Day 287 - 25 Oct 96 - Page 03

     
     1        their policies or may be breaching their policies, the only
     2        certification that he had any knowledge of whatsoever is
     3        what we have got in this court from Co-op Montecillos,
     4        which is about five letters or something, all of which are
     5        completely ambiguous.  We would say, deliberately
     6        ambiguous, because if that is the certification, then what
     7        they were looking for obviously is a complete
     8        incontrovertible contradiction to allegations that have
     9        been made.  So we would say that the ambiguity of the
    10        letters is not a coincidence but it is a deliberate
    11        avoidance of the facts.  So that is what I say about that.
    12
    13        On day 222, this is the same thing he has dealt with on
    14        page 44 of the transcript.  On page 45 of that day, 222,
    15        after he has talked about those letters and that he is
    16        relying for his information on those suppliers and those
    17        people, he then says about the definition of rainforest
    18        which he has in his corporate policy statement was based
    19        upon the same definition that he gave in court and that is
    20        that he gives to his suppliers what they can and cannot
    21        use.  That is the top of page 45.  So we would say that
    22        offers no protection to 90 percent of the rainforest.
    23
    24        Then in their corporate rainforest policy, on day 225,
    25        pages 29 and 30, he discusses what he meant.  Well, he
    26        gives evidence about what he meant when he made that
    27        policy, about "using only locally produced and processed
    28        beef in every country where we have restaurants".  And then
    29        he basically says on page 30 that he agrees with
    30        hamburgers..." - that is to the UK -"...that because the
    31        bought locally, the ingredients -- or the hamburgers were
    32        locally, whatever -- that the ingredients were -- he said
    33        many ingredients are sourced globally, but they go into
    34        products that are produced locally.  So, therefore, that
    35        did not breach the policy."  Question: "That was what the
    36        policy meant.  Is that what it means to you as well?"
    37        Answer: "Yes".
    38
    39        So he agrees with Mr. Oakley that the policy only relates
    40        to the finished products.  Then he was asked: "So, as far
         as you are concerned, this corporate policy statement is
    42        guidelines?".  And he said: "That is correct".  So that is
    43        further admission, we would say, of the worthlessness and
    44        uselessness of that policy, even if it was carried out,
    45        which we do not believe it is.
    46
    47        There are just a few more references relating to things we
    48        discussed, we talked about, yesterday.  In terms of Dr.
    49        Gonzales, I did mention -- I am not sure if I brought the
    50        references in yesterday.  I am not sure if we are going to 
    51        need Dr. Gonzales. 
    52 
    53   MR. JUSTICE BELL:  I have done that already.
    54
    55   MR. MORRIS:   It must have been a nightmare.
    56
    57   MR. JUSTICE BELL:  I am not going to do it again, save insofar
    58        as something you, Ms. Steel, Mr. Rampton or a question in
    59        my own mind leads me to do so.
    60