1. Of the judgment of the court of first instance, the part regarding “a provision of facility convenience” (attached Form 3-7, No. 4, and No. 6) of “a provision of facility convenience” (attached Table 3)

1. The Plaintiff is an industrial trade union whose organization covers workers in metal and metal-related industries.

On June 29, 2010, the Plaintiff entered into a collective agreement with the Korea Voluntary Safety Company (hereinafter “instant company”) and the term of validity from April 1, 2010 to March 31, 2012.

However, the Defendant violated the Trade Union and Labor Relations Adjustment Act (hereinafter “Trade Union Act”) and ordered correction, as stated in each of the provisions in the attached Table of the collective agreement, “the details of the corrective order” in the attached Table of the same Table.

(hereinafter “instant corrective order”). [Grounds for recognition] Gap 1, 2, and 8; the purport of the entire pleadings and arguments

2. Whether the corrective order of this case is lawful

A. Article 1 of the collective agreement provides for one-day negotiating party.

1) The content company of the provision recognizes that a union is the sole labor organization that negotiates wages, conditions of labor, rights to union activities and other matters on behalf of all union members, and does not recognize any other two labor organizations. 2) The Defendant’s ground for disposition violates Articles 5 and 29(1) of the Trade Union Act that guarantees workers’ organization, freedom of joining and right to collective bargaining.

3. According to Articles 5, 29(1) and 29(1) of the Trade Union Act, workers may freely organize or join a trade union, and the representative of a trade union shall have the authority to negotiate with an employer or employers’ association and to conclude a collective agreement for the trade union or union members, thereby guaranteeing workers’ right to organize a trade union and join a trade union and the right to collective bargaining with an employer or employers’ association.

However, the provision on the negotiating party of this case is the only labor organization that only the plaintiff can conduct collective bargaining with the company of this case, and it does not allow other organizations that can conduct collective bargaining with the company of this case.