Saturday, December 28, 2019

Cultural Anthropology And The American Society - 1346 Words

Lucas Mochal General Education Task Assignment 1 10/3/2014 Cultural Anthropology Feminist Approach to the American Society One theoretical approach in the field of cultural anthropology is the Feminist Approach. The feminist approach is an approach that helped females from all diverse cultures to band together for equal rights or more freedom for themselves. A feminist theory can be described as an approach to move towards empowering women worldwide. Feminism has been a problem in any culture from any time in history, and feminist worldwide are all banding together for one reason: to become independent and highly powered women. The main goals of feminism are to discuss the importance of women, break the gender inequality†¦show more content†¦In the later centuries in school girls were depicted to be in home economic classes to learn how to be a homemaker, whereas boys were sought out to be in math and science classes. As the centuries progressed society has changed immensely in how men have treated their women and how women have overcome their typical roles in society. People have always had the impression that society is driven by males. One big feministic move that women fought for was the right to be able to vote. Women had never been able to vote because it was thought that men should only have the right to choose who would be serving us locally and nationally. Liberal feminists thought that this idea was unfair and that both genders should be able to vote, so they fought for the right for some women to vote in 1918 and then in 1928 their appeal was approved and all women got the right to be able to vote. Another area that feminists fought to change was the view of women in the workplace. Many career areas have always been depicted as a â€Å"men only† career such as Political, law enforcement, military and construction. Feminist have taken the challenge to prove that this is a gender equal nation where women are able to do the same amount of work that men can do if not better than men. In the earlier centuries when it came to serving in the military you would never find a women serving because they were known to be very weak and physically unfit to serve in the

Friday, December 20, 2019

Terrorism A Systematic Weapon Of War - 1320 Words

â€Å"Terrorism has become a systematic weapon of a war that knows no border or seldom has a face† - Jacques Chirac, September 24th, 1986. As Mr. Chirac says Terrorism has become a systematic weapon of war. This does not just mean the US and its allies this mean on a global scale in Africa, Europe, Asia, Australia, North and South America the whole planet is affected. Even the countries that support groups like ISIS and al-Qaeda are affected by the bombing that we send. This War knows no borders while there is international terrorism there is also domestic terrorism that happens inside countries. Terrorism plagues the world that we live in today that affects everyone men, women, children and as a world we need to come together and eliminate this threat which will help establish peace. The definition of terrorism is defined differently by different departments of the US government. According to the FBI the definition comes right out of Code of Federal Regulations â€Å" The unlawful use of force and violence against persons or property to intimidate or coerce a government, the civilian population, or any segment thereof, in furtherance of political or social objectives†. Terrorism in happening right here at home. Oklahoma City, Oklahoma April 19, 1995 ex-Army soldier/ security guard Timothy McVeigh parked a rented truck in front of the Alfred P. Murrah Federal Building. Inside was a powerful bomb that McVeigh had built himself at home. He got out of the truck lit a timed fuse got inShow MoreRelatedThe Threat Of Nuclear Terrorism1483 Words   |  6 Pages Nuclear Terrorism Introduction to Homeland Security Victor Reyes Valencia College Abstract Nuclear terrorism can take a variety of forms. The most frequently discussed form involves a terrorist group either stealing a nuclear weapon or building a nuclear device using stolen or illegally purchased nuclear material. This paper explores the dangers and threats of Nuclear Terrorism. It also goes in depth with how the government’s actions have prevented groups, countries and homegrownRead MoreThe American Response1361 Words   |  6 PagesAmerica’s two most recent wars are the Iraq War and the War on Terror. Both of these wars have accomplished their goals, but come at a great cost. There were quite a few factors in both of these wars that affected international security. First, I will analyze both of the wars and then intertwine them together to show the overall effect they have created on America. Let us look first at the War on Terror. The War on Terror started after the terrorist organization Al-Qaeda attacked America on SeptemberRead MoreTerrorism: A Growing Threat898 Words   |  4 Pagespeople