Viable Alternative Energy For Replace Fossil Fuels

Viable Alternative Energy to Replace Fossil Fuels Nauman Syed Zia University of Houston Nearly all of the United States production of energy comes from non-renewable sources, also known as fossil fuels. However, the problem with using fossil fuels to satisfy the United States ever-growing demand for power is that they are a limited resource and their production and usage cause a myriad of harmful environmental effects. There are other sources of energy available that do not run out and are much more environmentally friendly such as wind, solar and hydro power. The government should take further action into transitioning from environmentally damaging non-renewable fossil fuels to cleaner and more permanent alternative†¦show more content†¦Based of the origins of these fossil fuels, it is easy to see how incredibly slow the fossil fuel process is. In fact, the process is so slow that regeneration is negligible. Continued use of these fossil fuels will cause them to rapidly run out. Basically, when these fuels run out, they are gone forever. Its simply a matter of time until the United States will need other sources of power, and it is a smart move to act now on creating sustainable methods of energy rather than wait until the nation is forced to switch. The attractive feature of using alternative energy such as wind, solar, and hydro power is the assurance of renewability. There will always be naturally occurring winds, moving water, and radiation from the sun that can be converted to energy. The United States government should invest its time and resources into implementing these energy sources in order to secure sustainable energy. These alternative energy sources are more environmentally appealing as they do not cause nearly as much environmental damage that fossil fuels do. Aside from fossil fuel s long-term non-sustainability, the United States should shift to renewable resources because of the detrimental effects fossil fuels pose to the environment and people. The use of fossil fuels lead to an increase in air pollution, water pol lution, land pollution, and even global warming. During fossil fuel combustion, pollutants such as carbon monoxide, nitrogen oxides,

The Dangers of Texting and Driving Essay - 1852 Words

Texting and driving is known to the world as one of the most dangerous things to do while on the road. Not only is it dangerous to the person driving, but also much more dangerous to the people and cars surrounding that particular individual. According to many people texting and driving is similar if not identical to that of drunk driving. For example texting and driving physically and mentally impairs you to drive straight down a road, without causing a danger to people. As a whole population, we need to stop the use of texting and driving whether it’s putting laws in place or designing a program that shuts off the use of texting the moment you step foot in the car. Anything at this moment in time will help us; all we need to do is†¦show more content†¦So clearly this is a valid problem that needs to be stopped. While watching â€Å"From One Second To The Next - A Texting while driving documentary† by Werner Herzog there were three instances where textin g and driving changed these three families lives forever. The first example from the documentary occurred in Milwaukee, Wisconsin where a small child and his older sister were walking along a cross walk at a four way intersection when a young teenager ran the stop sign impaired while texting, and hit the small child paralyzing him from the neck down. The second accident took place in Bluffton, Indiana. A man had his head in his lap texting his wife when he hit an Amish Buggy, going about 50 mph and killed three young children on impact. The third example happened in Logan, Utah when a young adult was distracted with his phone when he crossed over the center line of the road where he side swiped another car leaving it skidding in his lane heading straight into oncoming traffic. The two passengers that were hit in the car suffered major injuries and killed on impact. This video not only shows us the consequences for the victims lives, but for the people that caused it in the fir st place. They now have to go through life knowing that they killed or seriously injured someone just because of a stupid text message. Something that could have been taken care of by pulling over or even at a stop light or when they arrived at theirShow MoreRelatedDangers Of Texting And Driving1361 Words   |  6 Pages Dangers Of Texting and Driving Drivers should not be able to use their hand held cell phones while in a moving vehicle. Too many teens and young adults are being killed each year in texting and driving related accidents. Teens and young adults must be educated about the effects, benefits and laws of texting and driving in order to keep adults and teens safe while driving a vehicle. Cell phones should not be in use inside a vehicle whileRead MoreThe Dangers Of Texting And Driving1391 Words   |  6 PagesDistracted driving alone has claimed around 3,500 lives in the year 2015 (Currin, Andrew). These numbers have increased throughout the last decade causing people to take notice. Texting while driving is the leading cause of distracted driving deaths in the United States. In the last seven years, states across the U.S. have banned texting and driving in efforts to stop fatal accidents that have claimed so many lives. The focus of this is piece is to understand the dangers of texting and driving, the directRead More The Dangers Of Texting And Driving1065 Words   |  5 Pagesan epidemic than a bad habit, is distracted driving. Texting and driving specifically, immediately endangers yourself and anybody around you. Besides texting and talking on the phone, other distractions include eating or drinking, looking at maps, changing the radio, grooming, etc. Next time you are able to watch people driving, notice what they’re doing. I’ve noticed that often times, especially on the freeway, people are doing everything except driving. It’s almost as if they see it as a mundaneRead MoreThe Dangers Of Texting And Driving1070 Words   |  5 Pagesyou to risk your life and the life of others on the road with you? The people that have been injured in texting and driving accidents would tell you probably not; and the people that have died in texting and driving accidents wish they were still here to tell you it absolutely was not important enough. II. Thesis/Subject: NEED We need to educate ourselves on the risks of texting and driving. It’s not just a small problem anymore, it is major cause of many accidents in our society today andRead MoreThe Dangers Of Texting And Driving Essay1775 Words   |  8 Pagesthan the safety of themselves and others. This is quite a terrifying thought. Unfortunately, I have experienced what texting and driving can do to someone. I wish I had not seen what texting and driving can do, but I have. Seeing the damage it can cause has made me always keep my phone out of my hands when I am driving. Some of the people I know that was involved in a texting and driving incident were lucky to survive while others were not so lucky. I might not see eye to eye with whoever is readingRead MoreTexting, Driving, And The Dangers Surrounded By It1080 Words   |  5 PagesTexting and Driving Introduction The message I chose to analyze is texting and driving, and the many dangers surrounded by it. I selected this message because people need to become more aware of how serious the issue is and the increasing number of fatalities that are resulting due to texting and driving. Did you know that texting takes your eyes off the road for 4.6 seconds? At 55 mph, that’s like