1.

- While living in Enfield (attachment 01 post code N18 2XR on payslip)

I started working for ASDA ERITH CDC, Isis Reach, Norman road, Belvedere Kent DA17 6JY (tel. 0208 320
8000) through A1 Personnel on October 17th 2011:
hourly rates varied between £6.08/h and £6.28/h

attachment 01: 1st A1 payslip October 26th 2011

A1 Personnel contact details :

4th Floor
Acorn House
Great Oaks
Basildon SS14 1AH
wrong http://a1onsite.co.uk
a1personnel.co.uk

It was a daily commute of bus train, 2 hours in 2 hours out, but since ASDA ERITH CDC was in need of
Strong, fast, and accurate pickers, they soon started giving more hours than those shown on payslip
attachment 01.

Soon I was often was given around 40 hours per week, but I didn't know if I would have work next day,
or next week: at the end of each shift I was told to whether come back next day or ring to know when would
next day be.

2.- On February 21st 2013 all payslips started coming from another temporary agency named Driving Edge.
All A1 agency workers were transferred from A1 to Driving Edge because A1 and ASDA did not agree upon
contract renewal.

attachment 02: 1st Driving Edge payslip

Driving Edge contact details :

MatthewW@drivingedge.com
Driving Edge Ltd
Unit 13
Matchworks II
Speke Road
Garston, Liverpool L19 2RF
tel. 0151 728 5000

3.- On November 11th 2013 I started part time ASDA permanent contract. Despite initial contract 20 hours /
week only it was really fully time some weeks in excess of 50 hours

attachment 03: letter online referencing self-service with start day with direct contract.

4.- I brought in ASDA ERITH CDC experience with counterbalance and reach, training that I received directly
from Jungheinrich

attachment 04: Jungheinrich training certificate for Reach Truck model

attachment 05: Jungheinrich training certificate for Counterbalance Truck model
attachment 06: Lidl refresher certificate for Reach truck
attachment 07: Lidl refresher certificate for Counterbalance truck

Jungheinrich Birmingham training contact details :

Midlands Sales and Service Office
Units 4 & 5 Holly Park, Holly Lane

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Erdington, Birmingham B24 9PD
Phone: +44-121-2065514

ITTSAR contact details :

4 Milbanke Court
Milbanke Way, Bracknell RG12 1RP
Telephone: 01344 426230
E-mail: kelly@itssar.org.uk
Website: www.itssar.org.uk

The Lidl refresh training was shorter than the Lidl full training I did not receive.
Refresh training enables already skilled workers bringing in core training to operate such vehicles within a
warehouse, at a lower training cost.

Despite such experience on identical counterbalance and reach truck models used at ASDA ERITH CDC,
managers repeatedly refused any training, or refresher on reach or counterbalance equipment in ASDA ERITH
CDC.

The partnership between ASDA ERITH CDC and Jungheinrich is so critical that there's a full time Jungheinrich
engineer based at ASDA ERITH CDC.

Despite my profile, many workers with no previous experience received Jungheinrich reach and
counterbalance training ahead of my early interest and were assigned full time counterbalance roles at ASDA
ERITH CDC while preventing my career development.

5.- Back to February 1999 I had achieved an engineering degree that grants direct membership in the
Institute of Engineering and Technology, member number 36486065.

IET contact:
tel. 01438 765610 or 01438 313 311
accreditation@theiet.org
Michael Faraday House
Six Hills Way, Stevenage SG1 2AY
Website: https://www.theiet.org

attachment 08: Engineering council certificate

attachment 09: IET receipt yearly membership for 2019
attachment 10: NARIC reference letter

IET member 36486065 since graduation in year 1999.

The IET only grants this type of membership to university graduates.

Despite full time picking potatoes carrots and other heavy items day in day out, because of the many career
development opportunities that ASDA would regularly offer in their website on Information Technology roles,
I repeatedly showed my interest on different vacancies, but only 1 application reached destination:

A 6 months clerical support secondment that IT manager Ken Ellis rejected arguing that the 6 months leave
that generated the vacancy had been cancelled because the IT worker had decided not to take such leave.

attachment 11: IT manager Ken Ellis letter with date 03/07/2015

Ken Ellis contact details: ken.ellis@asda.co.uk tel. 01132 152121

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6.- After 7 initial years mainly picking, I never had online access to ASDA Logistics Services ACADEMY website

https://academy.asda.com/login
Despite repeatedly asking for a chance to improve skills through such portal, that had been created by ASDA
Leeds HQ to help all colleagues to develop skills, the access to such portal was withheld from a majority of
hard working employees and arbitrarily granted to a few only.

