The History of Terrorism and Special Forces Research Paper

The History of Terrorism and Special Forces - Research Paper Example An extensive investigation on terrorism has to be carried out especially on the historical background of the US in order to gather a broader perspective about terrorists’ intentions. I strongly believe the research will assist government agencies and legal systems to make timely decisions on how to tackle the deadly threats. The historical background on terrorism dates back to the French revolution (Mitchell, 2010). For the last ten years, however, a dramatic increase in this barbaric act has been observed. To pursue their political agenda they use hijacking, murdering, kidnapping and bombing. Armstrong indicated that modern suicide terror was first noted at an American embassy in Lebanon in 1983 near Beirut (Simpson & Robert, 2004). The group behind the attack was known as Hezbollah, meaning an army of God. The group later led another attack against the French multinational force and the Marine headquarters resulting in the death of 300 people (Bernstein, 2002). The terror attack made western forces to leave Lebanon. A suicide terror attack is presumed to be the most devastating form of terrorism. The terrorists usually use religion to justify their awful acts though the assaults are politically motivated. Hezbollah as I noted uses suicide terror attacks against Israel as a retaliatory apparatus. For example, after their secretary general Abas Musavi was assassinated by Israeli military personnel in 1992, the Hezbollah bombed an Israeli embassy stationed in Buenos Ares (Mann, 2004). Twenty-nine people died while two hundred and fifty people were seriously injured. I also noted that whenever a terror group achieved a political goal their terror activities were observed to reduce. This was a clear indication that the perpetrators were politically motivated rather than being religiously influenced. Islam is also the most dominant religion in the Middle East and terrorists use this opportunity to their advantage. The objective of

Coursework 6 Essay Example | Topics and Well Written Essays - 500 words

Coursework 6 - Essay Example For instance, the physicist Hans Bethe was briefed on SDI in 1983 and his reaction was doubtful that it would work to defend the U.S. (â€Å"Strategic...†). Apparently Soviet scientists had the same reaction. Compared to the U.S., which still spends 4 billion dollars a year on Star Wars, the Soviet Union spent very little on it. The largest cause of the end of the Cold War was Gorbachev, and his dedication to reform. Gorbachev was not afraid to make economic reforms such as glasnost (liberalization), perestroika (reconstruction) and uskoreniye (acceleration of economic reform), even though these reforms were considered radical by apparatchiks (bureaucrats of the Communist Party) in the Soviet government(â€Å"Mikhail...†). Gorbachev democratized much of the Soviet Union and went so far with reforms and freedoms that an unintended wave of nationalism and call for independence was created within the Soviet republics. Eventually Gorbachev was put under house arrest by hard-line apparatchiks and the Soviet Union collapsed, effectively ending the Cold War. The Colombian government has been involved in a civil conflict for four decades with the left-wing rebel group Farc, the Revolutionary Armed Forces of Colombia. Farc rebels recently killed several police with a roadside bomb (â€Å"Colombian Rebels...†). The police were attempting to destroy coca bushes, which are the source of cocaine that finances Farc. Another left-wing rebel group active in Colombia is the ELN, or National Liberation Army. The left-wing groups are blamed for kidnappings, assassinations and extortion. The rebel groups are fought by right-wing paramilitaries such as the AUC, or United Self-Defense Forces of Colombia. Paramilitaries were supported by rich landowners who descend from the Spanish settlers. These right-wing groups are involved in drug-trafficking as well. They are blamed for massacres and torture. The Colombian conflict

Community Support Intervention for Alcohol Abuse

Community Support Intervention for Alcohol Abuse Community support intervention (s) for alcohol abuse in adults living in Glasgow, UK; A Proposal Introduction International perspective on alcohol abuse Alcoholism is a collective term for alcohol related disorders including, but not limited to, alcohol abuse, binge drinking and alcohol dependence (World Health Organisation [WHO], 2016). Global alcohol consumption levels in 2010 were estimated to be 6.2 litres of pure alcohol in persons aged 15 years and above (WHO, 2017). In the United Kingdom, the Health and Social Care Information Centre (2014) recommended that among the adult population group, women and men should not consume more than 3 and 4 units of alcohol a day, respectively. Furthermore, existing evidence trends on alcohol consumption levels indicate that the greater the economic prosperity/wealth of the country, the higher the alcohol consumption levels and thus the lower the number of abstainers among the populations (WHO, 2017). Additionally, statistics from the WHO (2017) indicate that in 2012, approximately 3.3 million recorded deaths globally were due to alcohol abuse, and at least 15.3 million people are thought to have a drug and/or alcohol disorder. Furthermore, 7.6% and 4% of the 3.3 million deaths globally were observed in males and females, respectively (WHO, 2017). Similarly, 139 million disability-adjusted life years (DALYs) recorded in 2012 were associated with alcohol consumption globally (WHO, 