Day 128 - 24 May 95 - Page 30


     
     1        is ingrained, in terms of team work, from day one with the
     2        crew.
     3
     4   MS. STEEL:   You mentioned about the new definition of "hustle"
     5        being sent out in a memo, in memo format; who was that sent
     6        to?
     7        A.  I cannot remember exactly, but it was Kevin Haag who
     8        was driving that, and I would have thought it would have
     9        gone to all of Operations, the hierarchy and the store
    10        Managers.
    11
    12   Q.   Presumably, they would be expected to put it in their
    13        health and safety file or maybe there was not one at that
    14        stage?
    15        A.  At the time it went out they had not got a file.  It
    16        was part of the reason why we followed it up with articles
    17        in the Company Newsletters, to make sure that crew were
    18        aware as well.
    19
    20   Q.   In the High Levels and Mac News?
    21        A.  Yes, and also when it did go into the Crew Handbook,
    22        every crew member is given an update sheet, so when
    23        changes  are made to the Crew Handbook, those existing crew
    24        members are given a sheet which highlights the changes.
    25
    26   Q.   Would you expect the store Managers to keep those memos on
    27        file so that they can show them to future crew members that
    28        come in, other Managers, Trainee Managers?
    29        A.  They would not have a need to, because that definition
    30        is then incorporated into the other training material we
    31        use, so there is no need for them to keep that memo to show
    32        people.
    33
    34   Q.   So you would just assume they would just throw it away, as
    35        soon as they have read it?
    36        A.  No, I am sure they would keep it on file for a while,
    37        because most stores keep a system for keeping memos on file
    38        for the management team to sign them all off, as well.
    39
    40   Q.   "Sign them all off", I am sorry, what does that mean?
    41        A.  In most restaurants there is a management meeting every
    42        week.  At that management meeting they go through the
    43        memos.  They all initial the memos that they have read
    44        them.
    45
    46   Q.   That is when they arrive, as opposed to before they chuck
    47        them out?
    48        A.  Then they are put on file.
    49
    50   Q.   You, Mr. Tindale and Mr. Haag prepared the definition of 
    51        "hustle"? 
    52        A.  We worked on it together, yes. 
    53
    54   Q.   Were you the only people that discussed it?
    55        A.  No, it was then discussed with the Regional Managers,
    56        all three of them, at their meeting.
    57
    58   Q.   That would have been a meeting that would have been
    59        minuted?
    60        A.  I do not think at that time minutes were taken of

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