Prepare a report for the board of directors of Summer Bodysuit Ltd Coursework

Set up a report for the top managerial staff of Summer Bodysuit Ltd that investigations the issues looked by the organization and that sets - Coursework Example 2. To read whether bank’s demand for a critical decrease in the overdraft office allowed to Summer Bodysuit Limited is sensible. Structure of the association The money related issues in an organization emerge essentially because of shortcoming in the structure of the association. Jill Dempsey and Mike Greaves have great involvement with the company’s business. The plan of action, planning and assembling of easygoing and relaxation garments pointing especially at the more youthful and higher-salary showcase, is in accordance with their experience. Be that as it may, the shortcoming in the association structure lies in absence of legitimate framework for monetary administration. Money related administration is a particular territory which needs aptitude for effectiveness in business tasks. Keeble brothers’ association in the everyday business exercises has been extremely constrained. The business has developed well over the timeframe and the request as of late got from Arena, a chain of easygoing and sportswear stores is seen especially significant. The draft accounts from the Auditors affirm the company’s achievement. However, absence of reasonable framework for working capital administration and arranging in capital venture has handled the organization in the current money related challenges. Relationship with the bank and anticipating the future The bank needs the organization to lessen the overdraft considerably throughout the following a half year. The organization had penetrated its overdraft limit on a few events in the course of recent years. The administration knows about the way that the tolerance of the bank has been wearing ragged. The biggest investor of the business is Keeble Estates Ltd, possessed by David and John Keeble. Neither one of the they are in a situation to make further speculations nor ready to acknowledge ventures from new speculators, dreading loss of impact over the organization. It is in this setting the examination is done to make appropriate suggestions for taking fundamental activities to defeat the current budgetary challenges. Business activities Dechow et al (2010) state, â€Å"the nature of a ?rm’s income relies upon both the ?rm’s ?nancial execution and on the bookkeeping framework that measures it.† Prima facie the organization has not agreed the merited consideration regarding bookkeeping in the association. The administration has set out on speculation binge without making important plans for the extra working capital required for its activities. David et al (2007) states that â€Å"overcon?dent directors think little of hazard and in this way take activities with extreme risk†. Assessment of the business possibilities includes investigation of a few variables identifying with the business. Schrand and Zechman (2009) express that â€Å"the arrogant chiefs make hopeful gauges and so as to meet these conjectures, show more significant levels of extortion and income management.† Though the outcomes don't in any capacity recommend misrepresentation its administration of fund calls for basic examination. Net overall revenue during the most recent two years has been at 14.99% and 20.61% separately which mirrors the adequacy of the strategic agreements of Jill Dempsey and Mike Greaves. The expansion in capital speculation and therefore working capital required extra ventures which are met fundamentally through bank overdraft. â€Å"An overdraft office empowers organizations to get transient financing - in spite of the fact that in principle the sum lent is repayable on request by the bank† (Riley, 2012). The investors are presently requesting that the organization lessen the

Chaser Free Essays

Reasoning 6: Ethical Issues in Business Midterm Essay Chase Novak Dr. Parker Need or Greed? New Protocol: How Drug’s Rebirth as Treatment for Cancer Fueled Price Rises Immanuel Kant-Kantian Deontology John Locke-The Justification of Private Property Adam Smith-Benefits of the Profit Motive Milton Friedman-The Social Responsibility of Business Is to Increase Its Profits Thesis: An assessment of the contextual analysis New Protocol: How Drug’s Rebirth as Treatment for Cancer Fueled Price Rises depends intensely on a sharp comprehension of the social and monetary ramifications of an industrialist framework, and once considered plainly Celgene Corp. is supported in raising costs dependent on the business showcase methods of reasoning affirmed by Adam Smith, Milton Friedman, Emanuel Kant, and John Locke. We will compose a custom paper test on Chaser or on the other hand any comparable subject just for you Request Now Word Count: 1690 Maybe the most troublesome circumstance in business emerges when the impoverished want the item being sold. Political weight is frequently put on the organization to bring down costs so as to suit the less blessed purchaser, be that as it may, this is in direct clash with the company’s central objective of making the biggest benefit conceivable. Issues are progressively mind boggling given the gracefully request parts of society and the impetus for creation. Thus ways to deal with business that stress benefit over accessibility can without a doubt help society from multiple points of view. Upon the topic of morals one must view the whole market overall and the advantages of rivalry when choosing a reasonable cost. An assessment of the contextual investigation New Protocol: How Drug’s Rebirth as Treatment for Cancer Fueled Price Rises depends intensely on a sharp comprehension of the social and monetary ramifications of an industrialist framework, and once considered plainly Celgene Corp. is defended in raising costs dependent on the business advertise ways of thinking attested by Adam Smith, Milton Friedman, Emanuel Kant, and John Locke. Celgene’s choice to raise costs is mind boggling and however from the start may seem, by all accounts, to be filled by voracity it is in certainty an important and useful advance in Celgene’s proceeded with creation of the medication thalidomide alongside looking