Legal Counsel Research Articles

Green SPACs

AbstractWe examine the structural characteristics of special purpose acquisition companies (SPACs) focused on green causes. We explain their ecosystem, primary determinants of initial public offering (IPO) size, and speed of going public, and we calculate their returns around merger announcements and subsequent acquisition. Green SPAC size depends on CEO characteristics, choice of exchange and specialisation of respective stakeholders. The speed to IPO is related to the respective concentration of legal counsel. Green SPACs exhibit cumulative market‐adjusted returns in the range 6%–12% around the merger announcement. Merger returns are positive at the merger date but quickly become negative (−1% to −9%) and decline further with time.

OPTIMIZATION THE ROLE AND FUNCTION OF THE COMMUNITY POLICE IN MAINTAINING COMMUNITY SECURITY AND ORDERLINESS IN SIDOMUKTI VILLAGE

The research aims to know and describe the role and function of the Community Police in maintaining security and order in the community. This research uses an empirical juridical approach. Data collection techniques are carried out by observation, interview, and documentation studies, which then the data obtained from the research are processed using qualitative analysis methods, which then the results of the analysis are described descriptively. The results showed that the role of the Community Police in maintaining security and order in Sidomukti Village, Sukamaju District, North Luwu Regency, one of which was to overcome fights by youth groups in Sidomukti Village, namely their position as law enforcement officers (Gakkum) and as the core of Kamtibmas Coach, in this case the National Police has a duty in regulatory efforts to create security and order in the community. In addition, the role of the Police in overcoming brawls at the Bone-Bone Police Station is by conducting coaching and activities that are 1) Prefentive, such as carrying out coaching, lighting, legal counseling activities and carrying out patrols in vulnerable areas, and 2) Repressive, such as implementation in the form of enforcement of soft ones, to strict actions in the form of criminal punishment.

Enhancing access to justice: free legal aid and client-centered legal counseling through Clinical Legal Education in Uzbekistan

This article explores Uzbekistan's recent legal and judicial reforms aimed at fortifying the rule of law, protecting human rights, and enhancing access to justice in alignment with international norms. Reforms include adopting the Convention on the Rights of Persons with Disabilities, enacting gender equality laws, and introducing digital tools for legal consultations. However, challenges persist, particularly for vulnerable groups like women, rural youth, and people with disabilities, who face limited awareness of their rights and difficulties accessing legal remedies. The article proposes integrating client-centered legal counseling through Clinical Legal Education (CLE) to improve the provision of free legal aid to address this. Recommendations encompass institutionalizing CLE, incentivizing pro bono work, fostering collaboration with NGOs, utilizing technology for outreach, and implementing legal reform for free legal aid. These measures, alongside robust monitoring and training, promise to democratize access to justice and create a more equitable legal landscape in Uzbekistan. However, challenges persist, particularly for vulnerable groups like women, rural youth, and people with disabilities, who face limited awareness of their rights and difficulties accessing legal remedies. To address this, the article proposes integrating client-centered legal counseling through Clinical Legal Education (CLE) to improve the provision of free legal aid. Recommendations encompass institutionalizing CLE, incentivizing pro bono work, fostering collaboration with NGOs, utilizing technology for outreach, and implementing legal reform for free legal aid. These measures, alongside robust monitoring and training, promise to democratize access to justice and create a more equitable legal landscape in Uzbekistan.

