Four line english writing paper
Writing Essay For Ielts
Friday, August 28, 2020
Abortion- Pro essays
Fetus removal Pro articles Fetus removal is an extremely delicate subject in American legislative issues. When managing this issue, there are different sides that one can take. There is the Pro-life side, which accept that fetus removal is anything but something to be thankful for, and ought to be made unlawful. On the opposite finish of the range, there is the Pro-decision side. The Pro-decision side accept that its a womans decision on the off chance that she needs to convey the child, or prematurely end the pregnancy. There are numerous advantages and disadvantages to every one of the contention. One explanation that Pro-decision advocates accept that there position on the issue is the correct one is that they accept that its a womans decision whether she prematurely ends the pregnancy since its her body. Since the hatchling is a piece of her body, she can settle on the choice whether she allows it to live beyond words. Its like, if a lady has some kind of problem with her leg, and one of the choices is to remove, she can either decide to dispose of the leg and be finished with it, or keep it. Another explanation that Pro-decision supporters feel that premature birth is okay is that they don't believe a hatchling to be a living person. One of the fundamental positions that Pro-life supporters have is that executing an embryo is much the same as slaughtering a person. While Pro-decision advocates accept that life starts during childbirth, and that murdering the embryo isn't slaughter a human, simply executing a piece of you. The last explanation I will address for the Pro-decision side is that occasionally, a premature birth is the best thing if the mother isn't equipped for dealing with an infant. Some of the time a mother isn't anticipating the infant, and when it is imagined isn't genuinely or monetarily prepared to deal with the child. At the point when this is the situation, a premature birth can take care of this issue, making it so she doesnt have an infant to deal with. On the opposite finish of things, There are motivation behind why Pro-life is the best approach to be. There are on the whole basically something contrary to the purposes behind Pro-decision. One of them is that a baby is a human ... <!
Saturday, August 22, 2020
Global Geopolitics of the Middle East Essay Example | Topics and Well Written Essays - 500 words - 2
Worldwide Geopolitics of the Middle East - Essay Example Generally speaking, the worldwide economy keeps on relying upon the Middle East. This zone likewise impacted America, just as other world areas. Then again, the present worldwide relations keep on being formed by the factor of oil the Middle East. The key players in these relations, as to oil, are the US and UK. Previously, UK as an outside player in the governmental issues of the Middle East forced its approaches on the region, according to the state framework development before. Today, the part of strategy in the Middle East has been exceptionally impacted by oil. Oil today has become a political device, and not a goal. For example, the USA put a prohibition on exchange with Libya and Iran, while the UN restricted Iraq. Lamentably, these nations have solidified their entrance to oil in the district, in light of the fact that their need is in governmental issues. The present geopolitics in the Middle East has from the start spun around oil. The greater part of the worldââ¬â¢s vitality flexibly originates from the Middle East, with the Persian Gulf holding immense oil wells. The purpose for the world giving a lot of significance to the Middle East is the way that, the worldwide economy can't get by without oil, which the Middle East delivers in bounty. Various nations, particularly the present and previous super powers and radicals, for example, the USA and UK, have created extraordinary enthusiasm for the Middle East. The revelation of oil in the Middle East likewise upgraded its key situating, as it lies in the focal point of three distinct mainlands. With this, it is in a situation to control significant connections in the worldwide arrangement of transportation. The worldwide noteworthiness of the Middle East exudes from the way that the zone is the worldââ¬â¢s most noteworthy maker of oil. Oil and other oil-related interests have consequently impacted the political and social economy of the Middle East, both at the neighborhood and global level. A great many people think about oil as a political item, since it is the fundamental
Friday, August 21, 2020
The Path to Be A Financial Planer Essay Example | Topics and Well Written Essays - 1500 words
