2008 by Pearson Education, Inc.Publishing as Wharton School PublishingUpper Saddle River, New Jersey 07458Wharton School Publishing offers excellent discounts on this bookwhen ordered in quantity for bulk purchases or special sales. For moreinformation, please contact U.S. Corporate and Government Sales,1-800-382-3419, [email protected] sales outside the U.S., please contact International Sales [email protected] and product names mentioned herein are the trademarks orregistered trademarks of their respective owners.All rights reserved. No part of this book may be reproduced, inany form or by any means, without permission in writing from thepublisher.Printed in the United States of AmericaFirst Printing June 2008ISBN-10 0-13-234649-4ISBN-13 978-0-13-234649-8Pearson Education LTD.Pearson Education Australia PTY, Limited.Pearson Education Singapore, Pte. Ltd.Pearson Education North Asia, Ltd.Pearson Education Canada, Ltd.Pearson Educatión de Mexico, S.A. de C.V.Pearson Education—JapanPearson Education Malaysia, Pte. Ltd.Library of Congress Cataloging-in-Publication DataAckoff, Russell Lincoln, 1919-Vice President, Publisher:Tim MooreAssociate Publisher andDirector of Marketing:Amy NeidlingerWharton Editor:Yoram (Jerry) WindAcquisitions Editor:Martha CooleyEditorial Assistant:Pamela BolandOperations Manager:Gina KanouseDigital MarketingManager:Julie PhiferPublicity Manager:Laura CzajaAssistant MarketingManager:Megan ColvinCover Designer:Alan ClementsManaging Editor:Kristy HartCopy Editor:Keith ClineProofreader:San Dee PhillipsSenior Indexer:Cheryl LenserSenior Compositor:Gloria SchurickManufacturing Buyer:Dan UhrigTurning learning right side up : putting education back on track /Russell L. Ackoff and Daniel Greenberg.p. cm.Includes bibliographical references.ISBN-13: 978-0-13-234649-8 (hardback : alk. paper)ISBN-10: 0-13-234649-4 (hardback : alk. paper) 1. Education—Aims and objectives. 2.Education—Philosophy. I. Greenberg, Daniel A. (Daniel Asher), 1934- II. Title.LB41.A184 2008370.1—dc222007038247
Preface:Why, and How, This Book Was WrittenWhen we first met at a conference devoted to learning in the twenty-firstcentury, we were delighted to find ourselves deeply in sympathy with eachother’s approach to education. We had each spent long years with peopleof all ages and in a variety of different environments—schools, universities, businesses (large and small), nonprofit organizations—espousingviews that were for the most part considered radical and unrealistic. Wehad each endeavored to turn our dreams into reality, and we had eachenjoyed enough support and success to encourage us to carry on.But we had never crossed paths, either directly or indirectly. We soon discovered our common interests, our shared goals, and the widely divergent paths that our lives had taken. We soon became friends.One day, we began to discuss a certain subject of mutual interest. Becausewe lived too far apart to meet regularly face to face, we resorted to writing each other. Because of the ease of e-mail, our exchange became, fromthe outset, a conversation, a rapid exchange of ideas, albeit in writtenrather than oral form.The more we chatted through e-mail, the more we delved into the aspectsof education that had engrossed us throughout our lives.Eventually, this book emerged—a book we believe could be of interest toothers who have struggled with the same problems.We wanted, in the body of this book, to keep our unique voices andapproaches distinct and obvious to the reader. What you will see is theactual conversation we had, rather than an amalgamation and homogenization of two separate worldviews. In each chapter, our separate viewshave been set off by icons to enable readers to distinguish our “voices.”However, in the final section of the book, which is about our vision of idealeducation, we found that we could speak with one voice, undifferentiated.We have derived immense pleasure out of our collaboration in this venture.We hope you, the reader, will enjoy eavesdropping on our conversation.
