Directors Duties under the Companies Act 2006

Directors Duties under the Companies Act 2006 Executive Summary This paper explains about the directors’ duties that is implemented in the Companies Act 2006. It is significant that every director have to act within the legal principles in order to prevent any dispute from company’s interest with their personal interest. In the Companies Act 2006, there are several duties that every director has to act with the duties that are provided in Section 171 to Section 177. However, the directors did not put the duties into practice when carrying their responsibility as a director in a company. As a result, it has caused a great impact to many aspects such as employment rate, economy and others. Question 1 Introduction: Directors’ Duties in Companies Act 2006 In this modern globalization, every company must have at least one director for non-public listed company and at least two directors for public listed company as it had mentioned under the Companies Act 2006 in Section 154 (Davies, 2007). The reason of having a director in each company is to represent the company to act due to the ‘artificial’ legal entities of the company. In a company, the directors are the persons who represents its owners to manage and solve the problems of a company. According to the Cornell University Law School (2015), the directors of a company are called as fiduciaries because they are owing the fiduciary duties of the company while the people who owes the fiduciary duties is called as principal. Fiduciary duty is a legitimate obligation where it act exclusively in another party’s interest, which is the company where the fiduciaries are representing of. In the legal systems of United Kingdom, fiduciary duty is the most rigorous duty of ca re and duty of loyalty because the fiduciaries have to obey the duty that had implemented to prevent themselves from any irreconcilable circumstances with their principals or with different fiduciaries’ customers. In order to prevent conflict of interest, the Companies Act 2006 has implemented several fiduciary duties to the company’s director that has mentioned in sections 171 to 177. Directors’ duties in Companies Act 2006 In the Company Act 2006, there are several directors’ duties that are necessary for a director to act when carrying the responsibility of its position in a company, which is duty to act within their powers, duty to exercise independent judgement as well as duty to avoid conflicts of interest. 2.1 Duty to Act within Powers This is one of the most important duties that every directors of a company should act on. This duty requires the directors to perform their authority accordingly with the rights they have assigned by the company and utilise it in a proper purpose to give the best interests to the company. It is stated in the Section 171 of Companies Act 2006 that: A director of a company must act in accordance with the company’s constitution, and only exercise powers for the purposes for which they are conferred. Davies (2007) explains that the directors of the company are required to take after all the directions with reference to how the company’s undertakings ought to be sorted out and regulated that are set down in the company’s constitution in order to agree with any constraints that is set down in the constitution on what exercises an organization might legitimately participate. In the Section 171 (b), he explains that the directors’ powers should be utilized just for the proper purposes doctrine. This is to deal with the directors’ affairs by implement those powers that the company wish in order to avoid any conflicts with the company. Unfortunately, the directors have abuse their powers and their acts are not in line with the company’s constitution. This matter is clearly seen in the case of Hogg v Cramphorn Ltd[1], where it concerns about the distribution of shares by the directors of Cramphorn Ltd in order to avoid a take-over in the honest belief as they believe that the take-over would not be in the interest of the company and they want to protect their position as a director in the board of directors. As a result, Mr Hogg, one of the shareholder of the company sued the directors for being misused of their powers accordingly and the new distribution of shares was not legally distributed, so the court announced that this distribution of new shares are invalid (Lawteacher, 2015). However, there’s a case in Western Australia, which is Whitehouse v Carlton Hotels Pty Ltd[2] where Mr. Charles MacDonald Whitehouse is being sued for issuing the shares to his son in order to prevent his former’s wife or daughter to take over the company when he dies. In this case, the High Court of Australia held that Mr Whitehouse does not breach the directors’ duty although he distributed it for improper usage and therefore, the appeal is dismissed with costs (UnistudyGuides, 2013). 