Whistleblower Case: Overview and Causal Map

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Table of Contents

🟦 Final Summary for NCP Reviewers (January 2026 Version)
🔷 Japan NCP (Ministry of Foreign Affairs)
🔷 U.S. NCP (U.S. Department of State)
🔷 OECD Secretariat (Investment Division / RBC Team)
🛑 These failures jointly violate:
⚠️ Consequences and Current Escalation Status:
✅ Request for Action (Under Chapter VIII):
🟦 Case Target: Infroneer Holdings Corporation (Japan-based Multinational)
🔷 Key Violations
🔷 Evidence Base
🔷 Procedural Escalation and Institutional Failure
📌 Conclusion
🟦 A Complete Record Proving the Institutional Deception of Japan’s Whistleblower Protection Framework Under International Standards
🔷 Background of the Case
🔷 Channels of Submission
🔷 Applicable International Standards Breached
📌 Submission Status
✅ Request for Action:
🔷 Escalation Justification
🟦 Case Overview and Jurisdictional Scope (Updated January 2026)
🔷Target Company: Infroneer Holdings Corporation (Japan-based multinational)
🔷 Evidence and Legal Submission
🌐 Multinational Presence and Jurisdiction
🔷 Applicable International Frameworks
🔷 Jurisdictional Escalation and Current Status
🟦 Causal Map: From Violations → Whistleblowing → Institutional Failure → Retaliation → International Oversight (2026 Updated Version)
📂 Complete Archive: Structural Collapse of Japan’s Whistleblower Protection System
📚 Evidence Timeline
1️⃣ Divergence from International Obligations
2️⃣ Actor-Based Records
3️⃣ NCP Engagements – Institutional Record and Jurisdictional Validity (as of Jan 2026)
Japan NCP (Ministry of Foreign Affairs)
United States NCP
🌐 OECD Secretariat (Investment Division / RBC Team)
European NCPs (Planned Submissions)
✅ Conclusion
🟦 [Conclusion: Systemic Assessment – 2026 Institutional Update]
🌐 [Global Significance – Verified as of Jan 2026]
🧾 Site Author

🟦 Final Summary for NCP Reviewers (January 2026 Version)

— Updated for OECD Secretariat, NCP Reviewers, and Institutional Observers —

This case documents the first internationally recognized instance of dual institutional non-performance under the OECD Guidelines, involving both the Japanese and U.S. National Contact Points (NCPs).

Despite the submission of a legally and procedurally complete Specific Instance — including 60 verified evidence files (Evidence No.00–60) and legal annexes — neither NCP fulfilled its core procedural mandate.

🔷 Japan NCP (Ministry of Foreign Affairs)

A Specific Instance was formally submitted on September 15, 2025.
The Japan NCP failed to acknowledge or assess the case for over 100 days, breaching the 30-day standard under OECD Procedural Guidance II.C.3.
It issued a formal acknowledgment only on December 25, 2025, after sustained pressure and OECD-level intervention.
This inaction constitutes a verified case of institutional non-performance, in breach of:

OECD Guidelines Ch. I.4 / VIII.1
Procedural Guidance II.C.3
2021 Council Recommendation ¶16 / ¶20

🔷 U.S. NCP (U.S. Department of State)

A parallel submission was filed on October 15, 2025, citing the U.S. subsidiary Maeda America Inc. and cross-border implications.
On December 10, 2025, the U.S. NCP issued a formal response declining jurisdiction, deferring to the Japanese NCP despite Japan's prolonged silence.
This deferral — issued without engagement or assessment — is recorded as constructive non-performance, undermining access to remedy.

🔷 OECD Secretariat (Investment Division / RBC Team)

On December 9–10, 2025, the whistleblower formally escalated the matter to the OECD Secretariat, citing systemic institutional failure across multiple NCPs.
The Secretariat has acknowledged receipt but has not yet initiated an institutional review, despite its duty under:

Procedural Guidance I.C.2 / II.C.3–4
Council Recommendation ¶20 (2021)

As of January 2026, the case remains under monitoring, with further escalation planned if OECD oversight fails to activate.

