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How To Write High

How To Write High Like blood sorts, the majority of these variations are enduring and resistant to change. Years in the past, once I first began interviewing, I struggled to learn the skill of making a report on a person after I had interviewed him. That could also be true, but they aren’t necessarily poor learners. The best approach to train an analyzer is to give her ample time within the classroom. Break her efficiency down into its component components so she will carefully construct it again up. But as Michelle’s expertise revealed, the payoff that will come in the form of elevated employee productiveness and engagement is properly value it. It takes time and effort to gain a full appreciation of an worker’s strengths and weaknesses. There’s no substitute for this kind of remark, however you possibly can acquire lots of details about a person by asking a few simple, open-ended questions and listening rigorously to the solutions. Two queries in particular have proven most revealing when it comes to identifying strengths and weaknesses, and I advocate asking them of all new hiresâ€"and revisiting the questions periodically. Second, capitalizing on uniqueness makes each person more accountable. Michelle didn’t simply praise Jeffrey for his capability to execute particular assignments. She challenged him to make this capacity the cornerstone of his contribution to the shop, to take possession for this capacity, to practice it, and to refine it. First, identifying and capitalizing on every particular person’s uniqueness saves time. No worker, however talented, is completely nicely-rounded. As one of the most various law colleges within the nation, the Washington College of Law equips students to navigate this new reality. Programs include international law, law and authorities, trial advocacy, and business, with experiential opportunities by way of clinics and externships. Only after a few minutes did I realize that he was dictating a report. I lastly noticed how every little thing ought to come together right into a coherent complete. I remember selecting up my Dictaphone, mimicking the cadence and even the accent of my neighbor, and feeling the phrases begin to circulate. Since most formal training applications incorporate both of these elements, watchers are often viewed as somewhat poor college students. Set within the coronary heart of our nation's capital, the School of Public Affairs is a top-ranked faculty of public administration and coverage, authorities, and justice. From our politically-engaged campus, students acquire entry to world-class college members, influencers, and internship alternatives the place they can have a meaningful impression on our world. I understood all of the required steps, however I couldn’t seem to put them together. Some of my colleagues might knock out a report in an hour; for me, it will take the better part of a day. Dedicated to professional and experiential studying, the School of Professional & Extended Studies provides an array of options for lifelong learners spanning the utilized social sciences. Programs vary from undergraduate internship-based semester packages to market-pushed on-line master's levels for professionals at critical junctures of their careers. With a vibrant neighborhood and passion for change, the School of Education is devoted to creating and guaranteeing glorious studying experiences for every youngster. Through chopping-edge research, revolutionary outreach programs, and the event of inspiring coursework, students tackle the most difficult points in the area. Another employee’s trigger might be simply the otherâ€"independence (she’s only worked for you for six months, but if you verify in with her even as soon as a week, she feels micromanaged). This technique will require of you, first, the creativity to envision a more practical association and, second, the braveness to make that arrangement work. Then one afternoon, as I was staring morosely into my Dictaphone, I overheard the voice of the analyst next door. He was speaking so rapidly that I initially thought he was on the telephone. A generally held view is that mistakes fuel learning, however for the analyzer, this simply isn’t true. In fact, the reason she prepares so diligently is to minimize the potential for errors. So don’t count on to show her a lot by throwing her into a brand new state of affairs and telling her to wing it. You can think about the impact these personalized prizes have on HSBC staff. It’s one thing to be introduced up on stage and given one more plaque.

Paper

Paper If you’re wanting back and forth between your resources and your paper as you begin writing, it’s simple to copy concepts without actually creating your own work. You have done a lot of work already, so belief that and work from memory as you write your research paper. It’s okay to look up a specific quote or statistic, but generally your ideas should be your personal at this level. Don’t fear about finding the right words, utilizing the perfect grammar, or crafting the proper title. There is time to perfect your analysis paper as you edit. Alternatively, if you just need help finding a topic or enhancing your work, we can additionally assist you to with that. Writers Per Hour is going to assist make analysis paper writing a breeze. If you’re panicking about this as a result of you've a submission in 24 hours, don’t fear. Writers Per Hour respects deadlines and is supplied to write down papers quickly. Our team consists of writers who've skilled levels similar to Masters and PhDs. Research librarians concentrate on research (it would sound obvious, but take a second to get excited about how a lot this might allow you to and your research paper!). These librarians usually specialize in particular fields and subjects, so you will get specific, skilled help that pertains to your topic. They may help you seek for resources, connect you with consultants in the area your researching, or offer you ideas concerning the direction of your research and writing. If your paper is too long or too quick, now is the time to cut it down or build it as much as a suitable size. It’s actually because they didn’t read the directions. Writing a paper is tedious work but it doesn’t should be when you could have a professional and reliable writing service just a click away. So, the following time you wish to get assist from somebody to write a paper, you know where to come back. Every order we receive is unique and that’s how we treat them. When you attain out to Writers Per Hour to hire individuals to write down papers, you possibly can expect to get your needs met. A thesis is a brief statement that you simply â€" as researcher and author â€" put forward for the readers of your paper as what you are trying to clarify or show. Although this will likely run opposite to what you’ve been advised, you need to use Wikipedia to write a analysis paper. You can use general sources like Wikipedia to get conversant in a topic, find key phrases that can additional drive your analysis, and shortly perceive giant quantities of data. Another typically-missed resource is the research librarian. Did you know that, along with tons of books and online materials, school and college libraries typically have staff whose job it's to assist answer your questions? Show them your thesis assertion and ask them if they assume itis a strong thesis that you will information you as you build your essay. Even should you aren’t arguing for or against anything, your paper wants a thesis. Don’t just delete your conclusion as a result of your paper is simply too long. Don’t waste your time playing with the font measurement and margins to attempt to make your essay longer. If you need to take one thing out, what is smart to cut and how will you re-manage your paper so that it maintains a strong structure? If you need to lengthen your paper, don’t just randomly add words or repeat issues you have already mentioned. It might be helpful to look over your analysis earlier than you begin writing, however don’t write directly from your research. But, for the information you use in your paper, you must discover reliable assets. This may sound obvious, however it’s very important to grasp what your teacher or professor is asking for earlier than you begin writing your research paper. Many college students skip this step, after which marvel why they obtain a low grade on a paper they worked hard on or had been excited about. You may need specific necessities for your essay paper writing project. Whether it’s a particular subject, formatting guidelines or some other specification - our staff is extraordinarily versatile to deal with various instructions. They hail from main universities throughout the US, UK, and Australia. Apart from being subject-matter experts, in addition they possess an exemplary command over the English language.