into other clinical advances. Celgene Corp. ’s choice to steadily raise costs is legitimized by Adam Smith’s free market reasoning in which he portrays serious creation as the primary power behind cultural turn of events and improvement. Despite the fact that there has been little effect to the expense of creation for thalidomide, the nature of free market creation directed the ascent in cost. This, as indicated by Smith is a characteristic component of the free market, â€Å"As each individual [†¦] tries as much as possible both to utilize his capital in the help of residential industry, thus to coordinate that industry that its produce might be of the best worth, each individual essentially works to render the yearly income of the general public as extraordinary as he can† (Donaldson, 167). In this citation, Smith is clarifying how every individual’s individual take a stab at progress, as creation, assists with improving society all in all. In the event that each individual’s extreme objective is to build their riches, and whenever expanded riches is looked for through improved creation, at that point the opposition for riches will without a doubt bring about improved creation. Improved creation can mean either less expensive assembling, bringing about lower costs for the customer, or a superior item, which will likewise support society. Smith proceeds to state that this opposition is self-sustaining and that the benefit made off of creation is reinvested to additionally improve producing. Proof of this can be seen in the Celgene Corp. aising of costs on thalidomide which came about in, â€Å"The capacity to [†¦] support the pharmaceutical industry’s innovative work programs, which carry new drugs to patients† (Donaldson, 151). This can be additionally demonstrated by the way that Celgene’s RD division utilizes practically 50% of the company’s income (Donaldson, 154). In this mode l, Celgene can furnish buyers with more up to date and increasingly powerful medicine because of its serious evaluating of thalidomide. In spite of the fact that numerous pundits of Celgene would call the corporation’s choice to raise costs a truly covetous and egotistical act, Smith sees nothing amiss with such a move. On this issue Smith expresses that a people egotistical thought processes regularly improve society: â€Å"By seeking after his own advantages he much of the time advances that of the general public more solidly than when he truly means to advance it† (Donaldson, 167). Given Celgene’s saw conceited activities, Smith would take note of that this sort of free market conduct is certain and is guided by a â€Å"invisible hand† which encourages such conduct to be gainful to society in general. The following scholar to be inspected would contend that the â€Å"invisible hand† that Smith talks about is to be sure discrete from the political domain. Milton Friedman proceeds with Smith’s line of rationale as he attests that the central worry of the representative must be to make a benefit under socially adequate methods and that the characterizing of â€Å"social responsibilities† must be left in the political circle. Celgene’s CEO, John Jackson, was the essential power behind the company’s choice to raise costs. Jackson’s activities are splendidly moral as indicated by Friedman who composes, â€Å"What does it intend to state that the corporate official has a â€Å"social responsibility† in his ability as an agent? In the event that this announcement isn't unadulterated talk, it must imply that he is to act somehow or another that isn't in light of a legitimate concern for his employers† (Donaldson, 35). Jackson answers to a board that speaks to the investors of the organization and it is his moral commitment to them to make a benefit. Celgene was losing cash until 2002, which clearly required an expansion in value (Donaldson, 153). Jackson’s move to gradually build the cost of thalidomide was not untrustworthy on the grounds that he has a commitment to investors to convey a benefit. Moreover, Friedman states that it isn't the corporate executive’s occupation to go about as an ethical business visionary as he is poorly fit to do as such. Friedman focuses on that calls for administrators to act â€Å"socially responsible† are dishonest as socially effective choices, for example, value change, must be surrendered over to publically chose authorities with information on the social and monetary ramifications of such activities (Donaldson, 36). Friedman makes an essential point as it clarifies that the social duty falls on people in general and its publically chosen authorities to implement social judges through governing body. In this way in the event that the open wanted Celgene to bring down costs of thalidomide, at that point it must expect it to do as such through law. Besides since no law exists requiring Celgene to sell thalidomide at a specific value, at that point Celgene is splendidly moral and defended in raising its costs. On the off chance that officials like Johnson balanced costs as indicated by their own convictions, at that point immense bits of society would be vigorously influenced by such choices and accordingly the general population should claim all authority to unravel such social issues through vote based methods as law. Emanuel Kant’s reasoning of the â€Å"categorical imperative† additionally attempts to morally legitimize the valuing of thalidomide by communicating the requirement for a general standard of moral practice. Despite the fact that Kant would in all likelihood want a communist perfect world or possibly complete all inclusive social insurance, nor is practical in the current day. In a Kantian culture people would need free human services for everybody. No moral issues would be being referred to if everybody got their whole social insurance for nothing. The outcome is a determined comprehension of his unmitigated objective, which clarifies an ideal situation where on party acts onto another gathering in a similar way he himself wishes to be dealt with (Donaldson, 112). In this sense, under an entrepreneur framework, Celgene is reacting to the market by acting as needs be and raising its costs to build creation. The most fundamental component of morals lies in John Locke’s