How do you write an essay
пятница, 28 августа 2020 г.
Essay assignment #1 Example | Topics and Well Written Essays - 500 words
Task #1 - Essay Example His response to the given inquiry sounds unambiguously and carefully, that is ââ¬Å"Absolutely not!â⬠(Phillips, 2010). William D. Phillips recommends a broad conclusion that with an advancement of specialized and logical advancement there are many individuals who don't discover a wonder of extraordinary God and His reality creation as an important clarification of the universe requesting (2010). Such thoughts made God outdated and shield the idea of consistent clarification to every thing happened on the planet. Then again, strict individuals remain a severe thought that science is mixed up. To such an expand religion and science are viewed as ââ¬Å"irreconcilable enemiesâ⬠(Phillips, 2010). William D. Phillips claims that such idea is thoroughly off-base and ludicrous. This researcher attempts to convince us that it is conceivable to keep in your spirit and brain the possibility of God and the importance of science (Phillips, 2010). He views himself as for instance of such individual. He asserts that he is a physicist and he interfaces for his entire life with logical explores and examinations (Phillips, 2010). He manages nature and causes attempts to know how to the nature functions (Phillips, 2010). Besides, he conveys his insight to others and trains them in science. In any case, he convincingly proclaims that he goes to chapel, asks and puts stock in confidence (Phillips, 2010). He makes certain in the presence of God and works with the science. As indicated by such thoughts William D. Phillips conveys two inquiries that he considers to be relevant. He clarifies how he can have confidence in God and why he has faith in God (Phillips, 2010). These two focuses appear to be important for William D. Phillips and his demeanor to religion. The appropriate response of the main inquiry is simple and clear. Phillips remains that have confidence in God doesn't require logical make a difference and legitimate affirmation (Phillips, 2010). He feels that it is essential just to accept with
суббота, 22 августа 2020 г.
Value Management of Construction Projects â⬠MyAssignmenthelp.com
Question: Examine about the Value Management of Construction Projects. Answer: Presentation: Moral direct is all the more firmly identified with the lawful lead despite the fact that they don't generally cover and leave equivocalness over progressively proper activities at some particular conditions. In any case, this vulnerability can be diminished by planning legitimate associations which energize or persuades moral practices. The components which become an integral factor, while taking morals in the building and development ventures are perceivability, reward frameworks and moral preparing programs, which ought to be presented in a positive way (Kelly, Male and Graham 2014). Furthermore, the data and information the board principally centers around the information accessible. It manages the unstructured just as organized figures and realities. Additionally, innovation is profoundly helpful and gainful in this viewpoint. It to a great extent centers around getting, finding, empowering and empowering by making societies, procedures and conditions where the information and data are made or shared (Walker 2015). Separated than these variables, the regular move for the ongoing alumni just as vocation experts is doing post graduate research preparing in building and development. The structure and development the executives courses which are offered in organizations help the understudies in building up their expert contacts just as building their commonsense aptitudes. It as a rule includes field excursions and site visits; in this way, giving the understudies the chance of incorporating hypotheses. The administrative control structure in development the executives majorly affects the exhibitions of Model Predictive Control, which must not be disregarded. Guidelines are viewed as a regularly developing component of current days. Along these lines, for the experts working in some particular enterprises like development, the executives, account and others, guidelines help with forming every single choice (Kelly, Male and Graham 2014). References Kelly, J., Male, S. also, Graham, D., 2014.Value administration of development ventures. John Wiley Sons. Walker, A., 2015.Project administration in development. John Wiley Sons.
пятница, 21 августа 2020 г.