Introduction: What Education Is AboutTo me education is a leading out of what is alreadythere in the pupil’s soul. [P]utting in of somethingthat is not there is not what I call education, I callit intrusion.—Muriel SparkBefore beginning a discussion about educational practices, it is necessaryto step back and determine the central purpose of the educational enterprise. Without a clear understanding of the goals of education, it isimpossible to make sensible suggestions about institutions that implement those goals.Usually, when this subject is raised, it is dealt with through some generalstatement such as the following: The purpose for which schools exist isto prepare children for life in the complex world of today. The equationof education with schools, the presumption that education deals primarily with children (or with adults who have inadequate skills, and are“childlike” in this regard), and the tacit assumption that everyone knowswhat specific knowledge is needed in today’s world—all these are treatedas self-evident, and the discussion quickly moves on to details of implementation, covering such matters as curriculum, assessment, pedagogy,and current child and adult development theories.For example, the American Heritage Dictionary defines education as “theact or process of imparting knowledge or skill; systematic instruction;teaching; schooling.” How far this current definition of the term straysfrom its original meaning can be seen from the shorter Oxford EnglishDictionary, which begins with the definition “the process of nourishingor rearing,” and refers to the Latin verb educere, from which the Englishword is derived, which means “to lead out,”“to bring out,”“to elicit,”“todraw forth.”In fact, this is the meaning on which ancient Greek philosophers focused.For them, education was a lifelong process of drawing forth from withineach person the full potential that lay within them. Where this potential
comes from was a matter of myth, and remains, for us today, a matter ofmystery. Nevertheless, the existence of some central purpose to each person’s life has been a cornerstone of American thinking from the earlydays of the Republic. For our Founding Fathers, the notion that everyhuman being had the “unalienable right” to “the pursuit of happiness” layat the very core of the justification for establishing this country. This“right” meant, for them, the right to find, pursue, and realize the reasonfor their own existence, which gives their lives meaning, and from whichthey can extract satisfaction. The declaration of such a right set our fledgling nation apart from all other nations and became one of the key elements of our country’s unique form of liberal democracy that has, overthe intervening centuries, come to appeal to an ever-increasing numberof people around the world.For us in America, education from the outset meant the process of discovering, in each and every one of us, the meaningful endeavors to whichwe are willing to devote ourselves with unflagging energy, given theopportunity to do so. For us, the creation of a polity that promotes order,tolerance, peaceful coexistence, and hope for the future depends criticallyon the establishment of an environment in which each of the individuals who constitute the polity has been given the greatest possible opportunity to “pursue happiness” in his or her personal life. It is essential tounderstand this, and to keep it in the front of our consciousness whendiscussing education in America today.There are several consequences to this understanding. Perhaps the mostobvious is that education is, by its very nature, not a process limited to,or even primarily revolving around, childhood. It is a lifelong enterprise,and it is a process enhanced by an environment that supports—or, moreprecisely, “nourishes”—to the greatest extent possible the attempts of allpeople to “find themselves” throughout their lives. As discussed throughout this book, the dawning twenty-first century provides, in this respect,avenues that have never been hitherto available to the human race.Something else to contemplate is the following question: Why have children been separated out as the primary objects of education in our society? Has this always been the case? If not, how has it come about, andwhat is the outlook for the future? In particular, is this developmentrelated to the migration of the term education from “lead forth” to“schooling”?xivTurning Learning Right Side Up
