Day 071 - 11 Jan 95 - Page 32


     
     1        the routes which customers take because they do not
     2        necessarily go in a 400 yards radius of the store.  They
     3        follow the Kings Road or they follow the routes south
     4        towards the bridges over the Thames.  In practice, it is a
     5        very, very insignificant number of our customers that would
     6        go north away from the store.
     7
     8   MS. STEEL:   You have worked in two other stores.  Are the
     9        environment/index.html">litter problems with Kings Road unusual?
    10        A.  Every store is different, Kings Road especially in the
    11        west end of London because it is in a residential area.
    12        Leicester Square is in the centre of London and Earls Court
    13        is also in a busy high street and there are residential
    14        areas around there, but we do not -- Earls Court was not
    15        adjacent to these areas.
    16
    17   Q.   So there might be the same amount of environment/index.html">litter being dropped
    18        but you are less likely to get complaints about it?
    19        A.  No.  In those restaurants I found that they had the
    20        same policies and did the trash walks, irrespective of
    21        complaints they would do the trash walks, not to stop
    22        getting complaints but to keep the local area clean.
    23
    24   Q.   In those two stores was that about the same distance that
    25        you went to do the trash walks?
    26        A.  Yes, but also in the Leicester Square branch, there are
    27        four branches in the immediate proximity on the Kings Road
    28        where there is a greater distance with the next branch, so
    29        obviously they would have less of an area to cover because
    30        they would overlap with other restaurants.
    31
    32   Q.   Was the general situation roughly the same, you know,
    33        roughly the same amount of environment/index.html">litter being dropped and the
    34        same amount being picked up?
    35        A.  Well, I could not comment on the measurements.  I do
    36        not know.  I have concentrated on the Chelsea branch.
    37        I was assistant manager there and I am store manager, so
    38        I had different responsibilities as well.
    39
    40   Q.   So you are not aware of the amount of environment/index.html">litter that was
    41        collected at the other stores then?
    42        A.  By volume, no, I could not give you any figures on
    43        that.
    44
    45   Q.   Do you know how often environment/index.html">litter patrols took place at the
    46        other stores?
    47        A.  I would say half hourly.
    48
    49   Q.   Half hourly as well.  Is it standard to just have one
    50        person with a bin bag doing the environment/index.html">litter patrol or with this 
    51        device, picking up device, and a bin bag? 
    52        A.  Well, I have only worked in three restaurants and I do 
    53        not know the policies in the 550 restaurants that we have.
    54        I would probably guess that a majority of restaurants would
    55        use a environment/index.html">litter picker and a bin bag as, effectively, you are
    56        just trying to pick up the rubbish, so that is the most
    57        effective way of doing it.
    58
    59   Q.   In the three that you have been at it has been one person
    60        going out on their own?

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