Evidence of Garratt Applin

P – Mr Applin you were the branch manager of Personnel Selection in April 1998. You dealt with Euromin Ltd supplying them with casual dock labour. Would you refer to exhibit 6, which gives details of Euromin's business.

GA – Yes.

P – What wages does it say were paid to casuals?

GA - £5 per hour.

P – What charge was made to the Company?

GA - £7 per hour.

P – Who was your contact at Euromin?

GA – Roger Grant.

P – The date on the document is 18 th September 1997?

GA – Yes.

P - It specifies that workers must arrive with a hard hat, high vis. jacket and boots.

GA – Yes.

P – Is exhibit 7 – the recruitment service manual and exhibit 8 a form that shows exactly what is expected of a casual labourer under job title stevedore?

GA – Yes – unloading of ships, person must be aged 18+, have a hard hat, high vis. jacket and boots.

P – On April 24 th three labourers were needed and they were to report to Mick Czaja?

GA – Yes.

P – Exhibit 9 confirms that 3 labourers were requested by Euromin. Do you have written terms of business for your customers?

GA – Yes. It's on the back of another exhibit.

P – Paragraph 7 reads client undertakes to supervise agency workers and ensure reasonable standards of workmanship?

GA – Yes.

P – The workers were engaged by you and deemed to be under the control and direction of the client?

GA – Correct.

P – Do you have a master card showing all the dealings with Euromin form September 1997?

GA – Yes. It's exhibit 10.

P – Did the firm always visit the workplace before supplying labour?

GA – No.

P – Did it never visit the workplace?

GA – Sometimes it did, sometimes it didn't.

P – Did anyone from the firm visit Euromin?

GA – No.

P – Do you have a record of registering Simon Jones? (exhibit 12)

GA – Yes.

P – This was dated March 1995 and included references?

GA – Yes.

P – Are the references checked by Personnel Selection?

GA – Yes.

P – This is exhibit 13 dated 20 th March 1998?

GA – Yes.

P – Did you have a record of checking employment history from an agency in Banbury?

GA – Yes.

P – You checked on Simon's qualities and found them “good”?

GA – Yes.

P – The form was signed by Simon on Monday 20 th April 1998?

GA – Yes.

P – Did he work on the 21 st and 22 nd of April for Lewes District Council refuse collection?

GA – He did.

P – On the 23 rd April he missed the early bus and didn't work?

GA – Correct.

P – On 24 th April between 6 and 6.30 am he phoned to say he had missed the bus?

GA – Yes.

P – He came into the office and was told there was work available at Euromin?

GA – Yes.

P – He was issued with a hard hat and a high vis jacket?

GA – As far as I'm aware.

P – He was put in a taxi at 7.45 am to Euromin.

GA – Yes.

P – How long was the journey?

GA – Within 15 minutes.

 

D – You worked for 17 years in the RAF?

GA – Yes.

D – Your role included flight safety and health and safety?

GA – Yes.

D – You attended courses including health and safety at work?

GA – Yes.

D – You left the RAF in 1996 and did a course with Blue Arrow Recruitment?

GA – Yes.

D – You offered a job as catering consultant at Personnel Selection?

GA – Yes.

D – This offer came from the branch manager?

GA – Yes.

D – You have proceeded to ensure as far as you can that people supplied are adequately trained?

GA – Yes.

D – Euromin contacted you on 18 th September 1997 and R.Grant was recorded as the manager?

GA – Yes.

D – Refer to document GA7, first page of the client master card. This is a record of the occasions that Euromin needed staff?

GA – Yes.

D – On 12 th Dec 1997 it suggests that you contacted Euromin?

GA - Yes.

D – On 14 th April 1998 you spoke to Mick Czaja trying to drum up business?

GA – Yes.

D – On 23 rd April 1998 it refers to a labourer needed for the next day?

GA – Yes.

D – There is another master card for the same date. Why?

GA – One is a revised document.

D – The revised document says that previous dock experience was essential?

GA – Correct.

D – It says other information – unloading fork lift trucks cranes etc. What does this mean?

GA – It means these machines are being used.

D – So you would send someone used to working with cranes?

GA – That's decided according to information received from the client.

D – Simon Jones was assessed and interviewed?

GA – Yes he was.

D – O.K. for working on docks and with bins?

GA – That was assumed from 1995.

D – It was later assessed in 1998 as interested in refuse, dockwork and general labouring?

GA – Correct.

D – Euromin made clear what it wanted in general terms?

GA – Yes.

D – “While every effort is made to ensure conditions ……..etc. No liability can be accepted.

GA – Yes.