Day 134 - 13 Jun 95 - Page 13


     
     1        managers" at the bottom.
     2
     3   MR. JUSTICE BELL:  Yes.  Is that hirings or people actually in
     4        post?
     5        A.  That is people in post.
     6
     7   Q.   That is not necessarily inconsistent, is it?
     8
     9   MR. MORRIS:  No, but it would show that since 1989, from all the
    10        information that has been provided since that date, the
    11        management, basically, a greater percentage -----
    12
    13   MR. JUSTICE BELL:  Why not put it as a question?
    14         (To the witness):  What is being suggested to you is
    15        although your pie charts show that more management have
    16        come from crew than from outside at the date of document B,
    17        can you remind me which date that is?
    18
    19   MS. STEEL:   Do we know what date that is?
    20
    21   MR. JUSTICE BELL:  Do you know what date the document is?
    22        A.  I think, from recollection, and it is cut off, that
    23        this will be the document relating to the period in 1992.
    24        I cannot say the precise date.  It will have been produced
    25        in 1993, I think, standing here now.
    26
    27   Q.   So although that purports to show that there are marginally
    28        more managers who have originated as crew than have come in
    29        from outside, what is being suggested to you is that since
    30        1989 anyway more have been coming into management
    31        positions, significantly more have been coming into
    32        management positions, from outside than from crew?
    33        A.  Right.
    34
    35   Q.   Do you follow?
    36        A.  Yes, I do.
    37
    38   MR. MORRIS:  Do you accept that?
    39        A.  The figures we have looked at show that and there have
    40        been many people hired externally.  We do hire graduates
    41        and so on, yes, and people who have worked in other
    42        employment.
    43
    44   Q.   Also on these documents, if we go back to page 700 as one
    45        that is easier to read although it has "COPY" all over it,
    46         -- mine has anyway -- was this document produced for the
    47        purposes of this case?
    48        A.  Page 700?
    49
    50   Q.   Yes, this series of documents? 
    51        A.  No. 
    52 
    53   Q.   The details that are on management hires and fires and
    54        turnover, would the same kind of details be available for
    55        crew turnover, the same information would be available, if
    56        you chose to use it?
    57        A.  I do not believe so, because they are held on two
    58        separate systems, so I do not know the answer to that.
    59
    60   Q.   If we leave those documents?  Can we just note, if we look

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