Table of Contents
- 🟦A Complete Record Proving the Institutional Deception of Japan’s Whistleblower Protection Framework Under International Standards
- 🟦 Japan’s Whistleblower Protection System is an Institutional Illusion
- 🟦 Case Overview and Jurisdictional Scope
- 🟦 Causal Map: From Violations → Whistleblowing → Institutional Failure → Retaliation → International Evaluation
- 📂 Complete Archive: Structural Collapse of Japan’s Whistleblower Protection System
- 📚 Evidence Timeline
- 1️⃣ Divergence from International Obligations
- 2️⃣ Actor-Based Records
- 3️⃣ NCP Engagements (Updated with Verified Corporate Evidence)
- 🟦 [Conclusion: Systemic Assessment]
- 🌐 [Global Significance]
- 🧾 Site Author
Summary for NCP Reviewers
This case provides documented evidence of Japan’s systemic failure to meet international whistleblower protection standards. Despite real-name reports of legal violations, all institutional responses failed.
This record, including a structured Specific Instance with 60 pieces of evidence (Evidence No.00–60) and full legal analysis, was submitted to the Japanese National Contact Point (NCP) on September 15, 2025, in accordance with OECD Procedural Guidance, OECD Guidelines for Multinational Enterprises, and UNCAC Article 33.
However, the NCP provided no acknowledgment, no assessment, and no engagement, even after the standard 30-day window required under OECD Procedural Guidance.
This confirms institutional non-performance by the Japanese NCP itself, violating both the OECD Procedural Guidance and Japan’s obligations under UNCAC Article 33 (Protection of Whistleblowers).
Further escalation to the OECD Secretariat and relevant international NCPs is under consideration.
📘Case Target: Infroneer Holdings Corporation (Japan-based multinational)
Key Violations (in breach of OECD Guidelines Ch. II, III, IV, V, and VIII):
- 52 concealed labor accidents
- 3 years of accounting fraud
- Retaliatory dismissal of a real-name whistleblower
Evidence:
- Real-name reports submitted through all available institutional channels
- Police-confirmed whistleblower legitimacy and victim status
- Chronologically structured and fully documented evidence set (Evidence No.00–60), submitted as part of the Specific Instance
This case constitutes a direct violation of international whistleblower protection standards under the OECD Guidelines and Council Recommendations, and is submitted for global review.
🟦A Complete Record Proving the Institutional Deception of Japan’s Whistleblower Protection Framework Under International Standards
Background of the CaseThis case provides documented proof of Japan’s failure to meet international whistleblower protection standards, based on a real incident involving serious misconduct and institutional inaction.
The whistleblower, Mr. Shunsuke Kimura, reported the following violations committed by Infroneer Holdings Corporation and its subsidiary, Maeda Corporation:
- 52 unreported labor accidents
- 3 consecutive years of accounting fraud
- Retaliatory dismissal of the whistleblower
Reports were submitted through all formal and recognized channels:
- Internal company reporting system (Infroneer / Maeda)
- Government agencies: CAA, MHLW, FSA, METI, MLIT
- Financial institution: MUFG
- National broadcaster: NHK
However, none of these institutions provided effective responses in line with OECD or UNCAC obligations, and the whistleblower was ultimately dismissed in retaliation.
This case constitutes non-compliance with the following international instruments:
- UNCAC Article 33 (Protection of whistleblowers)
- OECD Guidelines for Multinational Enterprises (Ch. I, II, IV, V, VIII)
- OECD Council Recommendation on Bribery (2009 revision)
- OECD Good Practice Guidance on Internal Controls, Ethics, and Compliance (2010)
This page and its attached evidence serve as the official record submitted to both the Japanese NCP and the OECD Secretariat, requesting formal evaluation and corrective recommendations in light of structural non-performance.
💡
This is not a personal labor dispute.
→ It is institutional-level evidence that Japan’s whistleblower protection system is structurally non-compliant with international obligations.
Therefore, this record is submitted not only to the Japanese NCP, but also directly to the OECD Secretariat, in response to Japan’s NCP failing to fulfill its procedural obligations under the OECD framework.
🟦 Japan’s Whistleblower Protection System is an Institutional Illusion
This report is grounded in verifiable, time-stamped evidence and is formally structured for submission to international bodies, including the OECD.
Japan has established a whistleblower protection framework that mirrors international standards in form but fails entirely in function.
- Legal provisions appear aligned with global norms but lack enforcement mechanisms.
