionally implies less working costs identified with doing stock. Essentially, a decline in stock decidedly impacts on the money to-money cycle along these lines greater liquidity (Christopher and Ryals, 1999; Farris and Hutchison, 2002). Writing REVIEW: Past work exists on the tie between gracefully chain and the exhibition of an organization (Christopher and Ryals, 1999). Be that as it may, organizations are supposed to source around 75 % of the estimation of therir administrations and merchandise from the gracefully chain (Trent, 2004). Others explores dependent on the impacts of improvement in the gracefully on the budgetary sidehave demonstrated that for the time being, the point at which we have a significant level of stock, this would have no immediate negative effect on the cost to-book proportion. Anyway over the long haul it could get to a decreased financial exchange esteem (Chen etal, 2005). In the retail business for instance, an association between the floor space and stock show better working stores are the ones with a higher stock turn for every unit territory (Raman and Gaur, 2005). It is imperative to locate the perfect measure of stock to have; in light of the fact that a lot of stock is as awful as excessively minimal stock as the two of them influence the business execution. Organizations with low (not most minimal) levels of stock would be bound to have a decent long haul securities exchange execution (Chen et al, 2005); yet it could likewise be because of better stock administration systems. Regardless of whether business execution is assessed by advertise and budgetary models, a momentary methodology of the flexibly chain the board goals would improve the proficiency and decrease the lead time and level of stock; while then again, a drawn out methodology of gracefully chain the executives targets would raise piece of the overall industry (Koh et al.2007). business execution is influenced through flexibly chain the board through various components, for example, : lead time, stock turnover, item return, deals level, cost decrease and meeting customers’ desires (Petrovic-Lazarevic et al. 2007)’ Lead time: time slipped by from the second the client makes a request and when it is totally fulfilled (Chan 2001). Organizations are feeling the squeeze to diminish their assembling lead time. Shorter lead time implies that organizations will have the option to quickly respond to changing business sector requests (Wadhwa et al., 2005; Chan and Qi, 2003). Stock turnover: this estimates the speed with which products travel through and are recharged by the sytem (Sahay and Mohan2003). Item return: to catch the market and keep the clients fulfilled, it is pivotal for a business to have great quality items (Chan and Kumar 2007). Deals level: this pointer help indicating whether the business has a decent piece of the pie or not. Cost decrease: in (Fawcett et al. 2008) it is plainly indicated that an all around worked flexibly chain will extensively help lessen costs. Meeting customers’ necessities: by the day's end, this is the thing that the business is for. It is tied in with fulfilling the customers and going past its desires. As ( Huang et al 2002) referenced, improvement in the flexibly tie the board prompts a superior reaction to client desires. Development execution: a decent flexibly chain the board organize permits organizations to share data both inside and remotely. This assistance improving the organization execution. There are different works that additionally show the connection between flexibly chain the board and an authoritative execution (Petrovic-Lazarevic et al., 2007). Others investigates put together their examination with respect to just about 200 firms understood that flexibly anchor the board could prompt upper hand and simultaneously improve the business execution (Li et al. 2006). Examination OBJECTIVES AND RESEARCH QUESTIONS: This task proposes to demonstrate the significance and advantage of flexibly chain the board inside starbucks association and the crucial job it plays for any business execution. Accentuation will be on the period from October 2007 onwards, since this is the period during which starbucks’ deals began going down, and its flexibly chain costs rose. Especially, fixation will be on the accompanying inquiries: What is starbucks flexibly chain the board strategy What is starbucks corporate social obligation What are their espresso buying and gracefully chain rehearses What is the adequacy of Starbucks operational systems How does their gracefully chain the board influence their extension system Exploration AND DESIGN: The strategy which will be utilized here so as to cover the examination destinations will generally be founded on subjective exploration through semi-organized meetings so I will even now have the option to concoct inquiries during the meetings. On the off chance that all around drove, these meetings could likewise help me gathering explicit data expected to answer the examination targets. There will likewise be utilization of quantitative strategies, which will be introduced through graphs and charts. Information COLLECTION AND ANALYSIS: Essential information will be gathered from interviews while optional information will be gathered from distributed reports on gracefully chain the executives, estimation of organization execution from dependable and regarded distributers, for example, flexibly chain digest, world exchange coordinations diary, flexibly request chain official, calculated quarterly, 3PL wire, DC speed. Information will likewise be gathered from the college of Westminster

Tuesday, August 25, 2020

My love Essay Example For Students

My adoration Essay She sat opposite me in Algebra class. As far as appearance, I generally thought about both of us as direct inverses. There I sat; a dull haired, tan-cleaned, green-looked at, arm-scarred, enormous, short-haired, tall, rather wakeful and mindful kid whose lone perceptible component was his solid jawline. I didnt even notice the sacks under my eyes so awful, it looked as though they were stuffed and prepared for get-away. She had a light appearance with spots simply over the extension of her nose and beneath her eyes. Her eyes were robins egg blue and her lips were a lovely dim dark red that stuck out, yet didnt shout for consideration. Her lips were slim, similar to her. The hair that she had was red with dull fair streaks. She didnt have a scar on her. The sacks under her eyes were non-existent. Be that as it may, she jumped at the chance to stay in bed class. This made the magnificence of her face secured by her long hair and the miracle that were her eyes secured by her eyelids. I would consistently see her eyes. I looked in the expectations that she wouldnt see me each time I looked. Possibly I needed her to see me. Catch me lost and swimming in her eyes. Albeit, regardless of the amount I took a gander at them, all I at any point received back consequently was my appearance. Her windows resembled those of a limo she could see out yet you were unable to see in. This showed me the exercise that here eyes were carefully stylish. It was really awful that she jumped at the chance to rest. It never gave me much an ideal opportunity to look at her eyes. Obviously I saw her in different classes for the duration of the day, however I never got a view like the one in Algebra 3-4. Truth be told, Algebra 3-4 turned into the feature of the day. There would be such a large number of schooldays where the main thing, the main expectation, getting me during that time was the chance to simply view her face. It got me through nearly anything on occasion. I wasnt over the top, nor in an intellectually unusual state around then. I knew my affection for her was high, yet it was unadulterated. My idea of this was approved by how I recognized what sort of an individual she was within. The leaves tumbled off the trees and turned earthy colored, flagging the appearance of fall. At that point those equivalent leaves solidified, put, to the ground, reporting winters coming. I am astounded I saw the seasons came, as all I ever truly payed thoughtfulness regarding was her. It was the Friday before winter break had started and school had recently finished. Everybody ran out of school. I was somewhat discouraged at the way that it would be some time before I saw her once more. The best I sought after was simply observing her at the shopping center or something to that effect. Christmas came and I got my presents and I had gotten others theirs. Individuals got me some new garments, another MP3 player, another toy for my PC. None of it truly filled what void I had inside. New Years dropped by. My companion welcomed me to a New Years party. It was to start at 9 Oclock PM. He moved by my home at 8:30. Before I left, my folks gave me the typical admonitions. No Sex. No medications. No drinking. No driving. I was a moderately decent child, so these abandoned saying. We showed up at a short while after nine. I strolled inside where the gathering was. I plunked down with a pop or two in my grasp. I was grinning withy my teeth and mouth, yet not with my heart. My companions saw past my cover and attempted to acquaint me with certain young ladies. Young ladies who said I was very appealing. Young ladies who said they realized I was the delicate man they needed. Im sure that at some other time I wouldve wanted to sit and talk with them. Perhaps accomplish more. Be that as it may, nobody had the option to get my advantage much as it was missing with Her. Exploratory writing: Surface EssayIn my misled state, I came back to class the following day. I was incapacitated until English. Everybody inquired as to whether I was alright and said that they were sorry I wasnt there yesterday. I addressed concisely. She wasnt there. She wasnt there. I heard the P.A. I half overlooked it since I was scanning for her. Looking for her like a lost schoolwork task lost in a heap of papers. I guess the expressions of the declaration soaked in subliminally. There will be a wake. I will join in. I got back. My folks got on to how weird I was going about starting late. I revealed to them that I was completely fine. I went to my room. I assembled my best and best outfit. Everything was totally spread out. The days experienced my fingers as I attempted to get them as I attempted to get rational soundness. The day for the wake came. My folks drove me to the memorial service home and dropped me off. I would call them when I should have been gotten. I advanced inside. Causing me a deep sense of shock, nobody was there from school. Is it accurate to say that i was the one in particular who seen her? The one in particular who gave any indication of sympathy for her? Sadly, this was affirmed by nobody appearing. I plunked down. During the entire wake, I did whatever it takes not to take a gander at her. The Pastor got up, and said his words. The mother and father got up, and said their words. Everybody left. The proprietor of the burial service home said that they would be shutting in ten or fifteen minutes. I gestured my head. I concluded the time had come to get up and look at her one final time. I drew nearer to her casket. No. No. What have they done to you? Her eyes, shut and gone forever. Her lips; cold and dead. Not indicating the existence they once had. Her skin, cold and frosty. The spots, nearly gone. Her hair, put behind her head. He magnificence had kicked the bucket with her. In any case, there was all the while something about her. I tumbled to my knees. I snatched her hand. Still virus. No. No. No. NO! My tears trailed unto her skin. Her face had gotten obscured by the tears of distress from my eyes. For what reason did this need to occur? No. Nothing occurred. Everything is as yet typical. Face it. Shes gone. For what reason did this transpire? Why didnt I disclose to her how I felt? Was it since I couldnt do it? Was it dread of dismissal? It didnt matter at this point. I think twice about it. I lament not having advised her. It is my deficiency. This is my responsibility now. It is my issu e she passed on, it is my shortcoming she didnt know, and it is my deficiency I at any point viewed her face in any case. My crying didn't stop. I kept on holding her hand, most likely in the vain expectations that she would press it. I murmured her name. No. I talked her name. No. I could just say nothing and sit in the stunning quiet.

