1. The Defendant’s payment of unpaid statutory allowances to the Plaintiffs (attached Form 3) is written in total.

1. Basic facts

A. The Plaintiffs, as members of the Korean Union Workers’ Union Federation under the Korean Labor Union Federation (hereinafter “instant trade union”), concluded an employment contract with the Defendant on the date of appointment as indicated below, and retired from office on December 31, 2014, respectively.

On the date of appointment of the Plaintiff, A A 1 on April 1, 1994, December 2 B B B on December 31, 2014, 201, May 1, 2014, 31, 2014; D 4, December 31, 2014, 195 August 8, 2014, 1985, May 1, 2014, E E on December 31, 2014, 31, 2014, December 31, 2014, 31, 1987, F 6, 1987, July 31, 2014; and

Among the collective agreement between the instant trade union and the Defendant in 2012 (hereinafter “instant collective agreement”) and the standards for the payment of wages and retirement allowances for street cleaners in 2012 (hereinafter “instant payment standards”), the main contents related to the instant case are as stated in the relevant provisions (attached Form 2).

C. The Defendant calculated the basic pay, special duty allowance, work encouragement allowance, household subsidy, fixed meal allowance, and transportation subsidy, based on which the Defendant paid the Plaintiffs (attached Form 3) overtime work allowance, holiday work allowance, night work allowance, annual allowance, etc. as stated in the details of unpaid statutory allowances.

[Ground of recognition] Unsatisfy, entry of Gap evidence 1 through 4 (including each number; hereinafter the same shall apply), the purport of the whole pleadings

2. In calculating the ordinary wages of the Plaintiffs pursuant to the instant collective agreement and the instant payment criteria, the Defendant’s summary of the cause of the claim is to calculate the ordinary wages by calculating the basic pay, special work allowance, work encouragement allowance, household subsidy, fixed meal allowance, and transportation subsidy, with the exception of the ordinary wages determined by the Labor Standards Act by nature, and based on the calculation of the ordinary wages, the overtime work allowance, night work allowance, holiday work allowance, and holiday work allowance for 2012.