2017). Therefore, harmful alcohol consumption is associated with negative health consequences which impact on the quality of life of individuals and their families, as well as society as a whole due to reduced productivity levels and financial costs associated with treating and managing alcohol misuse related conditions (National Institute for Health and Care Excellence [NICE], 2011). Alcohol abuse relative to Scotland In 2007, a joint research undertaken by the Glasgow City Council, Strathclyde Police and NHS Greater Glasgow and Clyde indicated that increased rates of harmful alcohol consumption have been observed across Scotland, with an estimated increase expected in the next decade (Glasgow City Council, Strathclyde Police and NHS Greater Glasgow and Clyde, 2007). The report indicated that at least 20.7% of all hospital admissions in the Glasgow area were associated with harmful alcohol consumption, which was associated with a cost of  £207 million to manage appropriately. In 2015, a survey by NHS Health Scotland, indicated that 1 in 4 Scottish people drink at hazardous levels and about 36% and 17% of men and women, respectively, consume more than 14 units of alcohol each week (NHS Health Scotland, 2015). Furthermore, at least 1,150 alcohol related deaths were recorded in Scotland and 386 of these were women while 764 were males, a figure expected to increase if alcohol misuse is not tackled in Scotland (National Records of Scotland, 2015). Additionally, in those aged between 45 and 59 years, largest proportion of alcohol related deaths are observed each year in Scotland (National Records of Scotland, 2015). Nevertheless, although the statistics indicate that the rates of harmful alcohol consumption have declined over the last few years in Scotland, the rates are on average still relatively higher than those recorded in Wales and England, and therefore more investment in managing alcohol misuse is still a public health priority (Monitoring and Evaluating Scotlands Alcohol Strategy (MESAS) work programme, 2014). Research undertaken by the Information Service Division, NHS Health Scotland (2015/2016) indicated that about 90% and 10% of alcohol related hospital admissions were to either to general acute hospitals or psychiatric hospitals, respectively. Similarly, 48,420 patients are thought to have accessed primary care equating to 94,630 alcohol related consultations in 2012/2013; higher rates observed in those aged 65 years and above (Scottish Public Health Observatory [ScotPHO], 2017). Furthermore, 25% of all trauma patients and 33% of all major traumas in 2015 were associated with alcohol misuse (The Scottish Trauma Audit Group, 2016). In terms of societal costs of alcohol misuse, a report by the Scottish Government (2010) indicated that alcohol related harms cost about  £3.6 million annually in social care, crime, productivity, health as well as wider/indirect costs in Scotland. In addition, at least  £267 million each year is spent by the NHS Health Scotland on alcohol related care, and  £727 million a year on managing alcohol related crimes across Scotland (Scottish Government, 2010). Alcohol policies and interventions are often developed with the main aim of reducing alcohol misuse as well as alcohol related social and health burden (NHS Health Scotland, 2015). Additionally, these policies or interventions may be formulated and implemented at a local, regional, national, sub-national and global level to ensure alignment and consistency of combating alcohol misuse across care settings (WHO, 2017). Nevertheless, the NHS Scotland in joint collaboration with other government bodies such as the Police have expressed a commitment to monitoring and evaluating alcohol misuse in Scotland with the aim of reducing the alcohol related health and social burden (Glasgow City Council, Strathclyde Police and NHS Greater Glasgow and Clyde, 2007). The aim of this essay is to explore the extent of alcohol misuse in Scotland and provide community support to the affected populations through the implementation of a relevant strategy/intervention to reduce harmful alcohol consumption. The epidemiological consideration of alcohol misuse/abuse will be discussed first and thereafter followed with the identification of the relevant strategy or intervention in combi nation with the implementation procedures, monitoring and evaluating its progress, based on a pre-specified assessment criteria/framework, to ensure that it continues to meet the needs of the population affected by alcohol misuse. Epidemiological consideration to exploring the level of alcohol abuse among adults in Scotland. Research suggests that the most effective alcohol interventions and policies are those that have combined measures that address the issue at a population level (WHO, 2007). Nevertheless, national levels should be aligned to local strategies to ensure consistency in the delivery of care/support for alcohol misuse (Faculty of Public Health UK, 2016). Therefore, to initiate a strategy or intervention to combat alcohol misuse in Scotland it is fundamental that the epidemiology of alcohol misuse (such as risk factors, aetiology, incidence, prevalence, prognosis, current service evaluation and the unmet need) is established based on evidence based medical literature which can take the form of systematic reviews or population longitudinal studies or clinical trials (National Institute for Health and Care Excellence, 2011). Furthermore, having a thorough understanding of the needs and priorities of those affected as well as the payors and clinicians need to be put in to consideration prior to initiating an intervention