Evidence Timeline

🟦 INFRONEER Holdings Inc.

Report No. 0 – Falsified Accounts and Labor Disaster Cover-Up

On March 16, 2025, Shunsuke Kimura submitted a formal real-name whistleblower report to Infroneer Holdings via its official inquiry system, exposing serious misconduct by its subsidiary, Maeda Corporation. The report cited previous filings with five Japanese government agencies and warned that escalation to criminal authorities would follow if no substantive response was received by April 14, 2025. Key allegations included falsified labor cost reporting, systematic concealment of work-related accidents, and misleading audit disclosures. Supporting evidence was submitted to both administrative bodies and the police.

🟦 INFRONEER Holdings Inc.

Report No. 1 – Oversight Failure by Parent Company

This whistleblower report, submitted on April 13, 2025, accuses Infroneer Holdings of failing to fulfill its supervisory obligations as the parent company by ignoring the March 16 real-name disclosure. No investigation notices, interviews, or corrective actions were provided. This failure constitutes a breach of Japan’s Whistleblower Protection Act (Article 11) and raises governance concerns under the OECD Guidelines and UNCAC Article 33.

🟦 INFRONEER Holdings Inc.

Report No. 2 – Ineffective Whistleblower Framework

The third report states that Infroneer Holdings’ internal whistleblowing system, while formally in place, is functionally non-operational. Since March 16, 2025, multiple serious disclosures—including those on industrial accident concealment and accounting fraud—have been ignored without investigation or follow-up. This systemic inaction likely violates Article 11 of Japan’s Whistleblower Protection Act and OECD standards for effective due diligence.

🟦 INFRONEER Holdings Inc.

Report No. 3 – Audit Breakdown and Accounting Misstatements

This third report highlights that from FY2022 to FY2024, Maeda Corporation failed to account for industrial accident costs and whistleblower-related expenditures in its financial reports. The responsible audit firm did not require any corrections. These omissions suggest a collapse of audit oversight and internal controls, in breach of Japan’s Financial Instruments and Exchange Act and the OECD Guidelines (Chapters III and V).

🟦 INFRONEER Holdings Inc.

Report No. 4 – Structural Suppression of Labor Accident Reports

The fifth report reveals systematic obstruction and falsification of industrial accident records at Maeda Corporation’s Kansai Branch since October 2022. Supervisors discouraged claims, gave misleading explanations, and altered reports. By the end of FY2024, 52 cases remained unreported. These practices indicate institutionalized concealment and constitute serious violations of Japan’s labor laws, Whistleblower Protection Act, OECD Guidelines (Chapters II & IV), and UNCAC Article 33.

🟦 INFRONEER Holdings Inc.

Report No. 5 – False Financial Reporting and Control Gaps

This whistleblower report alleges that Maeda Corporation falsified its financial reports for three consecutive fiscal years (FY2022–2024) by omitting industrial accident costs, whistleblower-related expenses, and system-related corrective measures. Audit firms also failed to reflect these irregularities in their reviews. These omissions raise serious concerns of accounting fraud, undermining accountability to investors, shareholders, and regulators, in violation of Japan’s Financial Instruments and Exchange Act and the OECD Guidelines (Chapters II & III).

🟦 INFRONEER Holdings Inc.

Report No. 6 – Internal Denial and Retaliatory Threats

This report documents that after Mr. Kimura submitted internal whistleblower disclosures concerning accident concealment and compliance violations, Maeda Corporation created an internal record suggesting possible disciplinary measures. Although no punishment was ultimately imposed, the act of documenting potential retaliation significantly undermines the credibility and trustworthiness of the internal reporting system—violating the Whistleblower Protection Act and the OECD Guidelines (Chapters II, III, IV).

🟦 INFRONEER Holdings Inc.

Report No. 7 – Structural Compensation Model Proposal

This report identifies systemic deficiencies across Infroneer Holdings and Maeda Corporation from 2022 to 2025, including 52 unreported industrial accidents, three consecutive years of improper financial reporting, retaliatory posturing against whistleblowers, and non-functional internal reporting systems. It calls for group-wide reforms and proposes a symbolic structural compensation model (JPY 5–9 billion (approx. USD 33–60 million)) to account for the cost of reconstructing the whistleblower system. The case highlights broad violations of the OECD Guidelines (Chapters II, III, IV, V, VI) and UNCAC Article 33, underscoring both governance failure and the urgent need for institutional remediation.

🟦 INFRONEER Holdings Inc.

