The defendant.

A. The Plaintiff (designated parties; hereinafter “Plaintiffs”) and the designated parties (including the Plaintiff, etc.”) are the workers working at the C University operated by the Defendant, and the C Site of the University Trade Union (hereinafter “Labor Union”) are the members.

B. When concluding a collective agreement in 2005 on August 31, 2005, the Defendant and the Trade Union concluded a private school pension agreement with the Plaintiff, etc. on August 31, 2005, the Defendant paid 80% of the individual pension charges retroactively from March 1, 2005. On August 12, 2009, when concluding a collective agreement in 2009, the Defendant paid 100% of the individual charges to the Defendant from March 1, 2010.

(hereinafter “instant collective agreement provision”). Article 51 (Payment of Wages) of the 2005 Organization (Labor) Convention (2) of the 2005 Agreement provides that “The wage increase of members shall be determined through a collective agreement each year along with the kinds of and standards for payment of allowances.” The details of increase in the year 2005 are as follows:

1. Private school pension: 10% of the principal contributions, 90% of the school contributions, and the types of and standards for paying allowances under Article 52 (Allowances) of the collective agreement of the Employee Labor Union of 2010 shall be as follows:

5. A school shall bear 100% of the private school pension.

(As from March 2010)

C. From March 2005 to October 2012, the Defendant paid the individual contributions of the Plaintiff, etc. as school expenses pursuant to the provisions of the instant collective agreement.

On December 7, 2012, the Minister of Education conducted a special audit on the actual status of the Defendant’s payment of the individual contributions and demanded the Defendant to prohibit the payment of the individual contributions and to recover the expenses already paid to the Defendant.

E. Accordingly, deeming the instant collective agreement provisions to be null and void as they are in violation of Article 29(6) of the Private School Act, and thus, the Defendant: (a) divided the individual contributions paid from March 2014 to 60 times without the consent of the Plaintiff, etc.; and (b) as indicated in the “total amount of payment” column of attached Table 2 under the name of “donations” or “amount of collection”, the Defendant, as indicated in the “amount of collection” column, shall be deemed to have been included in the amount of wages