Sunday, December 29, 2019
The Liability of Directors under the Modern Corporate Environment - Free Essay Example
Sample details Pages: 8 Words: 2494 Downloads: 1 Date added: 2017/06/26 Category Business Essay Type Analytical essay Did you like this example? Z3434911 1 Introduction The Middleton J observation cited in the title question brings a crucial contemporary corporate governance issue into starker focus.[1] Corporate governance is a phrase that has an undeniable à ¢Ã¢â ¬ÃÅ"motherhoodà ¢Ã¢â ¬Ã¢â ¢ element, in that most reasonable people might understand that company directors cannot insulate themselves from liability where they take no steps to properly inform themselves concerning day to day business operations. It is the ability to establish certain parameters to define Middleton Jà ¢Ã¢â ¬Ã¢â ¢s à ¢Ã¢â ¬ÃÅ"more than merely going through the pacesà ¢Ã¢â ¬Ã¢â ¢ assertion that is the profound challenge in this important corporate governance aspect. The effort to establish the requisite parameters undertaken in this essay is guided by a careful review of Corporations Act (CA) section 180 à ¢Ã¢â ¬ÃÅ"care and diligenceà ¢Ã¢â ¬Ã¢â ¢ provisions.[2] This review is additionally informed through its alignment with Corporate Constitutionalism theory. Donââ¬â¢t waste time! Our writers will create an original "The Liability of Directors under the Modern Corporate Environment" essay for you Create order The conclusion that is supported by this dual emphasis is that not only is Middleton J correct in his à ¢Ã¢â ¬ÃÅ"going through the pacesà ¢Ã¢â ¬Ã¢â ¢ observation, a director is obliged to approach their duties with considerable vigor. Directors will escape liability in the modern corporate environment where they demonstrably took their responsibilities seriously, even when things go wrong. The Corporations Act requirement The CA provisions concerning the due care and diligence with which Australian directors are expected to discharge their obligation owed to the specific enterprise are as easy to state as they have proven difficult to apply in practice. Section 180 provides that any corporate officer or director must exercise their powers and discharge their duties with the degree of care and diligence that a reasonable person would exercise if they were similarly situated.[3] It can be clearly inferred from s180(1) that the circumstances or special roles of each direc tor should be considered by the court and the objective à ¢Ã¢â ¬ÃÅ"reasonable personà ¢Ã¢â ¬Ã¢â ¢ standard should also be met.[4] The reasonableness test is measured by another hypothetical reasonable directorà ¢Ã¢â ¬Ã¢â ¢s skills and responsibilities with similar circumstances, where the tailored degree of care and diligence for each director required reflects the companyà ¢Ã¢â ¬Ã¢â ¢s hierarchy of the corporate governance structure to some extent. [5] The business judgment rule described in the companion CA s180 provision is the primary lens through which director duties will be evaluated.[6] The section defines a à ¢Ã¢â ¬ÃÅ"business judgmentà ¢Ã¢â ¬Ã¢â ¢ as any decision to take or not take action in respect of a matter relevant to the business operations of the corporation.[7] Such judgment must demonstrate compliance with the overarching due care and diligence obligation, combined with evidence of four specific attributes listed under s180(2).[8] T he rule is not designed to exempt the directorà ¢Ã¢â ¬Ã¢â ¢s liability from failing to make a sound judgment completely, but to give a defence to those who delivered à ¢Ã¢â ¬ÃÅ"reasonable but loss-generatingà ¢Ã¢â ¬Ã¢â ¢ business judgments made with a rational belief and due care, and in good faith.[9] Consequently, the burden is on the directors to show the specific evidence required by the provision and their persuasive considerations because of its defensive nature. On may readily suggest that on the bare, dispassionate s180 of the CA language alone, the Middleton J title quotation accuracy is confirmed. The intricacies and occasional inconsistencies revealed in the practical CA s180 applications are often driven by the variability of phrases such as good faith and rational belief. The following examples assist in this understanding. Specific examples The statutory requirements for directors under CA s180 are basically similar to what they are imposed under case law. The s180 duties are also better understood when placed against the broader implications that flow from the director-corporation relationship.[10] The case law confirms that directors owe a fiduciary duty to the corporation, as endorsed in cases such as ASIC v Rich[11], and more generally in the High Court of Australia decision in Chan v Zacharia[12]. The fiduciary duty injects a further element of higher obligation than that inspired by a person regarded as merely going through the paces. The leading Australian authority Whitehouse v Carlton[13] describes the fiduciary duty as both non-delegable and non-negotiable.[14] The subjective breach of duty test confirms that a director will avoid personal liability where the decision reflects their honest but mistaken belief that when made, the anticipated results the decision would generate were seen as consistent with the company best interests.[15] It is equally important to appreciate that there are specific instances wher e the director decision may trigger both s180 consequences and other liabilities.[16] An example is s588G[17] of the CA personal liability imposition where the director permits the company to incur debt at a time after the director reasonably knows the enterprise is insolvent, or is likely to become insolvent.[18] In her examination of the Australian business judgment rule evolution, Du Plessis notes its inspiration as derived from earlier English appellate authority.[19] She places specific emphasis on the dicta extracted from Re Smith and Fawcett Ltd[20] in this respect, where directors are mandated to exercise their discretion à ¢Ã¢â ¬Ã
âà ¢Ã¢â ¬Ã ¦bona fide in what they consider not what a court considers is in the interests of the companyà ¢Ã¢â ¬Ã .[21] This seminal position has been interpreted to mean that the business judgment rule reinforces the proposition that courts will not assume the function of being the ultimate arbiter of commercial decisions. It is important to understand that company directors ought not to be found legally responsible on the sole basis that a court later disagrees with the wisdom of their actions. This is a sound approach to the s180 business judgment rule for two reasons. It fairly recognises that no business, no matter how shrewdly operated or resolutely managed, can possibly control or anticipate every commercial variable. There are often forces larger than the company at work; factors such as international financial markets volatility, interest and currency exchange rates, and government policy initiatives can all play an unforeseen role in business performance.[22] The second reason is directly connected to the s180 requirements à ¢Ã¢â ¬Ã¢â¬Å" the law ought only to impose a standard, namely reasonableness that the director can satisfy through efforts any rationale observer is equipped to assess. The standard is not one of superhuman expectation. Harloweà ¢Ã¢â ¬Ã¢â ¢s Nominees[23] makes this point effectively, where the Court observes that the right and duty of à ¢Ã¢â ¬Ã