🛑 These failures jointly violate:

OECD Procedural Guidance II.C.3

(Obligation to assess within a reasonable time frame)

OECD Council Recommendation (2021), Paragraphs 16 & 20

(On institutional accessibility and remedy facilitation)

UNCAC Article 33

(State obligation to ensure effective whistleblower protection)

⚠️ Consequences and Current Escalation Status:

As of January 2026:

The Japanese NCP has been formally recorded as non-performing for over 100 days.
The U.S. NCP’s jurisdictional deferral is documented as a constructive failure to ensure remedy.
The OECD Secretariat has been notified and is expected to launch a formal institutional review.

✅ Request for Action (Under Chapter VIII):

An institutional report under OECD Guidelines Chapter VIII is now formally requested, addressing:

Multi-jurisdictional NCP failure
Whistleblower retaliation and denial of remedy
Restoration of procedural integrity across OECD jurisdictions

This case no longer concerns only corporate misconduct — it now constitutes a test case for the credibility of the OECD grievance framework itself.

🟦 Case Target: Infroneer Holdings Corporation (Japan-based Multinational)

🔷 Key Violations

(in direct breach of OECD Guidelines Ch. II, III, IV, V, and VIII)

52 concealed workplace accidents, including misclassification and suppression of claims(Violation of labor law and safety obligations)
3 consecutive years of accounting fraud, concealing liability and compliance costs(Financial misrepresentation across audited statements)
Retaliatory dismissal of a real-name whistleblower, without internal investigation or remedy(Violation of whistleblower protection standards and procedural fairness)

🔷 Evidence Base

Real-name whistleblower submissions delivered across:

Corporate reporting channels
Government ministries and regulators
Financial and audit-related institutions

Whistleblower status and victim legitimacy officially confirmed by police authorities
60 fully verified evidence files

(Evidence No.00–60)
Structured by timeline, stakeholder, and issue type

Supplemented by 7 legal annexes

(Annex0–7)
Cross-referenced with obligations under:

OECD Guidelines
UNCAC Article 33
Whistleblower Protection Act (Japan, 2022 revision)

🔷 Procedural Escalation and Institutional Failure

The case triggered NCP-level failures in:

Japan NCP: Over 100 days of silence before any acknowledgment
U.S. NCP: Jurisdictional deferral despite procedural violations by Japan

Official escalation made to the OECD Secretariat (Investment Division) on 9–10 December 2025, invoking:

OECD Procedural Guidance I.C.2 / II.C.3–4
2021 Council Recommendation ¶16 & ¶20

📌 Conclusion

This case constitutes a cross-border violation of international whistleblower protection standards.
It is now subject to OECD-wide institutional review due to documented non-performance by multiple NCPs and the systemic denial of remedy mechanisms.

🟦 A Complete Record Proving the Institutional Deception of Japan’s Whistleblower Protection Framework Under International Standards

🔷 Background of the Case

This case provides internationally verifiable documentation of Japan’s systemic failure to meet global whistleblower protection standards, based on a real-name, cross-border incident involving:

Severe corporate misconduct
Prolonged institutional inaction
Documented retaliation against a whistleblower

The whistleblower, Mr. Shunsuke Kimura, submitted structured, real-name reports detailing the following violations committed by Infroneer Holdings Corporation and its subsidiary Maeda Corporation:

52 unreported workplace accidents(in violation of occupational safety laws and reporting obligations)
3 consecutive years of accounting fraud(concealing compliance liabilities from financial statements)
Retaliatory dismissal of the whistleblower(without investigation, despite full evidence and legal validity)

🔷 Channels of Submission

These violations were reported through all major formal and institutional channels, including:

Internal hotlines: Infroneer Holdings / Maeda Corporation
National authorities:

Consumer Affairs Agency (CAA)
Ministry of Health, Labour and Welfare (MHLW)
Financial Services Agency (FSA)
Ministry of Economy, Trade and Industry (METI)
Ministry of Land, Infrastructure, Transport and Tourism (MLIT)

Financial institution: MUFG Bank (audit and compliance function)
Public broadcaster: NHK

Despite these submissions and the police-confirmed legitimacy of the whistleblower, none of these institutions provided timely or effective protection.

