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Island at the British Pavilion 2018
PAVILION OF GREAT BRITAIN AT THE 16TH INTERNATIONAL ARCHITECTURE EXHIBITION LA BIENNALE DI VENEZIA
The British Pavilion is commissioned by the British Council; please make sure to credit the British Council in all editorial features.
The British Council unveils Island at the British Pavilion for the 16th International Architecture Exhibition – La Biennale di Venezia opens Thursday 24 May.
The curatorial team, Caruso St John Architects with artist Marcus Taylor, have responded to Freespace, the theme of Biennale Architettura 2018 – set by the curators Yvonne Farrell and Shelley McNamara – with the construction of a new public gathering space in the Giardini. This marks the first joint art and architecture curatorial team commissioned for the British Pavilion.
Visitors approaching the British Pavilion will find the building covered with scaffolding supporting a wooden platform at roof-level. A staircase running the length of one side of the building leads up to an elevated piazza, a place to meet or to relax amongst the tree-tops of the Giardini, open to the sky with views across the Lagoon. Tea will be served at 4 p.m. each day, with seats and umbrellas offering comfort and shade. The peak of the Pavilion's roof projects up through the floor at the centre of the space, suggesting both an island and a sunken world beneath.
Throughout La Biennale di Venezia, the British Pavilion will host a programme of events, performances, installations and debates responding to the theme of Freespace and ideas raised by Island. The programme has been produced in collaboration with partners including Tate Collective, the Royal Academy of Arts, the Design Museum, musician Matthew Hebert, poet Inua Ellams, Studio Wayne Mcgregor and many more. It will address topics ranging from migration and decolonisation to language and borders, from isolation and identity to buildings and landscapes.
The programme is launched at the opening of the Pavilion with a performance by spoken word artist Kate Tempest. On Friday 25 May, the Pavilion hosts the Royal Institute of British Architects' EUROPA Super Session, to explore the future of architecture practice across Europe at this pivotal moment in history. This is followed by No Place Like Home, in which experts from a range of backgrounds present their perspectives on climate change and migration. With the exception of these performances, the building will be empty, abandoned and untouched after the last exhibition. A detailed schedule of events at the Pavilion will be made available to visitors at the start of each month from June to November.
In a joint statement, the curatorial team of Adam Caruso, Peter St John and Marcus Taylor said:
"In past Biennales, the Pavilion has held curated exhibitions on architectural themes. This year, we have taken a different approach. There will be no exhibits; instead we have realised a structure that can be experienced like a building. There are many ways to interpret the experience of visiting Island and the state of the building suggests many themes; including abandonment, reconstruction, sanctuary, Brexit, isolation, colonialism and climate change. It is intended as a platform, in this case also literally, for a new and optimistic beginning. It is forward looking whilst acknowledging the past, whether good or bad."
Sarah Mann, Director of Architecture Design Fashion at the British Council and Commissioner of the British Pavilion 2018 said:
"This year's winning proposal, Island, will represent Great Britain at the most influential gathering for contemporary art and architecture anywhere in the world. We are thrilled to present this new structure for the British Pavilion which breaks with convention, creating a place for visitors to meet and engage with the building and each other, in a new way. The accompanying programme of events will highlight the Pavilion's role as a space for debate, for exchange of ideas and for visionary thinking."
An accompanying publication brings together a collection of works that have informed the project. Published by The Store X The Spaces, the book features contributions from Kate Tempest and artist John Akomfrah, a reprint of Shakespeare's Tempest and three short stories by Trinidad-born writer Sam Sevlon. The publication also features installation photographs by architectural photographer Hélène Binet and an introductory essay by Penelope Curtis, director of Lisbon's Museu Calouste Gulbenkian. John Morgan Studio has created a graphic identity for the project that takes its cue from the first edition of James Joyce's Ulysses, the cover of which, with the title set in white on a blue background, was said to resemble a chain of white islands in a blue sea.
The British Council has been responsible for the British Pavilion in Venice since 1937, showcasing the best of the UK's artists, architects, designers and curators to an international audience. This year, the British Council will also support the participation of UK architects and designers in the central exhibitions at La Biennale di Venezia.
In addition, the British Council's Venice Fellowships supports a group of over 60 UK-based students, young professionals and researchers to go to Venice to invigilate the Pavilion and undertake independent research. The Fellows have been selected and supported through partnerships with 29 universities and institutions. Each month a new group of Fellows will be at the British Pavilion to assist visitors, answer questions and offer information on the programme of events taking place. During their month in Venice, the Fellows undertake a research project responding to the context of Venice or the ideas of Freespace and Island. The Venice Fellowships offer students and recent graduates an opportunity to gain international experience, develop key skills and networks within the arts and architecture sector.
Please find the full press pack, including images here: https://venicebiennale.britishcouncil.org/press
The 16th International Architecture Exhibition - La Biennale di Venezia opens to the public on Saturday, 26 May and closes on Sunday, 25 November 2018. The Vernissage is on 24 and 25 May 2018.
Updates Online
Follow updates about the #BritishPavilion at:
Twitter: @British_Design
Instagram: @British_Design
Facebook: BritishArts
Official La Biennale di Venezia hashtags: #BiennaleArchitettura2018 #FREESPACE
Find out more about the British Pavilion in Venice: www.britishcouncil.org/venicebiennale
It's Nice That Instagram Partnership
Drawing on the themes of Island, design platform It's Nice That invites designers to create a flag representing the values of their own imagined island, to explore ideas of identity and culture through design. Audiences are encouraged to submit their creations on Instagram during ten days in July. www.itsnicethat.com www.instagram.com/itsnicethat
For further information and interviews about the British Pavilion at the 16th International Architecture Exhibition - La Biennale di Venezia, please contact ING Media:
Laura Colapietro
E: Laura.colapietro@ing-media.com
DL: +44 (0) 20 7392 1999
M: +44 (0) 7534 970 576
Serra Ataman
E: serra.ataman@ing-media.com
Benno Rembeck
E: benno.rembeck@ing-media.com
Sophie Reid
E: sophie.reid@ing-media.com
T: + 44 (0) 20 7247 8334
For more information about the British Council, please contact:
Karolina Szlasa | E: Karolina.szlasa@britishcouncil.org | DL: +44 (0)203 285 3659 | M: +44 (0) 7769 285079
The British Council is the UK's international organisation for cultural relations and educational opportunities. We work with over 100 countries in the fields of arts and culture, English language, education and civil society. Last year we reached over 65 million people directly and 731 million people overall including online, broadcasts and publications. We make a positive contribution to the countries we work with – changing lives by creating opportunities, building connections and engendering trust. Founded in 1934 we are a UK charity governed by Royal Charter and a UK public body. We receive 15 per cent core funding grant from the UK government. britishcouncil.org
Caruso St John Architects was founded in 1990 by Adam Caruso and Peter St John. The practice has completed major projects throughout Europe and was awarded the 2016 RIBA Stirling Prize for the Newport Street Gallery built for Damien Hirst to show-case his collection of contemporary art. www.carusostjohn.com
Marcus Taylor has exhibited widely in the UK and overseas. His work has been collected by several major institutions including the Tate and Foundation Cartier. He has collaborated on several architectural projects as part of his artistic practice, most recently with Caruso St John Architects on the competition for the United Kingdom Holocaust Memorial next to the Houses of Parliament.
About the Venice Fellowships
The Venice Fellowships enables students, graduates and researchers to spend a month in Venice during one of the world's most significant art and architecture exhibition organised by La Biennale di Venezia. This year the British Council is working with 29 partner universities and institutions to send 69 Fellows to Venice. https://venicebiennale.britishcouncil.org/fellowship
About Pavilion Patrons
The Pavilion Patron scheme supports the preservation of the British Pavilion as a historic venue and the ambitions of artists and architects, demonstrating excellence in contemporary arts and architecture on a global stage. With thanks to our Patron's hospitality partner Hotel Danieli, a Luxury Collection Hotel, Venice. www.britishcouncil.org/arts/venice-biennale-pavilion-patron
About The Store X The Spaces
The Store X is a platform for presenting ideas and culture that engages a global community of icons, innovators, creators and the curious in an ever-evolving dialogue. The Spaces is a design, art and property publication exploring new ways to live and work. It calls on leading artists, architects, critics, curators and photographers to re-examine how we use the spaces around us, presenting their ideas on digital magazine TheSpaces.com and in limited-edition books. www.thespaces.com
The accompanying book for Island can be bought at La Biennale shop and online at The Spaces: www.thespaces.com/books
Scaffolding is provided by Altrad Generation and Altrad DESSA.
www.generationscaffolding.com www.dessa.co.uk