âà ¢Ã¢â ¬Ã ¦deciding where the companys interests lie [and] à ¢Ã¢â ¬Ã ¦ their judgment, if exercised in good faith and not for irrelevant purposes, is not open to review by the courtà ¢Ã¢â ¬Ã .[24] Du Plessis additionally observes that unlike the business judgment rule scope as observed in the United States, director protections in s180 are inherently more limited. She argues forcefully that Australian directors are not afforded a truly safe harbour from liability unless the good faith and rational judgment tests are satisfied. Corporate Constitutionalism Legal and economic analysis had been the predominant frameworks to review and examine corporate law and corporate governance over the years where the contractual feature reflects its private and individual nature in the context of corporate governance.[25] Although the economic analysis successfully developed an institution al account of relevant laws which regulate companies, its individual and market-oriented approach has been criticised primarily due to lack of responsiveness to political and social concerns.[26] Therefore, s180 under the contractualism framework only requires the directors to fulfil the obligations in the contract without considering other stakeholdersà ¢Ã¢â ¬Ã¢â ¢ rights and interests affected by their decisions.[27] Without denying the reasonableness of economic analysis approach and private nature of corporate law, Stephen Bottomley creatively introduced and implemented a corporate constitutionalism framework by adapting the constitutionalist ideas in political and social theory to give a more comprehensive explanation of corporate governance.[28] In its formulation, corporate constitutionalism is defined by three key features: dual decision-making, deliberative decision-making, and the separation of powers.[29] It can also be crystallised that the board of directors and general meeting should be responsible for their decisions by applying a separation of decision-making powers to corporate governance (accountability), where any disputes with regards to the corporate decisions are required to be solved by deliberation (deliberation), and all shareholders are entitled to contest the decisions to ensure they stands for their interests (contestability).[30] Under dual decision-making structure, directorsà ¢Ã¢â ¬Ã¢â ¢ abilities to make decisions are restrained constitutionally by the considerations of majority membersà ¢Ã¢â ¬Ã¢â ¢ interests which positively benefit the corporate governance.[31] Furthermore, deliberation feature can not only advance the quality in decision-making process but also contribute to protect the membersà ¢Ã¢â ¬Ã¢â ¢ best interests, where the separation of powers provide alternative mechanism to enhance the accountability and monitor the corporate governance process.[32] Each of these constitutionalism feature s is rooted in the notion that decision-making spanning a vast potential topics range is the essence of corporate life.[33] For this reason, Australian law pays significant attention to the rules, doctrines and standards that influence corporate decision-making. These have an informational component, such as the need to disclose annual account and prospectuses. The CA provisions also prescribe procedural rules such as board meetings, and s180 requirements discussed above.[34] For these reasons, corporate constitutionalism is also a concept that explains the importance of structure and process, as opposed to substantive legal doctrine. Among various criticisms towards corporate constitutionalism approach, the fundamental limitation is that most companies which make any business decision in order to maximise profits may be driven to ignore the public policy concerns.[35] Nevertheless the framework is an important supplement to the existing corporate law theory which considerably im proves the integrity and quality of corporate governance.[36] Overall, constitutionalism delivers an alternative account of corporation law to take into account non-shareholder and other public interests in the process of corporate decision-making. The Rich[37] impact Legg and Jordan suggest that prior to the ASIC v Rich[38] decision, the business judgment rule was rarely invoked in Australian director breach of duty claims.[39] The prevailing academic view was the rule added little to the existing directors duties law. The ready conclusion was offered that where the facts establish a director failed to exercise his corporate duty of care, the company would ipso facto negate the business judgment rule.[40] In Rich, the Court plumbed deeper into the rule rationales. The Court decided to approach the question as one of à ¢Ã¢â ¬Ã
âà ¢Ã¢â ¬Ã ¦.how much further the concept of business judgment is extended into the realm of management, organisation and planningà ¢Ã¢â ¬Ã .[41] This key phrase illustrates how the Court was prepared to take the examination. Through its focus on the decision-making occasion, as opposed to the directorà ¢Ã¢â ¬Ã¢â ¢s general state of knowledge, the Court characterised the director as one obliged to become informed about the subject matter of the decision prior to making it. The Court stresses that the s180 qualifying words, à ¢Ã¢â ¬ÃÅ"to the extent they reasonably believe to be appropriateà ¢Ã¢â ¬Ã¢â ¢, must convey the idea that protection may be available even if the director was not aware of the available information material to the decision, so long as the director reasonably believed appropriate steps were taken on the decision-making occasion to be properly informed concerning the subject matter.[42] It is apparent that this approach is largely consistent with the corporate constitutionalism as described by Stephen Bottomley.[43] The prudent director is revealed as one that understands and adhe res it the proper procedures; once followed, the director should enjoy significant protection from liability claims. Conclusion As noted in the initial examination of the s180 languages, it would be difficult to imagine a director being able to discharge their stated obligations if their role was merely ornamental, or one characterised as simply going through their paces. The business judgment rule as taken from the English authorities and adopted for use under s180 of the CA auspices places significant obligations on Australian directors, ones that are made more prominent when fixed against their fiduciary duties backdrop. Neil Young pointed out in his article with regard to corporate governance that there are considerable numbers of directors who should have great knowledge and understandings of their companies are not familiar with the operations or strategies of the companies.[44] As a result of that, it was suggested that a à ¢Ã¢â ¬ÃÅ"responsive regulationà ¢Ã¢â ¬Ã ¢â ¢ approach which lays much heavier penalties even criminal sanctions for the breach of directorsà ¢Ã¢â ¬Ã¢â ¢ duties should be used to enhance the compliance of the CA and achieve a better balance between s180(1) and (2).[45] It is equally apparent that the corporate constitutionalism theory that also exerts its influence over how director obligations ought to be understood affords further liability protection to those directors that assiduously follow correct board procedure in their decision-making processes. [1] ASIC v Healey [2011] FCA 717. [2] Section180(1), Corporations Act 2001 (Cth). [3] Andy Gibson, Business Law (Pearson Australia, 6th edition, 2013), pp232-236. [4] Emillios Kyrou, à ¢Ã¢â ¬Ã
âDirectorsà ¢Ã¢â ¬Ã¢â ¢ Duties, Defences, Indemnities, Access to Board Papers and DO Insurance Post CLERPAà ¢Ã¢â ¬Ã (2000) 18 CSLJ 555, p558. [5] Neil Young, à ¢Ã¢â ¬Ã
âHas directorsà ¢Ã¢â ¬Ã¢â ¢ liability gone too far or not far enough? A review of the standard of conduct required of directors under sections 180-184 of the Corporations Actà ¢Ã¢â ¬Ã (2008) 26 CSLJ 216, p220. [6] Section180(2), Corporations Act 2001 (Cth). [7] Section180(3), Corporations Act 2001 (Cth). [8] Section180(2), Corporations Act 2001 (Cth). [9] Sarah Worthington, à ¢Ã¢â ¬Ã
âReforming Directorsà ¢Ã¢â ¬Ã¢â ¢ Dutiesà ¢Ã¢â ¬Ã (2001) 64 Mod LR 439, p450. [10] Brian Horrigan, à ¢Ã¢â ¬Ã
