1. Defendant (Counterclaim Plaintiff): (a) the Plaintiff (Counterclaim Defendant) paid KRW 91,392,136 to the Plaintiff (Counterclaim Defendant); and (b) from June 30, 2020 to February 3, 2021.

A principal lawsuit and a counterclaim shall be deemed simultaneously.

1. Basic facts

A. (1) On July 30, 2018, the Plaintiff contracted the construction of a new plant (hereinafter “instant plant”) to the Defendant (hereinafter “instant contract”).

The main contents of the contract are as follows:

1. Public mission: New construction of a factory of 1 parcel, other than chemical C in terms of harmony;

2. The place of construction: C, C, and D in terms of harmony.

3. Details of construction works;

4. Date of commencement: The date on which the completion is scheduled on July 30, 2018: 6,000 won on December 30, 2018 (the supply price of KRW 630,000,000, and the value of KRW 63,000,000);

7. Payment of the price;

(a) Advance payment: 10% of the down payment (the time when advance payment securities and contract performance bonds are issued);

(b. -1 completed portion - Payment in cash of 40% of the down payment after completion of the framework construction: Payment in cash of 40% after completion of the outside board construction - Payment in cash of 14%: Payment in cash of 10% within 14 days after completion of the construction work [Conditions for a construction contract] and the contractor (hereinafter “A”) and the contractor (hereinafter “B”) shall cooperate with each other on an equal footing and faithfully perform the contract in good faith.

Article 12 (Inspection, etc. of Self-inspection) (1) Materials to be used in the Corporation shall be new materials, and quality names, etc. shall coincide with design books.

However, if the quality name, etc. is not clearly specified in the design book, it shall be the most appropriate for the achievement of the purpose of the contract as materials equivalent to the standard product or standard product.

Article 20 (Suspension of Modification of Construction Works) ① A’s modification of the contents of construction work or temporary suspension of construction work for all or part of construction work by this design modification, etc. shall be delivered to “B” in advance.

(2) When “A” does not deliver any document related to the modification of the content of the construction project under the preceding paragraph, “B” shall be notified in writing to “A” about the modification of the content of the construction project that he/she has contracted.