1. Basic facts

A. A. On April 207, D Co., Ltd. (hereinafter “D”) entered into a contract with the commission agency agreement with the prepaid telecom Co., Ltd. (hereinafter “SK Telecom”), and started the prepaid phone-related business (hereinafter “prephone business”) by being entrusted with the opening of the prepaid phone (hereinafter “prephone”), the sales and charging of pre-paid cards, etc. from the SK Telecom.

D Of the pre-paid business, the scope of the pre-paid opening business is to deal with the opening of the SK Telecom on behalf of the customer, and to receive the opening fees, and the pre-paid sales business is to sell the pre-paid card on behalf of the SK Telecom and to receive the sales commission, and D was the main source of the pre-paid opening business.

B. From December 5, 2005, Defendant A served as the representative director D from around December 5, 2005 to the present date, and he overalled the prepaid phone business from April 2007 to the present.

Defendant

B entered as a member on December 5, 2005, and was promoted to directors on October 1, 201, and was directed and supervised by Defendant A’s instructions from April 2007.

Defendant

C was employed as a staff member of D's opening room around January 2009, and from January 201, through the head of the opening team around January 2012, the C worked as the Vice Minister for Customer Management from January 2014 to January 201, and was in charge of managing the opening room staff and pre-paid project under the direction of Defendant B.

2. Criminal facts;

A. Joint criminal conduct by Defendant A, B, and C

(1) In order to create operating profits and maintain the market share (M/S), the public invitation for the commission of crime requires the agency to achieve the opening performance above a certain level each month, and the agency has been implementing policies that provide differential payment incentives for the promotion of prepaidphones (hereinafter “the opening commission”) depending on the actual opening performance.