Thursday, September 19, 2019

Antony and Cleopatra Essay -- essays research papers

Joseph Innes How does Shakespeare present the sense of opposites or polarities And what is the importance of these to the play? William Shakespeare wrote Antony and Cleopatra around 1606, during the reign of King James  ². The play is a history, set in the time of the Roman Empire many centuries before it was written and based on the well-documented history of Octavius Caesar, Marc Antony and Cleopatra. These characters and their lives were contained in primarily one document: Plutarch's Lives of the Noble Grecians and Romans, which was translated by Sir Thomas North in 1579. In the creation of the play, Shakespeare kept very close to the plot of North’s history although some characters such as Enobarbus are largely Shakespeare’s creations. In the play, Shakespeare creates two completely different, conflicting worlds from which most if not all of the drama and tension is derived from, causing tension between those living in the two ideals of Rome and Egypt. From the very beginning one of the themes of the play becomes very evident to the audience, the conflict between Rome and Egypt. The two places represent a symbolic clash of ideals in the play. Rome is seen as a place of honor and duty and taken very seriously, this is shown through the actions and behaviour of Caesar, a man with huge responsibilities, and even when his associates are celebrating and getting drunk, he does not. As a contrast, Egypt is shown as a place of indulgence and pleasure, shown this time through Cleopatra’s court, where it seems the inhabitants do nothing but indulge themselves with games, wine and sex. These differences in ideals are so great that the people in Rome treat Antony’s indulgence in Egypt with Cleopatra as a taboo â€Å"this is the news: he fishes, drinks, and wastes / The Lamps of night in revel†(1.4.4-5). Caesar’s condemnation of Antony’s behavior is an example of how much he is despised for turning his back on Roman duty. This clash is in some ways an example of Elizabethan perceptions on the differences between East and West, an obstacle that is impossible for Antony and Cleopatra to overcome. Shakespeare personifies the two poles of the world as the people living there. Caesar is seen as the embodiment of Rome, with his rigid sense of duty and honour, and Egypt is presented through Cleopatra with her excessive and theatrical extravagance and free flowing passio... ... and charming towards Cleopatra, although she knows he is merely trying to avoid her committing suicide, so that she can be his trophy. After this meeting, Cleopatra resolves to follow her plan of death and although Rome may have triumphed at face value, the East is in fact presenting its true spirit, Cleopatra is refusing to become anything but herself. This conclusion to the conflict between East and West is needed to provide a satisfying ending to the play, although neither East or West wins, but is left at a stalemate. The West wins over reason and duty, and yet the East has won through emotion and love, the love between Antony and Cleopatra. The polarities between Antony and Cleopatra are huge and arguably impossible to overcome as the conflict and differences between Egypt and Rome would inevitably end in tragedy. Shakespeare uses this as the centre of his drama, and without it would lose its powerful and emotive realism that Shakespeare spent his life perfecting. In this way, the conflict between Egypt and Rome is the most important theme, as from it spawns the differences in honour, reason, emotion and ideals, thus forming the framework for much more drama beyond it.

Wednesday, September 18, 2019

The Impact of Lenin on Russia and the Russian People Essay -- Papers

The Impact of Lenin on Russia and the Russian People Vladimir Ilyich Ulyanov (a.k.a Lenin) was born in 1870, into a middle class family. In the year 1887 when Lenin was 17 his elder brother Alexandra was executed for conspiring to assassinate the tsar. Lenin who was already well educated and fond of reading and writing was encouraged to enter politics to make changes and to somehow avenge his brothers' death. The long term effects of this were that Lenin would later become one of the great revolutionary leaders of all time. Lenin begins to study law and the works of Karl Marx. He is then exiled to Siberia by the authorities as he becomes more politically involved. Whilst he is there he marries another revolutionary in 1898. After this he spends some time travelling abroad with his wife Krupskaya but, he continues to write political material laying down the foundations for revolution and communism in Russia. Lenin is in Britain in 1903 and it is there that he forms the Bolshevik party to help the working class Russians who he has been brought up to have compassion for. The immediate effects of this are the formation of the Bolshevik party. The Long term effects of this are that the Bolshevik party stays in power and Russia becomes a communist country. Between 1903 and 1917 Lenin spends his time moving around Europe. Also at the time he writes pieces for political newspapers and builds the foundations for the Bolshevik party. Lenin spends a great deal of time raising money for the party to enable them to print their revolutionary literature and newspapers such as 'Zvezda'. Lenin uses this time to create the fundamentals neede... ...ere were great improvements in Russia. The results of the N.E.P brought about Trotskys criticism of Lenin. He accused Lenin of being capitalist. Lenin realised that in order to take a giant leap sometimes one must take a couple of paces back first. The creation of the N.E.P brought about the rise of the Russian economy. Lenin and the communist party brought many changes to Russia. Russia had been governed by the tsar and his family for three hundred years. When Lenin gained power he brought about a lot of reforms and in effect modernised Russia to some extent. He also brought Russia through the civil war. The major effects of Lenin on Russia and the Russian people are the introduction to communism in Russia and that he will be remembered as a great leader and had the respect and admiration of a lot of Russian people.