The Path to Be A Financial Planer - Essay Example That is valid, and I donââ¬â¢t need to be a degenerate authority. Before I went to this school, I understood that I needed to consider something great as I should choose to pick a significant which is connected with my future profession. After much thought and discussion with my folks, I at last picked fund and venture. I chose to learn business not just due to my dad who is my godlike object as a representative, yet in addition since I trust it can offer you more significant compensations that could permit me to carry on with an agreeable life. In any case, the subject of picking the major was as yet an issue to b settled. The most familiar profession that I know is the money related organizer. In secondary school, my educator Mrs. Tooth in China educated us a great deal of about our majors. Obviously, I heard a great deal about my calling which I am generally keen on. She disclosed to us the significant subject consistently give you a chance to prepare as future expert monetary organizers in the after graduation. We can work at security organizations, insurance agencies, banks, venture warning organizations, resource the board organizations, prospects organizations, subsidize organizations, and other money related endeavors as monetary consultants, budgetary organizers, industry examiners, account directors, counter staffs, and different situations in the organization can work inside the money related arranging process. Moreover, my educator revealed to me that it is anything but difficult to get a new line of work as an alumni who learns the money major. Among them, I chose money related organizer. N otwithstanding, it is as yet hard for me to choose to be a business person or a representative. At the time I picked my major, I chose to concentrate in America as it is anything but difficult to get a new line of work. At that point I effectively entered the college, and was admitted to the significant I am presently - money and venture. In any case, the expense of learning in America stunned me. Figuring the expense of $477 per undergrad credit hour, I would pay $ 14,306 just in educational cost as a full time understudy,
Tuesday, May 26, 2020
Florida Bar Essay Topics - How To Choose Top Contenders
Florida Bar Essay Topics - How To Choose Top ContendersFlorida is one of the hottest and most popular places to take bar essay topics because of the quality of the people, the hospitality in the towns and the amazing beaches. Florida offers an incredible mix of culture, style and traditions. It is also a great place to take on a bar essay because of the food and drink options and its amazing entertainment venues.Florida is not only popular for the beaches but it is also popular for its warm climate. The average temperature of Florida is in the high 30s and no matter what season it is, there is always a chill on the beach. But the weather does not only keep tourists away, it also keeps away most of the locals. Florida is quite a lot less tourist oriented than the states. You are not just limited to beachfront hotels in Florida but you are able to find many fine hotels and motels as well.The hotels in Florida are of various types and most of them offer a full bar service. Most of the h otels have bars with its own special music and events. Other than this, the hotels in Florida offer many other services like customized room services, complimentary access to nearby restaurants and bars and of course their own fully equipped dining rooms.Florida is also known for its sea life and in fact, the State of Florida is known as the gateway to the world of sea. There are many historical sites that can be explored while on your vacation in Florida like Cocoa Beach, Fort Myers and many more.The tourism industry in Florida is also growing day by day and because of this, the hotel and resorts are hiring more staff in order to accommodate all the guests. So for all your bar essay topics in Florida, you need to hire a travel agent who can guide you and ensure that you get the best deal for your Florida bar essay topics.One of the things to look out for when you go for a Florida vacation is the price. As the cost of living in Florida is quite high, you have to really think about t he cost of your stay and of course the accommodations you will be getting. If you are on a tight budget, Florida hotel essay topics are the perfect solution for you. You do not need to spend your vacation dollars on the premium restaurants and bars in Miami Beach.There are many tourists who like to stay in Florida during their holidays, so they try to book their hotels or resorts to the rooms with amenities and cost as low as possible. The internet is your tool here to find a cheap Florida hotel essay topic so that you do not waste any amount of money while on your trip.