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Scientist Discovers New Element, Names It After His Ex-Girlfriend
by Andy Leeds on 4/12/2005 (0)
Behold, Fluffybunnyium!
This past Monday, high school science student Zach Young's many late nights of experiments paid off with the discovery of the 119th element, but the excitement of his discovery was overshadowed by his own broken heart. The jilted teenage lover had thrown himself into his work after being dumped by his girlfriend.
"I wanted someone who did not stink of cat piss," said seventeen year old Amanda Wilson when asked why she would leave such a promising young man.
"Ammonia is essential to my work," explained a tearful Zach. "She was asking me to choose between science and her. I couldn't do that."
In an effort to win her back, Zach will dedicate his monumental discovery to his lost love.
"I called it Fluffybunnyium, it was my pet name for Amanda," Zach needlessly explained.
Young discovered the element while recording the results of several fungal cultures he was monitoring.
"I was obviously very upset, but I needed to record how many spores were dropped every hour, so I wiped away my tears and got on with it," sniffed Zach. "Then I noticed the element mixed in with the spores, it was unlike anything I had seen before, and was not in my textbooks, so I called the physics lab at Cal-Tec, who later verified the discovery."
Although Fluffybunnyium is of no real value to most people, given that only 20 grams of it exist on Earth, scientists are still thrilled at its discovery.
"Its amazing, most of the recent elements have only been created in high tech labs, and the last few only really exist in theory," said leading partial physicist Professor Clifford V. Johnson. "For Zach to actually find this in solid form is really beyond our wildest expectations. It just goes to show that you can never underestimate the contents of your basement fungi."
"I'm happy for Zach and I hope that now he can move on with his life and stop sending me email, cards, and flowers," said Amanda Wilson. "I found someone new, I didn't want a smelly boyfriend who never left his mothers basement. I wanted to go out now and again. I'm a woman, not a fungus. Sitting in the dark night after night was starting to really depress me."
Amanda, who was with new boyfriend Ted Hatcher, went on to describe her happiness with new love.
"Ted is different, we spend more time doing stuff, and we are very much in love. We do...erm, more fun things in the dark."
Upon hearing this news, Zach was visably distraught and unable to comment further. He has however agreed to give us a full interview after the official naming ceremony of element 119, now to be named Bitchium.h="0" hei

redpajama_set_name: RedPajamaCommonCrawl


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Home ARCONTES US govt to issue wallet-sized COVID-19 proof of vaccination cards
ARCONTES
US govt to issue wallet-sized COVID-19 proof of vaccination cards
Releasing the image on the Department of Defense (DOD) website, the description says that they 'will be sent out as part of vaccination kits from Operation Warp Speed.'
By Michael Haynes,
As COVID-19 vaccines prepare to be rolled out, the Department of Defense has released an image of a wallet-sized vaccination record card, which will be given to everyone who receives a COVID-19 vaccine.
Releasing the image on the Department of Defense (DOD) website, the description says that they "will be sent out as part of vaccination kits from Operation Warp Speed."
The kit will further include "a card, a needle and syringe, alcohol wipes and a mask."
Reporting on the news of the card, Dr. Kelly Moore, associate director of the Immunization Action Coalition which is involved in distributing the vaccine, said "Everyone will be issued a written card that they can put in their wallet that will tell them what they had and when their next dose is due. Let's do the simple, easy thing first. Everyone's going to get that."
Moore also stated that people would be widely asked to volunteer their cell number, in order to "get a text message telling them when and where their next dose is scheduled to be administered."
CNN added that "Vaccination clinics will also be reporting to their state immunization registries what vaccine was given, so that, for example, an entity could run a query if it didn't know where a patient got a first dose."
The Texas Department of State Health Services, in an updated instruction on their website, includes mention of the vaccine record card. Providers of the vaccine "must provide a completed COVID-19 vaccination record card to every COVID-19 Vaccine recipient." The card will be included in the vaccine shipment.
Similar information regarding the use of the vaccine record card is contained on the Department of Health for Minnesota's website.
A document detailing the vaccination program, compiled by the CDC, consistently refers to the vaccination card. "Provide a completed COVID-19 vaccination record card to every vaccine recipient/parent/legal representative," the document states, when listing the duties of a vaccine provider.
In an October article Dr. Michael Yeadon,who "spent over 30 years leading new [allergy and respiratory] medicines research in some of the world's largest pharmaceutical companies," and retired from the COVID-19 vaccine developer, Pfizer, with "the most senior research position in this field," dismissed the need for a COVID-19 vaccine.
Yeadon stated: "There is absolutely no need for vaccines to extinguish the pandemic. I've never heard such nonsense talked about vaccines. You do not vaccinate people who aren't at risk from a disease. You also don't set about planning to vaccinate millions of fit and healthy people with a vaccine that hasn't been extensively tested on human subjects."
The technology involved in administering the vaccine, as used by Pfizer and Moderna, is so novel that it has yet to be approved by the Food and Drug Administration, as admitted by Pfizer itself.
It also avails of "messenger RNA," which directly affects a person's cells, and is "a vaccine technology that's so new, no mRNA vaccines have ever been approved by the Food and Drug Administration."
Doctors from the Advisory Committee on Immunization Practices (ACIP), advising the CDC, warned that patients needed to be informed about the side-effects of COVID-19 vaccines. According to a report from CNBC, Dr. Sandra Fryhofer of the American Medical Association stressed, "We really need to make patients aware that this is not going to be a walk in the park," she said. "They are going to know they had a vaccine. They are probably not going to feel wonderful. But they've got to come back for that second dose."
Some of the immediate results from some of the vaccine trials have included "severe" complications, involving headaches, fever, body aches and symptoms similar to a "severe hangover.
To register complaints and concerns about the vaccination card, visit the U.S Department of Health and Human Services page or the Centers for Disease Control here and here.
Source: https://www.lifesitenews.com
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Nonsense Makes No Sense: A "vaccine" that is so safe, they asked for and received immunity from liability.
Quentin Holt, Deplorable Thought Criminal December 5, 2020 At 8:25 AM
Actually, a person really can be made to take a vaccine. I have known of people in bug houses that were made to take debilitative "tranquilizers" that they did not want to take. If extreme duress and threat of force did not work, actual force did. There were an unlimited number of "hospital attendants" available to tackle the recalcitrant "patient" and administer shots As far as big government is concerned, we are all wards of the state and, like "mental patients," do not know what is good for us. They have ways to "enforce compliance." Well, the insane asylum has more inmates than it has staff and we inmates are more sane than the bug house administration.. Only if we unite in opposition can we defeat the tyrants. So far they have been defeating us because too many of us believe in their dream world of lies and deceptions.. That seems to be changing for the better.
LaVerne December 5, 2020 At 1:13 PM
I was in Home Depot the other day & complimented someone who was wearing a beautiful 2nd Amendment jacket, but I continued to say "you must work on the 1st Amendment as well & take off that mask." He continued to tell a story of some young lady getting thrown out of the grocery store that he was at & proceeded to claim two employees took her by the arms & showed her the door. The moral of me typing this in is to show how people misdirect what really happened to cover up there own inability. The reason I know he was embellishing the story is because no store employee in their right mind would touch a customer, your talking about a major Law suit. I asked him what grocery store that happened in & the one he claimed is the same one I have been shopping at nonstop since this nonsense started. I have not worn a mask, nor will I ever cover up my ability to Speak, Smile or Breath.
Oh Enough Already! The title alone is ridiculous, No One can make anyone get any vaccine, period. This goes for anyone anywhere.


