Donoghue v Stevenson Analysis

Donoghue v Stevenson Analysis Introduction The case of Donoghue v Stevenson is arguably one of the most famous cases in the common law system and definitely one of the most important in the history of the development of the tort law. The revolutionary significance of the decision in this case is in the establishment of a standardised duty of care in negligence cases. Indeed, over the years after the precedent was set the courts have progressively shifted from the ascertaining a specific duty of care for each kind of situations, to the approach that assumes the existence of the general duty of care as it was established in Donoghue v Stevenson, and in particular Lord Atkins famous neighbour principle.[1] This essay is going to discuss the relevance of the principles established in this case in the modern tort law. The essay will start with the discussion of the established precedent, then moving to the development of the neighbour principle in the subsequent case law and its application today. The importance of the decision of the case In fact, the case established several important principles. They are: the recognition of the negligence as a distinct tort, the recognition of liability in situations, where there is no contractual relationship between the defendant and the claimant, the establishment of a duty of care owned by manufacturers to the ultimate consumers and the neighbour principle. [2] Nevertheless, Lord Atkins neighbour principle is the most well-known part of the decision of the case, despite the fact that according to the official sources it was never a part of the ratio of the decision in Donoghue v Stevenson.[3] Lord Atkins approach was recognised for the first time Word count: 1391 in the case of Hedley Byrne v Heller[4], and later in the Home Office v Dorset Yacht Co Ltd Lord Reid stated that the decision in the case of Donoghue should be treated as a precedent and that that it ought to apply unless there is some justification or valid explanation for its exclusion.[5] The idea behind this was to unify the previous cases and to make the decisions in the future cases more predictable. Thus, the neighbour principle established two concepts foreseeability and proximity. These two key concepts triggered the development of tort law in the 20th century. The development of the established concepts The principle established in Donoghue v Stevenson was seen as an important milestone in the history of tort law as it was the first successful attempt to set out a general principle with respect to the concept of the duty of care. However, later the courts started to acknowledge that the neighbour principle was too simplistic and limited in scope. Therefore, the evolution of the tort of negligence since the snail in the bottle case has been a search for control mechanisms that can limit the scope of the duty concept. So, within the case law on duty of care there has been a shift from a general concept of duty formulated in the neighbour principle to more specific criteria. Indeed, in Anns v Merton London Borough Council, the House of Lords decided to modify the test for the establishment of a duty of care by imposing policy considerations to limit the imposition of a duty of care.[6] The test formulated in Anns was that the defendant owed the claimant to take reasonable care, as long as it was reasonably foreseeable that a failure of doing so would result in damage to the claimant, unless there was some policy reason that limited the scope of the duty or the class of people to whom it was owed or the damages to which a breach of the duty may Word count: 1391 give rise. [7]The first part of the test clearly corresponds to the Lord Atkins test, but the second part was created to restrict claims. The main criticism of this test was that it could lead to an expansion of the situations in which a duty of care could arise. Therefore, in 1990 the Anns test was rejected in the case of Murphy v Brentwood District Council.[8] As the test set in Anns was not sufficient enough, and it was replaced with the test for a duty of care set in Caparo Industries v Dickman. [9] The Caparo test narrowed the test set in Anns by implementing an additional stage to the test. The Caparo test consists of requirements of reasonably foreseeable harm, a relationship of proximityaand that for the imposition of a duty to be fair just and reasonable. The first two stages of Caparo test were based on judgement in Anns, which corresponds back to Lord Atkins neighbourhood principle and the fair, just and reasonable requirement relates to same public policy considerations as the second stage of the Anns test. However, an essential difference between Caparo and Anns is that Caparo test emphasised the incremental and by analogy approach in order to prevent massive extensions of the duty of care concept, meaning that there must be an analogous situation in the previous case law in order to justify the extension of the duty of care in novel situations.