Day 060 - 02 Dec 94 - Page 52
1 A. Yes.
2
3 Q. -- in 1991, but that change over only took place in May
4 1991 ---
5 A. Yes.
6
7 Q. -- that if carry-out bags were changed to 100 per cent
8 before May 1991, you would have put that in this document?
9 A. If they had been. I am not certain of the date of this
10 document.
11
12 MR. JUSTICE BELL: Do you know what date it is or what the
13 materials are?
14
15 MS. STEEL: This is giving a picture of the year in total, is
16 it?
17
18 MR. JUSTICE BELL: I mean, one sees there are some -- if one
19 looks at 38, for instance, assuming this is all the same
20 document ---
21
22 MR. MORRIS: It is the same document.
23
24 MR. JUSTICE BELL: -- it talks about 1992 in the past tense in
25 the marginal note.
26
27 MS. STEEL: I think this document was produced in 1993, would
28 that be right?
29 A. I would think so, yes. That was certainly about the
30 time we first produced this document.
31
32 Q. In fact, right at the beginning, the introduction page
33 says: "By the end of 1992 the company had opened 472
34 restaurants"?
35 A. OK, yes.
36
37 Q. Which does indicate that it is likely to be 1993. So,
38 would you agree that this appears to reflect what the
39 situation was at the end of 1991, if anything, the chart?
40 A. It is not specific in terms of when in 1991 they are
41 talking about.
42
43 MR. JUSTICE BELL: No, I think the point which may be made (and
44 is being made against you) is this, that obviously
45 McDonald's is anxious to say that materials it uses are
46 made from a high percentage of recycled material, if that
47 is so. If this document was produced in early 1993, and at
48 any time in 1991 the carry-out bags were 100 per cent
49 recycled material, one might expect McDonald's to put that
50 100 per cent figure in on a chart for "Recycled Material
51 Used in 1991" because at some stage in 1991 the carry-out
52 bags have become 100 per cent; that is the effect of what
53 is being put to you.
54 A. I think that would be misleading, my Lord.
55
56 Q. Right. Why do you say that?
57 A. Because at the end column it says "Total UK saving in
58 kilos". If we claimed a saving relating to 100 per cent
59 recycled carry-out bag, that would have been wrong because
60 it was not 100 per cent for the whole of 1991.