5 Unicorns Of Unique Marketing To Stand Out From Mediocre
5 Unicorns Of Unique Marketing To Stand Out From Mediocre What makes a unicorn, other than the shimmers, rainbows, and single horn? Irregularity. Something you donââ¬â¢t see time and again, if at any point. So with regards to content advertising, what are the unicorns? Whatââ¬â¢s uncommon and elusive? A few clients pondered about arranging one of a kind promoting with their substance schedules. Here isâ how you can locate your own unicorns. 1. One of a kind Marketing Has Originality Inventiveness, the lord of the unicorns. Itââ¬â¢s very uncommon, on the grounds that most substance is subordinate, and thatââ¬â¢s OK to be completely forthright (more on that in a piece). Unique reasoning, with regards to content showcasing, is profoundly transitory. Its termination date is short, since unique thoughts are immediately aped by others urgent for thoughts who at that point flood the specialty with so much equivalence that the first unique is immediately lost. Youââ¬â¢ve seen this at work, where a special thought shows up, and inside a month, everybody is making a case for it. Our own accepted procedures hamper it, since connecting to and contacting influencers is an altogether effective approach to become your own after. Discovering something new and new, as you look through substance promoting blog entries, is uncommon. Something new and new in your specialty is shockingly uncommon. See innovation as unique.All of it is not necessarily the case that inventiveness is the most significant capability for content. Like I stated, utilizing the thoughts of another person to make your own has genuine worth (read here). The greater part of us, myself notwithstanding, expand on a thought of another person. This is almost in every case great and how imagination capacities. However, prizing inventiveness extends into incredible hard working attitude when youââ¬â¢re making that subordinate work. It implies you care enough to expand on a thought, not only repackage it. Again and again, in light of the fact that weââ¬â¢re continually driving ourselves to discover content thoughts, itââ¬â¢s enticing to gather, rephrase, repackage, and scarcely improve somebody elseââ¬â¢s thought. You can be unique regardless of whether youââ¬â¢re expanding on otherââ¬â¢s thoughts. The key is to assemble, not obtain. You can be unique regardless of whether youââ¬â¢re expanding on otherââ¬â¢s thoughts. The key is to manufacture, not borrow.2. Interesting Marketing Backsà Up Its Promises Too many substance advertisers make guarantees. Void ones. We as a whole tip toward this snare, regularly on the grounds that weââ¬â¢re attempting to locate that ideal feature that will make content hang out in a packed field. ââ¬Å"How To Get 50,000 Twitter Followers In A Weekâ⬠ââ¬Å"I Made $100,000 In One Month. You Can, Too.â⬠Honest features are substantially less fascinating, regardless of whether they honestly mirror the substance of the post or the presumable result of the normal peruser who probably won't have the option to reproduce a particular nature of your prosperity (for example an influencer referencing you online to her enormous after) that assumed a major job. ââ¬Å"Get 50 Twitter Followers In A Weekâ⬠ââ¬Å"I Made $2,000 In One Month. You Can Too.â⬠A significant number of your perusers presumably excuse you for the shocking guarantees you make in your features, since they know about those sorts of features. Here and there, weââ¬â¢ve adjusted as perusers and the large guarantees are naturally downsized in our minds. We donââ¬â¢t truly hope to get 50,000 Twitter devotees in a single week, however we do expect a blog entry that will give us data on the best way to get a ton of Twitter supporters rapidly. Not all perusers are so lenient, however. Their dissatisfaction some of the time springs up in remarks as they request to realize more particulars to get it going for them. I get genuinely amped up for a post that vows to convey something sensible, and afterward really thinks of the pragmatic and explicit strides to do as such. Guarantee toâ deliver something reasonable, at that point ensure the contentâ follows through.We must be cautious as substance advertisers to not energetically turn our chance victories as though they were orderly triumphs, and be progressively forthright about our deliberate (and less hot) triumphs. On the off chance that it took your performance blog a year to pull in 4,000 Twitter devotees, there is as yet something your perusers can gain from that. This plays into the following unicorn, that of being real. Abstain from promising what you canââ¬â¢t convey just to get beginning consideration. Abstain from promising what you canââ¬â¢t convey just to get starting consideration. #uniquemarketing3. Genuineness Itââ¬â¢s a hard line to tool, professing to be true yet in addition realizing you have to extend achievement if youââ¬â¢re going to get adherents to purchase what youââ¬â¢re selling. I had a viral blog postâ on my own blog once. There were a few things I gained from it that I imparted to my perusers, including what it feels like, what I followed the wonder back to, and how I oversaw it. I endeavored to analyze the blog postâ find the characteristics that may have added to that virality. In any case, I must be straightforward (and I admitted this to my blog perusers): Iââ¬â¢d been blogging for eleven yearsâ before I