âDirectorsà ¢Ã¢â ¬Ã¢â ¢ Duties and Liabilities à ¢Ã ¢â ¬Ã¢â¬Å" Where Are We Now and Where Are We Going in the UK, Broader Commonwealth, and Internationally?à ¢Ã¢â ¬Ã (2012) 3(2) International Journal of Business and Social Science1, p1. [11] [2009] NSWSC 1229. [12] [1984] HCA 36. [13] (1987) 162 CLR 285. [14] Whitehouse v Carlton Hotel Pty Ltd (1987) 162 CLR 285. [15] R P Austin and I M Ramsay, Fords Principles of Corporations Law (LexisNexis, 15th edition, 2012), Pt I.2 and Pt III.6. [16] Section9, Corporations Act 2001 (Cth); as discussed in Taylormaid Marine Industries Pty Ltd v Beaurepaire Ors (1987) 5 ACLC 253. [17] Section588G, Corporations Act 2001 (Cth). [18] J Jean and Du Plessis, à ¢Ã¢â ¬Ã
âOpen Sea or safe harbour? American, Australian and South African business judgment rules compared: Part 1à ¢Ã¢â ¬Ã (2011) 32 Company Lawyer 345, p347. [19] Ibid, p348. [20] [1942] Ch 304. [21] Ibid. [22] Andy Gibson, Business Law (Pearson Australia, 6th edition, 2013), pp234-236. [23] Harlowes Nominees Pty Ltd v Woodside (Lakes Entrance) Oil Co NL (1968) 121 CLR 483. [24] Ibid, p493; see the similar English reasoning in Howard Smith Ltd v Ampol Petroleum Ltd [1974] AC 821, p835. [25] Stephen Bottomley, The Constitutional Corporation: Rethinking Corporate Governance (Ashgate, 2007), Chapter2, pp 19, 25, 26, 29. [26] Angus Corbett and Peta Spender, à ¢Ã¢â ¬Ã
âReview Essay: Corporate Constitutionalismà ¢Ã¢â ¬Ã (2009) 31 Sydney Law Review 147, pp148, 149. [27] Stephen Bottomley, à ¢Ã¢â ¬Ã
âFrom Contractualism to Constitutionalism: A Framework for Corporate Governanceà ¢Ã¢â ¬Ã (1997) 19 Sydney Law Review 277, p289. [28] Ibid, p296. [29] Ibid, p298. [30] Neil Andrews, à ¢Ã¢â ¬Ã
âReviews and Current Developments: Putting the politics back into corporate law: A review of Stephen Bottomleyà ¢Ã¢â ¬Ã¢â ¢s The Constitutional Corporation: Rethinking Corporate Goveranceà ¢Ã¢â ¬Ã (2007) 21 Aust Jnl of Corp Law 16 1, pp162-164. [31] Stephen Bottomley, à ¢Ã¢â ¬Ã
âFrom Contractualism to Constitutionalism: A Framework for Corporate Governanceà ¢Ã¢â ¬Ã (1997) 19 Sydney Law Review 277, p300. [32] Ibid, pp 306-207, 309. [33] Angus Corbett and Peta Spender, à ¢Ã¢â ¬Ã
âReview Essay: Corporate Constitutionalismà ¢Ã¢â ¬Ã (2009) 31 Sydney Law Review 147, p149. [34] Ibid, p150. [35] Stephen Bottomley, à ¢Ã¢â ¬Ã
âFrom Contractualism to Constitutionalism: A Framework for Corporate Governanceà ¢Ã¢â ¬Ã (1997) 19 Sydney Law Review 277, p313. [36] Angus Corbett and Peta Spender, à ¢Ã¢â ¬Ã
âReview Essay: Corporate Constitutionalismà ¢Ã¢â ¬Ã (2009) 31 Sydney Law Review 147, p154. [37] ASIC v Rich [2009] NSWSC 1229. [38] [2009] NSWSC 1229. [39] Michael Legg and Dean Jordan, à ¢Ã¢â ¬Ã
âThe Australian Business Judgment Rule after ASIC v Rich: Balancing Director Authority and Accountabilityà ¢Ã¢â ¬Ã (2013) 34(2) Adelaide Law Review 179 , pp179-181. [40] ASIC v Rich [2009] NSWSC 1229, p1231. [41] Ibid. [42] Ibid, p7284. [43] Stephen Bottomley, The Constitutional Corporation: Rethinking Corporate Governance (Ashgate, 2007), Chapter2. [44] Neil Young, à ¢Ã¢â ¬Ã
âHas directorsà ¢Ã¢â ¬Ã¢â ¢ liability gone too far or not far enough? A review of the standard of conduct required of directors under sections 180-184 of the Corporations Actà ¢Ã¢â ¬Ã (2008) 26 CSLJ 216, p231. [45] Ibid, pp230-231.
Saturday, December 21, 2019
Religious Texts- Examining the Content of the Holy Bible...
Sunlight beams through arched windows encased in stained glass; reflecting rays of red, blue, green, and yellow throughout the entryway. Below our feet, a wood floor echoes as we walk, and silences with a step onto the red carpet. Dark mahogany pews stand at attention to our left and right. Directly above on the back wall, a stained glass image of a woman standing over an infant in a cradle, sunlight illuminating her delicate features, she gazes down at the child. Her thin angelic lips slightly open, her hands clasped together in a prayer-like stance. A blue veil cascades down her shoulders interlocking with her robe below. To the right of the infant, a table displays a large white book with gold-tipped pages. On the cover, prominent goldâ⬠¦show more contentâ⬠¦Originally written in Greek about 45 AD, this volume contains 27 books and 260 chapters. Its scriptures tell the story of the life of Jesus, believed by Christians to be the Messiah, Son of God in human form, and sent b y God to fulfill the promises and prophesies of the Old Testament. In comparison, the Holy Quran, written after the Old Testament, remains in its original form. Written in Arabic, Quran means ââ¬Å"recitationâ⬠and contains Islamic teachings believed to bring guidance, direction, and ââ¬Å"IS the word of God,â⬠whom they call Allah. It is against Islamic law to change the text in any way because Muslims believe Mohammad, founder of Islam, wrote the verses as revealed to him by the angel Gabriel. Muslims view Mohammad not as the creator of the religion, but as the restorer of the original the Hebrew Bible. Islam teaches Mohammad was not only a religious prophet but also a political and military leader. He was human, but not without sin, so he is not God. Although there have been several language translations, a good follower must read and memorize its teaching in its native Arabic language. For a follower to live by Islam he must completely submit (to God). In looking at its history, we can understand a little about its followers. Islam is the second largest religion in the world, with 1.7 billion members or 21% of the worldââ¬â¢s population. ItsShow MoreRelatedImportance of Intercultural Communication to Ist7702 Words à |à 31 Pagesdeep-seated hatreds that turn one culture against another also endure. iii) Deep Structure Institutions and their Messages are Deeply Felt The content generated by these institutions, and the institutions themselves, arouse deep and emotional feelings. Think for a moment about the violent reactions that can be produced by taking Gods name in vain. Countries and religious causes have been able to send young men to war, and politicians have attempted to win elections by arousing people to the importance ofRead MoreSources of Ethics20199 Words à |à 81 PagesTABLE OF CONTENTS 1.0- JOHN STEINER AND GEORGE STEINER SIX PRIMARY SOURCES OF ETHICS: 6 1- Religion: 6 2- Genetic Inheritance: 8 3- Philosophical Systems: 8 4- Cultural Experience: 8 5- The Legal System: 9 6- Codes of Conduct: 9 2.0- EXPLANATION OF THE SOURCES OF ETHICS: 10 2.1- RELIGION: 10 Teaching business ethics 12 2.11- Impact Of Religiosity: 13 2.12- Ethics Of Islam: 14 Nature of Islamic Ethics 17 The Human-Environment Relationship: 20 The SustainableRead MoreAn Introduction to Intercultural Communication29172 Words à |à 117 Pageson the bottom side of the iceberg, the invisible side. It is these invisible elements that are the underlying causes of what manifest on the visible side. So, when thinking about culture, the bottom side of the iceberg will include things such as religious beliefs, worldviews, rules of relationships, approach to the family, motivations, tolerance for change, attitudes to rules, communication styles, modes of thinking, comfort with risk, the difference between public and private, gender differences
Friday, December 13, 2019
Last Sacrifice Chapter Nineteen Free Essays
