Day 142 - 26 Jun 95 - Page 26
1
2 MR. MORRIS: Yes. If we are to believe McDonald's claims that
3 workers can increase their wages through performance
4 reviews and bonuses and all that kind of stuff, then the
5 average starting rate must be considerably below what the
6 average general hourly rate is of its staff, must it not?
7 A. I do not agree with that word "considerably". I think
8 we have talked about turnover. There are a variety of
9 factors that come into play here.
10
11 Q. You have said something like people at performance reviews
12 would average something like a 20 cents increase?
13 A. They can qualify for that, yes.
14
15 Q. Are you saying now that in general they do not get 20
16 cents -----
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18 MR. JUSTICE BELL: No, look I want you to put what your case is
19 on this because a lot of the cross-examination in this case
20 has been directed at suggesting that, although they are
21 entitled to get pay rises two or three times a year, they
22 get a pittance when they do.
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24 MR. MORRIS: I would say so, yes.
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26 MR. JUSTICE BELL: Right. Now you are suggesting that the pay
27 rises can be as much as 20 cents in order to establish that
28 the average starting pay is a lot less than the average
29 pay. So I would like you to put a positive case, if you
30 can.
31
32 MR. MORRIS: These average hourly rates for hourly paid staff
33 include people like swing managers, maintenance staff -- I
34 do not know what percentage those -- what percentage of
35 hourly paid staff are above the position of crew?
36 A. There would probably be three, may be four, swing
37 managers; there would be generally one maintenance person
38 -- there could be a second but generally one primary --
39 and then there are crew trainers and crew chiefs that will
40 vary greatly as to how many of those there would be.
41
42 Q. Is swing manager the highest hourly paid?
43 A. Yes, it is.
44
45 MR. JUSTICE BELL: That is our Floor Manager.
46
47 MR. MORRIS: So we can say something like seven or eight staff
48 in a typical store of between 60 and 70 workers will be on
49 higher pay than the average crew person? They are in
50 positions that are -----
51 A. They are in positions that are higher, but there could
52 be -- I do not know how many crew chiefs you would have on
53 average or how many crew trainers you would have on
54 average, I would think it may include another two or three
55 on top of that.
56
57 Q. So maybe something like 10 out of 60 or 70?
58 A. Eight to 10 is probably maximum.
59
60 Q. Which would mean something like 15 per cent of hourly paid
