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first_imgIreland Blyth Limited ( listed on the Stock Exchange of Mauritius under the Financial sector has released it’s 2007 annual report.For more information about Ireland Blyth Limited ( reports, abridged reports, interim earnings results and earnings presentations, visit the Ireland Blyth Limited ( company page on AfricanFinancials.Document: Ireland Blyth Limited (  2007 annual report.Company ProfileIreland Blyth Limited is a company based in Mauritius and operates as a subsidiary of Compagnie d’Investissement et de Développement Limitée, since its acquisition in 2016. The company has running activities in the sectors of commerce, engineering, financial services, logistics, aviation, shipping, retail, and seafood and marine where services in the distribution and marketing of products such as frozen foods, pharmaceuticals and wellness products, and medical equipment, as well as offers warehousing and logistics support services are provided. Ireland Blyth Limited also supplies industrial chemicals and equipment, as well as engages in crop protection, agriculture, and irrigation systems, the sale of construction and material handling equipment. The company also provides solutions for electrical installations, refrigeration equipment, power management systems, construction tools, abrasives, and building materials, as well as provides mechanical, electrical, plumbing, and fit out solutions. Ireland Blyth Limited is listed on the Stock Exchange of Mauritius.last_img read more

first_imgAG Leventis Plc ( listed on the Nigerian Stock Exchange under the Industrial holding sector has released it’s 2012 annual report.For more information about AG Leventis Plc ( reports, abridged reports, interim earnings results and earnings presentations, visit the AG Leventis Plc ( company page on AfricanFinancials.Document: AG Leventis Plc (  2012 annual report.Company ProfileThe A.G. Leventis Group is a leading manufacturing and distribution company in Nigeria and West Africa supplying a variety of products and services across a range of industries including general dealerships, motor dealerships and real estate. The company has business interests in supplying power and gas products, consumer foods and bakery products and printing supplies as well as offers products and services for the real estate, hotel and commercial vehicles sectors. AG Leventis (Nigeria) Plc operates through a number of subsidiaries; Leventis Foods Plc, Leventis Motors, Abuja (Capital Motors) Plc, Mainland Hotels, Leventis Real Estate, Druckfarben Nigeria Plc and Chrisstahl Nigeria Plc. The company was established by Chief AG Leventis in Ghana in 1937 and mainly supplied local and imported textile products. It devolved into Leventis Motors Plc, Leventis Stores Plc, Leventis Technical Plc whilst it retained ownership of valuable freehold and leasehold property throughout Nigeria. Through a series of mergers and schemes of arrangement, the independent companies were dissolved and AG Leventis (Nigeria) Plc was established. The company’s head office is in Lagos, Nigeria. AG Leventis (Nigeria) Plc is listed on the Nigerian Stock Exchangelast_img read more

first_img See all posts by Alan Oscroft Simply click below to discover how you can take advantage of this. Alan Oscroft | Saturday, 15th May, 2021 “This Stock Could Be Like Buying Amazon in 1997” Our 6 ‘Best Buys Now’ Shares Image: GlaxoSmithKline The best UK biotech shares to buy in 2021? Click here to claim your copy now — and we’ll tell you the name of this Top US Share… free of charge!center_img Enter Your Email Address Renowned stock-picker Mark Rogers and his analyst team at The Motley Fool UK have named 6 shares that they believe UK investors should consider buying NOW.So if you’re looking for more stock ideas to try and best position your portfolio today, then it might be a good day for you. Because we’re offering a full 33% off your first year of membership to our flagship share-tipping service, backed by our ‘no quibbles’ 30-day subscription fee refund guarantee. I would like to receive emails from you about product information and offers from The Fool and its business partners. Each of these emails will provide a link to unsubscribe from future emails. More information about how The Fool collects, stores, and handles personal data is available in its Privacy Statement. Alan Oscroft has no position in any of the shares mentioned. The Motley Fool UK has no position in any of the shares mentioned. Views expressed on the companies mentioned in this article are those of the writer and therefore may differ from the official recommendations we make in our subscription services such as Share Advisor, Hidden Winners and Pro. Here at The Motley Fool we believe that considering a diverse range of insights makes us better investors. I’m sure you’ll agree that’s quite the statement from Motley Fool Co-Founder Tom Gardner.But since our US analyst team first recommended shares in this unique tech stock back in 2016, the value has soared.What’s more, we firmly believe there’s still plenty of upside in its future. In fact, even throughout the current coronavirus crisis, its performance