driving the length of an entire football field blindfold (Distraction.Gov). Now just envision thatRead MoreThe Dangers of Texting and Driving752 Words   |  3 PagesThe parents of a popular 17-year-old who died on the first day of school are urging teen drivers to resist distracted driving after police confirmed Deianerah L. was texting when she crashed into the back of a school bus. Deianerah died shortly after the crash near Byron. It was the first and last day of her senior year. She crashed into the back of a bus. Ethan Hinton, 7, was exiting the bus at the time of the crash, and was knocked down by the impa ct, but the student was not seriously injured.Read MoreThe Dangers Of Texting While Driving1239 Words   |  5 PagesDriving While Intexticated The invention of the automobile has revolutionized transportation; likewise, the more recent invention of mobile devices, such as the cell phone, has transformed the world of communication. However, there’s no doubt that using the two together is not the safest way to go. In our modern technological society, people are inclined to constantly use their hand-held devices wherever they go. Texting while driving is a growing habit that not only teens, but adults as well haveRead MoreThe Dangers Of Texting While Driving1561 Words   |  7 Pagesways in which this powerful object can be dangerous. Texting while driving is one danger many do not realize until something drastic happens. Texting while driving is not only a threat to us, but as well as other drivers, passengers, and pedestrians. However, with the lack of enforcement on the laws and punishments, the use of cell phones while driving does not come as a threat to drivers, which needs to change. Using a cell phone while driving causes an overwhelming amount of accidents, injuriesRead MoreThe Dangers Of Texting While Driving977 Words   |  4 Pagescaused by texting while driving (â€Å"Cell Phone†). Likewise, that is about half the percentage of accidents kindled by drunk driving. Driving preoccupied is injurious; furthermore, adding texting into the equation yields the greatest amount of accidents. One text could alternate a person’s entire life, or worse, cease their life. The danger of texting while driving is an outlandish issue that can be diminished by prohibiting its use and offering phone-disabling devices in vehicles. Texting and driving

Group Minds - 1068 Words

Brandon L. Locklear Deana Johnson ENG1050 July 9, 2012 Dismissing your own individual opinions to reach group consensus, now that’s negative peer pressure! Peer pressure will always be a problem and can affect anyone. I say that because no matter where you’re from or who you are, peer pressure is lurking about. Anytime you’re pressured to do something and your conscience is telling you not to do it, and you follow through with the task anyway, that is dismissing your opinion just to please other group members. Not wanting to be ostracized by others is the basis of conformity. Peer pressure doesn’t discriminate against race, nationality, or social class. It’s like a plague waiting to spread like wildfire throughout your school, your†¦show more content†¦Lessing pronounces â€Å"the majority in the group-according to instruction will assert stubbornly that these two shapes or lengths are the same length, or size, while the solitary individual, or the couple, who have been so instruc ted will assert that the pieces of wood or whatever are different.† I am completely on one-accord with Lessing’s example. Lessing demonstrates that the majority will intimidate the minority group and have the minority group strayed away from their opinion, hence conformity. That is typical human behavior and Lessing clearly proves her point. For example: Four people are determining whether or not the color of a flower is pink or fuchsia. The majority group says the flower is pink, while the minority group says the color is fuchsia. The majority group is stubborn, and refuses to accept that the color is fuchsia and insist that the color is pink; meanwhile, the minority group soon after conforms, leading up to the dismissal of their own individual opinion. In consequence, Lessing is a remarkable writer and role model. She demonstrates eye-opening evidence about typical human behavior. I predict that the negative effects of peer pressure will never change for the better unless; more people want to make a change. Creating organizations like â€Å"Live above the Influence† will always fight a never-ending battle, and they will continue to bring awareness to negative peer pressure.Show MoreRelatedGroup Mind869 Words   |  4 PagesThe Group Mind People change to the atmosphere. If you are with a friend you can watch how this attitude changes from when he is with you to when he is set in the group mind around other peers. You can also look at yourself. Humans act on their natural instincts and if you look at yourself and how you act when you are alone compared to how you act in the group mind setting, you will see that you almost dumb yourself down to a level that you think will help you fit in with your friends. If weRead More`` Group Minds `` By Doris Lessing881 Words   |  4 PagesDoris Lessing presents a discussion in â€Å"Group Minds† â€Å"regarding the context of obedience in group settings by shedding light on its most fundamental flaw, the â€Å"western image†. The western image is one of individualism, we are social creatures by nature.† â€Å"By socializing in groups we diminish the space for our individual growth by abiding by the ideologies of one group.† Lessing was a daughter of farmers born in Persia, present day Iran in the year 1919. Lessing’s educational journey started at aRead MoreThe Human Mind And Behavior As Individuals And Small Groups984 Words   |  4 PagesA. Unlike psychology which focuses on leaning the human mind and behavior as individuals and small groups, sociology is the course to study human social relations and the society itself. Sociology focuses on explaining societal behavior by studying how gender, race, social classes, religion, socioeconomic status, and sexuality can associate with the overall culture. Example of sociology, social stratification, sociology will lean about how social stratification is formed and how it divides the peopleRead MoreComparitive Critique of Doris Lessings article Group Minds and Solomon Aschs experiment.2130 Words   |  9 Pagesinfluences shape every persons practices, judgments, and beliefs. (Asch 306) In Opinions and Social Pressure, Solomon Asch examines how individuals tend to conform to a group or majority. He does this by explaining the results of his experiment that he devised to observe to what extent conformity occurs. In her essay titled Group Minds, Doris Lessing claims that as a society we have enough knowledge about conformity to do something about it, yet we choose not to. Although Doris Lessing and SolomonRead MoreVirtual Community Essay1342 Words   |  6 Pagessharing activity. Facebook is one of many sites that lodges online community, and among many groups founded on Facebook, game group is one of most common ones. People who play the same game will gather together in the group for players who play the same game and share what they know, make guide, and discuss many things related to the game. When such group is created, this kind of group also naturally has their own style to identify themselves through their language. For exampleRead MoreWhy Groups Experience Conflict Within The Organization997 Words   |  4 PagesIn today’s complex business environment managers and employees face many obstacles relating to working in groups on assigned projects in order to complete those projects that ultimately contribute to the bottom line, or enables the company to