You are on page 1of 19

Running Head: ETHICS IN COUNSELING

Ethics in Counseling LaKenya Browder Liberty University

ETHICS IN COUNSELING Abstract Therapists today must adhere to many ethical guidelines when treating clients. The concept of

ethics is always relevant, despite the theory or type of treatment, involving a myriad of variables a therapist has to consider when making clinical decisions. This paper will discuss ethical choices counselors have to make when dealing with issues such as billing, confidentiality, termination, minority clients, screening; as well as difficult situations, such as dual relationships and when to ask certain members to leave group therapy. Ethics in group counseling and addictions counseling will be reviewed, which are unique to individual counseling. Though waning, leadership skills and education on group dynamics is needed in order for one to effectively counsel groups. It is unethical for a leader to attempt to lead a counseling group without the proper education on how to be a leader or the general dynamics of a group. The paper will end with my personal experience with leading a group.

ETHICS IN COUNSELING Ethics in Counseling Ethics has been defined by The Free Dictionary (2009) as the rules or standards governing the conduct of a person or the members of a profession. In the counseling field,

ethics was established in order to protect both the client and the therapist, while as the same time setting a standard to ensure healthy, effective treatment. Humans are complex beings, therefore, counseling can run into various situations that depend on a counselor who is not only educated and knowledgeable, but who is unbiased and confident enough to make solid, ethical decisions. Ethics is not always black and white, consisting of many shades of grey. Therefore, an effective counselor must be aware of the different difficult ethical situations that may arise in counseling, and weigh the various options that are available in order to come to a decision that is not only ethical, but compassionate to the clients needs. Harry Goolishisn (as cited in Faith, 2001) argued that damage could be done in therapy even when every ethical standard is religiously followed (p. 26). Clients may run the risk of being misunderstood, labeled, or having their wishes ignored as a result of following the letter but not the spirit of good ethics. Ethics should include the highest level of beneficial goals, not only for the client, but for the counseling relationship as well. In order to do this, the counselor must openly participate with the client, putting his or her wishes and ideas on the back burner. Lewis Thomas (as cited in Faith, 2001) believes ethics should include both one's mind and heart (pp. 26-27). When the counselor keeps an open heart, he or she is able to enter into the client's world, increasing the level of client identification and relational honesty. When the counselor is willing to feel what the client feels, boundaries are kept flexible, as each person becomes completely a part of what is created (Faith, 2001, p. 30).

ETHICS IN COUNSELING

Some counselors encounter anxiety and difficulty when it comes to the ethics of finances, which include the managing of fees and setting financial arrangements. A counselor is obligated to reasonably manage all financial business; yet, they are called to do so ethically and compassionately. The counselor must have solid billing and payment policies in order to set clear boundaries with each client, making sure these policies are maintained, as each member is expected to make full payment on time. Gans (as cited in Shapiro & Ginzberg, 2006) suggested that financial arrangements be included in the initial group contract (p. 485). If the counselor has an internal conflict with financial matters, or if he or she misunderstands the idea of taking care of business with being a uncompassionate caregiver, they may minimize the role of money, attempting to defend themselves from being seen as greedy and uncaring. It can become very problematic when the counselor beieves the erroneous idea that he or she is making money off of other peoples problems (Mangione, Forti & Iacuzzi, 2007; Shapiro & Ginzberg, 2006). There are certain variables that need to be considered when managing the financial aspect of counseling: the length of the session, the level of care given, whether or not to charge for pregroup evaluations, the amount charged for each session, and if there will be one general fee for all members of a group or a sliding scale. Members of a group, rather than individual counselees, may perceive the group experience parallel to his or her family dynamic, with can then invoke repressed memories of how money was perceived in his or her family of origin. For example, setting a sliding scale within a group can cause conflict when members transfer their original sibling rivalry to the group, resulting in accusations that the leader is showing partiality (Shapiro & Ginzberg, 2006). When a group has been meeting for a long period of time, the counselor may consider raising the counseling fee. In order for this decision to be made ethically, he or she must take