at long last had my essence of a true blue viral blog entry. It was so enticing to compose as an expert on viral blog entries, as though I was swinging grand slams consistently, yet that would have been inauthentic. Being a legitimate achievement implies having a considerable lot of disappointments. Offer it all.Iââ¬â¢ve since seen different posts arrive at different degrees of viral achievement, yet I need to be mindful so as to not utilize that as my turn, selling my substance as though I can get that going for my perusers unfailingly. Credibility, that word you hear relentlessly in content showcasing, shrivels under the hot glare of marking. We need our image to be true, however we additionally need it to ooze achievement, so we search for approaches to commend our high focuses and turn the low ones as insignificant workable minutes. You can in any case show your prosperity while legitimately sharing your disappointments without being disparaging. So no. I canââ¬â¢t disclose to you how to compose a viral blog entry, however I can enlighten you regarding the characteristics that have encircled them. Without a doubt. Also, thereââ¬â¢s esteem in that. Being a bona fide achievement implies having a considerable measure of disappointments. Offer everything. 4. Important Unmeasurables Content advertisers love-information. Numbers. Things that can be estimated. Since shrewd choices can be made with those sorts of things. You canââ¬â¢t settle on an educated choice in the event that you donââ¬â¢t have any information to back it up. For the most part. Information is a piece of the tool stash. Itââ¬â¢s not the tool compartment. I can be somewhat of a curmudgeon with regards to information, if just trying to place some rudder into the non-numerical side of the boat to abstain from making an unavoidable whirlpool. And furthermore on the grounds that, for me, numbers donââ¬â¢t trigger thoughts just as other information. Hereââ¬â¢s a messy mystery (and itââ¬â¢s not so much a mystery, since Iââ¬â¢ve admitted to it previously): Iââ¬â¢m not a major numbers individual. Now and then, when I take a gander at a post loaded up with reference charts and disperse plots that work to picture the information somebody painstakingly collected and deciphered, I get taken up with the hues and examples in the genuine diagram and canââ¬â¢t even observe the information behind it. Truly. Information is a piece of the tool stash. Itââ¬â¢s not the tool kit. #uniquemarketingI take a gander at the estimating cup and get diverted by the shade of it rather than the fixing inside. There are significant unmeasurables, those things of worth that wonââ¬â¢t appear in any examination you may gather. While you might not have any desire to go on a hunch for your next large business choice, you ought not disregard it, generally. Over and over again, we get caught in the issue of the bogus situation, that thought that there are just two alternatives: for, or all against. There are multiple choices. Itââ¬â¢s not either/or, yet either/and. Information andâ a premonition. In my psyche, the rundown of what disregarding the information driven way to deal with content showcasing may look like is interminable, however here are a couple of guides to make you think thusly: One person.à One individual may demand a post theme. One individual may state a specific post made a difference. One individual may have questions that need further clarification. The estimation of one of every an information driven world is low; you donââ¬â¢t get a pattern off of only one. In any case, in a people-driven world, one is a serious deal. So donââ¬â¢t disregard the one individual who needs assistance, needs to know more, or poses an inquiry, regardless of whether your bigger information state that isnââ¬â¢t a theme that will support your general traffic. Burnout. Your information might be disclosing to you that composing posts about Topic An all the time is acquiring the merchandise. However, long stretches of investigating and examining each conceivable edge to Topic A has forgotten about you totally consumed. So expound on something you appreciate Topic B-regardless of whether your information canââ¬â¢t back you up with guaranteed achievement. Something else, itââ¬â¢s all work and drudgery. So consider the possibility that it doesnââ¬â¢t get transformations. Itââ¬â¢ll give you a breather and you need that. Keep in mind, youââ¬â¢re not boundâ by information. You donââ¬â¢t serve it; rather, it should serve you. Utilize information, however not to prohibition. There are things you canââ¬â¢t measure that issue, as well. Youââ¬â¢re not boundâ by information. You donââ¬â¢t serve it; rather, it should serve you. #uniquemarketing5. Genuine Language One of my more established posts on this blog managed deciding how much altering was an excess of altering. I worked it out of a battle I was confronting, attempting to locate that ideal point where you tidy up the duplicate however you donââ¬â¢t change the voice of the essayist. Except if thereââ¬â¢s a severe style guideâ in place and the substance makers arenââ¬â¢t truly getting perceived as distinctive individuals, their one of a kind voice ought to be heard and not altered out. This was a fight over pet expressions, word decisions, paragraphical cadence (separating sections into littler ones and causing the duplicate to show up and read rough). Be that as it may
вторник, 26 мая 2020 г.