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Category Archives: Myanmar
Politicial Perception: Myanmar, Rohingya, Terrorist Provocateur
Posted by commart in 21st Century Feudal, Asia, Burma, Conflict - Culture - Language - Psychology, Islamic Small Wars, Myanmar, Political Psychology, Politics
Burma, Islamic extremism, Islamist victimization of Muslims, Islamists, Myanmar, political infiltration, political theater, Rohingya, terrorism
But not everyone wants to be sacrificed. When vigilante mobs and Myanmar's soldiers burned down his village, Noor Kamal, 18, tried to flee with his 6-year-old brother, Noor Faruq. Both were hacked in the head by ethnic Rakhine armed with machetes and scythes.
At a bleak government hospital in Cox's Bazar, Bangladesh, Noor Kamal shivered with outrage at the ARSA insurgents from his village in northern Maungdaw Township, who attacked a local police post last month. "We are the ones who are suffering because of Al Yaqin," he said. "They disappeared after the attack. We were the ones left behind for the military to kill."
Beech, Hannah. "Rohingya Militants Vow to Fight Myanmar Despite Disastrous Cost." The New York Times, September 17, 2017.
The Rohingya, marginalized in Burma / Myanmar and ripe for agitation by Islamist organizations have been forced into conflict by way of the agitation and provocations produced by the latter.
As you read through the excerpts chosen by BackChannels for display and continue following the story, the image of the "poor Rohingyans" being placed at the mercy of Myanmar military may need to be modified by the barbaric criminality produced by those who have infiltrated their numbers.
Still, what compels Myanmar to use so much force against the Rohingya?
BackChannels would venture that earlier border insecurity and inability to defend informants and detect the Islamists for arrest have contributed to the wholesale response.
In essence, the Ummah is especially being "played" — manipulated! — by Islamic extremists who have learned how to abuse the innocent among Muslims to turn them into the victims of larger but also legitimate forces. This is the same model that Hamas has used in its rapacious abuse of the Palestinians to create the showcase of victimization while the leadership and patronage system make off with billions in loot wrung from global sympathy.
https://www.crisisgroup.org/asia/south-east-asia/myanmar/283-myanmar-new-muslim-insurgency-rakhine-state – 12/15/2016:
The insurgent group, which refers to itself as Harakah al-Yaqin (Faith Movement, HaY), is led by a committee of Rohingya émigrés in Saudi Arabia and is commanded on the ground by Rohingya with international training and experience in modern guerrilla war tactics. It benefits from the legitimacy provided by local and international fatwas (religious judicial opinions) in support of its cause and enjoys considerable sympathy and backing from Muslims in northern Rakhine State, including several hundred locally trained recruits.
The emergence of this well-organised, apparently well-funded group is a game-changer in the Myanmar government's efforts to address the complex challenges in Rakhine State, which include longstanding discrimination against its Muslim population, denial of rights and lack of citizenship. The current use of disproportionate military force in response to the attacks, which fails to adequately distinguish militants from civilians, together with denial of humanitarian assistance to an extremely vulnerable population and the lack of an overarching political strategy that would offer them some hope for the future, is unlikely to dislodge the group and risks generating a spiral of violence and potential mass displacement.
http://www.cnn.com/2017/09/12/asia/arsa-rohingya-militants-who-are-they/index.html – 9/12/2017
http://www.abc.net.au/news/2017-09-14/al-qaeda-urges-muslims-globally-to-aid-rohingya-in-myanmar/8946390 – 9/14/2017
Al Qaeda has warned Myanmar will face punishment for its "crimes against the Rohingyas".
"The savage treatment meted out to our Muslim brothers … shall not pass without punishment," Al Qaeda said in a statement, according to the SITE monitoring group.
"The Government of Myanmar shall be made to taste what our Muslim brothers have tasted."
https://www.reuters.com/article/us-myanmar-rohingya/at-least-71-killed-in-myanmar-as-rohingya-insurgents-stage-major-attack-idUSKCN1B507K – 8/24/2017
https://www.cnbc.com/2017/09/13/myanmar-rohingya-crisis-islamic-terror-groups-may-take-advantage.html – 9/13/2017
http://www.mizzima.com/news-domestic/uehrd-begins-reconstruction-houses-rakhine-state
Myanmar has launched a project of re-construction of destroyed houses in conflict-torn areas in northern Rakhine state under a mechanism of the Union Enterprises for Humanitarian Assistance, Resettlement and Development (UEHRD), Xinhua reported quoting the Myanmar News Agency.
Someone always has to pick up the pieces — and the terrorists never do.
https://www.timesofisrael.com/mounting-evidence-of-genocide-in-myanmar-watchdogs-warn/ – 11/16/2017. Related: BBC – "Tillerson Calls for Myanmar Rohingya Investigation" – 11/15/2017; CNN – "Tillerson refuses to label Rohingya crisis 'ethnic cleansing,' calls for investigation" – 11/15/2017; Sky News – "Tillerson: Scenes of Rohingya suffering 'just horrific'" – 11/15/2017.


Another of my Mum's classic recpies - I thought it was about time I shared it! I stuff these peppers with a beef and rice mixture, but you could easily substitute the meat for quorn, or a vegetable mix. You could also change the rice for cous cous or quinoa which are equally as tasty!
Start off by chopping your peppers length ways, de-seeding, and popping in the microwave for a few minutes to soften. Keep an eye on them, but about 3-5 minutes is usually about right.
Put your rice on to cook following usual instructions. While the rice and peppers are cooking fry a diced onion in a pan, and when browned add the mince and combine. When cooked, drain off any excess fat (if necessary) and crumble over a stock cube. Cook for a further few minutes then put to one side. When the mince mixture and rice are both cooked, combine!
Place your peppers into an ovenproof dish and spoon in the beef and rice mixture - press down with a spoon to fill as much as possible. In a bowl defrost the spinach balls and add to a tin of tomatoes. Pour over the peppers and sprinkle with some grated cheese. Pop in the oven for about 45 minutes - 1 hour on about 180c.
Give each person either one or two peppers depending on greed hunger, and serve with steamed green veg. I usually just serve with vegetables, but this usually leaves a not-quite-full boyfriend... hence the homemade wedges this time! You can adjust the amount of rice you use in the stuffing mixture according to taste.
Brilliant recipe and it's given me loads of ideas of how to adapt it too ... thank you!
Man alive, these look delicious!


Aqueous (physiological saline) extracts of berry atom from seven aboriginal plants were initially buried for their antimosquito action adjoin eggs, larvae of all instars, and pupae of Aedes aegypti. Among assorted berry kernels tested, the Soapnut Extract was begin to exhibit, for the aboriginal time, a able antimosquito action as axiomatic from its adeptness to administer 100% bloodshed of all the adorning stages of A. aegypti.
Furthermore, the atom abstract of S. emarginatus aswell exerted ovicidal, larvicidal, and pupicidal action adjoin two added important abettor mosquitoes, namely, Anopheles stephensi and Culex quinquefasciatus. Differential susceptibility of the assorted adorning stages of the three mosquito breed apparent to Soapnut Extract was aswell noticed. The atom abstract was begin to be safe for two nontarget amphibian insects tested: the larvae of Chironomus costatus and the nymphs of Diplonychus rusticus. Lethal absorption ethics of Soapnut Extract to these nontarget insects were consistently threefold or fivefold college than those that produced 100% bloodshed of the larvae of the three mosquito breed examined.
The allegation of this abstraction acutely authenticate that the aqueous atom abstract of S. emarginatus has almighty antimosquito action apparent adjoin all the adorning stages of three important abettor mosquito breed as able-bodied as it is safe for nontarget amphibian organisms, and appropriately this new botanical ability could be acclimated as an eco-friendly another biocidal abettor in ascendancy of mosquitoes.


The Yankee Hill Machine Lightweight Series Mid-Length Forearm is an excellent upgrade for your AR-15. This fantastic forearm is made of high quality aluminum with mil spec rails and mounting points for sling swivel studs. This is an excellent way to mount vertical grips, lights, lasers, and optics.