ETHICS IN COUNSELING certain matters into consideration, such as the initial counseling agreement, the duration of the group, how long each member has been there, and whether or not he or she is making a reasonable decision in the first place. This last consideration is where the counselor may have to

confront his or her own conflict with money, in which he or she may choose to seek supervision. Pepper (as cited in Shapiro & Ginzberg, 2006) suggested additional variables to be considered, such as the cost of living, inflation or even the counselors personal financial situation when contemplating whether or not to raise fees (Shapiro & Ginzberg, 2006, p. 486). Billing can be a significant ethical issue for a counselor, deciding whether or not to mail the bill or hand it to the client in person. Rutan and Stone (Shapiro & Ginzberg, 2006) suggested that a counselor distribute and collect payment during the group in order to directly address money matters openly (p. 488). Difficulty in this situation may occur when a group member fails to pay, which may become a source of shame and guilt. The counselor should do his or her best to prevent counseling debt from accumulating, if possible. It has also been suggested that counselors confront outstanding balances at the beginning of the group, but should refrain from shaming a member at all times. A counselor must also be aware of the manipulative member who may try to control the counselor or the group by paying in advance or even overpaying. An effective counselor will use discernment and not allow money to dictate his or her ethical decision-making (Shapiro & Ginzberg, 2006). In Western society, dual relationships in the field of counseling is often looked down upon, yet Kottler (2004) beliefs differently. He has worked among indigenous peoples where the group leader is expected to have dual roles in order to effectively intervene according to the culture. He believes multiple relationships are most problematic when they are exploitive, when one has been taken advantage of by another. As abuse in counseling became more common,

ETHICS IN COUNSELING safeguards had to be developed in order to guide practitioners, protect clients, safeguard the

autonomy of professional workers, and enhance the status of the profession (Faith, 2001; Kottler, 2004). Making ethical decisions is not something that comes naturally, but must be learned and practiced. Clinical decisions are not always ethical decisions, though tied together, ethics transcends theory. T. Andersen (as cited in Faith, 2001) suggested that therapists learn from practical conversations within the relationship with the client, rather than through training and reading alone. When counseling conversations develop from a mutual respect, great things can happen (Faith, 2001). In a group setting, there are multiple dynamics that need to be addressed in order for a counselor to be able to effectively discern the needs of each member, as well as the needs of the group as a whole (Mangione, Forti & Iacuzzi, 2007). Ending a group also requires ethical decision-making. When terminating a group, the counselor must make sure he or she effectively plans to ensure growth is facilitated throughout the duration of the group, up until termination. This includes careful group preparation from the very beginning. A counselor must also take into consideration how each individual member may deal with the loss of the group, which may evoke emotional difficulties for some, such as feelings of rejection and abandonment. Fantasies about developing a nonprofessional, including romantic, relationship can also occur, for both patient and therapist (Mangione, Forti & Iacuzzi, 2007). When members drop out of a group suddenly or prematurely, for unknown reasons, the counselor must ethically deal with this situation, as the group may press him or her for details or begin to come up with their own conclusions as to the reason why the individual left. Here, the counselor must figure out how to help the remaining members process the leave, while at the

ETHICS IN COUNSELING same time respecting and protecting the privacy of the departed client (Mangione, Forti & Iacuzzi, 2007). A situation may arise when a counselor has to ask a problematical member to leave the group. This can occur for different reasons: the member may be threatening, disruptive, not committed to the group, have a conflicted relationship with another member, or the group is not appropriate for the individual. The counselor must consider all perspectives before asking a member to leave; making sure no one is harmed or leaves the group with feeling rejected or abandoned by the leader or the group (Mangione, Forti & Iacuzzi, 2007). There may be a time when a counselor must leave a group, due to personal reasons, such as relocation, illness, or retirement. When it is for personal reasons, it is always an ethical obligation for the counselor to put the clients needs before his or her personal needs, when possible. Sometimes it is not in the best interest for a leader to continue the group, for example, when the leader is being threatened by a member who has a history of violence, in which therapists are allowed to terminate therapy when threatened or endangered by a client. In this

matter it is still the leaders ethical responsibility to make sure all of the members are taking care of, making referrals if needed for a smooth transition (Mangione, Forti & Iacuzzi, 2007; Randolph, 2010). Jeffery Kottler (2004) stated that he does not know how to teach people to lead groups without giving them the opportunity to experience being in a group and leading a group (under supervision). He argued that one could not become a group leader without knowing what it is like being a client, stating, "How the heck do you think youre going to convince your clients to take risks, to be open and authentic and real, when you are unwilling to be so yourself?" (Kottler, 2004, p. 52). Kottler (as cited in Davenport, 2004) believes it is hypocritical for a leader of a

