Day 134 - 13 Jun 95 - Page 13
1 managers" at the bottom.
2
3 MR. JUSTICE BELL: Yes. Is that hirings or people actually in
4 post?
5 A. That is people in post.
6
7 Q. That is not necessarily inconsistent, is it?
8
9 MR. MORRIS: No, but it would show that since 1989, from all the
10 information that has been provided since that date, the
11 management, basically, a greater percentage -----
12
13 MR. JUSTICE BELL: Why not put it as a question?
14 (To the witness): What is being suggested to you is
15 although your pie charts show that more management have
16 come from crew than from outside at the date of document B,
17 can you remind me which date that is?
18
19 MS. STEEL: Do we know what date that is?
20
21 MR. JUSTICE BELL: Do you know what date the document is?
22 A. I think, from recollection, and it is cut off, that
23 this will be the document relating to the period in 1992.
24 I cannot say the precise date. It will have been produced
25 in 1993, I think, standing here now.
26
27 Q. So although that purports to show that there are marginally
28 more managers who have originated as crew than have come in
29 from outside, what is being suggested to you is that since
30 1989 anyway more have been coming into management
31 positions, significantly more have been coming into
32 management positions, from outside than from crew?
33 A. Right.
34
35 Q. Do you follow?
36 A. Yes, I do.
37
38 MR. MORRIS: Do you accept that?
39 A. The figures we have looked at show that and there have
40 been many people hired externally. We do hire graduates
41 and so on, yes, and people who have worked in other
42 employment.
43
44 Q. Also on these documents, if we go back to page 700 as one
45 that is easier to read although it has "COPY" all over it,
46 -- mine has anyway -- was this document produced for the
47 purposes of this case?
48 A. Page 700?
49
50 Q. Yes, this series of documents?
51 A. No.
52
53 Q. The details that are on management hires and fires and
54 turnover, would the same kind of details be available for
55 crew turnover, the same information would be available, if
56 you chose to use it?
57 A. I do not believe so, because they are held on two
58 separate systems, so I do not know the answer to that.
59
60 Q. If we leave those documents? Can we just note, if we look