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FCPA Professor A Forum Devoted to the Foreign Corrupt Practices Act
FCPA 101
FCPA Institute
FCPA Connect
On Measuring The Effectiveness Of A Compliance Program …
By Mike Koehler on September 4, 2018 in Compliance, Internal Controls
A reader (a compliance professional at a large publicly traded company with operations around the world) asks:
"One of the things I am struggling with is how to measure the effectiveness of a compliance program. I find it easy to measure activity, but the real value is in the avoidance of penalties and pre/post expenses, negative publicity, customer retention, share value reduction, etc. A good compliance program for a global company is a significant and costly investment and one that is always being reviewed and squeezed as business cycles fluctuate. The catch-22 is that the more effective the compliance program, the less issues that are identified, equaling more questions as to why we need such a significant investment. The programs own success can be its biggest challenge. Thoughts on ideas on effective measurements of a compliance program?"
Set forth below are my thoughts on this difficult issue – difficult because of what legal authority (as well enforcement agency guidance) actually say vs. seemingly conflicting actual FCPA enforcement actions and enforcement agency double-speak.
For starters, even though "effective" is a nice goal, the FCPA does not require issuers to have an "effective" compliance program.
Rather, the statutory standard is that issuers shall "devise and maintain a system of internal accounting controls sufficient to provide reasonable assurances that" certain financial objectives are met. The FCPA then defines "reasonable assurances" to "mean such level of detail and degree of assurance as would satisfy prudent officials in the conduct of their own affairs."
Moreover, the FCPA states:
"where an issuer … holds 50% or less of the voting power with respect to a domestic or foreign firm … [the books and records and internal controls provisions] require only that the issuer proceed in good faith to use its influence, to the extent reasonable under the issuer's circumstances, to cause such domestic or foreign firm to devise and maintain a system of internal accounting controls consistent [with the statutory standard]. Such circumstances include the relative degree of the issuer's ownership of the domestic or foreign firm and the laws and practices governing the business operations of the country in which such firm is located. An issuer which demonstrates good faith efforts to use such influence shall be conclusively presumed to have complied with the requirements of [the books and records and internal controls provisions]."
In enacting the FCPA's internal controls provisions, Congress noted:
"[M]anagement must exercise judgment in determining the steps to be taken, and the cost incurred, in giving assurance that the objectives expressed will be achieved. Here, standards of reasonableness must apply. In this regard, the term 'accurately' does not mean exact precision as measured by some abstract principle. Rather it means that an issuer's records should reflect transactions in conformity with generally accepted accounting principles or other applicable criteria. While management should observe every reasonable prudence in satisfying the objections called for [in the accounting provisions] the committee recognizes that management must necessarily estimate and evaluate the cost/benefit relationships to the steps to be taken in fulfillment of its responsibilities … The size of the business, diversity of operations, degree of centralization of financial and operating management, amount of contact by top management with day-to-day operations, and numerous other circumstances are factors which management must consider in establishing and maintaining an internal accounting controls systems." (See S. Rep. 95-114 (1977).
When the accounting provisions were amended in 1988 by defining the terms "reasonable assurance" and "reasonable detail" to mean such level of detail and degree of assurance as would satisfy prudent officials in the conduct of their own affairs," legislative history instructs:
"The prudent man qualification [was adopted] in order to clarify that the current standard does not connote an unrealistic degree of exactitude or precision. The concept of reasonableness of necessity contemplates the weighing of a number of relevant factors, including the costs of compliance."
In addition to above legal authority, SEC v. WorldWide Coin is believed to be the only judicial decision to construe the internal controls provisions. As highlighted in this previous post, the judge stated in pertinent part:
"The internal controls requirement is primarily designed to give statutory content to an aspect of management stewardship responsibility, that of providing shareholders with reasonable assurances that the business is adequately controlled.
Internal accounting control is, generally speaking, only one aspect of a company's total control system; in order to maintain accountability for the disposition of its assets, a business must attempt to make it difficult for its assets to be misappropriated. The internal accounting controls element of a company's control system is that which is specifically designed to provide reasonable, cost-effective safeguards against the unauthorized use or disposition of company assets and reasonable assurances that financial records and accounts are sufficiently reliable for purposes of external reporting. […] Internal accounting controls must be distinguished from the accounting system typically found in a company. Accounting systems process transactions and recognize, calculate, classify, post, summarize, and report transactions. Internal controls safeguard assets and assure the reliability of financial records, one of their main jobs being to prevent and detect errors and irregularities that arise in the accounting systems of the company. Internal accounting controls are basic indicators of the reliability of the financial statements and the accounting system and records from which financial statements are prepared.
"Among the factors that determine the internal accounting control environment of a company are its organizational structure, including the competence of personnel, the degree and manner of delegation and responsibility, the quality of internal budgets and financial reports, and the checks and balances that separate incompatible activities. The efficiency of the internal control system of a company cannot be evaluated without considering the company's organizational structure, the caliber of its employees, the strength of its audit committee, the effectiveness of its internal audit operation, and a host of other factors which, while not part of the internal control system itself, have an impact on the function of the system.
Although not specifically delineated in the Act itself, the following directives can be inferred from the internal controls provisions: (1) Every company should have reliable personnel … and all should be supervised. (2) Account functions should be segregated and procedures designed to prevent errors or irregularities. The major functions of recordkeeping, custodianship, authorization, and operation should be performed by different people to avoid the temptation for abuse of these incompatible functions. (3) Reasonable assurances should be maintained that transactions are executed as authorized. (4) Transactions should be properly recorded in the firm's accounting records to facilitate control, which would also require standardized procedures for making accounting entries. Exceptional entries should be investigated regularly. (5) Access to assets of the company should be limited to authorized personnel. (6) At reasonable intervals, there should be a comparison of the accounting records with the actual inventory of assets, which would usually involve the physical taking of inventory, the counting of cash, and the reconciliation of accounting records with the actual physical assets. Frequency of these comparisons will usually depend on the cost of the process and upon the materiality of the assets involved."
Notwithstanding the above, the judge struggled to articulate specific guidance for the accounting provisions and stated:
"The main problem with the internal accounting controls provision of the FCPA is that there are no specific standards by which to evaluate the sufficiency of controls; any evaluation is inevitably a highly subjective process in which knowledgeable individuals can arrive at totally different conclusions. Any ruling by a court with respect to the applicability of both the accounting provisions and the internal accounting control provisions should be strictly limited to the facts of each case."
Nevertheless, the judge offered the following key language:
"The definition of accounting controls does comprehend reasonable, but not absolute, assurances that the objectives expressed in it will be accomplished by the system. The concept of 'reasonable assurances' contained in [the internal controls provisions] recognizes that the costs of internal controls should not exceed the benefits expected to be derived. It does not appear that either the SEC or Congress, which adopted the SEC's recommendations, intended that the statute should require that each affected issuer install a fail-safe accounting control system at all costs. It appears that Congress was fully cognizant of the cost-effective considerations which confront companies as they consider the institution of accounting controls and of the subjective elements which may lead reasonable individuals to arrive at different conclusions. Congress has demanded only that judgment be exercised in applying the standard of reasonableness. The size of the business, diversity of operations, degree of centralization of financial and operating management, amount of contact by top management with day-to-day operations, and numerous other circumstances are factors which management must consider in establishing and maintaining an internal accounting controls system. […] It is also true that the internal accounting controls provisions contemplate the financial principle of proportionality—what is material to a small company is not necessarily material to a large company."
In short, the above legal authority does not answer the reader's questions, but should provide some comfort to any compliance professional at an issuer based on the following salient points:
there is no legal requirement that an issuer have an "effective" compliance program or that internal controls provide "absolute assurances";
rather internal controls should provide "reasonable assurances" that certain objectives are being met and a cost / benefit analysis is relevant to this standard;
good faith is a relevant standard for issuer's with minority owned subsidiaries;
In addition to the above legal authority, there are also non-legal sources of authority relevant to the internal controls provisions.
In 1981, the SEC issued additional formal guidance concerning the accounting provisions in the form of a speech by the SEC Chairman that was thereafter adopted by the SEC as a formal statement of policy. (See SEC Release No. 17500 (Jan. 29, 1981). In pertinent part, the SEC stated:
"The Act does not mandate any particular kind of internal controls system. The test is whether a system, taken as a whole, reasonably meets the statute's specified objectives. 'Reasonableness,' a familiar legal concept, depends on an evaluation of all the facts and circumstances."
"Private sector decisions implementing these statutory objectives are business decisions. And, reasonable business decisions should be afforded deference. This means that the issuer need not always select the best or the most effective control measure. However, the one selected must be reasonable under all the circumstances."
"The accounting provisions principal objective is to reaching knowing or reckless conduct."
"Depending on the circumstances, intentional circumventions of a company's system of records and of accounting controls by a low-level employee would not always be considered violations of the Act by the issuer. No system of adequate records and controls – no matter how effectively devised or conscientiously applied – could be expected to prevent all mistaken and improper transactions and disposition of assets. Given human nature, regardless of the adequacy of the system, a bookkeeper may still erroneously post entries, an overzealous agent may make unauthorized payments, or an unscrupulous employee may falsify records for his own purposes. The Act recognizes each of these limitations. Neither its text and legislative history nor its purposes suggest that occasional, inadvertent errors were the kind of problem that Congress sought to remedy in passing the Act. No rational federal interest in punishing insignificant mistakes has been articulated. And, the Act's accounting provisions do not require a company or its senior officials to be the guarantors of all conduct of company employees."
In concluding this portion of the speech, the Chairman stated:
"The test of a company's internal control system is not whether occasional failings can occur. Those will happen in the most ideally managed company. But, an adequate system of internal controls means that, when such breaches do arise, they will be isolated rather than systemic, and they will be subject to a reasonable likelihood of being uncovered in a timely manner and then remedied promptly. Barring, of course, the participation or complicity of senior company officials in the deed, when discovery and correction expeditiously follow, no failing in the company's internal accounting system would have existed. To the contrary, routine discovery and correction would evidence its effectiveness."
The highlighted language is perhaps most relevant to the reader's question, but do the current FCPA enforcement agencies act consistent with this prior guidance?
As to the SEC's enforcement policy, the Chairman concluded his remarks:
"The genius – and challenge – of [the accounting provisions] , it should be remembered, is their reliance on private sector decisionmaking – rather than specific federal edicts – to address an area of public concern. The Act's eventual success or failure will, therefore, depend primarily upon business's response. The Commission's obligation, in turn, is to provide a regulatory environment in which the private sector can address these issues meaningfully and creatively. In this regard, we must encourage public companies to develop innovative records and control systems, to modify and improve them as circumstances change, and to correct recordkeeping errors when they occur without a chilling fear of penalty or inference that a violation of the Act is involved."
In 2012, the DOJ and SEC jointly issued FCPA Guidance setting forth its "FCPA enforcement approach and priorities" and a specific chapter concerned the accounting provisions. Like previous enforcement agency guidance, the FCPA Guidance cited legislative history or the FCPA itself for the following statements:
"The term 'reasonable detail' is defined in the statute as the level of detail that would 'satisfy prudent officials in the conduct of their own affairs.' Thus, as Congress noted when it adopted this definition, 'the concept of reasonableness of necessity contemplates the weighing of a number of relevant factors, including the costs of compliance.'"
"Like the 'reasonable detail' requirement in the books and records provision, the Act defines 'reasonable assurances' as 'such level of detail and degree of assurance as would satisfy prudent officials in the conduct of their own affairs.'"