Saturday, May 16, 2020
The Theory Of The Economy - 1261 Words
Economy is the production, trade, and consumption of limited goods and services by different groups in varied geographical locations. Economists use scientific methods to study the nationââ¬â¢s economy and learn about what drives the supply and demand of certain areas. Economistsââ¬â¢ develop theories of how they believe certain aspects of the economy, for example inflation, derive and the test their theories through data collection, analyzing the flow of money, etc. Then they take their research and compare their theories with the collected data to determine if their theories are correct (Mankiw, 1998). Since theories and research in economy can be confusing and difficult economists use models to help interpret and explain how the economy works and how different aspects of the economy affect each other. One of these models is called the circular flow diagram. In some models, the economy is simplified to include only two types of decision makers, firms and households. Firms pro duce goods and services. Households own the factors of production and consume all the goods and services that the firms produce (Mankiw, 1998). The following is an example of a circular flow diagram. It is comprised of several different sectors including the household sector, business sector and the government sector. The household sector includes all people seeking to satisfy unlimited wants and needs. This sector is responsible for consumption. It also owns all productive resources. The business sectorShow MoreRelatedThe Theory Of The Political Economy872 Words à |à 4 PagesThe theory of the political economy in the context on media studies, is that behind every media product, has a commercial and economic imperative and as such, has particular impacts on the media content that would not exist if such imperatives ceased to exist. It is these impacts that both limit media products, and allow media products of a particular nature exist. A political economic approach in the production of media is in contrary to the nature of media itself; accuracy, integrity and authenticityRead MoreThe s Theory Of Political Economy795 Wor ds à |à 4 Pagesargues that these desires have become detached from actual human needs. What is frequently overlooked, however, is the inherent critique of capitalism in the narrative of planned obsolescence and how strongly it builds upon Marx s theory of political economy.1 Marx was already well aware of the fact that even perfectly functioning goods can lose their value and become obsolete, a phenomenon he termed ââ¬Å"moral depreciationâ⬠(1992, p. 264). To Marx, the reason for this lies in the capitalist logicRead MoreThe Political Theory Of The Chilean Economy1112 Words à |à 5 PagesDespite the small size of the Chilean economy and its rather relative weight in the global economy, several accounts acknowledge that Chile was at the forefront of the worldwide neoliberal experiment since the mid-1970s under the civic-military dictatorship that ruled the nation between 1973 and 1990 (Harvey, 2005a; Klein, 2007; McChesney, 1999; Paley, 2001; Stiglitz, 2002). Indeed, t he Chilean authoritarian regime not only has radically applied neoclassical theory, but also turns it into ââ¬Å"the foundingRead MoreThe Theory Of A Open Market Economy2492 Words à |à 10 Pagesthe hands of men and women of all walks of life. With this almost natural concept came another one of darker pretenses, the invisible hand. Originally proposed by logician and economist Adam Smith, the invisible hand is the concept of a open market economy in which everyone looks out solely for their own well being. This was seen at first as the sure fire way to ensure prosperity for all no matter what social class one may inhabit. However, this system of economic trickle down has proven not only inefficientRead MoreThe Impact Of Keynesian Theory On The Economy1805 Words à |à 8 Pageseither the economy is in a recession, economic stability or inflation. And when itââ¬â¢s in a Recessionary or Inflationary period the things the government must do to correct the situation to bring th ings back to normal before the situation becomes worst. Here we are going to try and understand the concept of the ââ¬Å"Keynesian Theoryâ⬠approach to ââ¬Å"fixingâ⬠the economy and bring things back to normal. John Maynard Keynes was one of the most influential economists of the 20th century. His theory has been usedRead MoreThe Theory Of Economy And The Validity Of Emh2350 Words à |à 10 Pagesyour own, you are unjust.â⬠Although the notion of market efficiency has- albeit rudimentarily- been dealt with since the 16th century , it was only when Eugene Fama published his PhD and his subsequent article Efficient Capital Markets: A Review of Theory and Empirical Work in 1970 that the Efficient Market Hypothesis (hereafter EMH) was established. The fundamental argument offered by EMH proposes that the multiplicity and interaction of fully rational economic actors within a market will lead toRead MoreThe Political Economy And Cultural Studies Theories1429 Words à |à 6 Pageshave constructed theories that explain the functions and impacts of mass media in the society across the globe (Mosco, 2008). The central theme in all mass communication models entails the meaning of media contents, which include the images and texts and their influence on the target audience. The perception of the target audience concerning the text