Day 118 - 01 May 95 - Page 59


     
     1   Q.   "...led me to issue you with a final written warning at the
     2        time and this letter should be taken as confirmation of
     3        this".  So if we look over the page, sorry on, 1744?
     4        A.  Yes.
     5
     6   Q.   We then see these labour percentages based upon the sales
     7        volume of the stores; is that correct?
     8        A.  Yes.
     9
    10   Q.   Are these standard national figures based upon volume and
    11        -- is that the standard position, that these are ---
    12        A.  No I do not know.
    13
    14   Q.  -- at the time.
    15        A.  I do not know.  I have nothing at all to do with this
    16        kind of subject.
    17
    18   Q.   You do not know about labour?
    19        A.  I do not know where they are given the guidelines for
    20        setting their targets.  I have never worked in operations.
    21
    22   MR. JUSTICE BELL:  So you do not know whether those ones are
    23        just set for Mr. Williams in his store or some national or
    24        area?
    25        A.  I would not have thought there was because there are so
    26        many variations up and down the country I would have
    27        thought these were the targets he was set for this store.
    28
    29   MR. MORRIS:  If it had been set for that store it would not
    30        vary, would it, between 60,000 or 110,000?
    31        A.  It could be.
    32
    33   MR. JUSTICE BELL:   Well, I do not know, you see, because I
    34        should imagine to run any store there must be a certain
    35        amount of labour to sustain the place at all and then as
    36        the income comes up I can see it might be expected that the
    37        percentage on labour goes down.  It does not answer your
    38        question as to whether it is a national characteristic or
    39        just what they thought Mr. Williams ought to be able to
    40        hit?
    41        A.  I cannot answer with certainty because I simply do not
    42        know, but I would be most surprised if that was national
    43        because the variations up and down the country are
    44        enormous.  So I would have thought that has been his
    45        monthly -- the goal set for him for his monthly volume.
    46        If his month's volume is between 60 and 70, then his labour
    47        target should be between 60 and a half and 16.
    48
    49   MR. MORRIS:  Would you think that those may be national rule of
    50        thumb guidelines which there may be some leeway depending 
    51        upon individual circumstances at the store, but the Company 
    52        would have some kind of rule of thumb expectations of a 
    53        store on labour?
    54        A.  I think the best person to ask for that (and he is
    55        coming back) is Paul Preston because he actually ran the
    56        operation side at one time.  I cannot think of anybody else
    57        who is coming who would be able to help you with that one.
    58        I really do not know what national guidance is given.
    59
    60   Q.   If we note the first sentence in that paragraph says:

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