to combat alcohol misuse (Griffin and Botvin, 2011). This can be undertaken by conducting a needs assessment which aims to identify health issues of the patients as well as establishing resource allocation to help plan, and implement a strategy or intervention that meets the unmet need of alcohol abusers (Care Informatio n Scotland, 2015). The health needs assessment should primarily be undertaken by a team of stakeholders representing various relevant perspectives including, but not limited to, healthcare professionals, patients or patient groups and payors with the aim of ensuring that all perspectives to reduce health inequalities have been explored, thus providing confidence that the proposed intervention to combat alcohol misuse will be accessible to relevant persons across care settings (NICE, 2005). Both quantitative and qualitative data are fundamental in identifying and establishing the community profiles of those affected by alcohol misuse in Scotland (NICE, 2014). A qualitative framework enables the researchers to obtain an in-depth understanding of the views and perception of those consuming alcohol at harmful levels and therefore the themed information can be used to shape the focus and implementation of the proposed intervention (Brownson et al. 2009). Additionally, qualitative framework can be utilised in terms of focus groups, audio recordings and one to one interviews across different sample sizes and sample types to ensure generalisability of study findings across adults in Scotland who misuse alcohol (Wilson et al. 2013). On the other hand, quantitative framework helps researchers to decide on what to focus on within the research based on data collected from participants, and thus quantify the data by analysing it in an unbiased and objective manner (Cairns et al. 20 11). Therefore, this will help researchers profile the trends of alcohol misuse in Scotland and provide potential explanations of the observed relationships between analysed variables (Jones and Sumnall, 2016). Therefore, both quantitative and qualitative data should be put in to consideration by the various stakeholders to help make informed decisions on the most appropriate intervention to tackle alcohol misuse in Scotland (Monitoring and Evaluating Scotlands Alcohol Strategy (MESAS) work programme, 2014). The nature of the data to be collected (i.e. primary and/or secondary) is often determined by the research question at hand (NICE CG21, 2010). For example, with regards to alcohol misuse, both primary and secondary data are critical because in combination, the data provide a comprehensive representation of the extent of the alcohol misuse among adults in Scotland, which could be limited if one or the other were to be used to inform policy making (Centre for Reviews and Dissemination, 2008). Furthermore, the hierarchy of evidence is dictated by the nature of the study design informing the evidence, and thus various stakeholders will put different weight to the study evidence obtained from various study designs (Scottish Intercollegiate Guidelines Network, 2015). For example, research recommendations consider randomised controlled trials (RCTS) as the superior study design due to the limited bias associated with the design and exploration of evidence, and therefore evidence from RCTs is considered to be of robust and of high quality (NICE, 2006; Higgins and Green, 2011). Subsequent from the RCTS, the other study designs of interest include cohort studies, case-control, case series and expert, in that order, are considered to be useful in answering certain types of research questions (Centre for Reviews and Dissemination, 2008). Nevertheless, meta-analyses and systematic reviews of RCTs are given more weight in the hierarchy to be able to provide robust data to inform deci sion making. However, it should be noted that conducting a RCT to establish alcohol misuse would be considered unethical by various stakeholders and therefore, qualitative studies or real world evidence studies would be more plausible to explore the concept in detail (National Institute on Alcohol Abuse and Alcoholism, 2017). Therefore, after consideration of the nature/type of evidence in combination with the epidemiology of alcohol misuse among adults in Scotland, a brief intervention that would be considered both clinically and cost effective would be a plausible approach (WHO, 2014). The brief intervention incorporates policy guidelines, training, as well as education on alcohol misuse to help patients and healthcare providers make informed decision on its applicability (Anderson et al. 2009). Brief interventions are preferred over other types, such as alcohol taxation because they aim to provide health and social support to alcohol abusers and thus they are more likely to be motivated to help change attitudes towards harmful drinking (Institute for Alcohol Studies, 2013). Therefore, a plausible intervention should include various phases such as planning, preparing other stakeholders for the intervention, establishing an intervention team, identifying consequences/benefits and harms as well as sharing information on the intervention with the relevant stakeholders and ensure that informed consent from users of the intervention is put in to consideration prior to implementation (Holland, 2016). Monitoring and evaluation of the intervention Monitoring and evaluation of an ABI is fundamental in ensuring that the intervention is fit for purpose and delivers expected outcomes to those in need of care (National Collaborating Centre for Methods and Tools, 2010). Monitoring and evaluation of an intervention follows