by using threats and violence to further political beliefs. Terrorism can be shown in many different ways; however, there are only two main types of terrorism: international and domestic. International terrorism usually occurs outside the jurisdiction, or boundaries, of the United States. Domestic terrorism is the exact opposite, occurring mostly within the jurisdiction of the United States. The violence of terrorism is usually comprised of assassination, destruction, or kidnapping. ThereRead MoreRational Choice Theory : Theories Of Political, Social, And Economic Sciences1467 Words   |  6 PagesFor nearly half a century rational choice theory (RCT) has dominated analyses of political, social, and economic sciences. Due to the theory’s objectivity and systematic predictability, rational choice is able to provide a comforting procedure to studying the decision-making process. However to truly gauge how and why actors make decisions, a more diversified and complex degree of emotions and behaviors must also be analyzed. Despite our efforts to prove the contrary, actors are human, thereforeRead MoreThe French Revolution First Popularized The Words Terrorist And Terrorism 1506 Words   |  7 Pages Whereas the French Revolution first popularized the words ‘terrorist’ and ‘terrorism’, its contemporary understanding differs from its revolutionary meaning in 1794. The serious economic difficulties, the threat of foreign invasions and the social structure of the French government are some of the causes that led to the fall of the monarchy in August 1792. Left without a constitution for almost three years and at the hands of a revolutionary government, the reign of terror suggests an example toRead MoreIs Declaration of War Ever Justifiable?1185 Words   |  5 Pagesthe beginning of war among settled civilizations, the question of whether war is right or wrong has been somewhat ambiguous. Some say war is wrong in totality and should not be an option because there are no moral, justifiable grounds for the damage caused during war. Others say that war can be just. The idea of having a justifiable war is called the â€Å"just war theory† or â€Å"just war doctrine†. As early as 400BCE, within the Indian book â€Å"Mahabharata†, the notion of having a just war has been debatedRead MoreTerrorism: A Defining Moment in Our Recent History1576 Words   |  6 Pagesthe 21st century, terrorism has been a defining moment in our recent history. It has shaped the foreign policies of many nations, changed the way society has viewed violence and created debates about national security. Yet, it is only recently that terrorism has gone global. The history of terrorism is rooted in its use by revolutionaries and governments, its influence on domestic affairs and the various methods used to instill fear and control. But since the end of the Cold War and more importantlyRead MoreA New Paradigm Of Terrorism1537 Words   |  7 PagesSince the 9/11 terrorist attacks many have sought to argue that a ‘New’ paradigm of terrorism exists and therefore that the nature of modern terrorist threats has changed. However, terro rism itself has never been clearly outlined, and as such both Copeland and Duyvesteyn argue current threats to be a continuation of older trends of traditional terrorism. More so terrorism is subjective and therefore current threats depends upon who the target is and who is reporting the attack. On the other handRead MoreThe George W. Bush Administration Essay1505 Words   |  7 PagesGeorge Shambaugh, Richard Matthew, Roxane C. Silver, Bryan McDonald, Michael Poulin, and Scott Blum, set out to discover how the before mentioned events effected the group unit of analysis, â€Å"U.S. Public†, views towards our government, the media, terrorism, and their overall outlook on America’s future. It had appeared that they had the predetermined notion that because of terrorist attacks and natural disasters the U.S. public would be pessimistic and afraid foreign countries. Other suggested hypothesisRead MoreEssay on The War on Terror1493 Words   |  6 PagesWar on terror refe rs to the ongoing military campaign led by U.S and U.K against organizations identified as terrorists. Terrorism can be defined as an unlawful violence or war deliberately targeted to civilians. It can also be defined as a systematic use of terror to coerce or violent acts intended to create fear. This threat is normally perpetrated for religious, political or ideological goals. The conflict as also called by other names. They include World War III, The Long War, War on Terrorism

Thursday, December 12, 2019

Strategic Management of Woodside