and images in the media are what form the basis of these theories. This essay disc usses two hypothetical frameworks: the political economy and culturalRead MoreMarx s Theory Of The Social Economy Essay1435 Words à |à 6 Pagesco-authored ââ¬Å"The Communist Manifestoâ⬠to ââ¬Å"Capital: Critique of Political Economyâ⬠. This paper, however, will concentrate on one of his lesser known works. In 1844 Marx wrote the ââ¬Å"Economic and Philosophic Manuscripts of 1844â⬠, this was not published during his lifetime and first appeared in 1927,an astounding forty-four years after his death. The manuscripts themselves explore a wide range of topics, this paper will be looking at Marxââ¬â¢s theory of the ââ¬Å"alienation of labourâ⬠. For Marx, the product of your labourRead MoreKarl Marx And The Marxist Theory Of Political Economy1100 Words à |à 5 Pagesgovernments, leading to the rebirth of the use of Marxist thinking. ââ¬Å"Sales of Das Kapital, Marx s masterpiece of political economy, have soared ever since 2008, as have those of The Commu nist Manifesto and the Grundrisseâ⬠. However, in a time of increasing admiration and application of his theories, it is vital to ask; Did Karl Marx construct masterpieces of political economy? Or is his work littered with ethical, economical and empirical discrepancies? This report will critically analyse aspectsRead More Economic Theories Applied to the New Economy Essay7222 Words à |à 29 PagesEconomic Theories Applied to the New Economy Discuss the extent to which the economic theories in the Marketââ¬â¢s Reader can be applied to the ââ¬Å"New Economyâ⬠. (50 marks) A) Discuss the extent to which the economic theories in the Marketââ¬â¢s Reader can be applied to the ââ¬Å"New Economyâ⬠. (50 marks) In this question, I will define the old and new Economy, then I will mention the main characters of New Economy and what is different between new and old Economy. After that, I will discuss the
Wednesday, May 6, 2020
Charter School Issues In America Case Study - 1548 Words
54 A. SAULTZ $700,000 total was spent opposing the measure (Rosenthal, 2012). Ballot measure 1240 passed by a narrow margin of 50.69% to 49.31%, or approximately 40,000 votes statewide (Connelly, 2015). Why did the measure pass this time? Previous work has used network analyses to show that wealthy elites wielded disproportionate influence over the outcome of the charter school initiative in Washington (Au Ferrare, 2014). This work adds to the literature by interviewing policymakers in Washington, and exploring the charter school issue through the lens of Race to the Top and educational federalism. This paper explores these issues in Washington by specifically asking: 1. Why did a statewide charter initiative pass after failing onâ⬠¦show more contentâ⬠¦This work extends the current literature on federalism within education by exploring whether, and to what degree, Washington policymakers borrowed strength in the form of license to help pass charter school legislation. The charter issue is of particular interest in the context of federalism, given that it is a policy area that has been rejected so many times in the past by voters and state legislators. The literature on the role of the economic elite and philanthropies in educational policy is increasing and is mainly focused on the city level in large urban districts. For example, Reckhow (2013) found that foundations have increased both the amount and scope of their donations to the education arena in recent years. Additionally, new and old foundations have converged to direct more money to the same organizations over time (Snyder, 2015). For example, foundations are increasingly funding organizations that compete with traditional public sector institutions and supporting grantees to engage in policy debates (Reckhow Snyder, 2014). This suggests a more unified strategy from large philanthropies. Further research finds that foundations and philanthropies have increased their role in knowledge production, interpretation, and utilization (Scott, Jabbar, Lubienski, DeBray, 2013). Other work has explored case studies, mainly at the FOURTH TIME ISShow MoreRelatedCharter School Analysis Essay1703 Words à |à 7 Pagesof Issue: Since the first charter school opened in Minnesota in 1992 (Minnesota Dept. of Education Website), America has seen charter schools move from a fringe educational alternative to an accepted and useful tool in public education. It is clear that charter schools are continuing to grow in popularity and student population, even with conflicting evidence about their effectiveness. This review will evaluate the necessity for strong educational leadership, a clear educational charter withRead MoreCharter Schools Vs. School Schools1261 Words à |à 6 Pagesthe charters providing an avenue of escape for some, it hasnââ¬â¢t been for the majority,â⬠(Zernike 4). In some cities charter schools are educating more that half the students in some American cities (Zernike 1). These charter schools make promises to parents and students that are hard to pass up in many cities, where public education is lacking and private education is out of reach for many. Charter schools exist all across America, in forty-two states and Washington D.C.