2.2 Duty to Exercise Independent Judgement Besides that, the directors must practice this fiduciary duty by using their power autonomously without influence by the other interests. In order to prevent the breach of this duty, the directors have to practice the duty in the Section 173 of Companies Act 2006, whereby they have to act: in accordance with an agreement which has been duly entered into by the company; or in a way authorised by the company’s constitution. In this fiduciary duty, it does not mean to give powers on the directors to delegate or avoid them from utilizing the power that is given by the company’s constitution to delegate. According to the Institute of Chartered Secretaries and Administrators (2015), the directors have to ensure that they will give the best interest entirely for its own company and shareholders instead of their own interests offered by the third party. Also, the directors of the company are allowed to consult other professions for the legal advice but, the final decision has to be judge independently by themselves. It is clearly seen in the case of Fulham Football Club Ltd. v Cabra Estates plc[3] that the directors did not exercise their powers accordingly with its independent judgement. This is happened where the Hammersmith and Fulham Borough Council consented to an agreement to expand the Craven Cottage, the football ground for housing purposes and assure that they will not restrict the advancement at a later date or bolster a compulsory purchase order. As a result, the directors of Fulham Football Club were held that they breached the duty of exercising independent judgement because they had not restricted the future exercise of their discretion accordingly (Quizlet, 2015). As mentioned in the AustLII (2015), the directors of the organization in the case of Thorby v Goldberg[4] was held by the High Court of Australia that they did not fetter on their discretion upon the interest of the organization in entering into a contract. 2.3 Duty to Avoid Conflicts of Interest Moreover, this directors are put into practice with this duty in order to dodge in a circumstances where a director can obtain either a direct or an indirect benefits from the conflict with the company’s interests. In conjunction of this, the Section 175 of Companies Act 2006 has clearly mentioned that this duty is not violated if: the situation cannot reasonably be regarded as likely to give rise to a conflict of interest; or the matter has been authorised by the directors. Based on the Institute of Chartered Secretaries and Administrators (2015), the breach of this duty is applied when the directors take advantages from the third party in terms of property, unofficial information and opportunities. At the same time, it is not a breach of duty in a circumstance that it is arise unreasonably or it has been approved by the directors. Unfortunately, the directors always face the conflict of interest with the competitor, major shareholder, or a supplier and it has been increasing from years to years. This is because the Act does not explained clearly on what is â€Å"interest† or the â€Å"conflict of interest† means. This issue has showed clearly in the case of Boardman v Phipps[5] where Mr Broadman and Tom Phipps buy the company shares with the acknowledgement of Mr Fox as they believe that they could turn the company around. Nevertheless, Mr Broadman and Tom Phipps did not entirely acquired to all beneficiaries and they have made a great pr ofit with Mr Fox. As a result Johnn Phipps has sued them for breaching the duty to avoid conflicts of interest (Webstroke Law, 2014). In Australia, the directors are also charge for breaching this duty, which is stated in the case of Chan v Zacharia [6]where the High Court of Australia was held that Dr Chan has breached the duty. This is because Dr Chan acted in his personal interest instead of legitimate the interest of the partnership as a whole (Oxbridge Notes, 2014). Conclusion: Prevention rather than cure? In conclusion, it is essential for every directors to act within the directors’ duties that is stated in the Companies Act 2006 to ensure that they do not breach the duty when carry out their responsibility to a company. There are several duties that is important among all of the directors’ duties, which is the duty to act within powers, duty to exercise independent judgement as well as duty to avoid conflicts of interest. It is mentioned in the LawTeacher (2015) that those directors who have breached the duties will caused the company to have financial losses and at the same time, the directors will also be charged for such as imprisonment, fines, and commercial consequences. The directors will also be barred from its position under the Company Directors Disqualification Act 1986 in the Section 6 if they breach the directors’ duties. In order to prevent the breach of duties rather than cure it, the Corporate Governance is a better system than the directorsâ€⠄¢ duties where the Cadbury Report 1992 states that it is a system where the companies are controlled and directed accordingly (SA Technical, 2012). This has led to more sharpness to the director’s responsibilities where they have the executive responsibilities and monitoring role to prevent the breaching of their duties as a directors. [1] Hogg v Cramphorn Ltd. [1967] Ch 254, Chancery Division [2] Whitehouse v Carlton Hotels Pty Ltd. [1987] 162 CLR 285 [3] Fulham Football Club Ltd. V Cabra Estates plc [1992] BCC 863 [4] Thorby v Goldberg [1964] HCA 41; (1964) 112 CLR 597 [5] Boardman v Phipps [1966] UKHL 2 [6] Kak Loui Chan v John Zacharia [1984] 58 ALJR 353

Development through life stages Essay