Question: Discuss about the Strategic Management of Woodside. Answer: Introduction: Woodside petroleum is the major hand of oil and gas production in Australia and also Australias biggest autonomous devoted oil and Gas Company. Headquarter of the Company is in Perth(Anon., 2017). Strategic management is a bunch of features that helps in establishing a brand image for a company (Leather, 2013). Every single company has their own strategy and its outcomes. Woodside Petroleum of Australia has proved its credentials to the world of business. This assignment helps in finding out the management strategies, which the Company uses to fulfil the desired goal. There was a time, when the Company was criticised for some reasons. This assignment also helps in finding out those two criticisms with its effective outcomes on the Company and the dependents. SWOT analysis is there to observe the core features of the Company varying from good to bad. It also provides a focus on the organizational culture or the leadership style within the organization. Strategic management of Woodside Petroleum: Woodside Petroleum manages their strategies on three themes that are increasing the significance of their core resources, enhancing their capabilities and increasing their portfolio. Woodside has a strong foothold in the Oil and Gas industries with a dependable manufacture base, unique capabilities and physically powerful relationships to produce excellent projects. The missions, visions and the values are the key features that provide the competitive edge to the Company (Chongzhi et al., 2013). Benefitting the Company with a worthy revenue generation along with providing equal importance to the shareholders are the most important asset of the Company, which is creating a resonant presence of the Company in the Oil and Gas industries. Vision is something, which motivates the functioning of a Company that varies from company to company producing distinct results (Dissanayake Xia, 2015). The management of the Woodside Company has the vision to be a universal leader in the Oil and Gas industry. Organizational values are of recommendable level in the Company. The management of the Company do trust in different values that matters a lot for an organization to have a long run with comprehensive success under the belt. The management believes in performing a transparent business with the addition of fulfilment of the commitment, which they propose to the people and to the world of business. The management of the Company gives utter importance to the core values of an organizational behaviour, which are truthfulness, admiration, Sustenance, Collaborative working, Discipline and Brilliance. Apart from all the core values of the Company, the three themes that are working as a driving force to the vision of the Company are of supreme importance. Maximising the production based on its supreme capabilities to enhance the revenues is the distinctive feature of the Woodside Company, which has continually helped it, emerged as the top performer. The Company has a proven recor d of accomplishment in the plan, structure and process of brilliant LNG plants, subsea skill, FPSO operations, seismic acquisition, underwater drilling and processing. The establishment of the distant operations from the Pluto Support Centre in Perth is helpful in reducing the working expenses and improving the preservation outcomes(Anon., 2017). Two criticism of its business in past and its outcomes: The Woodside Petroleum Company is the most reputed Oil and Gas Company in Australia. With its distinctive core values and management strategies, it has catapulted the paramount of success in the world of business market (Novatsis McCormick, 2012). Criticism is an integral part of an organization that it receives for some unexpected works. Moreover, the Woodside Company is no any exception, which itself met with little criticism in the past that has hampered the reputation of the Company to a bit. Nonetheless, criticism creates a bad impression of the brand in front of the business world but never destroys the complete existence. There are certain criticism associated with the history of the Company, which has resulted in bad outcomes in past. The one incident of criticism happened back in the year 2006-2007, which revolved around the Pluto LNG project. In carrying this project, Woodside witnessed oppositions on their plans to construct an onto land processing site on the Burrup Peni nsula in the Western part of Australia. Further, the Burrup Peninsula site is providing home to notable petroglyphs, which are approximately 30,000 years old. Woodside claimed to have practised a vigorous amount of violation against the trading policy of the Howard government for the emission of carbon (Al Kindi, 2013). The Company produced different speeches to the common people and the shareholders regarding the carbon emission. It spoke about the carbon free practice in the public but took the otherwise step to get the free carbon permits. No action took place against the Woodside Company for this violating practice from The Australian Consumer Commission(Fields, 2012). Another incident of criticism took place in April 2011 when the Fair Work Ombudsman of Australia complained the mal practice of the Company regarding the labour payment. It claimed that foreign workers were partially paid on the two oilrigs in the North-West shelf of Woodside