1. The Plaintiff (Counterclaim Defendant) paid KRW 871,400,000 to the Defendant (Counterclaim Plaintiff) and against this, from July 21, 2016 to March 28, 2018.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. On September 2, 2015, the Plaintiff entered into a heavy equipment safety insurance contract (hereinafter “instant insurance contract”) with Defendant B Co., Ltd. (hereinafter “Defendant B”).

(1) A contractor: Defendant B: The Defendants’ insurance period:

B. The terms and conditions of the instant insurance contract (hereinafter “instant terms and conditions”) pertaining to the instant case are as follows.

Article 28 (Interpretation of Terms and Conditions) (2) If the meaning of the terms and conditions is not clear, the plaintiff shall interpret it in favor of the contractor.

③ The Plaintiff does not interpret any content unfavorable to or bearing on the contractor or the insured, such as non-compensation loss.

Article 34 (Compensation for Loss) (1) The Plaintiff is liable for damages sustained by an accident that happens during the cover period.

Article 35 (Non-Compensation Damages) (1) The plaintiff shall not compensate for the following losses:

8. Where the subject-matter of insurance is processed (other than repair), the damage resulting from the internal machinery itself or the malfunction thereof; 11. The damage of the machinery which occurred in contravention of any statute or other rule, as provided for in Article 36 (Limits of Payment of Insurance Money, etc.) (1) the damage referred to in Article 34 (Compensation for Loss) (1) shall be calculated by applying mutatis mutandis Article 37 (Calculation of Insurance Money for Payment), and the aggregate amount shall be written in the insurance policy.