Day 258 - 07 Jun 96 - Page 11


     
     1
     2   MR. MORRIS:  Yes.  But have we got the additions, that is the
     3        point, because it was not fully disclosed?
     4
     5   MR. JUSTICE BELL:  It is the complete one, I think, anyway the
     6        pages you want.
     7
     8   MR. MORRIS:  It is in my copy.  Here it is, internal page 335
     9        onwards, it should say 'sales and marketing'.  I mean, this
    10        is--
    11
    12   MR. JUSTICE BELL:  It is 322.
    13
    14   MR. MORRIS:  Yes, of the bundle.
    15
    16   MR. JUSTICE BELL:  'Sales and marketing'.
    17
    18   MR. MORRIS:  This is the operations manual that guides.  It has
    19        been described, I think, as the bible for stores and the
    20        company in general; yes?
    21        A.  No, it is the operating manual for restaurants not for
    22        the corporate departments.
    23
    24   Q.   Right.  So, this sets out the corporate philosophy and
    25        rules and guidelines by which stores must basically go?
    26        A.  It sets out corporate guidelines for restaurants within
    27        the US.  European markets frequently pick and choose
    28        sections which they use or do not use.  There are varying
    29        degrees of adherence to the US principle, but this is
    30        primarily aimed -- this is the main operating manual for
    31        the US market.
    32
    33   Q.   This is the one that every store in the UK has?
    34        A.  Yes.
    35
    36   Q.   If we turn to page 636, 'building sales'.  If there is
    37        anything that does not apply to the UK, do stop me.  Shall
    38        I assume it applies to the UK?
    39        A.  Unless I indicate otherwise, yes.
    40
    41   Q.   Because I think it was originally disclosed as the UK
    42        manual.  So, 'building sales'.  'There are three ways a
    43        store can increase its sales, increase the size of the
    44        average cheque, increase the frequency of the visits, bring
    45        in new customers'.  Then there are three ways of increasing
    46        the average cheque through marketing.  This is the average
    47        cheque -- sorry, section.  'Encourage customers to order
    48        more, larger portions, encourage customers to purchase more
    49        than originally considered, increase the size of group
    50        ordering'.  That would be a general guideline for store and 
    51        how to increase-- 
    52        A.  For marketing at a local restaurant level, yes. 
    53
    54   Q.   Right.  To put this in context, the restaurant or the front
    55        line, and your job is to provide an overall context and
    56        strategy by which stores can benefit?
    57        A.  Yes.  I mean, marketing in McDonald's is essentially at
    58        two levels, what we, most marketing people, call above
    59        line, which is television advertising and radio
    60        advertising.  That is the job, and the remit of corporate

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