Day 123 - 09 May 95 - Page 21

     
     1        A.  That is correct.  The basic footprint equipment package
     2        would be the same.  The manner in which the restaurant is
     3        operated would vary from place to place depending
     4        upon -----
     5
     6   Q.   Are there any significant differences, do you think,
     7        between the employment conditions in McDonald's own
     8        restaurants and franchisees restaurants, either so far as
     9        pay is concerned, or hours are concerned?
    10        A.  In general there tends to be very little difference.
    11        They are no significant differences.
    12
    13   MR. MORRIS:  The Operations Manual, does that apply to
    14        franchised stores as well as company stores?
    15        A.  Yes, it does.
    16
    17   Q.   There was one question I did want to ask you, which was to
    18        clarify what you said in evidence-in-chief, or in your
    19        evidence before.  You said in 1989 that 44 per cent of crew
    20        members were from what you said were "minorities".  Is that
         ethnic minorities?
    22        A.  It would be female and ethnic minorities.
    23
    24   MR. JUSTICE BELL:  I think the transcript was not clear, but
    25        I think you referred to 46 per cent and at one stage in the
    26        transcript it says 46 per cent are black women and ---
    27        A.  That was not correct.
    28
    29   Q.   -- I did not think that was right.
    30        A.  No, no.  It is women and minorities.
    31
    32   Q.   Together?
    33        A.  My Lord, I am not certain of the exact percentages but
    34        it is around 40 some per cent.
    35
    36   MR. MORRIS:  So, in order just to clarify the situation, in
    37        terms of the percentage of, let us say, for example, you do
    38        ethnic monitoring, do you, in McDonald's stores in the
    39        States to see what the composition -- you must do -- to
    40        find out the composition?
         A.  For our Company stores we do.
    42
    43   Q.   What was the percentage of crew members that you would
    44        describe as black origin, approximately?
    45        A.  I would not know the exact percentage for black, but if
    46        you consider all minorities and women it would be pretty
    47        substantial.  It would be pretty close to 50 per cent.
    48
    49   Q.   I am just trying to separate women out from the picture.
    50 
    51   MR. JUSTICE BELL:  Yes.  Can you separate them out in your own 
    52        mind? 
    53        A.  I do not recall.  I cannot tell you exactly what the
    54        percentage would be.  It would be pretty substantial if you
    55        count Hispanic, Asian and African/American, counting all of
    56        the minority groups, it would be in excess of 37 per cent
    57        easily.
    58
    59   Q.   Some of whom, of course, are women rather than men?
    60        A.  Yes, that is correct, and if you counted all women that