Академический Документы
Профессиональный Документы
Культура Документы
PROJECT REPORT
Submitted to:
Sir.Naveed Khan
Submitted by:
Anwar Hussain
Abuzar Ahsan
Saad Iqbal
Nadeem Muzaffar
Batch:
BBA (Hons)
16-A
1 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
TABLE OF CONTENTS
16-A ....................................................................................................................................1
TABLE OF CONTENTS.....................................................................................................2
ISLAMIC ECONOMIC SYSTEM VS CAPITALISM AND SOCIALISM.......................3
INTRODUCTION:..........................................................................................................3
ISLAMIC ECONOMIC SYSTEM..................................................................................3
Introduction:.................................................................................................................3
History:........................................................................................................................3
Property in Islam:.........................................................................................................4
CAPITALISM:................................................................................................................5
History:........................................................................................................................5
What is Capitalism? ....................................................................................................6
Features of Capitalism: ...............................................................................................6
Comparison with Islam: ..................................................................................................7
SOCIALISM..................................................................................................................12
What is Socialism? ....................................................................................................12
History:......................................................................................................................13
Distinctive Features of Socialism: ............................................................................14
CONCLUSION:.............................................................................................................17
COMPANY AND LIMITED LIABILITY FROM SHARIAH PROSPECTIVE.............18
Company in Islam:.........................................................................................................18
The Principle of Limited Liability:................................................................................19
Waqf:..........................................................................................................................22
Inheritance under debt:..............................................................................................25
Conclusion:....................................................................................................................27
2 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
INTRODUCTION:
The most dominant economic systems in the modern world at present are
capitalism and socialism. The capitalism is the dominant economic philosophy
in the western world mainly comprising Western Europe and Northern America
under the leadership of United States. The socialism has been dominant
economic ideology in USSR, Peoples Republic of China and some countries of
Eastern Europe. Although socialism, with downfall and dissolution of its former
leader Soviet Union, has received a great setback, yet it still holds a lot of
relevance as an economic philosophy.
Islamic economics in accordance with Islamic law. Islamic economics can refer
to the application of Islamic law to economic activity either where Islamic rule is
in force or where it is not; i.e. it can refer to the creation of an Islamic economic
system, or to simply following Islamic law in regards to spending, saving,
investing, giving, etc.
History:
3 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
These concepts, like others in Islamic law, came from the "prescriptions,
anecdotes, examples, and words of the Prophet, all gathered together and
systematized by commentators according to an inductive, casuistic method."
Sometimes other sources such as al-urf, (the custom), al-aql (reason) or al-ijma
(consensus of the jurists) were employed.
Property in Islam:
The Qur'an states that God is the sole owner of all matter in the heavens
and the earth. Allah said:
“So walk in the paths of the earth and eat of His sustenance which He
provides.”[Al-Mulk: 15]
“It is He who created for you all that exists on earth.” [Al-Baqarah: 29]
• Public property
• State property
• Private property
4 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
CAPITALISM:
History:
The origins of capitalism and free markets can be traced back to the Islamic
Golden Age and Muslim Agricultural Revolution, where the first market economy
and earliest forms of merchant capitalism took root between the 8th–12th
centuries, which some refer to as "Islamic capitalism". A vigorous monetary
economy was created by Muslims on the basis of the expanding levels of
circulation of a stable high-value currency (the dinar) and the integration of
monetary areas that were previously independent. Innovative new business
techniques and forms of business organisation were introduced by economists,
merchants and traders during this time. Such innovations included the earliest
trading companies, big businesses, contracts, bills of exchange, long-distance
international trade, the first forms of partnership (mufawada) such as limited
partnerships (mudaraba), and the earliest forms of credit, debt, profit, loss, capital
(al-mal), capital accumulation (nama al-mal), circulating capital, capital
5 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
What is Capitalism?
Capitalism, as defined by the Collins Dictionary, “is an economic system
based on the private ownership of the means of production, distribution and
exchange”. Broadly speaking, capitalism is the name given to the economic
system in which the principal means of production, distribution and exchange
are in private (individual or corporate) hands. The profit motive constitutes the
prime stimulus to productive exertion and the ‘price mechanism’ determines
what things shall be made in what quantities and what conditions.