Extreme Heat and Suicide Watch Incidents Among Incarcerated Men

ImportanceExtreme heat poses a distinct risk to the 2.1 million incarcerated people in the United States, who have disparately high rates of behavioral health conditions. Suicide is a leading cause of death among people in prisons.ObjectiveTo examine associations of extreme heat, solitary confinement, and an indicator of suicidal behaviors among incarcerated men in a Deep South US prison system.Design, Setting, and ParticipantsThis longitudinal case series panel study included adult men in prisons in Louisiana, a state with one of the largest prison systems in the United States that has been engaged in litigation due to lack of air conditioning and extreme heat. The unit of analysis was prison facility-days. A facility-level data set was created by merging administrative data files, which included demographic characteristics, health classification, housing location and movement, disciplinary records, and involvement in suicide-watch incidents for all incarcerated men in Louisiana during the observation period. Individual-level variables were aggregated to facility-days to merge in daily maximum heat index data from the US Local Climatological Data, which were linked to the zip codes of prisons. The observation period was January 1, 2015, to December 31, 2017. Data set construction occurred from August 2020 to September 2022, and analysis was conducted from December 2022 to February 2023.ExposureThe focal exposure was extreme heat days. Daily maximum heat index data were categorized into 6 bins (<30 °F, 30-39 °F, 40-49 °F, 50-59 °F, 70-79 °F, and ≥80 °F) and as an indicator for any facility-day where the maximum heat index exceeded the 90th percentile of heat indices for total days in observation period. Conditional fixed-effects negative binomial regression models were used to calculate incident rate ratios to test associations between extreme heat and suicide watch incidents, while controlling for covariates.Main Outcomes and MeasuresThe focal outcome was daily count of suicide watch incidents that were recorded in a carceral system database. Covariates included daily percentages of incarcerated persons at each prison with serious mental illness diagnosis, daily rate of solitary confinement, and total facility population.ResultsThe sample of 6 state-operated prisons provided 6576 facility-days for the analysis. Results suggest a dose-responsive association between extreme heat and daily counts of suicide-watch incidents; compared with days with temperatures between 60 and 69 °F, the rate of daily suicide incidents increased by 29% when the heat index reached the level of caution (ie, 80-89 °F) and by 36% when reaching extreme caution (90-103 °F) (80-89 °F: incidence rate ratio [IRR], 1.29; 95% CI, 1.17-1.43; P < .001; 90-103 °F: IRR, 1.36; 95% CI, 1.15-1.61; P < .001). Compared with other days, those with the extreme heat indicator were significantly associated with a 30% increase in the incident rate of daily suicide-watch incidents (IRR, 1.30; 95% CI, 1.18-1.45; P < .001).Conclusions and RelevanceFindings suggest an association between extreme heat and an indicator of suicidality among an incarcerated sample, contribute to an emerging literature exploring linkages between climatological events and health outcomes in prisons, and may have implications for legal interventions and advocacy seeking to abate heat-induced morbidity and mortality in carceral contexts.

Immigrant mothers as advocates: Understanding how Korean immigrant mothers of children with disabilities navigate special education in the USA

Despite a myriad of linguistic and cultural barriers, immigrant parents of children with disabilities in the United States have adopted a variety of advocacy strategies. Drawing upon the frameworks of Community Cultural Wealth and Ecological Systems Theory, this study explores how Korean immigrant mothers of children with disabilities advocate for their children within the special education system in the United States. Seven Korean immigrant mothers participated in semi-structured focus group interviews. The findings reveal that these mothers use various strategies, such as seeking resources, attending training, and engaging with support networks within the Korean immigrant community. They also proactively acquired knowledge of special education policies and sought assistance from legal advocacy groups. However, they face challenges in accessing information due to linguistic barriers and a lack of clear descriptions of their children's rights and available services. They also identified that their intersecting racial, ethnic, cultural, and gender identities contribute to their experiences of discrimination and disadvantage. The study underscores the importance of providing tailored information, enhancing community support, and addressing systemic barriers to empower immigrant mothers within the special education system. Implications for schools, school psychologists, and families are discussed, along with recommendations for future research.

Reconsidering Miranda rights: Modeling strategic action during the invocation stage of a police interrogation

This paper develops a method to identify manipulation of custodial suspects who attempt to invoke the Miranda right to legal counsel during a custodial interrogation. The method, developed from a combination of framing theory and hypergame theory, first documents the point where custodial suspects’ preferences shift and second identifies the proximate cause of that shift using excerpts from legal cases. The method applies linguistic analysis within a hypergame framework to reveal rational behavior of custodial suspects who, despite owning an initial preference to invoke, waive their right to counsel without explicit pressure from police. The paper terms this shift in preferences “manipulation” adding the concept to hypergames and to the literature on noncooperative discursive exchanges.