"The Act does not specify a particular set of controls that companies are required to implement. Rather, the internal controls provision gives companies the flexibility to develop and maintain a system of controls that is appropriate to their particular needs and circumstances."
"Companies may not be able to exercise the same level of control over a minority-owned subsidiary or affiliate as they do over a majority or wholly owned entity. Therefore, if a parent company owns 50% or less of a subsidiary or affiliate, the parent is only required to use good faith efforts to cause the minority-owned subsidiary or affiliate to devise and maintain a system of internal accounting controls consistent with the issuer's own obligations under the FCPA. In evaluating an issuer's good faith efforts, all the circumstances—including 'the relative degree of the issuer's ownership of the domestic or foreign firm and the laws and practices governing the business operations of the country in which such firm is located'—are taken into account."
Consistent with the legal authority discussed earlier in this post, the above enforcement agency guidance should provide some comfort to any compliance professional at an issuer based on the following salient points:
an issuer need not always select the best or the most effective control measure, but the one selected must be reasonable under all the circumstances;
"no system of adequate records and controls – no matter how effectively devised or conscientiously applied – could be expected to prevent all mistaken and improper transactions and disposition of assets";
"Barring […] the participation or complicity of senior company officials in the deed, when discovery and correction expeditiously follow, no failing in the company's internal accounting system would have existed. To the contrary, routine discovery and correction would evidence its effectiveness."
Even though "effectiveness" is not a standard set forth in the law, the FCPA Guidance does contain an entire section titled "Hallmarks of Effective Compliance Programs" which begins as follows.
"Individual companies may have different compliance needs depending on their size and the particular risks associated with their businesses, among other factors. When it comes to compliance, there is no one-size-fits-all program. Thus, [the hallmarks are] meant to provide insight into the aspects of compliance programs that DOJ and SEC assess, recognizing that companies may consider a variety of factors when making their own determination of what is appropriate for their specific business needs. Indeed, small- and medium-size enterprises likely will have different compliance programs from large multi-national corporations, a fact DOJ and SEC take into account when evaluating companies' compliance programs. Compliance programs that employ a "check-the-box" approach may be inefficient and, more importantly, ineffective. Because each compliance program should be tailored to an organization's specific needs, risks, and challenges, the information provided below should not be considered a substitute for a company's own assessment of the corporate compliance program most appropriate for that particular business organization. In the end, if designed carefully, implemented earnestly, and enforced fairly, a company's compliance program—no matter how large or small the organization—will allow the company generally to prevent violations, detect those that do occur, and remediate them promptly and appropriately."
The FCPA Guidance then lists several hallmarks that readers can review for themselves.
Of course none of these "hallmarks" of effective compliance programs are legal standards. The legal standards for the internal controls provisions were set forth above. Sure, we can call the hallmarks "best practices," but not acting consistent with a "best practice" is not necessary a legal violation. (See here for the prior post).
In 2017 the above "hallmarks of effective compliance programs" were basically just converted from the narrative form in the FCPA Guidance into a question format in the DOJ's "Evaluation of Corporate Compliance Programs." (See here for a prior post as well). The non-binding policy document is general in nature and not FCPA specific and begins as follows:
"[T]he Fraud Section does not use any rigid formula to assess the effectiveness of corporate compliance programs. There are, however, common questions that we may ask in making an individualized determination. This document provides some important topics and sample questions that the Fraud Section has frequently found relevant in evaluating a corporate compliance program. The topics and questions below form neither a checklist nor a formula. In any particular case, the topics and questions set forth below may not all be relevant, and others may be more salient given the particular facts at issue."
The DOJ's Evaluation of Corporate Compliance Programs asks a lot of questions but fails to provide answers, including as to the reader's question.
Among the questions asked relevant to the reader's question are the following:
"How has the company assessed whether these policies and procedures have been effectively implemented?
How has the company measured the effectiveness of the training?
Confidential Reporting and Investigation
Effectiveness of the Reporting Mechanism – How has the company collected, analyzed, and used information from its reporting mechanisms? How has the company assessed the seriousness of the allegations it received? Has the compliance function had full access to reporting and investigative information."
As you can see, the word "effective" is used several times in questions, but no answers are provided.
Relevant to the reader's question, it should also be noted that the government clearly recognizes that "no compliance program can ever prevent all criminal activity by a corporation's employees." (See DOJ Principles of Federal Prosecution of Business Organizations, 9-28.800, Corporate Compliance Programs).
In addition, high-ranking DOJ officials have recognized that "there will always be employees who decide to take matters into their own hands – they are a fact of life," and that "even the best compliance program may not stop fraud or corruption from occurring." (See Press Release, U.S. Dep't of Justice (Jan. 26, 2011); See Press Release, U.S. Dep't of Justice (May 26, 2010).
Indeed, the former Assistant Chief of the DOJ's FCPA Unit candidly stated "most government attorneys realize that a company can take every reasonable step to prevent wrongdoing but ultimately is powerless if somebody really wants to break the law." (See The Metropolitan Corporate Counsel, "Former Chief Of DOJ Fraud Unit Discusses Healthcare And FCPA Enforcement" (Sept. 29, 2012).
Yet when such real conduct fitting these precise scenarios occurs, the enforcement agencies still bring an FCPA enforcement action against the company.
For instance,in the Schering-Plough enforcement action the SEC charged the company with violating the accounting provisions based on payments made to a bona fide Polish charitable foundation because the founder and president of the foundation was also associated with a government health fund that, among other things, provided monies for the purchase of pharmaceutical products. The action was based on the conduct of one individual (a unit manager at a branch office of a foreign subsidiary) and the SEC acknowledged in the enforcement action:
The individual structured his conduct to evade certain internal controls and otherwise provided false information on documents submitted to the company's finance department;
the donations were made to a bona fide charitable organization;
the aggregate donation amount (approximately $76,000) was not material (during the relevant time period Schering-Plough's net income was over $2 billion per year).
the donations were recorded as "donations" on the company's books and records.
Even though the SEC further acknowledged that "the payments to the Foundation were made without the knowledge or approval of any Schering-Plough employee in the U.S." the SEC nevertheless charged the company with accounting violations because the donations were "to induce the purchase of Schering-Plough's pharmaceutical products" and "none of the payments to charity [were] accurately reflected in Schering-Plough's books and records" and its "system of internal accounting controls [were] inadequate to prevent or detect the improper payments."
The SEC found that Hewlett-Packard ("HP") (see here for a prior post), a technology company with over 300,000 employees worldwide, violated the accounting provisions based on the following summary allegation:
"HP Co.'s indirect, wholly-owned subsidiaries in Russia, Mexico and Poland, by and through their employees, agents and intermediaries, made unlawful payments to various foreign government officials to obtain business. These payments were also falsely recorded in the subsidiaries' books and records and, ultimately, in HP Co.'s books and records."
As to the company's internal controls, the SEC's found:
"HP failed to devise and maintain an adequate system of internal accounting controls sufficient to provide reasonable assurance that: (1) access to assets was permitted only in accordance with management's authorization; (2) transactions were recorded as necessary to maintain accountability for assets; and (3) transactions were executed in accordance with management's authorization."
In announcing the enforcement action, the SEC stated:
"Hewlett-Packard lacked the internal controls to stop a pattern of illegal payments to win business in Mexico and Eastern Europe. The company's books and records reflected the payments as legitimate commissions and expenses. Companies have a fundamental obligation to ensure that their internal controls are both reasonably designed and appropriately implemented across their entire business operations, and they should take a hard look at the agents conducting business on their behalf."
Yet elsewhere in the resolution documents of the $108 million parallel DOJ and SEC enforcement action, the government acknowledged the following about HP's internal control environment at the time of the alleged improper conduct:
HP had existing FCPA and related policies and procedures in place and all relevant employees received training on the policies;
HP had existing policies and procedures in place related to commission payments to channel partners, due diligence of channel partners, and other tracking policies regarding channel partners;
HP had an existing approval process in place that applied to all service-related projects valued at greater than $500,000 anywhere in the world and as part of that process HP managers questioned relevant subsidiary employees at questionable information; and
HP had an existing SOX certification and sub-certification process in place as relevant to the referenced subsidiaries.
It would seem quite clear that the government would have found violations of the internal controls provisions if:
HP did not have FCPA policies relevant to all employees;
HP did not have policies relevant to third party commission payments and due diligence of third parties; or
HP did not have an approval process or SOX certification and sub-certification process.
However, according to even the government, HP did these things and yet the government still found HP to be in violation of the accounting provisions because, in the words of the government, a "small fraction" of employees at certain foreign subsidiaries engaged in covert means to willfully circumvent HP's internal controls. Among the covert means used by this "small fraction" of employees was communicating through anonymous e-mail accounts and prepaid mobile telephones and a subsidiary employee and alleged foreign official driving around in vehicles in "remote locations" and typing "messages in a text file, passing the computer between themselves." According to the government, "communications were made in this fashion to avoid possible audio recording of the discussions by hidden devices, and to circumvent HP's internal controls." The HP enforcement action thus seems to represent a "damned if you, damned if you don't" theory of enforcement and would seemingly result in every issuer violating internal controls provisions when a "small fraction" of employees take drastic measures to willfully circumvent existing internal controls.
A final enforcement action, and recognize there are many more that could also be highlighted," concerns Nu Skin Enterprises (a small Utah-based company involved in the manufacturing and marketing of cosmetic and nutritional products primarily through direct selling, or multi-level marketing, channels). The SEC specifically noted the following regarding Nu Skin's internal controls at the time of the alleged improper conduct involving a charitable donation made "to obtain the influence of a high-ranking Chinese Communist party official to impact an on-going provincial agency investigation."
Nu Skin identified the FCPA risks inherent in the charitable donation and advised its Chinese subsidiary to consult with outside U.S. legal counsel based in China to ensure that the donation complied with the FCPA; and
Nu Skin's outside counsel made recommendations to the Chinese subsidiary, but employees at the subsidiary acted contrary to counsel's recommendations and otherwise failed to disclose certain relevant information to the company.
Once again, it would seem quite clear that the government would have found violations of the internal controls provisions if Nu Skin did not pro-actively identify the FCPA risks inherent in a charitable donation and did not advise its Chinese subsidiary to consult with U.S. legal counsel in China concerning the donation. However, Nu Skin did these things and yet the SEC still found in the approximate $765,000 enforcement action that:
"Nu Skin violated the books and records provisions because: "in its wholly-owned subsidiary's expenditure authorization form, the purpose of the payment to the charity was inaccurately and/or unfairly described as a donation rather than an improper payment to obtain the Party Official's influence"
"Nu Skin violated the internal controls provisions because: it "did not ensure that adequate due diligence was conducted by Nu Skin China with respect to charitable donations to identify links to government or political party officials and to prevent payments intended to improperly influence such persons in violation of the company's anticorruption policy and the FCPA."
The Nu Skin enforcement action also seems to represent a "damned if you, damned if you don't" theory of enforcement and would seemingly result in every issuer being in violation of the internal controls provisions when its instructs a foreign subsidiary to consult legal counsel regarding a specific issue, but the foreign subsidiary acts contrary to legal counsel's recommendations and otherwise fails to disclose certain relevant information to the parent company.
Returning to the reader's question, what is the answer?
My best answer is that compliance professionals need to gain comfort with uncertainly and recognize that there are few concrete answers to many compliance issues and also recognize that there may be tension between actual legal authority (and even enforcement agency guidance) and actual FCPA enforcement actions.
It's a heck of a place to leave a compliance professional, but it is my best answer to the reader's question.
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Foreign Subsidiaries Of French Pharma Company Sanofi Allegedly Bribe Kazakh And Middle Eastern "Foreign Officials" – Uncle Sam Collects $25.2 Million
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I Wish You a Merry Quilt-A-Long | Sparkle On!
The I Wish You a Merry Quilt-a-Long mystery QAL 2017 has ended.
Please visit and join a community of quilters at Partners in Design's Facebook group page. Here you will find out about current and/or upcoming QALs from Partners in Design.
Next Mystery QAL to be announced in 2019!