a set of criteria which measures the effectiveness of the intervention such as the RE-AIM model which aims to evaluate the Reach, Efficacy, Adoption, Implementation and Maintenance (Glasgow et al. 1999). For example, the Reach category puts in to consideration the proportion and characteristics of alcohol abusers that access the intervention and can be assessed on an individual level which aims to provide first-hand information on what patients thoughts are (NICE, 2014). However, given the difficulty in accessing information on the non-respondents it is challenging to establish why the intervention was not deemed essential to suit their needs and therefore, this creates challenges quantifying the cost effectiveness of an intervention that was designed to reach a large proportion of patients (Vogt et al. 1998). Efficacy of the ABI considers the measuring of both positive and negative outcomes to ensure that a balanced evaluation of evidence is assessed on the value of the intervention to individuals who want to reduce alcohol misuse (National Collaborating Centre for Methods and Tools, 2010). Additionally, the ABI should aim to collect behavioural, biologic, and quality of life outcomes which are fundamental in assessing whether patients are benefiting from the program or otherwise (NHS Scotland, 2017). Additionally, it is essential to establish if payors are investing in a valuable intervention, and if healthcare professionals are delivering the strategy correctly or it needs to be adapted for each individual to optimize outcomes (Kaplan et al. 1993). The adoption of the ABI takes in to perspective the proportion of care settings utilising the intervention across Scotland (NHS Scotland, 2017). This could be within the community, hospitals, and work and leisure settings to ensure that the hard to reach populations are given the opportunity to access the intervention without incurring significant costs (Alcohol Focus Scotland, 2017). Although direct observation may provide measurable outcomes, audits, surveys and interviews may provide further evidence to support the monitoring and evaluation of the ABI (Scottish Government, 2017). Similarly, the implementation and maintenance of the ABI is fundamental in assessing the extent to which the intervention has been executed in the real world setting as intended, as well as the extent to which the intervention is sustained over a pre-specified period of time (WHO, 2014). Implementation can be assessed at an individual level, and maintenance may be accessed both at an individual and organi sation level to ensure alignment and consistency in the delivery of the ABI. Nevertheless, the RE-AIM framework across the five categories is not often put in to consideration across settings to evaluate alcohol interventions, and therefore the time points for evaluation of optimal effectiveness of the ABI in Scotland are often dependent on amount of available resource within the care settings which make generalisability of findings across settings challenging to ascertain (Institute for Alcohol Studies, 2013; Scottish Government, 2017). Conclusions Alcohol misuse presents a significant burden on the health and social aspects of adults in Scotland both in the short and long term. Given the quantifiable burden in the alcohol misuse related illness, crime and costs of management, this has necessitated a change in the harmful consumption levels of alcohol in Scotland through the implementation of ABIs in conjunction with national and local policies. The epidemiology of alcohol abuse in Scotland through existing literature from both primary and secondary data sources is key in providing a comprehensive insight in to the alcohol misuse circumstances over time, and how the issue can be addressed.   Likewise, the implementation of ABI across care settings in Scotland ensures that the population at need is given access to care through education and training on the harms of excessive alcohol consumption in the short and long term. Additionally, this ensures that the patients are given the option to receive care, after informed consent, and are able to take control of their care. Therefore, healthcare providers have the duty of care to promoting confidence among alcohol abusers to help them come up with various coping strategies to change their attitudes and behaviours. For those that decline care, the opportunity to access care in the future should be provided, but most importantly their decisions should be respected. The monitoring and evaluation of the intervention should also encompass a set of pre-specified criteria such as the RE-AIM framework to establish effectiveness of the intervention as well as the cost effectiveness of the ABI over time. References Alcohol Focus Scotland. (2017) Alcohol licencing in your community; how you can get involved [online]. [Viewed 28 March 2017] Available from: http://www.alcohol-focus-scotland.org.uk/media/133477/Community-licensing-toolkit.pdf. Alcohol Research UK, 2014. Delivering Alcohol IBA Broadening the base from health to non-health context: Review of the literature and scoping. London. Middlesex University. Anderson, P., Chisholm, D andFuhr, D.C., 2009. Effectiveness and cost-effectiveness of policies and programmes to reduce the harm caused by alcohol. Lancet [online]. 373(06), pp. 2234- 46. [Viewed 28 March 2017]. 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paradigm shift in utopian fiction :: essays research papers