The whistleblower was ultimately retaliatorily dismissed, without institutional remedy or acknowledgment of the systemic nature of the violations.

🔷 Applicable International Standards Breached

This systemic failure constitutes a direct breach of multiple international frameworks, including:

UNCAC Article 33(obligation to protect whistleblowers from retaliation)
OECD Guidelines for Multinational Enterprises(Ch. I – IV, V, and VIII – including protections, due diligence, remedy)
OECD Council Recommendation on Bribery (2009 revision)
OECD Good Practice Guidance on Internal Controls, Ethics, and Compliance (2010)

📌 Submission Status

This documentation has been formally submitted as part of:

The Specific Instance filed with the Japanese NCP (Sep 15, 2025)
The official escalation to the OECD Secretariat (Dec 9–10, 2025)

✅ Request for Action:

A formal institutional evaluation of Japan’s procedural and legal compliance
Corrective recommendations under the OECD Guidelines framework

💡 This is not a personal labor dispute.

→ It is institutional-level documentation of a deliberate and systemic failure within Japan’s whistleblower protection framework, under binding international norms.

🔷 Escalation Justification

Following the institutional silence and procedural non-performance by the Japanese NCP and other national authorities, this case has been elevated to the OECD Secretariat (Investment Division / RBC Team).

The case now stands as a formal test of the OECD’s institutional integrity and remedy framework.

🟦 Case Overview and Jurisdictional Scope (Updated January 2026)

This page documents the structural deception and systemic exclusion mechanisms embedded in Japan’s whistleblower protection framework, based on a fully verified case involving a multinational enterprise.

🔷Target Company: Infroneer Holdings Corporation (Japan-based multinational)

The whistleblower case against Infroneer Holdings and its subsidiary Maeda Corporation includes:

52 concealed workplace accidents (labor law violations)
Three consecutive years of accounting fraud (financial misrepresentation)
Retaliatory dismissal of a real-name whistleblower (in violation of UNCAC Article 33 and OECD Guidelines)

Despite formal, structured, and legally grounded reports:

No internal investigation was initiated
Retaliation was escalated, culminating in dismissal
The case was submitted to multiple authorities and institutions, but all failed to act

🔷 Evidence and Legal Submission

All evidence has been:

Submitted to Japanese law enforcement and relevant ministries
Validated by legal counsel under Japanese labor and administrative law
Integrated into a Specific Instance formally filed with the Japanese and U.S. NCPs
Escalated to the OECD Secretariat following dual NCP non-performance

🌐 Multinational Presence and Jurisdiction

✅ Headquarters: Japan

✅ North America:

Maeda America Inc., a wholly owned subsidiary of Infroneer, incorporated in Texas in 2022 🔗 Official Website – Maeda America Inc.

✅ EU Market Presence:

Verified via restricted stock compensation disclosures and confirmed export activity 🔗 IR Reference – Stock Compensation (June 24, 2025)

This governance structure confirms centralized control across jurisdictions, meeting OECD criteria for multi-jurisdictional applicability.

🔷 Applicable International Frameworks

OECD Guidelines for Multinational Enterprises

Chapters I, II, IV, V, and VIII
Applicable NCPs: Japan / U.S. / France / Germany / Netherlands

UNCAC Article 33 – Protection of whistleblowers
UNGP Principles 29–31 – Access to remedy and institutional integrity

🔷 Jurisdictional Escalation and Current Status

Japan NCP: No action for over 100 days; formal acknowledgment occurred only after OECD-level scrutiny (Dec 25, 2025)
U.S. NCP: Deferred jurisdiction (Dec 10, 2025) despite Japan’s documented inaction
OECD Secretariat: Escalation accepted (Dec 9, 2025); institutional review pending
EU NCPs: Submissions planned to France, Germany, and the Netherlands based on verified market ties

This case now qualifies for cross-border institutional evaluation under the OECD framework, involving:
Multiple National Contact Points (NCPs)
The OECD Secretariat (RBC team)
International observers and legal stakeholders

It serves as a documented example of structural breakdown in both corporate and institutional whistleblower protection mechanisms.

