Day 142 - 26 Jun 95 - Page 29

     
     1        A.  I disagree with that totally.  I do not understand what
     2        you are talking about.  You asked me whether or not I have
     3        seen collective bargaining agreements in the catering
     4        industry that is below what we pay.  I am telling you
     5        I have seen them and I have seen them time and time again
     6        and you ought to look at some of the colleagues who you are
     7        talking about.
     8
     9   Q.   If we can go back to the abstract page 37.  Before I deal
    10        with this, those are the average hourly rates that we were
    11        looking at before, were they not?
    12        A.  That is correct.
    13
    14   Q.   Of course, a lot of McDonald's employees, the vast
    15        majority, 80 per cent, are part-time, are they not?
    16        A.  That is correct.
    17
    18   Q.   So they would only be having something averaging about 20
    19        hours a week?
    20        A.  I believe -- our average hours for our crew is about 23
         hours.
    22
    23   Q.   If we look at page 37, paragraph 106 -- I will just read it
    24        out in the pleading, it says:  "In Denmark, a staff
    25        handbook given to McDonald's employees between 1982 and
    26        1990, says that making a statement to a trade union is
    27        grounds for dismissal.  The LLO youth Trade Union picketed
    28        McDonald's first store, McDonald's attempted to suppress
    29        criticism by obtaining a Court order.  The HRF Union took
    30        up the 'banned' themes without action by McDonald's.  In
    31        Autumn 1983, HRF initiated negotiations with McDonald's
    32        lawyer, trying to arrange a collective agreement for staff
    33        similar to a national agreement covering many similar
    34        companies in the catering industry.  This agreement
    35        included guaranteed income, hours of work", presumably,
    36        guaranteed hours of work, "sickness benefit, the right to
    37        notice and overtime rights.  McDonald's pulled out of the
    38        negotiations.  In Spring 1985 McDonald's again refused to
    39        negotiate.  In September 1988, McDonald's broke off year
    40        long negotiations with Unions over staff rights.  A Trade
         Union publicity and boycott campaign, involving blocking of
    42        supplies was launched, with support from Trade Unions in
    43        other countries.  McDonald's tried but failed to ban the
    44        Trade Union boycott stickers.  In May 1989 after two months
    45        of negotiations McDonald's finally accepted the Trade Union
    46        agreement over staff conditions.  After this the Trade
    47        Union protests were called off."
    48
    49        I want you to go to a document which is -- you remember the
    50        one we got out before -- in the Defendants' original list 
    51        of documents.  No. 151? 
    52 
    53   MR. JUSTICE BELL:  It is bundle V, please, of the original
    54        documents.  It will appear as 51 rather than 151, please,
    55        Mr. Stein.
    56
    57   MR. MORRIS:  Do you have this one, yes?  It is a document of the
    58        International Union of Food Workers.  It is dated May 17th
    59        1989.  You may want to note that the second page at the
    60        bottom (and we have a witness from the International Union