Day 197 - 07 Dec 95 - Page 52


     
       1      A.  It does.
       2
       3 Q.   Yes, it does.
       4      A.  This would be the same high turnover that the store
       5      had previously, and it had its whole career.  It is not
       6      just a thing that happened when I was a Store Manager.
       7      This store always had a history of high turnover.
       8
       9 Q.   Mr. Coton, the point is this, is it not -- you will tell
      10      me whether it is genuine or not -- what we will see as we
      11      go through these documents, and as you have already seen,
      12      is that Mr. Davis is expressing concern about two things:
      13      Your having too high a turnover and your having too few
      14      staff and too few Managers of the right quality.  He is
      15      continuingly encouraging you to improve in those areas.
      16      Improvement in those areas costs money, does it not?
      17      A.  It does, yes.
      18
      19 Q.   Is what you are telling us that every time we see
      20      Mr. Davis saying one of those things he is, in fact, being
      21      hypocritical and dishonest?
      22      A.  He is not being hypocritical or dishonest, but it
      23      works in two ways.  For example, your labour per cent that
      24      you are judged on is normally your crew labour per cent
      25      which is your hourly paid, so Managers do not really come
      26      into the equation.  If that be the case, OK, in going
      27      through PRs you will be told to watch things like, improve
      28      your crew levels, amongst other things, but why is it that
      29      every morning I would have a phone message asking me why
      30      my labour was so high.
      31
      32      It is, as I said before, two sets of rules, two rule books
      33      being used -- one that is written, one that is unwritten,
      34      and you will find that in every McDonald's in the country.
      35
      36 Q.   You must not readily suppose, Mr. Coton, that it is
      37      accepted on this side of the court that such phone
      38      calls  -----
      39      A.  Do you think you could speak up a little bit?
      40
      41 Q.   Yes, sorry, I was not only not speaking up, I was bending
      42      down.  It is very discourteous -- I apologise.  You must
      43      not readily suppose, Mr. Coton, that it is accepted on
      44      this side of the court that such phone calls were ever
      45      made.  You never mentioned any phone calls like that
      46      before in any of your statements, did you?
      47      A.  I thought that was mentioned at some stage about when
      48      I was asked about how the pressure was exerted.  It was
      49      stated in meetings, in daily meetings, and phone calls.
      50
      51 Q.   No, no, you said it yesterday.
      52      A.  Yes. 
      53
      54 Q.   Page 34, Mr. Coton, under "Special Goals", No. 3,
      55      schedule:  "Ensure crew members are maintained at least up
      56      to" and I think the word is "premium", do you not?
      57      A.  "Up to plan".
      58
      59 Q.   Oh, "up to plan".  I thought it was an abbreviation.  I am
      60      grateful to your Lordship.

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