Managing People Through Change Essay Example | Topics and Well Written Essays - 2500 words

Managing People Through Change - Essay Example However, employees cannot be expected to perform to the highest standard without competent management. Problems such as low employee morale, high turnover rates, and poor performance of job duties can result from inadequate people management. People management, which encompasses both formal performance evaluation and compensation strategies and informal leadership practices and techniques, is one of the determining factors in employee morale and the resulting work quality, as well as determining other factors such as workplace loyalty. While there are many approaches to leadership, from Goleman's basis of leadership in primal intelligence to Wren's group dynamics view (Goethals and Sorensen, 3), all hold in common that leadership is one of the most basic elements of successful people management. However, people management practices in isolation are not enough to ensure the success of the firm or even of the management practice - the ideals that are embodied by the people management practice must be embedded in the corporate culture in order for them to be successful. In essence, people management theory argues that if management implements a specified set of employment as well as work practices, it is going to lead to better performance (Boxall and Purcell 47-70). A lot of the practices such as teamwork, redesigned jobs, employee participation, teamwork as well as communication and information sharing - have been shown to improve performance, but not in a consistent manner (Appelbaum et al. 737-775). Although there are various stakeholders in an organization, the chief strategic goal of any business is higher financial performance or maximization of wealth for the shareholders (Becker and Huselid, 53-101). Financial performance of an organization depends to a large extent on effective operational performance. The operational performance of an organization is a function of people, process and technology. 2.0 Qualities of a Leader A leader influences others by his qualities, viz. confidence, communicative ability, awareness of his impact on others as well as perceptions about the situation and his subordinates. The effect of a leader's background experiences, his communication ability, self-awareness, confidence, his perceptions of subordinates, the situation and the self are shown below (Prasad, 2006, p. 264). SOCIAL VALUES ECONOMIC CONDITIONS LEADER STRUCTURE FOLLOWERS POLITICAL CONSIDERATIONS [Source: Taken from, Prasad LM, (2006) Organizational Behavior, Fig 26.1 p 287] All these factors interact together to determine the leader's ability to influence others. 3.0 Leadership Styles in People Management A fundamental question that needs to be addressed

Crisis Intervention Essay Example for Free

Crisis Intervention Essay PART 2: Application of Crisis Assessment Intervention Skills 1. Tour 1st task of this qn is to comprehend the given case scenario below: Kelvin Lemmy just celebrated their 10th weding anniversary. Lemmy was 39yrs old and expecting her 1st baby. She and her 41yrs old husband Kelvin were eagerly waiting the birth of their child. The child was also the 1st grandchild in the family on both sides At 17 weeks she went to her pediatrician for a scheduled check up. Subsequent to an examination and ultrasound examination, she learnt that the baby had died. She was thrown into a state of shock, simultaneously both angry and sad and cried uncontrollably. You were being called in to talk to Lemmy. 2. U r to use the 6-step crisis intervention model together with other aspects we have covered thus far. 3. The various steps must be clearly indicated in your ans 4. Pay close attention to demonstrating ur understanding of all the elements of the ci model including appropriate use of Triage Assessment System, Worker’s Continuum, Suicide Risk Assessment, The Crisis Trigger and the likely meaning that might be attached to the triggering event 5. When addressing step 4, 5 6 pls keep in mind the distinction between intervention in crisis state, as opposed to intervention when the client is stable and mobile(i. e. counseling). I will need to see that u hav a plan that focuses on immediate action aimed at restoring mobility stability, not one which target long term decision making personal change

The Lives of Dickens Characters :: GCSE English Literature Coursework

The Lives of Dickens' Characters Charles Dickens' literary works are comparable to one another in many ways; plot, setting, and even experiences. His novels remain captivating to his audiences and he draws them in to teach the readers lessons of life. Although each work exists separate from all of the rest, many similarities remain. Throughout the novels, Oliver Twist and Great Expectations, the process of growing up, described by the author, includes the themes of the character's ability to alienate themselves, charity given to the characters and what the money does to their lives, and the differences of good and evil individuals and the effects of their influences. Collectively, these major novels overflow with orphans, adoptive parents, guardians, and failed parent-child relationships. Oliver, the main character in Oliver Twist, must forget about his "infantile past" (Marcus 182) in order to seek "the idyllic future" (Marcus 182). He gets hurled from orphanages to foster parents and so on until he finds himself a portion of the "wrong crowd." The pickpockets take him under their authority and attempt to show him the ropes of the embezzling operation. The orphan adapts well to the swindling lifestyle of Fagin and the boys, and through a series of mischievous choices, authorities apprehend him for stealing (although Dodger was the true felon), and Oliver must live with the consequences. Great Expectations also emphasizes the process of growing up through Pip, the main character. Pip's mother and father passed away while he was young, and he was forced to reside in the house of his older sister and her husband. The boy obtains many idealistic fat hers, including Joe, Magwitch, Jaggers and Pumblechook, but none of these men can give him what he needs from a predecessor. Dickens demonstrates to the reader the consequences that bad parenting has on children. Some children are warped by the "knottiest roots" (Lucas 141). Pip, Estella, and Magwitch are all examples of hurt children. The bitter children dwell on their past, or "what has been forgotten" (Marcus 182), and blame the parents for their sufferings. Other children such as Joe and Herbert survive bad parents and go on with their lives, not letting the history affect the outlook. Personalities in the novels became cut off physically or spiritually from human companionship. Oliver suffers from a sense of estrangement. He fears being abandoned by foster parents and friends, even though the relationships are not healthy for him.

Physics of Projectile Motion in Computer Games :: physics video game computer

Introduction Physics define the rules by which we live our physical existence. Many of us go about our day to day lives without any true understanding of the Laws which govern how we interact with our surroundings. Physics is our way of making sense of the forces which act upon us and shape the way we accomplish even the most menial of tasks. From walking to driving to playing a game of catch, anyone can see physics in action. A computer game programmer must take a special look at the forces at work around us. The programmers who code flight simulators, first person shooters, and similar games, often need to model their virtual world as closely as possible to our own. In this project we will look at the first person combat simulator called "Tribesâ„ ¢", by Dynamix. We will focus mainly on projectile motion, but we will also discuss the challenges the programmers had in computing ranges for projectiles, friction, and momentum. Also touched on, will be how they succeeded and failed in their efforts. Challenges In Tribesâ„ ¢, the programmers had to create an environment for the players. The challenge is to model our real life Laws of physics as accurately as possible. However, programmers are not physicists and it would take a super computer to accurately model all physics in a real world environment. This environment includes a variable gravity. This was important to game play in that the programmers could now make different worlds for the players to fight in. A planet of different mass will obviously have a different gravity. The following equation shows the horizontal range of a projectile, R = (VÂ ²o / g) * sin(2Ø) (Halliday, et al 60-64). Where R is the range, Vo is the initial velocity, g is gravity, and Ø is the angle the projectile is fired at. It is easy to see from the equation that a change in gravity will affect the total horizontal range achievable by a projectile. An interesting note is that a 45 degree angle will provide the maximum horizontal range for the projecti le, no matter what the force of gravity is. (Assuming gravity does not equal zero). We are neglecting air resistance in our calculations, as did the makers of Tribesâ„ ¢. When the programmers did this however, they got some unexpected, yet fun results. While projectile motion was not affected greatly, a person flying in the game could reach insane speeds, as there was no terminal velocity.