7.- When ASDA ERITH CDC managers have to train staff in for instance the hybrid pallet truck that I was
trained at the beginning of year 2018, a paper print-out is handed to the trainee but the access to the
academy.com is refused arguing it's for managers only and key colleagues (appointed by managers) only: no
performance selection, no advertising of vacancies before selection, no exams or tests, the chance to develop
skills is bargained to buy loyalty.

8.- this is how me and all other ASDA ERITH CDC workers I know of got permanents job at ASDA ERITH CDC:
the interview was carried out first, among the temporary workers, and then the vacancy was published online,
in the ASDA website, so all we had to do was to fill out the online application when the job was already
assigned to the applicants

attachment 12.1 : letter outcome of magic interview Clive.Irlam@asda.co.uk

9.- I brought in ASDA ERITH CDC previous experience from Lidl warehouse, 2 years full time picking in rack
with earlier version of Jungheinrich ECE-225 (https://www.jungheinrich.co.uk/products/new-forklifts/order-pickers/low-level-
order-pickers/ece-220-225-108308 ) also known as legger, with outstanding performance paletising on chep while
picking.

10.- The farce of the continuous improve groups work

Right after joining ASDA with a full time permanent contract, I was offered to join the continuous
improvement groups in order to improve the productivity of the warehouse, the figure of merit that ASDA calls
OWP: Overall Warehouse Performance.

attachment 12.2: ASDA permanent contract.

attachment 13.1: Manager Allen Notley letter inviting to continuous improvement groups

Such work involved the important charting of the grids inside the ERITH CDC chill rooms, with significant
accuracy improvement.

I used a laser ranger to accurately measure the corners of each block that had been painted on the floor but
no one cared to accurately measure against the existing plant diagram.

attachment 13.2: Plant diagram

attachment 13.3: my work building a scale replica of the grids
attachment 13.4: draft proposal to include weight and distance in pickers performance

Also, during meetings that included the warehouse manager Gavin Town, Shift managers Robin Kelly
(Robin.Kelly@asda.co.uk) and Peter.MacGuigan@asda.co.uk I soon highlighted the importance of applying a
better system in work measurement regarding how hand picking was, and still is currently measured at ASDA
ERITH CDC: just by barely counting boxes put in roller cages.

Such system has the following problems:

 is prone to abuse a few seasoned workers who always get the 'easiest' loads and put the heaviest
orders on others, because picked weight is not taken into account: Basically it's like going to a gym
where the performance is measured just by the repetitions, on any machine, ignoring the weight used.

 It also disregards walked distances, that are capital to control time spent walking around, which is in
turn heavily related to paid wages against hand delivered items to containers.

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My current employer is 24.7 Recruitment, a contractor for DHL at Sainsbury's warehouse in Dartford.
Contact details 24.7 Recruitment. DHL runs logistics for Sainsbury's.

Without getting into too much detail, DHL takes a lot of effort in controlling the above mentioned key
parameters.

That has significantly contributed to a far better logistics chain, that in turn has helped Sainsbury's save to end
up purchasing ASDA: article The Grocer

Where ASDA has been squandering budget and resources by pretending to show interest in controlling such
parameters, but eventually leaving the continuous improvement meetings in the hands of ignorant envious
puppet union GMB lazy stewards who clocked thousands of hours claiming trying to improve the warehouse
performance, but told me and my line of improvement not to continue because it would put too much stress
on the pickers.

I also briefly took part in continuous improvement groups for ASDSA ERITH CDC transport, but again GMB
was exerting a paralysing effect on any change, while blocking 'outsiders' bringing any change that would
significantly improve results.

This was the microscopic symptom of why Walmart ended up selling ASDA, and in the same line why Opel
sold the Vauxhall plant, or more recently, Onda's plant went same way: The business generates money, it
may be even a gold mine, but the fraction of benefits that should and must (for the survival of the business
itself) go to improving the process, it all ends up squandered, eventually chaining the enterprise down to a flat
line of growth, that may end up costing ASDA up to 460 stores, article The Guardian.