Saturday, August 22, 2020

Movement and singing Research Proposal Example | Topics and Well Written Essays - 750 words

Development and singing - Research Proposal Example Alexander considered himself in mirrors while he was stating his lines. He understood that his ongoing method of holding himself would be extremely difficult to survive, yet realized he needed to deal with his stance and demeanor so as to deliver the best solid. So he built up a technique to re-show his body acceptable behavior. Entertainers regularly don’t even acknowledge they’re tense until they’re reminded to unwind. Snugness in the vocalist can mutilate sound and cause the sound to be less thunderous (Alexander). The Alexander Method shows understudies how all the muscle bunches cooperate. The educator guides understudies through a progression of delicate activities, and once in a while contacts them a little to control them into better approaches for utilizing their muscles. The muscle remedies are unobtrusive, and an Alexander Technique educator coordinates the understudy with little developments and verbal guidelines. Entertainers believe that â€Å"standing up straight† will give them the best stance for singing, however the demonstration of standing straight can put additional strain on the neck, back, and legs, really lessening the breath and reverberation. Deliberately causing the body to do anything presents strain. The Alexander procedure loosens up the stance, lessening hidden pressure (Moore). The â€Å"whispered ah† is a method of making Alexander strategy understudies mindful of how the breath enters and leaves the body. By consummating the â€Å"whispered ah,† artists can loosen up their breathing into its increasingly regular rhythms and connect with the entire body in creating sound. The sound will be progressively unadulterated and full since it comes out the entire individual. The murmured â€Å"ah† may appear to be a straightforward exercise, however culminating it is very dubious. Breaking old examples requires both focus and giving up to allow the procedure to work. The significant point with the Alexander strategy is to unwind and quit attempting to control body developments and positions. Going into a characteristic posture when singing and discharging pressure gives the voice its profundity. Once

Data mining titanic dataset Essays

Information mining titanic dataset Essays Information mining titanic dataset Paper Information mining titanic dataset Paper Titanic dataset Submitted by: Submission date 8/1/2013 Declaration Author: Contents Dated: 29/12/2012 The database compares to the sinking of the titanic on April the fifteenth 1912. It is a piece of a database containing the travelers and team who were on board the boat, and different credits associating to them. The motivation behind this errand is to apply the approach of CRISP-DMS and follow the stages and assignments of this model. Utilizing the order technique in quick excavator and both the choice tree and INN calculations, I will make a preparation model and attempt apply the class endure or didnt endure. On the off chance that I apply a choice tree to the dataset all things considered, I get a forecast pace of 78%. I will attempt different methods all through this report to build the general expectation rate. Information mining targets: I might want to investigate the pre imagined thoughts I have about the sinking of the titanic, and demonstrate in the event that they are right. Was there a dominant part of third class travelers who kicked the bucket? What was the proportion of travelers who kicked the bucket, male or female? Did the area of lodges have any kind of effect with regards to who endure? Did gallantry ring through and did Women and kids first really occur? Information Understanding: Describe the information: Figure Class name: Survive (1 or O) 1 = endure, kicked the bucket. Type = Binomial. All out: 891. Endure: 342, Died: 549 Attributes: 10 characteristics 891 columns The dataset have essentially a clear cut kind of quality so there is uninformed substance. This may show a choice tree would be a suitable model to utilize. I can see that the quantity of lines in the dataset is without a doubt 10 to multiple times the quantity of sections, so the quantity of occurrences is sufficient. There doesnt appear to be any inconsistencys in the information. Pappas: first, second, or third class. Type: polynomial. Unmitigated, third class: 491, second class: 216, first class: 184 0 missing Name: Name of Sex: Male, female. Type: binomial. Male: 577, Female: 314 0 missing Age: from 0. 420 to 80. Normal age: 29, standard deviation of 14+-, Max was 80. 177 missing Sibs (Siblings ready): Type: whole number. Normal under 1, most elevated 8. This recommended an exception, however on assessment the names where there were 8 kin related. (The name was wise, third class travelers, all kicked the bucket. ) O missing Parch: number of guardians, kids locally available. Type: number. Normal: 0. 3, deviation 0. 8. Max was 6. O missing Ticket: ticket number. Type: polynomial. To me these ticket numbers appear to be very arbitrary and my first tendency is to dispose of them. O missing Fare: Cost of ticket. Type: genuine. Normal: 32, deviation +-49. Most extreme 512. There is by all accounts a significant difference in the scope of qualities here. Three tickets cost 512, exceptions? O missing Cabin: lodge numbers. Type: polynomial. 687 missing From taking a gander at this information I want to limit one of my underlying inquiries concerning lodge numbers. On the off chance that there was more information it may be an intriguing element as respects lodge areas and endurance. As it stands the nature of the information isn't acceptable, there are Just o many missing passages. I. E. More prominent than 40%. So I will erase (sift through) the lodge quality from the dataset. The age property could cause an issue with the measure of fields missing. There are beyond any reasonable amount to erase. I may utilize the normal of any age to fill in the spaces. Investigate the information: From an underlying investigation of the information, I had the option to take a gander at different plots and discovered some intriguing outcomes. I have attempted to hold my discoveries to my underlying inquiries that I needed replied. Was there a greater part of third class travelers who kicked the bucket? You can tell from Figure 2 this was valid. This diagram Just shows endurance by class, third class fairing the most noticeably awful. Again this is appeared with a dissipate plot however with the additional quality sex. You can see on the female side of the top of the line travelers, just a couple kicked the bucket. Strikingly it shows that it was for the most part male third class travelers who died, and it is shown that more guys then females passed on. There is a reasonable division in classes illustrated. This chart responds to my other inquiry. What was the proportion of travelers who passed on, male or female? From this we can see that basically guys didn't endure. In spite of the fact that there were more guys ready (577), around 460 died. From the females (314), around 235 endure. Another trait that needs consideration is the age classification. I needed to see whether the ladies and youngsters first strategy was clung to, however there are 177 missing age esteems. This will confound my outcomes on this. From leaving the 177 as they seem to be, I get this chart: yet this isn't indisputable in Figure 5. I believed that the charge cost may show a childrens cost and along these lines permit me to fill during a time, yet the toll cost doesnt appear to have a lot of example. Another thought I thought may help is take a gander at the names of travelers, I. . Miss may imply a lower age. (In 1912 the normal time of marriage was 22, so anybody with title miss could have an age under 22. ) Names which incorporate ace may show a youthful age too. Figure 5 additionally shows potential anomalies on the correct hand side. From this chart I could without much of a stretch see the breakdown of the distinctive class of traveler and where they left from. Clearly Southampton had the biggest number of travelers jump aboard. Question had the most noteworthy extent of third class travelers contrasted with second and first class at that port, and its likewise intriguing o note this was an Irish port. This chart further investigates the port of bank and shows the endurance rate from each, just as the various classes. To me it appears that most of third class travelers were lost who originated from Southampton port, in spite of the fact that they had the most elevated measure of third class travelers. A more intensive gander at Southampton port. The dominant part who didnt endure were third class (blue), additionally noted is the bunch of first class travelers (green) who kicked the bucket, yet Southampton had the most noteworthy number of first class travelers to board. See figure 6. Check information quality There were various missing qualities in the dataset. The most noteworthy measure of missing information originated from the lodge property. As it is higher than 45% (687 missing) I chose to sift through this section. There are additionally 177 missing qualities from the age property. This measure of missing information is again too enormous a rate to overlook and should be filled in. I can see that the dataset contains under 1000 columns, so I imagine that examining won't need to be performed. There doesnt appear to be any inconsistencys in the information. There are as yet 2 missing snippets of data from the bank trait. I see that they are first class travelers so from my chart on dike I want to put her bank from Churchgoer. The other traveler is a George Nelson, which I will add to Southampton. I chose to sift through names moreover. I dont perceive how it can help in the dataset. It might have assisted with age, by taking a gander at the title as I stated, however for this I Just utilized the normal age to supplant the missing qualities. Another way to deal with filling in the missing age fields may be direct relapse. Expel potential anomalies? I can see that there might be a few anomalies. For example in the passages characteristic, there re three tickets which cost 512 when the normal is 32. They were top of the line tickets, however the thing that matters is tremendous. Information Preparation: Here is the aftereffect of utilizing x approval on the dataset before any information readiness has occurred. I will currently sift through the issue of 667 lodge numbers missing. With it being higher than 40%, Vive chose to erase the quality totally. Vive likewise erased the name trait, as I dont perceive how it will help. By erasing lodge, name and ticket, here is the outcome I get: I supplanted the missing age fields with the normal of ages, this expanded the exactness daintily and gave these outcomes with x approval: I utilized recognize anomalies and picked the main ten and afterward sifted them through. This gave this outcome: The class review for endure has not improved a lot. Expanding the quantity of neighbors in the recognize anomalies administrator improved things, additionally constraining the channel to erasing 5 improved an exactness. I chose to utilize determined binning for the ages and broke the ages into three containers. For youngsters matured up to 13, moderately aged from 13 to 45, and more established from 45 to 80. I attempted diverse age ranges and found that these extents yielded the best outcomes. It increased the precision. I likewise utilized binning for the charges, parting them into low, mid, and high which additionally improved outcomes on the disarray lattice. I utilized distinguish exception to locate the ten most evident anomalies, and afterward utilized a channel to dispose of them. I have chosen to expel lodge from the dataset, and furthermore there are 177 missing age esteems which I have attempted different methodologies in evolving. I changed the ages to the normal age, yet this gives a spike in the quantity of ages 29. 7. Case of normal age issue: Modeling: I attempted to actualize both the choice tree and motel calculations, seeing as the dataset as principally unmitigated. I found that motel yielded the best outcomes with respect to precision. This was set at k=l . The precision was not extraordinary at 73%. The parameter of K is excessively little and might be impacted by commotion. Hotel: 5 worked the best at 82. 38%. This is by all accounts the ideal incentive for k, and the separation is fixed. Class exactness is about even on each class. Choice tree: The choice tree calculation didnt give me as much precision, and I found that killing pre pruning gave me a superior exactness. From the choice tree, the age binning appeared to foresee moderately aged guys (13 to 45) with a low admission well. The class review for survi