How to Write a Book Review

How to Write a Book Review A book review is a description, critical analysis, and an evaluation on the quality, meaning, and significance of a book, not a retelling. It should focus on the book's purpose, content, and authority. A critical book review is not a book report or a summary. It is a reaction paper in which strengths and weaknesses of the material are analyzed. It should include a statement of what the author has tried to do, evaluates how well (in the opinion of the reviewer) the author has succeeded, and presents evidence to support this evaluation. There is no right way to write a book review. Book reviews are highly personal and reflect the opinions of the reviewer. A review can be as short as 50-100 words, or as long as 1500 words, depending on the purpose of the review. The following are standard procedures for writing book reviews; they are suggestions, not formulae that must be used. 1. Write a statement giving essential information about the book: title, author, first copyright date, type of book, general subject matter, special features (maps, color plates, etc. ), price and ISBN. 2. State the author’s purpose in writing the book. Sometimes authors state their purpose in the preface or the first chapter. When they do not, you may arrive at an understanding of the book’s purpose by asking yourself these questions: a. Why did the author write on this subject rather than on some other subject? b. From what point of view is the work written? c. Was the author trying to give information, to explain something technical, to convince the reader of a belief’s validity by dramatizing it in action? d. What is the general field or genre, and how does the book fit into it? (Use outside sources to familiarize yourself with the field, if necessary. Knowledge of the genre means understanding the art form. and how it functions. e. Who is the intended audience? f. What is the author's style? Is it formal or informal? Evaluate the quality of the writing style by using some of the following standards: coherence, clarity, originality, forcefulness, correct use of technical words, conciseness, fullness of development, fluidity. Does it suit the intended audience? g. Scan the Table of Contents, it can help understand how the book is organized and will aid in determining the author's main ideas and how they are developed – chronologically, topically, etc. . How did the book affect you? Were any previous ideas you had on the subject changed, abandoned, or reinforced due to this book? How is the book related to your own course or personal agenda? What personal experiences you've had relate to the subject? h. How well has the book achieved its goal? i. Would you recommend this book or article to others? Why? 3. State the theme and the thesis of the book. a. Theme: The theme is the subject or topic. It is not necessarily the title, and it is usually not expressed in a complete sentence. It expresses a specific phase of the general subject matter. . Thesis: The thesis is an author’s generalization about the theme, the author’s beliefs about something important, the book’s ph ilosophical conclusion, or the proposition the author means to prove. Express it without metaphor or other figurative language, in one declarative sentence. Example Title: We Had it Made General Subject Matter:  Religious Intolerance Theme: The effects of religious intolerance on a small town Thesis: Religious intolerance, a sickness of individuals, contaminates an entire social group 4. Explain the method of development-the way the author supports the thesis. Illustrate your remarks with specific references and quotations. In general, authors tend to use the following methods, exclusively or in combination. a. Description:  The author presents word-pictures of scenes and events by giving specific details that appeal to the five senses, or to the reader’s imagination. Description presents background and setting. Its primary purpose is to help the reader realize, through as many sensuous details as possible, the way things (and people) are, in the episodes being described. b. Narration: The author tells the story of a series of events, usually presented in chronological order. In a novel however, chronological order may be violated for the sake of the plot. The emphasis in narration, in both fiction and non-fiction, is on the events. Narration tells what has happened. Its primary purpose is to tell a story. c. Exposition: The author uses explanation and analysis to present a subject or to clarify an idea. Exposition presents the facts about a subject or an issue as clearly and impartially as possible. Its primary purpose is to explain. d. Argument: The author uses the techniques of persuasion to establish the truth of a statement or to convince the reader of its falsity. The purpose is to persuade the reader to believe something and perhaps to act on that belief. Argument takes sides on an issue. Its primary purpose is to convince. 5. Evaluate the book for interest, accuracy, objectivity, importance, thoroughness, and usefulness to its intended audience. Show whether the author's main arguments are true. Respond to the author's opinions. What do you agree or disagree with? And why? Illustrate whether or not any conclusions drawn are derived logically from the evidence. Explore issues the book raises. What possibilities does the book suggest? What has the author omitted or what problems were left unsolved? What specific points are not convincing? Compare it with other books on similar subjects or other books by the same as well as different authors. Is it only a reworking of earlier books; a refutation of previous positions? Have newly uncovered sources justified a new approach by the author? Comment on parts of particular interest, and point out anything that seems to give the book literary merit. Relate the book to larger issues. 6. Try to find further information about the author – reputation, qualifications, influences, biographical, etc. any information that is relevant to the book being reviewed and that would help to establish the author's authority. Can you discern any connections between the author's philosophy, life experience and the reviewed book? 7. If relevant, make note of the book's format – layout, binding, typography, etc. Are there maps, illustrations? Do they aid understanding? 8. Check t he back matter. Is the index accurate? Check any end notes or footnotes as you read from chapter to chapter. Do they provide important additional information? Do they clarify or extend points made in the body of the text? Check any bibliography the author may provide. What kinds of sources, primary or secondary, appear in the bibliography? How does the author make use of them? Make note of important omissions. 9. Summarize (briefly), analyze, and comment on the book’s content. State your general conclusions. Pay particular attention to the author's concluding chapter. Is the summary convincing? List the principal topics, and briefly summarize the author’s ideas about these topics, main points, and conclusions. Use specific references and quotations to support your statements. If your thesis has been well argued, the conclusion should follow naturally. It can include a final assessment or simply restate your thesis. Do not introduce new material at this point. Some Considerations When Reviewing specific genres: Fiction  (above all, do not give away the story) Character 1. From what sources are the characters drawn? 2. What is the author's attitude toward his characters? 3. Are the characters flat or three-dimensional? 4. Does character development occur? 5. Is character delineation direct or indirect? Theme 1. What is/are the major theme(s)? 2. How are they revealed and developed? 3. Is the theme traditional and familiar, or new and original? 4. Is the theme didactic, psychological, social, entertaining, escapist, etc. in purpose or intent? Plot 1. How are the various elements of plot (eg, introduction, suspense, climax, conclusion) handled? 2. What is the relationship of plot to character delineation? 3. To what extent, and how, is accident employed as a complicating and/or resolving force? 4. What are the elements of mystery and suspense? 5. What other devices of plot complication and resolution are employed? 6. Is there a sub-plot and how is it related to the main plot? 7. Is the plot rimary or secondary to some of the other essential elements of the story (character, setting, style, etc. )? Style 1. What are the â€Å"intellectual qualities† of the writing (e. g. , simplicity, clarity)? 2. What are the â€Å"emotional qualities† of the writing (e. g. , humour, wit, satire)? 3.. What are the â€Å"aesthetic qualities† of the writing (e. g. , harmony, rhythm)? 4. What stylistic devices are employed (e. g. , symbolism, motifs, parody, allegory)? 5. How effective is dialogue? Setting 1. What is the setting and does it play a significant role in the work? 2. Is a sense of atmosphere evoked, and how? . What scenic effects are used and how important and effective are they? 4. Does the setting influence or impinge on the characters and/or plot? Biography 1. Does the book give a â€Å"full-length† picture of the subject? 2. What phases of the subject's life receive greatest treatment and is this treatment justified? 3. What is the point of view of the author? 4. How is the subject matter organized: chronologically, retrospectively, etc.? 5. Is the treatment superficial or does the author show extensive study into the subject's life? 6. What source materials were used in the preparation of the biography? . Is the work documented? 8. Does the author attempt to get at the subject's hidden motives? 9. What important new f acts about the subject's life are revealed in the book? 10. What is the relationship of the subject's career to contemporary history? 11. How does the biography compare with others about the same person? 12. How does it compare with other works by the same author? History and other Nonfiction 1. With what particular subject or period does the book deal? 2. How thorough is the treatment? 3. What were the sources used? 4. Is the account given in broad outline or in detail? 5. Is the style that of reportorial writing, or is there an effort at interpretive writing? 6. What is the point of view or thesis of the author? 7. Is the treatment superficial or profound? 8. For what group is the book intended (textbook, popular, scholarly, etc. )? 9. What part does biographical writing play in the book? 10. Is social history or political history emphasized? 11. Are dates used extensively, and if so, are they used intelligently? 12. Is the book a revision? How does it compare with earlier editions? 13. Are maps, illustrations, charts, etc. used and how are these to be evaluated? Poetry 1. Is this a work of power, originality, individuality? 2. What kind of poetry is under review (epic, lyrical, elegiac, etc. )? 3. What poetical devices have been used (rhyme, rhythm, figures of speech, imagery, etc. ), and to what effect? 4. What is the central concern of the poem and is it effectively expressed? Subject headings used in the catalog: Book reviewing  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Criticism Related books: Book reviewing : a guide to writing book reviews for newspapers, magazines, radio, and television. Boston. The Writer, 1978 PN98. B7 B6 Drewry, John. Writing Book Reviews. Boston: The Writer, 1974. PN98. B7 D7 1974 Teitelbaum, Harry. How to Write Book Reports. New York: Monarch Press, 1975. LB2369 . T4 Miller, Walter James. How to write book reports : — analyzing and evaluating fiction, drama, poetry, and non-fiction  New York. Arco Pub. , 1984. LB2369 . M46 1984 Sources of Book Reviews Book Review Digest  1985+ INDEX Z1219 . C96 Book Review Index  1965+ INDEX Z1035. A1 B6 Contemporary Authors  REFERENCE Z1224 . C5 Related Websites: How to Write a Book Review. Stauffer Library. http://library. queensu. ca/inforef/bookreview/wri. htm Writing Book Reviews. University of Waterloo Library. http://library. uwaterloo. a/libguides/1-12. html ————————————————- How to Write a Book Review. Dalhousie University Libraries. http://www. library. dal. ca/How/Guides/BookReview/ How to Write a Book Review chillibreeze writer  Ã¢â‚¬â€Ã‚  Amy Sengupta A book review is a critical summary of a book. It is an open forum where one analyses and forms an opinion of the writers work. This critical evaluation is not only a useful source of information for the reader, but for those who intend to read the book. The essential step for writing a book review is to read it thoroughly and understand the contents of the book. One has to understand that it is simply not a summary but a critique. The three important steps in writing a book review are: Step 1: Introduction Start by mentioning the essentials like the title of the book, author’s name and relevant publishing information. You should also specify what type of literature it. For example it could be a sociological analysis, a historical book, a purely academic one or a lighter piece of work. Normally, the background about the writer is not required but one should not omit it if it’s of special relevance – for example a refugee writing on refugees. This helps to put the text in a specific context. Step 2: Main Section – Description and Summary The main section ideally consists of two sections – the description and the summary. The description can have excerpts from the book that give valuable insight into the work. However, while reviewing the storyline one has to make sure that the suspense of the story is not given away. Step 3: The Critical Analysis In this section, one has to remember not to critically analyze the entire book but take out those points which are intriguing. For example, if the book is on the urban poor, one can perhaps focus on their politics and culture. Your opinion on the book is crucial here as it shapes your analysis. It helps to provide an insight into the attributes of the book – Is it worth reading, is it interesting and so on. This section should also talk about one’s learning’s from the book and whether it holds an important or interesting message that caught your attention. Chillibreeze's disclaimer: The views and opinions expressed in this article are those of the author(s) and do not reflect the views of Chillibreeze as a company. Chillibreeze has a strict anti-plagiarism policy. Please contact us to report any copyright issues related to this article.

