Day 181 - 01 Nov 95 - Page 33
1 numerically at once? Some might have stayed but -----
2
3 Q. No, let us take a simple number. If you start with a
4 workforce of 100 ---
5 A. Yes.
6
7 Q. -- and your turnover is 100 per cent, it means that you
8 have replaced the whole lot in the course of a year?
9 A. No, not necessarily.
10
11 MR. JUSTICE BELL: It means that 200 people have worked for you
12 that year?
13 A. It could be more than that.
14
15 Q. If it is 100 per cent turnover, it means -- you explain why
16 you think it is more?
17 A. Because it depends on your core and your periphery.
18 Your core staff are your full-time staff, and they tend to
19 stick, and they would have longer service patterns, and
20 then the part-time staff, using your definitions, there may
21 be very, very heavy turnover amongst a few particular job
22 categories.
23
24 Q. But it still means that 100 people have worked for you, 20
25 of them may have been there for 10 years?
26 A. That is right.
27
28 Q. Those 20 may not have changed during the years?
29 A. That is quite possible.
30
31 Q. 20 of the other 80 may have changed four times and 20 of
32 them may have changed once and so on? It is infinitely
33 variable?
34 A. It is.
35
36 MR. RAMPTON: That is rather what I was driving at because you
37 would have to count in people who had left after maybe two
38 years? If they leave in the middle of the calendar year,
39 they have to be replaced, do they not?
40 A. Indeed.
41
42 Q. So they have to be counted into the turnover?
43 A. They do, of course.
44
45 Q. So what I am asking is this: Can you tell, apart from your
46 knowledge and experience of the business or the industry,
47 from looking at turnover figures what sort of length of
48 time the people whom those figures reflect will have served
49 the Company?
50 A. No.
51
52 Q. No, you cannot, can you?
53
54 MS. STEEL: Can I just ask something? On page 30, line 57, it
55 was something that you said: "It still means 100 people
56 have worked for you". It would mean 200, would it not, if
57 you have a workforce of 100 and you have 100 per cent
58 turnover?
59
60 MR. JUSTICE BELL: Yes, I said 200. I said, if you have