ETHICS IN COUNSELING counseling group to ask its members to undergo experiences that they have been unwilling to undergo themselves (p. 44-46). An effective leader should be able to understand firsthand the vulnerability of a client. If the leader is not experienced enough, it is unethical for him or her to attempt to deal with others deep rooted issues and unfinished business. When dealing with a student leader, as Kitchener (as cited in Davenport, 2004) stated, it is the faculty's responsibility

to instill ethical attitudes (p. 44-46). It is unethical if a group counseling leader does not to have a firm understanding of group dynamics, leadership styles, counseling methods, ethical standards, and relevant research (Davenport, 2004; Susan & Barret, 2000). Koocher and Keith-Spiegel (as cited in Lasky & Riva, 2006) defined confidentiality as "a general standard of professional conduct that obliges a professional not to discuss information about a client with anyone"(p. 456). The counselor is obligated to relay information about confidentiality in a manner in which the client fully comprehends. There are situations when a counselor cannot guarantee confidentiality, for example, if there is a danger to others or a suspicion of child abuse. When discussing confidentiality to a client, it is ethical for the counselor to be entirely honest about its limitations, giving the client an opportunity to decide what information he or she will offer (Lasky & Riva, 2006). During group therapy, confidentiality becomes a little more difficult to ensure due to the presence of others. In this environment, there is no guarantee that members will keep any of the personal information disclosed in the meeting confidential. The therapist is still bound to the requirements of confidentiality when conducting group therapy, although he or she has less control over the depth of material disclosed or the level of confidentiality. In a group setting, the members are not bound to the same requirements. Privileged communication is nonexistent in group therapy in many states because of the presence of a third party during personal disclosure.

ETHICS IN COUNSELING Legally, personal disclosure in the presence of a third party is considered public. There are no legal consequences for a member of a group who discloses another member's personal information. Unfortunately, most members do not understand confidentiality, in which it the counselor's ethical responsibility to educate the group. This also includes the legality of confidentiality, making sure members understand that they can refrain from disclosing

information even if they receive a subpoena. Is it essential for the counselor to be educated about the statues in his or her state and how to apply it to groups (Lasky & Riva, 2006). Respecting the privacy of clients can create difficult ethical situations. It has been shown to cause harm to some members, when an individual is pressured to disclose personal information before they are ready, causing psychological distress. Not only can this make the individual feel uncomfortable, but may also cause concern, as there is no guarantee that his or her personal disclosures will be kept confidential by the other members in the group. If confidentiality is indeed breached by members of the group, the individual may feel betrayed. There are ways that a counselor can effectively handle such situations, preventing negative outcomes by dealing with each client ethically and compassionately. Koocher and Keith-Spiegel (as cited in Lasky & Riva, 2006) suggested that members be warned about the limitations of confidentiality in groups, and notify each one that it is basically unrealistic to expect absolute confidentiality. They also suggested that leaders educate members about respecting the privacy of other members, which is shown by keeping their personal information confidential (Lasky & Riva, 2006). When working with minors, individuals under the age of eighteen, in a group, it has been recommended that the counselor meet with potential group members and their parents to discuss what will be potentially disclosed. The manner in which the parents agree to the terms will

ETHICS IN COUNSELING significantly affect the way the minor will feel about personal disclosure. In school settings, school counselors can look to the Ethical Standards for School Counselors of the American

10

School Counselor Association for the standards (Harriet & Robert, 2002; Lasky & Riva, 2006). Addictions counseling is distinct when it comes to ethics. Six ethical situations unique to addictions counseling has been identified by Scott (2000): the lack of communication and continuity between research and clinical practice; lack of agreement over the necessary professional credentials; the questionable propensity of group work in the addictions field; special issues of confidentially and privileged communication; boundaries of professional practice in making treatment decisions; and unusual circumstances of informed consent (p. 209). Due to the complexity of addictions counseling, Scott (2000) suggested that counselors remain flexible, allowing these particular clients to discover their own path to recovery, as addiction is a heterogeneous disorder (Scott, 2000). One outstanding unethical practice in the field of addictions counseling is when the therapist fails to use, or even understand, research concerning addiction. Clinical standards for addictions counselors have historically been lower than other types of counseling. It is essential for addictions counselors not only to stay aware of current, relevant research, but also to be educated in various counseling theories, relapse prevention, cognitive strategies, neuropsychological processes, assessment, and individualized treatment planning. This can be obtained through relevant coursework, continuing education, and experience in treating addiction (Scott, 2000). Group work, such as self-help and in/out patient treatment, is popular in conventional addictions treatment, mainly due to a lack of resources. These groups raise ethical concerns. For one, self-help groups are not supervised by a licensed professional, which opens the group to a