THE VANS PARKED IN A semi-remote part of Court, so seeing the area packed with eager Moroi was quite a shock to Lissa. Guardians moved through the people like ghosts, just as they had at the nomination session, keeping as much order as possible. The crowd kept getting in the way as the vans attempted to reach the garages, and faces looked in the windows, trying to get a glimpse of the royal candidates. We will write a custom essay sample on Last Sacrifice Chapter Nineteen or any similar topic only for you Order Now Lissa stared at the masses in shock, almost afraid to get out. Ariana gave her a comforting smile. ââ¬Å"This is normal. They all want to know who made it and who didnââ¬â¢t. They especially want to know.ââ¬â¢ She inclined her head toward the front of the van. Peering through the windshield, Lissa spied the other six candidates. Because the forest course could only accommodate so many people, the group had been split in half. The rest of the candidates would take the same test tomorrow and were no doubt curious who among their competitors had passed today. Lissa was used to order and decorum around royals, so she was astonished to see such eagerness and frenzy among them now. And of course, the ââ¬Å"commonââ¬â¢ Moroi whoââ¬â¢d been arriving at Court were mixed into the crowd too. Everyone was pushing, peering over the heads of others to find out what had happened. People were shouting some of the candidatesââ¬â¢ names, and I was half-surprised they hadnââ¬â¢t come up with songs and banners. Lissa and her companions exited the van and were met with a wave of cheers that rippled through the crowd. It became obvious pretty quickly who had passed and who hadnââ¬â¢t. This sent the crowd abuzz even more. Lissa stood rooted to the spot, staring around and feeling lost. It was one thing to rationally discuss the pros of her running for queen with her friends. It was an entirely different matter to suddenly be thrust into what the elections truly meant. Her focus had been limited to a few things: my safety, finding the murderer, and surviving the tests. Now, as she took in the crowd, she realized the election was bigger than her, bigger than anything she could have imagined. For these people, it wasnââ¬â¢t a joke. It wasnââ¬â¢t a scam to twist the law and stall for time. Their lives were figuratively on the line. Moroi and dhampirs lived inside various countries and obeyed those laws, but they also obeyed this government, the one that operated out of the Court. It reached around the world and affected every dhampir and Moroi who chose to stay in our society. We had some voting, yes, but the king or queen shaped our futures. The guardians in charge of the crowds finally gave the okay for family members to push through the masses and collect their nominees. Lissa had no one. Both Janine and Eddieââ¬âdespite earlier claimsââ¬âwere occasionally given temporary tasks that prevented them from being with Lissa 24/7, and she certainly had no family to come for her. Adrift, she felt dizzy in the chaos, still stunned by her moment of clarity. Conflicting emotions warred within her. Deceiving everyone made her feel unworthy, like she should resign her candidacy right now. At the same time, she suddenly wanted to be worthy of the elections. She wanted to hold her head high and walk into the tests proudly, even if she was taking them for ulterior motives. A strong hand at last caught hold of her arm. Christian. ââ¬Å"Come on. Letââ¬â¢s get out of here.ââ¬â¢ He pulled her away, shouldering through the onlookers. ââ¬Å"Hey,ââ¬â¢ he called to a couple guardians on the crowdââ¬â¢s periphery. ââ¬Å"A little help here for the princess?ââ¬â¢ It was the first time I had ever seen him act like a royal, throwing around the authority of his bloodline. To me, he was snarky, cynical Christian. In Moroi society, at eighteen, he could now technically be addressed as Lord Ozera. Iââ¬â¢d forgotten that. The two guardians hadnââ¬â¢t. They rushed to Lissaââ¬â¢s side, helping Christian part the crowd. The faces around her were a blur, the noise a dull roar. Yet, every once in a while, something would come through to her. The chanting of her name. Declarations about the return of the dragon, which was the symbol of the Dragomir family. This is real, she kept thinking. This is real. The guardians efficiently led her out of it all and back across the Courtââ¬â¢s grounds to her building. They released her once they considered her safe, and she graciously thanked them for their help. When she and Christian were in her room, she sank onto the bed, stunned. ââ¬Å"Oh my God,ââ¬â¢ she said. ââ¬Å"That was insane.ââ¬â¢ Christian smiled. ââ¬Å"Which part? Your welcome home party? Or the test itself? You look like you just â⬠¦ well, Iââ¬â¢m not really sure what you just did.ââ¬â¢ Lissa took a quick survey of herself. Theyââ¬â¢d given her dry towels on the ride home, but her clothing was still damp and was wrinkling as it dried. Her shoes and jeans had mud all over them, and she didnââ¬â¢t even want to think about what her hair looked like. ââ¬Å"Yeah, weââ¬âââ¬Ë The words stuck on her tongueââ¬âand not because she suddenly decided not to tell him. ââ¬Å"I canââ¬â¢t say,ââ¬â¢ she murmured. ââ¬Å"It really worked. The spell wonââ¬â¢t let me.ââ¬â¢ ââ¬Å"What spell?ââ¬â¢ he asked. Lissa rolled up her sleeve and lifted the bandage to show him the tiny tattooed dot on her arm. ââ¬Å"Itââ¬â¢s a compulsion spell so I wonââ¬â¢t talk about the test. Like the Alchemists have.ââ¬â¢ ââ¬Å"Wow,ââ¬â¢ he said, truly impressed. ââ¬Å"I never actually thought those worked.ââ¬â¢ ââ¬Å"I guess so. Itââ¬â¢s really weird. I want to talk about it, but I just â⬠¦ cant.ââ¬â¢ ââ¬Å"Its okay,ââ¬â¢ he said, brushing some of her damp hair aside. ââ¬Å"You passed. Thatââ¬â¢s what matters. Just focus on that.ââ¬â¢ ââ¬Å"The only thing I want to focus on right now is a showerââ¬âwhich is kind of ironic, considering how soaked I am.ââ¬â¢ She didnââ¬â¢t move, though, and instead stared off at the far wall. ââ¬Å"Hey,ââ¬â¢ said Christian gently. ââ¬Å"Whatââ¬â¢s wrong? Did the crowd scare you?ââ¬â¢ She turned back to him. ââ¬Å"No, thatââ¬â¢s the thing. I mean, they were intimidating, yeah. But I just realized â⬠¦ I donââ¬â¢t know. I realized Iââ¬â¢m part of a major process, one thatââ¬â¢s gone on sinceââ¬âââ¬Ë ââ¬Å"The beginning of time?ââ¬â¢ teased Christian, quoting Nathanââ¬â¢s nonsensical statement. ââ¬Å"Nearly,ââ¬â¢ she answered, with a small smile that soon faded. ââ¬Å"This goes beyond tradition, Christian. The elections are a core part of our society. Ingrained. We can talk about changing age laws or fighting or whatever, but this is ancient. And far-reaching. Those people out there? Theyââ¬â¢re not all Americans. Theyââ¬â¢ve come from other countries. I forget sometimes that even though the Court is here, it rules Moroi everywhere. What happens here affects the whole world.ââ¬â¢ ââ¬Å"Where are you going with this?ââ¬â¢ he asked. She was lost in her own thoughts and couldnââ¬â¢t see Christian as objectively as I could. He knew Lissa. He understood her and loved her. The two of them had a synchronicity similar to what Dimitri and I shared. Sometimes, however, Lissaââ¬â¢s thoughts spun in directions he couldnââ¬â¢t guess. Heââ¬â¢d never admit it, but I knew part of why he loved her was thatââ¬âunlike me, who everyone knew was impetuousââ¬âLissa always seemed the picture of calmness and rationality. Then, sheââ¬â¢d do something totally unexpected. Those moments delighted himââ¬âbut sometimes scared him because he never knew just how much a role spirit was playing in her actions. Now was one of those times. He knew the elections were stressing her, and like me, he knew that could bring out the worst. ââ¬Å"Iââ¬â¢m going to take these tests seriously,ââ¬â¢ she said. ââ¬Å"Itââ¬â¢sââ¬âitââ¬â¢s shameful not to. An insult to our society. My ultimate goal is to find out who framed Rose, but in the meantime? Iââ¬â¢m going to go through the trials like someone who intends to be queen.ââ¬â¢ Christian hesitated before speaking, a rarity for him. ââ¬Å"Do you want to be queen?ââ¬â¢ That snapped Lissa from her dreamy philosophizing about tradition and honor. ââ¬Å"No! Of course not. Iââ¬â¢m eighteen. I canââ¬â¢t even drink yet.ââ¬â¢ ââ¬Å"Thatââ¬â¢s never stopped you from doing it,ââ¬â¢ he pointed out, becoming more like his usual self. ââ¬Å"Iââ¬â¢m serious! I want to go to college. I want Rose back. I donââ¬â¢t want to rule the Moroi nation.ââ¬â¢ A sly look lit Christianââ¬â¢s blue eyes. ââ¬Å"You know, Aunt Tasha makes jokes about how youââ¬â¢d actually be a better queen than the others, except sometimes â⬠¦ I donââ¬â¢t think sheââ¬â¢s joking.