Lies Youve Been Told About Third Person Point of View Essay Samples
Lies You've Been Told About Third Person Point of View Essay Samples Life, Death, and Third Person Point of View Essay Samples One of the most frequent kinds of third-person is third-person limited. Beyond that it becomes confusing. The way the very first person narrator is relating the story will impact the language used, the duration of sentences, the tone of voice and lots of other things. Ernest Hemingway is really the most renowned case of this technique. Each one of us has a different perspective. You have to decide which point of view you'll utilize to inform your story. It's regarded as the most formal, impartial perspective. For our purposes, however, we will divide third-person viewpoint into three categories. The reply is the fact that it doesn't. Alternately, you can opt to take care of viewpoint like the professional you mean to be. Whichever point of view you choose to use, it's important to be certain you keep things in the right perspective. For instance, you might observe that a first-person perspective may be too limiting because it only presents one particular character's feelings. Introducing Third Person Point of View Essay Samples By putting it in third individual, you're able to list sources, and you're encouraged to achieve that. Since you might anticipate, authors have stretched this concept in a wide range of creative directions previously. When writing in third individual, you've got to be everybody! First person is a kind of writing where the writer says things from their very own personal experience. Keep in mind that unless the essay calls for you to write about yourself, or to directly deal with the reader, stay centered on the topic of the essay and you'll be well on your way to a fantastic bit of writing! It is also helpful to show the goal of your essay. Essays aren't the only types of writing assignments you're very likely for. How can you compose a very good argumentative essay. Generally, however, first-person writing isn't very helpful in writing essays. Always make certain you revise your essay as a way to knock out the demand for use of pronouns in sentences thus developing a formal fashion of writing that is more appropriate. Utilizing third-person writing can produce a huge difference in giving your essay the proper tone. It is not easy to be relatable once you are writing in third individual. A rare kind of first person is the very first person omniscient, where the narrator is a character in the story, but in addition knows the ideas and feelings of all of the other characters. Notice, however, that I said can earn a novel claustrophobic And it is just the very same thing with a novel. A sensible explanation fitting the inner workings of the story's world is normally provided or inferred, unless its glaring absence is an important plot point. When POVs are typical in a genre, it has a tendency to be for a very good reason. Among the biggest is you could only achieve intimacy between the reader and the most important character in a very first person point of view novel. Have her cover this up or attempt to hide it in some manner. So that the detective's sidekick may be the viewpoint character in a number of the chapters, although the detective stays the novel's protagonist. So in a boy-meets-girl novel, as an example, you could Don't be concerned about multiple viewpoint novels at the moment. Both are utilised to provide the writer's individual perspective. A writer employs a specific point of view to tell a particular type of story.
пятница, 15 мая 2020 г.
Overview of the Xiongnu Nomads
Xiongnu was a multi-ethnic nomadic grouping from Central Asia which existed between about 300 BCE and 450 CE. Pronunciation:à SHIONG-nuAlso Knownà As:à Hsiung-nu The Great Wall The Xiongnu were based in what is now Mongolia and frequently raided south into China. They were such a threat that the first Qin Dynasty emperor, Qin Shi Huang, ordered the construction of huge fortifications along the northern border of Chinaââ¬âfortifications that later were expanded into the Great Wall of China. An Ethnic Quandry Scholars have long debated the ethnic identity of the Xiongnu: Were they a Turkic people, Mongolian, Persian, or some mixture? In any case, they were a warrior people to be reckoned with. One ancient Chinese scholar, Sima Qian, wrote in the Records of the Grand Historian that the last emperor of the Xia Dynasty, who ruled sometime around 1600 BCE, was a Xiongnu man. However, it is impossible to prove or disprove this claim. The Han Dynasty Be that as it may, by 129 BCE, the new Han Dynasty decided to declare war against the troublesome Xiongnu. (The Han sought to re-establish trade along the Silk Road to the west and the Xiongnu made this a difficult task.) The balance of power between the two sides shifted over the next few centuries, but the Northern Xiongnu were driven out of Mongolia after the Battle of Ikh Bayan (89 CE), while the Southern Xiongnu were absorbed into Han China. The Plot Thickens Historians believe that the Northern Xiongnu continued west until they reached Europe under a new leader, Attila, and a new name, the Huns.
среда, 6 мая 2020 г.