ETHICS IN COUNSELING

11

variety of potential risks, including confidentiality issues and lack of effective treatment. Another ethical issue that may arise in addiction groups is whether certain individuals are appropriate for the group. For example, there may be individuals in an Alcoholics Anonymous group who suffers from cognitive impairments, such as paranoia or psychosis, in which he or she will have problems in the group, especially without professional care. Proper screening methods may prevent his from occurring. A third ethical risk in addiction counseling is confidentiality. Many individuals with addiction problems have legal problems. Disclosing personal information in this type of environment poses the risk of personal information getting back into the community and reaching authorities. This can happen without any legal consequences for the informant, due to the informational being disclosed in a public group. Dual relationships can also be an ethical problem with addiction counseling, due to the fact that many leaders of these self-help addiction groups were addicts from the community. In this situation the leader must seek to maintain a level of professionalism with boundaries (Scott, 2000). Proper screening is not only relevant in addiction counseling, but in any group setting, including minors. Group counseling in a school setting has its own set of complexities. For example, the counselor must decide whether or not to get parental permission during pre-group screening. Another ethical issue is deciding who is the actual client- the child or the parent? Martin & Huss (2000) believe that the child is the client ethically, but legally, the parent is the client. Whatever decision the counselor makes concerning these issues, he or she must obtain parental consent before including a minor in any type of counseling, group or individual (Martin & Huss, 2000). Corey, Corey & Haynes (2006) listed some additional guidelines of ethical principles when leading a group: have a clear idea of the type of group you are designing; tell prospective

ETHICS IN COUNSELING

12

group members what is expected of them; make prospective participants aware of the techniques that will be employed in of the exercises that they may be asked to participate in; be thoroughly grounded in a number of papers theoretical orientations as a basis for creating your own personalized style of leading group; be aware of the cultural context as you work with members; and make referral resources available to people who need or desire further psychological assistance (Corey, Corey & Haynes, 2006, p. 88). Group counseling is underutilized just as much as individual counseling, despite its effectiveness. For example, approximately 92% of college counseling centers offer group counseling in which approximately one in five students are willing to participate. It is essential for a counselor to take many variables into consideration when suggesting that a client start group counseling. Keeping communication open and honest can help the counselor discern the best type of treatment for each client (Vogel, Shechtman & Wade, 2010). There have been some concerns about stigmatization concerning individual counseling, yet its role in group counseling has not been as widely researched. Group counseling seems to be sought out less regularly than private, individual counseling. One of the main barriers to an individual seeking counseling is facing the stigma of being labeled as having a mental health problem. In order to avoid this labeling, an individual may avoid counseling altogether. Not only is does the individual face public stigma, but self-stigma. This is when an individual labels him or herself, perceiving themselves as inferior or weak, which results in a decrease in self-esteem. There seems to be a common belief that group counseling is for individuals who are highly disturbed. Perhaps there is only the picture of AA or NA when one thinks about group counseling. Clients may experience a high level of anxiety and resistance. The individual may fear that they will be judged by others, despite the fact that most individuals have positive