Think Twice Before You Pay For Essay Writing Services

Think Twice Before You Pay For Essay Writing Services But apart from the results, the homework you don’t do is all the material you aren’t learning or training. This defeats the aim of going to Uni to study should you aren’t able to handle the workload and examine and learn in your personal means. Paying someone to do his or her homework benefits the student in methods apart from academics; they're allowed to concentrate on many elements of life. They can focus on hobbies, psychological health, bodily health, finances, and social health. This leads to a happier life and a happier lifestyle, over some homework that you in all probability received’t remember in 2 years. Kids discover it hard to complete stories and essays as soon as every week, typically more usually. Completing duties and tasks that take hours to do appear to empty you second by second. The work begins to pile and pile as exams come and it looks as if you'll be able to never take a break from all this. to reinforce your subject data;to quote references for ideas and numerical knowledge included;to paraphrase the content, according to your faculty's academic integrity policy. So, relaxation assured when you flip to us for paid thesis writing, you received’t be disappointed. If your faculty uses SafeAssign, or Blackboard, then you're in double bother â€" no cash + plagiarism accusations. Unfortunately, I actually have little understanding of what to do in case you are not happy with the paper. Their Money Back Guarantee could be very inflexible and not buyer friendly. It seemed to me that they tried to cowl their butts with as many excuses as possible. It is not a assure for anything in any respect, nothing in life is assured. And there's a danger concerned in paying for homework, so be sure to understand the results. But if you actually need the help, there are other ways, like paying for homework! Some will see it as innocent, so long as they steadiness all of those and still actually examine. To combat this huge workload, students find many ways to make their lives simpler. Some work together with their classmates and prepare research periods, some e-mail their professors to rearrange office hours, and some construct workable schedule set only for homework and learning. All this liberation and freedom handed to young folks may cause some undesirable stress, however this is utterly regular. Or even getting a examine group together, or seeing your professor throughout workplace hours. The unhealthy about paying for homework is usually a long list, relying on who you ask. It make even include some heavy penalties. If caught plagiarizing, it could end in a zero for the course or even worse, expulsion. The web site offered all the required information to get a stable understanding of how the service works. Too bad they don’t actually have the Pricing web page, their pricing coverage is kind of complicated. Yes, after all, you should use our enhancing service and add your personal directions. I am not very communicative individual, so making speech is always stressful. If you still have any questions, please be at liberty to succeed in out. If you need somebody allow you to apply for a scholarship, this web site is the one. I simply hope I will get a scholarship now this essay offers me the most effective opportunity. It is necessary handy in a analysis paper in anatomy for finest grades. So, after I had done all the written work, I despatched my work for proofreading. use some thematic communities, the place professionals are prepared that will help you with enhancing and proofreading your essay. you possibly can by no means ensure that you haven’t paid by way of the nose on your essay. The paper flows, though it did kind of stray from the thesis statement provided. For instance, if they deliver plagiarized paper, they received’t refund you something unless you provide a Turnitin report. I imagine this is the biggest downside of an EssayPro â€" they lie to you where it isn't needed. Even if you are okay with an “Average Joe,” who has a Bachelor’s diploma, they'd say that a fucking Ph.D. is working on your Literature paper. Don’t want to be rude, however they behaved like a bunch of assholes, who get pleasure from their power and censor their clients whenever they want to dig deeper. Of course, I positioned other orders, using a VPN and without questions, but this case can divert even essentially the most curious customers like me. 1 out of 5 for customer service. Writers have done a perfect work as my economics presentation went well. Very trustworthy group and saved their word about submitting an A-level essay. If you could have any questions or doubts, please don't hesitate to contact us at any time. We are so glad you appreciated the application for a scholarship service and we might be very happy that will help you anytime. Since I was short of time, I could not afford to ship the order for revision, but should you do have time â€" go for it. EssayPro presents limitless revisions, which may be good for orders with a long deadline. As I’ve stated before, I placed three related orders with totally different educational ranges (School, University, Ph.D.) AND THE BIDS WERE ALL THE SAME. Do you actually imagine that Ph.D. holders will ever work on a paper for a child?

Think Twice Before You Pay For Essay Writing Services

Think Twice Before You Pay For Essay Writing Services But apart from the results, the homework you don’t do is all the material you aren’t learning or training. This defeats the aim of going to Uni to study should you aren’t able to handle the workload and examine and learn in your personal means. Paying someone to do his or her homework benefits the student in methods apart from academics; they're allowed to concentrate on many elements of life. They can focus on hobbies, psychological health, bodily health, finances, and social health. This leads to a happier life and a happier lifestyle, over some homework that you in all probability received’t remember in 2 years. Kids discover it hard to complete stories and essays as soon as every week, typically more usually. Completing duties and tasks that take hours to do appear to empty you second by second. The work begins to pile and pile as exams come and it looks as if you'll be able to never take a break from all this. to reinforce your subject data;to quote references for ideas and numerical knowledge included;to paraphrase the content, according to your faculty's academic integrity policy. So, relaxation assured when you flip to us for paid thesis writing, you received’t be disappointed. If your faculty uses SafeAssign, or Blackboard, then you're in double bother â€" no cash + plagiarism accusations. Unfortunately, I actually have little understanding of what to do in case you are not happy with the paper. Their Money Back Guarantee could be very inflexible and not buyer friendly. It seemed to me that they tried to cowl their butts with as many excuses as possible. It is not a assure for anything in any respect, nothing in life is assured. And there's a danger concerned in paying for homework, so be sure to understand the results. But if you actually need the help, there are other ways, like paying for homework! Some will see it as innocent, so long as they steadiness all of those and still actually examine. To combat this huge workload, students find many ways to make their lives simpler. Some work together with their classmates and prepare research periods, some e-mail their professors to rearrange office hours, and some construct workable schedule set only for homework and learning. All this liberation and freedom handed to young folks may cause some undesirable stress, however this is utterly regular. Or even getting a examine group together, or seeing your professor throughout workplace hours. The unhealthy about paying for homework is usually a long list, relying on who you ask. It make even include some heavy penalties. If caught plagiarizing, it could end in a zero for the course or even worse, expulsion. The web site offered all the required information to get a stable understanding of how the service works. Too bad they don’t actually have the Pricing web page, their pricing coverage is kind of complicated. Yes, after all, you should use our enhancing service and add your personal directions. I am not very communicative individual, so making speech is always stressful. If you still have any questions, please be at liberty to succeed in out. If you need somebody allow you to apply for a scholarship, this web site is the one. I simply hope I will get a scholarship now this essay offers me the most effective opportunity. It is necessary handy in a analysis paper in anatomy for finest grades. So, after I had done all the written work, I despatched my work for proofreading. use some thematic communities, the place professionals are prepared that will help you with enhancing and proofreading your essay. you possibly can by no means ensure that you haven’t paid by way of the nose on your essay. The paper flows, though it did kind of stray from the thesis statement provided. For instance, if they deliver plagiarized paper, they received’t refund you something unless you provide a Turnitin report. I imagine this is the biggest downside of an EssayPro â€" they lie to you where it isn't needed. Even if you are okay with an “Average Joe,” who has a Bachelor’s diploma, they'd say that a fucking Ph.D. is working on your Literature paper. Don’t want to be rude, however they behaved like a bunch of assholes, who get pleasure from their power and censor their clients whenever they want to dig deeper. Of course, I positioned other orders, using a VPN and without questions, but this case can divert even essentially the most curious customers like me. 1 out of 5 for customer service. Writers have done a perfect work as my economics presentation went well. Very trustworthy group and saved their word about submitting an A-level essay. If you could have any questions or doubts, please don't hesitate to contact us at any time. We are so glad you appreciated the application for a scholarship service and we might be very happy that will help you anytime. Since I was short of time, I could not afford to ship the order for revision, but should you do have time â€" go for it. EssayPro presents limitless revisions, which may be good for orders with a long deadline. As I’ve stated before, I placed three related orders with totally different educational ranges (School, University, Ph.D.) AND THE BIDS WERE ALL THE SAME. Do you actually imagine that Ph.D. holders will ever work on a paper for a child?