remain a competitive force within their assigned industry. There are many reasons as to why groups experience conflict but one business I want to highlight refers to conflict within the organizational structure. Organizational Structure According to RobbinsRead MoreCulture Is The Mind s Way Of Separating One Group Of People From Another ( Kawar )1087 Words   |  5 PagesIntroduction Culture can be defined into many definitions and it also can be separated into different types, all so that we can better understand it. Hofstede claimed that culture was the mind s way of separating one group of people from another (Kawar, 2012). Due to the technological advancements in the world people from all over are working together with new ways of communication. Though we must know the diversities of each culture in order to avoid being offensive, the same principles we useRead MoreThe Application of Zone of Proximal Development and Scaffolding in Elementary Math Instruction1440 Words   |  6 Pagesa teacher and learner not only focus on the skill but the social and cultural value of the skill which is imparted through praise and positive relationship building (Gordon and Browne,2004,P149). Additionally, students were seated in collaborative groups and conversation was not discouraged during the practice portion of each segment. This socialization allowed for formal and in formal support to be provided through peer interaction thus cultivating a stronger understanding of the concept though theirRead MoreHow My Leadership Project Went And The Pros And Cons Of Each Member Within My Group958 Words   |  4 Pageswill evaluate myself and the rest of my group on how overall our leadership project went and the pros and cons of each member within my group. The members of my group include myself, Michael Williams, Divya Reitz, Zack Benner, and Travis Geidroc. Reviewing and looking at how well each student worked individually will help show where things went wrong or went well throughout the planning of the leadership project. Not only will I evaluate each student in my group, but I also will review our full valueRead MoreNaomi1820 Words   |  8 PagesThis assessment opportunity is worth 20% of your final grade Collaborative Comic For this assignment, you are also welcome to create a short comic of your own. You may do this in a small group. Your comic should be in either black and white or in colour. Please consider the following for your group submission: âÅ"“ Your work is a minimum of two A4 pages (at the very least) if you are working manually. Your work must be saved as a PDF so that it can upload to SLATE, and be downloaded

The Raven by Edgar Allan Poe - 1334 Words

Beatriz Castro Professor Gary Smith English 1302 10/31/2012 Symbolism in â€Å"The Raven† Edgar Allan Poe was highly criticized throughout his life whether it was for his high achievements or his downfalls; he always seemed to be talked about. Poe was born in January 19, 1809; his mother died shortly after being abandoned by his father leaving him and his brothers’ orphans at an early age. Poe was taken by John and Francis Allan. With the help of his foster parents he was later able to attend the University of Virginia where he studied French, Spanish, Italian, and Latin, and had an excellent scholastic record. He soon was not able to pay for tuition and started gambling and drinking. His foster father would not pay his â€Å"debts of†¦show more content†¦This also says a lot about the level of sanity of the student. â€Å"A more rigorous reading suggests that the ravens Nevermore does not provide even the ostensible answer the speaker reads into it† (Freedman, 1). With this quote it is clear that the level of sanity of the student is suffering f rom the loss of his lover Lenore. The loss of his lover is what drives the student to see the raven as a prophet something far more than what he really is. The bust of Pallas is also a symbol in the poem â€Å"The Raven†. Pallas is Athena, Greek goddess of wisdom. â€Å"But, with mien of lord or lady, perched above my chamber door—Perched upon a bust of Pallas just above my chamber door† (Poe, 599). There was a statue of Athena right outside the student’s door. It is not merely a coincidence that Poe decides to position the raven perched upon the bust of Pallas a statue that represents wisdom. This helps signify the importance of the raven on this poem and that of the statue. This statue brings upon a sense of knowledge; so as the raven positions himself on it, it can be understood as to why the student would consider the bird to be far more than just an animal. This statue being located right in front of his house could symbolize the wisdom and answers the student desperately needs. Despite the fact that the narrator, the student, knew that the raven was speaking out of repetition he had the belief, orShow MoreRelatedThe Raven By Edgar Allan Poe849 Words   |  4 Pagesnarrator of The Raven by Edgar Allan Poe experiences this void after the loss of his love Lenore. The narrator is isolated from the world until a raven appears before him. The events and dialogue that follow are what makes The Raven such a legendary piece of literature. The gothic poem The Raven by Edgar Allan Poe is an example of repetition and shift. With the help of repetition and shift, Poe’s use of diction gives the reader clarity to the meaning of the poem. Nevermore, the answer the Raven gives theRead MoreEdgar Allan Poe (the Raven)1496 Words   |  6 PagesEdgar Allan Poes The Raven Poes The Raven is not only an American classic, its a favorite of high school students around the world, as well as their teachers. That being said, its still poetry and therefore can be difficult to understand. Read this summary to review the contents and get a better understanding. * Stanzas: 1-2 Make everyone in class think youre really smart when you bust out everything youve learned in this summary: Stanza 1:  Its late. The poems speaker is tiredRead MoreThe Raven By Edgar Allan Poe1062 Words   |  5 PagesWritten by Edgar Allan Poe, â€Å"The Raven† is a famous short poem known for the dark fantasy that it portrays. From the mindset of a first person narrative, one may experience the tale through the eyes of a haunted man who is in mourning for the death of his beloved Lenore. As this man sits in his chamber, within a dark and dreary December night, a â€Å"raven of the saintly days of yore† visits him. The raven is no ordinary bird, for it is like a ghost, silent, yet it answers every inquiry the man presentsRead MoreThe Raven By Edgar Allan Poe964 Words   |  4 Pages Essay 1 In the poem â€Å"The Raven†, Edgar Allan Poe expresses a current state of drunkenness, drug use, and depression as existing in a dark and dreary prison like setting, tormented by the memories of a lost love. Poe’s literary career was undoubtedly influenced by the many tragedies he suffered in his life. These misfortunes are evident in the correlation between his characters in his writings and real life events. It is clear that Poe had a problematic life from a young age; he struggled with mentalRead MoreThe Raven, By Edgar Allan Poe Essay1741 Words   |  7 Pagesprominent writer of the horror fiction genre would be Edgar Allan Poe, well known for writing The Raven, who would be the most recognizable and most established horror writer. Edgar Allan Poe was born in Boston on January 19, 1809 and was the middle child of three children. At the age of 3, both of his parents died and was then taken in by a tobacco merchant by the name of John Allan in Richmond, Virginia. John Allan wanted Poe to be a businessman but Edgar was by no means a businessman. By the age of 13Read MoreThe Raven By Edgar Allan Poe1157 Words   |  5 Pagesâ€Å"The Raven† is a fictional poem written