Shouldice Hospital Case Essay Example

Shouldice Hospital Case Essay Example Shouldice Hospital Case Essay Shouldice Hospital Case Essay â€Å"Shouldice hospital, the house that hernias built, is a converted country estate which gives the hospital ‘a country club’ appeal. † A quote from American Medical News Shouldice Hospital in Canada is widely known for one thing-hernia repair! In fact, that is the only operation it performs, and it performs a great many of them. Over the past two decades this small 90-bed hospital has averaged 7,000 operations annually. Last year, it had a record year and performed nearly 7,500 operations. Patients’ ties to Shouldice do not end when they leave the hospital. Every year the gala Hernia Reunion dinner (with  complimentary hernia inspection) draws in excess of 1,000 former patients, some of whom have been attending the event for over 30 years. A number of notable features in Shouldice’s service delivery system contribute to its success. (1) Shouldice accepts only patients with the uncomplicated external hernias, and it uses a superior technique developed for this type of hernia by Dr. Shouldice during World War II. (2) Patients are subject to early ambulation, which promotes healing. (Patients literally walk off the operating table and engage in light exercise throughout  their stay, which lasts only three days) (3) † (p. 8) -â€Å"We don’t have an organization chart. A chart tends to make people think they’re boxed into jobs. † (p. 9) â€Å"The hospital relied entirely on word-of-mouth advertising [†¦]† (p. 10) Shouldice Hospital is focused on good working conditions. It tries to meet people’s needs and makes the hospital as good of a place to work as possible; not only for the patients, but also for the members of the hospital staff: For example surgeons, assistants and nurses were rotated every few days or weeks that they get as much experience as possible. Furthermore each secretary is trained to do another’s work and in an emergency is able to switch to another function immediately. In spite of the fact that the pay scale for the staff is higher than the union scale for comparable jobs, there is also a high bonus pool and profit-sharing plan for all of the employees. The hospital also provides some free services for parents, who accompany their children and also provides free annual checkups for past patients. As a conclusion, Shouldice Hospital is doing well in capacity, service, quality, efficiency and performance. What performance exactly means and how you account performance will be answered in the next question. 2. How do you account for its performance? To answer this question we looked at the literature of performance management and tried to relate the theoretical background with the information provided in the â€Å"Shouldice Hospital Limited† case material. In business literature several different approaches to performance exist. In organizational development, performance can be thought of as actual results vs. desired results. Any discrepancy, where actual is less than desired, could constitute the performance improvement zone. Performance management and improvement can be thought of as a cycle: 1. Performance planning where goals and objectives are established. 2. Performance coaching where a manager intervenes to give feedback and adjust performance. 3. Performance appraisal where individual performance is formally documented and feedback delivered. A performance problem is any gap between desired results and actual results. Performance improvement is any effort targeted at closing the gap between actual results and desired results. Other organizational development definitions are slightly different. The US Governments Office of Personnel Management indicates that performance management consists of a system or process whereby: 1. Work is planned and expectations are set, 2. Performance of work is monitored, 3. Staff ability to perform is developed and enhanced, 4. Performance is rated or measured and the ratings summarized and 5. Top performance is rewarded. In Business performance management literature, performance is described as a set of processes that help businesses discover efficient use of their business units, financial, human and material resources. The definition of  performance in Operational performance management literature focuses on creating methodical and predictable ways to improve business results, or performance, across organizations. The answer to question 1 of our paper focuses on actual performance of the Shouldice hospital and the answers to questions 4, 5 concentrate on ways to improve hospital’s capacity, which covers the operational management approach to performance. Since the case material is short on data as far as desired results are concerned, we will take historical and comparative approach in order to account the performance of Shouldice Hospital. Since the number of operations is considered by us as the most important measure of performance, from historical perspective we can see that performance on this measure has been increasing steadily since year 1982. â€Å"[†¦] the volume of activity continued to increase, reaching a total of 6,850 operations in the 1982 calendar year. † The average number of operations per year reached 7750 (please see question 4 for reference) at the time of interview. Increased number of operations indicates the higher number of patients, which could also indicate a high customer satisfaction level. Since the hospital in not using any marketing strategy to attract clients, and â€Å"relied entirely on word of mouth advertising† , we could presume that satisfaction reached desired results and increased the number of new patients. We could also look at the performance from financial perspective in terms of employees’ salaries â€Å"we try to maintain a pay scale higher than the union scale for comparable jobs in the area† . Ability to pay above average market salaries indicates reaching target revenues and non-existent or minimal gap between desired results and actual results for financial performance. From the facts in Shouldice hospital case material, high involvement of experienced surgeons in coaching and giving feedback in order to maintain high quality of operations could be also observed. â€Å"Training in the Shouldice technique was important because the procedure could not be varied. It was accomplished through direct supervision by one or more of the senior surgeons. The rotation of teams and frequent consultation allowed for an ongoing opportunity to appraise performance and take corrective action. † The above example of training program gives us insight on personnel management at Shouldice hospital. Here we can refer to The US Governments Office of Personnel Management approach to performance. Holistic approach to personnel performance management including planning, monitoring, development, performance evaluation and reward system (â€Å"bonuses to doctors were voted by the board of directors twice a year, depending on profit and performance† ) are integral parts of this approach and all of them, according to data from case material, exist (and are of great importance to Shouldice hospital’s management. We looked at different performance measures and approaches from comparative and historic perspective in order to answer this question. With the data given in the case and the facts outlined in the answer to question 1, we can conclude that in all discussed fields, i. e. customer satisfaction, capacity, financial performance and personnel management Shouldice Hospital is performing with no gap between actual results and desired results. 3. Develop a process flow chart for Shouldice Hospital. In this answer, we will provide a process flow chart for patients, who have had their hernias repaired at Shouldice Hospital. A process flow chart deals with a schematic diagram for describing a process. From our point of view, the real process starts when the patient arrives at Shouldice Hospital. That’s the reason why we do not have the previous steps (filling out questionnaires (1), patients getting their operation dates (2), information logged into the computer (3), patients sent their confirmation cards (4), patients contacted by phone (5)) in our process flow chart. Our process flow chart starts at 1:00-3:00 P. M. , when the patient arrives at Shouldice Hospital with 30 to 34 other patients. As you can see from the process flow chart, after four days, a patient is ready for discharge. This multi-stage process flow chart also includes a lot of buffers , where the patient has to wait till the next step in the process flow chart can be processed. As you can see on the last slide of the process flow chart, there is only limited information available about the third and fourth day. Finally, patients can leave Shouldice Hospital after four days. 4. What is Shouldice Hospital’s capacity? First of all, to make more clear how we interpreted this question, we will give a definition of capacity: â€Å"Capacity means the number/throughput of  units a facility can hold or produce in a period of time. † If we adjust this explanation to the Shouldice case, we assume that the capacity of the hospital is the maximum number of patients who can have an operation during one year. Referring to the case, the peak activity occurs in September when as many as 165 operations per week might be performed. Each year has 52 weeks, however according to the text: â€Å"For many of the same reasons, the hospital closed for two weeks late in December each year,† this means to a total of 50 work weeks each year. Using this information we can assume that the weekly capacity would be 165 patients and the yearly capacity being 8,250 operations. Alternatively, using an average figure of 155 weekly operations performed, this will result in a yearly average capacity of 7,750 operations. Also the capacity could be the number of beds, â€Å"Initially, a 36-bed capacity was create in Thornhill, but after some years of planning, a large wing was added to the house to provide a total capacity of 89-beds. † 5. As Dr. Shouldice, what actions, if any, would you take to expand the hospital’s capacity? In order to create further opportunities to expand the hospital’s capacity, and secure future growth, Dr. Shouldice should expand the hospital’s facilities into the U. S. This notion supported by the case, which states, â€Å"Approximately 42% of all Shouldice patients came from the United States† (p. 3). As of now, these patients are forced to pay â€Å"roughly $200 to $600† (p. 10) to travel to Toronto and patients from the U. S. must now have passports when travelling to Canada. Having a hospital in the U. S.  could reduce some of the costs of travelling for these patients, decrease some of the anxiety of travelling to a foreign country, and make the facilities more accessible for potential patients. Additionally, it would be in the best interest of the hospital to diversify its practice and pursue â€Å"opportunities such as eye surgery, varicose veins, or hemorrhoids† (p. 11). An expansion to the U. S. is an enormous undertaking and since opening a facility in the U. S. is akin to starting anew this is an opportune time for Shouldice Hospital to diversify their opportunities. Based upon Exhibit 4 in the case study, â€Å"it is quite clear that others are trying to emulate us,† which means that Shouldice Hospital is the premier hernia care provider. Now that they have mastered the hernia care and procedures, they must now transfer that knowledge of patient care to other areas of medicine. A staggering 86% of the attendees of the 1983 Shouldice Hospital Annual Reunion responded that Shouldice Hospital most definitely cared for them as a person (Exhibit 3, p. 16). With numbers like these and given Shouldice’s record of accomplishments, it is time for Shouldice to move forward and expand their opportunities. Furthermore, it would be in the best interest of the hospital to patent its world-renowned hernia procedure. Currently the procedure is available to all hospitals who, â€Å"may copy our technique and misapply it or misinform their patients about the use of it. This can result in failure, and we are concerned that the technique will be blamed for the recurrences. † (p. 11). Occurrences such as these can denounce the Shouldice name and can hinder potential patients from looking into Shouldice’s procedures. Shouldice should also look into advertising its procedures in order to increase its capacity. Presently, Shouldice is â€Å"afraid to send out this new brochure [they’ve] put together for fear it will generate too much demand† (p. 11). Advertising, in correlation with the expansion into the U. S. , would greatly increase the awareness of Shouldice because â€Å"the hospital relied entirely on word-of-mouth advertising† (p. 10). With the expansion into the U. S. Shouldice would be able to support the extra demand generated by an advertising campaign. The main types of advertising Shouldice should consider are direct mailings, magazine/newspaper ads, and infomercials. The atmosphere at Shouldice in Toronto is definitely one of a kind. The patients, nurses, and surgeons all have a special bond rarely seen in a hospital, which greatly contributes to the success of Shouldice. In such a quaint working environment, it is important to consider the needs of everyone involved when contemplating facility expansions and work schedule changes. With this in mind, and seeing that there are only a small number of workers, all of whom do not agree on a work schedule change to add Saturdays, Shouldice should continue its present work schedule and not add Saturday operations. Additionally, adding a floor to the current facility would greatly change the working dynamics of the hospital and the quaint environment in which the patients and staff thrive. Adding a new floor and Saturday operations may add revenue but it would take away from all that Shouldice stands for. As the case states, â€Å"‘I’d hate to see the practice split over the issue’† (p. 12). Finally, Shouldice should look into updating and digitalizing its computer systems. This will not only expedite the administrative process but would also lower patients’ waiting time and reduce the stress attributed to masses of paperwork. Patients should be able to fill out all the necessary paperwork one time on a computer and then not be bothered until the procedure. In addition, digitalizing Shouldice’s system would make the brochure sent out to patients (Exhibit 1) a more fluid process. If the form was available on the Internet then there would be faster response times and fewer mistakes. 6. How would you implement changes you propose? Based upon the information provided in the case, it seems as though Dr. Shouldice already has a few places in the U. S. in mind for the hospital (p. 11). We would encourage him to do further research to determine where the best geographic region is according to demand for hernia operations as well as the other opportunities mentioned (eye surgery, varicose veins, or hemorrhoids). Dr. Shouldice must also consider the cost of building a new facility and future revenues derived from greater capacity. In order to protect the surgery that has made the hospital so famous, Dr. Shouldice would need to apply for patents through the provincial government. Moreover, it would be wise for Dr. Shouldice to apply for patents in the U.S. as well before he begins operations there. Taking the necessary steps to obtain a patent would secure Shouldice’s unique surgical procedure and their future success. Although Shouldice currently handles all of their own operations, it is necessary for them to hire an advertising agency to launch a new campaign. An advertising agency has much more experience and knowledge about best practices and with the guidance of the administrative staff they could work together to achieve the desired outcome. Shouldice should consider advertising for their U. S. facility as soon as an expansion plan is completed and for their Toronto facility as soon as the U. S. facility is open. This would promote awareness among U. S. patients prior to the opening of the facility and give the Toronto facility enough time to phase out some existing U. S. patients. A test period of six months should be implemented and if the advertising proves successful then further implementation and changes can be made. The first step Shouldice should take to implement a new computer system is to find a company who provides the services they are looking for. Then the two sides would need to work together to develop computer software that fits the specific needs of Shouldice. Next, employee training would be required to familiarize all necessary parties with the new system. Then, a test period would be needed to ensure that the computer software was working properly and that all employees knew how it worked. Finally, the old system Shouldice currently uses would cease to exist and the new system would be fully implemented.

