Day 117 - 27 Apr 95 - Page 22
1 again in a minute. I want to read to you something that
2 the Defendants allege because I want you to comment on it.
3 This is, my Lord, tab 7 of the Abstract, allegation No. 86
4 on page 30. I do not need you to look at it,
5 Mr. Nicholson, because it is very short.
6
7 MR. JUSTICE BELL: Yes.
8
9 MR. RAMPTON: The Defendants say this in their defence: "The
10 Defendants will also contend that the Plaintiffs put
11 pressure on branch management to keep labour costs below 15
12 per cent of takings, thus resulting in low staffing levels
13 which puts undue pressure on employees to work at speed."
14 As far as you are aware, is that a true or a false
15 statement?
16 A. Totally false.
17
18 Q. If it were true, would you expect to know about it?
19 A. Certainly.
20
21 Q. What is the Company's position on crew cost as a percentage
22 of takings?
23 A. Clearly, it is a commercial interest, so the wage has
24 to be commensurate with the earnings of the store. We do
25 not set anybody targets. The stores themselves budget for
26 their next year and say: "Our crew labour costs will be",
27 whatever they are, store by store. Once they have
28 been agreed, that is their target, but if they do not
29 attain their target, they simply do not attain it.
30
31 It is a fact that the average crew payroll, not crew labour
32 cost, crew payroll, is about 15.5 per cent. It varies year
33 by year. But to get 15.5 per cent, you will have some
34 stores that will be as high as 20 and the very high powered
35 stores, very high sale stores, will be somewhere in the
36 region of 13, perhaps.
37
38 Q. 13?
39 A. Oh, they could be 13 per cent, but the average over the
40 whole of the country is something like about 15.5 per
41 cent. Then you add on to that the holiday pay and payroll
42 taxes, and you come out at somewhere around about 18 per
43 cent.
44
45 Q. If we look at that paper -- my Lord, this is one of the
46 sheets that I handed in yesterday -- it only has a very few
47 lines on it, it is headed: "Store profit and loss". It is
48 dated in the top left-hand corner 12th January 1993. Is
49 this for -----
50
51 MR. JUSTICE BELL: Can you tell me where -- I put them away so
52 I would not lose them and I need the reference.
53
54 MR. RAMPTON: It is behind Mr. Nicholson's first statement.
55
56 MR. JUSTICE BELL: Yes, I have it.
57
58 MR. RAMPTON: It says: "12th January 1993, Store Profit & Loss
59 Report" -- then I am not sure if a line has slipped or
60 whether it is my old eyes -- for 1992/12; what does that