by Edgar Allan Poe in which the audience witnesses the narrator’s gradual change from a weary scholar to grieving lover. While falling asleep, he suddenly hears a tap at his chamber door. In alarm, the scholar tries to reason with himself and explain away the soft tapping. Eventually, he gains courage, opens the door, and finds it void of anyone. The narrator immediately wonders if it is perhaps his lost love, Lenore waiting for him, yet the only answer toRead MoreThe Raven By Edgar Allan Poe Essay1073 Words   |  5 Pages The poem I selected is â€Å"The Raven† written by popular American writer, Edgar Allan Poe. I chose this poem because of previous memories of reading several of Edgar Allan Poe’s writings. I remember in 8th grade when my teacher introduced the whole class to a short story called â€Å"The Tell Tale Heart†. I loved the poem a lot, I liked how gory, detailed, and interesting it was. It went perfectly for the time of year it was, which was October. Soon after we were done reading the poem, the whole grade wentRead MoreThe Raven By Edgar Allan Poe945 Words   |  4 Pageshad to experience hardly any grief in my life. Everyone is different which results in everyone having their own way that they deal with grief. The way that Edgar Allan Poe describes grief and the way that Emily Dickinson describes grief is both different and similar. Poe’s famous poem titled â€Å"The Raven† is a great example of how Edgar Allan Poe writes about grief. The poem is about the grief of the narrator during the loss of the love of his life, Lenore. The narrator’s opening statement in theRead MoreThe Raven By Edgar Allan Poe1900 Words   |  8 Pagesall expectations and thoughts on poetry. His name is Edgar Allan Poe. He brought a lot more to the scene than just poetry, and that is what he is well known for. His poetry was more than just writing; they were dark stories that somehow resembled to him in some way. He wrote great works such as, â€Å"Eldorado†, â€Å"A Dream†, and â€Å"Alone.† All of those poems are great, but there is two that stand out far greater than all of them: â€Å"Annabel Lee† and â€Å"The Raven.† They share a similar story-line, but different popularityRead MoreThe Raven By Edgar Allan Poe Essay2246 Words   |  9 Pagesthat directly connects you to a well-known poem by Edgar Allan Poe. â€Å"The Raven† is a literary work that has gone down in ages as being a timeless classic that transcends your senses as you dive into this sinister tale. Poe had a life of hardships but still was able to prevail in life becoming a great writer writing many poems and stories that are mysterious and prevalent today. â€Å"The Raven† has many displaced factors that make it seem as though Poe is truly referencing his life throughout the work

Free Essay about Ethical Issues Of Employers

Question: Write an essay on "Ethical Issues of Employers". Answer: Self Reflection: Each person has own ethics that induce him to work in his way. Nowadays, the ethical dilemma at the workplace has been growing. I think conflicts influence to create ethical dilemma at the workplace. Hence, it can be assessed that ethical dilemma is a major issue in the workplace. Few days ago, I faced an ethical dilemma at my workplace. There are several types of ethical issues of employers including favoritism, sexual harassment, terminating employees without any notice and delaying in payment. On the other hand, employees are also responsible for making ethical dilemma in the workplace. In recent days, my managers and higher authority have shown favoritism at the workplace, and many staffs of the company have noticed it. The manager of the organization always favors his friends who have been working with other employees. Moreover, the manager does not take any responsibility for sexual harassment at the organization. Hence, is harms the work culture. On the other hand, most employees have been resigning from the particular organization. Consequently, it is responsible for decreasing the productivity in the business. Nowadays, social media is one of the powerful media that allows us to transmit any message globally. I have posted about the managers behaviors on the social media platform so that job seekers and other employees could be aware of this fact in an effective manner. However, my manager has noticed the particular message and asked me to meet him personally. On the next day, the manager terminates me without providing any reason for doing the same. Although the higher management knew about my unnecessary termination, they did not even ask me for the reason. I could have clarified all details to the manager and the human resource management about the particular situation. However, they did not allow me to provide the information about the mangers behaviors and his unethical practices at the workplace. The human resource management of the organization has unnecessarily terminated me for the company. I think it is an ethical dilemma of the employer, as they did not take appropriate action a gainst the manager. Each organization maintains its ethics in order to uphold a healthy work design at the workplace. Sometimes, employees are also responsible for conducting ethical dilemma of the business, and the organization takes action against that individual to maintain proper work design in the business. On the contrary, if the employer conducts ethical issues on the employees, then they are not treated as guilty. Consequently, it damages the work environment and workers often become de-motivated due to these unethical practices. Most business analyst discusses the consequences of ethical issues executed by employers. Through the engagement of conducting the ethical issues, organizations often fail to experience profitable growth in the business. I consider it as an indication of huge risk factor that could damage the organizations value in the global market. I think it is also responsible for diminishing the brand value of the business in the marketplace. Hence, it can be assessed that each dep artment of the organization needs to take the responsibility to get rid of this particular issue in an effective manner. Literature review: Avey, Palanski and Walumbwa (2011) have discussed that ethical leadership consists of ethical beliefs and values that allow the employees to retain their rights and dignity in an effective manner. True leaders are aware of the values of ethical approaches and recognize the importance of conducting ethical behavior at the workplace. On the other hand, Abdul-Rahman, Wang and Yap (2010) have argued that approaches of ethical leadership needs to be shown in the business. Employees expectation is one of the major factors that influence the ethical leaders for implementing the right approach in the business. Avey, Wernsing and Palanski (2012) has discussed that the ethical leadership facilitates the organization to obtain sustainable growth in the industry. It has a tremendous impact on the employees achievement in the organization. Ethical leaders not only improve the business culture but also contribute to creating differences in the world. Effective leaders focus on the necessity of the employees in order to motivate them for providing enhanced performance in the business. Banks and Nhr (2013) have argued that the leaders need to take some actions in order to implement ethical approaches in the business. Ethical leaders need to face the complexity included in making ethical choices. Ethical leaders investigate the key development areas of the business and according to that; they implement the ethical approach in the business. The prime motive of ethical leaders is to evaluate the complexity of work life (Banks 2012). It facilitates to retain a proper work design at the workplace. On the