8 Tips on How to Read Emily Dickinsons Poetry

8 Tips on How to Read Emily Dickinsons Poetry Of all of the past American poets, Emily Dickinson (December 10, 1830 â€" May 15, 1886) remains one of the most enigmatic and treasured. There is much we dont know about her life. However, we know that she lived a lot of her life isolated, despite receiving a strong education at Amherst Academy and Mount Holyoke Female Seminary.Although she had friends, much of her relationship with them was based on correspondence. She never married, and the few times the locals of Amherst saw her in her later years, she would typically be wearing all white and preferred to speak to guests through doors instead of face to face. As mysterious as the poet herself was, her poetry also challenges those who read it, with its unique approach and form.As with much of writing, to understand the words, you must first understand the author and some of the ways she approached writing poems. With that in mind, here are 8 tips on how to read Emily Dickinsons poetry.#1. Understand that much of her published poems were highly editedIf you feel like a Dickinson poem is missing something, you might be right, as a 1998 New York Times article revealed that her published work is highly edited. There have been reprints of her poetry collection without the bulk of these edits, but in some cases, we may never know how much of her work was edited by Mabel Loomis Todd and T. W. Higginsonâ€"the first publishers of her found poetry after her death.Part of the reason they were edited is that much of Dickinsons poetry was highly personal, and at points, even erotic. Dickinson asked her younger sister to burn all of her letters and poems on her deathbed, but when her sister found the bulk of her writing, couldnt bring herself to do it. Instead, she gave it to Mabel Loomis Todd, who was a family friend. According to Todd, when she first saw most of the poetry, The outlook was appalling. Emily wrote in the strangest hand ever seen, which I had to absolutely incorporate into my innermost consciousness before I could be certain of anything she reflected. A problem also arose in parts where Dickinson had written six or eight different words she was considering using, without ever settling on one in particular.#2. Focus on the lively style and voiceIn April 1862, Thomas Wentworth Higginson, a literary critic wrote a piece for The Atlantic Monthly titled, Letter to a Young Contributor, urging aspiring writers to charge your style with life. This attracted Emily Dickinsons attention, compelling her to contact Higginson and send him a few of her poems. Here is her query letter, revealing the spark of personality that becomes equally evident in her poetry, as well as a glimpse of her unique style of punctuating lines.Mr. Higginson,Are you too deeply occupied to say if my Verse is alive?The Mind is so near itself â€" it cannot see, distinctly â€" and I have none to ask â€"Should you think it breathed â€" and had you the leisure to tell me, I should feel quick gratitude â€"If I make the mistake â€" that you dared to tell me â€" would give me sincerer honor â€" toward you â€"I enclose my name â€" asking you, if you please â€" Sir â€" to tell me what is true?That you will not betray me â€" it is needless to ask â€" since Honor is its own pawn â€"#3. Realize there is more to her than reclusive poetAlthough Emily Dickinsons name is now most widely used in poetry circles, when she was alive, she was best known for her gardening abilities. Dickinson studied botany from the age of nine and was responsible for the garden at her family home. She collected pressed plants in a 66-page leather-bound herbarium, containing 424 flower specimens that she collected, classified, and labeled using the Linnaean system. Her references to botany throughout her poetry reflect this passion.#4. Think of her poetry as songsEmily Dickinsons poetry is referred to as lyric poetry, where first-person point of view is common. Its written in common meter, which is when lines alternate between eight sylla bles and six syllables. In most of her poems, youll find that these syllables alternate between unstressed (short) and stressed (long) syllables, imitating the beating of ones own heart. While Shakespeare also made use of the iamb (alternating between unstressed and stressed syllables), Dickinson plays with the formâ€"and at points, loses it completely. This is part of what made her poetry very modern for its time.Her poem Wild Nights â€" Wild Nights! is a great example of this.Wild nights - Wild nights! (269)Wild nights - Wild nights!Were I with theeWild nights should beOur luxury!Futile - the winds -To a Heart in port -Done with the Compass -Done with the Chart!Rowing in Eden -Ah - the Sea!Might I but moor - tonight -In thee!#5. Dont expect titlesFinding a particular poem within Dickinsons vast portfolio of poetry (approximately 1800 poems) can be difficult. However, keep in mind that most of her poetry is not titled, and is therefore cited using the first line of the poem as its title. There are also numbers assigned to her poetry, but these have been assigned by editors and dont have intrinsic meaning other than as a system for organizing her work.#6. Dont get hung up on formEmily Dickinson experimented with several different forms, which is part of the reason her poetry was ahead of its time. She did this by varying the meter and stanza of her writing. While she mostly wrote in common meter, this was not always the case, and she didnt force a strict number of syllables per line. So, if youre looking for perfect form in her poetry, youll be disappointed. Some poems, however, do force a strict number of syllables per line, such as Tell all the truth but tell it slant.Tell all the truth but tell it slant â€" (1263)Tell all the truth but tell it slant â€"Success in Circuit liesToo bright for our infirm DelightThe Truths superb surpriseAs Lightning to the Children easedWith explanation kindThe Truth must dazzle graduallyOr every man be blind â€"#7. Understand slant rhymeJust as Dickinson experimented with meter, she also experimented with rhyme, choosing to use what is known as slant rhyme throughout much of her writing. Also known as approximate rhyme, slant rhyme is rhyme in which either the vowels or the consonants of stressed syllables are identical. For example, crate and braid are slant rhyme because of their shared long a syllable.When poets use slant rhyme, the listeners ear picks up on it, even though its subtle. Its obviously not as distinct as a perfect rhyme, but there is still a cohesiveness to the words that can turn them from prose into poetry. Its also unexpectedâ€"especially if it follows perfect rhymes in previous stanzas.#8. Read it aloudPoetry is meant to be read aloud and is part of an ancient tradition of oral storytelling. Without reading Emily Dickinsons poetry aloud, youll miss the lyrical quality of her words and cadence, which are much of what makes her poetry so beautiful. In fact, Mabel Loomis Todd convinced Thomas Wentworth Higginson of the power of Dickinsons poetry by reading selections aloud to him.For example, try reading I felt a Funeral, in my Brain without reading it aloud first, then read it aloud. Youll understand the difference between the two and how it changes the quality of her words.I felt a Funeral, in my Brain (340)I felt a Funeral, in my Brain,And Mourners to and froKept treading - treading - till it seemedThat Sense was breaking through -And when they all were seated,A Service, like a Drum -Kept beating - beating - till I thoughtMy mind was going numb -And then I heard them lift a BoxAnd creak across my SoulWith those same Boots of Lead, again,Then Space - began to toll,As all the Heavens were a Bell,And Being, but an Ear,And I, and Silence, some strange Race,Wrecked, solitary, here -And then a Plank in Reason, broke,And I dropped down, and down -And hit a World, at every plunge,And Finished knowing - then â€"