The Effects of the Cuba Missile Crisis Essay - 1656 Words
The Effects of the Cuba Missile Crisis During the Cuba missile crisis near every newspaper and radio station would talk about how the end of the world on the brink of destruction. Because of this many people around this time lived in fear and felt the world was going to end. The effects of the Cuba missile crisis didnââ¬â¢t just affect the two nations its effects also had major effects on the people of these nations, the world, and the countries themselves. These effects only truly made the world change when it was too late. The effects that the Cuba missile crisis left on the people of these nations consisted of fear, panic, and enough paranoia to scary the entire world. It also affected the world as other counties would do anythingâ⬠¦show more contentâ⬠¦The future generations were effected most of all as the thought of death and propaganda of the red scary drove their parents into a fear life they began to raise paranoid children. These children were forced to practice air raid drills and many others terrify ing thing. Other thing the parentââ¬â¢s paranoia leads to was how so city and family would have bomb shelter at the ready a great example giving by Alice L. George as she talks about how the American began to panic so badly they began to build bomb shelters in their homes and how they were prepared to stay within these shelters for ââ¬Å"days or weeksâ⬠(George 22). As this shows the parents paranoia the children were just pass these skill of panicking and living in fear all the time as they would practice these drills at home and school and vice versa this end turn would cause fear to anyone. These thought of nuclear wasteland where spreading threw out the youth fast as most kid within the 1960ââ¬â¢s believe that the end of the world or nuclear end was on the way as no one could stop it. These future kids and people of these nations werenââ¬â¢t just the only thing that the countries had to deal with when it affected their counties but also the world and it mass chao s to this new news of coming so close to war. The Effect on the World! The effects on the world were most crucial as this was like the beta wolfs waiting for the new alpha wolf to be choosing. So the weaker countries toShow MoreRelatedThe Cuban Missile Crisis - Secret Meetings Involving Malpractices And Miscommunication873 Words à |à 4 PagesThe Cuban Missile Crisis Secret meetings involving malpractices and miscommunication will lead to global destruction. Senior Enlisted Leaders will understand the importance of acquiring proper intelligence through the right channels before making decisions that will impact mankind around the world. This essay will discuss the history, evolution, and the effects of the Cuban Missile Crisis. History On October of 1962 there was a big misunderstanding between the dictator of the Union Soviet andRead MoreThe Cuban Missile Crisis Essay1292 Words à |à 6 Pagesinevitable to the world, it was the first time nuclear war was hanging on a thread. The Cuban Missile Crisis presented a threat to the world, in which the USSR planted nuclear missiles on Cuba. Americaââ¬â¢s response was to threaten launching nuclear missiles at the Russians. This incident launched the world into a new time, which presented nuclear weapons as a source of power. The incident of the Cuban Missile Crisis still connects with us today because the power nuclear weapons present, which providesRead MoreThe Cuban Missile Crisis The World On The Edge Of Its Seat1315 Words à |à 6 Pagesââ¬Å"Weââ¬â¢re eyeball to eyeball, and I think the other fellow just blinkedâ⬠(Dean Rusk). The Cuban Missile Crisis put the world on the edge of its seat, and was the closest humanity has ever gotten to full-scale nuclear war. Even though the event lasted a mere two weeks (from October 14-24, 1962), it played a significant role in international politics, and its effects can still be seen today. The Cuban Missile Crisis is significant to current international relations because it proved the importance of theRead MoreCuban Missile Impact On The World Of The Cold War902 Words à |à 4 PagesCuban Missile War Is Cuban communism the beginning of the Cold War? Could the Cuban Missile Crisis end in the world devastation? According to freedictionary.com, nuclear war is ââ¬Å"war in which nuclear weapons are used by both sides. As generally used, the term assumes major use of nuclear weapons by at least two opposing warring states.â⬠The invasion of Cuba by United States caused by the alliances between Cuba and the Soviet Union brought conflict between those countries. The United State tried toRead MoreThe Cuban Missile Crisis : A 13 Day Standoff1726 Words à |à 7 PagesThe Cuban Missile Crisis was a 13 day standoff in Cuba during the Cold War that struck fear into many American people. Joseph Roblat said, ââ¬Å"The most terrifying moment in my life was October 1962, during the cuban missile crisis. I did not know all the facts - we have learned only recently how close we were to war - but I knew enough to make me trembleâ⬠. Missiles were in Cuba, in range of the U.S.. The world has never come so close to being in a full out Nuclear War. If the Soviets launched one ofRead MoreCuban Missile Crisis : A Ten Day Confrontation Between The United States And The Soviet Union 878 Words à |à 4 Pages Will Fain Mr. Shea English 2 Honors 25 January 2016 Cuban Missile Crisis Essay The Cuban Missile Crisis was a thirteen day confrontation between the United States and the