Day 062 - 06 Dec 94 - Page 51


     
     1        per cent of the packaging used by the restaurants in that
     2        country.  However, WLS does supply some of the packaging
     3        items going into Austria (mostly served by SDL),
     4        Switzerland (HLS), Spain and Portugal (DCSA) or Norway and
     5        Sweden (McInco).  Since we don't have those data and we
     6        wanted to avoid estimates, we did not consider the inter-DC
     7        trading."
     8        A.  Can I explain that?
     9
    10   Q.   How does that effect the figures you have given?
    11        A.  So that will mean that if we sell it to WLS based in
    12        Germany because it may be better in shipments, we are
    13        talking smaller volume items, so it may be better to get
    14        one truck to go from a supplier into the DC, into a large
    15        DC, such as WLS, and then have a truck with various items
    16        go from the DC, from that DC, to other DCs.
    17
    18   Q.   All I am trying to say is -----
    19        A.  So, it only -- these figures are then added to WLS, so
    20        that the WLS figures will actually be a bit higher than
    21        what is actually used by Germany.
    22
    23   Q.   So all I am saying is when you have got on 7.3 those
    24        figures -----
    25
    26   MR. JUSTICE BELL:  Some of the figures under WLS, for instance,
    27        are not just going to McDonald's stores in Germany.  A
    28        proportion (and, it would appear to me at the moment, a
    29        small proportion) goes into the countries which were listed
    30        in the last paragraph on 7.1, although there are
    31        distribution centres in those countries.
    32        A.  Correct.
    33
    34   Q.   But does that matter?  If it does matter -----
    35
    36   MR. MORRIS:  No, I am just trying to see -----
    37
    38   THE WITNESS:  The reason why that was put in was that because we
    39        later on -- you will find that in that document as well --
    40        we tried to establish a per store usage, and that fact that
    41        we did not consider inter-DC trading distorted those
    42        figures slightly.  These were done because simply ------
    43
    44   MR. JUSTICE BELL:  Does it matter, Mr. Morris?
    45
    46   MR. MORRIS:  It may not matter.  I thought it might do but may
    47        be  -----
    48
    49   MR. JUSTICE BELL:  It does not look to me at the moment as if it
    50        does. 
    51        A.  It will not matter for the European overview. 
    52 
    53   MS. STEEL:   The table you have got on at your Appendix 1?
    54        A.  Yes.
    55
    56   Q.   The material used in 1991, what is that taken from?
    57        A.  Sales data multiplied by again data that we had at that
    58        time.  Over 91 we did have sales data for most of the year.
    59
    60   Q.   That is the amount of packaging that you sold to whom?

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