Day 154 - 13 Jul 95 - Page 26


     
     1        because, although people might leave, they tend to be the
     2        people who were still on the basic rate who were leaving,
     3        so that the percentage would not vary very much?
     4        A.  It is not necessarily the people who are on the basic
     5        rate who would leave.  It may be a student who is quite a
     6        bit above the basic rate who has finished his college
     7        course and gone off to pursue another career.  So, it does
     8        not necessarily follow that the people on the basic rate
     9        are the people who would turnover.
    10
    11   MR. MORRIS:  No, what I am trying to say is that if you have 230
    12        people on your books in a year -- say you have 100 staff
    13        and you have a turnover rate of 130 to 140 per cent  ---
    14        A.  OK.
    15
    16   Q.   -- so you have something between 230 and 240 people on your
    17        books in a year, yes, the people that are staying on a long
    18        time with the Company, four or five years ---
    19        A.  Sure.
    20
    21   Q.   -- are not going to appear continuously in those figures as
    22        the people who are leaving and coming back.  They are not
    23        going to appear in the turnover figures.  But the people
    24        that are leaving more regularly, the people actually on the
    25        starting rate, the people that have been there less than
    26        four and a half months, say, are going to be people that
    27        are the bulk of the turnover figure.
    28
    29        I am not putting myself very clearly, but do you see what
    30        I am saying?
    31        A.  I think I see what you are saying.  What I would say is
    32        that whilst the turnover rate with the crew who are less
    33        than four and a half months would be slightly higher than
    34        the average, then the overall turnover rate occurs at all
    35        stages and pay rates.
    36
    37   Q.   Yes, I know.  May be if I express myself a bit better; if
    38        you have 230 people on your books in a year, say, for
    39        example, and something like approaching a quarter are on
    40        the starting rate at any one time?
    41        A.  Right.
    42
    43   Q.   It would be a far greater percentage than a quarter of all
    44        the staff that you had on your books in that year that
    45        would have been at the starting rate while they worked at
    46        McDonald's because, the far greater percentage of those 230
    47        people will be the people that are coming and going less
    48        than -----
    49
    50   MR. JUSTICE BELL:  That may be so but you can only have 100 per 
    51        cent at any given moment.  What he is giving is the 
    52        percentage of that 100 per cent at any given moment who are 
    53        on the starting rate.
    54
    55   MR. MORRIS:  But it may be a fact that the majority of
    56        McDonald's employees, even by your own admission, in a
    57        year, if not at any one moment, would have been on the
    58        starting rate for most of the time they were at McDonald's?
    59        A.  Right.  I think I see what you are trying to get at.
    60        Your assumption assumes that the majority of turnover

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