ââ¬â¢ Lissa groaned and stretched back on the bed. ââ¬Å"I love her, but weââ¬â¢ve got to keep her in check. If anyone could actually get that law changed, it would be her and her activist friends.ââ¬â¢ ââ¬Å"Well, donââ¬â¢t worry. The thing about her ââ¬Å"activist friendsââ¬â¢ is that they have so much to protest, they donââ¬â¢t usually get behind one thing at the same time.ââ¬â¢ Christian stretched out beside her and pulled her close. ââ¬Å"But for what itââ¬â¢s worth, I think youââ¬â¢d be a great queen too, Princess Dragomir.ââ¬â¢ ââ¬Å"Youââ¬â¢re going to get dirty,ââ¬â¢ she warned. ââ¬Å"Already am. Oh, you mean from your clothes?ââ¬â¢ He wrapped his arms around her, heedless of her damp and muddy state. ââ¬Å"I spent most of my childhood hiding in a dusty attic and own exactly one dress shirt. You really think I care about this T-shirt?ââ¬â¢ She laughed and then kissed him, letting her mind free itself of worry for a moment and just savor the feel of his lips. Considering they were on a bed, I wondered if it was time for me to go. After several seconds, she pulled back and sighed contentedly. ââ¬Å"You know, sometimes I think I love you.ââ¬â¢ ââ¬Å"Sometimes?ââ¬â¢ he asked in mock outrage. She ruffled his hair. ââ¬Å"All the time. But Iââ¬â¢ve got to keep you on your toes.ââ¬â¢ ââ¬Å"Consider me kept.ââ¬â¢ He brought his lips toward hers again but stopped when a knock sounded at the door. Lissa pulled back from the near-kiss, but neither of them broke from the embrace. ââ¬Å"Donââ¬â¢t answer,ââ¬â¢ said Christian. Lissa frowned, peering toward the living room. She slipped out of his arms, stood up, and walked toward the door. When she was several feet from it, she nodded knowingly. ââ¬Å"Itââ¬â¢s Adrian.ââ¬â¢ ââ¬Å"More reason not to answer,ââ¬â¢ said Christian. Lissa ignored him and opened the door, and sure enough, my devil-may-care boyfriend stood there. From behind Lissa, I heard Christian say, ââ¬Å"Worst. Timing. Ever.ââ¬â¢ Adrian studied Lissa and then looked at Christian sprawling on the bed on the far side of the suite. ââ¬Å"Huh,ââ¬â¢ Adrian said, letting himself in. ââ¬Å"So thatââ¬â¢s how youââ¬â¢re going to fix the family problem. Little Dragomirs. Good idea.ââ¬â¢ Christian sat up and strolled toward them. ââ¬Å"Yeah, thatââ¬â¢s exactly it. Youââ¬â¢re interrupting official Council business.ââ¬â¢ Adrian was dressed casually for him, jeans and a black T-shirt, though he made it look like designer clothing. Actually, it probably was. God, I missed him. I missed them all. ââ¬Å"Whatââ¬â¢s going on?ââ¬â¢ asked Lissa. While Christian seemed to consider Adrianââ¬â¢s arrival a personal offense, Lissa knew that Adrian wouldnââ¬â¢t be here without a good reasonââ¬â especially this early in the Moroi day. Although he had on his normal lazy smile, there was an excited and eager glitter in his aura. He had news. ââ¬Å"Iââ¬â¢ve got him,ââ¬â¢ said Adrian. ââ¬Å"Got him trapped.ââ¬â¢ ââ¬Å"Who?ââ¬â¢ asked Lissa, startled. ââ¬Å"That idiot Blake Lazar.ââ¬â¢ ââ¬Å"What do you mean trapped?ââ¬â¢ asked Christian, as perplexed as Lissa. ââ¬Å"Did you set out a bear trap on the tennis courts or something?ââ¬â¢ ââ¬Å"I wish. Heââ¬â¢s over at the Burning Arrow. I just bought another round, so he should still be there if we hurry. He thinks I went out for a cigarette.ââ¬â¢ Judging from the scent wreathing Adrian, Lissa had a feeling he actually had been out for a cigarette. And likely shared in the round. ââ¬Å"Youââ¬â¢ve been at a bar this early?ââ¬â¢ Adrian shrugged. ââ¬Å"Itââ¬â¢s not early for humans.ââ¬â¢ ââ¬Å"But youââ¬â¢re notââ¬âââ¬Ë ââ¬Å"Come on, cousin.ââ¬â¢ Adrianââ¬â¢s aura didnââ¬â¢t have the muted colors of someone who was completely drunk, but yes, heââ¬â¢d definitely had a few drinks. ââ¬Å"If pretty boy Ambrose was right about Aunt Tatiana, then this guy can tell us the names of other jealous women.ââ¬â¢ ââ¬Å"Why didnââ¬â¢t you ask him yourself?ââ¬â¢ asked Christian. ââ¬Å"Because me asking about my auntââ¬â¢s sex life would be sick and wrong,ââ¬â¢ said Adrian. ââ¬Å"Whereas Blake will be more than happy to talk to our charming princess here.ââ¬â¢ Lissa really wanted her bed, but finding out anything to help me sparked a new rush of energy within her. ââ¬Å"Okay, let me at least get some different clothes and brush my hair.ââ¬â¢ While she was changing in the bathroom, she heard Adrian say to Christian, ââ¬Å"You know, your shirtââ¬â¢s kind of grungy-looking. Seems like you could put in a little more effort since youââ¬â¢re dating a princess.ââ¬â¢ Fifteen minutes or so later, the threesome were on their way across Court to a tucked away bar inside an administrative building. Iââ¬â¢d been there before and had originally thought it was a weird place to house a bar. But, after a recent stint of filing, Iââ¬â¢d decided that if I were doing office work for living, Iââ¬â¢d probably want a quick source of alcohol on hand, too. The bar was dimly lit, both for mood and Moroi comfort. Adrianââ¬â¢s joking aside, it really was early for Moroi, and only a couple patrons were there. Adrian made a small gesture to the bartender, which I presumed was some kind of ordering signal because the woman immediately turned and began pouring a drink. ââ¬Å"Hey, Ivashkov! Whereââ¬â¢d you go?ââ¬â¢ A voice called over to Lissa and the others, and after a few moments, she spotted a lone guy sitting at a corner table. As Adrian led them closer, Lissa saw that the guy was youngââ¬âabout Adrianââ¬â¢s age, with curly black hair and brilliant teal eyes, kind of like Abeââ¬â¢s recent tie. It was as though someone had taken the stunning color of both Adrian and Christianââ¬â¢s eyes and mixed them together. He had a leanly muscled bodyââ¬âabout as buff as any Moroi could manageââ¬âand, even with a boyfriend, Lissa could admire how hot he was. ââ¬Å"To get better-looking company,ââ¬â¢ replied Adrian, pulling out a chair. The Moroi then noticed Adrianââ¬â¢s companions and jumped up. He caught hold of Lissaââ¬â¢s hand, leaned over, and kissed it. ââ¬Å"Princess Dragomir. Itââ¬â¢s an honor to meet you at last. Seeing you from a distance was beautiful. Up close? Divine.ââ¬â¢ ââ¬Å"This,ââ¬â¢ said Adrian grandly, ââ¬Å"is Blake Lazar.ââ¬â¢ ââ¬Å"Itââ¬â¢s nice to meet you,ââ¬â¢ she said. Blake smiled radiantly. ââ¬Å"May I call you Vasilisa?ââ¬â¢ ââ¬Å"You can call me Lissa.ââ¬â¢ ââ¬Å"You can also,ââ¬â¢ added Christian, ââ¬Å"let go of her hand now.ââ¬â¢ Blake looked over at Christian, taking a few more moments to release Lissaââ¬â¢s handââ¬â seeming very proud about those extra seconds. ââ¬Å"Iââ¬â¢ve seen you too. Ozera. Crispin, right?ââ¬â¢ ââ¬Å"Christian,ââ¬â¢ corrected Lissa. ââ¬Å"Right.ââ¬â¢ Blake pulled out a chair, still playing the over-the-top gentleman. ââ¬Å"Please. Join us.ââ¬â¢ He made no such offer to Christian, who went out of his way to sit close to Lissa. ââ¬Å"What would you like to drink? Itââ¬â¢s on me.ââ¬â¢ ââ¬Å"Nothing,ââ¬â¢ said Lissa. The bartender appeared just then, bringing Adrianââ¬â¢s drink and another for Blake. ââ¬Å"Never too early. Ask Ivashkov. You drink as soon as you roll out of bed, right?ââ¬â¢ ââ¬Å"Thereââ¬â¢s a bottle of scotch right on my nightstand,ââ¬â¢ said Adrian, still keeping his tone light. Lissa opened her eyes to his aura. It bore the bright gold all spirit users had, still muddled slightly from alcohol. It also had the faintest tinge of redââ¬ânot true anger, but definite annoyance. Lissa recalled that neither Adrian nor Ambrose had had a good opinion of this Blake guy. ââ¬Å"So what brings you and Christopher here?ââ¬â¢ asked Blake. He finished a glass of something amber colored and set it down beside the new drink. ââ¬Å"Christian,ââ¬â¢ said Christian. ââ¬Å"We were talking about my aunt earlier,ââ¬â¢ said Adrian. Again, he managed to sound very conversational, but no matter how much he might want to clear my name, delving into the details of Tatianaââ¬â¢s murder obviously bothered him. Blakeââ¬â¢s smile diminished a little. ââ¬Å"How depressing. For both of you.