Day 166 - 28 Sep 95 - Page 18


     
     1        what we call the labour percentage?
     2        A.  That is right.
     3
     4   MR. JUSTICE BELL:  Where is 15.92?
     5
     6   MR. ATKINSON:  If you go look at under January and you go to
     7        payroll crew, you have 25,000 -- this is on the budget --
     8        and then it says 15.92, 15.92, 15.72, 15.32.  It does go
     9        down to 14.92 in July and August.  Why does that happen?
    10        Why were you projecting that it is going down?
    11        A.  If you look at the sales in July which are 29500
    12        against January of 163, on the first sheet, you are taking
    13        a vast amount more money and, obviously, the holidays are
    14        in July as they are in August, and  ---
    15
    16   Q.   Does the same apply -----
    17        A.  -- the seasonality of it.
    18
    19   Q.   Does the same apply in December?
    20        A.  Yes.  You have Christmas shopping and again the sales
    21        will rise then with Christmas shopping and also the
    22        children being off.
    23
    24   Q.   If you want to put that away, Mr. Atkinson, unless his
    25        Lordship has any questions?
    26
    27   MR. JUSTICE BELL:  No.
    28
    29   MR. ATKINSON:  Paragraph (17) of your statement you have that
    30        there:  "Magill is incorrect in saying that no jacket was
    31        provided.  The coats provided" -- this is for the freezer
    32         -- "for environment/index.html">litter patrols were available for everyone to use
    33        if they wanted.  I cannot recall at this distance of time
    34        whether gloves were specifically provided for use in the
    35        walk in freezer.  However, had anyone requested gloves I
    36        would have provided them and I cannot ever recall receiving
    37        any such request.
    38
    39        Similarly, I do not recall receiving requests for gloves
    40        from people who had developed skin rashes.  If someone had
    41        an allergy to a particular cleaning fluid, I would make
    42        sure that they did not come into contact with it.  It is
    43        almost entirely untrue that people with skin conditions
    44        would work on the preparation of food".  Do you stand by
    45        that?
    46        A.  Yes, I do.
    47
    48   Q.   Just one question on that:  Do you take the safety of your
    49        crew seriously?
    50        A.  Very much so.  I mean, if somebody had a problem when 
    51        they used a cleaning material, both for them in terms of 
    52        themselves and also for the customer point of view, you 
    53        would not want them to have a problem using it.
    54
    55   Q.   Just one more thing on that, what is your understanding of
    56        "hustle"?
    57        A.  Serving customers efficiently.
    58
    59   Q.   Does it involve running in store?
    60        A.  No.

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