Utopian fiction or the imaginary projection of a perfect society in which all need and want have been removed and conflict is eliminated, has a long history. Sir Thomas More’s Utopia is a focal point in the tradition of the genre, and More’s contemplation of a society removed from daily struggle to a place of ease, has had a powerful and lasting effect on subsequent visions of the future. Dystopian fiction is the natural correlative of this literary mode and presents visions of imaginary worlds in which the worst of all possible social conditions pertains and where all ethical, aesthetic and metaphysical judgments are consequently problematised. A strict definition of utopia would serve no useful purpose; as Nietzsche says, ‘only that which has no history can be defined.’ A utopia always maintains a close and specific relationship with the sociopolitical environment from which it stems. Utopia is thus a game played between the two poles of reality and fiction.( George Orwell, A reader’s guide to essential criticism, edited by Daniel Lea,2001) The term â€Å"utopia† first appeared in the 1516 work Utopia by Sir Thomas More , literally meaning â€Å" nowhere†, it represents the perfect society. Thus, the idea is inherently ironic in that can never be achieved. Utopian Literature of the 20th century stands out / marks out through the relinquishment of the perspective which governed the utopia of past centuries: a positive utopia, confident in institutions and progress- an internal law of utopian genre. In the first years of the 20th century, utopia ceases describing the advantages of progress in the service of community, eliminating individual. In the first half of the 20th century, utopian history is dominated by H.G.Wells’ s work.. His creation marks the transition from one period to another. Social and political themes are still present ,but this time are accompanied by scientific speculation. Characteristic to the 20th century is the next mutation or shifting : political and social regimes are no longer a concern or an interest, but rather the human nature, altered gradually, eugeny or controlled evolution; utopia abolishes history and past, in general, being placed in a parallel present, but in the 20th century, it is planned in the future. Anti-utopia or dystopia continues the tradition of utopia from the point of view of invention and of technique, but it differs regarding intention. Instead of welfare and prosperity, we have despair and misery; instead of flourishing, the end of humanity.

Editing Style in Crash Essay

Paul Haggis’ 2003 film Crash is about Los Angeles citizens with very separate lives. They go through interweaving stories of race, loss and redemption. It shows us how we connect or disconnect with other people. Although we feel separated by a number of factors such as race, class, status or gender we are more connected than we think. The editing used in this film contributes to the over-all theme. Characters involved are a black detective estranged from his mother, his criminal younger brother and gang partner, a white District Attorney and his irritated and pampered wife, a racist white police officer who disgusts his more younger partner, an African American Hollywood director and his wife, a Persian-immigrant father who is distrustful and vigilant of others, and a locksmith who is a Hispanic hard-working family man. A lot of cross cutting is used to connect the different characters together. For example in the end of one scene the door slams. The sound of the door slamming is used to wake up the other person in the next scene. The ending of one scene is pushing a door, and a door opening leads to the next scene. The ending of a scene is a close up of the black detective putting groceries away in his mother’s fridge; the next scene is the District Attorney’s wife talking about grocery shopping. This film uses montage shots so that the overall effect is greater than the individual parts. The length of each shot determines the pace of the action including the change of pace and that affects the mood. The shot of the introduction of each character lasted about the same time. That way we saw the general type of person or attitude each character has. When shots were used to show emotion, the shot lasted a bit longer so that the viewers are able to connect and understand the character. Especially in the scene when the Persian father shot the Hispanic man’s little girl. That went into slow motion and the shot lasted long. The music was sad and dramatic and that shot personally made me cry because I can really feel the pain of the tragedy that just occurred. A scene that sends a message through editing is when the black Hollywood director and his wife were stopped by the white police officer. The white police officer molests his wife and that hurts the couple in many ways. They both become very affected by what happened. Later on in the film the wife gets into a car accident where her car flipped over and gets stuck but needs to get out of the car before it explodes. That event became a turning point in the white officer’s life and changed him. He became the opposite of the man that was introduced to us. This editing plays an important role because it shows us that the same person who hurt us would be the same person that is there in your time of need. The editing used in this film definitely portrays the theme. The techniques used show that all the major events that happened in their lives were caused by each other. People that think that they have no connection with each other actually are connected. The editing used in this film had an important role in sending an important message to the viewers. There may be differences between us but we are all the same, we are all human with feelings and emotions. We are all connected.