other hand, (Ciulla, Martin and Solomon 2011) has argued that ethical leaders articulate and exemplify the purpose and values of the business. Negative interpersonal behaviors may create difficulties for the ethical leaders as it does not help to encourage employees in the business. Sometimes, ethical leaders often contribute huge success in the business by cultivating respectful e nvironment at the workplace. Gray and Webb (2010) have discussed that load-bearing work culture indicates an ethical issue of the employer, and it is responsible for diminishing the brand values across the global platform. On the other hand, with the involvement of ethical culture, organization enhances its customers base in the market. Kacmar et al (2011) have discussed that ethical leaders are committed to reducing the ethical dilemma from the business so that employees obtain social justice in an effective manner. However, the management should regard the leaders if the business in order to motivate them for providing enhanced performance in the business. By analyzing the action of the ethical leaders, it can be assessed that the organization enhances the productivity of the business in an effective manner. Kalshoven et al. (2011) have argued that the most effective method of enhancing the productivity is that the leaders must select the right people for conducting the business in an effective manner. Skill development facilitates employees to improve their individual performance in the business. Ethical leaders are always responsible for evaluating and developing the right talent for the business. On the contrary, Kim and Brymer (2011) have argued that talent crisis often creates difficulties for managing true performers for the organization. Many CEOs have agreed with the fact that judging employees integrity is far more important than identifying their experiences and skills on a particular task. Levy and Slavin (2013) have discussed that focusing on the organizational success is more important than carrying personal ego. Ethical l eaders are aware of their place within the larger network of stakeholders and constituents. Moreover, the ethical leaders value the efforts of employees and other staffs for achieving the organizational goal and objectives. For example, in 1998, Roger Enrico, the former chairman and CEO of PepsiCo decided to forego all except $1 of his salary, in order to contribute to a scholarship fund for employees children. It indicates an ethical decision of the leaders that motivates employees for enhancing performance in the business. Consequently, it facilitates organization to experience profitable growth in the global market. Mahsud, Yukl, and Prussia (2010) have discussed the process of becoming an ethical leader in the organization. To become ethical leaders the individual needs to maintain some values and principles of the business. Employees feedback is one of the important parts of judging the leaders. Hence, ethical leaders need to accumulate the peers response along with the subordinate views. It indeed facilitates leaders to evaluate the key development area in the leadership trait. On the other hand, Mayer et al. (2012) have discussed that proper mechanism and processes have to be designed by the leaders in order to implement ethical approaches in the business. it is very important for the leaders to uphold open communication with employees and other staffs at the workplace in order to clarify the goals and objectives of the business in an effective manner. Piccolo et al. (2010) have argued that the management of the business also has responsibilities to provide enhanced learning and training ses sion to leaders for developing their interpersonal skills. Moreover, training and development process would facilitate them to take right decisions in a business crisis. Hence, it indicates the ethical approach of employers providing such knowledge and development program to their leaders. There are five benefits of the ethical leadership such as reducing business liability, facilitate to make the right decision, assuring high-quality customer service, preventing costly administrative errors and rework and consistently increases the bottom line. Reamer, F.G., (2013) has discussed the impact of ethical leadership in the business. The prime advantage of ethical leadership indicates the process of building customer loyalty. Loyal customers base is responsible for expanding the business in large demographic areas. Ethical behavior facilitates the organization to enhance brand popularity in the global platform. Second, the ethical practice in the business contributes in retaining good employees in the business for a long period. Schaubroeck et al. (2012) have highlighted that fact that positive work environment and avoiding legal problems are major outcomes of the ethical leadership practices in the business. On the contrary, ethical leadership faces several challenges in o rder to implement appropriate ethical approaches in the business. By discussing the challenges of ethical leadership, it can be assessed that consistency is the major challenge for leaders in the business. Dimotakis and Peng (2012) have discussed that ethical leaders often face difficulties in adhering the rules consistently within the organization. Moreover, policies make a differentiation in the business. Sometimes, leaders face difficulties in implementing right policies in the business to obtain a profitable outcome. Shapiro and Stefkovich (2016) have argued that ethical leadership can be difficult dealing with gray areas. In this scenario, the right thing could be less beneficial to the businesss bottom line. The safety regulation has facilitated the business to maintain a proper work design in the business. Therefore, it can be assessed that ethical behavior in business enables businesss productivity in an effective manner. Customers loyalty, retaining good employees, and main taining positive work environment are the major outcomes of the ethical leadership practicing. Shin (2012) has discussed that ethical leadership facilitates in enhancing the strategic advantages in the business. Proactive business always focuses on the ethical practices at the workplace for enhancing the business opportunity in an effective manner. Application exercise: By analyzing above two discussions, it can be identified that the ethical leadership is one of the major aspects of the business that facilitates the organization to experience profitable outcome in an effective manner. There are huge challenges for the leaders for maintaining accurate work design in the business. However, Walumbwa et al. (2011) have argued that ethical leaders are not always responsible for implementing proper work culture in the organization. Sometimes, the higher management of the organization avoids their responsibilities to engage proper work design at the workplace. It has been seen that the higher management often fails to monitor their work culture within the organization, as the monitoring system enables leaders and management to identify the challenges of the system. Ethical failures indicate major risk for the organization, as it is responsible for downsizing the business in the global market. In recent years, the global industry has experienced several ethical failures in the business. Consequently, the productivity of the business has decreased a lot. The modern corporate culture allows the leaders to implement major decisions in the business in order to enhance its performance in an appropriate manner. However, leaders often make bias decisions in the organization, and it affects the work culture. Yeh and Xu (2010) have argued that ethical leaders need to be aware of the organizational values and