Day 133 - 12 Jun 95 - Page 19


     
     1        A.  Yes.
     2
     3   Q.   These are hourly paid workers?
     4        A.  Yes.
     5
     6   Q.   What does the YTD leavers figure represent, the year to
     7        date leavers figure represent?
     8        A.  Well, it will be the number of leavers since the year
     9        began, the total number.
    10
    11   Q.   So that is a sliding figure as well because you counted
    12        from the same quarter, the end of the same quarter, of the
    13        previous year; is that right?
    14        A.  Yes.
    15
    16   Q.   Is it the number of people that left during that time?
    17        A.  Yes -- well, I am not sure I understood the question
    18        actually.
    19
    20   Q.   What is the year to date which gives the total of leavers
    21        as 34,753?
    22        A.  The year runs from the previous, the end of the --
    23        I think I have to say "yes" to your question -- from March
    24        1994, the end of that quarter, March 1994.  It runs from
    25        then.
    26
    27   Q.   So that is a rolling figure as well?
    28        A.  Yes.
    29
    30   Q.   I thought I had understood it.  I just wanted to make
    31        sure.  One calculates the turnover, does one, by seeing
    32        what the difference is between the two, which in that
    33        particular case is 6,121 -- I can tell you that -- and then
    34        working out what percentage of 28,632, 6,121 represents, in
    35        other words, what the excess is as a percentage of the
    36        current rate?
    37        A.  Yes.
    38
    39   Q.   I can tell you that that does actually produce a turnover,
    40        it is 21.38 per cent, therefore, you have a turnover of
    41        121.38 per cent?
    42        A.  Yes.
    43
    44   MR. JUSTICE BELL:  Can I understand then, the YTD leavers are
    45        the number of people who have actually been on the payroll
    46        at any given time during the year so far, are they?
    47        A.  No.  They are the number of people who have left
    48        employment during that time.
    49
    50   Q.   Yes, I understand. 
    51 
    52   MR. RAMPTON:  I think there is no dispute about this, Ms. Mead, 
    53        what these figures do not tell us, of course, is how many
    54        of these YTD leavers that are recorded here have, in fact,
    55        come back to work for the Company?
    56        A.  There will be quite a lot of those because I am sure
    57        you know -----
    58
    59   MR. JUSTICE BELL:  I think what Mr. Rampton is asking, the
    60        names, if you get Joe Brown three times, he counts three

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