- Whistleblowers receive no meaningful protection, and retaliation is procedurally ignored or institutionally tolerated.
- Administrative agencies are functionally powerless to enforce corrective measures or provide remedies.
The result is a system that exists on paper but collapses in practice.
📘 This structure violates:
- OECD Guidelines:
- Chapter I-4 (Legal alignment and institutional responsibility)
- Chapter II-2 (Due diligence obligations)
- Chapter VIII-1 (Effective implementation mechanisms)
- UNCAC Article 33: Duty to protect whistleblowers
- UNGP Principles 29 & 31: Access to effective and non-judicial remedy mechanisms
🟦 This is not a case of poor implementation.It is a deliberately constructed institutional design that avoids accountability while simulating compliance.
🟦 Case Overview and Jurisdictional Scope
This page documents the structural deception and hollowing-out of Japan’s whistleblower protection system as of 2025, with the aim of revealing the systemic exclusion of whistleblowers and proving that the system itself is fundamentally dysfunctional under international standards.
The whistleblower, Mr. Shunsuke Kimura, made real-name reports of serious legal violations—including the concealment of workplace accidents, fraudulent accounting, and retaliatory personnel actions.
However, the companies involved—Infroneer Holdings, a multinational corporation, and its subsidiary, Maeda Corporation—initiated no legally required internal investigation, and instead carried out retaliatory dismissal of the whistleblower.
All supporting evidence has been officially submitted to the police, and the whistleblower’s actions have been legally recognized as justified under Japanese law through third-party legal evaluation.
Target Company: Infroneer Holdings CorporationCountry of Incorporation: Japan
Global Operations: Multinational presence including North America and Southeast Asia
- Subsidiary in the United States: MAEDA AMERICA Inc., headquartered in Katy, Texas (est. 2022) 🔗 Official Website – Maeda America Inc.
- Subsidiaries and operational bases in Southeast Asia
- Export activity and investor filings confirmed in Europe
Applicable International Frameworks:
- OECD Guidelines for Multinational Enterprises (Relevant NCPs: Japan / Europe / North America – due to the presence of MAEDA AMERICA Inc.)
- United Nations Guiding Principles on Business and Human Rights (UNGP)
🔗 IR Document: Restricted Stock Compensation (June 24, 2025)
This document explicitly outlines stock-based compensation for executives of subsidiaries and serves as primary evidence of the company’s international governance structure.
🔷 Due to the Japanese NCP’s abdication of institutional responsibility, this case necessarily falls under the scope of multi-jurisdictional review by multiple international NCPs, including those in Europe and North America.The target company is now situated within the framework of international accountability, and escalation to the OECD Secretariat is actively under consideration.
- Europe: The company has officially declared sales activity in EU markets, confirming the existence of local stakeholders and regulatory exposure.
- North America: The company operates through a wholly owned U.S. subsidiary.
Accordingly, this case qualifies for international review not only by the Japanese NCP but also by European and North American NCPs, all of which retain valid jurisdiction under the OECD Guidelines.
🟦 Causal Map: From Violations → Whistleblowing → Institutional Failure → Retaliation → International Evaluation
This matrix illustrates the causal sequence of events, mapping each actor’s behavior to specific breaches of international standards (OECD Guidelines, UNGP, and national obligations).
It makes visible the roles of corporations, state agencies, the media, and financial institutions in the cycle of non-compliance.
🔴 Major Corporate Misconduct | 🟦 Whistleblowing Actions | 🟠 Institutional Failures | 🔴 Retaliation Measures | 🟩 Breach of International Standards |
Concealment of 52 workplace accidents | Company: Infroneer Holdings | Corporate: No investigation initiated; whistleblowing ignored | Dismissal notice issued despite ongoing whistleblower protection obligations | OECD Guidelines Ch. III-1 (Transparency & Effectiveness) violation |
Three consecutive years of accounting fraud | State: CAA, MHLW, etc. | Government: No enforcement despite notice | Dismissal letter explicitly cites whistleblowing as “defamation of corporate reputation” | OECD Guidelines Ch. II-3 / III; UNGP Principle 22 |
Retaliatory HR actions and disciplinary threats | Media: NHK | Media: Failed to investigate despite structured reports | “Objection” formally recorded on resignation documents | OECD Guidelines Ch. I-4: National law removed “effectiveness” requirement |
— | Finance: MUFG | Finance: Discontinued follow-up after initial contact | Not Applicable | OECD Guidelines Ch. II-2 (Due Diligence) violation |
— | Law Enforcement: Evidence submitted | No Response Recorded | Not Applicable | — |
Notes:
- Each column reveals a stage in the systemic collapse of whistleblower protections.
