Implied Term of Trust and Confidence: the Change in Approach of the Court of Appeal to the Requirement to Pay Redundancy Compensation

This article examines the changing views of the Court of Appeal to payment of redundancy compensation where a contract of employment is silent. The author contrasts the leading cases, particularly Brighouse and Aoraki, and examines their differing approaches to issues such as the intention and interpretation of the Employment Contracts Act 1991, the extent of the implied term of mutual trust and confidence, and the perceived need for certainty in the law. The article concludes that the outcome is at least partly a result of changing judicial politics, and that perceptions of the correctness or otherwise of the current law will largely depend on readers views of ideology and politics

The Impact of Westernization on Tongan Cultural Values Related to Business

This study examined the impact of Westernization on Tongan cultural values (Collectivism I, Collectivism II, Power Distance, Future Orientation, and Uncertainty Avoidance) related to business. A Tongan version of the Project GLOBE Beta Questionnaire measuring cultural dimensions at the societal level was completed by 222 Tongans from the island groups of Vava’u, Ha’apai, and Niuatoputapu. One-way ANOVA and planned comparison results indicated significant differences for Collectivism II and Uncertainty Avoidance. Scores from Vava’u showed significantly less Collectivism II than Ha’apai, but not Niuatoputapu. Furthermore, scores from Vava’u showed significantly less Uncertainty Avoidance than Ha’apai and Niuatoputapu. No significant differences were found between Ha’apai and Niuatoputapu on any of the cultural dimensions in this study. The results of this study indicate the cultural dimension scores in one of Tonga’s more populated and technologically advanced island groups are beginning to reflect the values of Western culture. Implications for organizations planning to conduct business in Tonga are discussed

Portable Airborne Laser System Measures Forest-Canopy Height

(PALS) is a combination of laser ranging, video imaging, positioning, and data-processing subsystems designed for measuring the heights of forest canopies along linear transects from tens to thousands of kilometers long. Unlike prior laser ranging systems designed to serve the same purpose, the PALS is not restricted to use aboard a single aircraft of a specific type: the PALS fits into two large suitcases that can be carried to any convenient location, and the PALS can be installed in almost any local aircraft for hire, thereby making it possible to sample remote forests at relatively low cost. The initial cost and the cost of repairing the PALS are also lower because the PALS hardware consists mostly of commercial off-the-shelf (COTS) units that can easily be replaced in the field. The COTS units include a laser ranging transceiver, a charge-coupled-device camera that images the laser-illuminated targets, a differential Global Positioning System (dGPS) receiver capable of operation within the Wide Area Augmentation System, a video titler, a video cassette recorder (VCR), and a laptop computer equipped with two serial ports. The VCR and computer are powered by batteries; the other units are powered at 12 VDC from the 28-VDC aircraft power system via a low-pass filter and a voltage converter. The dGPS receiver feeds location and time data, at an update rate of 0.5 Hz, to the video titler and the computer. The laser ranging transceiver, operating at a sampling rate of 2 kHz, feeds its serial range and amplitude data stream to the computer. The analog video signal from the CCD camera is fed into the video titler wherein the signal is annotated with position and time information. The titler then forwards the annotated signal to the VCR for recording on 8-mm tapes. The dGPS and laser range and amplitude serial data streams are processed by software that displays the laser trace and the dGPS information as they are fed into the computer, subsamples the laser range and amplitude data, interleaves the subsampled data with the dGPS information, and records the resulting interleaved data stream