Actually, we know the answers to these questions. Mass schooling for allchildren is a recent phenomenon, a little over a century and half old. Amillion years of human history transpired without sending all childrento formal schools—a million years during which all the world’s rich cultures of prehistoric times, the ancient and medieval worlds, the Renaissance, and early “modern” times were formed, developed, and passedon. A million years during which the overwhelming majority of peoplelived in small, rural or tribal settings, where children from a very tenderage indeed became an integral part of the larger community.1Schools for children became an important feature of societies where theIndustrial Revolution took hold, together with a comprehension of thechallenge that industrialization might pose to the social fabric. In ourmodern world of computers and robotics, we tend to forget that duringthe first two centuries of industrialization, machines designed to producegoods at a staggering rate never before achievable through manual effortswere actually rather stupid: Their successful operation depended on theintimate conjoining of human effort to machine power. People had toperform as parts of machines—with precise, repetitive, mind-numbingaction.For societies accustomed by long tradition to having a large downtrodden underclass—such as those of Western Europe—it was not much ofa challenge to transform traditional forms of servitude to the newerservitude to the machine and the company owner. For the United States,the situation was touchier. Here, a culture declaring itself to be the protector of individual liberty, and affording seemingly boundless opportunities for the expression of personal freedom, the challenge of creatinga large, docile population that would accept the dominance of the factorysystem in their lives was enormous.2 In the first decades of the nineteenth century, it became clear that the only way to succeed with industrializing (and hence modernizing) this country was to find a way tobreak the inherently free human spirit during childhood.This was no secret, sinister conspiracy against humanity. On the contrary,it was a project discussed openly and candidly by the leading Americanthinkers of the day, who set out to create an environment for children inwhich they could be forcibly trained to be obedient, to follow orders, andto perform highly monotonous tasks without rebelling. What amountedto incarceration of children during a period of indoctrination and training was explained as a necessity for their own future good—for theirIntroductionxv
own prosperity, for the prosperity of the country, and for the benefit ofa glowing destiny for their progeny.The founders of modern mass schooling decided, in addition, to use thetime children spent in school to impart to them, through endless drill,some skills that were deemed useful in a thriving industrial environment. The three Rs—reading, writing, arithmetic—were seen to providea work force that could understand basic instructions, engage in rudimentary written communication, and perform simple office functions,thus creating the most skilled mass workforce in the world.The success of mass schooling in this country was dramatic, by industrialstandards. From a provincial backwater, America rapidly marched to theforefront of industrial powers, reaching unheard-of levels of productionand wealth. The mass schooling methods of child education thusappeared to be vindicated and became models for the developed world.When we are discussing the creation of an ideal educational environment, the fundamental question before us is this: Can the root meaningof education, as a lifelong process of self-discovery, be restored in a liberal democracy such as ours in the twenty-first century? If it can, whattransformations does that demand in our present culture?Education, as currently provided, has many objectives, some consciousand some not. One objective seldom raised to consciousness is to ensuremaintenance and preservation of the status quo—to produce membersof society who will not challenge any fundamental aspects of the waythings are. Students and teachers may be aware of the possibility of—andeven favor—certain improvements, but these tend to be ones that aresmall and incremental, not fundamental. Some well-known aphorismsreflect this: Let well enough alone, don’t rock the boat, and let nature takeits course. When action is required, people tend to look for the least thatneeds to be done to take care of the problem.Education has the objective of giving meaning to the lives of the students.This requires making them aware of the value they can create for others,how they can be useful to and be valued by others. This objective isenclosed in what I believe should be the primary objective of education:xviTurning Learning Right Side Up
to enable students to develop and be able to contribute to the development of the society of which they are part.Unfortunately, development and growth are commonly treated as synonyms. They are not the same thing. Either can take place without theother. Rubbish heaps grow but do not develop, and Einstein continuedto develop long after he stopped growing.Growth is an increase in size or number. The amount of resources onehas available can grow and is reflected in standard of living. Developmentis not a matter of how much one has but of how much one can do withwhatever one has. This is reflected in quality of life. Robinson Crusoe isa better model of development than J. Pierpont Morgan.To develop is to increase one’s desire and ability to satisfy one’s ownneeds and legitimate desires and those of others. A legitimate desire isone the satisfaction of which does not reduce the desire and ability ofothers to develop.Development is a matter of learning, increasing one’s competence.Therefore, because one cannot learn for another, the only kind of development that is possible is self-development. Others, like the educationalsystem, can and should