Features of Capitalism:
Chief features of capitalism include : existence of unrestricted private
ownership of means of production, exchange and distribution; economic
freedom; profit motive as incentive for productive activity; free market and
competition; existence of monopolies; banking and institution of interest; wide
6 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
7 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
the limited right of private ownership with law of inheritance which distributes
the estate of the deceased among fairly large number of heirs averts
concentration of wealth in few hands and thus prevents class-conflict.
8 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
“O you who believe! Spend of the good things which you have earned, and of
that which We bring forth from the earth for you.” [Al-Baqarah: 267]
Islam forbids unhealthy competition and bans all the ways which lead to
it. Islam also disallows establishment of monopolies.
“And give them from the property of Allah, which He gave to you.”[An-Nur: 33]
9 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
big projects and economic ventures, huge funds are required which no
individual or firm can arrange. This leads to establishment of banks who borrow
capital from depositors and investors on lower rate of interest and lend it to
business enterprises on higher rate of interest. Thus the institution of interest has
become part and parcel of capitalism.
Islam considers interest as the most exploitive institution for humanity and has
abolished it root and branch in its every form and manifestation. According to
Al-Quran taking of interest tantamount to war against God and His
Apostle, while according to Prophet Muhammad (PBUH) interest is worse
than adultery. Islam builds its economy on interest free basis and promotes
profit and partnership as incentive for saving and investment.
“Whoever gives a good loan to Allah; and Allah will multiply it to him many
folds”
10 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
Islam on the one hand guarantees provision of basic human needs such as
food, clothing and shelter to everyone and, on the other hand, ensures fair and
equitable distribution of wealth and economic resources among all. It does not
tolerate existence of wide disparities among the rich and the poor and tries to
eliminate concentration of wealth in few hands. For bridging the gulf between
the rich and the poor and for ensuring equitable distribution of wealth, Islam has
taken many steps such as Zakat and Sadaqat, laws of inheritance and bequest,
voluntary charities and compulsory contributions in the form of taxes and duties.
To prevent concentration of wealth in few hands Islamic economic code has
taken measures like abolition of interest, prohibition of earning of wealth
through haram means, prohibition of hoarding of wealth, etc.
11 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
SOCIALISM
What is Socialism?
According to the Collins Dictionary, “Socialism is an economic theory or
system in which the means of production, distribution and exchange are owned
by the community collectively through the state. It is a transitional stage in the
development of a society from capitalism to communism, and is characterized
by the distribution of income according to work rather than need”. Advanced
Learner’s Dictionary explains socialism as “a political and economic theory
advocating that a country’s land, transport, natural resources and chief industries
should be owned and controlled by the whole community or by the state and that
wealth should be equally distributed.”
12 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
History:
Socialism has drawn its strength from the desire of conscientious men is all
ages from Plato to Ruskin for a more equitable and fair distribution of the
income and wealth. However, the word ‘socialism’ came into general use
around 1830. But it was Karl Marx who founded it on scientific lines. Marx is
known as father of socialism. He developed the principle of scientific socialism
which came to be known later on as communism. Along with his friend
Frederick Engel’s, he wrote and issued the famous communist Manifesto in
1848 calling upon the labour of the world ‘to unite as they were nothing to lose
but their chains’. He wrote his famous book Das Capital in 1867 which is
considered to be the Bible of socialism. Philosophy of Marx is mainly based
upon the following two principles:
13 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
Islam does not abolish private ownership of property and does not place
all the means of production, distribution and exchange in the hands of the state.
Although Islam upholds public ownership of some means of production which
are the common utility to the people, but it concedes the rights of private
ownership of majority of the means of production and distribution. Unlike
socialism, Islam gives economic freedom to an individual who can earn wealth,
own it and enjoy it within certain limits provided he does not infringe teachings
of Islam in the process of earning, owning and consuming it.