culture. The effective leaders are responsible for retaining the standard of the business in the global platform. In this scenario, the particular organization needs to follow the ethical practices in order to retain employees. By analyzing the 2.1 (self-reflection), it can be assessed that the particular organization needs to get rid of this ethical dilemma in order to retain employees in the organization. On that particular case study, the leader in the organization follows favoritism. Moreover, the leader is responsible for the unnecessary termination of the employees. Consequently, it makes a negative impact on the brand value of the business. Banks and Nhr (2013) have discussed that not only the ethical leaders are responsible for diminishing the ethical issues but also the human resource management needs to focus on implementing right approaches in the business. In the particular scenario, the management has terminated the employee based on a message posted on the social media platform. Hence, it indicates the ethical dilemma in the business. On the other hand, the management has never taken any serious action against the ineffective leaders. Consequently, the organization has been facing challenges i n retaining employees in the business. By analyzing the 2.2 (Literature Review), it can be assessed that ethical leadership has huge importance in the business, as it facilitates the organization to enhance its productivity in the business. In the literature review, the important actions of the ethical leadership have been discussed in an effective manner. Banks (2012) has discussed the role of ethical leadership in the business. By analyzing the literature review, it can be identified that the leaders often face difficulties in maintaining consistency of particular rules and regulations. On the other hand, Gray and Webb (2010) have highlighted the fact that adhering to rules is one of the important tasks for the leaders in order to bring sustainability growth in the business. In this context, the particular organization could have implemented appropriate rules for the employees and leaders for maintaining a proper work design within the workplace. Through the engagement of analyzing the particular study, it can be identi fied that besides employees, employers are also required to review on their ethical dilemma in order to maintain the healthy work environment in the business. Consequently, it facilitates to expand the business in the larger demographic area. Kalshoven et al. (2011) has argued that policy implementation is one of the major aspects of an ethical dilemma. If the management of the organization does not implement appropriate policy in the business, then they can face challenges in managing sustainable work design at the workplace. Kim and Brymer (2011) have discussed that the involvement of ethical practices in the organization is responsible for obtaining proper growth in the global platform. The literature review highlights the fact that ethical dilemma causes awful work culture in the organization. Ethical leadership is responsible for identifying the key developing areas in the business. It is a kind of challenge for leaders to uphold workplace culture and environment, as the oppressive work environment creates difficulties for the staffs and employees to provide enhanced performance in the business. In the literature review, several authors have provided a brief discussion on the ethical leadership and its impacts on the business. Moreover, the self-reflection section has highlighted an example of ethical dilemma in the organization. Through the engagement of employing ethical leadership, organization diminishes the ethical issues from the business. Furthermore, the organization could review the potentiality of their ethical leadership for avoiding the work culture issues in an effective manner. In the literature section, authors have discussed the outcome of ethical leadership in the business. As per the review section, it can be assessed that the ethical practice facilitates the organization to avoid legal issues from the business. Hence, the business could make an enhanced brand image in the global platform by engaging ethical leaders in the business. References: Abdul-Rahman, H., Wang, C. and Yap, X.W., 2010. How professional ethics impact construction quality: Perception and evidence in a fast developing economy.Scientific Research and Essays,5(23), pp.3742-3749. Avey, J.B., Palanski, M.E. and Walumbwa, F.O., 2011. When leadership goes unnoticed: The moderating role of follower self-esteem on the relationship between ethical leadership and follower behavior.Journal of Business Ethics,98(4), pp.573-582. Avey, J.B., Wernsing, T.S. and Palanski, M.E., 2012. Exploring the process of ethical leadership: The mediating role of employee voice and psychological ownership.Journal of Business Ethics,107(1), pp.21-34. Banks, S. and Nhr, K. eds., 2013.Practising social work ethics around the world: cases and commentaries. Routledge. Banks, S., 2012.Ethical issues in youth work. Routledge. Ciulla, J.B., Martin, C.W. and Solomon, R.C., 2011. Honest work: A business ethics reader. Gray, M. and Webb, S.A. eds., 2010.Ethics and value perspectives in social work. Palgrave Macmillan. Kacmar, K.M., Bachrach, D.G., Harris, K.J. and Zivnuska, S., 2011. Fostering good citizenship through ethical leadership: exploring the moderating role of gender and organizational politics.Journal of Applied Psychology,96(3), p.633. Kalshoven, K., Den Hartog, D.N. and De Hoogh, A.H., 2011. Ethical leadership at work questionnaire (ELW): Development and validation of a multidimensional measure.The Leadership Quarterly,22(1), pp.51-69. Kim, W.G. and Brymer, R.A., 2011. The effects of ethical leadership on manager job satisfaction, commitment, behavioral outcomes, and firm performance.International Journal of Hospitality Management,30(4), pp.1020-1026. Levy, C.S. and Slavin, S., 2013.Social work ethics on the line. Routledge. Mahsud, R., Yukl, G. and Prussia, G., 2010. Leader empathy, ethical leadership, and relations-oriented behaviors as antecedents of leader-member exchange quality.Journal of Managerial Psychology,25(6), pp.561-577. Mayer, D.M., Aquino, K., Greenbaum, R.L. and Kuenzi, M., 2012. Who displays ethical leadership, and why does it matter? An examination of antecedents and consequences of ethical leadership.Academy of Management Journal,55(1), pp.151-171. Piccolo, R.F., Greenbaum, R., Hartog, D.N.D. and Folger, R., 2010. The relationship between ethical leadership and core job characteristics.Journal of Organizational Behavior,31(2 3), pp.259-278. Reamer, F.G., 2013.Social work values and ethics. Columbia University Press. Schaubroeck, J.M., Hannah, S.T., Avolio, B.J., Kozlowski, S.W., Lord, R.G., Trevio, L.K., Dimotakis, N. and Peng, A.C., 2012. Embedding ethical leadership within and across organization levels.Academy of Management Journal,55(5), pp.1053-1078. Shapiro, J.P. and Stefkovich, J.A., 2016.Ethical leadership and decision making in education: Applying theoretical perspectives to complex dilemmas. Routledge. Shin, Y., 2012. CEO ethical leadership, ethical climate, climate strength, and collective organizational citizenship behavior.Journal of Business Ethics,108(3), pp.299-312. Walumbwa, F.O., Mayer, D.M., Wang, P., Wang, H., Workman, K. and Christensen, A.L., 2011. Linking ethical leadership to employee performance: The roles of leadermember exchange, self-efficacy, and organizational identification.Organizational Behavior and Human Decision Processes,115(2), pp.204-213. Yeh, Q.J. and Xu, X., 2010. The effect of Confucian work ethics on learning about science and technology knowledge and morality.Journal of Business Ethics,95(1), pp.111-128.