Petroleum. The same criticism took place in April 2013 when the Federal Court in Western Australia alleged Woodside for underpaying few foreign labours. Less than $3 was the payment for those foreign labours on the oilrigs(Grafton, 2014). SWOT analysis: There are numerous strengths of the Woodside Petroleum Company, which has established the brand new image of the Company in the world of business. It houses the production of distinct quality of Oil and Gas assets in few of the wealthiest basin of the world including the Carnarvon Basin. It is the biggest manufacturer of liquefied natural gas (LNG) in Australia. Handful experience in structure engineering along with subsea structure vessels and tube set barges, they are building their supreme dominance in the Oil and Gas industry. The Company misses on the legal adherence of the government rules regarding the carbon emission along the oilrigs site. The Company unlawfully got the licence of reduced carbon emission. A protest of foreign labours against the payment policy of the Company highlights another probable weak point of the Company(Smith, 2013). Projects development focussing on the expansion of LNG capabilities has the potential to help company in expanding the position of the Company to the worldwide LNG leader. North West Shelf is under development, which can assist the Company in maintaining an offshore and onshore gas supply(Bayzakova, 2014). A wide range of natural calamities in Australia such as floods, bushfires, earthquakes, landslides, severe storms and cyclones are a significant threat to the future of the Company. Nonetheless, competition from its competitors such as China Petroleum Chemical Corporation (Sinopec), ExxonMobil Australia and ROC Oil Co. Ltd. is a serious threat of losing the competitive edge (Wilson, 2013). The Woodside Petroleum in Australia had its association with some legal violation in past regarding the payment of wages to the foreign workers. However, the Company still has lot to offer to its employees, which is evident from the success story of the company. The Company need to put some extra effort in bringing a fair practice of legal adherence to avoid any political clash. The opportunities, which the Company has, require diverse work force to take the charge and produce the fruitful for the Company. However, it requires a gutsy move from the management of the Woodside Petroleum to nullify any political and legal flaws in the Company. PESTEL Analysis: Few of the past incidents related to the organizational behaviours support the fact that the Company is lacking in meeting with the set policies. Incidents such as the underpayment to the foreign labours form the supportive evidence in favour of the policies violation (Vermeire, 2011). The Company is enjoying a healthy rift in their economical structure keeping apart all the criticism that has occurred in the past. Nonetheless, the Company is evolving as the potential choice for the largest manufacturer of LNG in Australia (Sakmar, 2013). Few of the social contributions that the Company is a part of, shows the social awareness of the Company towards the general being. Every year, the Company provides monetary and in-kind support to an extensive range of society groups(Cassidy, 2012). To mitigate the challenges faced by its development managing systems, the Company has formed a fresh side- operational Technology. Downstream technology, upstream technology, superficial technology and Disruptive technology are the key highlights of the inclusion of science and technology in the Company. Nevertheless, these technologies have potentials to help Company in attaining the maximize recognition across the globe (Puckett, 2013). Violation of carbon emission rule set under the government law support the fact that the Woodside Company is environmentally challenging for the lives of human being (Qian, 2012). In April 2013, the allegations made on the Company by the Federal Court of WA speak about the legal violation of the Company. The allegations were for the underpayment to the foreign labours (Hanson, 2012). Woodside Petroleum is the leading company in the OG industry in Australia. However, the Company is lacking in environmental terms as it has tried an illegal way to get the permit on carbon free emission in the past. The Company has also faced criticism in terms of an injustice payment to foreign workers. However, the government did not impose any serious obligations on the Company. Any OG company is a threat to environment and Woodside is no any exception. However, the OG industry do play a vital role in the GDP of a country and affect the economy therefore. The prospering of Woodside is of utmost important for Australia and its economy. However, there is a requirement of taking proper care of carbon emission. It needs some serious effort to ensure that the carbon emission does not surpass the allowed level. Organizational culture or leadership style within the organization: The leadership style of an organization prepares