philosophical clarification of item proprietorship and it attempts to demonstrate Celgene’s option to raise its costs. At the very heart of business is the responsibility for private property which one chooses for sell for a benefit. As indicated by Locke, God made the earth for man to misuse for his own needs and in this way it is intelligent that a few men won't have normal responsibility for land (Donaldson, 158). Locke’s theory on private property clarifies that man has the privilege to possess property and that only he can picked how to utilize his property. Utilizing this support, Celgene’s responsibility for qualifies them for value it at any rate it sees sensible. Additionally this defense is moral since it contains the sole power behind creation. In the event that partnerships like Celgene can't hold the option to request their own cost for the items that they produce then there exists no motivation to create. As a general public we can't drive organizations to create fundamental data, innovation, or medication without a motivating force. That isn't the means by which society works. Or maybe, our general public is works under an impetus based framework, which utilizes rivalry to incite the best and most splendid to create the most significant items for society’s use. On the off chance that Celgene was made to sell their items at a cost helpful for the customer yet devastating to the maker then creation would decrease and society would flounder. Along these lines to guarantee proceeded with creation and quality organizations, for example, Celgene must be permitted to direct busines

Business Group Report - Australian Hardware - Free Essay Example

Business Report The type of existing business of my choice is hardware firm used to work in Melbourne by the name of Australian Hardware. Its first store opened in 1921 in Sydney. It was famous for making different type of small households as well as furniture. After getting fame by people, the business was expanded and four new branches were opened by 1928 in just 7 years, it employed 60 permanent workers. They were mostly the friends or relatives of the one who started this business. But in 1930, there was some decline in the business and they were asked to close their three stores but somehow the situation was handled as people working there on full-time so it was hard to find jobs by all of them and they all tried to managed the business and even by 1937, two more branched were opened by the struggle of workers they got rid of great tribulation. It was again somehow affected in Second World War in 1941. But then the management of the firm started giving training to its employees and strengthened the relation between salesmen as well as done many contracts. In 1982, Australian Hardware was listed on Australian stock exchange and till now providing significant benefits to its customers. It basically makes different instrumental tools fo r construction, house wares, paints garden for those who like to feel natural. Now after describing about the background of business, ità ¢Ã¢â€š ¬Ã¢â€ž ¢s necessary to focus on the type of data it should gathered to run effectively and for following all of its tasks properly. All relevant sales trends must be reported and analyzed. Information about external environment including products of rival business will also be gathered to know about their quality of type of service they provide to customers. Annual reports of different private companies will be observed to find the way they got success. Publication as well as their online databases will be thoroughly studied to operate business effectively and economically. Nature and behavior of customers will be observed to get information what they want so that products can be developed accordingly. The data of employees will also be gathered but it will be sure that their privacy does not get compromised (Stengel, 2001). So this was a ll about the kinds of data that will be gathered. The important thing after gathering all information is that how business will get benefit from it as well as all the other data saved in their databases. It can improve the mode of doing business and knowledge in information system can help in accessing the data faster. All the right information classified can help in proper decision making as well as better service can be delivered to the customers as all the information will be in the information that can be easy to locate. Time will also be saved and continuity of business can also be improved lastly, ità ¢Ã¢â€š ¬Ã¢â€ž ¢s a cost saving method of using all the useful gathered data that helps in the efficient operation of the business (Naa.gov.au, 2014). There are some knowledge requirements of business which are necessary to be known while operating an Australian hardware. Different tasks and activities should be designed for monitoring of business which is the key requirement and without having knowledge of monitoring process; a business cannot run in right direction. Different mitigated risks must also be studies and knowledge should be gathered so that firm can handle any risks in effective manner. It is also the knowledge requirement of the business to be aware about the way business analyst work with stakeholders which involves communicating requirements how they resolve different conflicts by getting agree on a single idea. Another knowledge requirement should be about the stakeholders and project team that they both get agree on the scope of the project and way project run otherwise conflicts between them will eventually cause a loss in business. Creating a marketing business plan in a detailed and well-structured way will also give right direction and help in gaining success to a business. Information system got their vitality by handling the information from organization inputs to produce data that is valuable for dealing with operations. To b uild the data frameworks adequacy, one can either add more information to make the data more precise or utilize the data as a part of new ways (Markgraf, 2014). The information system that would be good for the business would be transaction processing system. As the name suggests, transaction processing system (TPS) are intended to process routine transactions proficiently