Day 303 - 19 Nov 96 - Page 39
1 one of the pink files... I did put this, I think, to Paul
2 Preston and to others. I have two bundle page numbers,
3 either 11 or 1,744. It was one of the letters written to
4 Clive Williams, who was under instruction to reduce labour
5 costs down or face dismissal as one of many things that he
6 had to do as a manager. Basically, that document, 21st
7 August 1991, sets out for the volume of takings what the
8 labour target is which they say he must achieve within the
9 targeted labour guidelines, "which are as follows", and
10 then it sets out these guideline targets between 14.25 per
11 cent and 16.5 per cent, depending on the volume of the
12 store. The point is that we -- it is volume 15, this
13 document.
14
15 MR. JUSTICE BELL: Pink 15?
16
17 MR. MORRIS: Yes, volume 15. In the light of all the evidence
18 that we have heard in the case, it is quite clear that
19 there is not one strict, just 15 per cent every store in
20 the country, but it depends on the volume of takings, but
21 that the overall effect is that a national figure of 15 per
22 cent, you know, give or take a decimal point here or there,
23 are the target targets that are imposed by Head Office on
24 stores through supervisors and that, you know, if there is
25 going to be any flexibility it is because of the volume of
26 sales but the targets are still strict, but they are strict
27 compared to what your store, what category of financial
28 turnover your store is in. Obviously, if it is a big store
29 or small store it makes a difference.
30
31 I think that is it.
32
33 MS. STEEL: I have a few little bits and pieces which I wanted
34 to mention. In relation to health and safety, I am not
35 sure, you know, what of this is going to come up, what
36 Mr. Rampton is going to be saying at the end of the day, so
37 I just mention these so you can bear them in mind and
38 compare them with what Mr. Rampton is saying.
39
40 In the video I think it is the management development
41 programme No. 1, floor control 1989, there was an extract,
42 which this is obviously designed for training managers, and
43 it says that 'if you run your crew will run', so obviously
44 they are trying to encourage managers to run around to get
45 the crew to run around, which the vast majority of sane
46 people in the world would consider to be a dangerous
47 working practice in kitchen environments with hot surfaces
48 and hot drinks around the place, and I would say that goes
49 for behind the counter as well because people are serving
50 hot drinks, including scalding hot coffee, and it is just
51 generally a dangerous practice to encourage people to run
52 around.
53
54 The other thing is that in the health and safety taskforce
55 minutes, which were disclosed very late in the day, very
56 late during the course of the trial, the minutes for 7th
57 November 1992 on page 1, I think it was, said that original
58 hygiene and safety advisers were to be introduced in
59 January 1993, and also that unless health and safety is
60 talked about in cost terms with hard figures top management