Discuss the nature-nurture debate in relation to the development of the individual (M1) & Evaluate how nature and nurture may affect the physical, intellectual, emotional and social development of two stages of the development of the individual (D1). Nature can be loosely defined as genetic inheritance or the genetic makeup (the information encoded in your genes) which a person inherits from both parents at the time of conception and carries throughout life. Several things in an individual genetically inherits include; ranging from gender, eye colour, risks for certain diseases and exceptional talents to height. The concept of nature thus refers to biologically inherited tendencies and abilities that people have and which may get revealed later on as they grow up. Nurture can be defined as the different environmental factors to which a person is subjected from birth to death. There are many environmental factors. They include both physical environments and social environments. Some t heorists believe that people behave as they do according to genetic predispositions or even because of ‘animal instincts.’ This is known as the ‘nature’ theory of human behaviour. Other theorists believe that people think and behave in certain ways because they are taught to do so. This is known as the ‘nurture’ theory of human behaviour. (www.yourenglishlessons.wordpress.com) Nature refers to the inherited (genetic) characteristics and tendencies that influence development. Some inherited characteristics appear in virtually everyone. All children have a set of universal human genes that, when coupled with a reasonable environment, permit them to develop as reasonably capable members of the human species. Inherited characteristics and tendencies are not always evident at birth. Many physical features emerge gradually through the process of maturation, the genetically guided changes that occur over the course of development. Environmental support, and responsive care from others, is necessary for maturation to take place. Children’s experiences in the environment affect all aspects of their being, for example the health of their bodies or the curiosity of their minds. Nurture affects children’s development in many ways. With good environmental support, children thrive. Unfortunately, the conditions of nurture are not always nurturing. For example, children who grow up in an abusive family must look outside the family for stable, affectionate care. It is known that your genetics determine what you will look like and even your height. However your height  and looks can be changed if a person doesn’t eat properly or are in an accident. People can become anorexic, obese, anaemic etc. And all of these can affect how a person looks and their height. If a child is malnourished then this can cause their growth to deteriorate and they may develop problems like rickets. By looking at adoption studies it is shown that identical twins share similar intelligence whether they are brought up together or not. With this data we can make an argument that genetics has a greater influence in the intelligence of identical twins as well as the environment. Your IQ which is determined by your genes can also be af fected by the environment around an individual. If a person has not got as good school opportunities as another person with the same determined IQ, if they perhaps cannot go to a good as school as them or if their teachers are not as good as the other then they’re IQ will not be as developed as the other person which means that nurture also plays a part in a person’s IQ. (www.boundless.com) However in recent years there has been a growing realization that the question of â€Å"how much† behaviour is due to heredity and â€Å"how much† to environment may itself be the wrong question. Take intelligence as an example. Like almost all types of human behaviour it is a complex, many-sided phenomenon which reveals itself (or not!) in a great variety of ways. The â€Å"how much† question assumes that the variables can all be expressed numerically and that the issue can be resolved in a quantitative manner. The reality is that nature and culture interact in a host of qualitatively different ways. (McLeod 2007) Nature vs. nurture could refer to really intelligent people. One reason given for their being so gifted at learning and acquiring information might be that it’s in their genes. They have really intelligent parents; a high IQ†¦ i.e. their genetic makeup has enabled them to be intelligent. And likewise, you might argue the opposite for very u nintelligent people. (Nature) Whereas some people might argue that it’s how that person is raised. The child’s parents gave him all kinds of means to learn with, or encouraged his education from an early age, etc. The ‘less intelligent’ child’s parents, on the other hand, kicked him outside all day, kept him from school, called him stupid, etc. (Nurture) In my opinion, both nature and nurture have an effect on the development of an individual. Having read both sides, I personally believe that indeed nature does have a significant impact on the holistic development of the  individual. In my opinion, our personalities are related to our genetics. I have a very similar temperament to my father, which supports my view. My sister on the other hand, has a temperament which is very similar to my mum’s. Also, I believe that our intelligence is genetically driven. Some people are naturally more intelligent than others and this cannot be disputed. Of course, nurture with regards to intelligence and personality is also important. If a child experiences a lack of support with their education, they may not perform to the best of their ability. With that being said however, the level of support that the child receives does not actually alter their natural ability. Also, an individual may suffer a negative experience in their upbringing. This may result in their development being ‘altered’ or ‘different.’ Peer pressure also exists and therefore we must consider all of these extra factors regarding the development of individuals. Researchers have uncovered convincing links between parenting styles and the effects these styles have on children. During the early 1960’s, psychologist Diana Baumrind conducted a study on more than 100 preschool-age children (Baumrid, D. (1967) child-care practices anteceding three patterns of preschool behaviour. Genetic psychology monographs, 75, 43-88). Using naturalistic observation, parental interviews and other research methods, she identified four important dimensions of parenting; disciplinary strategies, warmth and nurturance, communication styles and expectations of maturity and control. Based on these dimensions, Baumrind suggested that the majority of parents display one of three different parenting styles. Further research by Maccoby also suggested the addition of a fourth parenting style (Maccoby, E.E. (1992). The role of parents in the socialization of children: An historical overview. Developmental psychology, 28, 1006-1017) The four parenting styles are: Authoritarian parenting: in this style of parenting, children are expected to follow the strict rules established by the parents. Failure to follow such rules usually results in punishment. Authoritarian parents fail to explain the reasoning behind these rules. If asked to explain, the parent might simply reply, ‘because I said so.’ These parents have high demands, but are not responsive to their children. Authoritarian parenting styles generally  lead to children who are obedient and proficient, but they rank lower happiness, social competence and self-esteem. Authoritative parenting: like authoritarian parents, those with an authoritative parenting style establish rules and guidelines that their children are expected to follow. However, this parenting style is much more democratic. Authoritative parents are responsive to their children and willing to listen to questions. When children fail to meet the expectations, the parents are more nurturing and forgiving rather than punishing. Authoritative parenting styles tend to result in children who are happy, capable and successful (Maccoby, 1992.) Permissive parenting: permissive parents, sometimes referred to as indulgent parents, have very few demands to make of their children. These parents rarely discipline their children because they have relatively low expectations of maturity and self-control. According to Baumrind, permissive parents ‘’are more responsive than they are demanding. They are non-traditional and lenient, do not require mature behaviour, allow considerable self-regulation, and avoid confrontation’’ (1991). Permissive parents are generally nurturing and communicative with their children, often taking on the status of a friend more than that of a parent. Permissive parenting often results in children who rank low in happiness and self-regulation. These children are more likely to experience problems with authority and tend to perform poorly in school. Uninvolved parenting: An uninvolved parenting style is characterized by few demands, low responsiveness and little communication. While these parents fulfil the child’s basic needs, they are generally detached from their child’s life. In extreme cases, these parents may even reject or neglect the needs of their children. Uninvolved parenting styles rank lowest across all life domains. These children tend to lack self-control, have low self-esteem and are less competent than their peers. It is extremely important for a parent to demonstrate good parenting skills. How parents interact with their child affects their development in a significant way. How a child is brought up could affect the child’s social skills, they could turn out to be too shy, suffer anxiety, get nervous around people or even become mute depending on their situations at home. If a child is bought up in a home with violence, they could grow up thinking that it is the normal thing to do. Similarly, if a child is brought up in a very stable and loving household, this could  enable them to be happier and enjoy life more and this could also help bring out their personality and feelings. I believe that this suggests that a person’s personality does take an effect on how they deal with their environmental surroundings and the person that they will grow to become. Nurture can significantly impact an adult’s emotional and social development. If someone was treated badly as a child, this may reflect on their personality and behaviour as an adult. The individual may be withdrawn and depressed. This could be caused by the negative experiences they had in their childhood. Also, if an adult is obese it may be as a result of nurture. If a child is brought up being allowed to eat nothing but junk food, they will consider this type of eating as ‘normal’. As a result of this, nurture has a significant impact on the physical development of a child and indeed an adult, with regards to obesity. We could argue however, that obesity is genetic and that is where nature is to blame. In a study that included more than 5,000 identical and non-identical twin pairs, researchers found heredity to be a much bigger predictor of childhood obesity than lifestyle. They concluded that three-quarters of a child’s risk for becoming overweight is due to genetic influences, while just under a quarter of risk can be attributed to en vironment. Either way, both nature and nurture can have an impact on the physical development of an individual. (www.webmd.co.uk) I believe that if a child has grown up in a ‘rough area’ then it will be more likely that they might get into trouble with the police, in school etc. This may be because they have seen older children or maybe even adults do something they shouldn’t and this influences them to do the same. Drink and drugs may influence antisocial behaviour. If antisocial behaviour is seen as normal you may end up repeating the cycle. However, it is the parent’s responsibility to make sure that their child is safe. Therefore, I believe that