and precisely (Riley, 2012). It meets the information accumulation, storage, handling and yielding functionalities for the major operations of a business. TPS information system gathers information from client inputs and after that produce output which is totally based on the gathered information at input side. A suitable example of TPS framework could be an online air ticket booking system. In such a system, people select their date for booking of flight and the seat they want during journey which is input, and the system looks for the available seats, evacuating those chosen by the person already which is called as processing. The system then produces a bill and a copy of the ticket that becomes. TPS information system is bases normally on real-time operations, and can help entrepreneurs take care of demand without getting extra personnel (Davoren, 2009). There are some requirements for knowledge management system such as it should be scale as it should be able to support any number of clients as well as support large database of an organization. It should be extended at anytime as per need. It should be secure and be safe from any fraudulent most importantly it should be relevant as well as timely prepared according to work being done in a firm. Now the knowledge management system suitable for our business framework would be explicit knowledge. This kind of knowledge management system is formalized and systematized, and is also called as recognize what. It is accordingly simple to recognize, store, and recover. This is the kind of knowledge most effectively taken care of by KMS, which ar e extremely successful at encouraging the storage, recovery, and change of records and writings. From a managerial viewpoint, the challenge with this knowledge system is similar data. It includes guaranteeing that individuals have entry to what they require; that essential information is stored; and that the knowledge is surveyed, upgraded, or discarded. Numerous theoreticians see this type of KMS as being less paramount. It is viewed as easier in nature and cant contain the rich experience based ability that can produce competitive advantage having lasting effects (Frost, 2010). Capacity means the different sorts and levels of assets accessible to create and keep up a group anticipation framework that can distinguish and react to group needs. Inspite of the fact that the arranging methodology itself can reinforce limit, purposeful limit building at all levels aides guarantee that effective projects are managed inside a bigger group setting, and consequently less helpless against local budgetary and political changes. Effective capacity building additionally expands an associations or groups capacity to react to changing issues with creative arrangements. Organizational development is important to construct capacity and in addition to maintain successful prevention arrangements, systems, and projects, and consequently incorporates a supportability part. Following are the factors for building an effective building capacity: Administrative structures and formal linkages: These must be assembled and reinforced so that the associations and systems in charge of the execution, incorporation, and oversight of projects have the ability to do their capacities successfully and responsively and to manage them. Linkages that facilitate collaboration among different associations additionally help manageable quality. Asset development: Satisfactory and economical financing, staffing, specialized support, and materials can help manage innovations Johnson et al. (2004). Future updates requirements including hardware software requirements for system capacity capability of business are defined below: Usage analysis: It includes recognizing the different clients of the deployment one is outlining and deciding the usage pattern for those clients. The data one assembles gives a thought of the normal load conditions and is later used to focus the requirement of performance and other requirement of system. System requirements: It defines the nature of administration a deployed system must give to meet the business necessities provided by business research. One normally utilizes the usage analysis and use cases together with the business requirement to determine system requirement. Business intelligence, or BI for short, is a broad term that includes skills, technologies, applications and practices used to help evidence-based decision making in an organization. In the broadest sense it can be characterized as an collection of methodologies for gathering, storing, doing research by analyzing and giving access to information that helps clients to gain insight knowledge and bring about a significant fact-based decision of a firm. Organizations use this tool to increase data driven experiences on anything identified with business performance. It is utilized to comprehend and enhance performance and to reduce expenses and recognize new business practices as well as opportunities. This can incorporate among numerous different things: Investigating client practices, purchasing examples and business performance. Measuring, tracking and foreseeing sales and money related performances. Planning and budgetary arranging. Keeping record of the performance of marketing and advertising campaigns. Streamlining courses of action and operational performance (Marr, 2014). There are several requirements such as hardware as well as software troubleshooting requirements of securing the system of business which will discuss here. Hardware requirements include A Pentium-class processor running at 400 MHz or quicker, RAM, 256MB prescribed, 128MB minimum, LAN card, CD ROM 250MB accessible hard drive space. Concerning about security and protection of system in business will drive appropriation of cloud encryption system, yet there are six security issues that organizations ought to handle. The normal compound yearly development rate of software as a sevice (Saas) from 2011 to 2016 is 19.5%, platform as a service (Paas) 27.7%, infrastructure as a service (Iaas) 41.3% and security administrations using 22%. On the other hand, security and protection are still referred to by numerous associations as the top inhibitors of cloud services