[10] By accepting the incremental and by analogy approach the courts rejected the broad formulations from the previous case law and constrained the precedent set in Donoghue v Stevenson to cases concerned with physical damage. [11] Word count: 1391 So, from one point of view, it can be said that the decision in Donoghue v Stevenson created a basis for the establishment of the test in Caparo as first two requirements are clearly taken from the neighbour test. However, some critics say that the intention of judges in Caparo was to change the neighbour principle in entirety. Indeed, in the modern times the incremental approach developed in Caparo suggests that the claimant can only sue the defendant for the breach of the duty of care only in situations where the existence of the duty is established. This seems to contradict the aim of Lord Atkins biblical principle. [12] As has been recognised in Anns and Caparo, the approach taken by the judges in Donoghue v Stevenson is too simple, especially in the modern times, where the law of negligence has become even more complicated than it used to be. Nowadays the courts use different approaches for different situations, for example the approach for the establishment of duty of care for psychiatric injuries is not the same as for physical injuries. Indeed, according to Heuston other considerations beyond foreseeability and proximity begin to acquire greater significance and the principles established in Donoghue are applicable only to relatively straightforward cases, but not to the liability for non-physical injuries, or for omissions, or for the conduct of third parties.[13] However, it can be said that the decision in Donoghue v Stevenson formed a foundation for the development of all the aforementioned areas of tort law. Conclusion To conclude, some scholars express the view that the importance of the case of Donoghue v Stevenson was overrated both by its supporters and critics.[14] However, in my opinion, even though the importance of the decision of this case nowadays is reduced, the case has a lasting effect, the significance of which lies not only in the established principles, but in the ideas that changed the law of tort forever, and in particular the law of negligence. Bibliography Cases Donoghue v Stevenson [1932] AC 562 Hedley Byrne Co Ltd v Heller Partners Ltd [1963] 2 All ER Home Office v Dorset Yacht Co Ltd [1970] AC 1004 Anns v Merton London Borough Council [1977] UKHL 4 Murphy v Brentwood District Council [1991] UKHL 2 Caparo Industries Plc v Dickman [1990] UKHL 2 Articles J.C. Smith, Peter Burns, Donoghue v. Stevenson: The Not so Golden Anniversary [1983], MLR 1 R.F.V. Heuston, Donoghue v Stevenson in Retrospect, [1957], MLR 20(1) Gavin Murphy, The snail and the ginger beer: the singular case of Donoghue v Stevenson [2011], CLB 37(1) Keith Patten, Snail trail, (New Law Journal, 11 May 2012) assessed 22 November 2016 Z0973311 Word count: 1391 Jessica Randell, Duty of Care Haunting Past, Uncertain Future (2014) North East Law Review 2 (2) Books Simon Deakin, Angus Johnston, Basil Markesinis, Markesinis and Deakins Tort Law (7th edn, Oxford University Press Higher Education Division 2012) Horsey K., Rackley E., Tort Law (3rd edn, Oxford University Press Higher Education Division 2013) [1] J. C. Smith and Peter Burns, Donoghue v. Stevenson-The Not So Golden Anniversary (1983) 46 (2) MLR 1 [2] R. F. V. Heuston, Donoghue v. Stevenson in Retrospect (1957) 20(1) MLR [3] Keith Patten, Snail trail, (New Law Journal, 11 May 2012) assessed 22 November 2016 [4] Hedley Byrne Co Ltd v Heller Partners Ltd [1963] 2 All ER [5] Home Office v Dorset Yacht Co Ltd Lord Reid [1970] AC 1004 [6] Anns v Merton London Borough Council [1977] UKHL 4 [7] Kirsty Horsey, Erika Rackley, Tort Law (3rd edn, Oxford University Press Higher Education Division 2013) [8] Murphy v Brentwood District Council [1991] UKHL 2 [9]Caparo Industries plc v Dickman [1990] UKHL 2 [10] Jessica Randell, Duty of Care Haunting Past, Uncertain Future (2014) North East Law Review 2 (2) [11] Simon Deakin, Angus Johnston and Basil Markensinis, Markesinis and Deakins Tort Law (7th edn, Oxford University Press Higher Education Division 2012) [12] Patten(n 3) [13] Heuston (n 2) [14] Gavin Murphy, The snail and the ginger beer: the singular case of Donoghue v Stevenson [2011], CLB 37(1)

