Day 196 - 06 Dec 95 - Page 09


     
     1        to get within set targets."   That was pressure from, all
     2        those were pressure from above?
     3        A.  From anyone in a position above you, yes.
     4
     5   Q.   "2.3 Question - Please state (a) what items you were told
     6        to 'water down'; (b) who gave that instruction; (c) how
     7        often it what given; (d) whether it was obeyed, if so (e)
     8        what steps were taken to put it into practice.  Answer: (a)
     9        You were told to water down shake mix, colas and double
    10        brew the coffee.  (b) Instruction given by Mark Davis and
    11        Frank Stanton.  (c) How often was it given?  1985 to
    12        1989ish.  By 1990 it had been stopped, but I was still
    13        expected to achieve impossible food costs targets."
    14
    15        I just want to clarify one thing there. When you said you
    16        left in 1991, you had originally put 1990, does this affect
    17        any of the timings?
    18        A.  Yes, the practices would have been stopped around about
    19        the beginning of 1991.  That is a year out on here.
    20
    21   Q.   So it should be by 1991?
    22        A.  Yes.
    23
    24   Q.   Is that because you calculated it back from when you left,
    25        when you gave the original figures?
    26        A.  Yes.  I miscalculated.
    27
    28   Q.   "Question: Whether the instructions were obeyed.  Answer:
    29        Yes.  What steps were taken to put it into practice?
    30        Answer: Done semi-openly.  I saw Mark Davis do it."   What
    31        position was Mark Davies when you saw him do that?
    32        A.  He would have been Store Manager.
    33
    34   Q.   That was doing what?
    35        A.  That would have been 1985 onwards.
    36
    37   Q.   No, I mean what was he doing?
    38        A.  It would have been either watering down the mix or the
    39        colas or being present while it was carried out.
    40
    41   Q.   "We were also told (and we did) to reduce the size of
    42        cheese portions, lettuce and all condiments and sauces,
    43        (this was done by Mark Davis and Frank Stanton)."   Was
    44        that the orders to do that or the actual doing it
    45        themselves?
    46        A.  The actual order I believe came from Frank Stanton
    47        through Mark Davis and then was actioned in the stores.
    48
    49   Q.   Are you saying they actually did that themselves or what?
    50        A.  I cannot say whether they actually did it themselves, 
    51        but I know they actually instructed it to be done. 
    52 
    53   Q.   "(3) Hours Worked.  3.1 - Please give the names of all the
    54        people you can remember who were not paid for all the hours
    55        they worked 'with two hours being docked off their time and
    56        clock cards being altered'.  Answer: I was taught this as
    57        an Assistant Manager by Mark Davies and monitored by
    58        him."   You did not give any names there.  Can you just
    59        explain the reason why not?
    60        A.  At these times the way the actual payroll was done, the

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