Essay on Whole Foods Market - 748 Words

Whole Foods Market: 2010 How to Grow in An Increasingly Competitive Market? Patricia Harasta and Alan N. Hoffman A Case Study Analysis Antonia Jackson MBA Dr. Pamela Barnes 13 October 2013 I. Introduction Whole Foods Market is one of the biggest organic and natural whole food suppliers in the world. They provide a wide variety of select foods that are without hormones or antibiotics and are stamped with the U.S. Department of Agriculture’s stamp of approval. They value the fact that they can provide people with access to healthy food and be identified with being socially and environmentally responsible. II. History Whole Foods Market started off as being Safer Way natural grocery store in 1978. However they were not†¦show more content†¦A weakness that Whole Foods have is their reputation. A reputation for a grocer is key to its survival and they have the reputation of being very expensive or some call it â€Å"whole paycheck.† a.ii) External Environment One of the biggest external environmental threats against Whole Foods is increases in domestic competition. At its inception Whole Foods was one of the only providers of organic foods. However now there are many rivals who have taken apart of this ever going interest in our society for better living. Stores such as Wal-Mart and Target have joined the bandwagon of providing their customers with organic foods. With many stores now offering organic foods this has put a dent in the availability of organic foods in other words has shorten the supply of organic foods to Whole Foods. Another external environmental threat was the economy. When the economy went down during the recession many people had to make tough choices when it came to their finances and one of the biggest things that were changed was the amount that they spent on groceries. Many people just simply deemed natural organic foods as being expensive and not a necessity. A major opportunity that Whole Foods have embraced was that during the recession Whole Foods recognized that they need to make adjustments decrease the overall prices. Another major opportunity that they need to embrace is marketing the necessity of whole organic foods. Letting people know that eating right is vital toShow MoreRelatedWhole Foods Market : Whole Food Market2993 Words   |  12 Pages Comparing Two Retail Companies Company A: Whole Food Market Whole Foods Market (WFM) is leading natural and organic food supermarket in the world. It started as one-store entrepreneur shop and has since grown into an $8 billion a year. By 2008, Whole Food Market had 264 stores in the United States that host its headquarters. It had six stores in Canada and five stores in the United Kingdom (Harbin, 2000). It is located in an area of 80000 square foot flagship store in Austin. The CEO and founderRead MoreWhole Foods : The Whole Food Markets Essay1369 Words   |  6 Pagesâ€Å"Whole Food Markets† Week #6 If you were to ask people if they enjoy going to work on Monday, I am sure most of them would give you a funny look, and say â€Å"No†. Americans dislike of their jobs is very evident. To see the magnitude of this just look on social media. On Fridays, there are vast amounts of thank god it’s Friday (TGIF) memes indicating how happy they are that they are done with work for the week. Many American simply do not enjoy working. However, a select few actually do. They enjoyRead MoreWhole Foods Market2057 Words   |  9 PagesCase Study: Whole Foods Market 2006: Mission, Core Values and Strategy 1. What are the chief elements of the strategy that Whole Foods Market is pursuing? Founder John Mackey strongly believed in Whole Foods’ mission to be very selective about store inventory, sticking to the company’s core values and ensuring that customers had an enjoyable and interactive shopping experience, while keeping with planned strategies that have set them apart from their competitors. Store Development andRead MoreWhole Foods Market1449 Words   |  6 Pagesï » ¿Whole Foods Market, Inc. A. SIC/NAICS #’s - The SIC number for Whole Foods Market, Inc. is 5411, which implies grocery stores. The NAICS number for Whole Foods is 445110, which means supermarkets and other grocery (except convenience) stores. (Mergent Online) B. Mission Statement - Barbara Farfan who writes for about.com states, â€Å"The mission statement of the Whole Foods Company and Whole Foods Markets begins with its motto, which is Whole Foods, Whole People, Whole Planet The Whole Foods missionRead MoreWhole Foods Market ( Wfm ) Essay1191 Words   |  5 PagesWhole Foods Market (WFM) is a leading natural and organic food supermarket founded in Austin, Texas by four local business people: John Mackey and Renee Lawson Hardy, owners of Safer Way Natural Foods, and Craig Weller and Mark Skiles, owners of Clarksville Natural Grocery. WFM opened its first store in 1980, they staffed their first store with only 19 workers, the store was an immediate success partly because at the time there were less than half a dozen organic stores in the entire country. Read MoreWhole Foods Market Inc.1231 Words   |  5 PagesINDUSTRY EVOLUTION Whole Foods Market Inc. is a service provider in the grocery industry, which report in the US economy under the North American Industry Classification System NAICS 42441, General-line groceries merchants wholesalers, by the time the company started operations in 1980 supermarkets had a history of 51 years. Supermarkets unlike other type of retail is considered truly American in origin, self service grocery stores are traced back to 1912 in Memphis Tennessee, and it was in 1930Read MoreWhole Foods Market, Inc.1304 Words   |  6 Pages Whole Foods Market, Inc. (WFM) was founded in Austin, Texas and is a supermarket chain concentrating in organic and natural foods. John Mackey, Rene Lawson Hardy, Craig Weller. The first store opened on September 20, 1980. Whole Foods Markets are located in the United States, Canada and the United Kingdom. Since 1980, Whole Foods Market has remained committed to upholding their missions and values within their company. Whole Foods Market’s motto—â€Å"Whole Foods, Whole People, Whole Planet—emphasizesRead MoreWhole Foods Markets1582 Words   |  7 Pagespaper examines the published case study Whole Foods Markets, 2005: Will There Be Enough Organic Food to Satisfy the Growing Demand? (Hitt, Ireland and Hoskisson, 2007, p. C534). Although the published study addresses numerous aspects of Whole Foods Market’s business as a leading international retailer of â€Å"natural† organic foods, the analysis provided herein is focused on Whole Foods Marketâ €™s ability to meet future growth demands. This paper explores Whole Foods Market’s basic internal environmentRead MoreWhole Foods Market1309 Words   |  6 Pages(i) Environmental Analysis – External Opportunities and Threats The demographic, economic and the socio-cultural segments would be the most relevant segments to Whole Foods Market. These segments have a direct impact on the profitability, sustainability and survivability of Whole Foods Market, and the organic food industry. The relevance of the demographic segment stems from the fact that the age structure, income distribution and population size are important factors which will influence the demandRead MoreWhole Foods Market Inc.1280 Words   |  6 PagesWhole Foods Market Inc. is a supermarket selling highest quality natural and organic food, was founded by John Mackey in Austin, Texas in 1980. Whole Foods Market is leading the supermarket industry worldwide, its recorded sales had reached $10,107.79 million in 2011 and it has expanded more than 430 stores in the United states in 2015 (Whole Foods Market, 2015). Website Overview Whole Foods Market’s main communication vehicle is their website, www.wholefoodsmarket.com. Whole Foods Market has