Psychology of State-Sponsored Violence Essay -- Human Rights

Psychology of State-Sponsored Violence State-sponsored violence has led to some of the most horrendous human right crimes such as genocide and torture. These crimes are often under the constant fire of debate as scholars try to reason as to why they occur. However, the debates of genocide and torture are not exclusively attributed to the fact that they occur, but also, as to why people participate in these acts to begin with. Contrary to popular belief the majority of participants in state-sponsored violence are often not radical extremists, but rather, ordinary people. In instances, such as the genocide in Rwanda, participants were average everyday people, often neighbors of the victims, who carried out many of the killings. Also, in cases of torture the soldiers who perform the acts are referred to as â€Å"ordinary Joes†. If it is the case that ordinary and regular people are involved in state-sponsored violence, why do they participate in the first place and what are the continuing effects they have because of their participation? In order to answer these pressing questions one must examine the sociological and psychological factors that guided people’s actions. There are different psychological features that come into play such as individual thought and how it is affected by group dynamics and authority. Moreover, the psychological features are further expanded when coupled with sociological attributions which animate the reasons behind participation in state-sponsored violence. In certain state-sponsored violence, like torture, the â€Å"average Joe† is sought after as opposed to a rebel for the reason that an â€Å"average Joe† can ]easily be psychologically developed to be a torturer. The psychological transformation involves a restr... ...s that come into play are sense of impunity, perception of authority figures, and group dynamics. These psychological factors along with sociological perceptions in deviance illustrate the complex environment that is present when an ordinary individual decides to participate in state-sponsored violence. Works Cited Asch, S. E., (1951) Effects of group pressure upon the modification and distortion of judgments. Brehm, S. S. & Kassin, S. M. (1993) Social Psychology, p.399 (2nd ed.). Boston: HughtonMifflin. Fujii, Lee Ann. Killing Neighbors: Webs of Violence in Rwanda. Cornell University Press, 2009. 45-75;154-179. Print. Hatzfeld, Jean. Machete season: the killers in Rwanda speak : a report. Farrar Straus & Giroux, 2005. 45-75; 154-79. Print. Schulz, William. "Torture." Human Rishts: Politics and Practice. Oxford University Press, 2009. Print.

Technology, Population, and the Impact of Ancient Humans on the Environ

Technology, Population, and the Impact of Ancient Humans on the Environment In recent years, humans have become increasingly concerned with their effect on the planet and its ecosystems. In the popular view, these problems are new and unprecedented in human history. While it is probably true that our impact on the environment on a global scale has never been as great, the difference is simply the scale on which our actions are being taken. Situations that previously were local or regional in scope have now become global, owing to the increasingly sophisticated technologies that we have developed and our ever-increasing population. As an examination of the impact of ancient humans on the environment illustrates, however, the current impact fits into the general pattern that the degree to which humans influence their environment is determined by their concentration and the sophistication of their technology. Contrary to the popular view which sees ancient humans as either benignly living with their environments (see Note 1 below) or as leading miserable short lives during which they were at the mercy of those environments, archeology tells us that humans have been interacting with and affecting their environments since the beginning. As Neil Roberts comments, humans' impact on landscapes began "even before†¦landscapes had become recognizably modern." (Note 2). My purpose in this paper is to illustrate some of the ways ancient humans, using a variety of technologies, altered the environments they lived in. Before I begin, however, I would like to emphasize that discussing human "impact" on the environment implies human action was detrimental to the environment. In this paper, I shall define "impact" as any change in the lands... ...ng paragraphs come from the author's lecture notes as described in note 7 above, as well as Ellen, R. "Modes of subsistence: hunting and gathering to agriculture and pastoralism," in The Companion Encyclopedia to Anthropology, ed T. Ingold, New York: Routledge, 1994.; and Price, T.D. and J.A. Brown. "Aspects of Hunter-Gatherer Complexity," in Prehistoric Hunter-Gatherers, T. Price and J. Brown, eds. San Diego: Academic Press, 1985. 9. Other populations such as mammoth hunters of the Central European Plain dealt with these pressures by shifting to specialized economies based on the extensive use of a few species. 10. The opposite is k-selected species such as mammoth, who produce fewer offspring, but give these offspring more care in order to give each offspring a higher chance of survival. Earlier subsistence patterns had tended to focus on k-selected species.