14 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
of history is the most vital element of Marxism. Marx has sought to explain
every event in history on economic grounds. According to him, origin of every
activity of man lies in economic factors. Marx does not believe in religion
which, in his view, is a bourgeois invention to keep the proletariat under their
perpetual control. Engel’s said: Matter is the only real thing in the world. The
communists believe that human reason is just a manifestation of matter and soul
has no independent existence of its own but is a product of matter. They hold
that all the different stages of human progress are determined by the interplay of
conflicting economic forces alone, thus leaving no place for God’s will. So
communism is a purely materialistic ideology which ridicules religion, concept
of God and all forms of spiritualism dubbing them as unscientific.
Islam is the perfect and final religion revealed by Lord of the universe for
the guidance of mankind. Its foremost aim is to ensure ‘falah’ or well-being of
humanity in this world and in the Hereafter. It does not give importance to
matter only at the cost of spirit as does a secular ideology like socialism. Islam
believes in the material as well as moral and spiritual welfare of its followers at
micro and macro level. Followers of Islam believe in one God, in all the
Prophets and Holy Scriptures, in the Hereafter, in the moral code and in the
universal brotherhood of mankind. In an Islamic state there exist no antagonistic
classes conflicting with each other; neither all the events in history are
determined by interplay of economic forces. Although, in the sight of Islam,
welfare of society does not lie in economic prosperity only as moral and
spiritual advancement is equally important, yet it does not discourage pursuit of
material prosperity through fair means.
15 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
16 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
fact, is a test by which Allah tries the human beings how they behave in good
and bad circumstances. However, Islam does not permit the differences in
possession of wealth to assume such proportions that concentration of wealth
takes place in few hands that live in luxury while vast majority of people lead a
life of abject poverty, misery and deprivation. Islam does not tolerate the
existence of unbridgeable gulf between the rich and the poor, but unlike
socialism it does not believe in equal distribution of wealth. Actually Islam
believes in fair, just and equitable distribution of wealth and in social justice.
CONCLUSION:
Islam as a religion and ideology needs to be revisited by both Muslims and non-
Muslims alike. It is a religion that should be looked at as a continuation of
previous religions and inheritor of them as well. As an ideology, Islam should be
viewed as one that provides economic, political, and social systems that do not
belong to the ideologies of materialism (both capitalism and socialism). After the
fall and collapse of socialism, the people of the world resorted to capitalism as
their only alternative. The collapse of capitalism is eminent. It is the responsibility
and the duty of the people of the world to examine Islam with serious and sincere
scrutiny, in order to consider it as the only viable alternative to capitalism.
17 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
Company in Islam:
Islam has laid down rules for ownership and designated various rules for
when individuals come together and distribute profits amongst themselves. This is
different to employment (Ijara) where one is compensated for the use of their skill
or labour in the form of wages or a salary. Islamic jurists have defined the word
'company' ("Shirkah" in Arabic) to mean "join together or intermix" and have
interpreted it as a legal concept "as a contract between partners in capital and
profits". A Shirkah is further elaborated to mean
1. The Company of Equals (Al-'Inan) this is where both partners put their money
into a business and work with it. Both partners would have the right to buy and
sell and take the company forward, hence all partners are all equal in their deposal.
2. The Company of Bodies (Al-Abdan) this is where two or more people come
together with their skills such as a consultant, doctor or craftsmen. Although they
use their money, the skill they have is what constitutes the basis of the company.
18 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
3. The Company of Body and Capital (Mudharaba) this is where one funds the
capital of the business and the other partner works with it. The partner who
provides the capital element is a silent partner and takes no part in the running of
the business. The other partner buys and sells on behalf of the company.