adoption, which has started the new era of cloud encryption system in the previous year. Experts propose that endeavors ough t to first create an information security plan that addresses six security issues. Disappointment to do thus, they say, could add expense and multifaceted nature to the adoption of cloud computing without tending to the key issues of protection of business data and long term security and flexibility. It is warned by analysts that not properly implemented encryption system might likewise interfere with the ordinary working of some cloud-based services. The six issues that must be focused are: Breach notification and data residency, data management at rest, data security in motion, encryption key administration, access controls long-term strength of the encryption system (Ashford, 2013). References: Stengel, G. (2001).Tips: The Tools Ten Tips for Developing a Meaningful Market Analysis. [Online] Stengelsolutions.com. Available at: https://www.stengelsolutions.com/tips_11.htm [Accessed 21 Nov. 2014]. Naa.gov.au, (2014).Benefits of digital information and records à ¢Ã¢â€š ¬Ã ¢â‚¬Å" National Archives of Australia. [Online] Available at: https://naa.gov.au/records-management/digital-transition-policy/benefits-of-digital-information.aspx [Accessed 21 Nov. 2014]. Markgraf, B. (2014).Importance of Information Systems in an Organization. [Online] Small Business Chron.com. Available at: https://smallbusiness.chron.com/importance-information-systems-organization-69529.html [Accessed 21 Nov. 2014]. Riley, J. (2012).ICT types of information system. [Online] Tutor2u.net. Available at: https://tutor2u.net/business/ict/intro_information_system_types.htm [Accessed 21 Nov. 2014]. Davoren, J. (2009).Types of Information Systems in an Organization. [Online] Small Business Chron.com. Available at: https://smallbusiness.chron.com/types-information-systems-organization-43097.html [Accessed 21 Nov. 2014]. Frost, A. (2010).Types of Knowledge. [Online] Knowledge-management-tools.net. Available at: https://www.knowledge-management-tools.net/different-types-of-kn owledge.html [Accessed 21 Nov. 2014]. Johnson, K., Hays, C., Hayden, C., Daley, C. (2004). Building capacity and sustainability prevention innovations: A sustainability planning model.Evaluation and Program Planning,27,135-149. Marr, B. (2014).Business Intelligence (BI) What is BI? Training, examples case studies. [Online] Ap-institute.com. Available at: https://www.ap-institute.com/Business Intelligence.html [Accessed 23 Nov. 2014]. Ashford, W. (2013).Six security issues to tackle before encrypting cloud data. [Online] Computerweekly.com. Available at: https://www.computerweekly.com/news/2240180087/Six-security-issues-to-tackle-before-encrypting-cloud-data [Accessed 23 Nov. 2014]. 1

Ethnodoxology The Theological And Anthropological Study

â€Å"Ethnodoxology is the theological and anthropological study, and practical application, of how every people group might use their culture s unique and diverse artistic expressions appropriately to worship the God of the Bible† The point about this article may be on reflect on the relationship for ethnodoxology and theology. At each purpose they allotment normal concerns, religious philosophy giving those substance Also ethnodoxology opening dependent upon culturally proper routes should express christian truth. Over particular, the ultimacy motivation behind both is doxology, those acclaim What s more glory of divine being. What Might make those possibility result of a more amazing partnership, though not a kaleidoscope of doxology? Imagine Mexican influxes of affection revolving around the globe, and Concerning illustration each planet region ascends will praise thus, it uncovers new tones, new sounds, new social progression, constantly on delicate of the distinguishmen t for divine force Furthermore from claiming as much Christ? no ethnic gathering may be prohibited and the a standout amongst a sort offerings of the humblest tribes would welcomed with remarkable delight. Ethnodoxology is exhibited and the magic clue about heart music clarified, close by its vitality for christian administration. Should A percentage degree 2, we transform our attention viewing true meeting-purposes from claiming religious logic Furthermore ethnodoxology, for example, disclosure, the

Personal Narrative Tha Thank You Essay - 860 Words

After I spoke those words I felt like there was a weight being lifted off my shoulders, but I still had an overwhelming need to cry. I could tell that Keith felt sorry for me but still he didn’t say a word. He probably didn’t know what to say. What did you say in a moment like that? There was nothing in the world he could have said that would have made me feel better. My whole world was crashing down around me. All I wanted to do was crawl into a hole and never come out again. â€Å"Let me get you home.† He finally said after starting his car. â€Å"Tha†¦ Thank you.† I was grateful. I just wanted to get away from the party. I never wanted to see Madison’s house ever again. I never wanted to see Mason or my sister. My depression was turning to anger, but I didn’t know which emotion was better. As Keith drove me home I just became angrier at them. How could they do this to me? Were they that heartless? Had I dated a monster f or four years? Why had I let him waste a part of my life like that? That was four years of my life I would never get back, and to think that during our slow dance at prom I was thinking about our wedding. I was angry at him, but I was also angry at myself. I was mad at myself for being so stupid. I should have seen it coming. My sister had always been jealous of Mason and me. She wanted what we had, never finding it with any of her boyfriends. She always commented on how handsome Mason was. And prom? She was all over him on theShow MoreRelatedEducation Reform And Curriculum Design2337 Words   |  10 Pagesseveral compliment pieces countering Lippmann’s claims. Dewey did not argue that much of the democratic processes as described by Lippmann were problematic. He conceded that current models were not ideal. However, he did reject any solution tha t erected a hierarchy with an amateur/expert citizen binary. Dewey believed the solution was to provide a better