Tuesday, September 17, 2019

Injustice anywhere is a threat to justice everywhere Essay

Injustice refers to either the absence or the exact opposite of justice. The term is applied either in reference to a particular event or even a larger incident. Injustice throughout society today is heard a lot about. People hear about major injustices all the time especially now media access is a lot easier. Many people can also come together and confront one another to either support or contradict these transgressions. This can also be contemplated throughout innumerable historical events and even ones that encourage Martin Luther King Jr.’s proclamation that any place with injustice means it is a portent everywhere else. Children both men and women are held in slavery over the course of the entire trans-Atlantic slave trade. The National Underground Railroad Network to Freedom Act of 1988 directed the National Park Service to commemorate and honor the history of the Underground Railroad. The Underground Railroad was the resistance to enslavement through escapes and flights throughout the Civil War. It also referred to the efforts of enslaved African Americans to gain their equality by escaping bondage. Wherever slavery existed, there was some sort of effort in escaping. While most completed their journey of escaping unassisted, each subsequent decade in which slavery was legal in the United States saw an accumulation in active efforts to reinforce these escapes. The decision to assist a freedom seeker was quite an experience. However, in other places, particularly after the Fugitive Slave Act of 1850, the Underground Railroad was surprisingly organized and even deliberate; seekers spread out into different directions to discuss the important movement in American History as an examination of the areas in which people were enslaved. The power of the word â€Å"injustice† results in many people abusing it and trying to apply it to situations where uninformed people will react by taking their side of the altercation. In the short passage â€Å"Protecting Freedom of Expression on the Campus†, Derek Bok discusses the problem of attempting to reconcile the rights of free speech along with the desire to  avoid racial tension. Derek begins his explanation by using two of his students, one who hung up a confederate flag in public view in Harvard along with having one who protested that same situation by hanging swastika. Oppositions may state that anything that may have been a threat or harm to human life should definitely contain limitations and restrictions. Bok stated how extraordinary perspectives argued by various student groups on the campus were also adding on to express how unique student groups suggested revolving this issue that Bok continued to explain the certain campuses resolving around sim ilar dissensions. â€Å"Freedom is never voluntarily given by the oppressor; it must be demanded by the oppressed.† A nation where most citizens are free to choose their careers, their homes and jobs can be both profitable and content. Having freedom being given freely to the oppressed which means they must fight for their own rights. Most of the time an oppressor benefits from its oppression and the oppressed has to be the first one to set an example of a better situation and then beginning the process of releasing the continuity of oppression. At any rate, it may not be the freedom that â€Å"freedom isn’t free† but it definitely is the basis for it. There is freedom in both social and political senses especially when others abstain from interfering with certain activities that they attend. Freedom in the sense of the inborn capacity to act as people rather than machine figures portray the fact that freedom is free. And that people’s obligations are mostly under a negative connotation rather than a positive connotation in respect to emancipation. In the book, â€Å"The System of Liberty: Themes in the History of Classical Liberalism† by George H. Smith, he discusses the difference between the positive and negative freedom as a huge part of the division between the â€Å"old liberals.† And how the newer liberal comprehension of freedom would require people to do more work instead of initiating force against others because newer liberal-T.H. Green believed that nobody could be free who lacked certain materials. And in order for them all to be free, everybody would be required to submit to the states  demands in the variety forms of taxations and regulations of consensual negotiations. However, oppositions may state that protecting one’s negative social freedom requires usage of scarce resources and in that sense, freedom is not free. Because liberals have spent a decent amount of time proving that new liberalism is founded on a contradiction, that the freedom of one postulates aggressive force upon one another because freedom cannot directly be accustomed; therefore, resulting in people having to work for their liberties. Freedom is not to be given freely because the rights that are already given to us are both significant and immeasurable. In the novel, â€Å"To Kill a Mockingbird† by Harper Lee, Atticus is appointed by the court to defend Tom Robinson-an African American who had been accused of raping a young White woman. Even though many of Maycomb’s citizens disapproved, Atticus continued to defend Tom. And that resulted in having other children taunt two children Jem and Scout by calling them a â€Å"nigger† for the actions that they have made. Scout was tempted to stand up for his father’s honor by fighting even though Scout’s father told her not to. It was also not the proper way to deal with a situation like this so her father did not want his daughter to get into trouble even though she was not treated as an equal. Though others may disagree and state that it was completely Scout’s fathers’ decision to defend the African American, he deserved the decision he made. Scout’s father stood up for Tom Robinson because he knew that he was innocent and he did what he believed was right. And in the end, Tom Robinson gained his freedom by trying to escape from prison because he knew he did not belong there and ended up getting shot. That was his definition of gaining his freedom and it was definitely not free since he practically sacrificed his life.

