AGREEMENT Regarding Unfair Labour Practice Cases ‘Heisei 10, No. 23’, and ‘Heisei 11, No. 85’, filed at the Osaka Prefectural Labour Relations Commission (together hereafter referred to as ‘the case’), the following has been agreed to and set down in this document of agreement between the plaintiff General Union (hereafter referred to as ‘the union’) and the defendant Nichibei Eigo Gakuin (hereafter referred to as ‘the company’), and both parties agree to execute it in good faith: 1. The company, concerning their behaviour that led the union to file this case for Unfair Labour Practices towards the union and its members, accepts this in good faith, and regrets this, and hereafter will make efforts to ensure that this kind of behaviour will not occur again. 2. Regarding the interested parties “A” and “B” (hereafter referred to as ‘the interested parties’), the company withdraws their dismissals and “A” agrees to quit the company as of May 10th 1998. The company confirms that “B” will return to work at (…) School from April 4th 2001. Regarding “B”‘s return to work – basically 15 hours of lessons over 3 days a week – the details will be worked out in discussions between the company and the union. 3. The company will pay 5,000,000 yen as a settlement fee to the union by March 10th 2001. 4. The union, the interested parties, and the company confirm that there will be no further monetary claims between any of the parties regarding the case, with the exception of the above. 5. The union withdraws the case. 5 March 2001 (Heisei 13) Plaintiff General Union Yamahara Katsuji, Executive Committee Chairman Niwa Masao, Representing Lawyer “A”, “B”, Interested parties Defendant Nichibei Eigo Gakuin Kanehisa Tamotsu, Chief Executive Officer Horii Masafumi, Representing Lawyer Osaka Prefectural Labour Relations Commission Kazahaya Toshio, Commissioner for the investigation Tokuyama Shigetsugu, Commissioner Tanimoto Eiko, Commissioner