Globalization Argumentative Paper - 717 Words

Globalization Argumentative Paper XXXXXXXX PHL/320 05/11/15 XXXXX Globalization Argumentative Paper The term globalization based on business ideas can be defined as the process of extending to other parts of the world to develop an increase in the integrated global economic system from utilizing cheap labor from foreign markets, free flow of capitol, and free trade. This can all be good for business in that it makes operating in foreign markets more efficient. The term good can be defined as having profit, advantage or benefit. Therefore, globalization is good for business in that it benefits the organization by increasing profit in other world markets. (1, Premise) When a business operates in an open†¦show more content†¦Deductive Reasoning I think the best example of deductive reasoning is the general examples that were listed that support the argument that leads to the conclusion that globalization is a good thing. Globalization does more then several things that are beyond question at the end of the day. Firstly, it creates jobs, which is a priority to the econom ic success of any market. And second, it improves infrastructure while also allowing more people to live at a higher global level. I used deductive reasoning by looking at how globalization affects businesses both positively and negatively and weighed out the options. References Baines, H.V., Ursah, J. (2009). Globalization: Understanding, Management, and Effects. Retrieved from The University of Phoenix eBook Collection Data Base. Parker, B. (2005). Introduction to Globalization and Business: Relationships and Responsibilities. Retrieved from The University of Phoenix eBook Collection DataShow MoreRelatedPhl 320 Critical Thinking and Decision Making in Business Complete Class996 Words   |  4 Pagesfrom this course? Write a paragraph summarizing the discussion. 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The Freedom of Establishment - Free Essay Example

Sample details Pages: 9 Words: 2567 Downloads: 2 Date added: 2017/06/26 Category Law Essay Type Analytical essay Level High school Did you like this example? Since the founding of the European Union (EU) one of the main aims has been to create an internal market in order to promote development and economic growth and to offer its citizens an area of freedom, without internal frontiers, in which free movement of persons is ensured[1]. Amongst the basic fundamental freedoms which the TFEU concedes to EU citizens to reach the above mentioned aims is the freedom of establishment. Together with the other freedoms found in the TFEU the freedom of establishment is crucial for the functioning of the EU internal market[2]. Don’t waste time! Our writers will create an original "The Freedom of Establishment" essay for you Create order This freedom is laid down in article 49 and 54 of the TFEU and enables persons, both physical and legal to undertake stable and continuous economic activities in one or more member states (MS). Thus MS have to remove all restrictions for individuals and legal persons who want to maintain a permanent or settled place of business in a MS[3]. For this to succeed the EU has made efforts to harmonise national legal systems especially in the field of corporate law[4]. Due to practical problems, the harmonisation process did not eliminate completely incompatibility problems between MS national corporate laws. Thus, the principle of establishment found in the TFEU has been in great part developed through interpretation by the European Court of Justice (CJEU). There have been a number of cases in front of the CJEU dealing with the right of establishment. In order to try and clarify the scope of freedom of establishment the CJEU has in a number of cases explained how Article 49 and 54 TF EU should be interpreted. The most renowned cases concerning freedom of establishment are, the Daily Mail, Centros, berseering, Inspire Art and Sevic. Right of Establishment The freedom to establish oneself or a company in any MS other than ones own, is a right enshrined in articles 49 to 54 of the TFEU. This freedom compliments freedoms such as the free movement of persons and the freedom to provide services. On paper these freedoms might seem easy to apply but in practice they have proved not to be so much. This is mainly due to the different national legislation and the fear by the States that citizens, including companies may abuse the system. The first paragraph of article 49 TFEU prohibits MS restrictions on the freedom of establishment. Restrictions include both unequal treatment and unjustified obstacles.[5] The second paragraph of the article gives a definition of the freedom of establishment. This is described as the ability to be able to pursue activities at par with nationals of the MS where they are established. One must also analyse what constitutes an establishment. The main elements are a stable and continuous basis on which the activity is carried on. This provision has direct effect, which means that MS must change their municipal law which may be incompatible with the spirit of this article. MS may only restrict such freedom in special circumstances such as to protect public policy, security or health[6]. In order remove any doubts whether such freedom applies also to companies, article 54 specifically puts companies at equal footing with natural persons. This holds as long as a company is formed according to the laws of a MS, is registered and has its principal place of business in an EU State. If these simple conditions are met it is considered to be established in the EU. In the Segers[7] case the ECJ widened this concept to cases where a company did not conduct any business in its place or establishment but did so in anoth er MS through a secondary establishment. The ECJ followed the same line of thought in the Centros case and further widened the scope to cover secondary establishments in the Insurance service case.