Friday, August 21, 2020

How did the British Empire Understand and Try to Combat Violent Literature review

How did the British Empire Understand and Try to Combat Violent Nationalism - Literature survey Example It is a trusteeship under what Lord Lugard has strikingly called a double command in frontier government (Williams, Gwyn A., 1980). For it involves not just an impulse to build up the region in light of a legitimate concern for a world economy however the fortress of the local occupants from the too abominable effect of contact with amazingly equipped mechanical civic establishments. An examination into the achievement of the British Empire in managing this most irritating issue has amazing enthusiasm to all colonizing powers. The thought of the world has been centered around atypical force thus on the East Coast of Africa, presently totally British, either through direct control or under League Mandate. There the white settlement, from which West Africa has been made sure about by its atmosphere, is most likely in the high uplands of Kenya, in parts of Tanganyika and Nyasaland, and maybe on down to the Union of South Africa, on the island pinnacles of high level nation, for example, an expansion as one goes south through the Rhodesias. Over the whole territory, Cecil Rhodes' fantasy of a white African domain for England is being battled out between the Colonial Office's strategy of requirement and the obstinate patriotism of the Union of South Africa.â it settlements of the Rhodesias and of Kenya, however the last is still sparingly settled protectorates or crown states, on account of Kenya without responsible government. The shibboleth that separates men about local strategy in Africa is the predominant enthusiasm of the locals (D. C. Dorward, 1986, pp. 399-459).The worry of this African battle and of different difficulties of a domain must be cleverly predicted after an investigation of each discretely, concentrating consideration first on the British Commonwealth of identical countries and weighing radial and centripetal pulls from race, religion, class, sequential ties, and monetary interests.British international strategy intensified and traded off into a fused framework out of the draw of these different premiums, with different focuses of financial and political attraction pulling at its segment individuals from both North and South America, and Europe (Philip Foster, 1965). Nor would one be able to neglect that Russia is co nceivably threatening to the structure of that entrepreneur world economy in which the City in London imparts to New York the decision position. For whatever length of time that industrialist countries sidestep war the risk is slight (G. O. Olusanya, 1973).