environmental factors can change how a child behaves depending for example on where they live and what kind of people they are exposed to. I personally do not believe there is a correct answer to this debate. There is no way to prove how much influence each has in forming who we are, so we have to rely on logic and researc h that has been conducted regarding the issue. But each side has different interpretations of what evidence is available. I do believe however, that both nature and nurture play a significant part in our personal development but I believe  that they are equally as important, there is no ‘better’ theory. I believe that you are born with certain genetic traits and predispositions which influence how you react to your environment. Your environment shapes the person you are because it presents you with choices, challenges, and opportunities. Your genetic traits provide you with strengths and weaknesses. It is how you utilize those strengths to overcome the challenges, and take advantage of the opportunities, and of course the choices that you make that ultimately make you who you are. How does nature/nurture affect the development of Miya at 5 years old? Nature has a significant impact on the physical, intellectual, emotional and social development of Miya. During this stage of childhood, Miya will be going through a p eriod of growth. Miya’s physical development will be determined by her genes and this cannot be controlled. Growth is pre-determined by nature and therefore, it cannot be changed or stopped. Nurture also has a significant impact on Miya’s holistic development during this stage of her life. Parenting has a huge impact on her intellectual, emotional and social development. If Miya is fed a lot of junk food by her parents, then nurture would be responsible for her becoming overweight. Unless Miya is genetically programmed to become overweight, this would be at the fault of her parents for allowing her to eat too many unhealthy foods, and not providing her with a balanced diet. Also, nurture will impact significantly on Miya’s intellectual development. If she is encouraged to complete her homework e.g. by doing reading or simple maths with her parents, Miya will benefit intellectually. Also, if Miya’s parents did not take the time to do these activities with Miya her intellectual development may negatively be affected by nurture. In terms of emotional and social developmen t, nurture is significantly important at this stage of Miya’s life. If Miya is shown love, she will feel emotionally secure and accepted by her parents. Miya will be able to trust her parents and will expect affection and love from others if she is used to getting that at home. On the other hand however, if Miya experiences abuse from her parents, this can have devastating consequences on her emotional and social development both at this stage in her life and in the future. If Miya experiences abuse, she may have problems trusting people and this could continue on to her adulthood. How does nature/nurture affect the development of Miya at 14 years old? Nature/ Nurture have a  significant impact on Miya’s physical, intellectual, emotional and social development during this stage of the lifespan. In terms of her physical development, Miya will be going through puberty during this stage of her life. Puberty is controlled by nature. Puberty is genetically programmed, Miya cannot change that puberty will happen as it is determined by nature; the individual cannot change that it will eventually occur. Nature also affects Miya’s intellectual development. Miya will have a specific IQ which will determine her natural intelligence. Of course, through nurture, Miya can make the most of her IQ e.g. by encouragement to study, parents providing resources etc. but, her IQ cannot actually be changed as it is determined by nature. Miya’s IQ will be developed by nature, but it will be supported through the nurture she receives in her life. For example, by her parents and teachers supporting her to achieve her best possible outcomes in school. Nurture will have a major impact on the emotional and social development of Miya. During this time, peer pressure and the influence of her friends will be huge. As a result of peer pressure, Miya may engage in activities that she otherwise may not have considered (drinking, drugs etc.) With regards to her development, this may have a negative impact as Miya will most likely not be truly happy with the decisions she makes. The internet and social media will also have a significant impact on the development of Miya both socially and emotionally. Facebook will be a very important part of Miya’s life as she will want to keep in contact with friends by using this social networking site. If Miya uses Facebook correctly, it could be a positive experience. However, sometimes Facebook can result in bullying which could negatively impact on her social and emotional development at this point in her life. Nurture can also have an impact on the type of friends Miya may have. If Miya’s parents are strict, they may choose who she is allowed to/ not allowed to be friends with. This will affect Miya’s emotional and social development. If Miya is not allowed to socialise with certain people, she may become upset with the decisions her parents have made for her. Miya may rebel against her parents if she feels she hasn’t got enough freedom. If her parents are too strict, she may withdraw from talking to them as she might feel they will ‘judge’ her. As a result of this, Miya may not discuss concerns/worries she has and this could have a very negative impact on her emotional development. On the