Superstition :: essays research papers

Writing on the wall   Ã‚  Ã‚  Ã‚  Ã‚  Superstitions exist everywhere in the world. Every country on the planet has its own local superstitions. Each country also has its own variations on common superstitions. Some of the most common superstitions have to do with cats, alcohol, and death.   Ã‚  Ã‚  Ã‚  Ã‚  Cats have been domesticated longer than any other animal. Humans have even worshiped them; therefore, it makes sense that there are innumerable superstitions worldwide involving them. In the United States, there is a belief that if a black cat crosses your path, you will have bad luck. In Germany, whomever harms or kills a cat shall meet with great misfortune. In France, there is a superstition that it is bad luck to cross a stream carrying a cat. In the Ukraine, it is believed that if you give a cat gin before sundown you will have much misfortune.   Ã‚  Ã‚  Ã‚  Ã‚  Alcohol is considered to be the bane of society by many people worldwide. Having existed for thousands of years, alcohol has many superstitions associated with it. In the Czeck republic, it is considered bad luck to serve alcohol on Christmas. In the US, it is considered bad luck to not serve alcohol on Christmas. In Germany, it is believed to be good luck to drink three or more drinks with the groom immediately before the wedding. In Poland, they believe that if one consumes alcohol before noon, one will die young.   Ã‚  Ã‚  Ã‚  Ã‚  Death is the one thing feared most by humans. They attempt to justify death by creating superstitions. Many of these superstitions have to do with agriculture. In China, it is believed that when a farmer’s child dies on a harvest moon, there will be an excellent crop the next year much like in â€Å"The Lottery†; death leads to a good harvest.