encourage and facilitate the self-development ofstudents.Development has four aspects: scientific, economic, ethical, and esthetic.Science consists of the pursuit of understanding of natural phenomena.Technology is the application of the products of science, and educationis the principal means by which the outputs of science and technologyare disseminated. The economy is concerned with the pursuit of plenty,making available the resources that enable people to use the outputs ofscience and technology. Ethics is concerned with the pursuit of the good,peace on Earth and peace of mind. This implies doing nothing toobstruct the development of others (to the contrary, promoting it).Esthetics is concerned with the pursuit of beauty and fun—the productsof creative and recreative activities. Together, these four aspects makepossible the continual pursuit of development, which strives toward agoal, “omni-competence,” that can never be attained. However, one canalways come closer to it.Put another way, education has both extrinsic and intrinsic functions. Itsextrinsic or instrumental function is to encourage and facilitate thedevelopment of students and help make them helpful to others and selfsupporting members of society. It should enable them to learn what theyIntroductionxvii
need to know and understand to make a living and contribute to thesurvival of the communities of which they are part. Education’s intrinsic function is to enable its subjects to derive satisfaction from activitiesthat have no instrumental value—cultural and recreational activitiessuch as enjoying music, art, and literature and engaging in recreationalgames.Industrialization and urbanization in the United States were broughtabout primarily by scientific, technological, and economic advances earlyin the nineteenth century. Because of this, education has focused onthese aspects of growth and development and given little attention toethics and esthetics. As a result, the Industrial Revolution did a great dealof harm and created a great deal of ugliness, both of which we tend tooverlook or underestimate.In the early part of the nineteenth century, the United States was a nationof widely dispersed farms and small villages; it did not have marketslarge enough to support industrialization. Unlike Europe, which alreadyhad population concentrations in close geographic proximity, industrialization in the United States required two technological developmentsbefore it could take place: first, transportation that aggregated smalltowns and villages into larger markets, which occurred with the development of railroads; second, the ability to communicate among marketsrapidly and effectively. This was accomplished by the invention of thetelegraph, followed by the telephone and wireless devices.Machines that replaced man as a source of energy, replaced his muscle,became the idols worshiped at the time. This was set forth graphically inthe work of Frederick W. Taylor,3 who by analysis reduced manual laborto simple elementary tasks that required repetitive machine-like behavior from unskilled laborers.As industrialization progressed, work and the mechanization associatedwith it became more complex. More skill and knowledge were requiredfrom workers. Schools extended their offerings into the challenge. Technical and professional schools emerged and flourished. Also, as industrialization expanded, and particularly with the demand for labor duringthe world wars, women were drawn into the workplace They were liberated; children were left in the care of others and the educational system.This imposed on schools a new function: “baby (and older child) sitting.”The economic success of mechanized production raised the concept ofthe factory to an elevated position in society. It suggested to educatorsxviiiTurning Learning Right Side Up
that they design and operate schools as much like factories as possible.Students came to be thought of as raw material to be processed mechanically into “salable” finished products.Our society has now entered another era called, among other things, thepost-industrial era. The educational system has yet to catch up with thistransformation. Perhaps the essence of this transformation was best capsulized by Einstein when he wrote, “One should guard against preachingto young people success in the customary form as the main aim in life.The most important motive for work in school and in life is pleasure inwork, pleasure in its result, and the knowledge of the value of the resultto the community.” Such a universal statement could only have beenmade in a post-industrial world.Introductionxix
IndexAabsolution (of problems)definition of, 31in failing schools, 34accessibility of archetypes, 83, 88accessibility of knowledge, 83, 88administrators, defined, 116admission requirementsat Sudbury Valley School, 164in voucher system, 156adolescence, “first adolescence”(ages 1-4), 131-132adult role modeling forpreschool children, 133aesthetics, functions of, 114age distinctions, avoiding ineducation, 151-152age mixing, benefits of, 6-7analysiscombined withobservation, 81definition of, 59results of, 61of systems, 61analytic thinking, syntheticthinking versus, 59-63archetypes, accessibility of,83, 88Aristotle, 42, 99artdefined, 114role in education, 107-117science, relationship with,44-46Art: The Basis of Education(Prasad), 108-109assessment. See testingattitudes, development during“first adolescence” (ages 1-4),131-133authorityin liberal democracy, 96-97suppression of creativity by,37-38autocracy in schools, 67-68automation, definition of, 57Bbirthrate in India example, 87building designs for schools,57-58Busch III, August, 75business entrepreneurship,85, 89187