the path of journey, walking on which, it earns the potential result as per the leadership credentials (Bahadori Nwaoha, 2013). With a vision to dominate the world of Oil and Gas industries, the Woodside Company calculated the required leadership quality in the Company. To build up a culture of soaring performance in the Company, which can deliver on consumer requirements, there was requirement to incept leadership quality in the Company (Bayzakova, 2014). Nonetheless, such a leadership excellence that could successfully maintain its employees engaging and energising with the extended expansion goals needs its inception. To attain the vision with the utmost success, hiring of such talents, which have proven records of accomplishment with them, needs their inception in the Company (Hanson, 2012). With their superior understanding of the circumstances, the leadership quality of the Woodside Company engaged in finding out worthy talents. Nevertheless, it resulted in significance organizational outcomes, which structured the success for the Company. Voluntary revenue has reduced by 25% in excess of three years. Environment has bettered considerably in a little gap of time against external and internal benchmarks; in reality, Woodside is delivering at superior levels than further Australian organizations. The high leadership quality has helped its employees understanding the strategies and the business directions. Further, staffs have understood their involvement in the business strategy. Employees feel prepared and energised to perform to the expected targets (Fields, 2012). Conclusion: The superior leadership quality can bring the sense of urgency into its employees, which is helpful in keeping employees engaged with a stretched target of the Company. In this case, the management of the Australian leading Oil and Gas Company Woodside get the spotlight. The Woodside Company whose headquarter is in Perth, serving the Oil and Gas industries in Australia with supreme performance. Nevertheless, the Company has never looked back ever since its inception. However, the Company met with certain political and legal objections for its few policies. Few of the criticism have taken a dig on the Company leaving a dark image on it. The Company claimed to have underpaid few of the foreign labours. The Federal Court of WA imposed the same allegations on the Company. However, this is an undeniable fact that the Company has overcome from this dark shadow and the performance of the Company simply supports the same. Several proposed future targets posses the opportunities to all, which belongs to the Company. The Company lacks in the adherence of the legal policies, which emerges as a potential threat to the Company for their peaceful run in the coming future. The social involvement of the Company by means of taking participation in some kind of donations is preparing a significant supportive environment for the Company. However, the violation of the carbon emission rule of the government is generating an unhygienic atmosphere in the surroundings. Nonetheless, the Company presented a two phase of it in front of their consumers and the shareholders. The Company have committed to keep the environment free from carbon but illegally tried to get the carbon free emission certificate. Nevertheless, in spite of all these dark sides of the Company, there are numerous brighter parts also, which are mounting the heap of success for the Company. References: "Working Sustainably | Woodside Energy". Woodside.com.au. N.p., 2017. Web. 12 Jan. 2017. Al Kindi, A. and Soh, M., 2013, January. Tight gas reservoir appraisal and development challenges for new LNG supply from Australia. InSPE Unconventional Gas Conference and Exhibition. Society of Petroleum Engineers. Bahadori, A., Nwaoha, C. and Clark, M.W., 2013.Dictionary of oil, gas, and petrochemical processing. CRC Press. Bayzakova, A., 2014. The Uncertain Future of Australian LNG Projects: The Use of Scenario Building in Strategic Management. Cassidy, M.J. and Tian, Y., 2012. Development and application of models for the stability analysis of Australia's offshore pipelines.Australian Geomechanics,47(2), p.61. Chongzhi, T., Guoping, B., Junlan, L., Chao, D., Xiaoxin, L., Houwu, L., Dapeng, W., Yuan, W. and Min, L., 2013. Mesozoic lithofacies palaeogeography and petroleum prospectivity in North Carnarvon Basin, Australia.Journal of Palaeogeography,2(1), pp.81-92. Dissanayake, N., Xia, B. and Wu, P., 2015. Measuring Sustainability Performance Within the Australian Energy Industry. InProceedings of the 19th International Symposium on Advancement of Construction Management and Real Estate(pp. 135-143). Springer Berlin Heidelberg. Fields, O.G., 2012. The Wider Contribution to Australia of the Oil and Gas Industry. Grafton, R.Q. and Lambie, N.R., 2014. Australia's liquefied natural gas sector: Past developments, current challenges and ways forward.Australian Economic Review,47(4), pp.509-522. Hanson, B., 2012. The leadership development interface: Aligning leaders and organizations toward more effective leadership learning.Advances in Developing Human Resources, p.1523422312465853. Leather, D.T., Bahadori, A., Nwaoha, C. and Wood, D.A., 2013. A review of Australia's natural gas resources and their exploitation.Journal of Natural Gas Science and Engineering,10, pp.68-88. Novatsis, E., McCormick, P. and Lardner, R., 2012, January. Developing Internal Human Factors Capability In An Australian Oil And Gas Company. InInternational Conference on Health, Safety and Environment in Oil and Gas Exploration and Production. Society of Petroleum Engineers. Puckett, S. and Regan, T., 2013. The Liquefied Natural Gas (Lng) Business: From Evolution To Revolution. InAsia's Energy Trends and Developments: (In 2 Volumes) Volume 1: Innovations and Alternative Energy Supplies Volume 2: Case Studies in Cooperation, Competition and Possibilities from Central, Northeast and South Asia(pp. 125-148). Qian, W. and Zvezdov, D., 2012. Environmental Accountability. Sakmar, S.L., 2013. Global Gas Markets: The Role of LNG in the Golden Age of Gas and the Globalization of LNG Trade. Smith, M., 2013. The Oil and Gas SectorClimate Change Risks and Opportunities. Vermeire, J., The LNG Industry in 2011. Wilson, B., 2013.The biogeography of the Australian North West Shelf: environmental change and life's response. Newnes.

Wednesday, December 4, 2019

Business and Corporate Law New Zealand Law

Questions: 1. What are the Directors duties under New Zealand Law?2. What are the shareholders rights under New Zealand Law?3. In relation to the law of torts, discuss liability for negligent misstatements under common law and current New Zealand law? Answer: 1. Directors duties under New Zealand Law The New Zealand Companies Act, 1993 provides in details all the duties as well as the liabilities that are imposed by the law on the company directors. Generally, the duties of the director are owed directly for the company. Hence the company has the right to sue the director in the case of any breach by the director. However, along with the company the shareholders and the creditors also have the right to sue the director in case of any breach but under different sections (Chiu and Monin, 2003). One of the primary fiduciary duties of the director is to act as an agent of the company. The directors are supposed to act as the agent who would be responsible to take actions on behalf of the company. Hence it can be construed that the relation between the director and the company is similar to that of an agent and principal. Hence accordingly the director holds a position of trust in the company. The second most significant duty of the director is to act in good faith and that acts of the director should be in the best interest of the company. Nonetheless, there exist some obligations related to this duty of the directors. The director can exercise the given powers for the purposes specified for, the director is not allowed to use the funds of the company until he is authorized for the specific purposes. Further the director should always act in a bona fide manner. He should always act in accordance to the laws of the country that is according to the Companies Act, 1993 and also the constitution of the company. The director is also not allowed to trade in any such manner that can put the company at any serious risk and possible loss to the creditors of the company. The director also has some duties with regard to the employees of the company. The director is an employer of the company it is the duty of the director to consider the interests of the employees of the company. The director also has the duty of skill as well as care. When the director acts as the company director all the duties that he or she performs should be done with skill and care. The care, skill and diligence that the director utilizes in the performance of the duties should be similar to any other reasonable man in his place and in the same conditions would have done. However, this standard is comparatively high and while deciding on the each case the judges would consider each case differently the breach would not be considered merely based on the error in the decision (Lehman et al., 2005). During performance of the duties the director also is not supposed to display such skill that may be considered greater than what is expected from a reasonable director with the same experience and skill. In the case of any breach by the director the shareholders have the right to sue him. Collectively, the shareholders have the right to act against the director of the company for any legitimate reason that includes the breach of duties. 