denmark brief history essays

denmark brief history essays Denmark is a constitutional monarchy in northwestern Europe. It is the southern most of the Scandinavian countries. Copenhagen is Denmarks capital. The country is administratively the country is divided 14 counties and 275 local authorities. Margaret II, who became queen in 1972, currently heads the country. The revised constitution of 1953 provides for succession to the throne in the female line and for a unicameral legislature, called the Folketing. I pick up in history where this class roughly starts in the 1400s. Waldemar IVs (1340-75) daughter Margaret I (1387-1412) was in power and she created the Kalmar union, which included Denmark, Norway, Sweden, the Faeroe Islands, Iceland, Greenland, and part of Finland. In 1520 Sweden and Finland revolted, seceding 1523. In 1448 the house of Oldenburg was established on the throne in the person Christian I and has continued to rule Denmark up to the present day. In 1523 Christian II was driven from the Danish throne, then followed a period of unrest. Unrest was settled when Christian III consolidated his power as king of Denmark. Also in 1523 the Kalmar union was dissolved, but Denmark and Norway remain united. During his reign Denmark was involved in a reformation and Denmark becomes Lutheran. 1618-48, Christian IV intervened in the thirty years war as a champion of Protestantism. Territorial losses were endured as a result of the wars with Sweden. In the 18th century it was a peri od of internal reform, which included the abolition if serfdom and land reforms. In the 19th century Denmark economically prospered despite the many military defeats the country was involved in. In 1849, King Frederick VII authorized a new constitution instituting a representative form of government and a wide range of social and educational reforms took place. In 1866 the Danish constitution was revised, making the upper chamber (Landsting) more powerful than the lower house (Folketing...

Learning German Adjectives and Colors

Learning German Adjectives and Colors German adjectives, like English ones, usually go in front of the noun they modify: der  gute  Mann (the good man), das  große  Haus (the big house/building), die  schà ¶ne  Dame (the pretty lady). Unlike English adjectives, a German adjective in front of a noun has to have an ending (-e  in the examples above). Just what that ending will be depends on several factors, including  gender  (der, die, das) and  case  (nominative, accusative, dative). But most of the time the ending is an -e  or an -en  (in the plural). With  ein-words, the ending varies according to the modified nouns gender (see below). Look at the following table for the adjective endings in the nominative (subject) case: With  definite article  (der, die, das) -  Nominative case Masculineder Femininedie Neuterdas Pluraldie der neu Wagenthe new car die schn Stadtthe beautiful city das alt Autothe old car die neu Bcherthe new books With  indefinite article  (eine, kein, mein) -  Nom. case Masculineein Feminineeine Neuterein Pluralkeine ein neu Wagena new car eine schn Stadta beautiful city ein alt Autoan old car keine neu Bcherno new books Note that with  ein-words, since the article may not tell us the gender of the following noun, the adjective ending often does this instead (-es  Ã‚  das, -er  Ã‚  der; see above). As in English, a German adjective can also come  after  the verb (predicate adjective): Das Haus ist groß. (The house is large.) In such cases, the adjective will have NO ending. Farben (Colors) The German words for colors  usually function as adjectives and take the normal adjective endings (but see exceptions below). In certain situations, colors can also be nouns and are thus capitalized: eine Bluse in  Blau (a blouse in blue); das Blaue  vom Himmel versprechen (to promise heaven and earth, lit., the blue of the heavens). The chart below shows some of the more common colors with sample phrases.  Youll learn that the colors in feeling blue or seeing red may not mean the same thing in German. A black eye in German is blau (blue). Farbe Color Color Phrases with Adjective Endings rot red der rote Wagen (the red car), der Wagen ist rot rosa pink die rosa Rosen (the pink roses)* blau blue ein blaues Auge (a black eye), er ist blau (hes drunk) hell-blau lightblue die hellblaue Bluse (the light blue blouse)** dunkel-blau darkblue die dunkelblaue Bluse (the dark blue blouse) grn green der grne Hut (the green hat) gelb yellow die gelben Seiten (yellow pages), ein gelbes Auto wei white das weie Papier (the white paper) schwarz black der schwarze Koffer (the black suitcase) *Colors ending in -a  (lila, rosa) do not take the normal adjective endings.  Ã‚   **Light or dark colors are preceded by  hell- (light) or  dunkel- (dark), as in  hellgrà ¼n  (light green) or  dunkelgrà ¼n  (dark green).

Public shipping - marine pollution and aspects of marine environment Essay

Public shipping - marine pollution and aspects of marine environment cases - Essay Example It is observed that disputes that arise in territorial waters have seen the port states exercise their special rights on territorial waters and claim to do so for the safety and security in their national interests. Marine environment and pollution is a concern for those holding rights over the territorial waters as well as on high seas, particularly in territorial waters due to its utilization for various activities like fishing, sea-bed activities, etc. The subject of Marine environment and pollution encompasses marine environmental activities and related principles, jurisdiction of port states over ships moving in the territorial region, and other sea-bed activities by the port state. In the particular cases of Corfu Channel and Anglo-Norwegian Fisheries conflict, marine pollution and environmental issues have been raised in the political, economic and historical contexts. It also seen that the port states have a rather diligent advantage over the claimant states in both the cases wherein in Corfu Channel case, the court put the responsibility of proof on the British government which is the claimant (Kazazi, 1995, p 86), while in the case of Anglo-Norwegian Fisheries case, the courts ruled that Norwegian government has the right to exercise its sovereignty on its territorial waters keeping in view the geo-socio custom of the Norwegians in depending on sea waters for fishing as an occupation by a majority (Wise, 1984, p 70). The Corfu Channel case- In 1946, two United Kingdom's ships have been damaged with loss of life of over 40 naval staff in the ships in the territorial waters of Albania. It is alleged by the United Kingdom that Albania has violated International law and had planted or was aware of the presence of mines in its territorial waters which caused loss of life and damage to two of its ships Soumarage and Volage when they struck mines lying under the sea. Earlier in 1944 and 1945 when the British seamen along with a team of international bodies swept the territorial waters of Albania, they had acted according to the law and had promptly informed and taken safety measures to keep the ships away during the minesweeping operations. However, on 15th May 1946 and again on 22nd October 1946, the British ships were shot at by the Norwegian authorities as a defensive attack alleging that the British ships were violating their orders and regulations in the international law to inform the port of their entry. In the second attack, in October, two of the ships that were sent by the British government after informing the Norwegian government of mine sweeping operations with the permission of the International Court of Justice (ICJ), were attacked and they stuck mines that lay under the sea resulting in loss of life and damage to the ships. The British government claimed that the Albanian government deliberately laid mines in the sea to disrupt the innocent passage rights of other nations. Also, since it had sent the two ships for mine sweeping operations, it alleged that Albania had violated the regulations in International law. It cites the articles 3 and 4 of the 8th convention of Hague of 1997 noting that Albania had violated the International law and failed to inform the other nations of the impending dangers due to the mines present in the territoria