Introduction:
The concept of 'limited liability' has now become an inseparable ingredient of
the large scale enterprises of trade and industry throughout the modern world,
including the Muslim countries. The present discussion aims to explain this
concept and evaluate it from the Shari‘ah point of view in order to know whether
or not this principle is acceptable in a pure Islamic economy. The limited liability
in the modern economic and legal terminology is a condition under which a
partner or a shareholder of a business secures himself from bearing a loss greater
than the amount he has invested in a company or partner-ship with limited
liability. If the business incurs a loss, the maximum a shareholder can suffer, is
that he may lose his entire original investment. But the loss cannot extend to his
personal assets, and if the assets of the company are not sufficient to discharge all
19 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
its liabilities, the creditors cannot claim the remaining part of their receivables
from the personal assets of the shareholders.
Although the concept of 'limited liability' was, in some countries applied to
the partnership also, yet, it was most commonly applied to the companies and
corporate bodies. The basic purpose of the introduction of this principle was to
attract the maximum number of investors to the large-scale joint ventures and to
assure them that their personal fortunes will not be at stake if they wish to invest
their savings in such a joint enterprise. In the practice of modern trade, the concept
proved itself to be a vital force to mobilize large amounts of capital from a wide
range of investors.
No doubt, the concept of 'limited liability' is beneficial to the shareholders of a
company. But, at the same time, it may be injurious to its creditors. If the
liabilities of a limited company exceed its assets, the company becomes insolvent
and is consequently liquidated, the creditors may lose a considerable amount of
their claims, because they can only receive the liquidated value of the assets of the
company, and have no recourse to its shareholders for the rest of their claims.
Even the directors of the company who may be responsible for such an
unfortunate situation cannot be held responsible for satisfying the claims of the
creditors. It is this aspect of the concept of 'limited liability' which requires
consideration and research from the Shari‘ah viewpoint.
Limited Liability in Shariah:
Although the concept of 'limited liability' in the context of the modern commercial
practice is a new concept and finds no express mention as such in the original
sources of Islamic Fiqh, yet the Shari‘ah viewpoint about it can be sought in the
principles laid down by the Holy Qur’an, the Sunnah of the Holy Prophet and the
Islamic jurisprudence. This exercise requires some sort of ijtihad carried out by the
persons qualified for it. This ijtihad should preferably be undertaken by the
Shari‘ah scholars at a collective level, yet, as a pre-requisite, there should be some
individual efforts which may serve as a basis for the collective exercise.
20 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
As students of Shari‘ah, the writers have been considering the issue since long.
It is the outcome of initial thinking on the subject, and the purpose of this article is
to provide a foundation for further research.
The question of 'limited liability' it can be said, is closely related to the
concept of juridical personality of the modern corporate bodies. According to this
concept, a joint-stock company in itself enjoys the status of a separate entity as
distinguished from the individual entities of its shareholders. The separate entity as
a fictive person has legal personality and may thus sue and be sued, may make
contracts, may hold property in its name, and has the legal status of a natural
person in all its transactions entered into in the capacity of a juridical person.
The basic question, it is believed, is whether the concept of a 'juridical person'
is acceptable in Shari‘ah or not. Once the concept of 'juridical person' is accepted
and it is admitted that, despite its fictive nature, a juridical person can be treated as
a natural person in respect of the legal consequences of the transactions made in its
name, we will have to accept the concept of 'limited liability' which will follow as
a logical result of the former concept. The reason is obvious. If a real person i.e. a
human being dies insolvent, his creditors have no claim except to the extent of the
assets he has left behind. If his liabilities exceed his assets, the creditors will
certainly suffer, no remedy being left for them after the death of the indebted
person.
Now, if we accept that a company, in its capacity of a juridical person, has
the rights and obligations similar to those of a natural person, the same principle
will apply to an insolvent company. A company, after becoming insolvent, is
bound to be liquidated: and the liquidation of a company corresponds to the death
of a person, because a company after its liquidation, cannot exist any more. If the
creditors of a real person can suffer, when he dies insolvent, the creditors of a
juridical person may suffer too, when its legal life comes to end by its liquidation.
Therefore, the basic question is whether or not the concept of 'juridical person' is
acceptable to Shari‘ah. Although the idea of a juridical person, as envisage by the
21 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
modern economic and legal systems has not been dealt with in the Islamic Fiqh,
yet there are certain precedents where from the basic concept of a juridical person
may be derived by inference.
