A. The Defendants, as indicated in the table below, have entrusted the Korea Highway Corporation with the duties of the safety patrol of each branch of the Korea Highway Corporation and performed the said duties under the name of each of the relevant business entities, and the Plaintiffs are workers employed by the Defendants and performed the safety patrol of the expressway in the form of shift work, as indicated in the following table:

The name of the Defendant-affiliated branch business operator (each of the instant Plaintiffs 1, 2, 32, 4-9, 118-1203, 10, 11-11-18, 91-18, 91-2, 95, 22, 6 DV EM 22, 23-6, 67- 72, 33-2, 33-43, 8-8-90, 444, 5-6-5, 97-14, 75-5, 97-16-5, 95-10, 7-2, 7-2, 67-1, 7-62, 7-7, 7-1, 7-6, 7-1, 7-6, 7-6, 97-1, 7-5, 97-5, 97-2, and 7.

B. The Defendants received wages 1) based on the “unit design of the unit wage of the foreign patrolman” designed and distributed to the Defendants in advance by the Korea Highway Corporation, the Defendants calculated and paid monthly wages to their employees. Accordingly, the Plaintiffs received from the Defendants the basic salary and bonus, on-site allowances (risk allowances, transportation expenses, meal expenses, etc.) on the pertinent monthly basis indicated in the table of “amount unpaid” by the Plaintiffs according to attached Forms 3 through 15.

The Defendants calculated the ordinary wage on the sole basis of the “basic wage” in the pertinent monthly wage, and paid each monthly extension allowance and night work allowance as stated in the “former payment” column in the pertinent monthly overtime allowance and night work allowance as stated in the “former payment” column of the said Table, on the basis of the ordinary wage calculated as above, and then calculated the ordinary wage, respectively, and Defendant D Q and DZ paid each of the pertinent monthly holiday work allowances as stated in the “former payment” column of the pertinent monthly night work allowance and holiday work allowance. Defendant Q and DZ paid each of the said monthly holiday work allowances to their respective Plaintiffs on the basis of the ordinary wage calculated only by the said basic wage.