Report No. 8 – Institutional Rejection of the Reporting System

The whistleblower system at Maeda Road, a wholly owned subsidiary of Infroneer Holdings, is non-functional in practice. This failure reflects a group-wide lack of compliance with the OECD Guidelines concerning effective grievance and reporting mechanisms.

🟦 INFRONEER Holdings Inc.

Systemic Whistleblower Rejection – Confirmation of Denial

Infroneer Holdings, the parent company, formally rejected all whistleblower reports—labeling them as “system abuse” based on an alleged demand for monetary compensation. Despite receiving eight detailed disclosures, the company failed to initiate any internal investigations. This constitutes a direct breach of its legal and ethical duty to maintain a functioning internal reporting system under the Whistleblower Protection Act and the OECD Guidelines.

🟦 INFRONEER Holdings Inc.

Unjustified Dismissal of Whistleblower – After Institutional Silence

This document is a dismissal notice issued to whistleblower Shunsuke Kimura by Maeda Corporation on April 23, 2025. It references internal rule violations without providing specific details and states that a separate document will explain the reasons. The structure suggests post-hoc justification and a lack of procedural transparency.

🟦 INFRONEER Holdings Inc.

Dismissal Clarification Request – Demanding Specific Grounds

This email, sent by Shunsuke Kimura on April 24, 2025, formally requests clarification from Maeda Corporation regarding the grounds for his dismissal. It questions the specific conduct cited, the timing and context of the alleged infractions, the absence of any prior hearing, and the connection between the dismissal and his ongoing medical leave. The original dismissal notice (Evidence No.10) was attached for reference.

🟦 INFRONEER Holdings Inc.

Retaliatory Dismissal – Executed After Legal Reports

The dismissal reason letter cites whistleblowing itself (reporting to authorities and the alleged “JPY 20 billion (around USD 133–138 million)” demand) as justification for termination. It also mixes unrelated internal issues as post-facto reasoning. The separation of the notice and reasoning documents further reflects a lack of transparency and due process. These practices amount to a clear case of retaliatory dismissal, violating the OECD Guidelines and UNCAC Article 33.

🟦 INFRONEER Holdings Inc.

Retaliatory Dismissal – Objection to Employer’s Reason

This document formally records Shunsuke Kimura’s objection to the stated reason for dismissal in the official separation certificate. The reason given — “damaging the company’s reputation by reporting to external authorities” — explicitly ties the termination to his whistleblowing activities. The dismissal occurred immediately after a corrective notice was issued by the Consumer Affairs Agency, reinforcing the conclusion that this was an act of retaliation and systemic suppression of whistleblowing.

🟩 Consumer Affairs Agency

Initial CAA Response – Limitations on Whistleblower Protection

The Consumer Affairs Agency (CAA) informed the whistleblower that, under Article 11 of Japan’s Whistleblower Protection Act, its mandate is strictly limited to confirming the formal existence of an internal whistleblowing system within a company. The agency explicitly stated that it does not have the legal authority to investigate individual cases of retaliation or misconduct.

🟩 Consumer Affairs Agency

Whistleblower’s Consent – Agreement Despite Exposure Risk

Despite being warned of the potential risk of identification and adverse treatment by the company, the whistleblower explicitly consented to allow the CAA to contact the company. This decision was made in order to facilitate an institutional-level review of the internal whistleblowing structure, even under limited procedural conditions.

🟩 Consumer Affairs Agency

CAA Confirmation – Acceptance of Consent Without Protective Action

The CAA formally acknowledged receipt of the whistleblower’s consent and proceeded with contacting the company, in line with its limited jurisdiction under domestic law.

🟩 Consumer Affairs Agency

CAA Limitation – No Authority to Investigate Real-World Practice

The agency later reiterated that its role is limited to verifying the presence of a whistleblowing mechanism and does not extend to evaluating the actual operation, fairness, or effectiveness of such systems. This clarification underlined the narrow procedural focus of Japan’s administrative approach.

🟩 Consumer Affairs Agency

Formal Acknowledgment – Request for Oversight Due to Compliance Collapse

In response, the whistleblower acknowledged the agency’s position but emphasized that the case illustrates a structural and systemic failure. Specifically, the whistleblower asserted that the mere existence of a compliance system—without any ability to intervene in retaliatory actions or ensure real protection—represents a violation of both domestic legal obligations and the OECD Guidelines for Multinational Enterprises.

🟩 Consumer Affairs Agency

Supplementary Submission – Notifying of Ongoing Retaliation

The whistleblower submitted a consolidated record of Reports 0–9, demonstrating that both Infroneer HD (parent company) and Maeda Corporation ignored or denied all whistleblowing submissions. The parent company explicitly dismissed the reports as “monetary abuse,” a stance which the whistleblower identified as a clear violation of Article 11 of the Whistleblower Protection Act, and as evidence of systemic rejection of internal reporting mechanisms.