and more holistic education to the public, therefore enriching the public’s ability to discern media messages a nd avoid manufactureRead MoreThe Rise of Social Media and Its Impact on Mainstream Journalism21031 Words   |  85 Pagesof a much wider change in the media landscape. Futurologist Paul Saffo talks of the shift from mass media to personal media. He believes many traditional publishers will fall by the wayside in the process: The Mass Media revolution 50 years ago delivered the world to our TVs, but it was a one-way trip – all we could do was press our nose against the glass and watch. In contrast, Personal Media is a two-way trip and we not only can, but also expect to be able to answer back.7 For academics like ClayRead MoreSupporting the Development of English Literacy in English Language Learners22851 Words   |  92 Pages development, evaluation, and dissemination needed to transform schooling for students placed at risk. The work of the Center is guided by three central themes—ensuring the success of all students at key development points, building on studentsâ €™ personal and cultural assets, and scaling up effective programs—and conducted through research and development programs in the areas of early and elementary studies; middle and high school studies; school, family, and community partnerships; and systemic

Project Management for Internal Rate of Return - myassignmenthelp

Question: Discuss about theProject Management for Internal Rate of Return. Answer: Project Selection Methods According to Dutra, Ribeiro and de Carvalho (2014), the analysis of the project selection methods would be helpful for the implication of the improved selection of the project in terms of value and feasibility. The methods include the analysis of the project value by using Benefit to Cost Ratio, Payback Analysis, Net Present Value, Internal Rate of Return, and Discounted Cash Flow. As explained by Laosirihongthong, Samaranayake and McLean (2013), these methods would form the use of the effective and improved analysis of the projects and their operations so that the organization could decide whether or not to take the project and proceed with it. Impact of the absence of Business Case Dutra, Ribeiro and de Carvalho (2014) have stated that the absence of a proper business case would tend to result in, Absence of resource requirement analysis Unable for development of project goals and objectives Lack of initial requirement analysis References Dutra, C.C., Ribeiro, J.L.D. de Carvalho, M.M., (2014). An economicprobabilistic model for project selection and prioritization.International Journal of Project Management,32(6), pp.1042-1055. Laosirihongthong, T., Samaranayake, P. McLean, M.W., (2013). Prioritizing of Six Sigma project selection: a resource-based view and institutional norms perspective. InInnovation for Business Sustainability Organisational Development: Proceedings of the 17th International Conference on ISO TQM 17-ICIT: 23-25 Aug 2013 at NSW Parliament House UTS Business School, Sydney, Australia(pp. 1-9). Wang, F.K., Hsu, C.H. Tzeng, G.H., (2014). Applying a hybrid MCDM model for six sigma project selection.Mathematical Problems in Engineering,2014.

Law and Religion free essay sample

Law and Religion 4/19/2012 Laws of General Applicability and Their Effect on Religion in America In 1990 the doctrinal landscape of free exercise was greatly altered by the groundbreaking case, Employment Division v. Smith. Prior to Smith, Federal free exercise cases were governed only by the opinion in Sherbert v. Verner. This required any law which placed a substantial burden on the exercise of religion be formed in the least restrictive fashion and to be justified by a compelling state interest. However in Smith the court articulated a new test for laws that placed a substantial burden on the free exercise of religion, holding that the law need not be supported by a compelling state interest so long as the law is neutral and of general applicability. In the analysis below I wish to first address the religiously burdensome laws upheld under the Smith test, requiring only neutrality and general applicability, without regard to a compelling state interest, and second, what laws following the decision in Smith were still shot down notwithstanding their neutrality and general applicability. We will write a custom essay sample on Law and Religion or any similar topic specifically for you Do Not WasteYour Time HIRE WRITER Only 13.90 / page The establishment clause in the Constitution states that congress shall make no law respecting the establishment of religion. In Lemon v. Kurtzman it was established that in order for a law to pass under the establishment clause it must have a secular governmental purpose, its primary effect must not be to advance or inhibit religion and lastly the law must not result in excessive governmental entanglement. What we are primarily interested in for the purpose of our analysis however, is the second clause of the first amendment requiring that the government not prohibit the free exercise of religion. Post Smith, under the free exercise clause at common law, a law must only be neutral and of general applicability to survive a constitutional analysis, even where the law substantially burdens religion and the compelling governmental interest standard is not met. In the following discussion we will address what laws have survived under this test and the effect they have had on religion in America. Religiously Burdensome Laws Upheld, and their Consequent Impact on Religion As stated above, it was in Employment Division v. Smith that the court first implemented this standard of neutrality and general applicability. In Employment Division v. Smith, Alfred Smith and Galen Black who were both members of the Native American Church and counselors at a private drug rehabilitation clinic were fired because they had ingested peyote, a powerful hallucinogenic drug, as part of their religious ceremonies. At that time intentional possession of peyote was a crime under Oregon law without an affirmative defense for religious use. The majority opinion in Smith stated that although ordinarily a religiously burdensome law only survives constitutional scrutiny if there is a compelling