Protests In Antigone By Sophocles - 1278 Words

Throughout Antigone, Sophocles develops the idea of emotion in protests through the actions of Antigone. Antigone, angry at Creon’s refusal to bury her dead brother, decides to protest and go against the rule of the state. Creon responds in return, rashly sentencing Antigone to death. At the end, the play ends in tragedy, with Creon’s son Haemon, Creon’s wife, and Antigone all dead from their emotionally driven choices. Throughout his play, Sophocles’ develops the idea of pathos in protests, showing that emotions are the driving force in starting many protests, the use of pathos is essential if the protest wishes to grow and gather a following, and that relying on simply pathos and emotions will lead to the failure of the protest without†¦show more content†¦Throughout the play, Sophocles’ presents the great power pathos has on swaying the minds of people, and the great importance it has in allowing a protest to flourish. When looking at t he chorus, it is clear the necessity pathos has in convincing others to join your side. When Antigone is sentenced to death, the chorus says, â€Å"In all her lovely strength she traded the light of day for the bolted brazen vault-buried within her tomb, her bridal-chamber, wed to the yoke and broken. But she was of glorious birth my child, my child† (l.1036-1040). The positive light that the chorus shines onto Antigone, is a stark contrast to how they portrayed Antigone as a â€Å"wretched child† in the beginning. The reason for this sudden change is evident when the chorus mentions Antigone’s current dire situation. By apealing to the people’s emotions through her actions of being sentenced to death, Antigone suceeds in gaining support that she would not have had without the use of pathos. A modern example of the use of pathos being vital in drawing people in to a protest could be seen throught the Civil Rights Movement led by Maritn Luther King Jr. His use of pathos shines through in his â€Å"Letter from Birmingham Jail†, where he writes, â€Å"As you seek to explain to your six year old daughter why she can’t go to the publicShow MoreRelatedAntigone Essay926 Words   |  4 PagesCivil disobedience is an act Antigone and multiple modern-day women commit to raise awareness of a lack of justice in their societies. Civil disobedience is the refusal to comply with certain laws as a peaceful form of political protest. This form of protest is shown throughout Sophocles’ tragedy Antigone. Antigone, the protagonist, exhibits civil disobedience when she gives her brother, Polyneices, a proper burial. Antigone is very much like Rosa Parks as described in the article â€Å"Rosa Parks leavesRead MoreThe Play Antigone By Sophocles1085 Words   |  5 PagesThe play Antigone by Sophocles provides multiple themes to the reader. One of which is Individual vs State as Antigone goes against Creon s rule. This act of defian ce is due to the feeling by an individual that what they believe is correct over that of a states law. This theme when applied to modern times can be interpreted as government vs personal freedoms. A person will always act on the values that they have and on those values souly, even when that is against the laws set in place. This ideaRead MoreBeing a Good Citizen Essay960 Words   |  4 Pageswithin his essay, Civil Disobedience; Thoreau discusses certain characteristics of a good citizen. Examples of Thoreaus definition exist in both the ancient and contemporary culture. Sophocles describes Antigone as a good citizen by Thoreaus definition. Within the play, Antigone, Sophocles utilizes the character of Antigone to epitomize the proper role of citizens within a society. Currently in India, economic growth has given rise to the need for good citizens to help morally develop the growing countryRead MoreCritical Lens Essay (Anitgone)  ¬Ã¢â‚¬  Ã‚ ¬Ã¢â‚¬  Ã‚ ¬Ã¢â‚¬  Ã‚ ¬Ã¢â‚¬  Ã‚ ¬Ã¢ €  Ã‚ ¬Ã¢â‚¬  Ã‚ ¬Ã¢â‚¬  Ã‚ ¬Ã¢â‚¬  Ã‚ ¬Ã¢â‚¬  Ã‚ ¬Ã¢â‚¬  Ã‚ ¬Ã¢â‚¬  811 Words   |  4 Pagestragedy Antigone by Sophocles in which two tragic heroes Creon and Antigone have to endure the pain of trying and failing.   To the naked eye it may seem although Creon and Antigone are the complete opposite of one another, however Creon and Antigone are enduring the similar experiences throughout the play despite the despise they have for one another. Creon and Antigone both have the characteristics of tragic heroes but demonstrate those characteristics in different ways. Both Antigone and CreonRead MoreCivil Disobedience In Antigone By Sophocles1195 Words   |  5 Pageslaw was interfering with their moral and ethical values even if it was unwritten. On the other hand, Sophocles, in the play â€Å"Antigone† reveals the grief, struggle, inner strife and distress of a young woman. Through her speech, Antigone can persuade her audience by employing rhetoric, passion and subtle alteration, and therefore, able to fight against injustice she faced from Creon. Thus, both Antigone and Martin Luther King Jr. employ the use language as a strategy to pass their messages and ideasRead MoreAntigone And Martin Luther Kings Letter From Birmingham Jail831 Words   |  4 Pagesit due to the racism and injustices that were happening. In Antigone, she buries her brother even though he was not meant to, and due to she is a female and that she broke the law that was unjust her consequence is to die. Sophocles’ Antigone and Martin Luther King’s â€Å"Letter from Birmingham Jail,† explore a common theme that law sometimes conflicts with justice through the characters of Antigone, Creon, and the voice of Dr. King. Antigone has broken a law and is willing to die for it. She has buriedRead MoreAntigone And Letter From A Birmingham Jail Analysis716 Words   |  3 PagesSophocles’ â€Å"Antigone† and Martin Luther King Jr.’s â€Å"Letter From a Birmingham Jail† are two works of literature addressing the concept of nonviolent civil disobedience. â€Å"Antigone† is the story of a young woman, who the play is named after, who buries her brother against the law, as he was a traitor. She was then incarcerated and sentenced to death by the king of Thebes and her uncle, Creon. â€Å"Letter From a Birmingham Jail†, as the name implies, was written while King was arrested in Birmingham forRead MoreThe Themes And Summary Of Antigone By Sophocles1318 Words   |  6 PagesSummary of Antigone â€Å"Antigone† is a tragedy made by the author Sophocles. Antigone starts out in Thebes in a post-war atmosphere. There was a war between two brothers for the crown of Thebes. The two brothers kill each other on the battle field resulting in one of the brothers receiving the people’s love and the other being labeled as a traitor to Thebes â€Å"Both brothers were killed in Battle.† Creon, the new king of Thebes, has decided because of Polyneices betrayal he shall not receive a soldier’sRead MoreCivil Disobedience And Martin Luther King s Letter From Birmingham Jail1236 Words   |  5 Pagescommit actions that may not be looked upon lightly such as committing civil disobedience. In Sophocles s â€Å"Antigone† and Martin Luther King’s â€Å"Letter from Birmingham Jail†, both, King and Antigone, were supporters and activist of civil disobedience. However, both, Antigone and Martin Luther King had different methods of conducting civil disobedience and viewed civil disobedience differently. Furthermore, Antigone and Martin Luther King were both steadfast in what they believed in and used civil disobedienceRead MoreThoreau Civil Disobedience Analysis963 Words   |  4 Pagesdisobedience. In Thoreaus work, â€Å"Civil Disobedience,† Thoreau makes points that clearly justify Antigone’s actions. One such case is when Antigone goes to give her brother a proper burial. Another one of these cases occurs when Antigone is put into jail for being honorable. Finally, an example of Thoreau’s idea of civil disobedience is epitomized when Antigone refuses allegiance to a government that she views as unjust. According to Thoreau, Antigone’s actions were just when she went to bury her