Tuesday, August 4, 2020

Mornin Glory

Mornin Glory In Berlin, we met and interviewed the founder of Mornin Glory, Nicolas Stoetter.In this interview, Nico shared his background, details about the business model of Mornin Glory, the market situation for male cosmetic and shaving products, as well as his advices for the first time entrepreneurs.Interviewer: Hi. Today we are in Berlin with Mornin’ Glory, with Nicolas, and we will show you today how to make men beautiful again. Nicolas, who are you and what do you do?Nicolas: I am Nicolas Stoetter, I am the founder and managing director of Mornin’ Glory. Mornin’ Glory is a European direct to consumer online brand for European male grooming products. We started out in 2012 as an inexpensive subscription service for razor blades.Interviewer: What did you do before you started this company?Nicolas: Like a lot of European ecommerce founders I started my career in management consulting, a couple of years with Boston Consulting Group, both in Germany and the US, doing traditional resturc tuing and transformation projects. Eventually got bored of that â€" that’s another parallel I share with a lot of people here â€" and went on to work as a social business consultant for Nobel peace laureate Muhammad Yunus in Bangladesh. The idea was to consult corporations and setting up social businesses. I was sent to Bangladesh, very interesting experience also for my stomach. And then eventually I decided that I wanted to start a company again.Interviewer: For profit this time?Nicolas: Yes, for profit or at least for shaving. To make that transition I pursued my MBA in Chicago and started Mornin’ Glory.Interviewer: Did you know the founders beforehand?Nicolas: No we didn’t. Fabio, my cofounder, is quite a bit older, so we didn’t exactly go to high school together. I met him here Berlin on the scene and we connected.Interviewer: Tell us a little bit more about how the business model works. From my understanding you started out as a basic subscription model for shavers. Wh at does your current business model look like?Nicolas: We are in the process of changing that. The whole subscription element for the blades will remain, simply because we see that it works both from an economic and from a consumer perspective. And what we are in the process of adding to that is the transactional component with different grooming products that basically complete the whole blade shaving experience. So in the first step we’ll launch a Mornin’ Glory branded range of pre- and post-shaving products.Interviewer: Something like this you can look at?Nicolas: Quite similar.Interviewer: When did you make this decision going from this mono-product company to adding more features and products?Nicolas: I think that’s pretty much baked into our vision. Our vision was not to be a subscription company for blades, and it’s also not the way we pitched it to the outside world. The vision was always to build a male grooming brand which will eventually also go to other categorie s. I think that was very much the plan from day one.Interviewer: Can you tell us a little bit how the value chain is structured. Where do you source the different supply material or even finished and branded products, and how is the operation working here in Berlin, and then how are you selling this and to which type of markets and what types of customer segments?Nicolas: I think it’s very different depending on whether you look at the blades or the shaving products. The blades we source from the biggest private label manufacture for system razor blades. There’s really not that many out there, which is also the main difficulty, to get into the market and to convince one of those big guys to work with you and to supply with you on a long-term basis, not just ship a couple of blades in bulk and then you go. So that’s something that we get from the US.The shaving product we developed ourselves in the last two years in Italy. We work with a small private label family on outfit the re, and we get the tubes that you see here delivered to our warehouse in Berlin and there we package everything. We’re surprisingly vertically integrated till today, so we get all the pieces and put them together and then ship to the consumer. In terms of market, it’s very much focused still on the German speaking countries, Germany, Austria, Switzerland. Recently we expanded into France, and we definitely have other countries on the agenda as well.Interviewer: And when you look at the person who is buying your products, is it 100% male, or are women also buying for their husbands or boyfriends?Nicolas: 99.9% male. There is the odd woman, and I do think that women have a role as re-purchasers for blades, not necessarily as brand decision makers. A woman wouldn’t say, “You know Martin, I think you should start shaving with Mornin’ Glory instead of what you’re at now.” So it’s very much men, and they’re pretty much the whole range, there is the very price sensitive c onsumer that just wants to save a couple of Euros on blades, there is the white collar busy guy that appreciates convenience, so it’s the entire range.Interviewer: How do you attract these male persons as potential customers coming to you website?Nicolas: I think one of the big challenges we have is that we’re selling a product in a channel where today the consumer is not buying. Mostly blades are sold offline and at the big retailers under brands which nobody knows, Mornin’ Glory versus Gilette Wilkins and the big guys. And then we have this subscription model. So I don’t think it’s a trivial seller trust in our marketing, we’re still very much focused on performance-driven online marketing, which is probably not a surprise. We’re adding more branding-related channels to that as we go on, always looking at cost and monitor and improve.Interviewer: You told us that you have one supplier from whom you get the blades, and that is one of the major companies in the world t hat is offering these kind of blades, this would lead me to think that the margins are quite low, and that’s because he might have a quite strong negotiation power with you as there are no other suppliers you could go to. Is this correct, or are there other smaller production facilities you could get the blades from?Nicolas: There’s a handful. There is not just one, but there is also not ten, so it’s probably four or five outlets in the world. It’s a fair point that you’re making, I don’t think that they are necessarily using their power to negotiate on price. Even before that, you need to convince them that you’re complementing their offline business rather than cut into that. You need to convince them that you’re not just two confused guys sitting in a Berlin coffee shop trying to change the world, but you actually know what you’re doing. I think it’s those kinds of hurdles that you need to get over. And then at some point they just have standardized price list s and you go with that.Interviewer: Did you talk to them in person in order to convince them?Nicolas: That was the very first thing that we did, and I was very naïve in thinking I’ll just pick up the phone and clearly they’re going to want to sell to me because that’s their job, it really didn’t work out that way. So I personally called them like 20 times, left them voice mail messages, they hated me, but they did get back to me and eventually we got the opportunity to convince them.Interviewer: Let’s talk about the corporate strategy. What kind of growth initiatives are you trying to do in the future, regional expansion that you told me about in terms of France, for example, or product-wise expansion? What is your long-term goal with Mornin’ Glory?Nicolas: I think if we are serious about being a European male grooming brand, there’s probably three components in there. You talked about the international reach, that’s just adding country by county until we eventually have a full European coverage, that’s mainly a marketing exercise, not so much a logistics exercise because our entire product range is in front of you, it’s not super-complex from an operations point of view. It has a product component, but I can’t credibly claim to be a European grooming brand if I just sell two sets of blades.And then, thirdly, and it’s probably the most subtle one in a way, we are really serious about building a brand and not just an online shop. That means that we strongly believe in doing products ourselves under our own brand, so we are very much private label driver, which makes it a bit harder, because developing your own product is probably harder than call up a distributor and just get in the warehouse. It also means that our online marketing is great, those performance driven low CPO channels are great, but eventually we need to grow up and also be in print and all the channels that the big brands are very much present. So I think it’s also ab out getting into those channels cost-effectively.Interviewer: Are you trying to build a brand because the typical products like blades etc. are perceived as a commodity, just to justify higher earnings once you’ve created this brand?Nicolas: There is a very personal reason. I think that building brands online is more fun than just building online shops and big warehouses with nice front-ends. From a business point of view we’re trying to change the grooming landscape out there a little bit. I think if you go out there and look at the regular shops that are out there, whether it’s online of offline it doesn’t really matter, men are always an afterthought. You walk into a Douglas shop, for example, which Germany’s biggest retailer for cosmetic products, and the whole experience is made for women. As a guy you feel very uncomfortable. And there is this one isle in the corner with the wooden couch which is made for you. But if you look at the market size and growth for male gr ooming it doesn’t really add up, it’ a very dynamic market, it’s a very big market. We want to start with men and really build and experience that is catered to them.Interviewer: What is the reasoning behind only focusing on Europe, is it because there are some other player already settled in other regions or is there some other logic behind that?Nicolas: If you look at our current product range, shaving, there is a lot of online competition in the US, and I wouldn’t rule out going to the US eventually, it’s not low hanging food, it’s definitely a big market. If you look at emerging markets, they really don’t shave that much. Imagine the average Asian guy probably not very strongly haired â€" I’m trying to be politically correct â€" but it’s not a huge market. If they do shave they use disposable razors, those very cheap ones that you throw away after initial use, so not great markets for us.Interviewer: This gets me to the point of talking about the market. Can yo u give us some rough numbers in terms of market size for razor blades or for maybe even grooming products for males in Germany or in Europe or even worldwide?Nicolas: Let us look at Europe, because that’s the market that we’re going after. It’s roughly two and half billion Euros per year for razors and blades, and then easily another half a billion for pre- and post-shaving products, and probably closer to ten billion if you look at the entire grooming range.Interviewer: How does this distribute over the major countries and major distribution channels?Nicolas: No big surprises. The big countries are also the big markets. It’s very much population-size driven. If you look at Germany, UK, France, Italy you probably have 50% of Europe.Interviewer: How much percentage is distributed through offline channels?Nicolas: Depressingly, the number is almost as high as our share of males in the overall customer base. It’s definitely above 90%. That is a conversation we have all the ti me. Is it because online is not interesting for the category from a consumer point of view, in which case we have a biggish problems, or is it because â€" and that’s what we believe â€" there is no one really pushing online. Sometimes you have to make take channel switch also from a retailers’ perspective. And if you look at blades as the core category the retailers are very happy with their offline business, they don’t see any reason to push online. They’re also under pressure sometimes from the big guys and the big guys not to change that. So I think it’s very much a situation where the established players are quite happy in their entrenched positions.Interviewer: Nicolas, we always try to give some kind of advice to people interested in entrepreneurship so they start a company and make less errors. What have been your major lessons learned over the last years?Nicolas: For one, I mentioned this calling up suppliers and being a bit naïve about it earlier. I think that is one of the major lessons. If you’re young and you’re starting a company you think that clearly online is well established by now, clearly people want to work with me. I think what you will experience is you will need to earn that right, initially you’re nobody, nobody knows you, nobody knows your brand, so you have to sell all the time, and you have to sell hard. It’s not always fun, because you’re the kind of the beggar, but you need to get through that and you eventually sit on the other side and enjoy that. That is one of the things that we learned, and maybe that’s because we were also going into a very consolidated market. But when I talk to other entrepreneurs I think that applies across the board.Secondly, and this is something that I think comes up all the time, pick your partners carefully, both from a team perspective, because you’re going to be stuck with them for a while, especially your co-founder, you’ can’t get rid of them easily, and I am quite luc ky in that respect in that I don’t want to. But also in terms of investors and strategic partner, those people with you for a long time, there will be great moments and there will also be less enjoyable moments, and you want to make sure that you’re with people that you trust.Interviewer: Thank you very much Nicolas.

