Day 303 - 19 Nov 96 - Page 21


     
     1        question, I am sure it would have got radically different
     2        results.
     3
     4        The only other document....  I am just going through
     5        various documents.  I do not think I have more than an hour
     6        and a half, really.
     7
     8        On that Doncaster document, on page K, the third to last
     9        person, the female who worked after 10 o'clock --
    10
    11   MR. JUSTICE BELL:  On the one you handed in, you mean?
    12
    13   MR. MORRIS:  Yes.
    14
    15   MS. STEEL:   Under 18.
    16
    17   MR. MORRIS:  Yes, she was under 18 and worked past 10 o'clock,.
    18
    19   MR. JUSTICE BELL:  Which name?
    20
    21   MR. MORRIS:  It is the third to last, Sarah Langford.  That is
    22        all, just to point that out.
    23
    24        There was a document disclosed by McDonald's - I am not
    25        sure what the reference to it was - but it was the three
    26        pages regarding number employed and crew to management
    27        percentage.  I do not know where it goes.  It was dated
    28        31st December 1988, or two of the pages were dated 31st
    29        December 1988.  I think one of them was said to be 21st
    30        January 1990.  Maybe I ought to hold it up.  I do not know
    31        if you remember these series of documents.  It may not
    32        matter that much because it is so obvious what I am going
    33        to say anyway.  It is a series of documents, crew to
    34        management percentage.  I am not confident that they were
    35        all in the same place but it does not really matter that
    36        much.
    37
    38        I think it was put to Mr. Nicholson, and it is an argument
    39        which I have put anyway, which is that if we take something
    40        like 31,000 staff as of January 1990 -- that may or may not
    41        be the right figure, it does not really matter -- and
    42        according to these charts something like 1,600 of that
    43        staff were salaried, which is about 3 per cent, and
    44        according to that chart about half of them were crew, ex
    45        crew, so ex crew, it leaves us with 1 and a half per cent
    46        of 31,000 staff might hope to end up as salaried.  These
    47        are very rough figures, obviously.
    48
    49        But we have to consider the turnover and at that time the
    50        turnover was something like 180 per cent of whatever, which
    51        means that not 30,000 staff that year were being employed,
    52        but something approaching three or four times as many on
    53        top of it.  Let us have a look.  It would turn over almost
    54        twice.  There would be something like three times as many
    55        staff employed that year, about 85,000 or 90,000 during
    56        that year, because of the turnover rate.
    57
    58        So, realistically speaking, because the salaried staff
    59        turnover is much smaller, it has to be -- well, really much
    60        less, very much less, something like 20 per cent or

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