Good Fall Free Essays

A Good Fall The word Freedom has a different connotation in every part of the world, to have freedom means to have certain characteristics. These characteristics would be having the Third Eye, self-control, humility, and the ability to be able to overcome problems with a strategized plan. In the short story collection A Good Fall by Ha Jin, each story puts characters in dissimilar positions where they show whether or not they have the characteristics that define freedom. We will write a custom essay sample on Good Fall or any similar topic only for you Order Now A Composer and His Parakeet†, â€Å" In The Crossfire†, â€Å"The Beauty†, and â€Å"Temporary Love† all involve characters that seem to be trapped in a current relationship, but for different reasons. Learned Helplessness is a disease, in which you close your heart and mind to your strong self and settle for your weak self-resulting in shame, several characters are diagnosed with this disease. The Third Eye can be defined as self-awareness, it allows us to interpret the current situation we are in, and analyze the good from the bad. It emphasizes the bigger, long-term picture over the short-term and helps make decisions out of reason rather emotion. A person with the third eyes exercises discipline over desire. Humility is simply learning from our mistakes to make us stronger and wiser. Fanlin from the story â€Å"A Composer and his Parakeets† shows traits of having freedom. His girlfriend Supriya owns a mute parakeet Bori; she leaves Bori with Fanlin as she goes off to Thailand for her job as an actress. At the beginning Fanlin disliked the bird because he believed one of Supriya’s ex-boyfriends gave her the bird. Over time he grows a heart and starts bonding with the bird, he lets him into his music studio in which the bird was not allowed in at first. Fanlin was preparing to write for an Opera event that was coming up. Weeks went on and the bird went everywhere Fanlin did, until one day by the beach the bird flies away and almost drowns and Fanlin throws himself into the water to save it. Bori would later die the following day and his girlfriend did not seem to care about the bird anymore. This made Fanlin’s third eye kick in as he wondered whether she would not care about him like she did with the bird over time. When the bird died so did his relationship with Supriya. Fanlin’s students that he thought music lessons seemed concerned about him and so they bring him another parakeet. This parakeet had a dirty mouth and Fanlin paid him no mind, he even left his window open so he would fly away. After the death of the first bird and the death of his relationship, Fanlin goes on to write a beautiful second half of music in his opera which was full of emotion and is told to go back to rewrite the first half. His second bird would fly away shortly after, symbolizing he being set free from his past relationship that was just a waste of time. Self-control is the ability to improve our position rather than surrender to self-destruction and compulsion. In the story â€Å"Temporary Love†, Lina a married woman who’s husband was in China, lived in the United States with a married man. Although she tells her husband that she lives by herself, she has sexual relations with this married man who’s spouse as well lived in China. They had a mutual agreement to end this temporary relationship until their spouses arrived in the United States. Unfortunately Panbin, the man Lina stayed with grew feelings for her and told her repeatedly he was in love with her. Lina told him a plethora of times that she was married and that they agreed to end this arrangement whenever one wanted. Her husband was coming to the United States so Lina prepares to move out and find her own apartment. She thought that her husband did not know about the affair but he did. He had his ways of having someone follow her and relay him the information he needed. This put Lina in an uncomfortable position, her husband told her he did not want to find a job and was going to go to business school to get his MBA. Not only that, but Lina was going to pay for it with all her money she had saved in her bank account. She had no other choice but to pay for his schooling, she feared that once she paid he would soon leave her. Secretly she would visit Panbin for advice but he paid her no mind for leaving him. Now she was trapped in a relationship she could not escape. Lina could either pay and face the consequences of her husband maybe leaving or not pay and face the humility, disappointment, and shame in her by her family back home for her actions. Lina is a victim of learned helplessness. Freedom was a major contributor in Fanlin actions as he could freely relieve himself from Supriya. As for Lina, she was strapped in for a long ride with the devil. Fanlin is able to figure out that Supriya was no good for him and that she would soon leave him. He made up his mind and left her, and was free without her. Lina in this case was stuck, she had no self-control, she was ashamed of herself and her actions, the only thing she could do was pay her husbands tuition for taking of her ailing father back home. Some people are born with the third eye such as Fanlin, while others lack it and suffer and live a life without any freedom. How to cite Good Fall, Papers

Money Makes the Mare Go Essay Example

Money Makes the Mare Go Paper Money is, no doubt, a miracle. It endows us with happiness, wipes our tears, soothes our wounds, makes our life mirthful and rosy, gives us laughter and joy and changes our dreams to reality. Though not for all of our problems, it is a panacea for most of them. In the eyes of the world a rich man is wise man. He gathers most friends. His prosperity makes him smart enough to collect as much friends as he likes. Wealth, even in the most improbable cases, manages to convey the aspect of intelligence. The golden key of money opens up even the trickiest locks of troubles thus rightfully giving its owner the prestige of being intelligent. Survival of the fittest is the law of nature. Those who struggle survive; those who shun effort become extinct. God says in His Holy book, ‘Man gets what he strives for’. It is a part of the nature of humanity to struggle for better food, better clothes and better lodging and surely money making is one of its basic needs. The art of getting rich consists not in industry, much less in saving but in a better order, in timeliness, in being at the right spot. We will write a custom essay sample on Money Makes the Mare Go specifically for you for only $16.38 $13.9/page Order now We will write a custom essay sample on Money Makes the Mare Go specifically for you FOR ONLY $16.38 $13.9/page Hire Writer We will write a custom essay sample on Money Makes the Mare Go specifically for you FOR ONLY $16.38 $13.9/page Hire Writer Though money is a terrible master and an excellent servant yet we ought not allow it to overwhelm all our abilities and master whole of our life. It was rightfully said by some one that he does not posses wealth that allows it to posses him. Rightfully, if we command our wealth we shall be rich and free, if our wealth commands us we are poor indeed. With out money we can’t even think of living a life of comfort and ease, so, yearning for wealth is a positive activity in itself but wealth shouldn’t be the ultimate end of all of our struggles. Money is like a serpent. If we know the trick to charm this creature it would be valuable for us but if we don’t know the mantra it would definitely bite us. Money has the seductive sting of engulfing all of our attention and abilities and at the end man becomes the epitome of the picture presented in the holy scriptures in the words of: ‘Although they posses more and more than enough yet they yearn for more’. This incessant urge for getting more is the real adversary of man’s spirituality. Admittedly, money is a source of solving all riddles in our lives but we should always keep in mind that worldly riches are like nuts; many a tooth is broke in cracking them but never is the stomach filled with eating them. The greatest wealth is contentment with little. It is an old saying that money makes the mare go and it is applicable on our life to day too. We see that there is nothing which is available to us without money. We have to install air conditioner, cooler or heaters to keep us cool and hot and even water is not available without money. If money is most necessary for properly running this life, we must have money and therefore, each one of us shall have to work and earn money. We shall need money for running our life and we also need money for the rainy days. We can fall ill and we shall turn old too and therefore, if we have no saving with us, we shall be facing difficulty. Money can be earned honestly and it is not necessary that we should adopt wrong methods to collect and save money. If we commit a crime, we shall be caught by the police and instead of having easy life with such money, we shall be attracting more and more problems for us and there are chances that we may be spending our earlier savings with the police or with the courts. Therefore, we should prepare ourselves to earn money with our own hands and we must adopt honest means to collect money. The people who have got proper education, proper training and they are properly adjusted at work, they are able to have money and they shall be happy to spend that money. People who collect money through wrong means, are not able to enjoy that money because they are always under fear compulsions and they do not enjoy life. Some people show that they are enjoying life with money which they had collected with wrong means, but we should be sure that such people are just showing that they are happy, but they cannot get sound sleep in the night and most of them live on drugs. Money may be most necessary for life, but it should be earned with proper care and through proper means and only then this money can play a good role in our life.