A committed Edmonton Oilers watcher?
Here it is mid-July, a shot sun-drenched day out on the West Coast, and I'm sitting on my deck by the ocean…writing a hockey column.
Instead of committed, maybe I should be just be committed?
But this isn't all that unusual for me, actually. I well remember as a kid waiting for the summer edition of The Hockey News to arrive at the Leavins house. Every member of the family would fight for their time with it. The summer edition was unique in that it summed up everything from the Stanley Cup Final to the Draft and off-season transactions. Long, long before Twitter this is how most of us got caught up on the summer's happenings with our favorite teams.
And so, for other Edmonton Oilers watchers who may also be on a deck somewhere during these precious summer days, here is a quick catch-up on what's transpired with the club over the past 7 days.
9. The Edmonton Corn Maze just West of the city features an Edmonton Oilers logo this year. As a youngster my son used to love winding his way through those paths. I hope the upcoming Oilers season is easier to navigate than this thing.
8. Brenden Ullrich announced this week that he was leaving the on-air side of radio to enter Sales. Brenden had grown into an exciting young hockey broadcaster alongside Bob Stauffer on Oilers Now. Many like me will miss him.
7. Fore! The photo flashed across my Instagram account on Saturday afternoon that Connor McDavid had apparently fired a Hole-in-One while golfing with his brother Cam. Cam carded a 5 on the same hole. What can't this kid do?
6. Peter Pocklington has a new business venture: A Cannabis company. The man who sold Wayne Gretzky is now managing Magic Dragon Realty, LLC. It's an indoor cannabis hydroponics operation near Palm Spring. From Peter Puck to Peter Puff.
5. Josh Currie has signed a 2-year contract with the Edmonton Oilers. Currie led the Bakersfield Condors in scoring last year (68-20-26-46). Unlikely to become an NHL player, Currie does however fit the bill as a skill veteran center that can play along other Oilers prospects in The Bake this winter.
4. The P.K. My Cult of Hockey colleague David Staples wrote an Oilers piece this week questioning why Connor McDavid should be part of the penalty kill. The link to that story is below. My take: If you had the best player in the game on your team, would you park him on the bench for 2 minutes at a time? Especially in games with a lot of penalties. Most players will tell you flow is a big part of their games, and 2:00 on the pine really disturbs that.
3. Darnell Nurse (a qualified RFA) still has not signed what I expect to be a bridge deal with the club. Some folks have Tweeted me, asking why Nurse did not file for salary arbitration? That's because he is not eligible to do so, yet. I'm made to understand that the club has offered Nurse a deal that he has yet to accept. Meanwhile, Ryan Pulock has signed for $2M on Long Island, and Ryan Murray for $2.8m in Columbus. Those 2 contracts aren't helping Darnell's cause.
2. Even Bouchard inked his 3-year ELC this week, for a reported $925,000 which is the NHL maximum. The debate now is whether the big, offensively gifted right-shot D-man makes the big jump immediately? My take: If Bouchard legit makes the team in training camp, then yes. The kid has a late birthday, is physically mature, and posses elite-level offensive skills. If he earns it, he earns it. The "over-ripe" argument doesn't apply to a player who has already dominated on a sub-standard OHL team. And the AHL isn't an option for him.
1. Todd McLellan and his staff will sit down starting tomorrow in Kelowna, to begin earnest to map out the plan to coach the Edmonton Oilers in 2018-19. To me, the coaching staff was the most important transaction Peter Chiarelli made this off-season. These 4 men have been tasked with the job of getting (a lot) more out of their players this season. McLellan, Glen Gulutzan, Trent Yawney and Manny Viveiros have a big chore ahead of them. Todd is starting off with no special assignments to begin with. Instead, all 4 are being asked to contribute in each area. Maybe special assignments will develop by or during training camp. But until then, it sounds like a full assessment and brainstorming session are the first and primary orders of business.
There you are, then, all up to date.
Now, if you'll please excuse me, I have nothing very important to do.
STAPLES: Why does McDavid PK?