Monday, June 22, 2020

The Holocaust Survivor - Free Essay Example

Even in his old age, Vladek still does his best to take care of himself as he pedals on his bike. This tendency was hard-wired into him during his time in the concentration camps: only the fit and the strong survived as they were valued over those who were weak and sick. Artie has clearly talked about chronicling Vladeks life during the war before, and Vladek suggests he sticks to what he is good at instead, apparently reluctant to reopen old wounds. In the fifth panel of the page, Vladeks prisoner number can be seen: one of the few remaining tangible reminders of the horrors he endured in the camps. It also hammers in the fact that Vladek is a survivor and that the Holocaust as it is for all survivors will always be a part of him. Artie is Jewish; however, he is not a Holocaust survivor like his father. Vladek may be in denial or does not realize it, but Artie knows that Vladeks experience as a survivor is a tremendous responsibility. Artie knows he is not fit to tell Vladeks story, he has never met any of the people in Vladeks life and does not have all of the information necessary to authentically depict the scenes Vladek describes. However, that does not change the fact that Arties family was almost wiped off the face of the planet during the Holocaust and he feels an obligation to preserve Vladeks memories out of respect for the suffering he endured and ensure the atrocities of the Holocaust are never forgotten. However, it is also worth noting that Arties first question about his fathers past shows how little he truly knows about him and how fragmented their relationship is. He does not even know how his own parents met. This foreshadows more unrest to come in later chapters. It is also a stark contrast f rom Vladeks life where familial bonds were an integral part of human life, even going so far as to sustain them and kept them alive. Artie is clearly distant from his family and very independent of them. Vladek and Mala are not happy together, but her and Artie seem to get along reasonably well. Artie treats her with respect and ignores Vladek when he tries to speak poorly of her, suggesting that perhaps Mala is not as bad as Vladek says she is. Arties stories about food and the dinner table hint at deep tension and brokenness and unhappiness in his family that everyone present at the table wishes not to address. Both Artie and Vladeks relationships have been fractured by the ruin of the Holocaust and the trauma brought by Anjas suicide. However, they are both selfish and neurotic, and both are too proud to address their shortcomings. The Holocausts effects on Vladek are also present in almost every aspect of his life, especially in his interactions with Artie. It is apparent that even from the beginning of the first novel where Vladek asks Artie to test the sincerity of his friends by locking them together in a room with no food for a week, that the Holocaust has shaped Arties entire life. He finds himself unable to relate to many of his fathers seemingly strange habits and mannerisms. Artie even tells his wife Francoise that he sometimes he could have been in Auschwitz with his family so he could better know what they went through and how it impacted them. Vladek is shown to be controlling and presumptuous by pitching Arties coat. He believes he knows better than Artie and Artie like a young child cannot make his own decisions. Vladek still thinks of Artie as a child despite the fact he is very much grown up. Artie tries to prove himself a man by berating Vladek but he is still forced to accept the hand me down, and like a child, he still has to what Vladek wants, even though it aggravates and that he is an adult. Artie strives to be as honest and upfront about Vladeks shortcomings as he can. He knows that despite all of the admirable qualities Vladek displayed, Vladek is not an uncomplicated, flawless hero and it would do Vladek a disservice to depict him as such. However, an unambiguously positive portrait would serve also allow Artie to vent his frustrations towards Vladek, which often seems to be the case. Artie is also distant from the love and compassion of his Jewish roots that his family displayed during the war even when they had little reason to live or persist living. This disconnect does not enable Artie to relate to what Vladek does or even see the good intent behind his actions although presumptuous. 4.) Vladek grows sick of hiding and wishes to be treated like a human once more. His frustration is justified, but regardless, he displays remarkable recklessness and stubbornness in asserting his decisions. He does not make an effort to understand Anjas anxieties nor does he exhibit any sympathy towards her. In such times of persecution, familial connections and friends were a crucial aspect to Vladek and Anjas survival. Parents, siblings, cousins, and friends all helped one another in any way they could even if they were not close before the war. While he is insensitive and reckless in this particular panel, Vladek still cares deeply for Anja, and Anja even states in a letter in Auschwitz that the fact he is alive is the only thing keeping her from throwing herself into the electric fence. All they had was each other, and Jewishness as Artie knew it became synonymous with survival under these circumstances. Artie is sharing his childhood insecurities with Francoise and how uncertain he was about his relationship with his parents. It also reveals the livings tendency to glorify or valorize the dead. Richieu did indeed die a tragic death, but he was still an ordinary person like Artie. Vladek and Anjas laud of Richieu was indeed a coping mechanism but revering his memory created tension among the living that was almost never resolved. Despite how hard Vladek has supposedly tried to forget about the Holocaust, he can recount the events in extraordinary detail and often cannot help becoming emotional as he relives his memories. He weeps when he remembers four of his friends hung in Sosnowiec and displays profound, parental grief when speaking of Richieu. Vladek displayed love and compassion constantly towards those around him, and that is what makes his memories so painful. Love like it did for so many Jews during the Holocaust, gave their lives meaning when the tyranny of the Nazi regime had taken all other reasons. Because Vladek and Anja loved so profoundly, they consequently hurt and mourn deeply as well. Nevertheless, comparing Artie to the memory of Richieu was unhealthy and contributed to Arties inferiority complex and widened the gap between him and Vladek. This panel portrays a number of different reactions to Vladeks life which perhaps represents how contemporary generations view the Holocaust. Artie remains firm in compartmentalizing his life and Vladeks, keeping them distant from one another. Francoise is sympathetic and tries to be very kind to Vladek in light of what he had to endure. The grocery store manager likely wished to end the conversation early and give Vladek what he wanted and instead of hearing the tales of cruelty and tragedy that Vladek had to endure. Both Artie and Vladek have a duty to share their experiences with the world. Both the survivors and those whose lives were touched by the tragedy have an obligation to share. By sharing, they contribute to the larger narrative of the Holocaust and help generations to come to make sense of the tragedy. Artie wrestles with whether or not it is right for him to share these experiences at all as he was not present and feels it is often not is place. The stories of the living, stories of triumph and overcoming impossible odds are often told, but in doing so, the perspectives of the dead are often forgotten. Artie is afraid he will misinterpret what Vladek tells him and in doing so dishonor the living and the dead. Nevertheless, while he cannot relate to the Holocaust the way that Vladek can, he has been molded by the tragedy, and the legacy of the event transcends generations. The Jewish people as a whole share it. While he is apparently willing to use his past to his advantage, Vladek st ill feels compelled to help Artie create an account worthy of the truth and gives those who cannot speak for themselves a voice. The mask that Artie wears is symbolic of his feeling of falsehood. He does not feel like he is worthy of his identity as a Jew and feels as though the story is not his to tell that he is profiting off the dead. He is unable to disconnect himself from his book, and his book persona has become intertwined with his real self. The dates he names show the passage of time as well as touching upon the thought of life and death and how they are interlocked in regards to the Holocaust. Artie is overwhelmed by the demands of success and his fear of doing the survivors and those who have perished a disservice. His ears and hair are visible from behind the mask he wears. The head of the mouse connects Jews over all nations and generations which suggests Artie feels as though he is a fraud and is hiding his true self. He feels as though he is unlike his parents and other Jews. This shows his anxiety about profiting off of a story that he feels he has no right to tell. The tombstone shows that Vladek and Anja are reunited in death. There is undoubtedly pain and complication that will persist after Vladeks death, but the peaceful grave quells these concerns. This is clearly a tribute to Arties love and forgiveness towards his parents. Artie knows that death does not resolve the relationship between him and his parents, but it is still a sign that Artie has moved forward and that love persists despite the conflict they endured in life. Artie has relinquished his anger and respects their memory peacefully. His story does not have an easy or pleasant ending, but Artie acknowledges the fact that he needs to let go. Arties peaceful release does not placate his wounds and suffering nor does it mend what his parents endured. The significance and depravity of a story such as theirs perhaps has no redemption. The last page shows that Artie must settle for some semblance of a resolution and learn to live with pain and anguish when he is unable to vanquish it himself.

Saturday, May 23, 2020

Asian American And Pacific Islanders Essay - 1981 Words

Introduction Asians have migrated to and have lived in the Americas since the days of our founding fathers. The first to come from the Eastern Hemisphere were a small group of Filipinos in the early 18th century that settled in present day Louisiana. The first major influx of Asian Americans was Chinese Americans who came in the 1800’s to find financial opportunity during the California gold rush. They settled in the Golden State and eventually spread out all over the United States, creating the now-famous Chinatowns that millions of Americans visit every year. There is a continual migration of well educated South Asians and East Asians for job and education opportunities and their success has formed the basis for the â€Å"myth of the model minority† (MMM). This is the idea that all people who are Asian American and Pacific Islanders (AAPI) are successful both socioeconomically and educationally. This does have a logical basis rooted in statistics—AAPI students are reported to have higher grade point averages, math scores, and overall standardized tests scores on tests such as the Scholastic Aptitude Test (SAT) and the American College Testing Exam (ACT). Other studies often use a racialized rhetoric comparing Asian Americans to white Americans in terms of education and socioeconomic status while contrasting them to the so-called â€Å"lazy† and â€Å"incapable† Hispanic and African Americans. The term â€Å"model minority† was first coined in a 1966 New York Times article written by WilliamShow MoreRelatedAsian American And Pacific Islanders2310 Words   |  10 PagesIntroduction Asian American and Pacific Islanders (AAPI) are one of the fastest growing minorities in the United States. 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Monday, May 11, 2020

The Power Of Independent Governance - 1629 Words

Topic A primary element in statehood is the quality of independent governance of its intrastate state and international duties from any external powers without which would render it a client state. The second limb of independent governance can largely be gauged by the degree of power a state has to converse with the international community and assert itself as an independent personality subservient to no other nation. Both the executive and legislative external affairs powers have evolved in lock step with one another and they should be viewed alongside each other. The external affairs power began with a narrow scope in regard to treaties with Australia as subservient to Britain on the international stage and there onwards has increased†¦show more content†¦From this the Original scope of the external affairs power was narrow and the element of the aforementioned power lay within the hands of the empire; that being the ability to enter into treaties or avoid entering into them independently. (1906) Six years after federation, Sir Isaac Isaacs then Attorney-General advised the Prime Minister on the aforesaid section with the observation that an express legislative power as to treaties would probably have enabled the Parliament to provide for the making of treaties by the Commonwealth without being expressly sanctioned by the Imperial Parliament of the Crown. At that time the Imperial Government could conclude treaties for the whole Empire. Nevertheless, he concluded that despite the removal of the reference to treaties in section 51(xxix) of the Constitution, the external affairs power still gave the Commonwealth Parliament the power to make such provision as is necessary to enable the obligation to be fulfilled . Although this was not in a judgement it was significant enough to intimate that the ‘External affairs’ power was slowly being interpreted more liberally wherefrom the powers in regards to implementing treaties was largely derived. (1911-1939) Political changes In the 1911 colonial conference, Sir Edward Grey, on behalf of the UK Government, assured the empireShow MoreRelatedThe Success Or Failure For The Walt Disney Company Essay1502 Words   |  7 Pagesmanagement to their organisation. 1.2 A - Definition of Corporate Governance Corporate governance is the internal and external framework of verification and counterbalance to the organisation. 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Shareholders should be provided with information about the composition, role and function of the audit committee in order to assess its effectiveness. Corporate Governance Disclosure Source Details of the composition of the audit committee, the work undertaken during the year and the numberRead MoreCaterpillar: Organizational Structure and Corporate Management Controls1092 Words   |  5 PagesSTRUCTURE/CORPORATE MANAGEMENT CONTROLS âž ¢ Corporate Governance Mission Statement: o Caterpillar’s corporate governance program ensures we serve the interests of stockholders and other stakeholders with the highest standards of responsibility, integrity and compliance with all laws. These standards are guided by our board of directors and global management team, who work to oversee the company’s actions, performance and governance policies. âž ¢ âž ¢ Announced that it is aligning itsRead MoreU.s. Corporate Governance System1325 Words   |  6 Pagescorporate governance system is maximization of shareholders value, thus executive compensation in U.S. are based on nature of the job performed and is linked to performance incentives such as bonuses or stock ownership. On the other hand, Japan and France corporate governance system objective lies on the mutual benefits of stakeholders, therefore their compensation is dependent on the achievements of the corporate overall objectives. Although all three countries uses different governance system, allRead MoreThe Rules and Principles of Corporate Governance Essay913 Words   |  4 PagesCorporate governance often refers to a set of rules and principles by which a company is directed. It provides a guideline for directing a company in order to fulfil its objective, brings added value to the enterprise, and is beneficial to the shareholders in long-term. 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Wednesday, May 6, 2020

Lying in Clinic Comprehensive Information and Management...