CCAI (computer-assistedinstruction), 17capital expenses, financing, 155careers, pursuing multiple,144-145Catholic Church during MiddleAges, 105changeexpectations of, 86resistance to, 71-75character, role in education,100-102Cherry, Colin, 53Child Art (Viola), 109-111child developmentrate of, assumptions bystandardized testing, 24-25role of arts in, 107-114childrenchanneling into disciplines ofstudy, 53creativity. See creativityeffect of standardized testingon, 27independence, learning, 130infants, learning in, 125-131mass schooling, developmentof, xvii-xviiineed fulfillment in, 127-129play, necessity for learning,47-48preschool children, learningin, 125-134problem-solving ability of, 29protecting from danger, 130citizenry, control over, 55188IndexCizek, Franz, 109-112clients, involvement in graduateeducaiton, 142collaborative learning withcomputers, 17college education, idealcharacteristics of, 139-145commision, errors of, 74-75common interests in learninggroups, 136communication. See alsolanguagewith infants, 129-130mechanization of, 57as part of human nature,107, 113in phases of humandevelopment, 129role in education, 103-104speaking, learning how,126-127at Sudbury Valley School,163, 168complexity, synthetic thinkingand, 61computer literacy experiment inIndia, 15-16computer-assisted instruction(CAI), 17computers in education, 14-17confidence, 101-102contemplation, role ineducation, 103context for questions, 28continuing education, 147-150Cooke, Stuart, 17craft, defined, 114crawling, learning how, 126
creative acts, requirementsfor, 35creative function of art, 114.See also artcreativity, suppression of, 29,35-38, 50. See also curiosityby disciplinary study, 42-44cultural purpose of schools,52-53culture, effect on individualrealization, 79-98cultures, interactions among,79-80curiosity. See also creativityas part of human nature,113-114role in education, 99-100suppression of, 104-105curriculum, complexity of, 53Ddanger, protecting childrenfrom, 130data, definition of, 18decoration, as part of humannature, 107, 113democracy. See liberaldemocracy; politicaldemocracydemocratic ideals. See ideals ofUnited Statesdependency of preschoolchildren, 133-134Descartes, 103designin dissolution of problems,33-34for school buildings, 57-58destructiveness of preschoolchildren, 133determination, 101developed society, individualrealization in, 79-89development. See also childdevelopmentaspects of, xixeffect of industrialization on,xx-xxigrowth versus, xixDewey, John, 57disciplines (of study), 39-44channeling children into, 53science and humanities, 44-46discussioncontinuing educationthrough, 148definition of, 10dissemination of ideas,ease of, 84dissolution (of problems)definition of, 33-34in failing schools, 35Eeconomic aspects ofdevelopment, xixeducation. See also learning;schoolingage distinctions in, avoiding,151-152arts, role of, 107-117character, role of, 100-102communication, role of,103-104Index189
computers in, 14-17contemplation, role of, 103continuing education,147-150curiosity, role of, 99-100definition of, xv, 9-10effect of industrialization on,xvii-xxieffect of life purpose on, xviextrinsic/intrinsicfunctions, xixin liberal democracy, 94-98objectives of, xv-xxiproblem solving, role of, 102talent development in,114-117teaching versus learning, 3-10educational systemidealized redesign of, 121-123resistance to change, 71-75educational tools natural tohuman beings, 99-105Einstein, Albert, xxielementary schools, idealcharacteristics of, 135-138elevator service example, 41-42employment opportunities,85, 89entertainment as art, 115entrance requirementsfor colleges anduniversites, 140in graduate education, 142equal opportunity, 66-68equality in liberal democracy,93, 96-97190Indexerrors of commission, 74-75errors of omission, 74-75esthetic aspects ofdevelopment, xixethical aspects ofdevelopment, xixexams. See testingexcellence, attainment of, 85exchange of ideas, ease of, 83, 88exercises, definition of, 28exit requirements in graduateeducation, 142explanation, role in learning, 5-7exposure (to knowledge),definition of, 10external motivation for learning,10-14extrinsic functions ofeducation, xixFfaculty members, role ingraduate education, 142-143failing schools, methods oftreating problem of, 34-35fantasy in modern science, 81-82feedback, 135ease of, 84, 88feeding children, 128financing operating expensesand capital expenses, 155fine arts. See art“first adolescence” (ages 1-4),131-132Ford Foundation example, 87