Dismissal for Protecting Job Security †Free Samples to Students

Question: Discuss about the Dismissal for Protecting Job Security. Answer: Introduction: The rights, responsibilities and duties of the employers and employees are set out by the employment contract. All contractual terms in relation to an employment contract has to be carefully analyzed before the contract is entered into by the parties to it. The legal rights of the employees include right to minimum wages, right to leave and right to healthy and fair working conditions. The rights and liabilities of employer are determined through analyzing the terms of an employment contract. The purpose of this part of the paper is to identify the types of terms in an employment contract and analyze how the terms are given meaning by the courts and what are their effects on the rights and obligation of the employees and employers. The terms of an employment contract can be divided into expressed terms, incorporated or implied terms. Express terms of those terms which have been expressly incorporated into the employment contract. These are the terms which have been agreed upon by the employer and employee in writing or orally. These are those elements of the employment contract which have been mentioned specifically in the contract. Some of the examples of an Express terms in an employment contract may include redundancy pay, sick pay, hours of work including overtime hours, how much will be the wages, what is the minimum amount of notice period which has to be served in order to end the contract and leave entitlements. Express terms in a contract are not only found in the employment contract itself but also in job adverts, employee or staff manual, any letter received from the employer or any document signed by the employee. On the other hand implied terms in an employment contract are those terms which are not written or discussed orally however these terms are present and can be applicable to almost all employment contracts. For instance the employee not stealing from the employer or not leaking out the confidential information of the employee is an implied term of the employment contract. Indeed and it is also the duty of the employee to provide the Employees with the safe working condition and not direct the employees to do anything which is not legally allowed such as driving a vehicle which is not insured. Another implied term in the contract of employment is that of a fiduciary relationship and the idea of mutual confidence and trust between the employee and the employer. Implied terms can be incorporated into the employment contract even through practices and Customs in the industry. This means that the terms which have never been expressly agreed by the parties to the contract but overtime such terms have become a part of the contract. This may include terms like letting the employee leave early on Friday or providing them with a Christmas Bonus. In order to be incorporated into the contract to practice and Customs and implied term has to be long standing, automatically received, uninterrupted and expected or well known. Terms which have been incorporated into the employment contract through collective agreements and work rules are known as incorporated terms. Thus Incorporated terms may be the rules and regulations which have been provided in employee policy or the code of conduct of the employer. On occasions expressed or incorporated term may look quite simple however they provide Complex issue of construction. Construction is the process through which properly meaning and scope is provided to the terms of a contract by the courts. An interesting example of interpretation difficulties with respect to express terms have been provided by the The Sarfaty case (1992) 28 NSWLR 68. In order to ascertain whether an incorporated terms or a Express term form a part of the contract, various circumstances have to be considered such as the situation in which the document have been brought to the attention of the employees and other provisions provided in the policy and procedures of the employer. The court analysis whether the language of such terms are merely aspirational or descriptive or actually promissory in nature to give rise to a contractual obligation. The court also analyzes whether the terms can be said to have an objective intention of creating a legal relationship between t he parties. The issue have been discussed by various cases including the Romero case [2014] FCAFC 177; 247 IR 315 as well as the case of Westpac Banking Corpn v Wittenberg [2016] FCAFC 33 (esp by Buchanan J at [69] to [115]). If it is found that a contractual term has been incorporated they are provided the status of an ordinary Express term of the contract by the court. Express terms can be incorporated into the contract through reference of other documents as being the part of the original contract of employment. For instance these documents may deal with code of conduct, disciplinary procedure, bonus schemes or leave entitlements. Even if such reference is not made these documents they are usually interpreted by courts as the part of the original contract of employment. In case where procedures and policy of the employers are considered as a part of the employment contract such policy may allow the employee to modify or alter the terms of the contract periodically. Primary focus is placed by the courts on the precise language used and the circumstances in which the original employment contract has been entered upon in order to determine the rights and duties of employers and employees to employment contract. Express terms can be understood differently by different parties to the contract and therefore poses a problem for the parties as well as the courts for interpreting them. However Express terms in a contract are most of the times interpreted by the court in and objective sense and not subjectively. This means that meaning is provided to the express terms based on what a reasonable person things about the terms to be and not what the parties to the contract think about the term as discussed in the Sarfaty case. Broadly speaking implied terms are of mainly two types firstly implied by law and secondly implied by fact. As discussed above contrary to the express or incorporated terms, whether implied terms are present in a contract or not is determined by the courts. One of the primary cases which discussed about an implied term in the contract is the case of dash dash dash. In this case it was ruled by the court that a term would be an implied term if it is obvious and necessary for the continuation of contract but not if it is really fair and just. There is a significant difference between terms implied by law and terms implied in fact. Individualized terms which are specific to the context and are implied from specific provisions and terms of the employment and are considered against the contractual settings are known as terms implied in fact. These terms are only incorporated by the judges when they find that it is necessary to incorporate search terms to provide business appreciation to the contract. These terms are usually incorporated through the application of the objective test which means a reasonable person in the position of the parties to the contract would have assume such terms to be present in the contract even if they are not specifically mentioned as it was done in the case of Byrne v Australian Airlines Ltd (1995) 185 CLR 410. Standardise terms which are considered by the courts as necessary terms of all employment contracts are known as terms implied by law as provided in the case of UWA v Gray (2009) FCR 346. The test which is used in order to determine the presence of a term implied by law is wider than the objective test used to determine the presence of a term implied by fact. It is upon the will of the party to add or exclude Anita in a contract however if such things have not been done terms which have been employed by law would be said to be present in the contract and bind the parties irrespective of their objective or subjective intention. In the case of Malik/Mahmud [1998] AC 20 at 45 it was provided by the court that the terms which are unique to a specific contract in context and depend upon the form of the contract and the express terms along with the surrounding circumstances are terms implied in fact. The common thing about both kind of implied turns out that they cannot be applicable into the contract if they are contradictory to anything which has been expressly incorporated into the contract. Therefore before entering into an employment contract the employees and the employers have to gain knowledge about the application of different terms in the contract of employment as the terms specifically set out what are the legal rights and obligations of the employee and the employer. According to the Fair work Act 2009, part 3 when an employee of an organization is harshly and dismissed from his job on unreasonable grounds, it can be stated that the employee has been dismissed unfairly. The employee who has been terminated on unfair grounds can seek remedies in the court of Fair work Commission. However it is to be noted that according to section 386 of the act, for an employee to seek remedy for unfair dismissal, it must be proved that he had been terminated on the initiative of the employer. However, it can be mentioned that a person who had been forced to resign because of the conduct of the employer will also constitute dismissal. Essentials of Unfair Dismissal According to the aforementioned act (Legislation.gov.au, 