state interest, when the law applies to everyone equally and the intent behind the law is not to regulate the exercise of religion, a compelling state interest is not required. Under this standard there is no room for the individualized consideration of the reasons a person might have for using peyote. In Smith the Supreme Court has sharply limited scrutiny of incidental burdens in the context of religion. The opinion states that if it permitted a wide approach to prohibiting religiously burdensome laws, it would be too easy for citizens to evade a multitude of important laws. This approach would run contrary to public policy and the very reason that we have a society governed by laws in the first place. Another famous utilization of this standard was in Christian Legal Society v. Martinez. Here a student organization, the Christian Legal Society, required members to subscribe to a Statement of Beliefs and refrain from certain proscribed behaviors, including homosexuality. The school subsequently refused to recognize the group as a student organization pursuant to its Nondiscrimination policy. Following this, CLS sued the school alleging that the policy conflicted with the group’s constitutional right to the free exercise of religion. The court rejected CLS’s free exercise argument, stating that the Nondiscrimination Policy did not single out religious beliefs, but rather was neutral and of general applicability. In this case the application of the Smith standard is perhaps less informative then it was in Smith. Here we are not only using the standard to burden religion, as it was in Smith, but also as a tool to protect against discrimination. With the additional force of Civil Rights available to swell its ranks, the full extent of the standards power is perhaps not visible, however this case does illustrate a new and innovative application of this concept that Smith had first brought to the table. Laws That Failed Because of the Burden They placed on Religion In Lemon v. Kurtzman we saw that in order for a law to pass under the establishment clause it must have a secular governmental purpose, its primary effect must not be to advance or inhibit religion and lastly the law must not result in excessive governmental entanglement. Ordinarily a religiously burdensome law would only be upheld if it survived the strict scrutiny test. However Smith changed this level of review in cases where the law in question was neutral and generally applicable. In Church of Lukumi v. City of Hialeah the U. S Supreme Court held that a religiously burdensome ordinance passed in Hialeah Florida failed the neutrality requirement of the Smith standard and subsequently did not pass strict scrutiny as was required. The Florida ordinance forbade the unnecessary killing of an animal in a public or private ritual or ceremony not for the primary purpose of food consumption. as unconstitutional. The law was enacted soon after the city council of Hialeah learned that the Church of Lukumi Babalu Aye, which practiced Santeria, was planning on locating there. Santeria is a religion practiced in the Americas by the descendants of Africans; many of its rituals involve animal sacrifice. The church filed a lawsuit in United States district court for the Southern District of Florida, seeking for the Hialeah ordinance to be declared unconstitutional. Adhering to the opinion in Smith, the lower court held that the law was in fact constitutional because it supported a legitimate and rational governmental interest. This application of the Smith standard did not require the law to pass the strict scrutiny test because it was a neutral law of general applicability. In the U. S. Supreme Court however this decision was reversed and the limits of the Smith standard were clearly defined. The Supreme Court held that while it was true that the law was technically neutral and generally applicable, there was more to be looked at in such cases. The court held that the surrounding facts of the case must also be taken into account in deciding if a law was neutral, and that in this case the law was clearly targeted at the Santerian Church, being that it was passed in anticipation of the church’s arrival and prohibited one of the church’s core practices. Furthermore the court pointed out that there really was no one else whom the law would effect, thus making it exclusively applicable, rather than generally applicable. Following this realization the court held the nature of this case to mandate a standard of strict scrutiny, requiring the law to be justified by a compelling governmental interest, and to be narrowly tailored to advance that interest. Because the ordinance suppressed more religious conduct than was necessary to achieve its stated ends, it was promptly deemed unconstitutional. What we see from this case is that in utilizing the Smith standard the court is not to rigidly adhere to the technical language of neutral and generally applicable without looking at a law’s motive and practical effect. This opinion, it would seem, was a step in the direction of legal realism, requiring legal standards to take into account the bigger picture rather then adhering to strict and easily manipulated technical language. Another important case that highlights the neutral element of the Smith standard is Watchtower Society v. Village of Stratton. In this case The Village of Stratton, Ohio promulgated an ordinance that, among other things, prohibited canvassers from going in and upon private residential property to promote any cause without first obtaining a permit from the mayors office by completing and signing a registration form. The ordinance imposed criminal sanctions on canvassing or soliciting without a license. The Jehovahs Witnesses, a religious group that publishes and distributes religious materials, sought injunctive relief, alleging that the ordinance violates its First Amendment rights to the free exercise of religion, free speech, and freedom of the press. While at first the lower courts held that the ordinance did pass intermediate scrutiny, the Supreme Court in an 8-1 vote reversed this decision arguing that the law was still unconstitutional. The court held that the law failed even intermediate scrutiny as it placed too