Editting Essay Example | Topics and Well Written Essays - 1000 words

Editting - Essay Example Instead, the continued thriving of consumerism is due to our own innate needs, desires and aspirations. The article by Randall Patterson titled ‘Profiles in Splurging’ complements Twitchell’s core thesis. This essay will qualify the aforementioned working thesis by considering all the facts and arguments presented in these two articles. To a great extent, the claim in the working thesis can be viewed as a logical one and there is evidence all around us that validates and supports it. The acquisition of property and goods is often used as a hallmark of success where the ones who have the â€Å"best†, â€Å"biggest† or â€Å"most† of something are considered most successful. To appreciate that, one only needs to observe the mass media, especially television, magazines as well as online polls. Every year Forbes comes out with a list of the richest in the world. There are surveys to show, for instance which footballer owns the biggest car and art enthusiasts and collectors often strive to have the most extensive collection of paintings, books and many other ostentatious goods. For example Bill Gates is ranked as the richest man in the world, this ranking being based on our perception of money as an indirect endorsement for the man as the most successful businessman alive. These measurements do not take into account what he has achieved, how many people he has helped or even how happy he is. All that counts are the possessions he has accumulated. Thus the rest of America works tirelessly to acquire as much as they can and often forgetting to enjoy them since their primary goal is to be viewed as successful in their circles. The most direct route to that is to buy and flaunt. It is as if most Americans would pick money over happiness if they had a chance. Twitchell is not blind to the obvious flaws of consumerist culture. Going by the centrality that society offers material possessions it would then appear that the poor lack meaning and inevitably

The Role Of Cultural Policy On Organisational Management Dissertation

The Role Of Cultural Policy On Organisational Management - Dissertation Example The study will seek to determine the effects of cultural policy within an organization. The utilization of an exploratory design enables the research to conduct research and gather raw information from the identified sources. This will be fundamental in opening up the direction for further research within the field by other researchers. Different data collection methods will be utilized in collecting qualitative data, which will be utilized in making recommendations within the research. Primary data will be collected through interviews and questionnaires sent to individuals who will be selected through the utilization of random sampling methods. These questionnaires will contain both closed and open-ended questions which will be utilized in the collection of qualitative data. Secondary data will be collected from existing literature and published material from research conducted by other researchers within the same field of study. This information will be fundamental in providing gui delines for establishing the findings of the research. Qualitative approaches to data analysis will be utilized in seeking to analyze the collected data. Iteration will be continuously utilized during the data collection period in seeking to ensure the analysis process becomes simplified and reduce the data analysis time. After the interim data analysis, memoing of the data contained within the filled questionnaire will be performed in seeking to summarise the information contained within the data.

Names are rigid designators so the description theory of names is Essay

Names are rigid designators so the description theory of names is wrong - Essay Example Some of the contributors to the development of this theory' is attributed to Kripke, Putnam and Wettstein. According to Kripke, proper names and definite descriptions are designators. That is, in every possible world they designate the same object. Kripke distinguishes the meaning of a designator and the way its reference is determined. Then he puts forth his causal theory of naming: initially, the reference of a name is fixed by some operation such as description then the name is passed from link to link. A name is not identified by a set of unique properties satisfied by the referent: the speaker may have erroneous beliefs about those properties or they may not be unique. The name is passed to the speaker by tradition from link to link. Kripke rejects the view that either proper or common nouns are associated with properties that serve to select what they are referring to. Both proper and common names have a referent. The property cannot determine the reference as the object might not have that property in all worlds. For example, gold might not be yellow in all worlds. Kripke's causal theory of names assumes that names are linked to their referents through a casual chain. A term applies directly to an object via a connection that was set in place by the initial naming of the object. A nonrigid designator is a term that changes its referent across possible worlds. The Nature of Names Consider, for example, a Biology class out on a field trip. Walking in the woods, the professor asks the students to identify the plants that they encounter. A student is asked to identify a plant. Seeing that the plant has thorns, has red flowers that are well known to be a symbol of love and lives in the wilderness, the student names the plant as a Wild Rose. Thus, the naming was based on descriptions that were learned and passed on to the student. Can we therefore say that naming, specifically proper names, are based on descriptions That is, is the Old Theory essentially correct In this paper we, argue that naming is not essentially descriptive but is actually an exercise of designating rigidly. Nevertheless, in this paper, we also argue that naming does have some degree of descriptive being. Naming Without Conceptualization In this philosophical argument, we find that there is a need to use real world examples to do away with the abstractions and complications that a discussion such as this would entail. The unifying string of this paper's argument is that a person could refer to an object by indicating its name without actually knowing the descriptions of the object that he doesn't have a concept of - no knowledge of any descriptions or whatsoever that may give the person naming an idea of the object/person being named. It would then follow that it is possible to name an object without substantial conceptualization. If it is possible to name objects without such conceptualization, then a theory of the meaning of names should not be secluded to such elements. Note that we use the word secluded. By conceptualization,

The Impact of Steady Increase in the Interest Rate in the UK Coursework

The Impact of Steady Increase in the Interest Rate in the UK - Coursework Example These effects caused by a low inflation, low interest, but highly tax economy are the outcomes that are current and continuing to thwart economic competitiveness and equilibrium across the UK manufacturing base. This assignment, therefore, seeks to consider some of the reasons for the causes and effect of an increase in interest rates that are now providing causal effects across the economy. In particular the economy of the USA, that has been a focus of concern across financial sector industries in the UK. Commenting on the effect that world interest rates have on domestic interest rates, Mr King said that: â€Å"We look at the balance between demand and supply, we ask ourselves what goes into that balance and there is no doubt that what is happening in the rest of the world is a key input into that assessment. However, the way in which overseas interest rate changes affect our judgment is solely as an input into that judgment.† â€Å"†¦all central banks are very clearly focused on meeting their own price stability objectives. Of course, they take the rest of the world into account, but they do not say ‘Oh gosh, Jean-Claude has put up interest rates, perhaps we ought to keep up with him’; it is not like that† (House of Lords 2006 p.10). Therefore, the economics of equilibrium is a force that has to be recounted in that the elasticity of the economy is a crucial aspect of financial housekeeping in all World economies and despite the fact, an economy must predominately consider its own fiscal policies, rather than being affected by other economic decisions.

Names are rigid designators so the description theory of names is Essay

Names are rigid designators so the description theory of names is wrong - Essay Example Some of the contributors to the development of this theory' is attributed to Kripke, Putnam and Wettstein. According to Kripke, proper names and definite descriptions are designators. That is, in every possible world they designate the same object. Kripke distinguishes the meaning of a designator and the way its reference is determined. Then he puts forth his causal theory of naming: initially, the reference of a name is fixed by some operation such as description then the name is passed from link to link. A name is not identified by a set of unique properties satisfied by the referent: the speaker may have erroneous beliefs about those properties or they may not be unique. The name is passed to the speaker by tradition from link to link. Kripke rejects the view that either proper or common nouns are associated with properties that serve to select what they are referring to. Both proper and common names have a referent. The property cannot determine the reference as the object might not have that property in all worlds. For example, gold might not be yellow in all worlds. Kripke's causal theory of names assumes that names are linked to their referents through a casual chain. A term applies directly to an object via a connection that was set in place by the initial naming of the object. A nonrigid designator is a term that changes its referent across possible worlds. The Nature of Names Consider, for example, a Biology class out on a field trip. Walking in the woods, the professor asks the students to identify the plants that they encounter. A student is asked to identify a plant. Seeing that the plant has thorns, has red flowers that are well known to be a symbol of love and lives in the wilderness, the student names the plant as a Wild Rose. Thus, the naming was based on descriptions that were learned and passed on to the student. Can we therefore say that naming, specifically proper names, are based on descriptions That is, is the Old Theory essentially correct In this paper we, argue that naming is not essentially descriptive but is actually an exercise of designating rigidly. Nevertheless, in this paper, we also argue that naming does have some degree of descriptive being. Naming Without Conceptualization In this philosophical argument, we find that there is a need to use real world examples to do away with the abstractions and complications that a discussion such as this would entail. The unifying string of this paper's argument is that a person could refer to an object by indicating its name without actually knowing the descriptions of the object that he doesn't have a concept of - no knowledge of any descriptions or whatsoever that may give the person naming an idea of the object/person being named. It would then follow that it is possible to name an object without substantial conceptualization. If it is possible to name objects without such conceptualization, then a theory of the meaning of names should not be secluded to such elements. Note that we use the word secluded. By conceptualization,