2. Shareholders rights under New Zealand Law According to the Companies Act 1993 there are a number of rights and remedies for the shareholders. These rights have been provided specifically under the laws of New Zealand. One of the primary rights available to the shareholder is the right to be bought out. The minorities in the company who dissent can compel the company to buy the shares after they have voted against the significant transactions of the company or any vital amendments to the Constitution or any such important right that is attached to the shares (Sealy, 2003). The second right available to the shareholder is the right to information. Any shareholder of a company has the right to make a written request for any important information to the company. The third right available to the shareholder is that they can claim for any inspection of any record. However, in this regard it must be noted that the records that has been asked for inspection is available in the company. The next right available to the shareholder is the right to question the management regarding any query. It is the board of directors who are to be held responsible for the management of the company. But the shareholders have the right to ask about any query to the directors regarding the management (Farrar, 2001). The next significant right for the shareholder is to approve all the important transactions. Any company cannot enter into any transaction until and unless all the shareholders in the special resolution have approved it. Further the shareholders have the right to sue the director. In case any breach takes place on the part of the director for any duty owed by the director, the shareholder holds the right to bring an action against the director for such breach. Finally, the shareholder also has the right of remedy for any repressive conduct carried out by any person on behalf of the company. Other than these rights of the shareholders, they also have the right to avoid the conditions of the Companys Act if they take any unanimous resolution amongst the shareholders. When the shareholders act together their rights increase and they can permit the company to obtain or trade their shares, or give financial assistance for purchasing shares or authorize the remuneration or benefits of the directors. However, it should be remembered that the shareholders should act together to utilize these rights. Further the company needs to satisfy the solvency test and the directors have to provide a certificate for that. The company also needs to conduct meeting annually. These meetings generally deal with financial reports, elections, director appointments and business resolutions. 3. Liability for negligent misstatements under common law and current New Zealand law A negligent misstatement may be considered to be such a statement of fact that is false and made honestly but in a careless manner. An opinion may also be regarded as a statement of fact incase such an opinion implies that the person making it has reasonable grounds for such opinion (McLay, 2010). It must be noted that for negligent misstatement action can be brought only in the law of tort and such an action arises only when there existed a duty to care while making such statement of opinion and there has been a breach of such duty resulting in the damage to the claimant. With regard to the financial matters there exists no duty of care for such statements. Any person would be responsible for the negligent misstatements only when those statements were made under the conditions which made the other party rely on them. This was stated in the case of Hedley Byrne v Heller Partners Ltd [1964] AC 465 (HL) and also in the case of Caparo Industries plc v Dickman [1990] 2 AC 605 (HL). Unde r such circumstances when a negligent statement has been used to make a person enter into a contract, such a statement may be considered as actionable and a term of contract or else it may result in payment of damages (Waddams, 2010). Under the English law, there were a number of cases which dealt with the issue of negligent misstatement. One of the oldest cases that dealt with this issue was the case of Derry v Peek (Derry v Peek, [1889]). The case was related to the tort of negligent misstatement in cases of pure economic loss. Some of the other issues in the case were fraud as has been given in contract, misrepresentation and fiduciary duty (Davies and Malkin, 2003). The House of Lords had held in this case that there existed no such duty with regard to care and skill with regard to the issuance of any prospectus to avoid the making of any misstatement and especially with regard to economic loss that results from the negligent misstatement (Dias and Markesinis, 1976). Another English law case dealing with this issue of negligent misstatement is Hedley Byrne Co Ltd v Heller Partners Ltd (Hedley Byrne Co Ltd v Heller Partners Ltd, [1964]). This case also deals with pure economic loss which was a result of negligent misstatement. Before this case, the general idea was that any party can owe a duty for caring of statements that is made on reliance. The remedy that was previously available in such cases was in contract law (Burrows, 2007). This idea was rejected in the case and House of Lords introduced the notion of assumption of responsibility. Hence from this case onwards the liability was recognized