1. The defendant,

A. The plaintiff A, C, D, E, G, H, N, P, Q, S, V, AA, AB, AC, AD, AE, AE, AF, AH, AI, AJ, and AK.

Basic Facts

The Defendant (formerly, “AM”) was “AM corporation,” and completed the registration of change with its trade name as of June 26, 2015; hereinafter “Defendant, regardless of whether it was before or after the change,” is a company aimed at insurance business, asset management, etc.

The Plaintiffs were those who were employed by the Defendant on each corresponding date in the “Date of Admission” in the attached Form 1’s “Date of Admission”. Among them, the Plaintiffs retired from the Defendant on each corresponding date indicated in the “Date of Withdrawal.”

[Based on recognition] The facts without dispute, Gap evidence Nos. 3 and 7 (including the provisional number; hereinafter the same shall apply), the summary of the argument of the parties concerned in the purport of the whole arguments, which are the part of the defendant's payment to the plaintiffs, constitute ordinary wages, but the family allowances, job allowances, (regular) bonuses, transportation expenses, and clothes expenses (hereinafter referred to as "each of the instant allowances") were paid by the defendant to the plaintiffs. However, the defendant paid annual leave allowances (hereinafter referred to as "annual leave allowances") and overtime allowances (hereinafter referred to as "overtime allowances") calculated by subtracting each of the instant allowances from ordinary wages.

Therefore, each of the instant allowances against the Defendant, including the ordinary wage, seek for the payment of the difference between the annual allowance and overtime allowance from 2014 to 2017, after deducting the annual allowance and overtime allowance already received by the Plaintiffs, and the delay damages.

In addition, the defendant paid the plaintiffs who retired from the defendant the retirement allowance calculated without reflecting the unpaid annual allowance and overtime allowance as above.

Accordingly, Plaintiff B, F, I, J, K, L, M, R, T, U, W, X, and Y seek an amount equivalent to retirement allowance calculated by including the aforementioned excluded annual allowance and overtime allowance in the average wage and its delayed payment from the Defendant.

Defendant is in accordance with the “improvement of wages and systems” under the collective agreement concluded with a trade union on August 7, 2006.