other hand  however, if Miya’s parents set reasonable boundaries the relationship may be better. Miya may feel more comfortable talking to her parents if they are not too strict. Also, Miya may be happier socially too. If she is allowed to socialise with who she wants, she will not feel the need to rebel against the restrictions that her parents create. References: McLeod, S. A. (2007). Nature Nurture in Psychology. Retrieved from http://www.simplypsychology.org/naturevsnurture.html (accessed 17/11/14) https://www.boundless.com/psychology/textbooks/boundless-psychology-textbook/intelligence-11/measuring-intelligence-62/genetic-and-environmental-impacts-on-intelligence-243-12778/) (accessed 19/11/14) http://yourenglishlessons.wordpress.com/2009/10/25/nature-vs-nurture-are-we-really-born-that-way/ (accessed 19/11/14) http://www.webmd.co.uk/children/news/20080211/nature-trumps-nurture-in-child-obesity (accessed 24/11/14)

Richman Investments “Internal Use Only” Data Classification Standard

Richman Investments â€Å"Internal Use Only† Data Classification Standard The â€Å"Internal Use Only† data classification standard at Richman Investments will include the most basic IT infrastructure domains to include the User Domain, Workstation Domain, and the LAN Domain. This will encompass all users and their workstations, as well their access to the internet and company server databases and any information in between. The User Domain will enforce an acceptable use policy (AUP) to define what each user can and cannot do with any company data shall he or she have access to it.As well as with company users, any outside contractor or third-party representatives shall also need to agree and comply with the AUP. All users must be properly identified and sign this AUP prior to gaining any access whatsoever to the company network. No exceptions. Any violation will be taken up with company executives and/or the authorities to assess further punitive action. The Workstatio n Domain includes all workstations approved on the company network. No personal devices or removable media may be used on this network. All devices and removable media will be issued by the company for official use only.To access any workstation, a user will need to be first verified, then setup with an account to be logged in with a username and pass code adhering to the IT departments set standards. All systems will undergo regular updates and be provided with anti-virus and anti-malware software for system monitoring. Access Control Lists (ACLs) will be drawn up to appropriately define what access each individual will have. Any violations will cause an immediate suspension of privileges and again the person(s) in violation will be subject to company executives decisions and/or the authorities for punitive action.The LAN Domain will include all data closets, physical elements of the LAN, as well as logical elements to be designated by authorized personnel. Authorized personnel wil l be properly screened and authorized by the IT department head and given a special access card with separate pin code as well their normal username and pass code. Each closet will require this special access card and code to gain admittance. Each server will also require this card and code along with separate username and login credentials.Any hardware, software and equipment is to be installed by these persons only on any machine. Along with that, they will assure proper print, e-mail, and file server setups. They will also be responsible for designating access to users according to ACLs. This includes setup and securing any company Wireless Access Points (WAPs) for use with company devices only. Any violations will be cause for immediate removal of special access rights and suspension of privileges. Again they will be dealt with by company executives and/or the authorities for further punitive action.

An Analysis of Chinaa E-Commerce Industry - 1488 Words

An Analysis of China’s E-Commerce Industry Introduction A little more than 10 years ago, China’s path to e-commerce leadership would have been difficult to foresee, even as the tech boom in the US and other markets saw the development of e-commerce as an important B2C and C2C channel. In 2000, China had yet to develop any e-commerce applications, and had only 2.1 million total internet users. Payment systems and physical delivery mechanisms to facilitate the development of e-commerce transactions were well-developed in other markets, but were simply lacking in China. Fast forward to the end of 2013: with Chinese internet users quickly approaching 600 million, China is on pace to pass the US and become the largest e-commerce†¦show more content†¦We can see from the chart below that by looking at the total e-commerce sales per country, China is the second-largest player in the global market, losing out only to the United States. Market trends Within the e-commerce industry in China, we are able to identify several market trends that shape the nature of the industry and also give us insights into how the industry will evolve in the near future. By comparing C2C and B2C transaction value over the pst few years, we can see that B2C has been gaining market share gradually, and will reach about 50% by 2016E. Also, we notice that there is rapid growth of mobile shopping, which is defined as customers who shop online using their mobile devices. Also, we notice that the amount of transactions that are processed using mobile devices has been slowly increasing over the past few years as well. Mobile Data from CNNIC indicate that mobile phones had become the number one terminal for surfing instead of computers by June