🟦 Causal Map: From Violations → Whistleblowing → Institutional Failure → Retaliation → International Oversight (2026 Updated Version)

This matrix outlines the sequence of systemic failures from corporate misconduct to whistleblower retaliation, ending in international escalation. It documents not only the corporate wrongdoing but also multi-sectoral institutional disengagement—now recorded as a matter of OECD-wide concern.

🔴 Corporate Violations	🟦 Whistleblowing Actions	🟠 Institutional Failures	🔴 Retaliation Measures	🟩 Breach of International Standards
Concealment of 52 workplace accidents	Internal + external reporting (Infroneer, Maeda)	No internal investigation initiated; compliance duty ignored	Retaliatory dismissal despite real-name legal status	OECD Ch. III-1, VIII-1; UNGP Principle 22
3 consecutive years of accounting fraud	Regulatory reports (FSA, CAA, METI, MLIT)	No state action despite verified notice	Dismissal letter cites whistleblowing as “defamation”	OECD Ch. II-2, III; UNCAC Art.33
Formal whistleblower reports to NCPs	Japan NCP submission (Sep 15, 2025)	100+ days of silence; accepted only Dec 25, 2025	No protection mechanism initiated during critical window	OECD Procedural Guidance II.C.3; Council Rec ¶16/20
U.S. NCP submission (Oct 2025)	Parallel filing under Maeda America jurisdiction	Jurisdiction rejected on Dec 10, 2025 despite Japan’s known silence	—	Procedural abdication; structural OECD Guidelines breach
Reports to media (NHK) and MUFG	Structured reports on systemic risk	No follow-up despite confirmed receipt	Objection filed upon dismissal (June 2025)	OECD Ch. II-2; Council Rec ¶20
Submission to OECD Secretariat (Dec 2025)	Full escalation with documented dual NCP failure	No formal review initiated as of Jan 2026	—	Procedural Guidance I.C.2, II.C.4; Council Rec ¶20

Each column maps a layer of systemic failure across corporate, state, financial, and multilateral institutions.
The timeline shows how one verified whistleblower was structurally excluded from all protective mechanisms—domestically and internationally.
This table is aligned with OECD Guidelines, UNGP Principles 29–31, and UNCAC Article 33 for institutional assessment.

📂 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

View the explanation page▶️

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

View the explanation page▶️

2️⃣ Actor-Based Records

Corporate Non-Compliance (Infroneer Holdings / Maeda Corporation)

View the explanation page▶️

Administrative Non-Compliance (Consumer Affairs Agency, Ministry of Health, Labour and Welfare, etc.)

View the explanation page▶️

Media Non-Compliance (NHK - Japan Broadcasting Corporation)

View the explanation page▶️

Financial Non-Compliance (Mitsubishi UFJ Financial Group)

View the explanation page▶️

3️⃣ NCP Engagements – Institutional Record and Jurisdictional Validity (as of Jan 2026)

Japan NCP (Ministry of Foreign Affairs)

A Specific Instance was submitted on September 15, 2025, with complete evidence and legal documentation.
However, the Japan NCP provided no acknowledgment, no communication, and no procedural action for over 100 days, missing the October 15 deadline set by OECD Procedural Guidance.
A formal acknowledgment and acceptance was issued only on December 25, 2025, following international escalation and OECD-level scrutiny.
This prolonged inaction constitutes a verified case of institutional non-performance under:

OECD Guidelines Ch. I.4 / VIII.1
Procedural Guidance II.C.3
Council Recommendation ¶16 / ¶20 (2021)

View the explanation page▶️

United States NCP

The U.S. NCP received a parallel submission in October 2025, citing:

Maeda America Inc., a wholly owned U.S. subsidiary of Infroneer Holdings
Cross-border implications of ESG misrepresentation and systemic retaliation

However, the U.S. NCP declined jurisdiction on December 10, 2025, stating:

“Given the geographic location of the company and the lead jurisdictional interest of the Japanese NCP, we deferred the matter...”

This deferral occurred despite Japan’s procedural silence, resulting in a dual non-performance (Japan + U.S.), formally recorded and submitted to the OECD Secretariat.