Waqf:
The first precedent is that of a Waqf. The Waqf is a legal and religious
institution wherein a person dedicates some of his properties for a religious or a
charitable purpose. The properties, after being declared as Waqf, no longer remain
in the ownership of the donor. The beneficiaries of a Waqf can benefit from the
corpus or the proceeds of the dedicated property, but they are not its owners. Its
ownership vests in Allah Almighty alone.
It seems that the Muslim jurists have treated the Waqf as a separate legal entity
and have ascribed to it some characteristics similar to those of a natural person.
This will be clear from two rulings given by the fuqaha’ (Muslim jurists) in
respect of Waqf.
Firstly, if a property is purchased with the income of a Waqf, the purchased
property cannot become a part of the Waqf automatically. Rather, the jurists say,
the property so purchased shall be treated as a property owned by the Waqf. It
clearly means that a Waqf, like a natural person, can own a property.
Secondly, the jurists have clearly mentioned that the money given to a mosque
as donation does not form part of the Waqf, but it passes to the ownership of the
mosque.
Here the mosque is accepted to be an owner of money. This principle has been
mentioned by some jurists of the Maliki School also. They have stated that a
mosque is capable of being the owner of something. This capability of the
mosque, according to them, is constructive, while the capability enjoyed by a human
being is physical.
22 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
bequest made in favour of a mosque, and gives the reason that a mosque can own
properties. Not only this, he extends the principle to an inn and a bridge also,
provided that they are Waqf.
It is clear from these examples that the Muslim jurists have accepted that a Waqf
can own properties. Obviously, a Waqf is not a human being, yet they have treated
it as a human being in the matter of ownership. Once its ownership it established,
it will logically follow that it can sell and purchase, may become a debtor and a
creditor and can sue and be sued, and thus all the characteristics of a 'juridical
person can be attributed to it.
Baitul-Mal:
Another example of 'juridical person' found in our classic literature of Fiqh is
that of the Baitul-mal (the exchequer of an Islamic state). Being public property,
all the citizens of an Islamic state have some beneficial right over the Baitul-mal,
yet, nobody can claim to be its owner. Still, the Baitul-mal has some rights and
obligations. Imam Al-Sarakhsi, the well-known Hanafi jurist, says in his work
"Al-Mabsut":
"The Baitul-mal has some rights and obligations which may possibly be
undetermined."
At another place the same author says: "If the head of an Islamic state needs
money to give salaries to his army, but he finds no money in the Kharaj
department of the Baitul-mal (wherefrom the salaries are generally given) he can
give salaries from the sadaqah (Zakah) department, but the amount so taken from
the sadaqah department shall be deemed to be a debt on the Kharaj department".
It follows from this that not only the Baitul-mal, but also the different
departments therein can borrow and advance loans to each other. The liability of
these loans does not lie on the head of state, but on the concerned department of
Baitul-mal. It means that each department of Baitul-mal is a separate entity and in
that capacity it can advance and borrow money, may be treated a debtor or a
23 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
creditor, and thus can sue and be sued in the same manner as a juridical person
does. It means that the Fuqaha of Islam have accepted the concept of juridical
person in respect of Baitul-mal.
Joint Stock:
Another example very much close to the concept of 'juridical person' in a joint
stock company is found in the Fiqh of Imam Shafi‘i. According to a settled
principle of Shafi‘i School, if more than one person run their business in partner-
ship, where their assets are mixed with each other, the Zakah will be levied on
each of them individually, but it will be payable on their joint-stock as a whole, so
much so that even if one of them does not own the amount of the nisab, but the
combined value of the total assets exceeds the prescribed limit of the nisab, zakah
will be payable on the whole joint-stock including the share of the former, and
thus the person whose share is less than the nisab shall also contribute to the levy
in proportion to his ownership in the total assets, whereas he was not subject to the
levy of zakah, had it been levied on each person in his individual capacity.