In my opinion, as soon as possible, DHL should take over ASDA's transport and logistics network.

11.- I have never had an @asda.co.uk email address or any kind of user/password to be able to use any of
the work computers at ASDA ERITH CDC because I was deemed only useful for picking despite many workers
without any degree, coming straight from foreign countries, some with even really poor command of English
language and really low Maths literacy, would be granted scanning roles for the critical inbound stock control,
and even management positions.

12.- When ASDA brought online the payslips into the portal

https://asda.walmartone.com/
Then suddenly all training tools were available to all ASDA ERITH CDC workers, not just the few who had
been holding such training tools for themselves.

The training tools that ASDA HQ had developed and published in the academy.com site were used as local
loyalty currency by ASDAS ERITH CDC managers.

With the Sainsbury's take-over, at the beginning of 2018 a host of CV development opportunities were
suddenly available to all ASDA ERITH CDC workers interested to improve CV, through the Walmartone online
portal.

Among many, the 5 apprenticeships I mentioned to Peter MacGuigan Peter.MacGuigan@asda.co.uk in email

attach.

Such training was not hidden anymore, now visible through the walmartone site; not just friends and relatives
of ASDA ERITH CDC would be able any more to take unfair advantage and abuse other workers by
withholding training opportunities.

attachment 14 : DVLA D licence application

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13.- With such purpose in mind, to develop CV within ASDA, even offering to fund myself any college training
needed to match any of 5 the ASDA apprenticeships that I considered I would be able to best perform, I sent
the following email to shift manager Peter MacGuigan Peter.MacGuigan@asda.co.uk

attachment 15 : email sent to manager Peter MacGuigan Peter.MacGuigan@asda.co.uk

and HR manager Dawn Holloway Dawn.Holloway@asda.co.uk regarding a long list of
apprenticeships that had suddenly appeared in then my Walmartone online account.

The 5 possible apprenticeships that after careful reading I considered I would be able to successfully complete
were the following ones:

 Digital Solutions Provider, level 6.

 Unified Communications trouble-shooter, level 4.
 Unified Communications technician, level 3.
 Data Analyst level 4 apprenticeship
 44Tn lorry driver. I also have experience with small vehicles delivery, had worked for mobile
telecom
contractors wide range of sites, and a 6 months full time beer monger delivery on 3.5Tn lorry.

14.- Of all these 5 options, with an engineering degree, being for years the top picker at ASDA ERITH CDC,
top picking performance, Lowest Down Time Ever at ASDA ERITH CDC, with a programming language
MATLAB forum top efficiency ranking of 62 (worldwide) https://uk.mathworks.com/matlabcentral/profile/authors/3789925-
john-bg

The only apprenticeship I was considered for was the Lorry driver.

Considering that working for ASDA has benefits like the 10% employee discount card and lorry drivers start at
£14/h so I jumped on the offer. I would be able to study IT while driving lorries.

My apprenticeship application was endorsed by Richard Barnes Richard.Barnes@asda.co.uk , and approved by

morning shift manager Peter MacGuigan Peter.MacGuigan@asda.co.uk and I was admitted to the course to
achieve D D1 driving license on 16th November 2019.

I was being offered to change department and work for ASDA ERITH CDC Transport full time as lorry driver.

Contact details of endorsing managers:

Richard.Barnes@asda.co.uk
Peter.MacGuigan@asda.co.uk
Noel.Boland@asda.co.uk

The ASDA lorry driver apprenticeship has a cost of £8000.- according to the congratulating letter signed by
transport manager Noel Boland accepting my application

attachment 16 : application endorsed by manager Richard Barnes.

attachment 17 : letter accepting apprenticeship program signed by manager Noel Boland.

I attended the initial meeting that the training contractor SP Training held at ASDA ERITH CDC by Ms Wilson
and Ms March Sarah.March@sptraininguk.com

So the only apprenticeship they considered I was suitable for was the lorry driver one, so be it, and I was
really happy to be admitted to such apprenticeship.