🟩 Consumer Affairs Agency

Correction of Response Deadline – Clarifying Timetable Interpretation

The whistleblower issued a formal correction clarifying that the response deadlines were defined by the whistleblower himself (April 14 for Report 0 and April 18 for Reports 1–7), not by the company, reinforcing the structured nature of the reporting process. No substantive content of the reports was altered.

🟩 Consumer Affairs Agency

Dismissal Notice After Whistleblowing – Formal Notification Received

On April 23, 2025, Maeda Corporation issued a dismissal notice shortly after the submission of the consolidated reports and the parent company’s rejection (Report No. 9). The whistleblower views this as a case of structural exclusion resulting from lawful and documented whistleblowing activity.

🟩 Consumer Affairs Agency

Dismissal Notices Citing Whistleblowing – Structural Retaliation Evident

The whistleblower submitted copies of the dismissal notice and explanation of reasons, which explicitly cited his whistleblowing reports to government authorities as grounds for termination. This provides direct evidence that retaliation was linked to protected whistleblowing, thereby constituting a structural failure of protection obligations under Article 11.

🟩 Consumer Affairs Agency

CAA Final Response – Confirmation Only, No Corrective Measures

On May 29, 2025, the Consumer Affairs Agency (CAA) issued a correction notice, formally requesting compliance with the Whistleblower Protection Act and confirmation of the effectiveness of internal systems. However, the notice did not address the retaliation or verify implementation, leaving accountability unresolved.

🟩 Consumer Affairs Agency

Company Ignores Objection – After CAA Notification Delivered

Following the CAA’s notice, Maeda Corporation proceeded with the dismissal paperwork, completely ignoring the agency’s request and the whistleblower’s formal objection to the separation reason. This indicates a lack of enforcement mechanisms within the CAA’s procedural framework.

🟩 Consumer Affairs Agency

CAA Limits – Confirmation Without Enforcement or Follow-Up

The CAA subsequently clarified that its role is limited to confirming whether internal whistleblowing systems are formally in place, and that any retaliation or dismissal disputes must be addressed through civil litigation or labor dispute procedures. This position reflects a formalistic and non-substantive interpretation of its supervisory responsibilities, fundamentally undermining the intent of the OECD Guidelines.

🟩 Ministry of Health, Labour and Welfare

MHLW Refusal – Deflecting Retaliation Responsibility to CAA

Although the whistleblower requested institutional intervention from the Ministry of Health, Labour and Welfare (MHLW) regarding systemic retaliation and denial of whistleblower protections—including labor rights and occupational safety violations—by Infroneer Holdings’ subsidiary Maeda Corporation, MHLW refused to take responsibility, falsely asserting that such matters fall under the jurisdiction of the Consumer Affairs Agency, thereby engaging in administrative deflection.

🟩 Ministry of Health, Labour and Welfare

Structural Retaliation – MHLW Denies Jurisdiction Despite Labor Links

Subsequently, the whistleblower submitted a formal report to the Ministry of Health, Labour and Welfare (MHLW), reaffirming that the dismissal and systematic disregard of whistleblower protections by Infroneer Holdings Inc. and its subsidiary Maeda Corporation constitute a structural violation of Article 11 of Japan’s Whistleblower Protection Act. The whistleblower further asserted that MHLW’s continued refusal to investigate—by redirecting responsibility to the Consumer Affairs Agency—represents a breach of OECD Recommendation II.20.

🟩 Financial Services Agency

FSA Acknowledgment – Formal Receipt of Whistleblower Report

On March 7, 2025, the Financial Services Agency (FSA), through its Office of Compliance and Investigation of Laws and Regulations, formally acknowledged receipt of the whistleblower’s information via the government’s Crypto-bin system, confirming that the submission was accepted and placed under review.

🟩 Financial Services Agency

FSA Response – Receipt Confirmed but Jurisdiction Declined

The FSA stated that key elements of the allegations—including breaches of the Companies Act, Industrial Safety and Health Act, and workplace harassment—fell outside its jurisdiction, referring them to police or other agencies. It also noted that without submission of employment proof and ID by March 14, the matter would be treated as “general information,” illustrating a fragmented and ineffective whistleblower protection system.

