Day 303 - 19 Nov 96 - Page 21
1 question, I am sure it would have got radically different
2 results.
3
4 The only other document.... I am just going through
5 various documents. I do not think I have more than an hour
6 and a half, really.
7
8 On that Doncaster document, on page K, the third to last
9 person, the female who worked after 10 o'clock --
10
11 MR. JUSTICE BELL: On the one you handed in, you mean?
12
13 MR. MORRIS: Yes.
14
15 MS. STEEL: Under 18.
16
17 MR. MORRIS: Yes, she was under 18 and worked past 10 o'clock,.
18
19 MR. JUSTICE BELL: Which name?
20
21 MR. MORRIS: It is the third to last, Sarah Langford. That is
22 all, just to point that out.
23
24 There was a document disclosed by McDonald's - I am not
25 sure what the reference to it was - but it was the three
26 pages regarding number employed and crew to management
27 percentage. I do not know where it goes. It was dated
28 31st December 1988, or two of the pages were dated 31st
29 December 1988. I think one of them was said to be 21st
30 January 1990. Maybe I ought to hold it up. I do not know
31 if you remember these series of documents. It may not
32 matter that much because it is so obvious what I am going
33 to say anyway. It is a series of documents, crew to
34 management percentage. I am not confident that they were
35 all in the same place but it does not really matter that
36 much.
37
38 I think it was put to Mr. Nicholson, and it is an argument
39 which I have put anyway, which is that if we take something
40 like 31,000 staff as of January 1990 -- that may or may not
41 be the right figure, it does not really matter -- and
42 according to these charts something like 1,600 of that
43 staff were salaried, which is about 3 per cent, and
44 according to that chart about half of them were crew, ex
45 crew, so ex crew, it leaves us with 1 and a half per cent
46 of 31,000 staff might hope to end up as salaried. These
47 are very rough figures, obviously.
48
49 But we have to consider the turnover and at that time the
50 turnover was something like 180 per cent of whatever, which
51 means that not 30,000 staff that year were being employed,
52 but something approaching three or four times as many on
53 top of it. Let us have a look. It would turn over almost
54 twice. There would be something like three times as many
55 staff employed that year, about 85,000 or 90,000 during
56 that year, because of the turnover rate.
57
58 So, realistically speaking, because the salaried staff
59 turnover is much smaller, it has to be -- well, really much
60 less, very much less, something like 20 per cent or