ââ¬â¢ That was directed to Adrian and Lissa. Christian might as well have not existed. ââ¬Å"Sorry about Hathaway too,ââ¬â¢ he added to Lissa alone. ââ¬Å"Iââ¬â¢ve heard how upset youââ¬â¢ve been. Whoââ¬â¢d have seen that coming?ââ¬â¢ Lissa realized he was referring to how sheââ¬â¢d been pretending to be angry and hurt by me. ââ¬Å"Well,ââ¬â¢ she said bitterly. ââ¬Å"I guess you just donââ¬â¢t know people. There were a million clues beforehand. I just didnââ¬â¢t pay attention.ââ¬â¢ ââ¬Å"You must be upset too,ââ¬â¢ said Christian. ââ¬Å"We heard you and the queen were kind of close.ââ¬â¢ Blakeââ¬â¢s grin returned. ââ¬Å"Yeah â⬠¦ we knew each other pretty well. Iââ¬â¢m going to miss her. She might have seemed cold to some people, but believe me, she knew how to have a good time.ââ¬â¢ Blake glanced at Adrian. ââ¬Å"You must have known that.ââ¬â¢ ââ¬Å"Not in the way you did.ââ¬â¢ Adrian paused to take a sip of his own drink. I think he needed it to restrain any snippy remarks, and honestly, I didnââ¬â¢t begrudge him it. I actually admired his self-control. If Iââ¬â¢d been in his place, I would have long since punched Blake. ââ¬Å"Or Ambrose.ââ¬â¢ Blakeââ¬â¢s pretty smile transformed into a full-fledged scowl. ââ¬Å"Him? That blood whore? He didnââ¬â¢t deserve to be in her presence. I canââ¬â¢t even believe they let him stay at Court.ââ¬â¢ ââ¬Å"He actually thinks you killed the queen.ââ¬â¢ Lissa then added hastily, ââ¬Å"Which is ridiculous when all the evidence proves Rose did it.ââ¬â¢ Those hadnââ¬â¢t been Ambroseââ¬â¢s exact words, but she wanted to see if she could elicit a reaction. She did. ââ¬Å"He thinks what?ââ¬â¢ Yes. Definitely no smile now. Without it, Blake suddenly didnââ¬â¢t seem as good-looking as earlier. ââ¬Å"That lying bastard! I have an alibi, and he knows it. Heââ¬â¢s just pissed off because she liked me better.ââ¬â¢ ââ¬Å"Then whyââ¬â¢d she keep him around?ââ¬â¢ asked Christian, face almost angelic. ââ¬Å"Werenââ¬â¢t you enough?ââ¬â¢ Blake fixed him with a glare while finishing the new drink in nearly one gulp. Almost by magic, the bartender appeared with another. Blake nodded his thanks before continuing. ââ¬Å"Oh, I was more than enough. More than enough for a dozen women, but I didnââ¬â¢t fool around on the side like he did.ââ¬â¢ Adrianââ¬â¢s expression was growing increasingly pained at each mention of Tatianaââ¬â¢s sex life. Still, he played his role. ââ¬Å"I suppose youââ¬â¢re talking about Ambroseââ¬â¢s other girl- friends? â⬠ââ¬Å"Yup. But ââ¬Å"girlââ¬â¢ is kind of extreme. They were all older, and honestly, I think they paid him. Not that your mom needed to pay anyone,ââ¬â¢ added Blake. ââ¬Å"I mean, sheââ¬â¢s actually pretty hot. But you know, she couldnââ¬â¢t really be with him in any real way.ââ¬â¢ It seemed to take all of them a moment to follow what Blake was alluding to. Adrian caught on first. ââ¬Å"What did you just say?ââ¬â¢ ââ¬Å"Oh.ââ¬â¢ Blake looked legitimately surprised, but it was hard to say if it was an act. ââ¬Å"I thought you knew. Your mom and Ambrose â⬠¦ well, who could blame her? With your dad? Though just between you and me, I think she could have done better.ââ¬â¢ Blakeââ¬â¢s tone implied exactly whom he thought Daniella could have done better with. In Lissaââ¬â¢s vision, Adrianââ¬â¢s aura flared red. ââ¬Å"You son of a bitch!ââ¬â¢ Adrian was not the fighting type, but there was a first time for everythingââ¬âand Blake had just crossed a serious line. ââ¬Å"My mom was not cheating on my dad. And even if she was â⬠¦ she sure as hell wouldnââ¬â¢t have to pay for it.ââ¬â¢ Blake didnââ¬â¢t seem fazed, but maybe things would have been different if Adrian actually had hit him. Lissa rested her hand on Adrianââ¬â¢s arm and squeezed it gently. ââ¬Å"Easy,ââ¬â¢ she murmured. I felt the smallest tingle of calming compulsion move from her into him. Adrian recognized it immediately and pulled his arm back, giving her a look that said he didnââ¬â¢t appreciate her ââ¬Å"help.ââ¬â¢ ââ¬Å"I thought you didnââ¬â¢t like your dad,ââ¬â¢ said Blake, utterly clueless that his news might be upsetting. ââ¬Å"And besides, donââ¬â¢t get all pissy at me. I wasnââ¬â¢t sleeping with her. Iââ¬â¢m just telling you what I heard. Like I said, if you want to start accusing random people, go after someone like Ambrose.ââ¬â¢ Lissa jumped in to keep Adrian from saying anything. ââ¬Å"How many women? Do you know who else he was involved with?ââ¬â¢ ââ¬Å"Three others.ââ¬â¢ Blake ticked off names on his hand. ââ¬Å"Marta Drozdov and Mirabel Conta. Wait. Thatââ¬â¢s two. I was thinking with Daniella; thatââ¬â¢s three. But then, thatââ¬â¢s four with the queen. Yeah, four.ââ¬â¢ Lissa didnââ¬â¢t concern herself with Blakeââ¬â¢s faulty math skills, though it did support Adrianââ¬â¢s previous ââ¬Å"idiotââ¬â¢ claims. Marta Drozdov was a semi-notorious royal who had taken to traveling the world in her old age. By Lissaââ¬â¢s estimation, Marta was hardly in the U.S. most of the year, let alone Court. She didnââ¬â¢t seem invested enough to murder Tatiana. As for Mirabel Conta â⬠¦ she was notorious in a different way. She was known for sleeping with half the guys at Court, married or otherwise. Lissa didnââ¬â¢t know her well, but Mirabel had never seemed overly interested in any one guy. ââ¬Å"Sleeping with other women wouldnââ¬â¢t really give him a motive for killing the queen,ââ¬â¢ pointed out Lissa. ââ¬Å"No,ââ¬â¢ agreed Blake. ââ¬Å"Like I said, itââ¬â¢s obvious that Hathaway girl did it.ââ¬â¢ He paused. ââ¬Å"Damned shame too. Sheââ¬â¢s pretty hot. God, that body. Anyway, if Ambrose had killed her, heââ¬â¢d have done it because he was jealous of me, because Tatiana liked me better. Not because of all those other women he was doing.ââ¬â¢ ââ¬Å"Why wouldnââ¬â¢t Ambrose just kill you?ââ¬â¢ asked Christian. ââ¬Å"Makes more sense.ââ¬â¢ Blake didnââ¬â¢t have a chance to respond because Adrian was still back on the earlier topic, his eyes flashing with anger. ââ¬Å"My mother wasnââ¬â¢t sleeping with anybody. She doesnââ¬â¢t even sleep with my father.ââ¬â¢ Blake continued in his oblivious way. ââ¬Å"Hey, I saw them. They were all over each other. Did I mention how hot yourââ¬âââ¬Ë ââ¬Å"Stop it,ââ¬â¢ warned Lissa. ââ¬Å"Itââ¬â¢s not helping.ââ¬â¢ Adrian clenched his glass. ââ¬Å"None of this is helping!ââ¬â¢ Clearly, things werenââ¬â¢t going the way heââ¬â¢d hoped when heââ¬â¢d first summoned Lissa and Christian from her room. ââ¬Å"And Iââ¬â¢m not going to sit and listen to this bullshit.ââ¬â¢ Adrian downed the drink and shot up from his chair, turning abruptly for the exit. He tossed some cash on the bar before walking out the door. ââ¬Å"Poor guy,ââ¬â¢ said Blake. He was back to his calm, arrogant self. ââ¬Å"Heââ¬â¢s been through a lot between his aunt, mom, and murdering girlfriend. Thatââ¬â¢s why really, at the end of the day, you just canââ¬â¢t trust women.ââ¬â¢ He winked at Lissa. ââ¬Å"Present company excluded, of course.ââ¬â¢ Lissa felt as disgusted as Adrian, and a quick glance at Christianââ¬â¢s stormy face showed he felt the same. It was time to go before someone really did punch Blake. ââ¬Å"Well, itââ¬â¢s been great talking to you, but we need to go.ââ¬â¢ Blake gave her puppy-dog eyes. ââ¬Å"But you just got here! I was hoping we could get to know each other.ââ¬â¢ It went without saying what he meant by that. ââ¬Å"Oh. And Kreskin too.ââ¬â¢ Christian didnââ¬â¢t even bother with a correction this time. He simply took hold of Lissaââ¬â¢s hand. ââ¬Å"We have to go.ââ¬â¢ ââ¬Å"Yeah,ââ¬â¢ agreed Lissa. Blake shrugged and waved for another drink. ââ¬Å"Well, any time you want to really experience the world, come find me.