has been beating Wall St expectations.And right now, we’re giving you a chance to discover exactly what has got our analysts all fired up about this niche industry phenomenon, in our FREE special report, A Top US Share From The Motley Fool. The global pandemic has brought UK biotech shares into the spotlight. And I’ve been looking around the sector to see if there are any I might want to buy now. Some are almost certainly overpriced. But there are good companies out there that I might buy on any future dips.I’ve recently examined e-Therapeutics. The company develops software-based drugs assessment technology. For its new pandemic project, the firm aims to “identify approved and known drugs that could rapidly be repositioned for the treatment of Covid-19.” Anything that speeds up that process could be in great demand in the future. But with the shares up 1,000% in two years, it’s expensive and not a UK biotech share I’d buy now.5G is here – and shares of this ‘sleeping giant’ could be a great way for you to potentially profit!According to one leading industry firm, the 5G boom could create a global industry worth US$12.3 TRILLION out of thin air…And if you click here we’ll show you something that could be key to unlocking 5G’s full potential…Another soaring Covid-related share priceAvacta Group shares are up over 800% over two years too and, again, I think that’s too rich for now. But I expect better buying opportunities in the future. It’s another company whose technology I like. It appears to have one of the best Covid-19 lateral flow tests, which it hopes will be on the market very soon. With an increasing number of competing products though, and with the rapid pace of development in the field, I’m waiting to see what the next few months bring.A fishy UK biotech shareUK biotech shares are pretty much dominated by coronavirus research at the moment. So how about Benchmark Holdings as an alternative? Forget viruses, Benchmark is into fish. The company researches fish genetics for improving strains and raising disease resistance. And it has divisions focusing on specialised foods and treatments for aquatic diseases.The share price hasn’t done much over the past five years, but it’s been picking up since the start of 2020. The downside though is that Benchmark isn’t currently profitable. But I’m putting it on my watchlist as a potential buy, and I’ll do some more research.There’s another UK biotech share that piques my interest, and it’s another that’s not doing Covid stuff. It’s still medical though, and researches treatments for diseases that affect the brain, immune system and gut. I’m talking of PureTech Health, and I see its structure as helping alleviate risk. PureTech does some of its own research, but it’s also a stakeholder in the Founded Entities group of nine companies involved in complementary research. We’re looking at a somewhat elevated share price, mind. PureTech is up 180% over five years, but it has been dipping of late. It’s definitely another I’m watching.An unmissable candidate?No list of UK biotech shares would be complete without Oxford Biomedica. Yes, we’re back to a company involved in Covid research — it played a big part in developing the AstraZeneca vaccine. But the company partners big pharma companies in research into other gene and cell-based therapies. The shares are up only a modest 49% over the past two years, so we’re not seeing the same pandemic-driven spike that’s pushed some to stratospheric levels.I like the look of all these companies, though I’m not sure I’d buy any right now, especially not the really big climbers. But I’d like to add a biotech stock to my portfolio, and I’m watching all of them.last_img read more

first_imgLATEST RUGBY WORLD MAGAZINE SUBSCRIPTION DEALS Dropkick the hangover – North EgmontThe visitor centre here houses displays of the European and Maori history of Mount Taranaki as well as information on historic volcanic activity and ecology of the area. A small café eases the stay and DOC retail staff can help with track information and weather updates. Nearby the viewing platform offers stunning views of the region. NEW PLYMOUTHPre-match jaunt – Dawson Fallscenter_img There’s a range of walks from the Dawson Falls Visitor Centre. One short steep descent through rainforest takes you to the base of Dawson Falls from Manaia Rd. Or get a taste of mountain scenery on an easy track through ‘Goblin Forest’. Begin at the picnic area above the visitor centre and follow signs. After 450m the track reaches a series of stairs from where it continues on to Wilkies Pools. Return via the same route.last_img read more