[8] As discussed further in this assignment, a company is free to establish itself through a primary establishment and has the right to open up secondary establishment. This can be done regardless if this is done just the take advantage of the more favourable legislation in the first state[9]. Harmonisation The EU also tries to harmonise the different national legal systems of its MS. This is done for the better functioning of the EU market. The harmonisation of corporate law is very important in this aspect. The freedom of establishment has been one of the main drivers behind this harmonisation since the law wanted to protect creditors of companies established under different national laws. Harmonisation of national corporate laws was regarded as a necessary balance for the right of establishment[10]. It may be opportune to give a brief idea of the main difference in municipal corporate laws. The main difference is in the way MS decide on the applicable law of corporate institutions. UK, Netherlands, Denmark and Ireland use the à ¢Ã¢â€š ¬Ã‹Å"State of incorporation rule, that is the applicable law is that where the company is incorporated or registered. On the other hand other MS use the real seat theory known also as the sge reel. Although this theory vary from State to State, the main reasoning is that a company is incorporated in that State where the company where it has its main centre of operations[11]. Art 50 TFEU specifically demands that there should be safeguards equivalent to the freedom of establishment for companies within the EU. Thus it clearly emerges that the EU has been trying to find a balance between the freedom granted by the treaty and the creation of a fair and level playing field between companies established in different MS[12] . Obviously harmonisation leads to an amount of security, standardisation and peace of mind and thus creates a fertile environment for economic growth. Companies will be in a better position to make use of the freedom of establishment and expand in other MS[13]. Harmonisation process has been going on since the 1960s with the issuing of the 1st directive. Following this a number of directives have been issued covering various aspects of corporate law. The process proved to be a difficult one especially with the expansion of the EU and the development of complex systems how big companies started to operate. Reaching a consensus has become an impossible task[14]. Thus there has been a shift in approach to a more regulatory system based on creating equal footing. Today the trend is to make company law more effective at national level within an EU framework. Instead from a top-down harmonisation there is the bottom-up approach. It is accepted that some degree of convergence between MS corporate law will help for the better functioning of the market, but this does not necessarily mean that devising a harmonised corporate law is the best way to achieve it. Some experts believe that the EU has to create a framework and then MS have to legislate within that framework. Thus one is creating a competitive environment within MS and companies choose to establish themselves in the MS whose legislative framework suits best their needs. The aim of creating the right environment for economic growth therefore created through competition rather than through uniformity of laws. Case law The shift in approach has not only been in the way EU legislated but also in the way the Courts of Justice of the EU (CJEU) pronounced itself. The lack of an EU regulation and the importance of freedom of establishment have led to numerous cases in front of the CJEU. The first case was the famous Daily Mail (case 81/87). This case concerned a British company Daily Mail that wi shed to transfer its central administration from the UK to the Netherlands without losing their status under British law. The company would still maintain their registered office in UK. The purpose of this move was done in order to enjoy the lower taxes in the Netherlands. The company law of the United Kingdom did allow for this, which means that the UK applied the incorporation theory. However, if the move was done for tax purpose consent was needed from the Treasury. The company claimed that Articles 49 and 54 TEFU (Former Articles 52 and 58 of the EEC Treaty) gave them the right to move its seat without permission and still keep their status as a legal person under British company law. The CJEU stated that Article 49 and 54 TFEU grants companies the freedom of establishment. Companies have the right to secondary establishment in opening up agencies, branches or subsidiaries, company also have the right to incorporate in another Member State[15]. This is however different from when a company want to incorporate in another Member State and keep its legal status as a United Kingdom company. The CJEU said that; unlike natural persons, companies are creatures of the law and, in the present state of Community law, creatures of national law. They exist only by virtue of the varying national legislation which determines their incorporation and functioning[16] Amongst the important principles which the court pronounced itself on during this case was that, under the Treaty, companies have the same rights as individuals do, as regards the right to leave their MS[17]. However, the CJEU also decided that the right of establishment does not include the right of transfer of management and control to another MS whilst retaining an establishment in another MS[18]. Of great importance is the reason which the court gave for such a decision. Laws of MS on the real seat of companies were not yet harmonised and thus different MS will have different views on this. The fact that the Member States use both the real seat and the incorporation theory are to be solved by future legislation This point was once again discussed ten years later in another case, the Centros case. This case concerned a Danish company, Centros Ltd, which was incorporated in the UK. The company wanted to open up