ââ¬â¢ Christian and Lissa headed for the door, with Christian muttering, ââ¬Å"I really hope that last part was meant for you, not me.ââ¬â¢ ââ¬Å"Thatââ¬â¢s no world I want to experience,ââ¬â¢ said Lissa with a grimace. They stepped outside, and she glanced around, in case Adrian had lingered. Nope. He was gone, and she didnââ¬â¢t blame him. ââ¬Å"I can see now why Ambrose and Adrian donââ¬â¢t like him. Heââ¬â¢s such a â⬠¦Ã¢â¬â¢ ââ¬Å"Asshole?ââ¬â¢ supplied Christian. They turned toward her building. ââ¬Å"I suppose so.ââ¬â¢ ââ¬Å"Enough to commit murder?ââ¬â¢ ââ¬Å"Honestly? No.ââ¬â¢ Lissa sighed. ââ¬Å"I kind of agree with Ambrose â⬠¦ I donââ¬â¢t think Blakeââ¬â¢s smart enough for murder. Or that the motiveââ¬â¢s really there. I canââ¬â¢t tell if people are lying or not from their auras, but his didnââ¬â¢t reveal anything overly dishonest. You joked, but if anyone was going to commit a jealous murder, why wouldnââ¬â¢t the guys want to kill each other? A lot easier.ââ¬â¢ ââ¬Å"They did both have easy access to Tatiana,ââ¬â¢ Christian reminded her. ââ¬Å"I know. But if there is love and sex involved here â⬠¦ it seems like itââ¬â¢d be someone jealous of the queen. A woman.ââ¬â¢ A long, meaningful pause hung between them, neither of them wanting to say what they were both likely thinking. Finally, Christian broke the silence. ââ¬Å"Say, like, Daniella Ivashkov?ââ¬â¢ Lissa shook her head. ââ¬Å"I canââ¬â¢t believe that. She doesnââ¬â¢t seem like the type.ââ¬â¢ ââ¬Å"Murderers never seem like the type. Thatââ¬â¢s why they get away with it.ââ¬â¢ ââ¬Å"Have you been studying up on your criminology or something? â⬠ââ¬Å"No.ââ¬â¢ They reached her buildingââ¬â¢s front door, and he opened it for Lissa. ââ¬Å"Just laying out some facts. We know Adrianââ¬â¢s mom never liked Tatiana for personality reasons. Now we find out that they were sharing the same guy.ââ¬â¢ ââ¬Å"She has an alibi,ââ¬â¢ said Lissa stonily. ââ¬Å"Everyone has an alibi,ââ¬â¢ he reminded her. ââ¬Å"And as weââ¬â¢ve learned, those can be paid for. In fact, Daniellaââ¬â¢s already paid for one.ââ¬â¢ ââ¬Å"I still canââ¬â¢t believe it. Not without more proof. Ambrose swore this was more political than personal.ââ¬â¢ ââ¬Å"Ambrose isnââ¬â¢t off the list either.ââ¬â¢ They came to Lissaââ¬â¢s room. ââ¬Å"This is harder than I thought it would be.ââ¬â¢ They went inside, and Christian wrapped his arms around her. ââ¬Å"I know. But weââ¬â¢ll do it together. Weââ¬â¢ll figure it out. But â⬠¦ we might want to keep some of this to ourselves. Maybe Iââ¬â¢m overreacting here, but I think itââ¬â¢d be best if we donââ¬â¢t ever, ever tell Adrian his mom has an excellent motive for having killed his aunt.ââ¬â¢ ââ¬Å"Oh, you think?ââ¬â¢ She rested her head against his chest and yawned. ââ¬Å"Naptime,ââ¬â¢ said Christian, leading her toward the bed. ââ¬Å"I still need a shower.ââ¬â¢ ââ¬Å"Sleep first. Shower later.ââ¬â¢ He pulled back the covers. ââ¬Å"Iââ¬â¢ll sleep with you.ââ¬â¢ ââ¬Å"Sleep or sleep?ââ¬â¢ she asked dryly, sliding gratefully into bed. ââ¬Å"Real sleep. You need it.ââ¬â¢ He crawled in beside her, spooning against her and resting his face on her shoulder. ââ¬Å"Of course, afterward, if you want to conduct any official Council business â⬠¦Ã¢â¬â¢ ââ¬Å"I swear, if you say ââ¬Å"Little Dragomirs,ââ¬â¢ you can sleep in the hall.ââ¬â¢ Iââ¬â¢m sure there was a patented Christian retort coming, but another knock cut him off. He looked up in exasperation. ââ¬Å"Donââ¬â¢t answer it. For real this time.ââ¬â¢ But Lissa couldnââ¬â¢t help herself. She broke from his embrace and climbed out of bed. ââ¬Å"Its not Adrian â⬠¦Ã¢â¬â¢ ââ¬Å"Then itââ¬â¢s probably not important,ââ¬â¢ said Christian. ââ¬Å"We donââ¬â¢t know that.ââ¬â¢She got up and opened the door, revealingââ¬âmy mother. Janine Hathaway swept into the room as casually as Adrian had, her eyes sharp as she studied every detail around her for a threat. ââ¬Å"Sorry I was away,ââ¬â¢ she told Lissa. ââ¬Å"Eddie and I wanted to set up an alternating system, but we both got pulled for duty earlier.ââ¬â¢ She glanced over at the rumpled bed, with Christian in it, but being who she was, she came to a pragmatic conclusion, not a romantic one. ââ¬Å"Just in time. I figured youââ¬â¢d want to sleep after the test. Donââ¬â¢t worryââ¬âIââ¬â¢ll keep watch and make sure nothing happens.ââ¬â¢ Christian and Lissa exchanged rueful looks. ââ¬Å"Thanks,ââ¬â¢ said Lissa. How to cite Last Sacrifice Chapter Nineteen, Essay examples
Thursday, December 5, 2019
Customer Loyalty Marketing Research â⬠Free Samples to Students
Question: Discuss about the Customer Loyalty Marketing Research. Answer: Introduction The report of the hotel chain illustrates the critical analysis of the management decision taken by the senior management of the hotel. The management decision of the hotel is based on the technology and the systems of the company based on the different IT implementation. The report will discuss about the development of the operational aspects of the ten hotel chains such as brand loyalty, continued patronage, customer choice, etc. The usage patterns of ICT in the organization are also discussed in detailed with their potential issues in it. The aim of the restaurant is to increase the strength of the customer base of the hotel chain along with the improved management operations and the goals and objectives of the company. The use of ICT is to gain the competitive advantage of the hotel chain in the market. Recommendations are to be formulated which are based on the aspects of the management decisions as well as technology implementation in the project. The case study consists of the merging of few hotels i.e. ten hotels in a single hotel chain in order to combat the pressure of the market for accommodation purpose of the lower accommodation hotel. However, it can be said that the new hotel chain has different categories of hotel starting from bed breakfast homes to backpacker to luxurious suites. The new hotel chain is known as Stay Together[1]. The aim of the hotel chain is to combat the sales of the websites like hotels.com, booking.com, etc. that are responsible for lesser sale of the hotel rooms. The main aim is to form a single website which will be provided to the customers from where they can book the accommodation and other facilities related to it. The price of the products will be remains same in all seasons except the peak season. The following section discusses about the critical analysis of the management decisions of the hotel chains[2]. Loyalty schemes are used in any businesses that are proven to be beneficial not only in attracting customers but also in order to maintain the loyalty of the customers and residents of hotel who are using the services of the hotel. The loyalty scheme of the hotel chain will be competitive enough in order to use the services of the hotels more than the regular services of the hotel. It can be said that the customer loyalty scheme of the hotel chain is Stay Together Loyalty that will reward its customers with different facilities such as car parking, free nights, airport transfers, etc. The loyalty programs of the hotel chain are structured in terms of the marketing strategies that are formulated for the customers[3]. For instance, customers who are using regular services of the hotels, they are provided with different kinds of customers in the hotel. The loyalty programs of the hotel are formulated in a way so that they can meet the needs of the customers individually. On the other ha nd, it can be said that sometimes the individual schemes of the hotel chains sometimes causes failure in the loyalty schemes of the different types of customers which are not satisfying the expectations of the hotel residents. The good aspect of the loyalty programs of the hotel chains are that it can attract new customers as well as the retention of the existing customers. The marketing techniques are also