great a burden on free speech and the free exercise of religion. Again we see in this case that while subsequent courts adhered to the application of intermediate scrutiny with respect to neutral laws of general applicability, they expanded the scope of what it was that neutrality covered in the first place. First in Church of Lukumi  v. City of Hialeah where the court extended the neutrality standard to exclude laws even with only a non-neutral motive, and then again in Watchtower Society v. Village of Stratton which additionally took into account the practical effect a law would have on free speech and religion. This type of progression is common in our legal system today and represents the ability of laws and legal concepts to evolve and be fine tuned with each new application of their precepts. Specific Exceptions Granted to Religiously Burdensome Laws On the other hand, there are some cases in which the Court allowed a religious motivation to exempt a person from a neutral, generally applicable law. This occurs when the courts find a particular group of people on whose religion a law not only imposes but also to whom the central purpose and policy of the law does not apply. In such cases the courts have been known to grant localized exceptions to the law. In Wisconsin v. Yoder, Jonas Yoder, Wallace Miller and Adin Yutzy, all members of the Old Order Amish religion, were prosecuted under a Wisconsin law that required all children to attend public schools until age 16. The three parents refused to send their children to such schools after the eighth grade, arguing that high school attendance was contrary to their religious beliefs. In a unanimous decision, the Court held that an individuals interests in the free exercise of religion under the First Amendment outweighed the States interests in compelling school attendance beyond the eighth grade. In the majority opinion by Chief Justice Warren E. Burger, the Court found that the values and programs of secondary school were in sharp conflict with the fundamental mode of life mandated by the Amish religion, and that an additional one or two years of high school would not produce the benefits of public education cited by Wisconsin to justify the law’s application. Justice William O. Douglas filed a partial dissent but joined with the majority regarding Yoder. While the law in question was neutral and generally applicable it did not pass intermediate scrutiny with respect to the Amish. If it had been just an imposition on their religious practices, even the Amish would have been held to the law, but because the law’s central purpose didn’t apply in the first place, with regards to the Amish, an exception was deemed necessary. Following the Supreme Court Ruling in Wisconsin v. Yoder all states are required to grant the Old Order Amish the right to establish their own schools (should they choose) or to withdraw from public institutions after completing eighth grade. In some communities Amish parents have continued to send their children to public elementary schools even after Wisconsin v. Yoder and in most places tensions have eased considerably after the Supreme Court ruling. The Evolution of the Smith Standard and its Effect on Religion Today Initially the Smith standard was viewed with much apprehension by the religious community and its advocates. It was seen to grant the court a new less restrictive power to burden religion, a power that could prove to extend and grow, a power that if left untended could have a substantial negative effect on religion in America. However as the standard stands today, even its critics would agree that these fears have proven to be largely unfounded, and that its predicted harm had been grossly overestimated. Smith introduced a novel concept. While a law that burdens religion ordinarily must pass strict scrutiny, a neutral law of general applicability need only pass intermediate scrutiny. The policy behind this standard being an assurance that laws do not target religion and are not created in an attempt to restrict religious practice. It is this policy and mindset that has guided subsequent judges in their attempt to define the limits of this standard, and it was only in the standard’s repeated application to an ever changing combination of circumstances that the definition has efficiently evolved. From the simple application of the concept’s language, in Smith, where a neutral and generally applicable law happens to burden religion, to the advanced modern analysis of what neutrality really should include, in Church of Lukumi and Watchtower, we now have a clear, historically fine-tuned precedent, guiding us in the application of this novel standard, one which we can be sure will only continue to evolve in the future. [ 1 ]. Harvard Journal of Law and Public policy: A Matter of Constitutional Luck (spring 2003) [ 2 ]. Sherbert v. Verner,  374 U. S. 398  (1963) [ 3 ]. Employment Division, Department of Human Resources of Oregon v. Smith, 494 U. S. 872 (1990) [ 4 ]. The Constitution of The United States,† Amendment 1 [ 5 ]. Lemon v. Kurtzman,  403 U. S. 602  (1971) [ 6 ]. Employment Division v. Smith, 494 U. S. 872 (1990) [ 7 ]. Id. [ 8 ]. http://en. wikipedia. org/wiki/Employment_Division_v. _Smith [ 9 ]. Employment Division v. Smith, 494 U. S. 872 (1990) [ 10 ]. http://en. wikipedia. org/wiki/Employment_Division_v. _Smith [ 11 ]. Christian Legal Society v. Martinez, 561 U. S. ,130 S. Ct. 2971, 177 L. Ed. 2d 838 (2010 [ 12 ]. Id. [ 13 ]. Id. [ 14 ]. Id. [ 15 ]. Id. [ 16 ]. Lemon v. Kurtzman,  403 U. S. 602  (1971) [ 17 ]. Church of Lukumi  Babalu Aye v. City of Hialeah, 508 U. S. 520 (1993) [ 18 ]. Id. [ 19 ]. Id. [ 20 ]. http://en. wikipedia. org/wiki/Church_of_Lukumi_Babalu_Aye_v. _City_of_Hialeah [ 21 ]. Church of Lukumi  v. City of Hialeah, 508 U. S. 520 (1993) [ 22 ]. Id. [ 23 ]. Id. [ 24 ]. Watchtower Society v. Village of Stratton,  536 U. S. 150  (2002) [ 25 ]. http://en. wikipedia. org/wiki/Watchtower_Society_v. _Village_of_Stratton [ 26 ]. Watchtower Society v. Village of Stratton,  536 U. S. 150  (2002) [ 27 ]. Wisconsin v. Yoder,  406 U. S. 205  (1972) [ 28 ]. http://www. oyez. org/cases/1970-1979/1971/1971_70_110 [ 29 ]. Id. [ 30 ]. http://en. wikipedia. org/wiki/Wisconsin_v. _Yoder