🔗 Maeda America Inc. Official Website

🔗 Infroneer Holdings – Subsidiary Establishment IR Notice (2022/05/13)

View the explanation page▶️

🌐 OECD Secretariat (Investment Division / RBC Team)

On December 9, 2025, the matter was escalated to the OECD Secretariat as a case of “Institutional Non-Performance” by both NCPs.
While the Secretariat acknowledged receipt, it has not yet initiated an independent review or issued a position on the systemic procedural failures.
As of January 2026, the case remains under international monitoring, and the Secretariat’s institutional responsibility under:

Procedural Guidance I.C.2 / II.C.3–4
2021 Council Recommendation ¶20

is pending clarification.

European NCPs (Planned Submissions)

Based on:

Confirmed product exports by Infroneer subsidiaries (incl. tunnel lining, water facilities, etc.)
Verified investor presence in EU markets

Submissions are under preparation, particularly toward:

France NCP
Germany NCP
Netherlands NCP

These jurisdictions are being considered to ensure cross-border remedy access and independent third-party evaluation.

✅ Conclusion

This case qualifies for cross-border review under the OECD Guidelines, involving:

The Japanese NCP (primary failure to engage)
The U.S. NCP (deferral despite inaction)
The OECD Secretariat (institutional oversight body)

The whistleblower’s standing, documentation, and submission integrity have all been verified and internationally recorded, ensuring full jurisdictional validity for continued escalation across NCPs and OECD bodies.

📌 As of January 2026, this archive serves as an official submission platform for third-party evaluation, including:
OECD Watch
Institutional investors (via ESG channels)
International civil society networks

🟦 [Conclusion: Systemic Assessment – 2026 Institutional Update]

This case constitutes the first cross-border procedural breakdown involving dual National Contact Points (Japan and the United States) and a real-name whistleblower under the OECD Guidelines framework—now fully documented and internationally recognized.

The company, Infroneer Holdings, refused to initiate any internal investigation and instead escalated retaliation, culminating in dismissal.
National authorities, including the Consumer Affairs Agency and MHLW, received formal reports but failed to compel corporate compliance or provide any institutional protection.
Law enforcement confirmed the whistleblower’s status as legitimate, with no evidence of defamation, coercion, or procedural abuse.
Despite seeking resolution exclusively through institutional and legal channels, the whistleblower was met with a framework structurally incapable of protecting disclosures.

This constitutes a verified breach of:

OECD Guidelines: Ch. I-4 (Institutional Responsibility), Ch. II-2 (Due Diligence)
UNGP: Principles 29 & 31 (Access to Remedy)
UNCAC: Article 33 (Protection of Whistleblowers)

👉 This case proves that Japan's whistleblower protection system, while legally codified, is operationally non-functional—a systemic deception now confirmed through cross-border institutional inaction.

🌐 [Global Significance – Verified as of Jan 2026]

This archive presents the first internationally recognized case of whistleblower exclusion and systemic institutional failure across multiple OECD jurisdictions.

All recognized disclosure channels—corporate hotlines, national regulators, financial institutions, and public broadcasters—were formally engaged.
Each stage of exclusion and retaliation was documented in real time, with over 60 timestamped records.
The case was escalated to both the Japanese and U.S. NCPs, and then to the OECD Secretariat, where it remains under procedural review.

🟦 This constitutes the first cross-border institutional failure involving dual NCPs, confirming a structural deception embedded within Japan’s whistleblower protection system.

🧾 Site Author

Shunsuke Kimura

Email: shukku9998@gmail.com

All statements, factual claims, legal analyses, and evidentiary materials presented on this site have been independently compiled, legally substantiated, and formally submitted by Shunsuke Kimura.

There is no proxy, representative, legal counsel, or affiliated organization involved in the authorship or submission process.

🟦 Full authorship and institutional accountability rest solely with the whistleblower himself.

link

📚Evidence Timeline

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–Dec 2025)3️⃣ Institutional Non-Performance by the U.S. NCP (Oct–Dec 2025) MSCI ESG Ratings「AA」MAEDA AMERICA Inc. Establishment