first_img Free webinar for job seekers on best interview answers, hosted by Goodwill June 11 The VOICE of InspirationBy Don LindseyApril 21st is a special day for our family because my father and middle son share a birthday. This year my dad will turn 86 and our son will turn 15.  While I look forward to the celebration aspect of their day (because who doesn’t love ice cream and cake?), I am also finding that I’m feeling very grateful for having these two gentlemen in my life.My earliest memories of my dad all involve learning some sort of lesson.  He was constantly teaching, pointing things out to me and encouraging me to learn from my mistakes.  Sometimes it was school related, and other times it was sports related, but no matter what the topic of conversation was, he wanted to make sure that I was learning as much as possible.I wish that I could say that I followed all his advice to the letter, but truthfully, I didn’t listen very often and would always end up wishing that I had.  I am happy to report now, however, that a lot of what he taught me are things that I apply to being a dad myself.  I’ve taken his lessons and fused it together with my mistakes so that my children can both learn from those mistakes and take away my father’s wisdom with them.  Having him and my mother living with us now is a wonderful thing and part of that is having the ability to lean on them for advice in the parental department.When I think of my stepson, I immediately think that time flies by way too quickly.  It was a little under 7 years ago that I first met this young man and as soon as I was introduced to him, I was amazed to find out that he has a very investigative mind that is always looking for answers to all kinds of questions.  I was also impressed with his desire to be helpful and to make folks happy.  I’ve seen him grow up a lot in the last 6 and a half years literally as he is as tall as I am now, but he’s kept that kind soul and the thirst for knowledge that he’s always had.Whether he’s taking things apart to see how they work or buying me a video game that he thinks I’ll enjoy with his own money, I see the qualities in him that I didn’t have or even understand until I was much older.  I cherish our talks on everything from politics to games to pretty much anything.  He continues to be one of the most intelligent people I know and I’m very grateful that I get to watch that intelligence cultivate daily.You would think that having to share a birthday would be a bit of a bummer, but we have a couple of those dueling birthdays and we have a lot of fun with them.  On the day that I’m writing this my dad and son have their celebrations going on and while the double cake and ice cream will be awesome, I’ll also be celebrating the gratitude of having these two guys as important pieces of my life. Don Lindsey is a follower of Christ, son, husband, father, and a survivor.  Originally from Dayton Ohio, and resident of Apopka for six years, Don sees his life as a dedication to his wife, parents, children, and community. Support conservation and fish with NEW Florida specialty license plate Family! What a blessing. Time passes, and then too soon those dear ones that blessed us are gone. As your father and mother has taught you now it is your turn to pass on their wisdom. I miss my father and mother so very much. I wish I could tell them how much I love them just one more time but… As your parents have blessed you it is now your turn to bless. Hug them, love on them, treasure them now for tomorrow comes on swift feet my young friend and the inevitable waits just around the corner. God bless you all, Chaz Reply Share on Facebook Tweet on Twitter April 22, 2018 at 8:16 am charles towne Please enter your comment! 2 COMMENTS The Anatomy of Fear Don Lindsey April 22, 2018 at 11:14 am Please enter your name here LEAVE A REPLY Cancel reply TAGSDon LindseyInspiration Previous articleTemper, temper…Next articleThwarting violence in an “us vs. them” society Denise Connell RELATED ARTICLESMORE FROM AUTHOR Reply Yes sir, I am very blessed to have my folks in my life. A lot of people don’t get the chance to have their parents in their everyday lives the way I do, so the opportunity is not lost on me. Thanks for the comment Chuck and God bless! You have entered an incorrect email address! Please enter your email address here Save my name, email, and website in this browser for the next time I comment.last_img read more

first_imgNews UpdatesIn The Guise Of Strike Workers Cannot Resort To Strong Arm Tactics To Intimidate Management: Kerala High Court LIVELAW NEWS NETWORK26 Feb 2021 5:52 AMShare This – xKerala High Court has observed that there cannot be any doubt that the workers have the right to resort to strike to effectively bargain with the management. However, under no circumstances can the workers resort to violence to further their cause as the same would infringe the rights of the concerned organization to carry on their business. The remarks come in a writ petition filed…Your free access to Live Law has expiredTo read the article, get a premium account.Your Subscription Supports Independent JournalismSubscription starts from ₹ 599+GST (For 6 Months)View PlansPremium account gives you:Unlimited access to Live Law Archives, Weekly/Monthly Digest, Exclusive Notifications, Comments.Reading experience of Ad Free Version, Petition Copies, Judgement/Order Copies.Subscribe NowAlready a subscriber?LoginKerala High Court has observed that there cannot be any doubt that the workers have the right to resort to strike to effectively bargain with the management. However, under no circumstances can the workers resort to violence to further their cause as the same would infringe the rights of the concerned organization to carry on