Produce a detailed and linguistically well-informed

Produce a detailed and linguistically well- informed analysis of the editor's letter from Elle magazine (July 2012) which focuses on the process of ‘synthetic personalisation By harpur91 Produce a detailed and linguistically well-informed analysis of the editor's letter from Elle magazine Ouly 2012) which focuses on the process of ‘synthetic personalisation What I am going to look like, in relevance to the above question, is the process of synthetic personalisation in the magazine, ELLE (July 2012).I am therefore going to nclude work produced by Norman Fairclough and his ideas on this process, but also including lexical features, conversationalisation; in which can be spilt up into numerous features combined under this discourse. Firstly, however, I am going to have to understand the terms In order to produce a detailed and linguistically well- Informed analysis of the editors letter from said magazine. The first area I am going to focus on is Synthetic personalisation'.F airclough defined this concept as being â€Å"a compensatory tendency to give the impression of treating each of the people handled' en masse as an individual† (Fairclough 2001 :52) this therefore it begins to become a process of addressing the mass audience, whilst speaking to them as they were Individuals. Thus, showing off an element of conversationalisatlon, not only that, but It begins to show Ideas of Informality with the language used throughout articles etc___ However when looking deeper into the Issue. we begin to see that this is only a cover-up, an attempt to give the impression that they are speaking on an informal, one-to-one basis.This therefore shows elements of manipulation; giving us, as the udience a false sense of intimacy, or fake intimacy (Hoggart 1957) with the writer. Furthermore this begins to signify the phoney sense of belonging we have with the text given, we are not seen as being an individual but as a collective group of people. Falrclough would t herefore describe and label the concepts spoken above as conversationallsation. As we begin to progress, we begin to see a clear difference In both private and public outputs. â€Å"People do not expect to be spoken down to, lectured or got at'.They expect to be spoken to in a familiar, friendly and informal anner as they were equals on the the same footing as the speaker† (Scannell, 1996:24) not only does this relate to radio and television, but it could be incorporated into the magazine and Journalist Industry. People reading Journalistic products such as ELLE magazine; expect to be treated In a certain way, a way In which Is Informal, conversational In order to gain that Illusion of Individualisation, rather than them addressing the audience as a whole.Conversationalisation is a â€Å"term used by Fairclough (1994:260) who describes it as ‘a restructuring of the boundary between ublic and private orders of discourse' Fairclough also notes that it involves the use of language that is normally associated with conversation† (Baker 2011 :22) because of tnls, we can Degln to see tnls development Detween tne relatlonsnlp 0T tne speaker and reader therefore creating this emotional connection, rather than it Just being informational.Furthermore â€Å"it could be argued that in capitalist societies, conversationalisation is often used as a way of securing customer loyalty by helping them create the appearance of a personal relationship† (Baker 2011 :23) this therefore inks back to the idea that companies/ in this case ELLE magazine writers have the ability to address a mass audience, but making them feel like they are being spoken to individually. And when it builds this relationship with the reader, they are able to exploit them through subtle, inclusive language.The editor's letter from ELLE magazine, shows off similar ideas of this informality of conversationalisation, we as the audience, when reading this text, may see it as being some thing you would sit amongst friends and chat about, thus giving that informal conversation (e. . â€Å"l wanted to pick the star of the show, the person you all want to date – sorry I mean meet) this shows that Joke like attitude women may converse in when with their girlfriends. Thus showing, in essence a form of popular opinion, allowing the readers to feel some sort of connection.Not only this, but specific language used throughout texts of this nature, i. e. fashion magazines, show a clear representation of that conversation amongst friends. And like said previously, the writer begins to address you as an individual, rather than a collective group. This therefore is a clear representation of language; that they are being supportive friends therefore helping another friend out in need. Lexical features are also used throughout this text in order to reinforce the idea of the writer personally addressing their ideas to an individual.For example, pronouns such as; l, you and we are used throughout this text, to make the reader feel connected to this historical fashion debut. An example of this would be; â€Å"this is the first time in ELLE's 27-year history we have put a man on the cover. I didn't take the decision lightly- after all, this is a LUXARY fashion magazine for women† not only is it addressing all women, whom have some sort of interest in fashion, but it begins to show off an element that, you as the reader had some sort of insight in picking and being a part of this event.Not only this, but the editor begins to apologise to those, whom thought R-Patz (Robert Pattinson) would grace their historical cover. â€Å"l feel I have to apologise to the R-Patz fans who hoped our first-ever cover man would be him (and told me repeatedly on Facebook and Twitter! ) Again, with the synthetic personalisation aspect, we begin to see that there is a clear formality of the writer-reader element. The fact they apologised, signifies the element of inti macy, thus allowing those to thought he would grace the cover, some clarification into why they chose David Beckham instead.When analysing the editor's letter in more detail, we begin to see the use of pronouns and how the language and context it is used in conforms to the idea of togetherness. The pronoun; we, is used during the letter, this therefore shows the representation of a hared identity of the audience, not only that but it becomes clear that the language used is in a specific way in which creates the idea of a togetherness for the audience, that they feel a part of this.The pronouns used do not Just simply and directly conform to the friendly stereotype between writer-reader but, they are also used in terms of exclusively, where there used amongst the editorial team therefore contributes to† setting up the producer as a team; the anonymous group voice is a Trlen01y gossip In tne orlentatlon Deneatn tn 5/6) tnls tnereTore hows that the editorial team act like a famil y, in which create the illusion of a wider- social informal friend-like association between writer-reader.For example â€Å"l knew I had made the right decision as I noted the giddiness among the editorial team before the shoot† this shows the clear representation of the pronouns used in order create the family-like background for the reader, it signifies a family into which collectively decides on what is right. And because of this, we as the audience/reader feel like this is addressing us on a personal/individual level. Not only does language ncorporate the idea of directly addressing an individual rather than a collective group, but the use of parenthesis can also create the idea of a quiet word between friends, therefore backing up this element.Within the editor's letter from ELLE â€Å"we have done two covers for the newsstand issue (so you can go out and buy the alternative, too) and a very SPECIAL illustrated collectors' cover for our loyal and much-valued subscribers (weVe also made a video for your eyes only, subscribers† with this, it represents ideas that if you are a loyal subscriber you can get extra ontent etc.. which therefore could symbolise ideas of your much closer friends. Therefore you are able to talk more and gain a more insightful understanding of the content. However this could be represented in a completely different light.The fact that this may mean the exploitation of individuals, in which creating the idea that you can get more from this issue if you become a subscriber, therefore reinforces the capitalist society. Overall when looking at what has been said, I can conclude that synthetic personalisation has played a massive part in the print industry, focusing ore on the fashion magazine ELLE, the fact we are able to see and understand the linguistic features used in order to create this illusion of a friendship connection between writer and reader and how, they have used their power in order to manipulate the audience .And because of this, the audience finds it more helpful knowing that they have some sort of â€Å"friend† to lend a helping hand. Not only that, but because the private and public have started to merge, we are seeing elements of public events being used for private consumption. But people are able to interpret hings different when there in private, than they could if they were in public.But overall, there are so many elements in ELLE magazine which represent the linguistic attributes in exploiting an audience through language and grammer.