Monday, September 16, 2019

American Bar Association, Section of Environment, Energy, and Resources Essay

                    The utility that is currently regulated by a regulatory commission or agency is electricity. The state, federal and local agencies regulate electricity that is delivered to the consumers while at the same time determining the rate of return for the utility. One of the major bodies that perform the duty of regulating electricity rates is the Federal Energy Regulatory Commission (FERC) (McGrew, & American Bar Association, 2009). Regulation of electricity as one of the commonly used utility is done by regulatory agencies and authorities that determine the prices that are charged. Apart from the regulation of prices of electricity that consumers are charged, the regulatory authorities also determine the terms of service to the consumers, the budgets and the various construction plans that have been put in place (McGrew, & American Bar Association, 2009).                  Electricity is a crucial utility that needs to be regulated so as to ensure the protection of the consumers from unscrupulous retailers of the utility (McGrew & American Bar Association, 2009). The regulatory rules laid down help in setting the retail rates that are charged on consumers while at the same time helping the retailers to recover the various expenses that they have incurred hence provide them with a rate of return on its capital that can be considered to be â€Å"fair.† Regulation of electricity retail rates by government agencies and regulatory commissions is also faced with the problem of allocating the common costs that are involved in the regulation (McGrew, & American Bar Association, 2009).                  Furthermore, the utility’s rate of return for the retailers is also affected by the politics, whereby this allows latitude that is involved in the setting of rates for the different consumers in the market (McGrew, & American Bar Association, 2009). The regulation by the government as well as the regulatory agencies and commissions also require that the utility serves all the customers as well as be able in planning expansion and additions of facilities for the purpose of anticipating growth in the market (McGrew, & American Bar Association, 2009). Deregulation has been part of the strategy that has been found to have some impact on the supply of electricity as well as the rates charged on electricity supply and distribution.                  According to the â€Å"Federal Power Act† (McGrew, J. H., & American Bar Association, 2009), the wholesale price of electricity in addition to the charges on transmission, needs to be based on the costs of production (McGrew, & American Bar Association. (2009). However, due to deregulation, the FERC tends to accept the prices that are set by the markets as long as the set standards by the agency are met. The main reason for this acceptance of prices set by the markets is to encourage and support competition within the industry and reduce monopoly (McGrew, & American Bar Association, 2009).                  The deregulation of the industry in general makes economic sense in that when there is sufficient competition. Competition within a market helps in the provision of quality service to consumers because each of the suppliers tries their best to attract customers (McGrew, & American Bar Association, 2009). Therefore, it means that the rates charged on consumers will not be as high as when there is monopoly in the industry. The general policy by FERC of wanting to expand the role played by the markets as well as increase deregulation makes economic sense in terms of revenues that suppliers will make as well as a healthy market for consumers (McGrew, & American Bar Association, 2009). Reference McGrew, J. H., & American Bar Association. (2009). FERC: Federal Energy Regulatory Commission. Chicago, Ill: American Bar Association, Section of Environment, Energy, and Resources. Source document