Evaluate the Financial Performance of a Business Assignment

Evaluate the Financial Performance of a Business - Assignment Example Balance sheet Income statement and Cash flow statement. These are the basic statements normally prepared by profit-oriented corporations. These statements help in knowing the profitability and financial soundness of the business concern. These are prepared at the end of a given period of time. Financial statements are used as an important tool to communicate the financial information to parties outside the organization (such as investors, creditors, and other external decisions makers). The Balance Sheet; The purpose of preparing balance sheet is to report the financial position (amount of assets, liabilities, and shareholders’ equity) of a firm during a particular period of time. A balance sheet contains complete information about assets, liabilities, and shareholders’ equity of the company. Assets; Assets are things which have economic value and that which are owned by the company. It include tangible asset, such as plants, trucks, equipment, and inventory. It also in cludes intangible asset, such as trademarks and patents. Cash itself is an asset. Tangible asset can be divided into two, Current asset and fixed asset. Current asset represent the company’s liquidity. This is where companies list all of the stuff which can be converted into cash in a short period of time, usually a year or less (Kennon 2012). Fixed asset is an asset held with the intention of being used for the purpose of producing or providing goods or services, and it is not meant for sale in the normal course of business (Accounting for Fixed Assets n.d). Liabilities: Liabilities include all kind of obligation that a company have. The term liabilities mean the amount of money that a company owes to others. Shareholders’ equity; It is also called capital or net worth. The following formula summarizes what a balance sheet shows: ASSETS = LIABILITIES + SHAREHOLDERS'EQUITY Income Statements; Income statement is a statement which shows the revenue that earned by the com pany during a specific period of time (usually for a year or some portion of a year Income statement also shows the expenses, and the cost associated with the earning of revenue. Income statement also gives information regarding how much the company earned or lost over a period of time. This statement helps to calculate earnings per share (EPS), and it also tells how much money shareholders would get, if the company decides to distribute the whole earnings of the company. Income statement can be also called the statement of operation, or statement of earnings. Statements of Cash Flow; A cash flow statement is a statement that contains a detailed report regarding the company’s inflows and outflows of cash. Cash flow statement is helpful in knowing the net increase or decrease in cash for the period. It is prepared by using the information and reports in the company’s balance sheet and income statement. Cash flow statement is helpful in recognizing the, changes in cash b alance(increase or decrease) sources of cash uses of cash There are three parts included in the cash flow statement. They are (1)  operating activities; (2)  investing activities; and (3)  financing activities. 2. Compare appropriate formats of financial statements for different types of business The financial statements explain from where a company's funds come from, where it goes and where it is at present. â€Å"Owners and CEOs use these statements to manage a business, bankers to check its creditworthiness, and investors to