a branch in Denmark but the Danish authorities refused on the basis that Centros did not trade or pursue any economic activity in the UK and in fact had its actual seat in Denmark. It meant that Centros had it primary establishment in Denmark and it is therefore an internal affair. The reason for incorporation in the UK was to avoid initial taxes in Denmark which the UK did not impose. The company claimed that according to Article 49 and 54 TEFU they had the right to open up a branch in Denmark regardless if they exercised any economic activity in the UK or not[19]. This time the CJEU decided that it is a right inherent in the notion of freedom of establi shment for a company to choose where to establish itself[20]. Here the courts seem to be favouring the approach of bottom-up harmonisation rather than top-bottom, thus favouring also competition amongst MS and bringing closer the rights of corporate persons to those of ordinary citizens. The CJEU also pronounced itself on the fact of lack of harmonisation amongst MS national laws, which was also mentioned in the Daily Mirror case and said the fact that company law is not completely harmonised in the Community is of little consequence[21]  Such stand was also confirmed in the Sevic Systems case. The CJEU said; It is known, and confirmed by the Courts settled case-law, that exercise of the freedom of establishment cannot be made dependent on the adoption of a directive on harmonisation. That is because these directives do not establish the rights laid down in the Treaty but are merely designed to facilitate the exercise thereof.[22] The CJEU also tackled the Danish claim th at this was just a way of how to circumvent national laws and was an abuse of the freedom of establishment[23]. The court said that MS have the opportunity to rely on other provisions of the law to make sure that no evasion was being carried out, and this within the limits of respect towards the freedom established in article. The Centros case was followed by another landmark case in this field, the berseering case. Berseering was company incorporated in the Netherlands, and owned a property in Germany. The company then commissioned a company to do some repairs on this property. The repairs were done but berseering claimed that the work was defective. Two years later two German nationals acquired the company and they brought action against the German company in a German court[24]. The German court, however, dismissed the claim because ÃÆ'Å“berseering did not have legal capacity of according to German law. Germany applied the real seat theory. The CJEU had to decide was whether or not Article 49 and 54 TFEU was interpreted as giving a MS the right to decide a company ´s legal capacity if it had transferred its central administration there from another MS. Once again the principle of freedom of establishment was given more strength. Harmonisation of laws was not accepted. A company which is incorporated in a MS and according to the laws of that MS, moves its centre of administration to another MS cannot be denied recognition just on the mere fact that it is incorporated in another MS. Once again the CJEU pointed out that there might be instances where such recognition can be restricted but MS have to use proportionality in their decisions and in the case of ÃÆ'Å“berseering, Germany did not[25]. In more recent cases, Cortesio OktatÃÆ' ³ ÃÆ' ©s SzolgÃÆ' ¡ltatÃÆ' ³ bt (2008) and Vale Construzioni SRL (2012) the CJEU confirmed the principles established in the previous case law. Conclusion When dealing with freedom est ablishment of companies it is rather a balancing act between competing interests. Both harmonisation of different municipal laws and judgments by the CJEU have contributed to this balancing act. It seems that the trend today is moving away from harmonisation and more towards legislative competition for the most attractive corporate law amongst MS known as reflexive regulatory techniques. The other option would be what is known as à ¢Ã¢â€š ¬Ã‹Å"negative harmonisationà ¢Ã¢â€š ¬Ã¢â€ž ¢, that is court-led decisions, but even though one would certainly be on the safe side with such a system, it does not mean that this would lead to a better environment for companies. Harmonisation should be seen as a guarantee for diversity in corporate laws and practices of MS. It should be seen as an instigator for innovation in self-regulation by MS of corporate laws which would avoid the rigid form of a single dominant law regime which leads to the Delaware effect in the US. [1] Article 3.1 and 3.2 TFEU as amended by the Lisbon Treaty [2] https://ec.europa.eu/internal_market/top_layer/living_working/services-establishment/index_en.htm [3] Craig. P. and De Burca. G. 2011 pg764 [4] https://www.germanlawjournal.com/index.php?pageID=11artID=216 [5] Craig. P. and De Burca. G. 2011 pg 771 [6] https://ec.europa.eu/internal_market/top_layer/living_working/services-establishment/index_en.htm [7] Case 79/85 Segers [8] Craig. P. and De Burca. G. 2011 pg 780 [9] Wedin. A. pg 14 [10] Mock, S. Harmonisation, Regulation and Legislative Competition in European Corporate Law [11] Ibid pg 15-16 [12] The Future of European Company Law (response to the European Commissionà ¢Ã¢â€š ¬Ã¢â€ž ¢s Consultation), May2012 [13] Mock, s. Harmonisation, Regulation and Legislative Competition in European Corporate Law [14] Deakin, S, Regulatory Competition Versus Harmonisation in European Company Law [15] Case 81/87 The Queen v H. M. Treasur y and Commissioners of Inland Revenue, ex parte Daily Mail and General Trust plc par. 17 [16] Ibid par 19 [17] Ibid par 16 [18] Craig. P. and De Burca. G. 2011 pg 780 [19] Ibid pg 780 [20] Centros Ltd vs Erhvervs-og Selskabsstyrelsen (Case 212/97) par 27 [21] Ibid par 28 [22] Sevic Systems (Case 411/03) [23] Centros Ltd vs Erhvervs-og Selskabsstyrelsen (Case 212/97) para 23 [24] Mock, S. Harmonisation, Regulation and Legislative Competition in European Corporate Law [25] Craig. P. and De Burca. G. 2011 pg 783