their business. The remarks come in a writ petition filed by Bharat Serum Vaccines Limited, against intimidatory tactics used by some of its employees and the Trade Union, after they were transferred to a unit out of the State. A Single Bench of Justice Raja Vijayaraghavan V. observed, “There cannot be any doubt that the workers have the right to resort to strike or dharna to effectively bargain with the management and to ensure that unfair labour practices are avoided. However, in the guise of a strike, the union leaders as well as the striking workers cannot resort to strong arm tactics and violence to intimidate and force the management to succumb to their demands.” Background It was the Petitioner’s case that in the month of October, 2020, on account of administrative reasons as well as business exigencies, they had to redeploy their Territory Branch Managers to other parts of the country. They submitted that the service conditions clearly state that the employees are transferable, and most of the employees accepted the transfer and joined the respective Stations. However, three employees refused to oblige. Thereafter, with the aid of the Association of Medical and Sales Representatives, the said three employees caused obstruction to the managerial staff, Regional Business Managers and Sales Representatives in carrying on their business. The Petitioners further informed the Court that the Respondents as well as the Union raised an open threat that they will not let the company to carry on its business activities in the State unless the Respondents demands are met with. However, no action was taken by the Police authorities on a complaint lodged in this regard. The Petitioners had therefore sought a direction to the concerned authorities to afford sufficient protection to its managerial/supervisory officers and field staff as to enable them to perform their duties without being obstructed or threatened in any manner. Findings The High Court has made it clear that the right to strike does not mean that a worker is entitled to obstruct the working of an organization. It held that even if the demand of the workers is legitimate, and even if the management do not accede to such legitimate demand, the only option is to resolve the dispute in a manner known to law. It observed, “Under no circumstances can the respondents resort to violence to further their cause. That would infringe the rights of the petitioners to carry on their business.” On this note, the Bench made interim protection granted to the Petitioners, absolute. It further permitted them to approach the jurisdictional police station, if any threat or intimidatory tactics are adopted by the Respondents. Case Title: Bharat Serum Vaccines Ltd. & Ors. v. State of Kerala & Ors. Click Here To Download Order Read OrderNext Storylast_img read more

first_img By Jaine Treadwell Book Nook to reopen Troy falls to No. 13 Clemson By The Penny Hoarder The Penny Hoarder Issues “Urgent” Alert: 6 Companies… Pike County Sheriff’s Office offering community child ID kits Published 7:58 pm Wednesday, September 2, 2009 Sponsored Content Email the author Hussey leads ‘Walk to remember’ Print Article In 1995, Ann Marie Hussey participated in the Alzheimer’s “A Walk to Remember” in honor of her dad, Ray Hickman. In 1996, she walked in memory of him.“Alzheimer’s is a terrible disease because you lose your loved-one twice,” Hussey said. “You lose them to the disease and then you lose their body to death. They lose their dignity and their pride. They lose everything. It’s just so sad. It’s hard to explain. I just can’t do it.”Hussey met Kay Jones, executive director of the Alzheimer’s Resource Center in Dothan, in Aug. 1995 when her dad was in the nursing home. “I’m an only child and Kay realized that I didn’t have anybody to talk to,” Hussey said. “She was an only child caring for a parent with Alzheimer’s like I was. She was a great help to me and I want to be a help to others.”Because she knows how devastating Alzheimer’s is to the family of the victim, Hussey does all that she can to help others along the dark journey,She is the facilitator of the Pike County Alzheimer’s Support Group and also the captain of the Oak Grove United Methodist Church’s A Walk to Remember team. “The caregivers in our support group are so involved with their loved ones that our group is not meeting right now,” Hussey said. “But, I’m available to them at all times and they know they can call me at any hour. I’m also available to provide information to anyone who needs information about Alzheimer’s. I can get them started in the right direction and what their next steps should be. I’ll do all that I can to help because I know what it’s like to be where they are.”Hussey and the Oak Grove UMC A Walk to Remember team will participate in the annual Walk to Remember on Oct. 3 at Westgate Park in Dothan and they invite others to join them in raising funds in support of the victims and caregivers of this devastating disease.