The judgment of the court below is reversed.

The sentence of sentence against the defendant shall be suspended.

1. Summary of grounds for appeal;

A. A company operating a mistake of facts or misapprehension of legal principles has already been registered in New Zealand and Canada by satisfying the requirements of the pertinent country, and is not a domestic job placement service for the recruitment of the natives in New Zealand and supplied them to the Republic of Korea. Since there was no need for registration in the Republic of Korea due to the recruitment outline of the office of education of Jeollabuk-do or the question of the pertinent department, there is no room for applying the Employment Security Act, and the Defendant had no intention to violate the Employment Security

B. The lower court’s sentence of unreasonable sentencing (hereinafter “fine 3,00,000”) is too unreasonable.

2. Determination on the grounds for appeal

A. 1) Article 2-2 of the Employment Security Act (Definition of misunderstanding of facts or misunderstanding of legal principles)

2. The term "job placement" means arranging a job offerer and job seeker to enter into an employment contract by searching for job seekers or job offerers or by recruiting job seekers upon receipt of an application for a job offer or job seeking;

4. The term "free job placement services" means job placement services provided without charge, membership fee, or any money or valuables;

5. The term "free job placement services" means job placement services other than free job placement services;

(1) Article 19 of the Employment Security Act shall be classified into domestic and overseas fee-charging job placement services on the basis of the place where a worker subject to introduction intends to work, and a person who intends to conduct domestic or overseas fee-charging job placement services shall register with the Governor of a Special Self-Governing Province or the head of a Si/Gun/Gu having jurisdiction over the location of the principal place of business,

(5) Personal and physical requirements for the registration of fee-charging job placement services under paragraph (1) and other matters concerning fee-charging job placement services shall be prescribed by Presidential Decree.