Day 303 - 19 Nov 96 - Page 39


     
     1        one of the pink files...  I did put this, I think, to Paul
     2        Preston and to others.  I have two bundle page numbers,
     3        either 11 or 1,744.  It was one of the letters written to
     4        Clive Williams, who was under instruction to reduce labour
     5        costs down or face dismissal as one of many things that he
     6        had to do as a manager.  Basically, that document, 21st
     7        August 1991, sets out for the volume of takings what the
     8        labour target is which they say he must achieve within the
     9        targeted labour guidelines, "which are as follows", and
    10        then it sets out these guideline targets between 14.25 per
    11        cent and 16.5 per cent, depending on the volume of the
    12        store.  The point is that we -- it is volume 15, this
    13        document.
    14
    15   MR. JUSTICE BELL:  Pink 15?
    16
    17   MR. MORRIS:  Yes, volume 15.  In the light of all the evidence
    18        that we have heard in the case, it is quite clear that
    19        there is not one strict, just 15 per cent every store in
    20        the country, but it depends on the volume of takings, but
    21        that the overall effect is that a national figure of 15 per
    22        cent, you know, give or take a decimal point here or there,
    23        are the target targets that are imposed by Head Office on
    24        stores through supervisors and that, you know, if there is
    25        going to be any flexibility it is because of the volume of
    26        sales but the targets are still strict, but they are strict
    27        compared to what your store, what category of financial
    28        turnover your store is in.  Obviously, if it is a big store
    29        or small store it makes a difference.
    30
    31        I think that is it.
    32
    33   MS. STEEL:   I have a few little bits and pieces which I wanted
    34        to mention.  In relation to health and safety, I am not
    35        sure, you know, what of this is going to come up, what
    36        Mr. Rampton is going to be saying at the end of the day, so
    37        I just mention these so you can bear them in mind and
    38        compare them with what Mr. Rampton is saying.
    39
    40        In the video I think it is the management development
    41        programme No. 1, floor control 1989, there was an extract,
    42        which this is obviously designed for training managers, and
    43        it says that 'if you run your crew will run', so obviously
    44        they are trying to encourage managers to run around to get
    45        the crew to run around, which the vast majority of sane
    46        people in the world would consider to be a dangerous
    47        working practice in kitchen environments with hot surfaces
    48        and hot drinks around the place, and I would say that goes
    49        for behind the counter as well because people are serving
    50        hot drinks, including scalding hot coffee, and it is just
    51        generally a dangerous practice to encourage people to run
    52        around.
    53
    54        The other thing is that in the health and safety taskforce
    55        minutes, which were disclosed very late in the day, very
    56        late during the course of the trial, the minutes for 7th
    57        November 1992 on page 1, I think it was, said that original
    58        hygiene and safety advisers were to be introduced in
    59        January 1993, and also that unless health and safety is
    60        talked about in cost terms with hard figures top management

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