“The members of Oak Grove have been behind me all the way,” Hussey said. “When my dad was diagnosed, I went in church and told them about the Walk and that I was going to participate. Seven of them said they wanted to walk with me. Every year, since then some of them have walked with me.”Each member of the team raises his or her own money. Hussey solicits sponsors and also has four yard sales a year that are fundraisers for the Alzheimer’s Resource Center in Dothan. Around the WebMd: Do This Immediately if You Have Acid Reflux (Watch Now)Healthy LifestyleIf You Have Ringing Ears Do This Immediately (Ends Tinnitus)Healthier LivingHave an Enlarged Prostate? Urologist Reveals: Do This Immediately (Watch)Healthier LivingWomen Only: Stretch This Muscle to Stop Bladder Leakage (Watch)Healthier LivingRemoving Moles & Skin Tags Has Never Been This EasyEssential HealthTop 4 Methods to Get Fortnite SkinsTCGThe content you see here is paid for by the advertiser or content provider whose link you click on, and is recommended to you by Revcontent. As the leading platform for native advertising and content recommendation, Revcontent uses interest based targeting to select content that we think will be of particular interest to you. We encourage you to view your opt out options in Revcontent’s Privacy PolicyWant your content to appear on sites like this?Increase Your Engagement Now!Want to report this publisher’s content as misinformation?Submit a ReportGot it, thanks!Remove Content Link?Please choose a reason below:Fake NewsMisleadingNot InterestedOffensiveRepetitiveSubmitCancel “People know that all of the money I get from the yard sales go to the Walk and many of them bring sale items for me,” she said. “Sometimes, I don’t even know who brings them. I’ll just find a sack of things on the doorstep. People have been very supportive. I don’t think there are many people that don’t know someone that has been affected by the disease.”The funds raised by A Walk to Remember are used to provide support packets to caregivers in the resource center’s 22-county area and to provide respite care.Anyone who would like to make a donation to A Walk to Remember through the Oak Grove United Methodist Church team may do so by dropping a check off at Curves in Troy. Checks should be made to the Alzheimer’s Resource Center A Walk to Remember.For more information, call Hussey at 566-1819. You Might Like GES Money Mania in full swing Goshen Elementary’s Money Mania kicked off on Monday. According to Traci Shaver of the school’s Parent Teacher Organization, Money Mania… read more Remember America’s heroes on Memorial Day Skip Plans underway for historic Pike County celebration Latest Storieslast_img read more

first_img Book Nook to reopen Published 3:00 am Saturday, February 25, 2017 Penny Hoarder Issues “Urgent” Alert: 6 Companies Are… Troy falls to No. 13 Clemson Print Article “But this was different,” he said. “It was a glowing green light that went across the sky for several seconds and it exploded and there was this loud noise. I’d never seen anything like that.”Floyd said on Monday morning there were several Facebook posts from others who had seen the green streak of light and heard the sonic boom.“We saw something real unusual. We just want to know what it was,” he said.Pike County Sheriff Russell Thomas said his office received several calls from around the Shellhorn area Saturday night and he even got calls at home. Green, glowing light lends mystery to night sky By Jaine Treadwell Email the author You Might Like Downtown hosts open mic event today Local artists are invited to another “open mic” night in Downtown Troy this weekend. The event, coordinated by the Downtown… read more Plans underway for historic Pike County celebrationcenter_img Pike County Sheriff’s Office offering community child ID kits “The calls reported strange lights in the sky and a loud noise,” Thomas said. “There was a call that a large fireball had struck the ground. We dispatched deputies out to Highway 29 toward Luverne but no evidence was found of anything striking the ground.”Thomas said he, also was told that there were several posts of  “sightings” on Facebook.A meteor is a small body of matter from outer space that enters the earth’s atmosphere. It becomes incandescent as a result of friction and appears as a streak of light.Thomas said the light in the sky Saturday night was probably a meteor that was more than just a flash in the night. “Some people just got lucky and got to see it,” he said. Latest Stories Remember America’s heroes on Memorial Day “The streak of light went from east to west, almost parallel to the highway,” Floyd said. “It went right over a cotton field that was empty so you could see it all the way.”“The boom sound like a jet breaking the sound barrier, only louder. About 20 minutes later, we heard another boom, only not nearly as loud. We saw it and heard it.  