Harassment in the Workplace Essays

Harassment in the Workplace Essays Harassment in the Workplace Paper Harassment in the Workplace Paper Journal of Academic and Business Ethics Sex, harassment and the workplace Cliff Fisher Purdue university Abstract Last year, high profile individuals, such as presidential candidate Herman Cain, former MIFF chief Dominique Strauss Kahn, and Weeklies founder Julian Ganges, Strauss-Kahn, made major media coverage, because of alleged issues relating to SEX. Now that I have your attention, this paper targets sexual harassment, therefore we will not be dealing with notion, Strauss-Khans alleged sexual abuse charge, nor Julian Gangues sexual assault charges. Khans The focus Is on sexual harassment, not to commit violations of Title VII of the CIVIC Call Rights Act of 1964 and Its amendments, but to help educate employers, In order to prevent these costly legal actions and payment of damages, or If they cannot be prevented, then to reduce the exposure Involving actions that might not have been preventable. The Civil Rights Act and its amendments do not require a general civility code on employers, nor does it require a utopian work environment, but it does require that employees not be sexually harassed, with one exception. Dealing with the based on ewe element requiring that the harassment that occurred because of the complainants ex gender, and did not occur to members of the opposite sex. Steiner V. Showboat Operating Co. , and Harris v. : Forklift Systems Inc. Both deal with this issue. This Issue is evident In Harris, when the president of Forklift Systems Is found to have made comments to female employees, often In front of others, regarding their appearance and their Intelligence; In one Instance, he called an employee a dumb ass woman, and in another situation, he suggest that a female employee and he go to the Holiday Inn to other goatee your raise. The president also asked only female employees to retrieve coins from his front pants pocket, and threw objects on the ground in front of the women and asked them to pick them up. He made no such requests of male employees. This paper also deals with quid pro quo tangible employment action issues and a hostile work environment, which includes constructive discharge. The theory of vicarious liability under agency relation legal standard will indicate why and how TTY agency-relation employers can be liable for actions of their employees, In addition, the allowably of employers for actions of customers for sexual harassment will be covered. Keywords: Sexual Harassment, Ministerial Exception, International Defense segments, INTRODUCTION have your attention, this paper targets sexual harassment; therefore, we will not be dealing with Strauss-Khans alleged sexual abuse charge, nor Julian Gangues sexual assault Khans charges. The focus is on sexual harassment, not to commit violations of Title VII of the Civil Rights Act of 1964 and its amendments, but to help educate employers, in order to prevent these costly legal actions and payment of damages, or if they cannot be reverted, then to reduce the exposure involving actions that might not have been duce EXECUTIVE ORDER 10925 President John F. Kennedy in 1961 signed Executive Order 10925 requiring government contractors to take affirmative action to ensure that employees are try treated during employment, without regard to their race, creed, color or national origin. On June 19, 1963, five months before his assassination President Kennedy submitted a bill to Congress, which was signed into law on July 2, 1964, and is known as Title VII of the Civil Rights Act of 1964. One of the more interesting elements is that neither the Executive Order nor the proposed Civil Rights bill included the word sex, and attention is not intended to be drawn to the allegations of extra marital activities of the former activities president, in regard to why he didnt include sex. The term sex was added as a last last-ditch effort by opponents of the statute to thwart the passage of the Act. Sex as a basis of discrimination was added as a floor amendment one day beef the before 2 House approved Title VI, without prior hearing or debate. The bill quickly passed as amended and we are left with little legislative history to guide us in interpreting the Acts prohibition against discrimination based on sex. 3 The word sex in Title VII is where the EEOC in 1980 created the l egal rational to form the Sex Discrimination Guidelines in dealing with sexual harassment in the workplace. Title VII says nothing about sexual harassment, but the Supreme Court in Grids indicated that EEOC guidelines should be shown great deference by the courts. 4 The guidelines define sexual harassment as follows: Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature constitute sexual harassment when (1) submission to such harassment employment, (2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or (3) such conduct has the such Ulnae v. Eastern Airlines, Inc. , 742 F. Ad 1081, 1084 (1984). Holloway v. Arthur Andersen co. , 566 F. Ad 659, 662 (1977). 3 Mentor savings sank v. Vinson, 477 US. 57, 64 (1986). 4 Grids v. Duke power co. , 401 U. S. 424,433 433-434 (1971). Sex, harassment and the workplace, Page 2 purpose or effect of unreasonably interfering with an individuals work performance or creating an intimidating, hostile, or offensive working environment. 5 What happens if the harasser subjects both men and women to the same sexual women harassment? This would be the equal opportunity harasser. Courts often conclude that because both men and women are victimized, the harassment does not disadvantage members of one sex relative to the other, therefore it is not discrimination based on sex. Discrimination In Lack v. Wall-Mart, the court stated that the supervisor was Just an indiscriminately Mart, vulgar and offensive supervisor, obnoxious to men and women alike. 6 The Civil Rights Act and its amendments do not require that employees be treated in ways hat are thought of as being appropriate. Employers can be demanding, tactless, crude, mean, and irritating. This is an unfortunate fact of life, in which the law does not require a general civility code on employers, nor does it require a utopian work environment, but it does require that employees not be sexually harassed, with a few exceptions. Dealing with the based on sex element requires that the harassment that occurred be due to the complainants gender, and did not occur to members of the members opposite sex. The Supreme Court case, Harris v. Forklift Systems Inc. , dealt with this issue, when the president of Forklift Systems is found to have made comments to female employees, often in front of others, regarding their appearance and their intelligence; in their one instance, he called an employee a dumb ass woman, and in another situation, he suggest that a female employee and he go to the Holiday Inn to negotiate your raise. The president also asked only female employees to retrieve coins from his front pants coins pocket, and only threw objects on the ground in front of the women and asked them men had been demeaned and equally abused this would not have been a violation of he Civil Rights Act, even if a hostile work environment was created. 8 Harassment must be discriminatory, not merely abusive or inappropriate to be protected under the Civil Rights Act. Bullying or abuse in the workplace that is not discriminatory under the Civil Rights Act, still might be actionable under civil claims minatory and/or criminal charges for assault, battery, intentional infliction of emotional distress, and other actions. There are two kinds of sexual harassment protected under the Civil Rights Act. They are quid pro quo and hostile work environment. Quid pro quo means something for meeting or something given or received for something else. Burlington Industries v. Alert, the Supreme Court held employers vicariously liable under agency law principles for the harassment by a supervisor who has authority over the sexually harassed employee. 9 Quid pro quo relates to tangible employment action regarding sexual harassment involving situations where a supervisor or individual with authority over the subordinate with has taken significant adverse tangible employment action, such as discharge, demotion, or an undesirable reassignment against a subordinate employee for the employees refusal 5 9 C. F. R. , Chi. XIV, part 1604. 11 (1980), 1629 C. F. R. Part 51604. [emailprotected]) (200 (2008). Lack v. Wall-Mart, 240 F. Ad 255, 262 (2001). 7 Harness v. Forklift system, 510 U. S. 17 (1993). 8 sterner v. Showboat operating co. , 25 F. Ad 1459 (1994). 9 Burlington Industries v. Alert, 524 U. S. 742, 758 (1998). 6 Sex, harassment and the workplace, Page 3 to submit to the supervisors or individual with authority demand for sexual favors. With There are no affirmative defenses available to the employer for tangible employment action cases. Pease v. Alfred Photo Industries, Inc. Indicated that the following five elements must exist for the plaintiff to successfully prove quid pr quo harassment: (1 . ) Plaintiff is a member of a protected class; Plaintiff was subjected to unwelcome sexual harassment in the form of sexual advances or requests for sexual favors from a supervisor or individual with authority (3. ) Harassment complained of was based on sex; Submission to the unwelcome advances was an e xpress or implied condition for receiving some form of Job benefits, or refusal to submit to sexual demands resulted in a tangible Job detriment; and (5. ) Employer knew or should have known of the harassment. 