EC Defense Essay Example for Free

EC Defense Essay Introduction Public security of Member States has long been on the agenda of the EC, which has culminated in the establishment of a European Defence Market to â€Å"support the Council and the Member States in their effort to improve the EUs defence capabilities in the area of crisis management and to further The European Security and Defence Policy.†[1] The EU also established a programme for countering illegal trafficking of arms.[2] However, national safety and defence has to do with nationalism and state sovereignty. It is doubtful whether a state can feel itself to be independent without being in control of its own defence. It has often been the case that regulations made by the European Community (EC or the Community) regarding trade and citizens’ movement within the territory have on occasion led to the discomfort of several Member States. The Treaty of Maastricht states that one of the major tasks of this supranational organisation is to establish a â€Å"common market† which promotes â€Å"convergence of economic performance†[3]. The Treaty objectives are largely realised through trade, and public procurement Directives, competition and Merger Regulations also exist to maintain the uniformity of trade on the European Common Market. Yet it might not be immediately obvious why documents governing trade, competition, and mergers would become a mechanism that regulates a country’s ability to defend itself. [4]   However, this has been an object of concern to EC Member States and has sparked a proliferation of legal literature discussing the extent to which this is (or has been) possible. An important part of national security and defence is to obtain up-to-date arms and other equipment necessary for the running of the military and constabulary forces as well as other departments responsible for State security. As no country produces all the products it needs for its defence, the balance must be acquired through trade with other countries. The purpose of this essay is therefore to explore the effect of the EU trade regulation of competition and mergers on the defence industries of Member States. It will assess these laws’ control over the means through which Member States are able to acquire the equipment necessary for national defence. Mergers, Trust, Subsidies, and Procurement Directives One of the duties of the European Commission is to stand as guardian of the Treaty that established the EC. Free trade on the common market is one of the major provisions of that Treaty, and competition within the EU is threatened in the presence of cartels or whenever mergers occur. These types of activities are subject to a substantive Competition Test, which gives the Commission the right to intervene wherever a merger occurs that is hostile to healthy competition as it regards trade on the European Common Market. All scenarios that follow mergers and that fail the test (including the existence of oligopolies) are subject to the scrutiny and handling of the European Commission and to possible escalation to the level of the European Court of Justice (ECJ).[5] Mergers have much to do with competition. When companies merge or have an understanding or trust they behave more and more like monopolies, oligopolies or cartels. Government subsidies and laws that regulate the purchases of nationals from a particular company often have the effect of behave like mergers and trusts. However, the government might, for defence purposes, see the need to make laws governing the nation’s spending in a certain market. It might also see the need to exclude other nationals or business from bidding on contracts if such bidding is deemed a threat to the nation’s security. Legislation by the Commission of the European Union disallows this kind of law-making on the part of the Member States. The Merger Regulation 4064/89 applies to these situations, and therefore might exercise a significant amount of control over defence. Public procurement is the process by which government bodies acquire equipment and services.[6] This represents about 14% of EU Member States gross domestic product.[7] Rules regarding this come from the EU in the form of Directives which are subsequently adopted by Member States. Public sector contracts, services and supplies are published across the EU, facilitating free trade in these areas as well. Breaches of these rules can be pointed out by the European Commission, and can incur legal action before the European Court of Justice.[8] The laws of the EC make it clear that competition should in no way be hindered, in the pursuit of the objective of good value for money[9]. Mergers and government subsidies are cases in which this might happen. However, there is evidence that where governments sanction mergers of companies that deal with military equipment, the effects of Merger Regulation 4064/89 might be escaped. The creation of Eurocopter and its encouragement by the French and German governments demonstrate this. Although the Commission granted that the merger was governed by the Regulation, it conceded that such a venture was â€Å"compatible with the Single European Market.†[10]   In addition, Article 21 and Court opinions formed as a result of the Aà ©ropatiale-Alenia-de Haviland case allow for Member States to take measures necessary to protect interests considered legitimate, and national security is admitted as part of that group. Therefore, though the EU Commission often does have a significant amount of control over defence industries, certain privileges are granted to the Member States for matters of national security. With soft defence materials the rules change slightly. In such cases, prohibitions of mergers by the Commission are final. If, however, the Commission chooses to allow such a merger, the Member State is at liberty to prohibit it. It has been found that exemption from the Merger Regulation all hard defence materials might be prudent, as mergers would help with competition against non-European countries such as the United States. As it stands, however, the Commission enjoys full control over soft defence (or dual purpose) goods, and tempered control over hard defence materials. With regard to the Directives governing public procurement of equipment and services, the European Commission demonstrates another way in which it can have an impact on Member States’ defence industry. One case finds the Commission applying to the European Court of Justice for a declaration that Belgium had failed to fulfil its directive obligations (with regard to 92/50/EEC), being in breach of the provisions Articles 11(3) and 15(2). Belgium had â€Å"issued a restricted invitation to tender† for the surveillance of its coastal regions by means of aerial photography, and did this without expressly notifying the European Communities via the Official Journal.[11] It is of note that this kind of coastal surveillance can have immense implications for national defence. However, the Commission faulted the Member State for neglecting to perform the necessary publishing measures before executing actions toward procurement of the contracts. The ECJ found it necessary to determine whether the action of the Belgian government was even governed by the Directive in question, considering that much of the contract regarded aerial photography and the Directive mainly deals with architectural, engineering, and landscaping services. The Court’s opinion was that it saw â€Å"no reason to call into question the Belgian Governments assessment that aerial photography accounts for the predominant value of the contract. Accordingly, the contract falls under Annex I B, with the result that the tendering procedure under Community law, under Titles III to VI of Directive 92/50, does not have to be followed.†[12] Here the Member state was granted autonomy in that sphere of defence. However, had the contracts involved a slightly different type of service, the Commission might have been awarded the case. Trade Laws and Defence Certain of the EC Articles, namely 30 (ex 36), 39(3) (ex 48), 58(1) (b) (ex 73d), (81)(1), 226, 296 (ex 223), and 297 (ex 224) deal explicitly with issues of trade and competition that concur with those of national security, and offer ways in which the Member States can attend to their national interest where they might conflict with the terms of the Treaty. However, some of the articles are equivocally worded such that they allow for sometimes opposing interpretations. These articles lead to uncertainty with regard to the provisions of Treaty as well as to how the European Court of Justice would rule in certain situations. Therefore, it is unclear exactly how Member-State sovereignty is affected by the Treaty, since certain controversies have arisen because to some extent the Treaty has touched the industries that deal in the trade of materials necessary for national defence. Articles 28 and 29 of the EC Treaty agreement ban restrictions on the quantities of goods that can be imported or exported by the Member States. However, article 30 states that such restriction â€Å"shall not preclude prohibitions or restrictions on imports, exports, or goods in transit justified on grounds of [†¦] public security.† This grants Member States the ability to derogate from the regular stipulations of the treaty should the goods in question pose a threat to public security. Clearly in this case, although the treaty is apt to regulate areas of the defence industry, the articles make way for the countries to be free from its influence in that regard. In fact, in June of 2003, the European Union adopted a Common Position requiring that Member States enact â€Å"ad hoc† legislation to regulate the activities of arms brokers.[13] However, the use of the word â€Å"require† indicates that the power to act in that way was conferred upon the state by an organisation in whose possession the power had rested before. It also implies that to some degree power still rests in the hands of that body. A closer look at EC Article 30 supports this idea. It reads: â€Å"Such prohibitions or restrictions shall not, however, constitute a means of arbitrary discrimination or a disguised restriction on trade between Member States.† This implies that any Member State that wishes to enact laws affecting the defence industry for the purpose of protecting their interests must do so for specific and justifiable reasons. Indeed, the use of the term ad hoc in the 2003 EU position on arms brokering indicates that the control that Member States are granted over their defence market laws is not a general one, but one that materialises only under extenuating circumstances. The Irish case involving Campus Oil is an interesting example. The Irish requirement that 35% of all oil and petroleum products be purchased from the national refinery constituted a case of according an unnatural advantage to a supplier on the Common Market. This was done to protect the Irish economy and to scaffold the company, but might be considered a matter of defence since such military equipment as tankers would require fuel from this national refinery in the event of a national emergency. It was therefore crucial for the refinery to stay in business. The Court saw this necessity, and allowed the national requirement to remain in place.[14] What this case demonstrates is that the European Community law regimes on trade, competition, mergers and the like do have the power to regulate the laws that regard the defence industry. Though the EC laws cited do not relate specifically to defence, the surveillance of a coastline or the protection of a State’s leading energy company can have immense implications for national security. These laws were enacted to combat that effect, and the EC law was able to call that Member State law into question. It, however, did ultimately grant leave to the Member States because of the delicate nature of the situation. Competition and Defence The EC Treaty article that concerns the distortion of competition exists to prevent scenarios in which monopolies could arise in the marketing of certain military goods and/or to certain areas. Articles 85 and 86 regulate situations to ensure that a firm or other venture which has a comparative advantage in the market does not in any way use that advantage to disrupt competition. As far as the Articles allow derogation from this rule, it is not clear whether private companies are able to claim that the provisions of the Articles apply to their situations. However, for derogation to be possible, such benefits as economic progress for both companies and consumers must be proven, and neither indispensable restrictions nor the elimination of competition for the products involved should result from the mergers. One aspect of the GEC-Siemens v. Plessey case concerned whether a company licensed to distribute arms has a right to award sub-licences. The Commission’s opinion on the subject was that only Member States are allowed to invoke article 296b[15]. Therefore, as far as private undertakings concerning military products are involved in the market, competition and free trade are to be assumed to govern military defence equipment.[16] With regard to resolving whether dual-use goods fall under the jurisdiction of the Treaty, there exists a list drawn up by the European Community in 1958.[17] Yet though it has not been officially published, it is now in the public domain. On it is contained traditional types of military equipment, such as tankers and other types of typically defence-oriented products. If this list were considered as containing all the items that are to be excluded from the jurisdiction of the Commission, then it would be clearer how far the EU laws govern the defence industries of Member States. Because goods that can be used both civilly and militarily are not present on the list, it would become clear that dual-use goods should fall solely under the jurisdiction of the Treaty. Though the list has been considered outdated by many, upon close consideration it can be found that many of the newer military equipment can be covered by the broad terms used in the list[18]. If, therefore, the list is to be considered exhaustive, it leads to the conclusion that dual-use goods are not covered by Article 296 and are therefore under the jurisdiction of the Commission. In such cases where dual-use goods are being traded for military purposes, then, the Commission would have some amount of control over the defence industry of the Member State in question. Recently the European Commission has sent forth a Communication[19] on the issue of the interrelatedness of civil, market and defence policies. The purpose of the Communication document is to promote and enhance more efficient spending on defence, to maintain competition in the defence industry, as well as to uphold fairness and ethics in the trade of defence materials. Long has the issue of European defence hung in limbo because of the problematic nature of defence collaboration among Member States. Such situations usually have resulted in encroachment upon the sovereignty of each state. The aims of the Communication are set to be effected through the monitoring of industries related to defence. This activity by the Commission is supported by EC Treaty Art. 296. Through this measure, the EC proposes to regulate licensing, delivery, certification, and other things which have caused arms-trade problems at the borders within the European Community. Beyond this, the EC recognises the importance of competition to the creation of defence sector that does not harm the common market—a defence market that is as similar as possible to the market that exists for non-military goods.   Article 296 has been thought of as a prime obstacle to the European defence market integration, though the European Parliament believes that this article does allow for integration if the Member States cooperate.[20] This article gives states the right to take â€Å"such measures as it considers necessary† to protect its own security interests as far as these concern the procurement of arms and other military equipment. It further stipulates that any action implemented ought not to impair the functioning of the market as far as it concerns goods that are not explicitly military related. It is here that much confusion enters concerning the extent to which the European Community laws govern the defence industry, as demonstrated in the cases of Werner and Leifer.[21] Arrowsmith notes that the importance of the Treaty is largely manifest in actions that lie â€Å"below the thresholds† of the Member state legislation.[22] These states are, according to EC 296, clearly in charge of the trade of expressly military commodities. However, which body shall be in charge of regulating those goods that may be used for both civil and military purposes (dual-use goods) remains in question. Koutrakos reminds us that the Common Commercial Policy established in EC 113 grants exclusive competency to the Community itself. Without this competency in the hands of the EC, the Member States might be inclined to act in a way contrary to the intentions of the Community and create mistrust among the members.