15.- On November 25th 2019 I was told to pick in grid PV. Awful supervisor Amanda Aspinal
Amanda.Aspinal@asda.co.uk ordered to pick first the heavy big boxes of juice. Marvis Nikaulos chose to walk
out of the grid, intercept a pallet of small light milkshakes and pick it instead of the heavy boxes that everyone

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else was picking in PV grid. I spoke to other worker in same grid and we agreed that something had to be
done.

On November 25th 2019 I stopped Marvis Nikaulos, a rude pampered kid who hated picking, hated heavy
lifting and didn’t like working in low temperature, or even the kind of teamwork that pickers carry out.

I was told that Marvis Nikaulos had been relocated to ASDA ERITH CDC from ASDA BEDFORD CDC, that
Marvis already had discipline problems there.

Managers Dawn.Holloway@asda.co.uk Germaine.MacDonald@asda.co.uk and Amanda.Aspinal@asda.co.uk

offered Marvis a 2nd chance with his relocation and Marvis was given by these managers MHE and scanning
roles from 1st day he walked in ASDA ERITH CDC, some weeks he wouldn’t pick a single box, hopping
between MHE roles, despite every one has to pick a quota at ASDA ERITH CDC, managers claim.

16.- On November 26th 2019 I was physically assaulted by Marvis Nicaulos on same grid PV: 5 minutes on
CCTV putting up with an arrogant consented petulant rude mouth-foul kid physically engaging and producing
rude verbal comments, attempting to impose his orders despite Marvis never had any kind of supervisory role
BUT every one knew Marvis was the protégée of Dawn.Holloway@asda.co.uk Germaine.McDonald@asda.co.uk
and Amanda.Aspinal@asda.co.uk

I was given copy of the CCTV by Richard Barnes Richard.Barnes@asda.co.uk on faulty DVD, that I returned
asking for a working copy, in writing twice, 2nd straight to HR managers Kiran.Balbajwa@asda.co.uk and
Dawn.Holloway@asda.co.uk

attachment 18 : envelope with Barnes handwriting regarding DVD inside

Despite the CCTV evidence, Marvis Nikaulos convinced 2 new workers that I had taken away the 1Tn pallet of
juice that was picking, that the scanner on duty Christina Patrut had told me to pick, because there was a
correction, and didn’t the risk of an error propagating by allowing Marvis or any of the new workers in PV
doing a picking mistake on that particular pallet.

attachment 19 : witness statement Dil-Raj on 26th November 2019 he was on his 11th
week as ASDA permanent, didn’t even have a 10% discount employee card yet.

attachment 20 : Ben Hubble statement, temporary worker that was offered to speed up
application next permanent job opening if he signed a favourable statement dictated word
by word by Germaine MacDonald, Richard Barnes and Amanda Aspinal.

attachment 21 : additional witness statements, one of the them anonymous that were
attached to the disciplinary notes, AFTER the investigation had been concluded by Richard
Barnes.

17.- I had no chance to interrogate, me or my then GMB Union representative, any of the witnesses.

18.- I asked Richard Barnes to ask scanner Christina Patrut to verify that I held to the 1Tn orange juice pallet
to avoid Marvis Nikaulos taking it because of the fear of careless picking by Marvis Nikaulos propagating errors.

19.- Marvis Nikaulos was wearing a hood, forbidden by Health & Safety regulations, ASDA code of practice,
and common sense, because who risks a counterbalance hit in a really busy noisy warehouse because or
reduced visual span? My answer was an aggressive kid that is not happy in his job and by his aggressive
inquisitive behaviour was probably doing some kind of illegal drug.

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20.- Richard Barnes refused to carry out any drug tests, on any one involved, no test was carried out
neither immediately after the incident nor on the next days. And Mr Nikaulos showed aggressive behaviour
consistent with some kind of substance abuse, just watch the CCTV.