1. Introduction Today technologies are relevant to us. Thus, technology is fast changing in order for us to work faster, efficient and more convenient. There are lots of inventions and developed technological advances that improved our lifestyle, in school, in business, health, the food we eat, on how we communicate with each other and even how we travel around. So by this, it’s a big help for us to grow more productive and progressive. Computers can be of great help in storing of patient-related data. Nowadays, many hospitals employ computer system to maintain patient record and its detailed records of medical history of their patient. Yichang (2011) stated â€Å"along with information network era widely accepted, the safety of information†¦show more content†¦They can too easily monitor on how many patients they’ve accommodated monthly and the average on maternal normal deliveries by age division. 2. Framework This study considers the Input-Output-Process, a lso known as IPO+S Model, is a functional model and functional schema of the general system. The IPO chart identifies a program’s input, its output’s and processing steps required to transform the inputs into the outputs. 3 Figure 1. Input-Process-Output The researchers applied the Input-Process-Output for the system of which has many disciplinary applications and is used to convey systems in IT overview education and as a brainstorming, preliminary investigation tool in systems development processes such as the SDLC. It consists of at least three, and sometimes four, distinct components. In contemporary Information Technology, it is almost always discussed as a four component model in which the fourth is a named optional. Data has to flow into the system in some form. INPUT is the data flowing into the system from outside. The next stage in the information flow is the input data being manipulated in some way. PROCESS is the action of manipulating the input into a more useful form. The final stage in the information flow is normally to present the information in a userfriendly way. OUTPUT is the information flowing out of the system. By using this model, it is suitable for theShow MoreRelatedInadequate Sanitary Facilities At Dhaka Water And Sewerage Authority ( Dwasa ) Essay1596 Words   |  7 PagesAuthority (DWASA) can serve only for 15 to 20% of city population. In absence of the sanitation and infrastructural services, 40% having septic tank and soak pit, 15% using pit latrines and 30% using open latrines. The sewage is mostly released into low-lying areas and river water in untreated manner causing great environmental hazards. 4. Arsenic Contamination of Ground Water Arsenic in ground water poses a serious environmental hazard for Bangladesh. About ninety-seven percentages (97%) of BangladeshRead MorePain And Its Effect On The Quality Of Individual s Life Essay2352 Words   |  10 Pagesthat will have a negative effect on the quality of individual’s life. Having a clear understanding of pain definitions and characteristics is important in order to have a clear understanding of the pain concept which will lead to have a proper pain management (McCaffrey Beebe, 1989). In nursing practice pain is the most frequent nursing diagnosis and most common phenomena which patients in the clinical setting seek help for (Montes-Sandoval ,1990). Health care providers need to have enough knowledgeRead MoreRole of Training and Development in an Organization4665 Words   |  19 Pagesmarkets, and challenges. Warner Burke emphasizes that OD is not just anything done to better an organization; it is a particular kind of change process designed to bring about a particular kind of end result. 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Superfund Program Free Essays

Superfund Program Peggy Toler E. Hansen/EVS1001-31 March 31, 2011 Peggy Toler 2 Superfund Program I did not know what a Superfund program was until I looked it up and then I found out that it is an act that is the cornerstone legislation that provides the mechanism and funding for the cleanup of potentially dangerous hazardous-waste sites and the protection of ground water and human health. When you live near a superfund site, you and your family are at risk of developing a disease from the exposure of the different pollutants in these sites and may experience a loss of value of your property. We will write a custom essay sample on Superfund Program or any similar topic only for you Order Now The EPA says that there are steps that we can take to fight back. They have also said that they have set up a â€Å"Post Construction† strategy to ensure that Superfund response actions provide for the long-term protection of human health and the environment. The Construction Completion activities also involve optimizing remedies to increase effectiveness and /or to reduce cost without sacrificing long-term protection. There is still a health hazard for those who live close to a Superfund site. The site that I have found in my state was the Chemtronic, Inc. in Swannanoa, NC. It is about 1,027 acres and only about 20 acres in total are contaminated with these pollutants. This property has had several owners and operators and it was first developed as an industrial site in 1952. After first opening the first products that were manufactured on this site were explosives, incapacitating agents, and chemical intermediates. There are about 23 individual on-site disposal areas that were identified during the investigation activities on this site. During 1971, the disposal practices were not well defined. Solid waste materials and possibly solvents were reportedly incinerated in pits dug in the burning ground these pits are known as the Acid Pit Peggy Toler 3 area. There are the chemical wastes that were also disposed of in the trenches located in the Acid Pit Area. All of the activities at this site ended in 1994, and no new activities are occurring on this site. There is no on-site ground water and surface water being used in any way for anything. This site is bordered up on the North and West sides by woodlands and primarily national forests. There are several industrial facilities to the immediate South of this site. In the contaminants contained in these on-site disposal areas there are volatile organic compounds which include (1,2-dichloroethane, trans-1,2-dichloroethane, trichloroethane, and tetrachloroethane), semi-volatile organic compounds which include benzophenone, benzylic acid, and explosives, and then there are the metals like chromium, copper, lead, nickel and zinc. The contaminants that are detected in the ground water include benzene, chloroform, 1,2-dichloroethane, trans-1,2-dichloroethane, trichloroethane, benzophenone, benzylic acid, picric acid, explosives, chromium, copper, lead, nickel, and zinc. The site cleanup plans were issued in 1988. The major cleanup elements for this site include the installation of a ground water extraction and treatment system down gradient of the disposal areas in both the front valley and the back valley which is known as the Gregg Valley, capping and fixation/stabilization for contaminated soil in the disposal areas. These capped areas are fence with a chain-link fence and marked. Then they have a monitoring program to be established for the surface water. The ROD has issued an amend for this site in 1989, that specified the deletion of the requirement to solidify soil in Disposal Area (DA-23) as a result of an error in the remedial investigation data which was carried over into the initial ROD. Peggy Toler 4 With the cleanup progress with the capping and stabilization/solidification or the contaminated soil in the disposal area began in 1991, and was completed in 1993. They have placed multi-layer caps in the following areas DA-6, DA-7/8, DA-9, DA-10/11, DA-23 and in the Acid Pit Area. They have also installed a gas venting system at the Acid Pit Area. The Rod of 1988, addressed only those disposal areas that were deemed CERCLA related. The other disposal areas on the property were considered Resource Conservation and Recovery Act also known as (RCRA) areas as prior to 1994. The potentially responsible parties (PRPs) for the site undertook corrective actions to improve the operation of both the extraction systems and treatment systems in both valleys. The corrections that have taken place have significantly reduced the down time to these systems experienced in the past. There have been two reviews that have been developed for the site in 2002 and 2007. The review that was done in 2007, they found that the site was protective of the human health and the environment in the short-term. The NC Department of Environment and Natural Resources requested that the EPA consolidate oversight of all site environmental remediation activities under the EPA’s superfund authority and relinquished the state’s RCRA oversight responsibilities for the site to the EPA’s Superfund program in March 2007. Recently the PRPs submitted the draft RI/FS Work Plan based on the Administrative Order on Consent (AOC) and accompanying statement of work. These cleanup activities have been undertaken by the PRPs with EPA’s oversight. Peggy Toler 5 There are three viable PRPs for the site that has been identified by EPA and they are Chemtronic, Inc. Northrop Grumman System Corporation, and CAN Holding, Inc. In 2008 the AOC signed by the PRPs and the EPA will address the cleanup for the former RCRA areas at the site that will now be addressed under CERCLA. The EPA has conducted a range of activities for the community to get involved at the Chemtronic site to solicit the c ommunity input and to ensure that the public remains informed about any of the site activities throughout the site cleanup process. These outreach activities include public notices, interviews and public meeting on these cleanup activities and updates. In the future they are monitoring the ground water at the site, they say that the field work for the revised RI/FS should begin in the summer of 2009, and the next FYR for these sites is expected in 2012. As you will find out the more we try to cleanup areas like this, we have other pollutants in the world. There are things that we can do to help with these pollutants like cleaning everything that we can and stop putting things into the ground. References * Boorse, D. F. amp; Wright, R. T. (2011) Environmental Science (11 Edition) * www. epa. gov/region4/waste/nplnc/chemtrnc. htm How to cite Superfund Program, Papers