All three of us.”Floyd said he has seen meteors or falling stars before but only as quick streaks of light. Sponsored Content By The Penny Hoarder Around the WebMd: Do This Immediately if You Have Diabetes (Watch)Blood Sugar BlasterIf You Have Ringing Ears Do This Immediately (Ends Tinnitus)Healthier LivingHave an Enlarged Prostate? Urologist Reveals: Do This Immediately (Watch)Healthier LivingWomen Only: Stretch This Muscle to Stop Bladder Leakage (Watch)Healthier LivingRemoving Moles & Skin Tags Has Never Been This EasyEssential HealthGet Fortnite SkinsTCGThe content you see here is paid for by the advertiser or content provider whose link you click on, and is recommended to you by Revcontent. As the leading platform for native advertising and content recommendation, Revcontent uses interest based targeting to select content that we think will be of particular interest to you. We encourage you to view your opt out options in Revcontent’s Privacy PolicyWant your content to appear on sites like this?Increase Your Engagement Now!Want to report this publisher’s content as misinformation?Submit a ReportGot it, thanks!Remove Content Link?Please choose a reason below:Fake NewsMisleadingNot InterestedOffensiveRepetitiveSubmitCancel Adam Floyd was burning trash on his property on the Shellhorn Road Saturday night when he saw a green, glowing light streak across the sky followed by a loud boom that seemed to shake him to the core.“It was somewhere between 9:30 and 10 o’clock Saturday night,” Floyd said. “It was such a bright light that I looked up as it streaked across the sky – probably for about seven or eight seconds. It looked like it blew up at the end and there was a loud boom, like the hard rumble of thunder. It illuminated the sky. It was cool.”Floyd had witnesses to the heavenly event. His friends, Molly Reeves and Richard Austin, saw the glowing, green streak of light and heard the loud boom.last_img read more

first_imgKABCBY: ROSA SANCHEZ, ABC NEWS(LANCASTER, Calif.) — A Lancaster, California, man has been arrested for allegedly killing and decapitating his son and daughter, police said.Firefighters initially responded to a possible gas leak at the house in the 45000 block of Century Circle after 7:30 a.m. Friday. Upon entering, they discovered the bodies of a 12-year-boy and 13-year-old girl, the Los Angeles County Sheriff’s Department said in a news release.L.A. County Sheriff’s Department Lancaster Station deputies were immediately summoned to the scene, where they “learned that the deceased male and female both appeared to be suffering from lacerations and stab wounds,” the release states.On Twitter, the LASD announced that homicide detectives responded to the 45000 block of Century Circle regarding the death of two victims. The victims were pronounced dead at the scene.One male and one adult female were also found at the house, along with two other children who were questioned by homicide investigators Friday afternoon.The relationship between the victims and the other four people found in the house is still unknown.Detectives arrested Maurice Taylor Sr., who police described as a Black 34-year-old male, for “the murder of his 12-year-old son and 13-year-old daughter.”He was booked at Lancaster station and is being held with a bail of $2 million.The investigation is ongoing.Copyright © 2020, ABC Audio. All rights reserved.last_img read more

first_imgNot in your backyard?On 1 Sep 2003 in Personnel Today Related posts:No related photos. Previous Article Next Article Comments are closed. Whendoes an employer’s responsibility for its staff’s actions end? Recent casessuggest they face increasing risks of being found liable for their employees’behaviour, as Sarah Johnson explains Employerliability for their employees’ violent behaviour is becoming ever wider inscope. This is bad news, particularly for HR, given the increasing reluctance of liability insurers to pay outfor deliberate acts that cause injury.TheCourt of Appeal recently confirmed this trend when it ruled a nightclub ownerwas liable after a bouncer he employed stabbed someone outside his club (Mattisv Pollock (t/as Flamingo’s Nightclub), 2003, EWCA Civ 887, and the victim wasleft a paraplegic. The court heard that the bouncer had been involved in anincident with Mattis and his companions at Pollock’s nightclub. The bouncer ranhome, picked up a knife, and returned 15 minutes later to stab Mattis outsidethe club, severing his spinal cord.Employersare legally responsible, or ‘vicariously liable’ for the behaviour of theiremployees if it takes place ‘in the course of their employment’. Liabilityderives from common law and discrimination legislation. So how could Pollock beresponsible for such a violent act which did not even take place on hispremises?Thefactors that were taken into account by the appeal court in this case providesome important lessons for avoiding liability.–Pollock encouraged his bouncer to perform his duties in an aggressive andintimidatory manner. Solution: Do not allow, encourage or give instructions forunlawful conduct. –Fellow employees warned Pollock the bouncer was ‘dangerous’ and ‘a bully’.Pollock seemed to see his reputation as an advantage. Solution: Act on warningsand take steps to prevent unlawful conduct.–The bouncer was not licensed as a doorman, and should not have been employed atall. Solution: Do not employee unsuitable staff.–How closely connected an act is with the performance of the employee’s dutieswill be crucial. Employers are at greater risk of liability for violence ifthey authorise an employee to deploy it in the course of employment, or employhim to keep order and discipline. For example, employers are more exposed toliability for an employee’s thefts if engaged to look after property; orliability for abuse if employed to care for and supervise others. Solution:Take particular care where duties may involve danger to others’ safety orpossessions.