- Emphasis is placed on the failure of multiple sectors (corporate, regulatory, media, and finance) to uphold due diligence, transparency, and protection duties.
- All citations are aligned with OECD Guidelines and the UNGP for direct evaluability by NCPs.
- This matrix also supports multi-stakeholder accountability review under OECD Council Recommendation II.16 & II.20.
📂 Complete Archive: Structural Collapse of Japan’s Whistleblower Protection System
From international legal gaps → to actor-specific institutional failures → to international benchmark violations → culminating in a chronological archive of 60 verified evidence records.
This archive maps the systemic breakdown and institutional retaliation structure across Japan’s corporate, regulatory, media, and financial sectors—structured by timeline, actor, and OECD/UNCAC/UNGP standards.
📚 Evidence Timeline
- All evidence organized by year and month
- Tagged by entity: corporate, government, and media
1️⃣ Divergence from International Obligations
- Under international evaluation, these omissions constitute a violation of binding obligations
- “Effectiveness” (実効性) requirement omitted from national law → fails to meet international compliance standards
- Significant discrepancies between OECD standards and Japan’s domestic legislation
2️⃣ Actor-Based Records
- Corporate Non-Compliance (Infroneer Holdings / Maeda Corporation)
- Administrative Non-Compliance (Consumer Affairs Agency, Ministry of Health, Labour and Welfare, etc.)
- Media Non-Compliance (NHK - Japan Broadcasting Corporation)
- Financial Non-Compliance (Mitsubishi UFJ Financial Group)
3️⃣ NCP Engagements (Updated with Verified Corporate Evidence)
- Japan NCP: Official submission completed in September 2025. No investigation or corrective action taken
- European NCPs: Submission planned, based on confirmed investor activity and product exports.
- United States NCP: Submission is supported by official IR documentation from Infroneer Holdings, confirming the establishment of MAEDA AMERICA Inc., a fully owned U.S. subsidiary with independent operations, thereby fulfilling the OECD Guidelines' requirements for cross-border jurisdiction:
- This case therefore qualifies for cross-border review under the OECD Guidelines, involving both the Japan NCP and North American NCPs, with legal jurisdiction and procedural standing.
🔗 Maeda America Inc. Official Website
🔗 Infroneer Holdings – Subsidiary Establishment IR Notice (2022/05/13)
🟦 [Conclusion: Systemic Assessment]
This case marks the first internationally verifiable documentation of systemic deception embedded within Japan’s whistleblower protection framework—with implications extending beyond national boundaries.
- The company refused to investigate the whistleblower’s claims and instead imposed retaliatory disciplinary actions.
- Government agencies issued corrective notices, but failed to compel any substantive corporate response.
- The police reviewed all submitted evidence and concluded there was no illegality or coercive behavior by the whistleblower.
- Despite avoiding litigation and seeking resolution within institutional channels, the case exposed a framework structurally incapable of protecting whistleblowers.
This represents a direct violation of OECD Guidelines (Chapter I, Art. 4; Chapter II, Art. 2) and the UN Guiding Principles on Business and Human Rights (Principles 29 & 31).
👉 It demonstrates that Japan as a whole is failing to uphold its international obligations to protect whistleblowers.
🌐 [Global Significance]
This site presents a rare and unprecedented record among OECD countries:
- All possible administrative channels were formally used, and
- Every instance of institutional exclusion is systematically documented.
This case thus constitutes the first international verification of structural deception within Japan’s whistleblower protection system.
🧾 Site Author
Shunsuke Kimura
Email: shukku9998@gmail.com
All statements, claims, legal analyses, and documented evidence on this site have been independently researched, structured, and submitted solely by Shunsuke Kimura.
There is no proxy, representative, or collaborator involved.
The full authorship and responsibility belong to the whistleblower himself.
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1️⃣ Divergence from International Obligations
2️⃣ Actor-Based Records – Infroneer Holdings (Multinational Corporation)
2️⃣ Actor-Based Records – Government (State Authorities)
2️⃣ Actor-Based Records – NHK (Public Broadcaster)
2️⃣ Actor-Based Records – MUFG (Mega Bank)3️⃣ Institutional Non-Performance by the Japanese NCP (Sep–Oct 2025)Evidence Timeline MSCI ESG Ratings「AA」MAEDA AMERICA Inc. Establishment