Day 152 - 11 Jul 95 - Page 54


     
     1        I think the figure of 15 per cent as proposed by the
     2        Defendants.  What comment do you have about that?
     3        A.  The Company never stipulated an exact labour per cent
     4        to keep in line with.  It is very much left to the local
     5        Manager in conjunction with the Supervisor to schedule to
     6        need rather than any fixed labour per cent.
     7
     8        So, if that need meant that on one particular week it was
     9        16 per cent and that was the end figure -- it was not like
    10        somebody came along and said:  "You have got to run your
    11        labour at 16 per cent or 15 per cent or 14 per cent".  It
    12        was done according to what management and crew need you had
    13        to take a particular amount of business.
    14
    15        For instance, if you needed two fry stations on, then you
    16        would put one person on each fry station.  That would not
    17        necessarily equate to any fixed labour per cent.
    18
    19   Q.   Perhaps I can ask it this way:  What is the key to labour
    20        costs?  Is it saving money or is it providing a service
    21        which will make a profit?
    22        A.  Providing a service that will make a profit at the end
    23        of the day, due to pleasing the customers, therefore, they
    24        will come back in the long term.
    25
    26   Q.   In your experience, what would be the consequence, do you
    27        think, if you were chronically under-staffed so that your
    28        crew were bad tempered, tired and grumpy?
    29        A.  The customers would not come back longer term.
    30
    31   Q.   Have you in all your experience in McDonald's ever come
    32        across a Manager or a Supervisor who was aiming rather at
    33        saving money than at providing the right number of crew for
    34        the right number of customers?
    35        A.  No.
    36
    37   Q.   Never?
    38        A.  Never.
    39
    40   Q.   Your restaurant at Colchester was Restaurant of the Year,
    41        I think, in 1987, was it not?
    42        A.  That is correct, yes.
    43
    44   Q.   What were the criteria which were used to judge that award,
    45        do you know?
    46        A.  It was the whole gamut of ways in which the store could
    47        be judged, firstly, sales increases, transcount increases,
    48        level of operation in the store, quality, service and
    49        cleanliness grades, resorts(?) are fulfilled, profit
    50        results, people development -- all those things. 
    51 
    52   Q.   You left, I think, as Manager in August 1987? 
    53        A.  I believe so, yes.
    54
    55   Q.   What was the date of the actual award, do you know?
    56        A.  The award, I think, was given out, would have been
    57        given out, at the conference around March/April time of the
    58        following year.
    59
    60   Q.   In 1988?

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