The same principle, which is called the principle of 'Khultah-al-Shuyu‘' is more
forcefully applied to the levy of Zakah on the livestock. Consequently, a person
sometimes has to pay more Zakah than he was liable to in his individual capacity,
and sometimes he has to pay less than that.
'The separate assets should not be joined together nor the joint assets should
be separated in order to reduce the amount of Zakah levied on them.
24 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
The fourth example is the property left by a deceased person whose liabilities
exceed the value of all the property left by him. For the purpose of brevity we can
refer to it as 'inheritance under debt'.
According to the jurists, this property is neither owned by the deceased,
because he is no more alive, nor is it owned by his heir, for the debts on the
deceased have a preferential right over the property as compared to the rights of
the heirs. It is not even owned by the creditors, because the settlement has not yet
taken place. They have their claims over it, but it is not their property unless it is
actually divided between them. Being property of nobody, it has its own existence
and it can be termed a legal entity. The heirs of the deceased or his nominated
executor will look after the property as managers, but they are not the owners. If
the process of the settlement of debt requires some expenses, the same will be met
by the property itself.
Looked at from this angle, this 'inheritance under debt' has its own entity which
may sell and purchase, becomes debtor and creditor, and has the characteristics
very much similar to those of a 'juridical person.' Not only this, the liability of this
'juridical person' is certainly limited to its existing assets. If the assets do not
suffice to settle all the debts, there is no remedy left with its creditors to sue
anybody, including the heirs of the deceased, for the rest of their claims.
These are some instances where the Muslim jurists have affirmed a legal entity,
similar to that of a juridical person. These examples would show that the concept
25 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
of 'juridical person' is not totally foreign to the Islamic jurisprudence, and if the
juridical entity of a joint-stock company is accepted on the basis of these
precedents, no serious objection is likely to be raised against it.
As mentioned earlier, the question of limited liability of a company is closely
related to the concept of a 'juridical person'. If a 'juridical person' can be treated a
natural person in its rights and obligations, then, every person is liable only to the
limit of the assets he owns, and in case he dies insolvent no other person can bear
the burden of his remaining liabilities. But at the same time, it should be
emphasized, that the concept of 'limited liability' should not be allowed to work
for cheating people and escaping the natural liabilities consequent to a profitable
trade. So, the concept could be restricted, to the public companies only who issue
their shares to the general public and the number of whose shareholders is so large
that each one of them cannot be held responsible for the day-to-day affairs of the
business and for the debts exceeding the assets. On this analogy the limited
liability of a joint-stock company may be justified.
As for the private companies or the partnerships, the concept of limited liability
should not be applied to them, because, practically, each one of their shareholders
and partners can easily acquire a knowledge of the day-to-day affairs of the
business and should be held responsible for all its liabilities. There may be an
exception for the sleeping partners or the shareholders of a private company who
do not take part in the business practically and their liability may be limited as per
agreement between the partners. If the sleeping partners have a limited liability
under this agreement, it means, in terms of Islamic jurisprudence, that they have
not allowed the working partners to incur debts exceeding the value of the assets of
the business. In this case, if the debts of the business increase from the specified limit,
it will be the sole responsibility of the working partners who have exceeded the limit.
The upshot of the foregoing discussion is that the concept of limited liability can
be justified, from the Shari‘ah viewpoint, in the public joint-stock companies and
those corporate bodies only who issue their shares to general public. The concept
26 of 27
ISLAMIC PROSPECTIVE OF BUSINESS
may also be applied to the sleeping partners of a firm and to the shareholders of a
private company who take no active part in the business management. But the
liability of the active partners in a partnership and active shareholders of a private
company should always be unlimited.
Conclusion:
At the end, we should again recall what has been pointed out at the outset.
The issue of limited liability, being a modern issue which requires a collective
effort to find out its solution in the light of Shari‘ah, the above discussion should
not be deemed to be a final verdict on the subject. This is only the outcome of an
initial thinking which always remains subject to further study and research. The
only purpose is to persuade them to evaluate their own performance from the
Shariah point of view and to adopt a realistic approach while designing their
procedure and determining their policies.
27 of 27