–Although the bouncer went home and armed himself before returning to thevicinity of the club, where he stabbed Mattis, it  was effectively the culmination of an incident (a fight) whichstarted within the club while he was working and occurred during his working hours.Solution: Do not allow incidents to start at the workplace which could developinto something more serious.CommonlawUndercommon law, courts used to look at whether an employee’s act could be viewed ashaving been authorised by the employer or as a wrongful or unauthorised mode(method) of doing some act authorised by the employer. Theproblem with this test was that, the worse the employee’s behaviour, the lesslikely it was that the employer would be liable. However,in Lister and Others v Hesley Hall Ltd, 2001, IRLR 472, the common law test ofvicarious liability was redefined.TheHouse of Lords held that when deciding whether an act had been committed in thecourse of an employee’s work, courts should concentrate on the relativecloseness of the connection between the nature of employment and the employee’swrongdoing. Thismakes it easier for an employer to be found vicariously liable. Thedifference in approach is highlighted when you compare Lister with the earliercase of Trotman v North Yorkshire County Council, 1999, IRLR 98 CA. In thatcase, a boy sued the council on the basis that it was liable when his deputyheadmaster sexually assaulted him on a school trip. The Court of Appeal heldthat the council was not liable for its employee’s behaviour; the indecentassault was an independent act outside the course of employment. It was not amode – albeitan improper or unauthorised mode – of doing what the deputyheadmaster was employed to do. The case was overruled by the Lister verdict.InLister, a boarding school owner was sued by boys who were sexually abused bythe school warden. The House of Lords held the employee’s position as warden,and the close contact with the boys his work involved, created a sufficientlyclose connection between the abuse and the work he was employed to do, to holdthe employer vicariously liable for his behaviour. The assaults were committedin the employer’s time and on its premises while the warden was caring for theboys. Thepotential for employer’s liability was expanded in Dubai Aluminium Company Ltdv Salaam and Others, 2002, UKHL 48. Historically, employers were lesslikely  to be held liable for employees’dishonesty than for their negligence. In Dubai, it was held that vicariousliability cannot be avoided just because the employee’s wrongdoing wasintentional, criminal, for his own exclusive benefit or contrary to expressinstructions. The closeness of connection between the duties he was engaged toperform and the wrongdoing must still be considered. DiscriminationEmployers’liability for their employees’ actions is easier to establish underdiscrimination statutes, although recent cases make the difference less marked.Underthe Race Relations Act 1976 (RRA), anything done by a person in the course oftheir employment is treated for the purposes of the RRA as having been done bytheir employer as well, whether or not it was done with the employer’sknowledge or approval. Similar wording is used in the Sex Discrimination Act1975 (SDA), Disability Discrimination Act 1995 (DDA) and in other legislation,including that protecting fixed-term employees and part-timers and inforthcoming regulations outlawing discrimination based on sexual orientation,religion and belief. Discriminatoryacts by employees can be seen as being done ‘in the course of employment’ evenwhere what they were doing had nothing directly to do with their duties. Forexample, in Jones v Tower Boot Co Ltd, 1997, IRLR 168 CA, Jones suffered racialharassment from colleagues. His arm was burnt with a hot screwdriver, metalbolts were thrown at him, he was whipped with a piece of welt and repeatedlycalled offensive names.Theemployer was held liable for its employees’ acts of harassment. Under the RRA,SDA (and arguably other discrimination legislation), the words ‘in the courseof employment’ should be interpreted as they are in everyday speech, not usingthe more restrictive common law test.OutsideworkLiabilitycan extend to social events outside work. The key question is whether a socialgathering involving work colleagues is an extension of their employment. Factorsconsidered when deciding an employer’s liability for discrimination outsidework are:–Whether the conduct occurred on the employer’s premises–Whether those present were on duty/there during their working hours–Who was present–Whether it was a work-related social gathering or a chance meeting–Whether it was immediately after work, and–Whether the victim was socialising with the perpetrator.Liabilitywill depend on the facts. In Chief Constable of the Lincolnshire Police vStubbs, 1999, IRLR 81, EAT, Stubbs was subjected to inappropriate sexualbehaviour by a fellow employee at a pub and a leaving party. It was held thatthe