Day 061 - 05 Dec 94 - Page 14

     
     1   Q.   Changing in recycled content, for example?
     2        A.  Not necessarily.
     3
     4   Q.   If the content changes?
     5        A.  No.
     6
     7   Q.   Then that would be something important, would it not, to
     8        note on paper?
     9        A.  If somebody had a conversation or a meeting regarding
    10        the recycled content of the packaging, then it would get
    11        recorded in a letter at that time to Mr. Edwards and at
    12        this time to Perseco.
    13
    14   Q.   Yes, but what I am saying is when McDonald's makes highly
    15        public claims about the recycled content of its paper, it,
    16        presumably, is basing that more on some kind of documented
    17        fact; it is not just dreaming it up or ---
    18        A.  It may have.
    19
    20   Q.   -- taking the word of Mr. Edwards without any documentary
         evidence?
    22        A.  It may have been a visit by Mr. Edwards or Perseco or
    23        on of their quality assurance people to a supplier, and the
    24        result of what happened when they made the visit to the
    25        supplier.  It would not necessarily be something that they
    26        wrote to each other about; it could be the result of a
    27        visit.
    28
    29   MR. JUSTICE BELL:  Might it have been just the result of a
    30        telephone call or something like?
    31        A.  It is possible, although that would normally get
    32        confirmed in writing, if it was a telephone call.  If it is
    33        a visit in person, it does not need to be confirmed because
    34        you are actually there.
    35
    36   MR. MORRIS:  I do not believe you, Mr. Oakley, because these
    37        letters seem to be quite responsible letters identifying
    38        changes and, you know, the changes in the product leading
    39        to changes in the commercial transactions between suppliers
    40        and McDonald's, and I would suggest that is the normal
         practice?
    42        A.  For a price negotiation, that is the normal practice.
    43
    44   Q.   Yes, and recycled content changes will affect the prices,
    45        will they not, because there will be differences?
    46        A.  Not necessarily.
    47
    48   Q.   Not necessarily, but generally?
    49        A.  It depends on the cost of virgin paper at that time.
    50        It depends on manufacturing cost, on labour cost, on 
    51        overhead cost.  Something may have gone up, something may 
    52        have come down, which, so recycled material did not affect 
    53        the cost of the package.
    54
    55   Q.   It is possible, is it not, by some staggering coincidence
    56        that a price change in one part would be exactly identical
    57        to the penny to a price change in other parts?
    58        A.  Oh, no.
    59
    60   Q.   Evening it up?