Day 181 - 01 Nov 95 - Page 34


     
     1        turnover of 100 per cent, let us suppose -- obviously it is
     2        far too simple to give an example -- your workforce is 100
     3        throughout the whole of the year, the turnover of 100 per
     4        cent would mean that 200 people had worked for you in the
     5        course of that year.
     6
     7   MS. STEEL:   That is what I thought.  It just came out at 100.
     8
     9   MR. JUSTICE BELL:  I may have not expressed it as I wanted to,
    10        but I am not wrong about that at this stage.
    11
    12   MR. RAMPTON:  No, I do not think so.  I think what it means is
    13        that 100 has left and been replaced within that year.
    14
    15   MR. JUSTICE BELL:  Not necessarily, because that is
    16        Mr. Pearson's point.  20 of them may not have been replaced
    17        at all.  Let us just suppose you might have 20 who have not
    18        been replaced at all, 20 who have been replaced twice and
    19        60 who have been replaced once and that would give you 100
    20        per cent turnover.
    21
    22   MR. RAMPTON:  Yes, that is a undoubtedly right, my Lord.  I was
    23        trying to simplify it too far.  (To the witness):  But that
    24        last occasion to his Lordship, Mr. Pearson, leads to this,
    25        quite apart from the fact one cannot tell how long people
    26        have been there from looking at turnover figures, it leads
    27        to this important consideration, does it not, that amongst
    28        those turnover figures you will find people who have left,
    29        come back, left and come back again, all within the same
    30        year?
    31        A.  The first point, turnover not connected with length of
    32        service.  I mean, turnover is associated with short -- you
    33        know, the higher the turnover, the shorter the average
    34        length of service.  That must be statistically correct.
    35        Whether people come and go and come back again, you know,
    36        you would have to record that properly as each time someone
    37        comes back, statistically, in order not to ruin your
    38        numbers, you would have to record it as a -- and being a
    39        bit of a statistician, I would be really annoyed if someone
    40        were to present me with figures which did not -- you know,
    41        if you had one person who had been there five times and
    42        they just turn up once, it would be five incidents of
    43        employment.  Do you see what I mean?
    44
    45   Q.   Yes, of course I see what you mean but, fortunately for me,
    46        I am not a statistician?
    47        A.  I am not really but I just use numbers quite often in
    48        my job.
    49
    50   Q.   And fortunately for you, you do not work for McDonald's, if 
    51        I may use your pinch of salt --- 
    52        A.  Is that a job offer? 
    53
    54   Q.   -- you may think it is serious.  Do you know enough about
    55        McDonald's to know that a proportion of their workforce,
    56        their part-time workforce and their full-time workforce,
    57        are, for example, students?
    58        A.  Well, I know you are asking me a polite question, so I
    59        will give you a polite answer.  Yes, I do know enough about
    60        them to know that students feature and, indeed, the table

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