Soviet Union in October of 1962. The stand off was over Soviet ballistic missiles deployed in Cuba. The Cuban Missile Crisis was the closest the Cold War ever came to a full out nuclear war. The event was broadcasted on television for the world to see causing a global panic, especially in America. John F. Kennedy announced thatRead MoreThe Realist Perspective of the Cuban Missile Crisis 912 Words à |à 4 Pages The Cuban Missile Crisis lasted two weeks in the midst of the Cold War, and brought the world closer to nuclear war than ever before. In October of 1962 multiple nuclear missiles of the Soviet Unionââ¬â¢ s were discovered in Cuba, a mere 90 miles south of the United States. Given the communist ties between Cuba and the USSR, this poised a considerable threat to our national security. Throughout the 14 days the two leaders, John F. Kennedy and Nikita Khrushchev struggled to clearly understand each othersââ¬ËRead MoreCuban Missile Crisis : The Height Of The Cuban War1307 Words à |à 6 PagesCuban Missile Crisis At the height of the Cuban War, the United States and the Soviet Union risked nuclear confrontation in an event known as the Cuban missile crisis. The Event was the closest the two countries came to a nuclear war. Even though the confrontation lasted a span of 13 days the crisis is considered one of the most fascinating events in American history due to the fact the war could have led to the destruction of the world. ââ¬Å"When Fidel Castroââ¬â¢s revolutionary July 26 Movement assumedRead MoreRussia and the Cuban Missile Crisis Essay939 Words à |à 4 PagesRussia, The Cuban Missile Crisis During the end of World War II, a political struggle existed between the Western World, North Atlantic Treaty Organization allies, and the Eastern Bloc. Lasting until 1991, this struggle was better known as the Cold War. At the helm of these sides was the United States of America and the Union of Socialist Soviet Republics or better known as the Soviet Union. Both of these nations were constantly competing amongst each other in order to demonstrate their superiorityRead MoreCuban Revolution By Andrew Caminiti1476 Words à |à 6 Pagesconditions that many Cuban citizens lived under during the Batista regime was unacceptable. The Cuban Citizens wanted a change and started a revolution. To find out why we go all the way back to 1868 when the United States defeated the Spanish Army giving Cuba its independence. The Cubans elected Fulgencio Batista who did not allow any more elections to take place. This angered many and a new revolution leader formed, Fidel Castro. Fidel overthrew the B atista Regime and named himself dictator. He started
вторник, 5 мая 2020 г.
Workplace Laws Employment Relationship
Questions: 1. Is Maisy an employee or another type of worker? 2.Assuming Maisy is an employee, who is Maisys employer, Technicalities or IS? 3.Assuming Maisy is an employee, has Maisys employer breached any contractual duty owed to her? Answers: Introduction: The chief issue to be discussed in the scenario provided is the nature of the employment relationship existing among the parties, that is, whether the engagement creates a contract of service or a contract for service. Additionally, the paper will also seek to determine the employer or client in the scenario provided depending on the identified type of employment contract. Finally, the discourse will be concluded with an analysis of the contractual obligations of employers to employees in an effort to identify whether there was any breach with regard to the same in the scenario provided. 1. Employment Contracts As aforementioned, the major legal issue arising from the provided scenario is the determination of Maisys employment relationship, that it, what type of worker she is. In order to identify Maisys employment relationship, the type of contract existing between her and either of the organisations is a legal issue that needs to be determined. A contract of service establishes an employee and employer relationship while a contract for services creates that of a client and an independent contractor (Brender, 2006). Various tests have been established with the aim of providing a criterion against which relationships are tested to determine employment (Hopgood Ganim Lawyers, 2011). These tests include; the control test, the organisation test, the multi-indicia test, and the economic reality test. The control test was the first to be applied in determining employment relationships(Hopgood Ganim Lawyers, 2011). It considered the degree of control and the actual exercise of control in any give n case to determine employment. (Brender, 2006). McCardie J, in Performing Right Society Ltd v Mitchell Booker Ltd [1924] 1 KB 762, stated that the nature and degree of control exercised on an alleged servant determined whether they were an employee or an independent contractor. Inadequacies with the control test led to the adoption of the multi-indicia or multi-factor test which considers control, among other factors, in establishing employment relationships(Fair Work Building Construction (FWBC), 2013). The test was outlined in Stevens v Brodribb Sawmilling Co Pty Ltd (1986) 160 CLR 16 where the High Court established that although the control test was significant it was no longer a sufficient and factors such as the mode of payment, working hours, tax deductions, delegation of duties among others also had to be considered (Sewerynski, 2003). Labour hire agencies, like Technicalities, can either directly employ workers