Day 133 - 12 Jun 95 - Page 43


     
     1
     2   MS. STEEL:   I wanted to ask you about the New Earnings Survey.
     3        Have you still got that in front of you?
     4
     5   MR. JUSTICE BELL:  The extract, the abstract made from it, G1.
     6        A.  Yes, I have it.
     7
     8   MS. STEEL:  And also G2?
     9        A.  Yes.
    10
    11   Q.   These were prepared by McDonald's, were they?
    12        A.  Yes.  This is typed from something extracted from a
    13        much fuller document, that is G1, and G2 is a prepared by
    14        McDonald's.
    15
    16   Q.   I notice G2 starts on page 5.  What is that part of?
    17        A.  I think it will be a Crew Pay Survey.
    18
    19   Q.   Entirely about crew pay?
    20        A.  I believe so.
    21
    22   Q.   Have you seen it before?
    23        A.  This document?
    24
    25   Q.   Yes.
    26        A.  Yes, I have.
    27
    28   Q.   But you do not remember exactly what it was from?
    29        A.  No.
    30
    31   Q.   What was the purpose of these surveys?
    32        A.  The surveys are done approximately annually in order to
    33        assess how we are doing in terms of pay rates and so on in
    34        the way that you have seen with regard to other employers
    35        and competitors.
    36
    37   Q.   To see whether you are paying low pay compared to the rest
    38        of industry?
    39        A.  To see whether our rates are competitive.
    40
    41   Q.   In G2, the figures for other industry, do you know where
    42        they are from?
    43        A.  Which page?  Do you mean the survey sample pages?
    44
    45   Q.   All the charts starting on page 8 and going onwards from
    46        there.
    47        A.  No, I do not precisely where they are taken from.
    48
    49   Q.   Do you know what year this was compiled?
    50        A.  I think it is 1994, but I am not certain about that. 
    51 
    52   Q.   Do you know whether the whole document might give, because 
    53        we have not got all of it, whether there might be an
    54        explanation elsewhere in this document about where the
    55        figures were from and what period they cover?
    56
    57   MR. RAMPTON:  My Lord, I do believe this is a bit of a waste of
    58        time.  I believe the document says where it comes from on
    59        the second page which is numbered 6.  "The survey is based
    60        upon the remuneration paid to staff in the following

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