[23] In cases where the goods in question are military in nature and a Member State wishes to derogate from the terms of the Treaty, the effects of doing so are subject to a proportionality test. This test ascertains that â€Å"no other measure, less restrictive from the point of view of the free movement of goods, capable of achieving the same objective† could have been performed in its place. The measure must also achieve a maximum amount of good for the Member State with the most minimal of adverse effects on the Community as a whole.[24] Moreover, the provisions of Article 296 do not automatically apply to any country as it regards military security. This article has to be invoked by any party that perceives the necessity to curtail or otherwise regulate the trade of defence products. In that case, the state must also be prepared to offer reasons why such action is necessary, as the burden of proof lies on that state. The EC Court then has the right to intensely scrutinise the actions and motives of the Member state that chooses to derogate from the provision of the Treaty via Article 296. It also has the power to demand that it change its policy back to that of the EC if the motives prove unethical or the reasons inadequate. One such case is the Commission vs. Spain[25], in which the Spanish government had enacted laws exempting from the value-added tax (VAT) exports and transfers of military goods within the Community and to third countries. The argument by the Spanish government was that the measure was necessary for the health of the defence industry, and that such a measure was protected under the provisions of EC 296(1)(b). The Community itself invoked EC 226, which gives the Commission the right to give an opinion on any matter in which it considers that the state has not complied with the terms of the Treaty.[26] The Court ruled that any interpretation of Article 296 should be a limited one. So that where the wording of the article gives the apparent idea that all measures considered necessary by the Member States are viable, the Court emphasises that the states must be able to prove the necessity of those actions in order for them to go unchecked. In this way, Spain was forced to change its policy, and the EC law demonstrated a significant amount of control over the defence industry of Member States. Yet the Spanish derogation was a frivolous attempt, and represented what might be seen as a much lower level of scrutiny by the Court than other cases might. Other states with much more dire cases could conceivably be granted much more autonomy with regard to the regulation of their own portion of the defence market.   The Member States have usually interpreted this article (EC 296) to mean that the exemption of defence material from the terms of the Treaty occurred automatically. On the other hand, the Community has held that any derogation by Member States must be according to strict rules testable by the aforementioned proportionality test. This would therefore mean that it is not only in the case of Spain’s obviously opportunistic case, but in all cases that â€Å"the Treaty would in general apply to hard defence material and [†¦] the Community has jurisdiction over these products unless a Member State can prove the existence of a situation justifying derogation from the regime.†[27] Other complications stem from the second part of Article EC 296(1)(b). This reads, â€Å"Such measures shall not adversely affect the conditions of competition in the common market regarding products which are not intended for specifically military purposes.† In the case between the Republic of Portugal and the Commission,[28] it was held by the Portuguese government that during the privatisation of the company Cimpor-Cimentos, no buyer would be able to acquire rights amounting to more than 10% of the shares. This privilege was reserved only for the Portuguese government. The Commissioners brought this government to the Court because its actions had in their view breached the EC laws against interference with competition. The Commission did acknowledge, however, that had the Portuguese law been concerned with matters of national security, an exception would have been made for the case. However, even in a Portuguese appeal to the Court, the opinion given by Advocate General Tizzano was that the appeal be rejected on the grounds that the action of that government served to impede competition on the European market. Therefore, though this case demonstrates that the ECJ clearly has the authority to force the compliance of Member States on questions of competition, it does sometimes refrain from this if/when defence equipment is involved. The Italian case C-423/98, Alfredo Albore [2000] ECR I-5965 concerned the right of any EU citizen to purchase land in any Member State. The Italian government made it illegal for the German citizen to purchase land declared â€Å"of military importance† to the country. Though this land, not being an expressly military commodity, does for that reason fall under the jurisdiction of the Treaty, the Court decided to allow the Italians derogation through the invocation of Article 296 and the declaration of the land a matter of national defence. Conclusion Some goods that are used by civilians and that can also be used for military purposes are regulated by the Commission. In other situations where countries accord merger rights or subsidies to certain business for military purposes, the Commission has a right to intervene and in those situations can be seen as regulating the country’s defence industry. Goods and services that are considered of military importance to a country may not always be explicitly military or differentiable from goods/services designated for civilian use. In those cases where the Commission has jurisdiction, the right is theirs to allow or prohibit the actions of a Member State government. The Treaties, Procurement Directives, and Merger Regulations of the European Community function in such a way as to promote a healthy market economy in which no producer or country has an unfair advantage with regard to the manufacture or sale of its product. The nature of the defence industry dictates that its functions often come under the regulations of the European Community, and this often indicates the possibility of national security problems for Member States. Because of this, several of the articles in these treaties/regulations allow for derogation from their provisions. Yet, in many cases this allowance has proven equivocal to the point where the European Court of Justice has had to become involved. The European Commission works hard to devise a method of regulation that accounts for the security of the individual states while maintaining the freedom of the Common Market; but as yet, where competition and merger control concerns public procurement and trade of dual-use goods, the EC still exercises, to a significant extent, control over the defence industry of its Member States. References Anders, Holger. (2004). â€Å"Controlling arms brokering: next steps for EU Member States.†   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   GRIP p6. Arrowsmith, Sue. (1995). The application of the EC Treaty rules to public and utilities    procurement. Public Procurement Law Review. 6.255-280. Arrowsmith, Sue. (2002). The EC procurement directives, national procurement policies,   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   and better governance: the case for a new approach.† 27(1), 3-24. â€Å"Competition: Mergers (Overview).† Europa. Accessed 2 March, 2006.  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   http://europa.eu.int/comm/competition/publications/special/3_merger.pdf   Ã¢â‚¬Å"Commission of the European Communities v Kingdom of Belgium (C-252/01).†   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Official Journal of the European Union. (2003). C 289/3.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   http://europa.eu.int/eur-  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   lex/pri/en/oj/dat/2003/c_289/c_28920031129en00030003.pdf â€Å"Consolidated version of the Treaty establishing the European Community.† (2002).   Ã‚  Ã‚  Ã‚   Official Journal of the European Communities. C 325/33. Eikenberg, Katharina. (2000) â€Å"Article 290 (ex. 223) and external trade in strategic   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   goods.† European Law Review. 25(2), 117-138. Georgopoulos, Aris. (2005). â€Å"Defence procurement and EU law.† European Law Review.   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   30(4), 559-572. Georgopoulos, Aris. (2003). â€Å"Industrial and market issues in European defence: the   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Commission Communication of 2003 on harmonisation and liberalisation of   Ã‚  Ã‚   defence markets.† Public Procurement Law Review. 4.NA82-89. â€Å"Fourth Annual Report on the implementation of the EU Joint Action of 12  July 2002 on   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   the European Unions contribution to combating the   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   destabilising accumulation   Ã‚  Ã‚   and spread of small arms and light weapons (2002/589/CFSP).† (2005). Official   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Journal of the European Communities. C 109, vol. 48.P. 0001 – 0025.      Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   http://europa.eu.int/eur-lex/lex/LexUriServ/LexUriServ.do?uri=CELEX:   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   52005XG0504(01):EN:HTML Koutrakos, Panos. (1998). â€Å"Exports of dual-use goods under the law of the European   Ã‚  Ã‚  Ã‚   Union.† European Law Review. 23(3) 235-251 O’Keeffe, D. Branton, J. (2006). â€Å"State Aid and Public Procurement: A Practical   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Guide.† Hammonds. http://www.hammonds.com/FileServer.aspx?oID=21843 â€Å"Portuguese Republic v Commission of the European Communities (C-42/01).† CVRIA. (2004). http://curia.eu.int/jurisp/cgi-bin/form.pl?lang=en Saggio, Antonio. (1999). â€Å"Association Église de Scientologie de Paris and Scientology International Reserves Trust versus the Republic of France.† Opinion of Advocate   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   General Saggio. CVRIA. http://curia.eu.int/jurisp/cgi-  Ã‚   bin/form.pl?lang=enSubmit=Submitalldocs=alldocsdocj=docjdocop=doco  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   pdocor=docordocjo=docjonumaff=datefs=datefe=nomusuel=domain  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   e=mots=military+arms+goodsresmax=100 Trybus, Martin. (2002). â€Å"The EC Treaty as an instrument of European defence   Ã‚   integration: judicial scrutiny   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   of defence and security exceptions.† Common   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Market Law Review. 39. 1347-1372. Trybus, Martin. (2005). â€Å"A fine balance: free movement and public security in the EC   Ã‚   Treaty.† European Union Law and Defence Integration. Hart: Oxford. Trybus, Martin. (0000). â€Å"European defence procurement: toward a comprehensive   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   approach.† European Public Law. Vol. 4(1). 111-133. Trybus, Martin. (2004). â€Å"The limits of European Community competence for defence.† European Foreign Affairs Review. 9, 189-217. Trybus, Martin. (2000). â€Å"On the application of the EC Treaty to armaments.† European Law Review. 25(6), 663-668. Trybus, Martin. (2002). â€Å"Procurement for the armed forces: balancing security and the    internal market.† European Law Review. 27(6), 692-713. Trybus, Martin. (2000). â€Å"The recent judgement in Commission vs. Spain and the   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   procurement of hard defence material.† Public Procurement Law Review. 4. NA   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   99-103. [1]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Georgopoulos, Aris. (2005). â€Å"Defence procurement and EU law.† European Law Review. 30(4), 559-572. [2]  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Fourth Annual Report on the implementation of the EU Joint Action of 12  July 2002. [3]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Article 2. â€Å"Consolidated version of the Treaty establishing the European Community.† (2002). Official Journal of the European Communities. C. 325/33. [4]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Trybus, Martin. (2004). â€Å"The limits of European Community competence for defence.† European Foreign Affairs Review. 9, 189-217. [5]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   â€Å"Competition: Mergers (Overview).† Europa. http://europa.eu.int/comm/competition/publications/special/3_merger.pdf [6]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Arrowsmith, Sue. (2002). The EC procurement directives, national procurement policies, and better governance: the case for a new approach.† 27(1), 3-24. [7]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Trybus, Martin. (2002). â€Å"Procurement for the armed forces: balancing security and the internal market.† European Law Review. 27(6), 692-713. [8]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   O’Keeffe, D. Branton, J. (2006). â€Å"State Aid and Public Procurement: A Practical Guide.† Hammonds. http://www.hammonds.com/FileServer.aspx?oID=21843 [9]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Arrowsmith, Sue. (2002). The EC procurement directives, national procurement policies, and better governance: the case for a new approach.† 27(1), 3-24. [10]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Trybus, Martin. (0000). â€Å"European defence procurement: toward a comprehensive approach.† European Public Law. Vol. 4(1). 111-133. [11]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   â€Å"Commission of the European Communities v Kingdom of Belgium (C-252/01).† Official Journal of the European Union. (2003). C 289/3. [12]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Ibid. [13]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Anders, Holger. (2004). â€Å"Controlling arms brokering: next steps for EU member states.† GRIP p6. [14]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Trybus, Martin. (2005). â€Å"A fine balance: free movement and public security in the EC Treaty.† European Union Law and Defence Integration. Hart: Oxford. [15]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   â€Å"Any Member State may take such measures as it considers necessary for the protection of the essential interests of its security which are connected with the production of or trade in arms, munitions and war material; such measures shall not adversely affect the conditions of competition in the common market regarding products which are not intended for specifically military purposes.† . â€Å"Consolidated version of the Treaty establishing the European Community.† (2002). Official Journal of the European Communities. C. 325/33. [16]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Trybus, Martin. (0000). â€Å"European defence procurement: toward a comprehensive approach.† European Public Law. Vol. 4(1). 111-133. [17]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Ibid. [18]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Trybus, Martin. (2005). European Union Law and Defence Integration. Hart: Oxford. [19]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Georgopoulos, Aris. (2003). â€Å"Industrial and market issues in European defence: the Commission Communication of 2003 on harmonisation and liberalisation of defence markets.† Public Procurement Law Review. 4.NA82-89. [20]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Ibid. [21]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Eikenberg, Katharina. (2000) â€Å"Article 290 (ex. 223) and external trade in strategic goods.† European Law Review. 25(2), 117-138. [22]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Arrowsmith, Sue. (1995). The application of the EC Treaty rules to public and utilities procurement. Public Procurement Law Review. 6.255-280. [23]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Supra n.2 at 1364. Qtd. in Koutrakos, Panos. (1998). â€Å"Exports of dual-use goods under the law of the European Union.† European Law Review. 23(3) 235-251 [24]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Trybus, Martin. (2002). â€Å"The EC Treaty as an instrument of European defence integration: judicial scrutiny of defence and security exceptions.† Common Market Law Review. 39. 1347-1372. [25]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Trybus, Martin. â€Å"The recent judgement in Commission vs. Spain and the procurement of hard defence material.† 4. NA 99-103. [26]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   â€Å"Consolidated version of the Treaty establishing the European Community.† (2002). Official Journal of the European Communities. C. 325/33. [27]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   Trybus, Martin. â€Å"The recent judgement in Commission vs. Spain and the procurement of hard defence material.† 4. NA 99-103. [28]   Ã‚  Ã‚  Ã‚  Ã‚  Ã‚  Ã‚   â€Å"Portuguese Republic v Commission of the European Communities (C-42/01).† Cvria. (2004).