free spirit of children. Seecreativity; curiosityfundingease in locating, 84, 88for ideal schools, 153-158GGalileo, 45global mind, 58graduate education, idealcharacteristics of, 139-145graduation from Sudbury ValleySchool, 166-167Greek philosophers, effect onmodern science, 81Greenberg, Michael, 107growth, development versus, xixHhealth-care system example(obtaining wisdom), 19-20Henry, Jules, 29Heraclitus, 86hierarchical social structures,individual realization in, 92Highet, Gilbert, 56history of liberal democracy, 93human beings, educational toolsnatural to, 99-105human naturecommunication as part of,107, 113conflict with industrialculture, 55curiosity as part of, 113-114decoration as part of, 107, 113music as part of, 107, 113play as part of, 113-114humanities, relationship withscience, 44-46Iideal schools, funding for,153-158idealized redesign, 121-123ideals of United States, 65-69ideasdissemination, ease in, 84exchanging, ease in, 83, 88feedback, ease of, 84, 88imagination in modern science,81-82immersion as education inliberal democracy, 94-98inalienable rights. See individualrightsindependence, learning, 130India, computer literacyexperiment, 15-16Indian birthrate example, 87individual realizationin developed society, 79-89in hierarchical socialstructures, 92in liberal democracy, 91-98obstructions to, 87-89individual rights, 65-66in liberal democracy, 93in schools, lack of, 67Index191
industrialization. See alsopost-industrial eracore elements of, 82development of massschooling, xvii-xviiieffect on educational aspects,xx-xxiindustrialized nature of schools,49-56infantscommunication with, 129-130learning in, 125-131information, definition of, 18inner-city literacy example,10-14instruction, definition of, 9internal motivation for learning,10-14interpersonal communication.See communication; languageintrinsic functions ofeducation, xixJ–Kjob security in education system,71-73jokes, as creativity example, 36K-12 schools, idealcharacteristics of, 135-138knowledgeaccessibility of, 83, 88definition of, 18rate of change, 46-48as result of analysis, 61Kozol, Jonathan, 54Kulkarni, Manu, 108192IndexLLaing, Ronald D., 29language. See alsocommunicationpurpose of, 92, 95role in education, 103-104standardization of, 95leaders, defined, 116leadershipas an art, 114-117nurturing ability for, 117requirements for, 115-116learning. See also education;schoolingclasses of content of, 18collaborative learning withcomputers, 17continuing education and,147-150in infants, 125-131interconnectedness with workand play, 46-48in K-12 schools, idealcharacteristics of, 135-138for learning’s sake, 147-150methods of, 4-5from mistakes, 74-75motivation for, 10-14play, necessity of, 47-48in preschool children, 125-134during “retirement,” 151-152role of explanation in, 5-7teaching versus, 3-10wisdom, obtaining, 18-22legitimate desires, xixliberal democracy, individualrealization in, 91-98
life expectancy, increase in, 88life meaningas educational objective, xviiieffect on education inAmerica, xviliteracy, inner-city example,10-14Mmanagers, defined, 116mass schoolingdevelopment of, xvii-xviiiindustrialized nature of, 49-56meaning of “teaching” in, 8-9mechanization ofcommunication, 57medical care example, 39-40memorization, 3Metaphysics (Aristotle), 99Middle Ages, suppression ofcuriosity during, 104mistakes, learning from, 74-75Mitra, Sugata, 15-16modern science, elements of,80-82motivation for learning, 10-14multiple careers, pursuing,144-145music, as part of human nature,107, 113N–Onatural philosophy. See scienceneed fulfillment in children,127-129observationcombined with analysis, 81of symbols, 57obstructions to individualrealization, 87-89omission, errors of, 74-75operating expenses,financing, 155opportunity. See equalopportunityPparents, types of, 111participatory democracyin schools, 136Sudbury Valley School as,164-165, 168passion, 100patience with preschoolchildren, 133-134pedagogical seduction, 12personality. See characterphysics problem example, 43-44playinterconnectedness with workand learning, 46-48necessity for learning, 47-48as part of human nature,113-114at Sudbury Valley School,161-163, 168political democracy, 68post-industrial era, xxidevelopments in, 56-59individual realization in,82-87Index193
practices, learning in graduateeducation, 141-142Prasad, Devi, 109preschool children, learning in,125-134private schools, financingoperating expenses and capitalexpenses, 155problem solving, 27-31definition of, 32in failing schools, 35role in education, 102separating solutions bydiscipline, 39-44problemsdefinition of, 27methods of treating, 31-35in practices, 141prospective explanations, 19protecting children fromdanger, 130public education. See massschoolingpublic schools, financingoperating expenses and capitalexpenses, 155puzzles, as creativity example, 36Q–Rquestions, definition of, 28rate of accomplishment, 85rate of change of knowledge,46-48rational thought, 81, 87reading (inner-city example),10-14194Indexrecreative function of art, 114redesign. See dissolution (ofproblems)research cells in graduateeducation, 142resistance to change, 71-75resolution (of proble
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Bribery Act 2010 published its Post-Legislative Scrutiny Report on March 14, 2019. While the report highlighted that the UK Bribery Act is an “excellent piece of legislation” and “an example to other countries”, it sets out 35 recommendations and conclusions around the implementation and enforcement of the Act. For instance, the Committee requested greater clarity as to where the .