Sunday, September 15, 2019

Mass Tourism Essay

HOW DOES TOURISM IMPACT THE ENVIRONMENT The effect of tourism on the environment can be both positive and negative. Each person or group of people will impact the area they visit in a different way. Whether it is in a negative or positive manner is entirely up to the visitor. Let’s consider the NEGATIVE impacts first: POLLUTION – This is probably the biggest negative factor concerning tourism. People have to travel to their destination. It doesn’t matter if it’s by plane to another country or by car to the local national park, traveling puts emissions into the air. WASTE – People typically use disposable items when they pack for a trip, after all, it’s a holiday and who wants to be bothered with washing dishes or saving scraps for the compost? Landfill here it comes! PHYSICAL DAMAGE – especially to the local fauna and animal habitat. Tromping carelessly through the forest, smashing down delicate flowers and grasses or burning deadfall and destroying habitat for local ground dwelling animals. We may not even notice what we are doing but the local area does. NOISE – may not seem like a big deal, but loud noises can scare animals out of the area and possibly even disrupt the local ecosystem. There are some POSITIVE impacts too: AWARENESS – when people visit an area, they notice things a local person may not. A tourist is more likely to notice a problem like pollution or habitat encroachment and bring it to the attention of local authorities or even the world! EDUCATION – tourists provide an endless supply of people from around the world that can be targeted and educated on everything from forest stewardship to local history and plans for the future. FUNDRAISING – a tourist provides an easy target for fundraising. Tourists pay fees for everything from camping sites and park entry fees, to licenses for fishing and hunting. The more tourists in a controlled area, means the more money that can be collected for things like education, policing and maintenance of national wilderness areas. ACTION – tourists visiting an area do so for many reasons. Maybe they are looking for someplace quiet where they can commune with nature or perhaps they want to see a piece of history. Whatever the reason, when that tourist returns home, s/he will remember the experience and may feel compelled to do something positive for the environment to help save that area. These are only a few ways that a tourist can impact the environment. Your personal impact as a tourist is entirely up to you Case Studies In this unit you have studied how tourism impacts on a range of environments and how the impact of tourism can be managed. In the examination you will be asked about one or more of these environments. The question will be worth five marks on the Foundation paper and eight on the Higher, so you need to revise carefully for these. In this unit you have completed a case study for: 1. A UK National Park or a coastal area e.g. Lake District or Blackpool 2. A tropical destination e.g. Jamaica or Maldives 3. An extreme environment e.g. Mount Everest base camp, Nepal or Antarctica 4. An example of eco- tourism e.g. The Galapagos Islands On the following pages you will find some brief notes about each of the destinations above and some practice case study questions. A UK National Park: Lake District National Park Where is the Lake District and why do people visit? The Lake District National Park is in the North West of England and attracts 14 million visitors every year because it has spectacular scenery – mountains and lakes. There are also lots of opportunities for outdoor activities – hill walking, sailing, mountain climbing and cycling. People also visit the picturesque towns – Ambleside and Keswick to visit major tourist attractions such as Beatrix Potter museum and the pencil museum. What is the impact of tourism? Footpath erosion from the millions of walkers Conflicts between farmers and visitors because they leave litter, gates open, cause fires, create traffic congestion which affects their business and livelihood Traffic congestion as many visitors drive to the Lake District and the narrow country roads are not designed to cope Changes the character of quiet villages if tourists come in large numbers. Visitors can be noisy and might not respect the rural way of life Increased house prices as city folk buy second homes in the country, which make the more expensive for the poorer paid country people. How is tourism managed in National Parks? The National Park Authority is responsible for developing strategies to cope with large numbers of visitors to protect the residents, local economy, businesses and the rural way of life for the future. It does this in a number of ways: Development of tourism has been concentrated on specific sites e.g. Lake Windermere and Keswick in order to protect other areas. These developed areas are known as ‘honeypots’ Countryside footpaths have been reinforced to prevent erosion from the huge numbers of walkers Number of car parks has been increased to take traffic off narrow country roads and to prevent inconsiderate parking Employment opportunities increased for the local population when traditional farming industries are in decline through the development of ‘honeypots’ A tropical destination: Jamaica Where is Jamaica and why do people visit? Jamaica is a tropical island in the Caribbean Sea and is part of a group of islands known as the West Indies. The island receives over a million international visitors each year because it has wide, sandy beaches and attractions in the cities and towns such as bars, museums and theme parks. 8% of the population are employed in tourism and it’s a very important industry to the country because each tourist spends on average US$931 which is a 20% contribution to GDP. What is the impact of tourism? Jamaica is a destination that both benefits and suffers from ‘mass tourism’ Mass tourism is tourism on a large scale to a particular country or area. The destination will be at the development or consolidation stage on the Butler’s life cycle model. Negative impacts include: ï‚•ï€  Using up the little water the country has on swimming pools