How the Visual Media Affect People

In modern society, media Is everywhere, and It Is almost Impossible to avoid. The mass media have become such an ordinary, everyday part of society that many people fail to realize the immense impact which the mass media have on all aspects of society – including political, economic, and ideological aspects. The mass media influence the way we vote, the things we buy, the way we act, the values we hold, and the way we perceive reality. The media can be very helpful to people and their children who carefully choose he movies and shows that they watch.With high-quality programming in various fields of study-?science, medicine, nature, history, the arts, and so on-?TV and videotapes increase the. Knowledge of the average and the well-educated person; they can also improve thinking ability. Moreover, television benefits elderly people who cannot go out often, as well as patients in hospitals and residents of nursing faceless. Additionally, It offers language learners the advantage of ‘real-life' audiovisual Instruction and aural comprehension practice at any time of day or night.And of course, television and video can provide almost everyone with good entertainment-?pleasant ways to relax and spend free time at home. Nevertheless, there are several serious disadvantages to the visual media. First of all, some people watch the tube' for more hours In a day than they do anything else. In a large number of homes, TV sets-?as many as five or more In a single household – are always on. Instead of spending time taking care of their kids, parents often use the tube as an ‘electronic baby sitter. As a result, television and video can easily place family communication as well as physical activity and other interests. Secondly, too much TV-?especially programming of low educational value-?can reduce people's ability to concentrate or reason. In fact, studies show that after only a 20. Minute minutes or two of visual media, a person's mind ‘rel axes' as It does during light sleep. Another possible effect of television and videotapes on the human brain is poor communication. Children who watch a lot of TV may lose their ability to focus on a subject or an educational activity for more than ten to fifteen 24. Mute minutes. Maybe it is because of the visual media that some kids-?and adults too-? develop attention deficit disorder ADD, a modern condition in which people are unable to pay attention, listen well, follow Instructions, or remember everyday things. A third negative feature of the media is the amount of violence or horror on the screen-?both in real events in the news and movies or TV programs. It scares people and gives them terrible nightmares; the fear created by media images and language can last for a long time.On the other hand, frequent viewers of ‘action programming' unusual about violent crime, fight, killing, and other terrible events and behavior. Studies show that certain personality types are like ly to have strong emotional reactions or dangerous thoughts after some kinds of ‘entertainment. ‘ They may even copy the acts that they see on violent shows-?start fires, carry and use weapons, attack people in angry or dangerous ways, and even worse. Because of the visual media, some people may become dissatisfied with the reality of their own lives.To these viewers, everyday life does not seem as exciting as the roles actors play in movies or TV dramas. They realize they are not having as much fun as the stars of comedy shows. Furthermore, average people with normal lives may new famous media personalities, who seem to get unlimited amounts of money and attention. Also, media watchers might get depressed when they cannot take care of situations in real life as well as TV stars seem to. On the screen, they notice, actors solve serious problems in hour or half-hour programs-?or in twenty- second commercials.Yet another negative feature of modern television is called tras h TV. ‘ These daily talk shows bring real people with strange or immoral lives, personalities, or behavior to the screen. Millions of viewers-?including children-?watch as these ‘instant stars' tell their most personal secrets, shout out their angry feelings and opinions, and attack one another. TV watchers seem to like the emotional atmosphere and excitement of this kind of programming-?as well as the tension of the real but terrible stories on TV ‘news magazine' shows.What effect does frequent viewing of such programs have on people's lives? It makes television more real than reality, and normal living begins to seem boring. Finally, the most negative effect of the tube might be addiction. People often feel a strange and powerful need to watch TV or play a CD even when they do not enjoy it or have the free time for entertainment. Addiction to a TV or video screen is similar to drug or alcohol dependence: addicts almost never believe they are addicted. Even so, tr uthful media addicts have to give yes answers to many of these questions.