10 player The distinction between quid pro quo and a hostile work environment regarding sexual harassment is important for determining employer liability. Hostile work environment is broader than quid pro quo and does not require an adverse tangible and employment action against the employee. The harassment can be caused by a supervisor, fellow employee, or a third party, such as a customer, vendor or stalker, if the employer knew or should have known of the harassing conduct and failed to take appropriate harassing corrective action. How hostile must the workplace become before the law is violated? In the Merits U. S. Supreme Court case, the court held that for sexual harassment to be actionable, no tangible Job detriment was necessary, but that the hostile work detriment environment harassment must be unwelcome conduct and it must be sufficiently severe or pervasive to alter the conditions of employees employment and create an abusive work environment. 11 Conduct that unreasonably interferes with an employees work performance reaches an actionable hostile work environment more quickly than mere offensive utterances, as does physically threatening conduct. 12 Whether the offensive activity has occurred in Louisiana, which is the 5th Federal District, or in Indiana, which is the 7th Federal District, the Courts have indicated that common sense and context must apply before courts and Juries in determining whether the conduct is severely hostile and abusive. 13 The employer can raise affirmative defenses, if there is no tangible loss from a hostile work environment involving sexual harassment. The defenses are as follows: (1 . ) the employer exercised reasonable care to prevent and promptly correct any sexually harassing behavior at its workplace and the plaintiff employee unreasonably failed to take 10 Pease v. Alfred Photo Industries, I Inc. , 667 F. Soup. 1188 (1987). Mentor v. Vinson, 477 US. 57 (1986). 12 13 Indent v. Freeman Decorating, Inc. , 164 F. Ad 258 (1999); Patty v. Family Health System, Inc. , 280 F. Ad 749 (2002). 11 Sex, harassment and the workplace, Page 4 advantage of corrective or preventive opportunities provided by the employer or to avoid harm otherwise. 14 The existence of an employer sexual harassment policy and notification employer procedures will aid the employer in proving an affirmative defense in hostile environment cases. Another defense is that the employer has less than 15 employees. The numerously acquirement goes to the merits of the case, and the employer must raise this defense at the beginning of the case, or the employer is deemed to have waived this defense to liability. 15 A third and creative defense for sexual harassment might be to use the ministerial exception rooted in the First Amendment. The ministerial exception allows religious employers to avoid liability for discrimination when making employment decisions concerning employees who qualify as ministers. 16 The ministerial exception defense was used in Hosanna-Tabor Evangelical Lutheran Church and School v. Equal Employment or Opportunity Commission, which was a Supreme Court case decided January 1 1 , 2012, involved a lawsuit under the American with Disability Act. The Court recognized that the ministerial exception, grounded in the First Amendment, precluded application of employment discrimination legislation to claims concerning the employment relationship involving the ministerial exception. If the government were to interfere with the employment decision of the church, the First Amendment rights under the Establishment Clause could also be in violation. In the recently decided Supreme Court case, Hosanna Tabor Evangelical Lutheran Church and School v. Equal Employment Opportunity Commission, Cheryl Perish, an employee and teacher, brought a claim against Hosanna Tabor. After being deign diagnosed with narcolepsy, Perish began the 2004 2005 school year on disability. When she tried to 2004-2005 return to work in January of 2005, the school reported that they had hired another teacher to fill her position. Refusing to resign from her position, Perish threatened legal action threatened insubordinate and disruptive behavior along with damage done to her working relationship. Perish, along with the EEOC, claimed that her termination was in violation of the Americans with Disabilities Act. Under the primary duties test, the Supreme Court ruled in favor of Hosanna Tabor Evangelical Lutheran Church and School stating that the court believes that the ministerial exception bars an employment discrimination suit brought discrimination on behalf of a minister, challenging her churchs decision to fire her. 4 While the ministerial exception relates to employment discrimination pertaining to religious institutions, the 1991 Amendment to the Civil Rights Act of 1964 provides a 1964 defense for employers working in foreign countries. The language of the 1991 Amendment may provide protection for an employer regarding sexually harassment allegations involving its employees. Under the 1991 Amendment: It shall not be unlawful under section 703 or 704 for an employer (or a corporation controlled by an employer), labor organization, employment agency, or Joint labor prearrangement committee controlling apprenticeship or other training or retraining (including on-the-Job training programs) to take any action otherwise prohibited by such inning section, with respect to an employee in a workplace in a foreign country if compliance with such section would cause such employer (or such corporation), such organization, such agency, or such committee to violate the law of the foreign country in which such workplace is located. The above section of the 1991 Amendment forces employers to comply with the laws of the country in which the workplace is located. When operating in progressive and satirized cultures, the clash between culture and legislation may be of little d concern. However, as our globalizes economy expands to include a multitude of nations and culture s, the statutory dynamic is changing. If a company operating in the United States begins a venture in Saudi Arabia, the United employer must abide by the laws of Saudi Arabia. If an American woman was to be assigned to a position at this workplace, she would be subject to Saudi law. While her male counterparts could obtain a license and drive, a female is unable to drive in Saudi license 24 see 17 Sex, harassment and the workplace, Page 6 Arabia. Under EEOC guidelines, this hypothetical company may have committed sexual discrimination under the Civil Rights Act of 1964. Since sexual harassment is based on sexual discrimination, there are all kinds of hypothetical in which a female employee might be sexually harassed because of the clothes she wears or doesnt The 1991 Amendment could provide a defense for t employer. The Continuing the hypothetical, Saudi Arabia adheres to a strict policy of sexual segregation. Under strict Islamic Shari law, women are not allowed to be in the dwelling or in a vehicle with an unrelated man. In one situation, a Saudi Arabian Oman who was raped 14 times consecutively by 7 men was sentenced to 200 lashes and 6 months in Jail, and the crime that the woman committed: entering the vehicle of an unrelated male. In a separate situation, a 75 year old woman was given 40 lashes and 4 months in prison for and 27 letting a young man deliver bread to her dwelling . Under the 1991 Amendment, the guidelines for sexual harassment must abide by the laws of the foreign nation. If a woman from employed by a United States global corporation were to be employed in Saudi Arabia, she would be forced to adhere to the confines of Saudi law. Although he law may constitute sexual harassment by our standards, no penalty may be levied against the employer under the Civil Rights Act. Aside from the international impact, the 1991 Amendment to the Civil Rights Act of 1964 provided codified clarification to the burden of proof required to prove an unlawful employment practice. Under 42 USC S IEEE 2000+2: (m) Impermissible consideration of race, color, religion, sex, or national origin in religion, employment practices. Except as otherwise provided in this title [42 USC IEEE et see. ], an unlawful employment practice is established when the complaining party monstrance that race, color, religion, sex, or national origin was a motivating factor for national any employment practice, even though other factors also motivated the practice. Prior to the 1991 Amendment, it was at the courts discretion to decide whether or not an employment practice was altered through unlawful consideration of race, color, unlawful religion, sex, or national origin. While case law supports the principle that an unlawful consideration need not be the sole factor in altering an employment pra ctice, the burden of proof was unclear. Under the 1991 Name Amendment, the so called mixed-motive dive standard emerged.