On November 26th 2019 I repeatedly requested drug tests to be carried out right after the incident to Amanda
Aspinal, and during the investigation, but Amanda Aspinal refused to even write it down during investigation,
and Richard Barnes disregarded my request.

attachment 22 : shambolic investigation transcript, faulty photocopies served by Amanda

Aspinal who reduced copy machine contrast to make it even more difficult her deliberate
awful calligraphy

attachment 23 : investigation transcript with corrected photocopies after me asking for a

readable copy.

attachment 24 : my transcript of the marred photocopies that disciplinary Shame Quinlan

shane.quinlan@asda.co.uk refused to read despite I sent it by email 1 week before the
disciplinary hearing.

attachment 23: 3 different dates for the disciplinary hearing, they had me walking upstairs, to be told
that Shane Quinlan was at that time busy doing something really important and that the disciplinary
hearing had to be delayed.

attachment 24 : 3 different dates for the same disciplinary hearing

On January 15th 2019 Shame Quinlan did not carry out a disciplinary hearing where he was supposed to listen
and assess whether I had to be sacked or not, Shame Quinlan droned over a script that had been given to
him and sacked me without any evidence to gross misconduct. According to ASDA rules, gross misconduct has
to do with drug abuse, damage to property, physical assault, .. so having me been the one physically
assaulted by a rude kid probably on drugs, I had to leave my employee card and walk so Marvis Nikaulos
could get a good reference to his next job, probably in another ASDA warehouse.

attachment 25 : decision disciplinary hearing

21.- I sent appeal by email to Gavin.Town@asda.co.uk that bounced back on same 15th January 2019, and
then by conventional post.

attachment 26 : appeal note.

attachment 27 : post office recorded delivery bar code.

submitting attachments 22 to 28 after completion of ET1 application.

22.- I have not yet received a P45 or a payslip telling me how they get to the £2600.- payment.

For all the above explained I ask this tribunal for consideration of the following points:

1.- On 15th January 2019 I still had 128 holiday unspent hours and 72 lieu unspent hours. I need them paid in
full, if any pending.

2.- I also need a clear account of all the worked days from the previous payslip up to January 15th 2019, and
also to have them paid in full, if any pending.

3.- To Dawn Holloway Dawn.Holloway@asda.co.uk : the apprenticeship scheme includes the reimbursement
of D4 form related checks. Dawn Holloway refused to reimburse £25.- out of £80.- arguing that because ASDA

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offers free eye checks to ASDA employees I should have gone to one of those. The person who produced such
petulant answer doesn’t comprehend that perhaps I couldn’t go to an ASDA optician, or as it was the case, I
was not aware of such 100% discount, therefore, I ask for the £25.- optician check. Given the narrow minded
attitude regarding training that some ASDA ERITH CDC had for years, it’s reasonable to consider that they
also kept that discount for themselves, until of course they can cheat a good picker out of an optician test that
took place before Marvis Nikaulos assault.

4.- I would like to keep copy of all the electronic payslips that I stopped receiving when ASDA decided to stop
printing them on paper, and to make them available online only, a portal that I was refused access on same
January 15th 2019 and therefore I could not download copies of the payslips that are in electronic format only.

5.- I ask the tribunal to request ASDA ERITH CDC to surrender the copy of CCTV that is critical to prove I was
the one assaulted, not the other way round, as Marvis Nikaulos managed to decoy with help of Richard Barnes,
Germaine MacDonald, et al.

The independent review of the CCTV by an expert would help defuse the argumentation of some witnesses
that I rammed Marvis Nikaulos with the pump-truck are completely false, are blatant lies, a smoke curtain to
divert the attention away from the fact that Marvis Nikaulos is the one that during 5 minutes on CCTV
physically assaults me including repeated pushing and punching.

6.- In an effort to retrieve the important CCTV in order to have it assessed by an impartial party and supply an
opinion to this tribunal, I asked the London Metropolitan Police to review the CCTV, MPS reference
39014721/19 cms@met.police.uk tel. 0808 168 9291 that assigned PC Jackson 4349SE to the case. ASDA
ERITH CDC was contacted and the CCTV was reviewed, but according to the attached letter 14th February 19
closing the case, I am concerned that ASDA ERITH CDC may have shown different CCTV footage, or argued
decoying off camera events. Also, ASDA neither showed to PC Jackson the contradictory statements dictated
by Richard Barnes and Amanda Aspinal to the conditioned witnesses, nor it was mentioned the absence of
drugs testing, which is concerning given the careless aggressive attitude of Marvis Nikaulos on me, right on
camera.

ASDA spelled ‘Nikaulos’ in investigation and disciplinary paperwork, yet ASDA spelled it ‘Nikolaus’ to the Police.

8 / 8