Global Corporate Citizenship Essay

1. Do you think that apple has demonstrated global corporate citizenship, as defined in this chapter ? Why or Why not ? Global corporate citizenship means that companies must not only be engaged with stakeholders but stakeholders themselves alongside government and civil society. Since companies depend on global development, which in turn relies on stability and increased prosperity, it is in their direct interest to help improve the state of the world. When Apple investigated and found some violations of its supplier code of conduct, which it had introduced in 2005. The following year, the company published its first annual supplier responsibility progress report, I think Apple demonstrated global corporate citizenship. Apple admitted its violations and did everything in its power to correct them. By 2011, Apple had inspected nearly 400 suppliers and had terminated 11 for serious violations. 2. In its response to problems in its contract factories, do you think Apple moved through the stages of corporate citizenship presented in this chapter ? Why or Why not ? _ Corporate citizenship is a term used to describe a company’s role in, or responsibilities towards society. So in Apple’s situation, it has moved through the elementary stage because at first it seemed they were not concerned the citizenship. During peak production periods, all three factories had exceeded the mandated limit of 60 hours of work per day, and many employees had been required to work more than 7 days in a row not receiving fair pay for overtime, unsafe conditions. Then Apple went through engaged stage, it turned to Social Accountability International and announced it had joined the Fair Labor Association. This is because Apple became aware that they needed to change public expectations. To make sure all contractors abiding the code; at Apple’s request and with the company’ s financial support, the FLA immediately undertook the most extensive audit ever conducted of conditions in China’s electronics supply chain. 35,000 workers filled out anonymous questionnaires about their experiences. This process means that Apple is in the innovative stage and they continue in the process of auditing and tracking improvements. 3. What are the advantages and disadvantages to Apple of using its own company-specific supplier code of conduct, rather than a global code, such  as those discussed in this chapter? Apple’s Supplier Code of conduct was already one of the toughest in the electronic industry, but it have made it even stronger. And its ensure compliance by conducting hundreds of audits per year worldwide. Its efforts span the entire range of its supply chain – from the manufacturers of tiny components to the facilities that assemble its final products. 4. What are the advantages and disadvantages to Apple of using and independent third-party auditor, rather than rely on its own internal audits? The advantages of bringing in a third-party firm are numerous. Investigative auditing firms employ accountants who do this work on a regular basis. As such, they know what to look for. Another advantage is impartiality. An outside investigative auditor – who has no personal or professional relationship with your employees – is likely to conduct the audit in an impartial manner. This is important, as these investigations can lead to criminal prosecution. Thus, relying on an internal accountant to find fraud or theft might place him in an uncomfortable situation, which can affect morale. The FLA can certainly claim to be more independent. It conducts its own audits and requires members to disclose the results. And it also has a third-party auditor re-audit some of its own inspections to make sure progress is being made on fixing violations. If indeed you have an accountant trained in investigative auditing on staff, it makes sense to use your own forensic accountant in the investigative auditing process. The positive side of this is that it gives you more control over the dissemination of information. It is typically harder to control dissemination of information when an outside firm is involved. Another disadvantage is cost-related. Hiring an investigative auditing firm is typically far more expensive than using your own investigative accountant.