PENINGKATAN PENGETAHUAN HUKUM MELALUI PENYULUHAN DASAR-DASAR KONTRAK BISNIS BAGI UMKM

Micro, small and medium enterprise (MSMEs) as business owner, in running their business also cannot rule out the role of business contract when running their business. One of the aspect that deserve attention from the perspective of MSMEs, is the legal aspect of agreements and business contract drafting techniques, so that MSMEs owners become more legal literate, and they understand the importance of a business contract as a support for securing their business, in order to avoid further potential disputes with their business partners. Basics of drafting business contract for MSMEs is important because there are still many MSMEs owner who are not yet legally literate, including understanding the importance of making written agreements with their business partner. The method that being used in this activity is in the form of descriptive legal counseling, and the question asked are answered by conducting an analysis based on regulations and the principle of contract law. The counseling on the basics of drafting business contract for MSMEs delivered to Komunitas Pebisnis Pemula Jakbar can be said to be successful, considering that from the impressions and messages conveyed by the participant, most of them stated that the material presented was very important because they had never received counseling related to contract law, and they hope that it can be continued with legal counseling activities with other materials that can support MSMEs.

Skutki uwzględnienia przez wojewódzki sąd administracyjny skargi na sprzeciw Ministra Sprawiedliwości w sprawie wpisu na listę radców prawnych

The consequences of a voivodeship administrative court’s upholding the complaint on the Ministry of Justice’s opposition to registration on the list of attorneys-at-law The main aim of this work is to analyze the consequences voivodeship administrative court’s ruling which revokes the opposition to registration on the legal counsel’s list issued by the Ministry of Justice. The main issue here is the fact, that due to Article 152 § 1 of the Act on Administrative Courts Proceedings, the effect of a ruling which revokes the administrative act is that the legal effects of such an act are suspended until the court’s ruling will not be final and enforceable. In such a case, an important question arises – should the competent authorities of the National Bar of Attorneys-at-Law assume that the registration on the attorneys at law’s list is legal and as a result set the date for the candidate to take the oath? The analysis of the law and the nature of the Ministry’s objection leads to conclusions that the aforementioned effect of Article 152 § 1 does not occur in such a case. This is due to the dual nature of the objection. On the one hand, it is an administrative act (conventional activity), but on the other hand, it is part of the hypothesis of the legal norm preventing the release of the disposition. As a result, it can be assumed that the objection in this regard is a factual act.

Legal Counseling on National Health Insurance as the Fulfillment of the Right to Public Health in Singasari Village, Jonggol District, Bogor Regency, West Java, Indonesia

Community service is carried out by the Faculty of Law at the Christian University of Indonesia by providing legal counseling on national health insurance as fulfillment of the right to public health. This activity was held by the Singasari Village Office which is located at Jl. Cihaur Raya No. 17 Jonggol, Bogor. The method used is to provide counseling/lectures. The results legal counseling are “very effective considering that there are still many people who do not get information on the national health insurance provided by the Government. With this legal counseling, the community will become aware of this program and what benefits can be obtained, such as the existence of multiple benefits, medically and non-medically.”

Trauma-Informed Legal Advocacy: Medicolegal Approaches &amp; Best Practices for Immigration Attorneys

Trauma-informed legal advocacy is a compelling approach to utilize when attorneys represent traumatized individuals. Trauma-informed legacy advocacy in partnership with medicolegal approaches is a growing field within the medical and legal professions with theoretical underpinnings still developing. Excessive conflicts, trauma, persecution, human rights violations, and war across the globe are associated with an increased efflux of individuals and families from affected areas and an increased influx of people in host countries that are largely developed countries including North America, Australia, and Europe, making the role of immigration attorneys challenging. The traumatic experiences of these immigrants, refugees, and asylum seekers with psychological or neuropsychiatric symptoms not only stem from past traumatic experiences but also are associated with potential fears of being deported, separated from family, legal ramifications, and residential uncertainties in host countries while harboring memories of suffering from fear of persecution due to nationality, race, religion, political opinion, affiliation in a social group, and sexual orientation in countries of origins. Though much of the literature on trauma-informed practice focuses on the secondary traumatic stress of medical professionals, little attention has been geared toward the secondary traumatic effects on attorneys. While the increasing demand for an immigration psychological evaluation may be beneficial for an immigration case and helps create an avenue for immigration attorneys to understand their clients’ traumatic experience, there is a gap in knowledge about how to limit attorneys’ exposure to secondary trauma when providing trauma-informed legal advocacy, how to identify malingering among clients, and how a client’s trauma and memory lapse interplay. This article discusses the importance of immigration attorneys understanding and utilizing trauma-informed legal advocacy, recognizing the re-traumatization of victims during legal appearances, the importance of an immigration psychological evaluation of a client, and developing routine self-care practices.