employee was acting in the course of his employment. Although the incidentstook place away from the police station, they were at social gatheringsinvolving officers from work either immediately after work or for an organisedleaving party, and were extensions of the workplace. However,in Sidhu v Aerospace Composite Technology Ltd, 2000, IRLR 602, CA, Sidhu wasracially abused by a fellow employee outside working hours at a family day outat a theme park organised by his employers. The employers were not found to be liable.Factors in the decision may have been that the day out was not at theworkplace, everyone was there in their own time and the majority ofparticipants were friends and family, not employees. DefenceUnderdiscrimination legislation, there is a defence for employers to claims they arevicariously liable for their employees’ acts. The employer has to prove it tooksuch steps as were reasonably practicable to prevent the employee from doingthe act complained of, or from doing acts of that description in the course oftheir employment. It is not enough for an employer to show that an act was donewithout its knowledge or approval.Whetherthe defence will work will be a question of fact in each case. Simply having anequal opportunities policy is unlikely to be enough. Nor is giving a warning orcirculating a note saying the employer will not tolerate discrimination, if, inpractice, this is not what happens. It will need to show it complies with thepolicy, that the policy has been brought to employees’ attention and thatmanagers at least, are trained on discrimination issues, the policy’s contentsand how to comply with it.Liabilityfor third-parties’ actionsEmployerswho fail to take adequate steps to protect their employees from harassment bythird parties (rather than employees or agents) could also face liability.Theleading case on this was Burton and Rhule v De Vere Hotels, 1996, IRLR 596,EAT, where two black waitresses successfully claimed the hotel where theyworked was liable for racial harassment by Bernard Manning, the speaker at adinner, and some diners. Itwas held that De Vere Hotels was liable if it had caused or permittedharassment serious enough to amount to a detriment to occur in circumstanceswhere it could control whether it happened.Thequestion was whether the event was sufficiently under the employer’s controlthat, by applying good employment practice, it could have prevented or reducedthe extent of  harassment. No statutorydefence applied, but the employers would not be liable if they had takenreasonable steps to prevent or stop the acts in question. However,in Pearce v Governing Body of Mayfield School, 2003, UKHL 34, the House ofLords criticised the Burton case, ruling on the basis that it overlooked theneed to establish discrimination, and held that it was wrongly decided. Despitethis, employers should still take the necessary steps to prevent harassment oftheir employees by third parties. A discrimination argument could still beraised and failing to protect employees can lead to claims of breach ofcontract, constructive unfair dismissal and liability for consequent illness,such as stress.Otherareas of liabilityLiabilityis not confined to the employer/employee relationship. For example, there is a‘vicarious liability’ provision under the Partnership Act 1890 coveringpartners, and an individual (principal) will be liable for agents’ acts thatlie within the scope of its authority. Therefore, if an agency puts forwardonly white male candidates for a position on an employer’s instruction, bothcould be liable for sex and race discrimination.ConclusionRecentcases suggest that the risk of vicarious liability for employers is increasing.It is vital to take all reasonable steps to prevent employees from engaging inunlawful conduct – otherwise employers may find themselves paying heavily fortheir behaviour. However, if appropriate steps are taken, and employees aremanaged properly, the risk should be significantly reduced. SarahJohnson is a senior solicitor in the employment department at ManchesPracticalsteps to take to avoid vicarious liability–Have an equal opportunities policy in place, and follow it–Train employees on the policy, how to comply with it, and what is acceptable behaviour–Ensure breach of the policy is specified as a disciplinary offence–Nip unacceptable behaviour in the bud – don’t just turn a blind eye–Manage misconduct fairly and consistently, ensuring that unacceptable behaviouris dealt with under your disciplinary procedure, if appropriate–Carry out risk assessments–Ensure employees with access to children or other vulnerable people arecarefully vetted, supervised and trained –Ensure employees are aware that appropriate standards should be maintained evenoutside working hours – for example, at the pub after work –Remind employees of what constitutes appropriate behaviour before workfunctions, such as the Christmas party–Implement a confidential complaints procedure (with specialist training forcomplaint handlers)–Deal promptly and fairly with complaints and investigate them sensitively–Don’t allow a culture to develop in which complaints are trivialised, lettingconduct get out of hand.last_img read more