(Oliver). These charter schoolsRead MoreWeââ¬â¢ve Found Superman All of the facts point to one prevailing conclusion; Americaââ¬â¢s school system1300 Words à |à 6 PagesWeââ¬â¢ve Found Superman All of the facts point to one prevailing conclusion; Americaââ¬â¢s school system is failing. No film makes this clearer than ââ¬Å"Waiting for Superman,â⬠directed by Davis Guggenheim. In the film, Guggenheim does not hold back in his onslaught of surprising, yet true, facts. Guggenheim points out that Americans are failing compared to the world in major areas of study, such as math and science. However, there is one place American children lead the world; Confidence. Guggenheim saysRead MoreThe Literacy Rate Of The United States1361 Words à |à 6 PagesStates depend on how education in public and private schools providing to students and how it is affecting them to build bright futures. American literacy rate has not been changed since ten years, thatââ¬â¢s sounds really sad that we are not continuing with our American dream. Who should we blame for this downfall in nation s education system? Our president, or department of education. Nobody will have better answers f or our question. According to the study, which conduct by the National Institute of literacyRead MoreMillennials Drive For School Choice1894 Words à |à 8 PagesMillennialsââ¬â¢ Drive for School Choice It is notable that the school system has major flaws where variation in methods has caused success and failure to come from different students; this is partially due to the way types of schools function. The flaws in the school system are highlighted in the chapter ââ¬Å"Better Schools: Investing in our future,â⬠from the book, When Millennials Rule: The Reshaping of America, written by David Jack Cahn. They are trying to bring the millennialsââ¬â¢ future actions andRead MoreIntroduction. A Resounding ââ¬Å"Thank Youâ⬠Is Directed Toward1514 Words à |à 7 Pagesstudents across America, regardless of social class, race, or disability by requiring all students to meet the same standards of quality education. Statement of the Problem The popularity of the CCSS falls onto a spectrum. One end favors the CCSS and is a part of the population that resides in underperforming school districts, or are parents of ââ¬Å"over-achievers whose children are often in gifted and talented in classroomsâ⬠(Rees, 2015). The other end rests the opposition, a mix of public school parents andRead MoreHigh School Sports Be A Drastic Decision Essay1165 Words à |à 5 PagesPublic high schools in the United States are responsible for predominantly educating children in the classroom. However, an education should be well rounded and teach students about multiple different aspects of life. Fitness education, physical education, and high school athletics are competitive. Public high schools hold the responsibility to offer as many sports as possible and to support as many students to succeed. Terminating high school sports would be a drastic decision. ââ¬Å"One 2010 study by BetseyRead MoreRacial Diversity And The School System1769 Words à |à 8 Pagesintegration in schools have multiple forces that continue to be examined today by race and class. Stratification in todayââ¬â¢s school systems are segregation in residential neighborhoods. Most attendance in public schools are determined largely by where students live. Predominantly white suburbs and poor minority neighborhoods both are grouped by income and race. This particular grouping can create school districts to be separated by race. Segregation in urban areas of North Carolina schools could be aRead MoreThe Education System Has Been Failing Students As Time Progresses885 Words à |à 4 Pagesnecessary equipment in high schools, teachers fail to make students engaged and feel passionate about education. Every morning, it is the same routine, forty minutes here or an hour there just to sit in a classroom and learn nothing because students do not find the lectures interesting. In The past year, the school reformed commission decided to close 23 public schools to reduce the citywide debt and in May the final decision was reached And they decided to lay off school faculties, teachers, principalsRead MoreScience Teachers and Professors Should Not Teach Creationism 1231 Words à |à 5 Pageschoose what to believe; so the actual question, which remains unsolved, is the following: what should public schools teach to their students? The answer to this query is extraordinarily obvious and uncomplicated: although it is true that as former President George Bush once said ââ¬Å"Both sides ought to be properly taught so people can understand what the debate is about,â⬠it is up to the school to teach evolution, while families or other educators should inform their children and students about creationism
Tuesday, May 5, 2020
Consul Developments Pty Ltd
Question: Discuss about the Consul Developments Pty Ltd. Answer: Introduction In ASIC v Citigroup Global, the two main principles that were stated by the Federal Court of Austria were; (i) the law does not require that an investment bank should not contract out of a fiduciary relationship under some circumstances and (ii) the sufficiency of Chinese walls which were sometimes also called "information barriers", can fix responsibility for insider trading. Apart from it, the efficiency of the compliance program of the company is also better that will be considered by the court while considering the allegations related with the breach of insider trading provisions. The facts of this case were rather intricate however for the purpose of the assignment at hand, these facts can be described briefly in the following words. The Citygroup