As this winter's deep freeze continues, the Coast Guard is cautioning mariners to be aware of ice formation on the upper Bay and its tributaries.
The Coast Guard Sector Maryland National-Capital Region Captain of the Port (COTP) has set seasonal ice condition two. That means "ice of noteworthy thickness and coverage has formed within the Chesapeake and Delaware Canal, the upper Potomac River, and on the Maryland eastern shore."
The Coast Guard is asking all boat owners and operators, masters, ship agents, marinas and marine facilities to report ice conditions they see to the Sector Maryland-NCR command center at 410-576-2693 or D05-SMB-SectorMD-NCR-SCC@uscg.mil.
There are currently steel hull restrictions in place for vessels using the C&D Canal. Boaters can contact the canal dispatcher on duty with questions about the requirements.


Mireya Reith, director of Arkansas United Community Coalition, is miles and worlds away from Two Rivers, Wis., where she was born 33 years ago.
Sr. Camille: Mireya, where did you spend your childhood?
I spent my early years between Manitowoc and Racine, Wis. When I was in junior high, my family moved to Fayetteville, Ark., which I have considered and continue to consider my hometown.
I grew up in a very loving home with my parents and younger sister. My mother is a first-generation immigrant from Mexico and my father is a native of Wisconsin. My parents met in Mexico City, where my mother worked for my father.
I attended a private Catholic school, Sacred Heart, from first through eighth grade, then did ninth grade and high school in the public school system here in Fayetteville.
I went on to pursue my bachelor's degrees in political science and Spanish at Williams College in Massachusetts. I also completed a master's degree in international affairs at Columbia University in New York, concentrating in political and economic development.
Where my family worked hard to ensure that my sister and I were safe, healthy and happy, my early years in life were very much influenced by my realities of growing up as a Mexican-American in communities that, at that time, did not honor diversity. Observing people's negative reactions to me and my family greatly influenced my personal and professional decisions later in life, forging a mission to demonstrate that diversity is positive and brings value to our society.
Did you have role models, heroes or heroines?
In those early years, a handful of my relatives in Mexico, specifically an aunt and my grandfather, served as my role models. Through their own involvement in politics back in Mexico, they helped me realize the potential good politics can have. They also helped open my eyes to not taking for granted our democracy and our vote. By helping me understand their own fight for a Mexico free of corruption, I was inspired to seek a career in democracy promotion and to help other nations with similar aspirations. Later in life, my activist hero has become Cesar Chavez for his work organizing immigrant workers. My political hero is President Barack Obama -- living proof of the value of diversity to America's political system. My Arkansas role model is Sen. Joyce Elliott, an African-American state senator who consistently puts her values above re-election and was the first political champion for immigrants in our state.
What is your favorite Scripture passage or Gospel story?
Mark 12:31: "The second is this, 'You shall love your neighbor as yourself.' There is no other commandment greater than these."
Has it influenced your life choices?
Both my family and my church have enabled me to see this as my personal and professional mantra. Inspired by the opportunities that the Catholic church gave me to serve my parish and community, I purposefully selected a career of service. Coupled with my passion for political development and diversity, I was able to carve out a professional niche where inclusion and service merged.
Both my parents came from a long line of Catholics. Growing up in this tradition, as I traveled around the country and the world, I'd always seek out the local Catholic parishes and instantly feel at home, regardless of my grasp of the language.
Please describe your current employment.
I'm the co-founder and executive director of Arkansas United Community Coalition, Arkansas' first immigrant advocacy nonprofit organization. AUCC has been working since 2010 to empower Arkansas immigrants and their communities through organizing, coalition building, leadership development and the promotion of civic engagement. We envision an Arkansas that achieves its full potential by all of Arkansas' people, native-born and immigrant, working together. I've been able to build on some previous campaigns to develop an Arkansas Latino youth civic association and direct Hispanic voter outreach during Arkansas' 2010 elections.
Mireya, your efforts to promote diversity have been recognized on several levels. You are the first Latina and youngest person ever appointed by the governor to the Arkansas State Board of Education. You served our country as a municipal development volunteer with the Peace Corps in El Salvador. Despite your youth, your passion for diversity inspired a 14-year career in the field of international political development, where you worked on five continents with American nonprofit organizations and the United Nations. Your goal was to engage marginalized communities in democratic processes.
In 2012, you were recognized as one of the 50 most influential people in Arkansas. In 2013, your efforts were rewarded with the White House's Cesar Chavez Champions of Change Award.
Please say something about your experience in the Peace Corps.
After college, I was eager to put into practice my education and learning with communities abroad. In the Peace Corps, I was assigned as a municipal development volunteer to a small village of Joateca, home to about 800 people. This community had endured the horrors of El Salvador's civil war and was seeking both peace and development. I couldn't have asked for a more welcoming community. The people responded with open arms and with a profound thirst for growing their own leadership and empowering community committees to seek positive change. I had seen poverty before, but I had never lived in it myself. It was this experience that opened my eyes to what it would take to help change the circumstances of people for whom this is a reality. I was humbled by the experience in that I came to fully appreciate that wisdom and knowledge don't come from education alone and that a person's socioeconomic circumstances don't define one's skills and talents. All people, regardless of background, have something to contribute.
What drew you to invest so much of your time and talent in these causes?
I returned to Arkansas in 2010 because of the sudden death of my father from cancer. My family had given me strength to pursue my career and life outside of Arkansas, and I knew I needed to return so we could grieve together. In those early months back, I started volunteering in the community and supporting some political campaigns with the hope of doing something positive during that difficult period. As a Mexican-American, I was drawn to the newly emerged immigrant population in Arkansas. At the end of that year, I was asked by community leaders to take on a more direct leadership role and start this nonprofit, Arkansas United Community Coalition. Throughout my career, I'd always envisioned myself helping others in achieving their leadership potential. And for the first time, I was now being asked to apply my skills and learning to the need of my own state. I was humbled by their request, accepted it, and now find myself on the most fulfilling career move of my life.
Whom do you count among your supporters?
My family, members of our immigrant community, nonimmigrants who care about inclusion and social justice, the faith community that believes in Gospel without borders, the business community that believes in a diverse workforce, political leaders who value their diverse electorate.
Where has your work brought you?
My work has brought me to five continents and, more importantly, to work with all types of social justice advocates and some of the most impoverished in the world. It's also led me to work with our political and economic elite who use their decision-making powers to improve the circumstances of this world. At times, I find myself practicing my faith more actively in the community than in the church, but the church remains the foundation in all I do.
Professionally, I hope to empower more immigrant leaders in my state at all levels of society and to achieve a more just system through policies that emphasize inclusion and integration.
Can you share some experience that sustains your interest in justice for immigrants?
My work is more than a job; it's a mission. And the people with whom I work are not just colleagues, but friends and family. Real lives are at stake, and my sincere hope is to see each one of those lives achieve their potential.
I can say that with age and experience, I have learned that there is bad and evil in this world, as there is good and love. God's existence and love for us will not always shield us from the bad. But God's loyalty, faith and love can continue to give us strength and guidance, if we let him.
It is a faith I share with my family.
Yes. My work gives me the privilege of observing, and many times encouraging, selfless acts.
Your devotion to others and your deep faith make me wonder if you ever considered joining a religious community.
Yes, when I was attending Catholic school in Wisconsin. Some of my teachers asked me to consider joining them. I have a deep admiration for sisters but feel my calling is elsewhere.
Having a family and continuing my service, whether locally or abroad. I want to continue making a difference in the lives of others.
How do you bring your faith to the workplace?
I encourage service and selflessness, and that is prevalent in all aspects of our work.
What does Christianity expect of you?
To live a life of service to one another and to God.
At Mass and during quiet moments, such as in the car. I have conversations with God and ask him questions.
I am encouraged by our new pope and his service to the poor; however, I concerned about polemic debate around the work of nuns, who are invaluable to the social justice community in this country, as well as prospects of recruiting ordained persons in the future.
Spending several years in Latin America, I became familiar with liberation theology. It is my hope that social justice may continue to be a guiding light for the Catholic church, as we observed so directly through that movement.
Our youth and seeing so many youth leaders step up at a young age to receive the torch for social justice.
What do you want from our faith for the world's children?
That they know that they are loved and that the church can be a home for them the way it has been for me, despite all other changes and experiences they will likely have in their lifetime.


"The resistance to E.coli, for instance, is booming. Resistance all over Europe is increasing and the only way to stop this is to follow the Guidelines and decrease antibiotic consumption," said F. Bruyere (FR) who gave an update on EAU Guidelines, particularly on urinary tract infections.
T. E. Bjerklund Johansen (NO), meanwhile, gave a comprehensive overview on the management of complications after prostate biopsies. "A 30-daymortality rate of 0.1% to 0.2% has been reported after prostate biopsies. A rate of 0.2% translates to 4,000 men dying from prostate biopsies in the US and Europe every year," Johansen said.
Regarding the issue of reducing the contamination status of a patient, Johansen said that transperineal biopsies have the lowest contamination category. He also recommended prophylaxis routines such as rectal cleansing, with one study noting the benefit of using bisacodyl. Hygienic measures also included needle use, disinfection of the biopsy channel and proper training for the urologist and assistants.
Future research should be directed at reduAccording to Johansen, future research should be directed at reducing the need for prostate biopsies and the contamination status of the biopsy procedure.cing the need for prostate biopsies and the contamination status of the biopsy procedure.


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Nepal Energy Forum An independent forum and an on-line channel for the Nepal energy markets(Hydropower, Wind, Biomass, Solar, Petroleum).
Daily power cuts may exceed
KATHMANDU, FEB 24 –
Consumers are likely to witness an increase in load shedding hours in the days to come as two major hydropower projects are suffering from mechanical problems, affecting the total power generation in the country. However, officials at the Nepal Electricity Authority (NEA), the country's sole power utility, have not commented on the upcoming power outage schedule.
The Kaligandaki 'A' Hydro Electricity Project, the country's largest hydropower project with an installed capacity of 144 megawatt, has been suffering from technical problems in the turbine, including the leakage of water from pipes joining the water flow from the tunnel to the turbine for more than five years. It is now ready to undergo repair work later this week. According to Abadesh Kumar Jha, Kaligandaki project chief, the powerhouse, which is now generating only around 60MW, will completely halt power generation from next week onwards for at least 10 days owing to repair work. There are three Francis turbines installed in the powerhouse with each carrying capacity of 48MW.
"To conduct a turbine overhaul, we need to de-water them so power generation will be stopped," said Jha. He further said that technical problems had been continuing for a long time and repair works is being carried out to avoid a bigger disaster in the future. The powerhouse has already obtained the equipment required for maintenance from Japan, according to officials.
Similarly, one of the two units at Kulekhani I with an installed capacity of 60MW, the only reservoir-type hydroelectric power station in the country, has been malfunctioning since Monday following a short-circuit of a cable. According to authorities, the hydropower project is only generating half its capacity and will be undergoing repair work for a week, affecting the overall power generation of the country. This is the second time in the last four months that power generation has been halved due to similar problems.
When contacted, Bhuwan Chhetri, chief of the Load Dispatch department at NEA , said that he had no information on the mechanical and technical problems associated with both the Kaligandaki and Kulekhani projects and hence, was unable to comment on the prospect of an increase in load shedding hours, which currently stands at 12 hours, in the coming days.
According to NEA statistics, the current peak power demand is over 1,000 MW while supply stands at around 700 MW. Both the Kaligandaki and Kulekhani projects were constructed with the loan aid of the Asian Development Bank and the Japan International Cooperation Agency.
Source : The Kathmandu Post
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PK Education are seeking an inspiring and dedicated teacher of Modern Foreign Languages to join a secondary school in Sheffield on a part time basis.
You MUST be able to teach French, Spanish and German to KS3 students. You will have the passion and expertise necessary to inspire students and a commitment to raising the attainment of all students of all abilities across the age range.
The school aspire to achieve individual and collective excellence in all that they do through nurturing every student's unique potential, expanding their horizons and promoting their understanding of the invaluable contributions they can make as citizens in a global society.
If you would like to be considered for this role and make a full contribution to the life of the school, please apply now!