Year of Wonders free essay sample

Year of Wonders suggests that adversity brings out the best and the worst in people. Do you agree? In  Year of Wonders, Geraldine Brooks recounts the tale of a small 17th century English village afflicted by the plague, through the honest and reliable narration of Anna Frith. The novels title alludes to the idea that though the plague is devastating, it gives rise to wonders. Brooks presents to readers an insightful exploration of the diverse reactions that people can have to adverse circumstances, from Anna Friths exceptional growth to Aphras descent into madness. She also acknowledges the complexity of human behaviour: adversity is not always polarising, and peoples responses lie on a spectrum, where the distinctions between right and wrong are sometimes blurred. As the plague wreaks havoc on the villagers, it drives many to commit horrible atrocities. In contemporary England, witchcraft was a common accusation in times of adversity, and Mem and Anys Gowdie are particularly vulnerable to become scapegoats, being independent women with knowledge of herblore and midwifery. We will write a custom essay sample on Year of Wonders or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page Brooks shows her readers how difficult circumstances can lead seemingly rational, kind people to turn against those who had never wronged them. Fuelled by hysteria, a panicked mob murders the Gowdies, who were prime targets as Aphras superstitious mutterings found many willing ears amongst the villagers. We also see how adversity brings out the worst in people such as Josiah Bont, who takes on the role of sexton. Josiah, who loved a pot better than he loved his children, was a product of an abused childhood at sea. As a result, he was an exceptionally cruel man, violently assaulting Anna when she was a child and subjecting her mother to the branks, though such punishment was not uncommon in the mid-seventeenth century. Nevertheless, he truly is at his worst when he attempts to bury a man alive and steal all of his possessions, and the community is rightfully outraged. Josiahs actions are all the more horrible, as he takes advantage of his neighbours in a time of grief and hardship. Not everyones actions are satanic, and evil, however. In Annas character, we see her rise out of her fog of grief and go on to do much good in the world She grows as she overcomes her pathological fears of mines and childbirth, becoming an expert midwife, and braving the mines in aid of young Merry Wickford. Through her defiance of the Bradfords and her father, we also see Anna become more courageous and embrace [her] state, alone as a woman in the world. Brooks emphasises this through her use of a circular structure, as Anna is presented to readers in the Autumn of 1666 as headstrong and liberated: though a servant has no right to stay, once she is dismissed, Anna defies orders in order to tend to Michael. She has grown from the timid girl who had worked for the Bradfords in a state of dread into Anna Frith, a woman who had faced more terrors than many warriors. This is in stark contrast to the Anna we meet in Spring, 1665; a widow of eighteen who misliked herself for giving into her fears. We see the full extent of Annas growth and change in the Epilogue, as she breaks free from her old life of servitude, becoming independent and leading a rewarding life under the tutelage of Ahmed Bey. Nevertheless, the human psyche is not completely divided into dark and light. Year of Wonders  not only shows us the best and worst in people, but also the patchwork of greys in between. Michael Mompellion is a natural leader, rising up to carry his parishioners through their self-imposed quarantine. He upholds his promise that while I am spared, no one in this village shall face their death alone and works tirelessly, driving himself to the brink of exhaustion in the process. Despite this, not all of his decisions reflect exemplary leadership, such as his harsh treatment of Elinor. After the plague has passed, we see this through Annas perspective, and she is horrified by his coldness, yet Brooks also makes it clear that Michael truly believed that his decision was right at the time. Michael has lost his faith by this point, and believes that he was most wrong in asking the villagers to quarantine themselves. From the readers perspective, some of Michaels actions are morally ambiguous. They do not have that bright, clear-cut edge, as in times of crisis, decisions often become a choice between the lesser of two evils. We may pity him after Elinors death, as he is overwhelmed by grief, remaining still and silent in his soporific state, yet we also expect him to demonstrate his leadership and therefore might be harsher in our judgement of him. In  Year of Wonders, Geraldine Brooks explores many facets of human behaviour in response to crisis; both the good and the bad. Though we clearly see the best and the worst in some characters, it is difficult to pass judgement on others, whose actions sometimes lie between the two absolutes of best and worst. In any adversity, circumstances can cause people to do horrible things, but we must remember that if you are drowning in a sewer, your first concern might be that you are drowning, not how vile you smell.

Thursday, April 30, 2020

The inspection of the register should reveal the identity of the owner, the nature of his ownership Essay Example