2017), it can be stated that for an employee to seek unfair dismissal he needs to have completed the minimum period of employment. It is also to be mentioned that there must be an existing agreement between the employer and the employee who wishes to seek remedy for unfair dismissal. The aforementioned act states the definition of minimum time period of employment. If the employer cannot be called a small business employer, it is essential for the employee to be employed under him six months. However it is to be mentioned that the employee must be provided with a letter of dismissal prior to the dismissal. In case of a small business employer, it is necessary for the employee to be employed under him for a period of not less than one year before he can bring charges of unfair dismissal on the employer. It is important to mention that the period of employment with an employer is the period when the employee was providing constan t service to the employer and was not on temporary employment. The time period of service of a casual employee does not count and the same cannot be eligible to seek remedies for unfair dismissal. However, there are exceptions to the abovementioned provisions. If a casual employee can prove that he was working on a regular basis or if the employee can prove there was reasonable ground for him to expect the continuation of service, he will be eligible for the seek remedies of unfair dismissal. However, section 387 of the aforementioned act governs the criteria to consider the harshness of dismissal. It can be stated that an employee will not be considered to have been dismissed harshly if it is to be proved that the employee was lacking the capacity required for the job or his conduct was inappropriate for the same. It is also to be mentioned that the employee must be notified of the same and given a warning and chance to rectify his actions before his dismissal. In that case the employee cannot claim that the employer was harsh in dismissing him. Remedies for unfair dismissal Reinstatement According to section 391 of the Fair Works Act 2009 it can be stated that the Fair Works Commission may reinstate a person if it is proved that the person was unfairly dismissed. Reinstatement of a person means to reappoint the person in the position in which he was working before. The commission can also give the order to appoint the person in a position which would be in no way be less favorable than the position he was working in prior to his dismissal. It can be stated that an employee can only be employed in a post which is equivalent to the position he was working in if the position in which he was employed is unavailable. It can be stated that the Fair Works Commission can order under subsection(1) of section 391 of the act to ensure the continuity of employment of the employee in the position he was employed before or an equivalent position. The commission under the Subsection 1 can also order the employer to pay remuneration for the time period when the employ ee was unemployed. The commission however takes into account the amount earned by the employee during the unemployment from other work in deciding the compensation. It may also take into account the remuneration likely to be earned by the employee during his unemployment, which can be considered reasonable. Compensation According to section 392 of the Fair Works Act 2009 it can be stated that the FWC may grant an order of compensation to be provided to the employee by the employer, if it is proved that the employee had dismissed unfairly. Compensation can be considered a remuneration to be paid to the employee by the employer for being able to reinstate the same in the employees former position or equivalent position. According to subsection 2 of section 392 of the Fair works Act 2009 it can be stated that the there are certain criteria to be followed by the Fair Works Commission for judging the compensation to be granted to the employee. They are: The time period of employment of the employee with the employer, The remuneration to have been received by the employee had not been dismissed. The effort given by the employee to mitigate the loss suffered by the same during the term of un employment The remuneration earned by the employee from other employment or work during the period of dismissal The amount of remuneration to have reasonably been earned by the employee during the time period of the award of the compensation and the actual compensation received. However according to subsection 3 of the aforementioned section of the aforementioned act the it can be stated that the Fair works commission takes into account the whether the employee in consideration had been charged of misconduct prior to the dismissal. In case the employee was charged of misconduct, the Fair works commission reduces the compensation it would have ordered if the employee had not been charged of misconduct. It is to be mentioned that the FWC does not take into consideration the mental stress, humiliation, disregard faced by the employee prior to its dismissal. It can be stated that the remuneration to be paid to the employee should be total of what the employee was entitled to which is the remuneration of twenty-six weeks, prior to the dismissal of the employee. If the employee was on leave without or partial pay the remuneration to be received by the employee will be in accordance with regulations of the employer. Subsection 391(3) and 392(2) of the aforementione d acts states that the FWC may instruct the employer to pay the compensation Installments. However it is to be mentioned that the employer must pay the compensation to the employee within the specified time as stated by the Fair Works Commission. Unfair Dismissal Remedy Procedure: It can be stated that the employee, who has been dismissed on unfair grounds and wishes to seek remedy must apply to the Fair Work Commission for granting a remedy to the employee. The application made to the Fair Work Commission must be made within a time period of twenty days of the dismissal. It is to be noted that the Fair Work Commission may grant an extension of the application period if: The reason of delay is mentioned by the employee The employee had become aware later of the dismissal of the same The application of the parties has merit. An application fee has to be paid by the applicant under Division 5 of the aforementioned act to apply to the Fair Work Commission for seeking remedy for unfair dismissal. Redundancy: An exception to Unfair Dismissal According to section 389 of the aforementioned act it can be stated the dismissal of an employee due to genuine redundancy will not be considered unfair dismissal. Genuine redundancy can be defined as a situation when the employer of an employee no longer requires the services of the employee due to a change in the nature of work. It can be stated when an employee is dismissed due the change in the operations of the business, his dismissal cannot be called unfair. However, it is to be stated that an employees dismissal cannot be justified by redundancy if the employee had a scope of redeployment in other sector of the enterprise of the employer or in the enterprise of an associate of the employer. Thus to conclude, it can be stated that there are several criteria which are to be taken into consideration by the Fair Work Commission in identifying whether an employee was dismissed unfairly. It is important to state that there are several criteria for the employees to prove that they had been terminated harshly. However, the employees if terminated on unfair grounds have the right to seek remedies for the same. The aggrieved parties may apply to the Fair work Commission to seek remedies for Unfair Dismissal by following the procedures as stated by the Fair Work Act 2009. The remedies to be granted to the employees include Reinstatement and compensation. It is important to mention that if the employees had been dismissed due genuine redundancy they can claim that they had been dismissed on unfair grounds. Reference List: Byrne v Australian Airlines Ltd (1995) 185 CLR 410 Davidov, G. and Eshet, E., 2015. Intermediate Approaches to Unfair Dismissal Protection.Industrial Law Journal,44(2), pp.167-193. Fair Work Act 2009 (Cth) Howe, J., 2013. Poles Apart? The Contestation between the Ideas of No Fault Dismissal and Unfair Dismissal for Protecting Job Security.Industrial Law Journal,42(2), pp.122-151. James, N. and Ombudsman, F.W., 2015. Commonwealth of Australia. Johnson case [2003] 1 AC 578 at 539 Legislation.gov.au.(2017).Fair Work Act 2009. [online] Available at: https://www.legislation.gov.au/Details/C2013C00033 [Accessed 22 Nov. 2017]. Malik/Mahmud [1998] AC 20 at 45 Romero case [2014] FCAFC 177; 247 IR 315 Sanders, A., 2014. The law of unfair dismissal and behaviour outside work.Legal Studies,34(2), pp.328-352. Southey, K., 2015. UNFAIR DISMISSAL FOR AUSTRALIAN WORKERS: THE HUNDRED-YEAR JOURNEY.Asian Academy of Management Journal,20(1). Spring v Guardian Assurance plc [1995] 2 AC 296 at 335 Tasmanian Ports Corporation Pty Ltd v Gee[2017] FWCFB 1714 The Sarfaty case (1992) 28 NSWLR 68 UWA v Gray (2009) FCR 346 Van Gramberg, B.E.R.N.A.D.I.N.E., Bamber, G.J., Teicher, J. and Cooper, B.R.I.A.N., 2014. Conflict management in Australia.The Oxford handbook of conflict management in organizations, pp.425-448. Walker v Salvation Army (NSW) Property Trust t/as The Salvation Army Salvos Stores[2017] FWC 32 Welsby v Artis Group Pty Ltd[2016] FWC 2251 West v Holcim (Australia) Pty Ltd[2017] FWC 2346 Westpac Banking Corpn v Wittenberg [2016] FCAFC 33