Global Markets was engaged in business by several business divisions which included Investment Banking (Private Side Employees) and Equities trading (Public Side Employees). The Private Side staff have to deal with classified and market sensitive information while in contrast the Public Employees did not have access to this information. In order to restrict the information flow between the various business divisions of the company, "Chinese walls" were set up by Citigroup. The present proceedings were the result of the five that the ET division of the company had purchased shares in Patrick Corp. Ltd. These shares were purchased when the IB division of the company was working on behalf of Toll Holdings regarding a future takeover bid of Patrick. These shares were procured by the ET division on the last trading day before the bid for Patrick was announced by Toll. When IB division came to know regarding the purchase, it took steps due to which ET was prevented from going further with the purchase of any more shares of Patrick. ET stopped the purchase of any mo you re shares, however how an hour before the the closing time for trading, ET sold 200,000 shares of Patrick that were purchased by it on that day at a profit. Subsequently, Toll came forward with its takeover bid for Patrick on the next day Outline the duties / responsibilities breached The main issues that were present in this case, were as follows. Although it was not alleged by the Australian Securities and Investment Commission (ASIC) that ET was aware of inside info when it took the decision of achieving the shares but it asserted that as an advisor to Toll Holdings, Citigroup was in a relationship with Toll that can be described as a fiduciary relationship. By purchasing the shares of Patrick, this fiduciary duty has been breached by Citigroup. In this way, ASIC alleged that Citigroup has breached its obligations that were imposed on the company by section 912A(1), Corporations Act, 2001. Moreover, ASIC also alleged that the requirements of section 1043H and 12DA of the ASIC Act had also been breached by Citigroup has these provisions restricted any misleading or deceptive conduct. It was also blessed by the ASIC that the insider trading provisions that have been mentioned in section 1043A, Corporations Act have been breached by Citigroup due to the following reasons. Due to what was said to ET after it was found by IB that there was a potential conflict of interest, it was supposed by ET that Citigroup was acting on behalf of Toll Holdings regarding the proposed takeover bid for Patrick. Hence, it was alleged by the ASIC that this supposition amounted to information as mentioned in section 1042A. as a result, it was alleged that the sale of 200,000 shares amounted to insider trading by the Citigroup (Aequitas v AEFC, 2001). In case of the second claim, the ASIC challenged the "Chinese walls" that were in position in Citigroup. It was alleged by the ASIC that as the senior IB management were aware of the fact that it was substantially probable that Toll is going to commence the takeover bid, such knowledge can be attributed to the Citigroup as a whole (McGhee, 2000). Consequently, it was alleged by the ASIC that Citigroup had been involved in insider trading as the ET division of Citigroup had purchased the shares (Hadid v Lengest Communications Inc., 1999). The findings of the court in this case were as follows. The fiduciary claim brought by the ASIC was unsuccessful at the outset because the letter of engagement through which Citigroup was retained by Toll particularly excluded the presence of a fiduciary relationship. In this regard, the court stated that the law does not stop the investment banks from contracting out of the fiduciary obligations by entering into a commercial relationship. For the purpose of the success of the first insider-trading claim, it was required that the employee who had made the trade, should not only hold the inside info but such knowledge and also be attributable to the company. According to s 1042G(1)(a), the knowledge of the member of staff cannot be attributed to Citigroup unless such employee was an officer of Citigroup as mentioned in section 9, Corporations Act. In the present case, the claim of the ASIC could not succeed as the particular employee was not an officer (Tuch, 2005). The court arrived at the conclusion that for the purpose of the Act, an "officer" was someone who had a role to play in the senior management of the company, which was not played by the employee in this case. Moreover, it was also stated by the court the above-mentioned supposition was not made by the particular employee, as alleged by the ASIC, namely that Citigroup was acting on behalf of Toll regarding the takeover bid for Patrick. In this way, the second insider-trading claim also could not succeed on the ground that the Chinese wall defense, that has been mentioned in section 1043F of the Act was successfully raised by Citigroup (Hollander and Salzedo, 2004). Or in other words, it was successfully established before the court by Citigroup that the company had put in position, compliance measures that can be reasonably anticipated to make sure that the price sensitive information that was in possession of IB did not reach its other division, ET. As has been mentioned in this section, the decision of the chasing the shares has been made by a person apart from the persons who were holding such information