Law education for students of Muhammadiyah Pujotomo Junior High School Mertoyudan Magelang to reduce juvenile crime

Child delinquency often leads to criminal behavior. Students involved in this case in juvenile law are known as Children in Conflict with the Law (ABH). Based on BPHN data for the 2020-2022 period, the number of ABH is 2,338 people. The three types of crimes that are mostly committed by children are theft, narcotics, and abuse. The purpose of this program is to provide legal counseling so that students understand which actions fall into the category of violations of criminal law, the types of legal sanctions, and the length of time the sentence has been served. The methods used are lectures, education and discussion. The results obtained from this program are students are able to understand what actions are included in criminal law violations. In addition, students are encouraged to strengthen their character by being brave in rejecting bad friends' invitations, being careful in choosing friends, not playing late into the night, and not being easily provoked.

Increasing Community Legal Awareness Regarding Legal Protection of Land Ownership Certificate Holders in Sawahan Village

This community service aims to increase public awareness of the legal protection of certificate holders. Registration of land ownership rights, guarantees legal certainty of land ownership rights to legal owners through the issuance of land certificates. Disputes over land ownership often occur in the community because the community needs to understand the legal force of land certificates as proof of rights. Land registration is carried out to provide legal certainty and protection for holders of land ownership certificates in good faith. Public awareness can be increased by understanding legal land ownership in the land registration system. There are 2 methods used in community service, namely, the socialization method and the legal counseling method. The knowledge provided to Partners was in the form of knowledge regarding the law regarding ownership of land certificates, the law in legal ownership of community land rights by statutory regulations, and the legal provisions regarding the land registration system. The results of this community service show that community understanding has increased. The result is indicated by the difference in pre-test and post-test scores administered when the activity was carried out. Communities understand their rights and obligations as owners of land rights legally by laws and regulations through a land registration system.

SOSIALISASI DESA SADAR HUKUM DALAM MENINGKATKAN KESADARAN HUKUM MASYARAKAT DESA JAMBANAN KECAMATAN SIDOHARJO SRAGEN

&lt;p&gt;The Community Service Program partners with the people of Jambanan Village, Sidoharjo District, Sragen Regency. There needs to be effective and sustainable socialization of the Law Awareness Family (Kadarkum) to overcome the lack of understanding of the law so that people really understand the importance of law. The activity method begins with the preparation stage, then the implementation stage and finally the reporting stage which is planned to be completed within 3 months. The research results show. The results and outputs of the activities after the implementation of the program have been achieved, that is, after the socialization was carried out, the community experienced an increase in knowledge and understanding of the importance of legal awareness in social life, therefore there is a need for synergy between related Ministries or Institutions in formulating programs that are sustainable and evaluated annually, one of which is through integrated legal counseling so that the program is expected to be focused, not overlapping, right on target and effective in disseminating information in order to increase legal awareness of the people of Jambanan Village, Sidoharjo District.&lt;/p&gt;&lt;p&gt;Keywords: &lt;em&gt;Village/Kelurahan Formation, Legal Awareness.&lt;/em&gt;&lt;/p&gt;&lt;p&gt; &lt;/p&gt;

Law Enforcement By Drugs Reserve Unit In Metro Resort Police Against Narcotics Abuse In Public Audience (Decision Number: 176/Pid.Sus/2021/Pn.Met)

The rise of narcotics abuse cases in Indonesia is currently increasingly troubling the community. Perpetrators of narcotics abuse are not only adults, even teenagers or parents are very many. The domino effect resulting from narcotics abuse is also increasingly diverse, and efforts to overcome narcotics abuse are steps that are not easy&#x0D; to implement. The problem in this study is how the efforts by the Metro Police Narcotics Investigation Unit and the inhibiting factors in law enforcement against perpetrators of narcotics abuse in the general public.Research method The research method uses a normative juridical approach and an empirical approach using secondary data and primary data, then a qualitative juridical data analysis is carried out. The results of the study show:&#x0D; (1) Law enforcement efforts by the Metro Police Drug Investigation Unit against perpetrators of narcotics abuse in the general public through preventive and repressive measures. (2) The inhibiting factors are the lack of coordination in the field and the limited personnel of drug investigators, the lack of supervision of the community for the prevention and eradication of drugs in the community, and the lack of facilities and infrastructure in the counseling and coaching process that support the prevention of drug crimes.Suggestions, awareness is needed from all parties, both from the government, society and the perpetrators themselves to be immediately aware of the dangers of narcotics abuse by holding and attending more frequent seminars, legal counseling and discussions regarding the dangers of narcotics.

