The judgment of the court below is reversed.

Defendant shall be punished by a fine of KRW 800,000.

The above fine shall not be paid by the defendant.

1. Summary of grounds for appeal;

A. Fact-misunderstanding and legal principles (1) misunderstandings E Housing Redevelopment and Improvement Project Association (hereinafter “instant association”)’s meeting on April 27, 2013, providing its members with rice tea and drinking water, and Defendant’s offering meals at a restaurant on April 18, 2013 does not constitute an act of offering entertainment in relation to the selection of the contractor.

(2) The cancellation agreement with K Construction, written around April 30, 2013, 2014, 1362, as indicated in the lower judgment’s holding, “request to submit details of union funds borrowed and disbursed” as stated in the attached crime List No. 1516, 2014, 2014, 1516, as indicated in the lower judgment’s holding, and “request to take safety measures and cooperate in management as a result of the inspection of dangerous facilities against storm and flood” as stated in paragraph (2) of the aforementioned crime list does not constitute materials to be disclosed to the members, etc.

(3) Nevertheless, the lower court found the Defendant guilty of this part of the charges by misunderstanding the facts and misapprehending the legal doctrine on the violation of the Non-Act on the Improvement of Urban and Residential Environments

B. The punishment sentenced by the lower court against the Defendant (an amount of five million won) is too unreasonable.

2. Determination on the Defendant’s misunderstanding of facts and misapprehension of legal principles

A. Each part of the facts charged (1) No person shall offer, display an intention to offer, or promise to offer money, valuables, entertainment, or other property benefits in connection with the selection of the contractor.

Nevertheless, the Defendant had a temporary office in the second floor of the Eunpyeong-gu F building from around March 2013, and had 50 public relations personnel, who are engaged in publicity activities of the general assembly of the construction of the association. (A) On April 27, 2013, the day when the general assembly of the construction of the association was held on April 27, 2013, while the Defendant mobilized the vehicles from 10:0 am to 2:0 am on the day at the H church located in Eunpyeong-gu on the day of the general assembly of the construction of the association.