included in it[4] Free buffet breakfast and dinner In terms of hotel industry, free breakfast and dinner or buffet are common offers that the hoteliers provide to the customers. It can be said that the free buffet or other times of meals are treated as complimentary treatment to the customers. The customers and tourists usually welcome any thing which is free. The senior management of the company decided that will include dinner and breakfast which will be included in the cost of the hotel room charges. The company StayTogether will include this thing in the website in the offers section of the website. It is one of the factors that will increase the customer loyalty of the hotel visitors[5]. The scheme of quality breakfast and meals is responsible for creating a competitive advantage of the hotels in the industry. It is seen that most of the customers search for hotels that have free breakfast or dinner. The customers will not have to go to other places in order to have breakfast and dinner which is irritating sometimes for them. It is seen that the hotels of the company are having more customers due to the complimentary breakfast provided to them. Research has proved the fact that the relationship between the visitors and the management of the hotels also gets increased due to the complementary aspects of breakfast and dinner. However, it is also a fact that this scheme will not affect the customers who are having breakfast or dinner from different exclusive restaurants. They will not be attracted towards this scheme of StayTogether[6]. Rebates are considered as a remarkable decision of the management of the company that has decided by the company in order to increase the customer satisfaction of the hotel chains. Rebate system will encourage the customers in order to book the hotels along with the other transportation facilities of the places. For instance, it can be said that the StayTogether include rebate systems to the customers in terms of the airlines booking. The visitors of the hotel are interested in the transportation of the places that are related with the tours and travels. The rebates are responsible for attracting the visitors of the hotel[7]. The management decision of the company is focusing on the development of mobile app in terms of rebates. The visitors of the webpage are provided with deals and discounts related to the hotel rentals and other services of hotels. Rebates are different for different types of customers. If they are using the website rebates are different. On the other hand, if the customers are using the mobile application then they will be getting different types of deals and offers[8]. This will affect the customer relationship with the hotel chain with the customers. Customer relationship is the important aspect in the hotel industry in order to seek customer retention and relationship. It will help in the different types of Word of Mouth Promotion of the hotel chains. On the other hand, it can be said that the sometimes the customers may not get happy with the services of transportation that are offered by the hotel chain in rebates[9]. Social responsibility Corporate social responsibility is the important part of the aspect of the business. The business responsibilities of the hotel chain group are mandatory as it comes under the regulation of the government of the country. It is seen that the hotel chain is contributing 1% of the income of every bill received from the customers. The customers are given an opportunity in order to contribute to the charity provided by the company to the community[10]. The decision taken by the different officials of the senior management of the hotel chain is considered as a master stroke by them in terms of the marketing campaigns of the hotel group. People nowadays are responsible for the contributor of the sustainability aspects in a different way. Companies nowadays promote the element of sustainability in their operational departments of companies in order to attract more customers to it. It can be said that the company has mentioned the impact of the charity donations to the various charity homes[11]. This is an indirect marketing technique used by the group of hotels in order to increase their corporate brand image among the different charity organizations. Apart from that, the visitors of the website are given the choice in order to select their preferred charity organizations while donating their contributions to it. Finally, it has been found that this helps in increasing rate of bookings of the hotel rooms of the different hotels of the hotel chain. It is indirectly helping the company for new customer attraction and retention of the existing visitors of the company[12]. IT and IS issues are more or less same in terms of technical aspect. IT issues refers to Information Technology issues while on the other hand IS issues refers to Information System issues. The issues can be categorized into different categories such as technology compatibility issues, scalability issues, sustainability issues, data conversion issues, employment issues, legal issues, user interface issues, employment issues, etc. The different types of technology compatibility issues are related with the improper development of the website or improper web designing elements in their company websites[13]. The scalability issues is related to the usage if the various technologies of IT and IS within the budget provided to the company. Data conversion loss is a big issue in terms of the hotel chain. It can lead to huge data loss. Data loss can leads to dissatisfaction of the customers in terms of loss of their information from the system. In terms of data conversion, sometimes technical faults can occurs that is also a cause of bad customer relationship management[14]. Apart from that, there are legal issues that the company can face in terms of the patented issues. The company must have to have the patent their technologies and their website so that the rival companies should not copy the technologies as well as other services offered by the company. The technology capability issues are related to the user interface issues of the customers to use the website of the new hotel chain. If the digital marketing and the improper website designing of the company is not done properly, then the user will find problem in using the website for finding different issues of the website. The employability issues are a vital problem for the new hotel chain. The hotel chain has to cut many employees from the office as human skill is replacing into machines which is cost effective[15]. Conclusion It can be concluded that though the group of hotels is planning to form a hotel chain and form a website of their own in order to gain a competitive advantage in the market. The problem is related to the different types of problems faced by the hotel chain while opening the website and incorporating it to the users. There are numerous advantages as well as disadvantages regarding IT and IS issues related to the website development of the company. However, recommendations are to be provided in order to mitigate the issues faced by the hotel chain. Recommendations are to be followed in terms of the different technical issues of the hotel chain. A strong team needs to be recruited by the company. The scalability issues of the company should be solved with a proper budget for the implementation. Human skill is required to control the activities of the technology. The technical faults should be addressed by the digital market team. Different forms of technology related to customer relationship management are to be implemented[16]. References Fakharyan, Meysam, Sadaf Omidvar, Mohammad Reza Khodadadian, Mohammad Reza Jalilvand, and Leila Nasrolahi Vosta. 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