The inspection of the register should reveal the identity of the owner, the nature of his ownership Paper Land is elemental: it is where life begins and it is where life ends. Land provides the physical substratum for all human activity; it is the essential base of all social and commercial interaction. The significance of land in human affairs is therefore incalculable, although it is only in an era of global environmental threat that we slowly begin to realise how fragile and irreplaceable is the rich resource on which we so utterly depend. As one English law lord recognised, [in] the case of real property, there is a defined and limited supply of the commodity. Gray Gray, Elements of Land Law (3rd Edition, 2000) Butterworths Before the 1925 property legislation, the mechanics of conveyancing were mired by formalism and plagued with danger even for the most conscientious purchaser. On one hand, purchasers of land were faced with numerous difficulties when trying to ascertain whether any other person has rights or interests in that land. The reliance on title deeds to prove ownership of land was both cumbersome and, for the purchaser, an expensive way to prove title, especially given the multitude of legal and equitable estates that could exist. On the other hand, an owner of equitable interest in that land might find that the interest was destroyed by a simple sale to a purchaser who was unaware of its existence. To meet both of those problems, a decision was made to move towards full title registration wherein all titles and the diverse interests in land would be recorded and guaranteed by the state. It was recognised, however, that this mammoth task had to proceed in stages and that a set of transitional provisions was needed. We will write a custom essay sample on The inspection of the register should reveal the identity of the owner, the nature of his ownership specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on The inspection of the register should reveal the identity of the owner, the nature of his ownership specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on The inspection of the register should reveal the identity of the owner, the nature of his ownership specifically for you FOR ONLY $16.38 $13.9/page Hire Writer Therefore, the Land Registration Act 1925 (LRA 1925)1 inaugurated a fundamental change in the law in England and Wales. In conjunction with the Law of Property Act 1925 (LPA 1925)2 and the Settled Land Act 19253, the LRA 1925 sought to simplify and codify. It aimed to bring certainty where there was obscurity and to bring equity where there was often inequality. The Land Registration Act 2002 (LRA 2002)4, which has replaced the 1925 Act completely, seeks to reinforce these goals and make the system fit for the twenty-first century and the electronic age. Firstly, there is a need to clarify that land in the England and Wales today is divided into two distinct types, that of registered land and unregistered land. There is a need for this as the law governing them are separate and different. Therefore, there is a need to describe what is meant by registered land. If a plot of land is described as registered, this means that title to it (that is, an estate of freehold, or leasehold) is recorded and guaranteed by the Land Registry. 5 In contrast, unregistered land is land to which title is not registered but is established by the title deeds of the particular property6. Unregistered land is now governed by the Land Charges Act 1972 (LCA 1972)7, while registered land is governed by the Land Registration Act 2002 (LRA 2002). As full title registration has yet to be achieved in England and Wales, therefore, a certain amount of unregistered conveyancing still remains. The LPA 1925 applies in full to unregistered land in the same manner as registered land. What is different is that the enforceability or rights and interests in unregistered land being those rights and interests capable of existing under the provisions of the LPA 1925 is governed by its own sets of rules and procedures. Unregistered land can be said to present a whole different problem in itself and therefore, for the purpose of this assignment, we shall focus on the law relating to registered land. The basic principle of the LRA 1925, and now the LRA 2002 which governs registered land, is that title to land should be recorded in a register and guaranteed by the state through title registration and interests in land should either be apparent on physical inspection of the land itself or noted on the Register. Registration of title replaces what were previously deeds of title and the Register should aspire to record the totality of land ownership throughout the entire country. Essentially, this encourages and effects a shift from unregistered to registered land. The original 1925 timetable called for full registration of all land by 31 December 1955, but regrettably, only on 1 December 1990 did all of England and Wales become subject to compulsory registration of title8. It will be a while longer before near universal registration of title is achieved, but currently, over 85 per cent of all potentially registrable titles are in fact registered9 and the LRA 2002 does much to encourage voluntary first registration by owners of unregistered land by way of extending the situations which trigger compulsory registration, low fees for voluntary registration and the introduction of incentives10. It cannot be stressed enough that the advantages of registering land are obvious and aplenty. Purchasers could buy land in the certainty that they were purchasing land suitable for their requirements because the existence of hidden burdens were minimised, and owners of interests in land, such as easements11 and covenants12, had a relatively easy and inexpensive method of ensuring that their rights survived a conveyance of the land to a third party. However, this begs the question, is this really so? How certain can a purchaser be that the land about to be purchased by him is free from any burden and encumbrances whatsoever by just inspecting the Register? Martin Dixon, in his book, Modern Land Law, 6th Edition at page 38, said that The inspection of the register should reveal the identity of the owner, the nature of his ownership, any limitations on his ownership and any rights enjoyed by other persons over the land that are adverse to the owner13. This is what has come to be known as the mirror principle. The mirror principle is one of the three fundamental principles of land registration which was laid down by Theodore Ruoff in 1963, after he was appointed as Chief Land Registrar14. This can be said to be akin to the concept of a personal identification card it is supposed to provide certain information of a particular individual such as ones home address, gender and nationality, and this information should indeed reflect that individual precisely. The mirror principle suggests that the Register should be a mirror for all the proprietary rights both estates and interests that exist in any given piece of land. Thus, the Register should amount to a comprehensive picture of the land for any prospective purchaser. Sad to say, however, that the register of title is not a perfect mirror of the title to a registered property. It is not possible to rely on entries on the Register as the complete record of everything that affects the title (per Peter Gibson LJ, Overseas Investment Ltd. v Simcobuild Construction Ltd)15. Unfortunately, the 1925 Act failed to eradicate all cracks in the mirror, instead preserving the relevance of certain interests which may override registration. These overriding interests burden registered land by operating on a superior plane to other registrable interests, binding purchasers outright and disproportionately empowering the overriding interest-holder. Under the former law, the class of overriding interests which caused the most litigation was contained under Section 70(1)(g) of the LRA 1925. This subsection protected the rights of persons in actual occupation of the land or in receipt of rent save where enquiry had been made of them and their interest had not been disclosed. The justification for having such a category of interests which exists outside the Register is that they will be discoverable on inspection. The balance between the interest of the purchaser and the objective of the 1925 legislation should therefore be struck. The difficulty with this theory is that it assumes that overriding interests are all discoverable by inspection. Before the LRA 2002, this was not necessarily true. For example, the rights of an adverse possessor were protected under Section 70(1)(f) of the LRA 1925, but there was no requirement that he should be in actual occupation. His rights might not, therefore, have been discoverable on inspection; indeed, they might not even have been known to the vendor, as in Red House Farms (Thorndon) Ltd. v Catchpole16 where the owner was unaware that the defendant was shooting fowl on its land, and Prudential Assurance Co. Ltd. v Waterloo Real Estate Inc. 17, where a neighbour took over a party wall without the owners knowledge. Moreover, when an overriding interest will take effect becomes a question to be answered. A purchaser would have inspected the property before the completion of the disposition to him, but in registered land, this disposition does not itself transfer the legal estate to him and only happens when the registration is subsequently registered at the Land Registry. This then begs the question, should overriding interests be allowed to arise during the time between completion and registration? The majority of the House of Lords in Abbey National Building Society v Cann18 decided that the critical time was the date of registration except for interests arising under Section 70(1)(g) LRA 1925 which were a special case. Their Lordships decided that the date when actual occupation should be relevant is the date of the completion of the registration. This means that all other types of overriding interests can be created, without the purchasers knowledge, between completion and registration. This situation clearly shows that the Register is not the mirror it is supposed to be. It was for this reason that Lord Bridge in the Abbey National case dissented on this point, preferring the date of disposition as the relevant date for all overriding interests (except for local land charges). The concept of overriding interests within the system of conveyancing contrasts remarkably with the effect of the LCA 1972 in unregistered conveyancing. Any registrable interest left unprotected under that Act is void against specified categories of purchasers (Midland Bank Trust Co. v Green)19 to reflect the intention of the legislature in keeping the process of conveyancing simple and in protecting the purchaser. Overriding interests protected under Section 70(1)(g) of the LRA 1925 prove to be the most difficult. This was apparent in the case of Williams Glyns Bank v Boland20 where the equitable interest of Mrs Boland was held to prevail as an overriding interest against the legal mortgagee. There was nothing to prevent Mrs Boland registering protecting her interest as a minor interest on the register. For this reason, the legislature deemed that they should be protected regardless of their appearance on the Register. Paragraph 2, Schedule 3 of the LRA 2002 requires that inquiries are made of the occupier himself and not of his solicitor or the vendors solicitor. At this point, it should be noted that interests which override on a first registration of title are contained in Schedule 1 to the LRA 2002, while interests which override on a registered disposition are contained in Schedule 3. They are both basically the same, except for the rights of a squatter, but it is slightly larger in scope for Schedule 1. Additionally, there is no restriction on the types of legal easements which will be overriding as there is in Schedule 3. The concept of actual occupation is not further defined in Schedule 3 of the LRA 2002. Case law decided on the meaning of actual occupation and gave the term a wide meaning. It could include, for example, occupation through an agent as in Lloyds Bank Plc. v Rosset21. Although the occupation must in general be continuous, a temporary absence from the property will not cause the interest to be lost, as in Chhokar v Chhokar22. A further problem with Section 70(1)(g) LRA 1925 was brought about by the case of Ferrishurst Ltd. v Wallcite Ltd. 23, where it was held that where a person who is in occupation of part only of property over which he has rights may assert those rights as regards the remainder of the property in the title of which he is not in occupation. It must be accepted that overriding interests in general represent a considerable departure from the fundamental principle that the Register is a mirror of the title. The Law Commission therefore made perfect reflection a priority, and it remained the fundamental objectives of the land registration system. The Law Commission had been working on this task for some time, but the publication of the Law Commission report No 271, Land Registration for the 21st Century a Conveyancing Revolution24 including a Draft Bill brought the process to fruition. In this report, the Law Commission strived to close the cavernous crack in the mirror. The Land Registration Bill 200125 eventually became the Land Registration Act 2002 and this statute came into force on 13 October 2003, completely replacing the LRA 1925. Consequently, the 2002 legislation attempts to reduce the effect of overriding interests, both by eliminating certain categories and by inaugurating a change in the way that we think about these important rights. The LRA 2002 can be said to achieve a reduction in the categories of overriding interests by making some of these interests registrable (leases over seven years and express easements), and by restrictions on the actual occupation provision. Rights of adverse possession have disappeared altogether as overriding interests, and an entirely new regime has been introduced for adverse possession. It must be noted, however, that overriding interests were not an accident in the 1925 legislation, and although redefined and narrowed in the 2002 Act, they remain crucial to the proper functioning of the system. They were deliberately created by the legislature and given automatic effect precisely because they should be obvious to any prospective purchaser or their enforcement is too important to depend on registration. However, here is the problem: social and judicial developments have enlarged the opportunity for the existence of overriding interests with the result that it is conceivable that a purchaser might not be able to determine whether such interests exists by inspection of the land. The most obvious example is the right of equitable ownership, stemming from Pettitt v Pettitt26, whose effect under the old Section 70(1)(g) of the LRA 1925 on an unwary purchaser was first fully appreciated in Williams and Glyns Bank v Boland27. Therefore, this difficulty concerning overriding interests was a major reason why the Law Commission recommended a reduction in their scope and effect and this has now been implemented in Schedule 3 of the LRA 2002, as explained above. It can be said that the 2002 legislation tackled much that was inaccurate, unwieldy, incomprehensible, inconvenient and downright wrong in the 1925 system. Many of its provisions deal with technical matters that, while important, establish no new principle. These are the tidying up aspects of the legislation. However, there is much that is groundbreaking or truly significant, not least the claim that the 2002 Act replaces registration of title with title by registration. More disappointingly is the existence of overriding interests which remain, and therefore continue to deny the mirror principle. The register today is not yet a perfect reflection of reality. It is clear that the mirror principle is still not fully entrenched in the England and Wales system primarily because of the existence of overriding interests. Although the LRA 2002 seeked to ensure that interests override only when they are (or should be) obvious to a purchaser conducting a reasonable inspection of the land, however, the point is this: even with overriding interests, the sensible purchaser should not be unaware of binding overriding interests. Therefore, it can be said that the 2002 Act only does so much to ensure it is not clear-cut and apparent at first inspection of the Register, and this means that it leaves no space for a purchaser to be careless or flippant when inspecting the land. For that reason, there is a need to ask the question: how then, can the mirror principle be truly effected in totality in the system of registered land in England and Wales in this present day and age? We look at the role of e-conveyancing and ask ourselves its role, and the direction it is heading towards. The mirror will only be a perfect reflection when all proprietary rights both estates and interests that exist in any given piece of land are registered on the Register. Consolation lies at the advent of compulsory e-conveyancing, promoted heavily by the 2002 Act, which envisages synchronicity of disposition and registration in land transfers. This development will render many equitable interests unprotected unless registered, despite being currently overriding upon actual occupation. Schedule 3, paragraph 2 of the LRA 2002 will then be restricted only to the protection of those occupiers interests which arise informally, through resulting or constructive trusts or through estoppel, effectively narrowing an occupiers ability to override registration. The underlying and pervading expectation that overriding interests will eventually be drawn onto the Land Register through positive registration will ultimately abolish the subsistence of occupiers unregistered and overriding interests upon a transfer of registered land which so adversely affects purchasers. Section 71 of the LRA 2002 provides for a general duty of disclosure whereby an applicant for registration of a title must disclose a range or overriding interests that affect his land so that they may be protected by registration28. E-conveyancing depends on the register being as up to date as possible and the duty of disclosure is one method by which the Register becomes more mirror-like. Therefore, it seems that that is the best way forward for the future of conveyancing and thus, it is lucid that the mirror principle does not reflect English land law today. Although the LRA 2002 is a good step forward, the mirror principle as it stands today is merely in theory, and it is flawed. However, it is hoped that with the development of the law and the future of e-conveyancing, the mirror principle will entrench itself as one of the hallmarks of English land law.