and IB had not provided any information or given any advice to such person regarding the purchase. Discuss and critically ANALYSE the court/ tribunal decision There are certain significant implications of this decision. While examining the adequacy of the Chinese walls put in place by the Citigroup, it was noted by the court that such measures have to fulfill the provisions of the Act but they do not require absolute perfection. Instead the only requirement is that the company should have taken reasonable steps. The best that has been mentioned in section 1043F was an objective test. According to this test, the requirement was that arrangements should be in place due to which it can be reasonably expected to make sure that the information has not been communicated. For this purpose, the following relevant procedures were outlined by the court that was necessary in case of defective Chinese walls. These were physical separation by departments, the presence of the procedures to deal with passing the wall, educational programs, effective supervision by the compliance officers and disciplinary sanction. Although in this case, the court upheld the defense provided by section 1043F, however the court also warned that the Chinese walls should be able to insulat the trader (ET) from the and information so that the necessities of this section can be satisfied. The court arrived at the conclusion that in the present case, adequate procedures had been put in place. For this purpose, the court referred to the region policies of Citigroup as well as its compliance procedures. Among others, the written policy of Citigroup and quiet that the private side employees (IB) should not have provided any significant non-public information to the employees who were on the public side (ET) without the involvement of legal or compliance personnel for the purpose of evaluating the significance of the information, and when necessary, for implementing the wall crossing procedures. The written policies adopted by the Citigroup were accessible to all its employees, the company also gave regular training to its employees in this regard and it was clearly mentioned in these policies that the employees of the company should be alert regarding any possibility of conflicts. There were also required to escalate any issue dealing with an actual, potential or apparent conflicts of interest. Moreover, retail policies and procedures had been put in place by the Citigroup according to which the considerations have been set out that had to be applying if a public side employee needs to be brought over the Chinese wall. But at this point it is worth mentioning that in this case, it has also been stated by the court that the ample measures need in excess of the written procedures and policies (Farah Constructions Pty Limited v Say-Dee Pty Ltd., 2007). It was mentioned by the court that it needs a comprehensive understanding of such measures by the employees of the company and also the willingness and the ability for applying these procedures and policies to a number of possible conflicts (Consul Developments Pty Ltd v DPC Estates Ltd., 1975). The fact was also noted by the court in this case that a clear escalation policy was present according to which, IB could give advice to the appropriate personnel regarding the probable conflict, which included the Compliance Department as well as the General Counsel of Citigroup and its Chief Executive Officer. In this way, the in-house compliance division of Citigroup was in a position to give proper advice to IB and ET regarding what could or what should not be disclosed by these divisions of each other and in this way, maintain the protection that has been provided by the Chinese wall that has been put in place among various divisions of the company. It was also found by the court that in view of such escalation procedure present in the company, it can be said that adequate Chinese walls have been placed in Citigroup. In the end, it can be said that the case title ASIC v Citigroup remains how a company can achieve protection if it has put in place adequate compliance system and how it can be protected from the liability under the insider-trading provisions of the Act. The purpose of installing the Chinese walls in the company is to forget the flow of information among various divisions of the company. As it has been shown in ASIC v Citigroup, if the Chinese wall requirements and the appropriate compliance schemes are followed by a corporation, it can save itself from likely huge fines as well as from any damage to the reputation of the company. In the same way, ASIC v Citigroup also serves as a reminder and a warning related with the significance of putting in place, adequate compliance measures, particularly related with Chinese walls. References Hollander C and Salzedo, S (2004) Conflicts of Interest and Chinese Walls, Sweet Maxwell, London, (4th ed). McGhee, J., (2000), Snells Equity, Sweet Maxwell, London, (30th ed). Tuch, A., (2005) Investment Banks as Fiduciaries: Implications for Conflicts of Interest, 29 Melbourne University Law Review 478 Aequitas v AEFC (2001) 19 ACLC 1006 ASIC v Citigroup Global Markets Australia Pty Ltd (No 4) [2007] FCA 963 Consul Developments Pty Ltd v DPC Estates Ltd (1975) 132 CLR 373 Farah Constructions Pty Limited v Say-Dee Pty Limited [2007] HCA 22 Hadid v Lengest Communications Inc [1999] FCA 1798
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