Day 068 - 16 Dec 94 - Page 31


     
     1        there is no definition of that?
     2        A.  There are no legal definitions for that.  There are no
     3        ecological foundations that are linked to a particular
     4        country or organisation, such as the United Nations, that
     5        they will agree on that.  It is a term that, as far as
     6        I remember, as far as I understand it, we created in
     7        addition to what is currently accepted as rainforest.
     8
     9   Q.   So what does the company mean by "recent", just roughly, in
    10        terms of years?  Are we talking about six months, or are we
    11        talking about 50 years?
    12        A.  As I mentioned before, it is from the time that we
    13        arrive or could potentially have an impact on any
    14        rainforest in a country.  We do not want to have, and we at
    15        McDonald's do not have to have any impact ecologically on
    16        the rainforest.
    17
    18   MR. MORRIS:   Let me just give you an example, then.  You are
    19        established a country with a large amount rainforest in it.
    20
    21   MR. JUSTICE BELL:  Stick to Costa Rica, as an example.
    22
    23   MR. MORRIS:  All right -- as an example.  Rainforest may still
    24        be being cut down.  Costa Rica is not necessarily the best
    25        example.  Take Brazil, for example; there is a continuous
    26        cutting down of large areas of rainforest in Brazil for
    27        various reasons.  Let us take that as something that will
    28        be proved later on in the case.  You have got a large
    29        operation in Brazil.  So are you saying that under your
    30        term "recent" in Brazil, seeing as you were established
    31        there in, I do not know, 1970 or something, how does your
    32        policy apply to Brazil; are you saying that if it is cut
    33        down -- what does your policy mean in terms of "recent"?
    34        A.  You have asked questions, you have made statements, you
    35        have reached conclusions.  I do not understand your final
    36        question.  I have given an answer.
    37
    38   MR. JUSTICE BELL:  Let us try to start again.  It was a long
    39        question.  If you cannot answer this, please say so,
    40        because I am very conscious of the fact that you did not
    41        join McDonald's until 1991 and you have spoken about when
    42        the first Costa Rican restaurant opened, which is many
    43        years before you were there.  But if you went into a
    44        country now, for the first time, which had rainforest
    45        areas, what would "recently deforested" mean?  Would it
    46        mean:  "We would not buy cattle from areas which have had
    47        rainforest trees chopped down from now on, or in the last
    48        10 years or the last 20 years or the last one year", or is
    49        there no specific definition?
    50        A.  Thank you for clarifying the question.  If we go into a 
    51        country, a new country, that has rainforest, our normal 
    52        practice is to meet with the Minister of Agriculture, fly 
    53        over the area, and he will tell us:  "This is the
    54        rainforest."  Let us say we start on this bench -- if I may
    55        use it as example of a map of a particular country -- we go
    56        on the right, it is considered rainforest by the definition
    57        of "rainforest"; on the left, it is not.  But people are
    58        continuously deforesting areas.  A year from now, and you
    59        can see that in Brazil, that area that is rainforest,
    60        ecologically rainforest, will go a little bit smaller.  So

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