for assessing the equipment's capabilities from a quality assurance viewpoint. Maietta set the quality standards for this equipment after observing how the prototype machine operated in the Savannah Tetley installation.
178. In 1986, Maietta participated in confidential discussions concerning the possible construction of a decaffeinated tea plant in the vicinity of Williamsport.
179. When an analytical laboratory was established for the first time in Savannah in the spring of 1988, Maietta, in conjunction with Plant Manager Fred Griffin, interviewed and hired Susan Stacey as Savannah's first on-site quality control analyst.
180. Both before and since his promotion in 1989, Maietta has borne and exercised responsibilities concerning a variety of other quality assurance matters beyond the scope of quality control at the Williamsport facility, including control over the disposition of "obsolete" tea products, acting as liaison with the United States Food and Drug Administration, state and local health agencies and United States Customs authorities whenever issues arise with respect to the integrity of raw leaf tea entering the country, or finished product leaving Tetley's tea facilities; providing to and receiving guidance and direction from Tetley's Corporate legal and Commodities groups with respect to matters of possible product contamination; and the addressing and resolution of other quality assurance issues of corporate-wide impact, ranging from the improvement of vendor compliance with Tetley packaging material specifications, to the proper use of hair restraints on the production line, to the creation of a program to evaluate competitive products, to the reclamation of raw tea otherwise "lost" in the filling and packing process.
I. Tetley's Use of the HAY System
181. Edward Schuler was employed by Tetley from February 1983 to early 1993 as Manager of Compensation and thereafter as Manager of Compensation and Staffing.
182. The HAY system has been used by Tetley at all times relevant to this case as a systemized method of determining salary ranges for salaried employment positions within the company.
183. The main tools in applying the HAY System are three charts, entitled "Know-How," "Problem Solving," and "Accountability" under which different points are assigned for different levels of "Know-How," "Problem Solving," and "Accountability."
184. Schuler utilized the HAY System in calculating the salary range for plaintiff as Quality Control Supervisor.
185. The HAY System is utilized to calculate a pay range for a position, not for the individual in the position.
186. An individual's actual salary within the salary range then is set based upon factors including years of experience.
187. In applying the HAY System, the "Know-How" slot is the most important, not only because it carries the most points, but also because the "Problem Solving" and "Accountability" slots and, therefore, points, are dependent upon the "Know-How" slot.
188. The "Know-How" slot is described by letters or numbers such as "EI3", with the "E" representing the technical depth of a particular position.
189. The Plaintiff's "Know-How" slot was determined by Schuler to be "DI3", indicating that the technical depth of her position was a "D."
190. Referring to the "Know-How" chart, the "D" characterization is as follows:
D. ADVANCED VOCATIONAL
Some specialized (generally non-scientific) skill(s), however acquired, giving additional breadth or depth to a generally single functional element.