ETHICS IN COUNSELING

13

experiences with participating in group counseling. Public stigma occurs more often in men than women, as most men tend to feel that they should be more self-reliant and in control of their emotions than most women, who are more likely to seek help (Vogel, Shechtman & Wade, 2010). In the field of counseling, leadership skills and behavior have not been researched too often. These are relevant issues when it comes to counseling, especially with groups. A counselor needs to learn about his or her personal leadership style and about which methods work with which type of individuals. Leadership training may include topics such as emotional intelligence, character, professionalism, and integrity. These characteristics are all relevant to ethics in the professional counseling field. Unfortunately, many students will be ill-prepared for the roles they will assume, as little leadership training has been offered in higher education institutions. Louis, Peggy & Hall (2010) suggested that leadership training be included in counseling curriculum, which would include topics such as leadership theory and leadership behavior. Although most counseling programs include the instruction of many leadership skills, there is still a need to teach leadership application skills in order to successfully lead others (Louis, Peggy & Hall, 2010). Various meta-analyses have shown group psychotherapy to be just as effective as individual psychotherapy with patients who suffer from disorders such as depression, anxiety, personality, somatoform, chronic physical (Gutteling, Montagne, Nijs & van den Bosch, 2012). Yet, good, specialized treatment can be expensive and timely. Group therapy had been a solution to this problem, which makes it possible to save time and money by treating more people in less time. There are many beneficial factors in group therapy, such as interpersonal learning, selfacceptance and self -responsibility. Group therapy allows the client to recognize destructive

ETHICS IN COUNSELING

14

behavior in others, thus acknowledging it in themself. Upon a clients awareness that they are not the only one in the world feeling a certain way, he or she may experience a reduction in feelings of guilt and shame (Gutteling, Montagne, Nijs & van den Bosch, 2012). One study on the effectiveness of dialectical behavior therapy (DBT) in a group context reported 17 out of the 18 participants experienced significant changes in group therapy when compared to individual therapy, resulting in less anxiety symptoms, less anger, less depressive symptoms, less somatization, less interpersonal sensitivity, less obsessive-compulsive behavior, less paranoid ideation, less hostility, less hopelessness, less sleeping problems; less suicidal thoughts, less despair and less general psychiatric symptoms; compared to symptoms before beginning treatment. None of the symptoms increased during group therapy (Gutteling, Montagne, Nijs & van den Bosch, 2012). When creating a therapeutic group, it is essential to match the treatment with the characteristics of the particular client. Doing so may increase the desired outcome and effectiveness of the group treatment. Planned behavior, control theory, and behavioral choice theory suggest that clients who are matched to treatment based on their characteristics have better outcomes than those who are not matched. In one particular study on the effectiveness of matching obese participants to treatment based on their personal characteristics for either individual or group therapy found that group treatment resulted in greater weight loss than individual treatment, even for individuals who preferred individual therapy. Therefore, matching the treatment with the characteristic of the individual did not necessarily increase the effectiveness of the treatment. Although the participants had better results in group treatment, it was not based on being matched to the group by their characteristics. It is up to the counselor to use discernment to decide whether or not he or she believes group treatment would be effective

ETHICS IN COUNSELING

15

for each client, regardless of what the client prefers (Renjilian, Perri, Nezu, McKelvey, Shermer & Anton, 2001). Based on my experience with leading a group, I recognize that I tend to have a casual leadership style, yet, will very quickly establish order when necessary. Due to my personality style, I tend to smile a lot and make jokes, keeping the atmosphere light. The problem that sometimes occurs is that others take my niceness for weakness or ignorance. Others tend to test my authority often, or try to intimidate me. I do need to learn how to balance my personality so that I will not always have to have this battle, yet, strive to always remain true to myself. Learning about how to be an effective leader, as well as various techniques on how to deal with other personality types, will enable me to get over some of the hurdles I am confronted with. Some of the ethical challenges I tend to face is being too pushy. Although I tend to have a casual leadership style, I can be pushy. I can be pushy by rushing others or dominating the discussion. I must admit, I interrupt a lot. I have to deal with my personal shortcomings, in which one is my entitlement to be heard. There was a time in my life where I was ignored and didnt have a voice of my own. Now that I have found my voice, and have the education to back it up, I have discerned a spirit of entitlement, where I am entitled to talk until I feel I have been heard and feel that I have thoroughly proven that I am important. I am grieved that I sometimes counsel from this broken spirit, but at the same time I thank God that I am now aware of it and will strive to work at communicating in a more effective and healthy manner. Another ethical challenge I have is I often desire to bring others into a deep spiritual awareness, uncovering their sins so that they can get delivered. I sort of try to lure them into digging up the darkness so that they can face their demons and get delivered. I have learned through my education at Liberty

ETHICS IN COUNSELING that is not how God operates. Yes, he wants us all delivered, but it is a process that is seasoned with wisdom and grace, not just truth.

