A. From December 1, 2009, while the Defendant was working as a reporter at the Plaintiff Company, on June 5, 2012, the Defendant filed an application for unfair transfer from the Plaintiff with the Gyeonggi Regional Labor Relations Commission (Seoul District Court Decision 2012Da7666) by asserting that he/she was subject to unfair transfer, and the said procedure for application was in progress on July 27, 2012, a settlement between the Plaintiff and the Defendant (hereinafter “instant protocol”) with the following contents (hereinafter “instant protocol”).

1. The defendant shall withdraw the case without any condition.

2. The Plaintiff shall issue a transfer order to the head of the Plaintiff’s sports head office by December 31, 2012.

3. The Parties shall not raise any objection to civil, criminal and administrative matters in connection with this case (change of position) in the future.

B. On April 26, 2013, the Plaintiff filed an application for commencing rehabilitation procedures with the Incheon District Court on May 31, 2013, and received the decision to commence rehabilitation procedures under the above court 2013hap19. The Plaintiff’s representative director D is deemed a custodian under Article 74(4) of the Debtor Rehabilitation and Bankruptcy Act (hereinafter “Rehabilitation Act”). The Plaintiff’s representative director D was registered on June 5, 2013.

C. On July 15, 2013, the Defendant filed an application with the Plaintiff for indirect compulsory performance against the Plaintiff on the ground that the Plaintiff did not perform the duty of assignment order as stipulated in the instant protocol of conciliation. On October 10, 2013, the said court rendered a decision as follows (hereinafter “instant indirect compulsory performance order”), and the said decision became final and conclusive on October 24, 2013.

1. The plaintiff must, within 21 days from the date of receipt of the decision of this case, issue a transfer order to the position of the head of the sports department of the plaintiff.

2. In a case where the Plaintiff did not perform the obligation under paragraph (1), the Plaintiff shall pay to the Defendant KRW 200,000 per day from the Do of the period specified in paragraph (1) to the completion of the performance.

On October 17, 2013, the Plaintiff held a personnel committee and issued a transfer order to the head of the Gyeonggi Editorial Office on the 21st of the same month, and then held the head of the Gyeonggi Editorial Office on the 28th of the same month.