Legal Counseling About the Problems of the Misuse of Pawned Goods

Guaranteeing goods in pawn guarantees often creates legal problems. One of the problems that arise is that creditors misuse pawn goods. Legal counseling on pawning to the community will first be carried out by exploring and identifying problems with pawn law that occur in the community. After the counseling, an evaluation will be given through question-and-answer interaction so that the level of success of the legal counseling that has been given can be known. In addition, the evaluation was carried out by distributing questionnaires to participants. Based on some of these evaluations, the results show that there has been an increase in public understanding regarding pawn law, the problems of abuse of pawn goods, and legal settlements when pawn law problems occur. Abstrak Penyuluhan Hukum Tentang Problematika Penyalahgunaan Barang Gadai. Penjaminan barang dalam penjaminan gadai seringkali menimbulkan permasalahan hukum. Salah satu permasalahan yang timbul yaitu kreditur melakukan penyalahgunaan barang gadai. Penyuluhan hukum tentang gadai terhadap masyarakat ini terlebih dahulu akan dilakukan penggalian dan pengidentifikasian permasalahn hukum gadai yang terjadi di masyarakat. Setelah penyuluhan akan diberikan evaluasi melalui interaksi tanya-jawab sehingga dapat diketahui tingkat keberhasilan penyuluhan hukum yang telah diberikan. Selain itu, evaluasi dilakukan dengan cara penyebaran kuisioner kepada peserta. Berdasarkan beberapa evaluasi tersebut maka didapatkan hasil bahwa terjadi peningkatan pemahaman masyarakat terkait hukum gadai, problematika penyalahgunaan barang gadai, dan penyelesaian hukum Ketika terjadi permasalahan hukum gadai.

Peran Notaris Dalam Memberikan Penyuluhan Hukum Kepada Masyarakat Dan Tanggung Jawab Notaris Setelah Pensiun

The aim of this research is to find out and examine the public's understanding of notarial deeds and their functions; the role of Notaries in providing legal understanding to the public in understanding the law and their responsibilities in making notarial deeds in Pohuwato Regency. The research method used is normative law using a statutory approach and a conceptual approach. The existence of an authentic deed as written evidence plays an important role in every legal relationship in people's lives, in various economic activities, activities in banking, land, social activities, etc. The need for written evidence in the form of authentic deeds is increasing in line with the growing demand for legal certainty in various economic and social relations, both at the national, regional and global levels. With an authentic deed, rights and obligations can be clearly determined, guaranteeing legal certainty and at the same time it is hoped that disputes can be avoided. As a public official, a notary is required to be responsible in carrying out his authority so that he can provide legal education to the public in accordance with the notary position law. The results of this research are (1) The role of Notaries in providing legal understanding to the public in understanding the law in relation to making notarial deeds is carried out by providing legal counseling to their clients, which can be divided into 2 (two) criteria, namely legal counseling followed by making the deed and legal counseling without being followed by making a deed. Legal counseling followed by making a deed is an inseparable unit; and (2) the notary's responsibility for authentic deeds made after the notary's position has ended or retired. This can be carried out by the authorized parties as long as the authentic deed has not been canceled by law within a period of 30 years from the date it was made by the Notary.

Peningkatan Kesadaran Hukum Mengenai Perlindungan Anak Bagi Siswa dan Guru di SMP Negeri 2 Luwuk

Children as the next generation of the nation, must be protected from childhood to adulthood. If a child has been in an environment of crime since childhood, that child can become a criminal in the future, and will disturb people's lives. It is wise for child protection to start in junior high school. Junior high school (SMP) as a place for children to gain knowledge, begins to learn to get along with peers, smaller friends or teachers and begins to understand ways to commit violence against others. Therefore, the protection of children and teachers is currently an important matter and must be a common concern. Lack of understanding and knowledge of legal protection for children in the school environment has resulted in many violations and even criminal acts of violence against children in the school environment. As a result, children do not feel comfortable at school, skip school, or even drop out. Taking into account the legal issues above, the law faculty community service team carried out this service activity as an effort to increase public awareness and teachers that the importance of child protection starts from a child-friendly school environment and teachers. Regarding these problems, we all must pay attention to the protection of children and teachers, including at SMP Negeri 2 Luwuk. In this community service, we provide counseling and outreach to the concept of child protection, namely the urgency of legal protection for children and teachers in schools. The outputs that will be produced through this service are legal counseling activities for the community, scientific articles in the Community Service Journal, Publication in the Media Period (Print/Online), then Mandatory Reports in the form of Service Implementation Results Reports, Activity Diary Books and Financial Record Books.