or engage them as independent contractors; where workers are employed for contractor services, they usually have their own Australian Business Number (ABN) as provided by tax law(Parliament of Australia, 2004). Odco arrangements give rise to three-party agreements where workers are seen as contractors for the agency and the host company and not as employees(Parliament of Australia, 2004). This was illustrated in Building Workers Industrial Union of Australia v Odco Pty Ltd (1991) 99 ALR 735 where, while applying the multi-factor test, the Full Federal Court found that the labour-hire workers were not employees but independent contractors (Karen, 2004). In Borg v Troubleshooters Available Pty Ltd [1995] WAIRComm 129, the labour hire agency had no control over Borgs work; he also did not receive any payments for leave and paid his own taxes, unlike an employee. These conditions were held to create an independ ent contractor relationship(Karen, 2004). In the case study, it is seen that Maisy took her daily work instructions from Innovative Storage. This allocation of duties and accompanying supervision constitutes a degree of control that under Federal Commissioner of Taxation v J Walter Thompson [1944] HCA 23 would be said to prove employment. Maisy also received training from IS in an account system once a week; in Ace Insurance Ltd v Trifunovski [2011] FCA 1204 this would be a factor distinguishing as an employee. It is, however, important to note that Maisy also had her own ABN, was not paid sick leave and paid her own taxes and superannuation. These issues qualify Maisy as an independent contractor. 2. Labour Hire Workers As Maisy was contracted by a labour-hire organisation, there is a need to identify whether she was contracted as an employee or an independent contractor by Technicalities Ltd. Labour hire workers arise from a situation where an organisation maintains and employs people who are later assigned to work in other companies(Workplace OHS). Where these workers are contracted to be paid by the labour-hire agency then they are considered as employees of the agency. In a labour-hire scenario, two notable relationships exist, the first being between the agency and the worker which is based on employment and the second being between the agency and the host company. If an employment contract exists between the labour-hire agency and the worker, then it is not expected that the worker and host company enter into an employment contract(Century Insurance Co. Ltd v Northern Ireland Road Transport Board, 1942). In the case provided, Maisy was contracted as an office worker in 2014 by Technicalities Ltd, a labour-hire company, who then placed her with their client, IS. The relationships outlined in the discussion above are evident in Maisys case as there is an established relationship between her and Technicalities Ltd and another between Technicalities Ltd and IS. Based on this finding, it can be assumed that Maisy is an employee of Technicalities and is therefore restricted from entering into an employment contract with IS unless she first resigns from employment with Technicalities Ltd. However, as much as it is evident that Maisy was probably a labour-hire worker on casual employment, there are still glaring characteristics of an independent contractor in this employment scenario. At this juncture, it is paramount to discuss the possibility of the existence of a sham contracting agreement. This is an arrangement created when an employer, in order to avoid certain obligations, purports to pass off an employer-employee relationship as one a contract for service (Australian Government, 2013). An example would be where the employee is required to have an ABN and submit invoices and a contractor agreement is relied on to make the working relationship appear legitimate(RP Emery Associates). Damevski v Guidice (2003) 202 ALR 494 is a case that illustrates how certain employers can take advantage of the contradiction in common law between employees and independent contractors to their workers disadvantage (Karen, 2004). In the given scenario, Technicalities Ltd. had requested Maisy to register an Australian Business Number so as to be able to receive her pay. This statement can be said to be a misrepresentation that led Maisy to enter into a contract without her knowledge. This misrepresentation can be said to have allowed Technicalities Ltd to avoid responsibilities such as paying superannuation and taxes on Maisys behalf. It can, therefore, be concluded that Technicalities, as Maisys employer, attempted to represent her as an independent contractor without prior notice or agreement and is thus liable for various penalties under the Fair Work Act 2009. 