Day 124 - 10 May 95 - Page 32


     
     1        McDonald's food?
     2        A.  I believe they are one of the laboratories.  I am not
     3        immediately conversant on the use of the lab.
     4
     5   Q.   Do you know anything about them being prosecuted for
     6        falsifying information in the past?
     7        A.  I am not knowledgeable on that.
     8
     9   Q.   You said when you were here before last July that you had
    10        seen statistics on the length of time that employees at
    11        McDonald's work before leaving, not just annual turnover
    12        statistics, but on the length of time of stay of
    13        employees.  I cannot remember whether we asked you to look
    14        into it further or not, but do you know where those
    15        statistics are kept or those reports?
    16        A.  I believe that the only statistics that we would have,
    17        the Company would keep, would be those that would be fairly
    18        current, fairly current being within the last few years.
    19
    20   Q.   That would be the Personnel Department or would it be
    21        Operations?
    22        A.  Human Resources, Personnel, would keep some reports but
    23        again they would be fairly current.  I mean, anything that
    24        would be old, stale would not be useful.  As I indicated in
    25        the past, we do not keep a lot of information around.
    26
    27   Q.   You did not since last July look into those documents
    28        specifically?
    29        A.  I have done no further research on that; I do not
    30        believe you had asked me to.
    31
    32   Q.   I do not think I did ask you on that particular one.  Does
    33        McDonald's monitor environmental matters which their
    34        business might affect?  That was a very badly worded
    35        question.
    36
    37   MR. JUSTICE BELL:  You have to be more precise than that and say
    38        what you mean by "monitor".  Put a particular topic, if it
    39        is important, to Mr. Beavers and say what you mean by
    40        "monitoring".
    41
    42   MR. MORRIS:  Yes.  (To the witness):  For example, if a
    43        particular paper mill was known to be damaging the
    44        environment in a serious way and McDonald's paper was
    45        sourced from there, and it came to the notice of
    46        McDonald's, would that be something which would concern
    47        McDonald's?
    48        A.  Yes, it would.
    49
    50   Q.   What I mean by "monitoring" is does it rely on the chance 
    51        sight by an executive of an article in the newspaper for an 
    52        environmental matter to come to your Company's attention, 
    53        or is there some kind of systematic way of being aware of
    54        problems that may be relevant to your Company?
    55        A.  Our Quality Assurance would extend to those products
    56        and services that would be supplied to McDonald's or would
    57        be in the chain of supply of a product that we would --
    58        that our restaurants would receive.  Beyond that there
    59        would not be any monitoring of environmental matters.
    60

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