16

Proverbs 20:5 (NIV) reads: The purposes of a man's heart are deep waters, but a man of understanding draws them out. Counseling can be complex. When dealing with the matters of the heart one must be very spiritually discerning. As Jeremiah stated, the heart is extremely deceitful, who is able to sift through it, deciphering the lies from the truth (Jer. 17:9)? The person who has the Word of God as his or her foundation, gleaning wisdom and understanding from it, is able to become wise (Heb. 4:12; 2 Tim. 3:15). This person is able to draw out the matters of the heart. This is not something to be executed carelessly, but with compassion and precision. Counseling is never to be taken lightly, for out of the heart comes the essence of life (Pro. 4:23). It is this essence that the client is entrusting to the counselor. When this counselor understands that Jesus Christ is the Wonderful Counselor, and that the Holy Spirit is the counselor that teaches us all things, he or she will submit their heart to the authority of God, as navigate for godly answers to ungodly problems together (Isa. 9:6; John 14:26). Finding the right counselor is not an easy quest, yet, one is blessed when they take the time to find a wise, Spirit filled counselor they can trust. I approach therapy in a way that helps individuals find hope in Christ. I believe that this is the first step: faith that God is truly on their side and that he holds the solutions to all problems. I do not lead others to believe that God will fix all of their issues, but that he will stand alongside them and guide them into His Truth, which is powerful and able to make changes in anyones life. My main objective is to always lead the other to dependency on Christ. It is not by their own will-power, or by the clinical might of a counselor, but their healing is by the Spirit of Christ, and by this power we are all overcomers (Zech. 4:6).

ETHICS IN COUNSELING

17

ETHICS IN COUNSELING References Corey, G., Corey, M. S. & Haynes, R. (2006). Groups in action: Evolution and challenges. Belmont, CA: Brooks/Cole, Cengage Learning.

18

Davenport, D. (2004). Ethical issues in the teaching of group counseling. Journal for Specialists in Group Work, 29(1), 43-49. Ethics. 2009. In The Free Dictionary. Retrieved from http://www.thefreedictionary.com/ethics Faith, K. R. (2001). Ethics in therapy: Moving from the mind to the heart. Journal of Systemic Therapies, 20(4), 25-25. Gutteling, B. M., Montagne, B., Nijs, M. & van den Bosch, L.M.C. (Wies). (2012). Dialectical behavior therapy: Is outpatient group psychotherapy an effective alternative to individual psychotherapy? Preliminary conclusions. Comprehensive Psychiatry, 53(8), 1161-1168. Harriet, L. G., & Robert, H. P.,Jr. (2002). Privacy and confidentiality in school counseling. Professional School Counseling, 6(1), 20-20. Kottler, J. (2004). Realities of teaching group counseling. Journal for Specialists in Group Work, 29(1), 51-53. Lasky, G. B., & Riva, M. T. (2006). Confidentiality and privileged communication in group psychotherapy. International Journal of Group Psychotherapy, 56(4), 455-76. Louis, V. P., Peggy, T. C., & Hall, S. (2010). Leadership and leader behavior in counseling: Neglected skills. International Journal for the Advancement of Counselling, 32(1), 46-55. doi: http://dx.doi.org/10.1007/s10447-009-9088-y Mangione, L., Forti, R., & Iacuzzi, C. M. (2007). Ethics and endings in group psychotherapy: Saying good-bye and saying it well. International Journal of Group Psychotherapy, 57(1), 25-40.

ETHICS IN COUNSELING

19

Randolph, K. S. (2010). Ethics codes: Monitoring the major changes. Journal of Psychology and Christianity, 29(3), 263-267. Renjilian, David A., Perri, Michael G., Nezu, Arthur M., McKelvey, Wendy F., Shermer, Rebecca L. & Anton, Stephen D. (2001). Individual versus group therapy for obesity: Effects of matching participants to their treatment preferences. Journal of Consulting and Clinical Psychology, 69(4), 717-721. Scott, C. G. (2000). Ethical Issues in addiction counseling. Rehabilitation Counseling Bulletin, 43(4), 209-214 Shapiro, E. L., & Ginzberg, R. (2006). Buried treasure: Money, ethics, and countertransference in group therapy. International Journal of Group Psychotherapy, 56(4), 477-94. Susan, R. F. & Barret, B. (2000). Teaching group counseling skills: Problems and solutions. Counselor Education and Supervision, 40(2), 94-94.

You might also like