3. Duties of Employers The case study gives rise to the issue of employers obligations especially with regard to entitlements or awards and safety at work. Workers are entitled to the relevant modern awards as well as National Employment Standards (NES) regardless of the standing arrangements at the host company (Australian Government, 2013). These awards include the employees right to; receive pay for work done which is inclusive of tax deductions and superannuation, paid carer and sick leaves among others stipulated in statute(Australian Taxation Office (ATO), 2016). Additionally, an employer is restricted from transferring employees to other employers without their consent. An employer is also tasked with ensuring mutual trust and confidence in the employment relationship and as such cannot conduct themselves in a manner that destroys this trust (Woods v WM Car Services (Peterborough) Ltd, 1982). An employer also has a duty to provide work for the employee. That major issue arising with regard to an employers duties in this scenario is the duty of care with regard to workplace safety. An employer is tasked with the duty to ensure the safety of employees at the workplace which is implied into employment contracts by common law(Scally v Southern Health Social Services Board, 1992). Lord Wright categorised the duties of an employer as the duty to provide; competent fellow employees, safe plant and equipment and a safe system of work(Wilsons Clyde Coal Co. v English, 1937). The standard test for the duty of care is that of reasonableness, that is, what would a reasonable employer do under the same circumstances(Latimer v AEC, 1953)? Employees are entitled to care and safety in the workplace as guaranteed by the Work Health and Safety Act 2011. In the case of labour-hire workers, this duty is imposed on both the host company and the labour-hire organisation as seen in Drake Personnel Limited v WorkCover Authority of New South Wales [1999] 90 IR 432, where it was held that in as much as the host company owes a duty to the employee, the labour hire agency has an obligation to ensure that the premises are safe for their employee(Emerald Group Publishing, 2006). As per the facts, Maisy received her remuneration from Technicalities who paid her at a flat hourly rate. However, she not paid sick leave as well as carer leave and her medical expenses after her injury at Innovative Storages premises were reimbursed by the host company. Technicalities Ltd has therefore breached various NES requirements with regards to the awards and entitlements due to Maisy. The duty of care to Maisy with regard to workplace safety has also been breached as the cleaning of the spill was not sufficient to ensure the workers did not slip. Additionally, any changes in the terms or conditions of a labour hire contract can be said to construe a dismissal. Although the labour-hire worker remains lawfully employed by the agency, where the agency fails to provide further work the employee can assume a dismissal. It is advisable to seek advice as soon as possible as the law only allows 21 days to file a case against unfair dismissal for labour hire employees(Nick, 2013). As it is the agencys duty to provide its employees with work; an implied duty as in most cases it would lead to a reduction in actual or potential earnings as illustrated in Turner v Goldsmith [1891] 1 QB 544. In Maisys case, IS employed a new worker which led to the termination of her services with the host company. Although this may seem as a dismissal, Maisy has been established as an employee of Technicalities and is therefore not dismissed as a worker. It is Technicalities duty to provide work for Maisy as lack of work means she cannot earn her keep. Ad ditionally, as Maisy is a labour-hire worker, she cannot enter into a contract with IS as an employee until she has duly resigned from the labour hire agency as earlier mentioned. Conclusion In conclusion, the discussion above provides evidence that affirms that Maisy is a labour-hire employee, contracted by Technicalities Ltd. There is no employment contract existing between Maisy and IS as the host company is merely a client of Maisys employer. Technicalities can also be said to have used a misrepresentation to exclude itself from various contractual obligations owed to Maisy as an employee and as such was in breach of its contractual duty. Maisys could also not get the job advertised at IS as she is a Technicalities employee and would have to resign if she wished to work elsewhere. Additionally, Maisys termination from work with IS does not constitute an unfair dismissal as she is still legally employed by Technicalities, however, should her employer fail to provide her work she could sue for unfair dismissal as they will have failed to uphold their duties. References Angela, W., Daniel, G. (2013, February 28). The differences between employee and contractor . Retrieved from Chartered Accountants: https://www.charteredaccountants.com.au/News-Media/Charter/Charter-articles/Business-management/2013-03-The-differences-between-employee-and-contractor.aspx Australian Government. (2010). Types of Employees. Retrieved from Fair Work Ombudsman: https://www.fairwork.gov.au/employee-entitlements/types-of-employees Australian Government. (2013, December). 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Sham Contracting- the facts you need to know. Retrieved from Find Law Australia: https://www.findlaw.com.au/articles/5706/sham-contracting--the-facts-you-need-to-know.aspx Ryde-Eastwood Leagues Club Ltd v Taylor, 56 IR (1994). Sarah, H. (2015). Independent Contractor, labour hire worker or employee? Wine Viticulture Journal. Scally v Southern Health Social Services Board, 1 AC 294 (1992). Sewerynski, M. (2003). Collective Agreements and Individual Contracts of Employment. Kluwer Law International. Snedden Hall Gallop Lawyers. (2015, May 19). Labour Hire Workers- who is the employer? Retrieved from SHG: https://www.shglawyers.com.au/news/legal-news/article/?id=labour-hire-workers-who-is-the-employer Wilsons Clyde Coal Co. v English, UKHL 2 (House of Lords July 19, 1937). Woods v WM Car Services (Peterborough) Ltd, ICR 693 (Court of Appeal 1982). Workplace OHS. (n.d.). Labour-hire Workers. 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