Saturday, September 14, 2019

Place and Process for the Promotion of Nike Removable Massaging Insole

In Nike Inc. ’s deliberation of where to physically position and place their new product of a sneaker with removable massaging insole, they can focus on making this product available at main flagship outlets and various retail stores across different cities among countries. Nike Inc. can prioritize mainly the various, almost universally-situated retail outlets known as Nike Town, serving as Nike’s premier product outlet amongst district, states, and nations. Such massive and multi-leveled outlets hold the obvious purpose and reputation of holding a comprehensive merchandise and accessory list and availability. Mall retail stores could also provide the product, but only after great discernment and thought. Nike Inc. must learn to build and at the same time keep the anticipation and buzz for this insole technology. Being that the product is of innovative and break-through orientation, many from sport enthusiasts, athletic foot-wear collectors, and even avid Nike accessorized shoe aficionados themselves may have an already heightened anticipation. Nike Inc. hould identify and foresee the sales requirement enough to provide for the demand of the product but not to the unnecessary point of landing clutter inventory at the said profit nests for Nike’s sneaker insole technology sales and distribution channels. Availability should be kept and maintained at either par or above par but should not be overdone in terms of in-store stock supply. With all of these, Nike Inc. must keenly consider a sense of consistency among the availability of the product. In terms of development of a formidable promotion strategy for the pioneering technological feature found exclusively first in Nike footwear, Nike Inc. hould build a series of promotional business activities for better and over-all brand and product awareness that would affix the company specifically as a sports athletic brand committed in spearheading in-detail inventiveness among products for customer satisfaction. Thus, truly giving note-worthy distinction to the brand’s reputation, in terms of product quality, ingenious product ideas, execution and indeed also on product promotion, separate from other players of the athletic shoe market and industry. The selection of promotional tools for a consumer good such as athletic footwear is still rather traditional, but with an originally unique Nike attribute, an edge could be truly utilized, and the creative envelope can be pushed further for endorsement. However, the objectives of the promotion strategy must be concretely identified and should touch as many bases as possible in terms of reaching consumers. As Kotler explains, â€Å"For consumers, objectives include encouraging purchase of larger-sized units, building trial among non-users, and attracting switchers away from competitors’ brands† (Kotler et al. 2006, p. 620). A good and strong sales promotion strategy â€Å"would have short-run sales impact as well as long-run brand equity effects† (Kotler et al. , 2006, p. 620). Nike Inc. must choose the most fitting means, and with such a revolutionary product, a choice of effective methods can be done. Such activities can range from optimization of handing out fr ee trials at outlets for the customer to acquire firsthand experience on the new product. Since the product is the first of its kind, Nike Inc. ust encourage in-store promotions for these help communicate product benefits, in-person, to the customers. Moreover, ensuring product warranties entails confidence in the product and at the same time conveys a sense of accountability in customer relations. And, also realizing cross promotions and holding sponsorships, and building independent programs for events with evidently sporting and athletic themes are other options to be included as part of the sale promotion program. This is where resourcefulness and ingenuity can be stretched. Nike Inc. ust incorporate the value and indispensability of the product in the customers’ lives through a gathered experience via events. In addition, with a strong and justly experienced advertising expertise, Nike Inc. ’s product promotion could have greater impact. Such potent pair-up is confirmed by Kotler and associates as they mention that, â€Å"Sales promotion seems most effective when used together with advertising† (Kotler et al. , 2006, p. 622). In terms of an initial sales promotion schedule, Nike Inc. must capture interest and awareness from the beginning as the product is launched to the market. The series of promotional endeavors at introduction should be broadly well-built and wide-spreading yet calculated. In-store promotions should be consistent in every outlet where the product is available. From the product’s launch until its maturity, customers must be well-informed of Nike’s insole technology even as the promotions gradually change. For approximately four months as the product is introduced, Nike’s sales promotions will be simultaneous and at its strongest, reinforced by an ample advertising campaign and also a comprehensive public relation program implementation.