STRATEGI KOMUNIKASI BADAN PEMBINAAN HUKUM NASIONAL (BPHN) DALAM MELAKUKAN SOSIALISASI DI MASA PANDEMIC COVID-19

The purpose of this study is to find out how the Communication Strategy of the National Legal Development Agency (BPHN) supports and hinders the implementation of legal socialization through online media. The method used is qualitative with interviews. The informants in this study were Mr. Gunawan as the Coordinator of the Legal Cultivation Division of the BPHN Center, Mrs. Asiyah Budiarti as BPHN Junior Expert Legal Counselor and Mr. Ahmad Noval as a private employee. Using the theory of diffusion of innovation. The results of this study BPHN in developing a communication strategy in legal outreach during the Covid-19 Pandemic used two methods, namely direct legal counseling by going directly to the field assisted by obligatory parties, then using the indirect method by strengthening BPHN's social media such as Instagram, YouTube, websites containing legal content.

Evaluating the utility of elicited imitation as a measure of listening comprehension in the context of forensic linguistics

The Miranda rights guard against self-incrimination and guarantee access to legal counsel (Miranda v. Arizona, 1966). Individuals may waive these rights if they do so knowingly, and this requires them to comprehend their rights. Many L1 English speakers do not adequately understand the Miranda warning, and the situation is even worse for L2 speakers (e.g., Pavlenko, Hepford, Jarvis, 2019). Research is needed to assess Miranda comprehension among vulnerable populations and to develop and validate instruments that are both accurate and efficient measures of Miranda rights comprehension. The Guidelines for Communication of Rights to Non-Native Speakers of English (CoRG, 2015) emphasize the importance of assessing Miranda comprehension by having individuals paraphrase the Miranda sentences. Yet, Pavlenko et al. (2019) found that verbatim sentence repetition produces similar results to paraphrasing. The present study further explores this finding by comparing L2 performance on the oral equivalents of the types of written tasks used by Pavlenko et al.: elicited imitation (EI) and oral paraphrasing (OP). The purpose of the study is to determine whether EI can substitute for OP as a test of listening comprehension. Forty-two L2 English and eight L1 English participants completed both an EI and an OP test consisting of the same 30 sentences (see Ortega et al., 2002). The results showed a high correlation (r >.90) between the two measures, suggesting that both tests measure the same construct. Drawing on these findings, we discuss the advantages of EI over OP as a measure of listening comprehension and Miranda competency.

Stopping Firestone and starting a citizen ‘revolution from below’: reflections on the enduring exploitation of Liberian land and labour

Attempting to reduce America’s dependence on foreign-sourced rubber, Firestone established in 1926 the world’s largest industrial plantation in Liberia under a controversial 99-year-lease agreement. Nearly a century later, backlash against the exploitative nature of corporate hegemony and economic globalisation crystallised in a transnational campaign, Stop Firestone, and class action suit to hold the multinational accountable. I argue in this article that Liberia’s unequal incorporation into global capitalism has configured and reconfigured the set of relations between government and citizens through parallel, albeit interrelated, processes—the globalisation of capital (via trade and investments) and the globalisation of rights (via universalised notions of citizenship as a human right). While the pursuit of foreign direct investment (FDI) in particular placed the interests of investors like Firestone ‘above’ the state thus undermining government–citizen relations, it simultaneously created a politicised workforce and network of Liberian activists thus strengthening citizen–citizen relations. Based on careful review of concession agreements and court proceedings as well as interviews conducted with government officials, activists and legal advocates based in Liberia and the United States, this article is the first to meld historical and contemporary developments, underscoring the twenty-first century implications of Firestone’s enduring exploitation of Liberian land and labour.