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EagleRockSchool.org
We're Seeking a Director of Curriculum to Start in January 2020
Here at Eagle Rock, we're kicking off a national search for an experienced academic leader to serve as our next director of curriculum.
This is an exciting position for someone with a proven track record in the classroom, experience coaching and developing teachers, and a passion for working in a small, non-traditional, creative, diverse, learner-centered environment.
Requirements for the position include seven-plus years of teaching experience; a master's degree in education, school leadership; experience as an instructional coach; and experience in progressive educational models, as well as experience with curricular models that value academic and personal growth. Additionally, residential school experience is highly desirable.
Among the tasks our new director will be focused on are the development and oversight of our academic, learner-centered curriculum, which is closely aligned with Eagle Rock's Continue reading…
Meet the Team: Athletics Coordinator Jocelyn Rodriguez
This trimester marks the beginning of Jocelyn Rodriguez' second year at Eagle Rock, where she formerly served as our Public Allies Fellow in Human Performance. Recently, she was asked to return as a full-time staff member, working in the new adjunct position of Eagle Rock athletic coordinator.
In her now role, Jocelyn is teaching several classes, including Changing the Game, a class that focuses on what it means to be a coach in professional sports. In addition, she is the new house parent for Spruce House.
As the athletics coordinator, Jocelyn continues to sustain our basketball program while also coordinating athletic events for the Eagle Rock community. Earlier this year, we highlighted Jocelyn's work in this area in a post title 'MoreThan a Game' Shines a Light on More Than Basketball.
Jocelyn also now manages Eagle Rock's Sports Challenge partnership with Strive at Haverford College, and will be attending Sports Challenge next year — a two-week program — with two members of the basketball team at Eagle Rock.
We recently caught up with Jocelyn between Eagle Rock tasks and asked her to fill us in a bit on her work experience, personal life, and some of her favorite things. Here's what she had to say: Continue reading…
New House Parents Settling in at Ponderosa House and Spruce House
We're not sure if it's the result of good luck, or skill, or just longtime experience, but it seems every time we have the need for a new house parent for one of our six student housing complexes here at Eagle Rock School, we always end up with staff members who are perfectly suited for the role.
Each of the six houses within our on-campus Living Village accommodates up to a dozen co-eds in two separate sleeping wings, with common areas and shared community values being the focus in between. And our house parents are there to support the community, act as a sounding board, make sure the house chores are done, and so, so, so much more.
That being said, we are proud to introduce new house parents taking over this trimester at Ponderosa and Spruce.
Elizabeth Rivera and Carlos Perez are new house parents at Ponderosa House but not new to Eagle Rock. This married couple arrived in Estes Park in the fall of 2017 from Miami, where Elizabeth worked in the hotel and hospitality industry for more than two decades, and Carlos served as a cook at a variety of Italian, American, and Latin restaurants for more than 15 years.
Elizabeth is originally from Lima, Peru, and Carlos hails from Maracay, Venezuela. At Eagle Rock, Elizabeth is a business office administrative assistant, assisting parents and students with Continue reading…
Meet the Team: Cedric Josey, Culture & Societies Instructional Specialist
Here at Eagle Rock, Societies and Cultures is our equivalent of Social Studies, and Cedric Josey, who has taught in middle schools and high schools in Massachusetts, is our new culture & societies instructional specialist.
While his new position makes Cedric the person on our campus primarily responsible for curriculum objectives related to world and U.S. history, physical and cultural geography, U.S. government, and civics, it's his love and pursuit of original works of music that we'd like to highlight in introducing him to the Eagle Rock Community.
(Image courtesy of NewBedfordGuide.com)
Cedric's love of music began while singing in a church choir as a child, and he later remembers driving his neighbors a bit crazy while learning to play the saxophone. So, years later, when he found himself living alone in a New Bedford, Mass., apartment, he picked up a guitar and quietly learned to play and write music in order to avoid disturbing those around him.
Most impressive, while working with Destination New Bedford — an effort of the City of New Bedford's Office of Tourism and Marketing to highlight that seaside town's unique attributes — Cedric wrote and produced a song called "Being in New Bedford," that was used extensively in the city's promotion efforts. (Scroll to the end of today's post for a video featuring Cedric performing this song himself).
Beyond his love for music, and in addition to teaching in public middle and high schools, Cedric has worked with the Youth Corps within the State of Massachusetts' Trustees of Reservations, which owns and cares for more than 25,000 acres across the Bay State. There, he provided youth in his community with an opportunity to learn in-depth leadership skills in an outdoor environment during the summer months. Ask him about it and Cedric will tell you it was an opportunity for him, as an African American male, to mentor youth in a way that highlighted an alternative path to success — outside of what society or peers might suggest.
For today's post, we asked Cedric to fill us in on some additional details of his life and career to date, and here's what he had to say: Continue reading…
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Eagle Rock – a non-profit initiative of the American Honda Motor Company – is both a school for high school age students and a professional development center for educators. The school is a year-round, residential, and full-scholarship school that enrolls young people ages 15-17 from around the United States in an innovative learning program with national recognition. The Professional Development Center works with educators from around the country who wish to study how to re-engage, retain and graduate students. The center provides consulting services at school sites and host educators who study and learn from Eagle Rock practices. For more information please visit www.eaglerockschool.org and check us out on Twitter @eaglerockschool and on Facebook at facebook.com/EagleRockSchool.


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Colombia Revealed
90 min • Nature & Environment, History • 2016 • M
Filmed by a team of 87, covering over 85 locations with 150 hours of footage, this ambitious natural history feature documentary showcases 38 different species filmed in 20 documented ecosystems including the jaguar hunting its prey, the silver Arowana fish mouth-brooding its young, the mating rituals of the Orinoco crocodiles, the blue Morpho butterfly emerging from its chrysalis, the hammerhead and their young's migration, the Nazca boobies raising its chicks, and the bright golden dart frog feeding on ants. The film reveals the first ever footage of pictographs thought to be 20,000 years old, sighted between Guaviare and Caquetá, in the Guiana Shield, and was the first time the world's rarest monkey- the Caqueta titi - has been filmed. Directed by Mike Slee (Bugs 3D / The flight of the Butterflies), and with a soundtrack by David Cambell (Spiderman 2 / World war Z), this film was premiered in movie theatres by Colombian President Juan Manuel Santos and quickly became the most successful Colombian release of all time.
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So I debated back and forth about whether or not I should label myself a heathen for downloading and playing Dungeon Keeper on my Droid, and ultimately decided F' it, gonna do it anyway.
It's not Dungeon Keeper in the traditional sense, for those not in the know. It contains some element of the title, but has been transformed into what most games on the portable/web platform are: Tap & Wait, unless helped by a social circle or paying money for speed up tokens.
This one isn't as bad as others, but it will definitely not have any of the replay value the original games had. At best you can go around wasting other Keepers who don't design their setup properly, but fortunately there is not really a need to spend real money to play.
It's good as a time filler during bathroom breaks, and killing 5 - 10 minute time lulls.
Well as the beginner play goes quite entertaining me as the further game when you need stronger creatures or bigger Dungeon is more and more hard to play for free, your development is slowed down, your actions takes hours. Of course you don't need to pay, but then wait couple of hours or days to be able to do something and to get free green diamonds is much longer way than at the beginning of your play.
Sometimes people want to play Tap & Wait games, but every actions like in DK for mobiles or Megapolis game after 2 days of playing these games takes hundred hours to be done. Ogame for example is T&W game, but you can shorten your awaiting time for anything and it can be done with your resources not payed options.
This game use Dungeon Keeper franchise, name to attract more customers, but this nothing more like money sucker - null lore, null creatures behaviours only stats what is against something better, what's not. Rooms cannot be built bigger, you don't have any influence on their shape. Spells cost mana that regenerates very slowly, but quite powerful. Traps are great, but some really cost very much as their upgrades, which if enemies has tougher units are useless - unless you gather enough resources which takes some time, especially that in this game you have infinite mines like in Ogame, that you can upgrade, but to reach desired amount of resources you need to upgrade them and storage room that could handle this amount of resources, but if could resources comes very slowly to you - and don't forget you can have limited amount of traps and pull up this limit if you upgrade mines, some of them the are in map corners need some more time to be occupied - but remember as more mines you have as more portals you have to your Dungeon, so there are more ways to get to you.
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