Friday, September 13, 2019

A Culture Of Compliance

A Culture Of Compliance What makes a good compliance culture can be deconstructed into multiple components yet it is instantly recognizable. It is strong and functional yet in no way hinders the development of profitable new business and can adapt to market, technological or regulatory change. A good compliance culture is represented across all levels of the organization ensuring a coherent and integrated approach to compliance throughout the company. The essence of how staff, managers and executives interact and work is towards a common goal and value system based on mutual respect, integrity and ethical behaviour focused on the long term health of the business, not just short term gains. In the wake of the financial crisis, good compliance culture and ethics are commonly touted by regulators and governments alike as key to promoting both trust and confidence within the financial system and regulatory bodies charged with their oversight. Equally without the credible threat of regulatory enforcement, it is questionable whether a good compliance culture would be possible. So what are the key ingredients? The framework for organizations that are serious in embedding a good compliance culture within their business is based on the following: Tone at the top: Corporate strategy partnered with legal, risk and compliance Tolerance statements aligned to policy measures and triggers, including swift remediation and proactive compliance risk management Governance and accountability with supervision, discipline and swift investigatory processes tied to performance management Risk assessment, ongoing monitoring, testing and reporting (internal and external) Ongoing Training, guidance and development aimed at all levels of the organization Robust regulatory and active supervisory regime Tone at the Top The tone at the top sets an organization’s guiding values and ethical behaviour. Executive commitment to invest and empower those in compliance, risk and legal resources creates the appropriate oversight and encourages staff to do the right thing. Legal, risk and compliance staff must be viewed as important and critical partners in the business and not simply as support functions. Their views are sought and followed through with respect to new business, operations, business models and planning, pricing and product development. Legal, compliance and risk staff have visible reporting lines into the Board, where breaches for non-compliance are taken seriously and are met with swift investigatory and disciplinary action and accountability. It then follows that the Executive which should include the Chief Compliance Officer, Chief Risk Officer and Executive Legal Counsel are duly qualified, credible leaders and can take action. A corporate strategy committed to compliance, risk and legal requirements must therefore be more than a statement of mere good intentions and must be continuously reinforced. Judy O’HanrahanIt is where the executive takes decisive leadership and ownership of a corporate strategy strongly aligned to regulatory, legal requirements consumer protection providing a safe and fair environment for staff implementing active deterrents of unethical or unlawful activities and protecting institutional assets from data theft, financial crime, fraud or business disruption promoting ethical behaviours that foster respect, integrity, consistency and concern for the organization’s core values. This should be the experience of every employee, from new starter to those that seek to exit. It should be clear to both new and veteran employees that those who represent the core endorsed compliance values and principles are promoted or hired to leadership roles and/or appropriately rewarded. Creating and maintaining the right tone at the top aligned with a corporate strategy partnered in legal, risk and compliance offers can and will increase client and employee retention, ultimately leading to the establishment of a good reputation. Tolerance statements aligned to policy measures A good compliance framework is not only designed to address events as they arise but also to pre-empt them by taking steps to address potential issues. In organizations that have zero tolerance for actions or lack of action that could lead to breaches in compliance, swift, specific, measureable, realistic and time-bound actions are taken by management to address exposures. Limits and warning levels should be built into processes and procedures with clear escalation policies that are adhered to. Notification of breaches and reporting should be well defined and transparent within an agreed structure characterized by a hierarchy up to the Board. Policies are widely understood and followed by staff who can attest to each by aligning their procedures with them and taking an active role in their review through a governance structure. Governance and Accountability In order to foster a good compliance culture, good governance is established through a robust and credible three lines of defense model. The First line All managers and staff take ownership of a consistent compliance approach supported by far sighted incentive structures, where recognition of staff doing the right thing for consumers and for the business and each other is recognized and rewarded and actively promoted. Each business unit has embedded risk and compliance partners who are knowledgeable about their business processes and are senior and independent enough to influence or change behaviours and reward positive outcomes. Primarily accountable for development of controls in tandem with procedures and policies to prevent, detect and respond to compliance failures, they can also test their effectiveness. Middle management are empowered to turn compliance values into practice and encourage employees to come forward with legal, compliance and ethical questions without fear of retaliation, building trust and increased levels of employee engagement. Judy O’Hanrahan Senior leaders hold