for economic loss even if it did not arise from the contractual relationship (Witting, 2004). After the decision of the House of Lords in the Hedley (Hedley Byrne Co Ltd v Heller Partners Ltd, [1964]) case, the courts in New Zealand also recognized these negligent misstatements. The difference in New Zealand was that the primary criterion for creating different section for liability in negligence was not mentioned here. Instead New Zealand laws preferred the principle based approach where the criteria was given but it was not considered necessary. The significance of the case in New Zealand was that in case of pure economic loss the liability did exist especially when it is caused as a result of negligent misstatement. One recent case on negligent misstatements is Caparo Industries plc v Dickman (Caparo Industries plc v Dickman, [1990]). It is the recent landmark case on the duty of care. In this case the House of Lords had held that for testing the presence of duty to care in negligence. The test introduced in the case was "three-fold test". According to this test, the harm that is caused must be reasonable and should be foreseen as given under Donoghue v Stevenson (Donoghue v Stevenson, [1932]). Secondly, there should be a proximal relationship between the parties and thirdly it should be fair and reasonable to impose the liability. Laws in New Zealand for negligent misstatements are not exactly as it has been given under the English common law. In this regard, a case may be mentioned. In the case of Scott Group Ltd v McFarlane the Court of Appeal had held that in the case of any negligence to the third party the auditor may be held liable since the audit report was relied upon. The Court had further discussed that the financial position of the Company was poor and there were chances of takeover by another company (Todd and Burrows, 1991). Hence the auditors had the duty towards the company of Scott Group to reveal the truth. Nevertheless, with regard to damages the Court had held that due to the fact that the company had not suffered any financial loss, they would not be entitled to receive any damages. It must be noted that the auditor had provided a disclaimer with regard to the exclusion of liability for the general public that included the Scott Group also. The court had held that the disclaimer was not sufficient to exclude the liability of the auditors in this regard. However, after this case, in most circumstances the disclaimers did exclude the liability to the members. Under the laws in New Zealand, for negligent misstatement another case may be mentioned. In the case of South Pacific Manufacturing v New Zealand Securities Investigations (South Pacific Manufacturing v New Zealand Securities Investigations, [2015]), a common approach was incorporated for the determination of duty to take care under all kinds of conditions. In this kind of approach the court would ask questions with regard to the duty to take care and related inquires regarding the policies and the proximity. It has been generally observed that these claims of negligent misstatement and the ones against public authorities has been observed beyond this approach and it falls under the distinct areas of liability in negligence. However, the contemporary decisions of the Court of Appeal have clarified all queries relating to the duty to care under novel situations which can be resolved by referring to the approach taken by the Court in South Pacific Manufacturing (South Pacific Manufacturing v New Zealand Securities Investigations, [2015]). References Burrows, A. (2007).English private law. Oxford: Oxford University Press. Caparo Industries plc v Dickman[1990]UKHL p.2. Chiu, P. and Monin, J. (2003). Effective Corporate Governance: from the perspective of New Zealand fund managers.Corporate Governance, 11(2), pp.123-131. Davies, M. and Malkin, I. (2003).Torts. Chatswood, N.S.W.: LexisNexis Butterworths Australia. Derry v Peek[1889]App Cas LR 14, p.337. Dias, R. and Markesinis, B. (1976).The English law of torts. Brussels: E. Bruylant. Donoghue v Stevenson[1932]AC p.562. Farrar, J. (2001).Corporate governance in Australia and New Zealand. Melbourne: Oxford University Press. Hedley Byrne Co Ltd v Heller Partners Ltd[1964]AC p.465. Lehman, C., Tinker, T., Merino, B. and Neimark, M. (2005).Corporate governance. Amsterdam: Elsevier JAI. McLay, G. (2010).Torts. Wellington, N.Z.: LexisNexis NZ. Sealy, L. (2003). Corporate Governance in Australia and New Zealand. By John Farrar. [Oxford: Oxford University Press. 2001. xxvi, 472 and (Appendices and Index) 52 pp. Paperback 33.99. ISBN 0195513142.].The Cambridge Law Journal, 62(2), pp.511-513. South Pacific Manufacturing v New Zealand Securities Investigations[2015]NZLR 2 (CA), p.282. Todd, S. and Burrows, J. (1991).The Law of torts in New Zealand. North Ryde, N.S.W.: Law Book Co. Waddams, S. (2010).The law of contracts. Aurora, Ont.: Canada Law Book Inc. Witting, C. (2004).Liability for negligent misstatements. Oxford: Oxford University Press.