themselves and others accountable for complying with the ideals of the agreed norms of what makes a good compliance culture. Bad behaviour such as circumventing policy or procedure must have negative consequences. It is clear to all that positive behaviour is rewarded and new recruits are screened against agreed principles and values. Finally, internal issues or matters must be adjudicated with fairness, transparency and integrity, and whistle-blowers are protected when they make a disclosure. The Second line Legal, risk and compliance departments are asking questions about conduct, ethics and culture and not just providing assurance on regulatory and legal technical questions. Their oversight of the effectiveness and integrity of the compliance value system must be established in every aspect of the business. Embedding compliance within the processes and procedures in business units must extend not only to laws, regulations and business principles but to best practice and proactive risk management. Their message must be consistent with that of the business and must be endorsed by the executive. They are seen as critical partners in protecting the reputation of the organization, involved in operational and strategic decisions, testing and compliance monitoring. Chief Compliance Officers play a strategic role in the organization, cultivate the right stakeholder relationships, are trusted advisors to the business, have access to the board, drive and influence the culture and are viewed as authentic leaders and role models. The Third line Audits are measuring the corporate compliance strategy and success of implementation of a good compliance culture based on agreed tolerance statements. An annual compliance charter, plan, policies, monitoring and reporting should be tested for effectiveness and accuracy and process related testing. Employee surveys on culture conducted internally or externally by third parties are helpful in measuring the cultural pulse of the organization. In essence, a good compliance culture is underpinned by good behaviour which must be linked to goals and an incentivized scheme that rewards respect, dignity at work, integrity and trust. Risk assessment, ongoing monitoring, testing and reporting A compliance risk assessment helps an organization understand its risk exposure, prioritize risks, assign ownership and adequately resource and mitigate risks, starting with those that have the highest potential for violations of laws and regulations. The application of a risk methodology based on impact and likelihood identifies the inherent risk combined with controls, highlights the residual risk. This must be authorized and agreed with business partners together with an appropriate response that is monitored and reported up the hierarchy, presented in a dashboard against defined tolerances. Audit and Compliance plans should be complementary and monitoring reviews carried out by risk, compliance and audit serve as an early warning system to potential compliance issues by taking samples of business unit activities, products or output. Ongoing Training, Guidance and Development Individuals will need additional reinforcement on ethics and compliance programs through innovative training or workshops so that staff can connect to the values through Judy O’Hanrahan information sharing and story-telling. New starters, higher risk staff, management and operational staff should have specific training geared towards their needs. Encouraging staff to enrol on professional compliance courses run by external parties and to become industry leaders by participating in external committees or federations contributes to further reinforcing a positive compliance culture supported by external validation. Robust regulatory and active supervisory regime A sharp supervisory approach by an active regulator supports organisations looking to create a positive compliance culture and provides the assurance to consumers that they will be protected. Bernie Madoff’s victims, for example, would wonder how did regulatory agencies such as the SEC, FINRA, which are charged with monitoring financial institutions, fail in their supervisory duty to uncover the largest Ponzi scheme in history. After all, there were warning signs and tip-offs that were ignored, missed or misunderstood. Examiners had sat in Madoff’s offices for two months in 2005 without a complete understanding of the firm’s activities. Regulators who understand how these organisations operate and are able to unravel what appear to be complex activities promote ethical behaviour and protect consumers. By focusing on matters associated with good corporate governance and operational risk with a credible threat of enforcement wake organisations up to the realities that created the perfect storm that was the financial crisis of 2008. In conclusion, organisations with a good compliance culture create lasting relationships with clients, customers, employees and suppliers. This ultimately leads to a good reputation in the market and a positive brand that in turn will attract long term investors. It is evident from scandals involving high profile companies such as Madoff, Enron or Anglo-Irish Bank that implementing and maintaining a positive compliance and ethical culture ensures organisational survival and contributes to the stability of the financial system, something that regulators recognize and are therefore scrutinizing as part of their supervisory regime. It is a reciprocal relationship between organisations and their regulators. Without the credible threat of regulatory enforcement extending to personal liability of senior management, compliance and ethics may be mere check the box exercises or seen as obstacles to new business. Nonetheless, organisations that encourage mutual respect, dignity at work, integr ity and honesty among staff and management lay the foundation for not just a good and positive compliance culture but a truly sustainable work environment that is recognisable by its outperformance and endurance.