🟩 Financial Services Agency

FSA Governance Report – Maeda Corporation Financial Misreporting

The whistleblower reported that Maeda Corporation, a subsidiary of Infroneer Holdings, engaged in concealment of occupational accidents, accounting fraud, internal whistleblowing suppression, and retaliation—violating Japan’s Corporate Governance Code, financial disclosure obligations, and international standards under OECD Guidelines and UNCAC Article 33.

🟩 Financial Services Agency

FSA Submission via Cryptobin – Followed by Silence and No Action

Following the March 10 submission of detailed documents, the FSA has not provided any further response or initiated substantive actions to date, effectively disregarding the report.

🟩 Ministry of Economy, Trade and Industry

METI Fragmentation – Report Redirected Without Follow-Up

On March 13, 2025, the Ministry of Economy, Trade and Industry (METI) refused responsibility for the whistleblower’s report and redirected it to other agencies (Labour Standards Inspection Office, Consumer Affairs Agency, and MLIT), illustrating Japan’s fragmented system where no authority assumes responsibility for retaliation or systemic noncompliance.

🟩 Ministry of Land, Infrastructure, Transport and Tourism

MLIT Structural Failure – Submission Silenced Without Response

After formally receiving the whistleblower’s report detailing Maeda Corporation’s concealment of 52 occupational accidents, accounting fraud, retaliation, and governance failures, the Ministry of Land, Infrastructure, Transport and Tourism (MLIT) acknowledged receipt on March 17, 2025, but has since provided no further response or follow-up, effectively silencing the case and abandoning its supervisory responsibilities.

🟫 NHK

NHK Inquiry Confirming Receipt of Whistleblower Disclosure

On March 10, 2025, NHK Osaka Broadcasting Station (journalist Keisuke Atomura) contacted whistleblower Shunsuke Kimura to request additional details about his disclosure, acknowledging the credibility and public-interest relevance of the report.

🟫 NHK

Whistleblower’s Response to NHK Inquiry

That same day, Mr. Kimura replied to Mr. Atomura, confirming that he was preparing supporting materials and asking NHK to clarify its reporting focus in order to provide relevant information.

🟫 NHK

NHK Request for Evidence on Corporate Industrial Accident Concealment

Also on March 10, Mr. Atomura emphasized that corporate concealment of industrial accidents was a serious societal issue and requested documents establishing the basic facts of the case.

🟫 NHK

Submission of Formal Report to Financial Services Agency and Notification to NHK

Mr. Kimura then informed NHK that he had submitted a formal report to Japan’s Financial Services Agency (FSA), detailing allegations of industrial accident concealment, retaliatory actions, and possible financial misstatements. A copy of the report was shared with NHK.

🟫 NHK

Consumer Affairs Agency's Reply Shared with NHK: Report Formally Registered as a Compliance Concern

On March 27, 2025, the Consumer Affairs Agency (CAA) officially acknowledged receipt of Mr. Kimura’s report. While it stated that the case did not qualify as a protected whistleblowing under the Whistleblower Protection Act, it confirmed that the content was registered as potential evidence of noncompliance with Article 11 (requirement to maintain internal whistleblowing systems). This recognition—although limited—contrasts with the complete inaction of other agencies and illustrates partial institutional acknowledgment of the whistleblower's validity, even while denying formal protection.

🟫 NHK

NHK Recognition of CAA’s Formal Acceptance of Whistleblower Report

Following this acknowledgment, Mr. Atomura noted that the CAA’s formal acceptance of the report represented a rare and significant development in the treatment of whistleblower cases in Japan.

🟫 NHK

Initiation of Article 11 Compliance Check by CAA Following Repeated Whistleblowing Silence by Infroneer Holdings Group

On April 10, 2025, the CAA formally initiated a compliance investigation under Article 11 of the Whistleblower Protection Act, based on Mr. Kimura’s report regarding systemic failures in Infroneer Holdings Group. This marked a shift from corporate silence to government-led scrutiny.

🟫 NHK

NHK Acknowledges Government Action as a Significant Development in Whistleblower Case

NHK recognized the initiation of this investigation as a turning point in the whistleblower case and requested continued updates on the outcome and possible consequences.

🟫 NHK

NHK Acknowledges Dismissal Notice and Requests Further Documentation

On April 24, 2025, NHK confirmed receipt of Mr. Kimura’s report that he had received a dismissal notice from Maeda Corporation the previous day. The broadcaster expressed interest in reviewing both the dismissal notice and the CAA’s subsequent response.

🟫 NHK

Objection to Dismissal Notice and Maeda Corporation’s Failure to Provide Justification

Mr. Kimura filed a formal objection to the dismissal, citing the absence of any justified reason. Maeda Corporation’s failure to provide adequate explanation highlighted the structural risk of retaliation following whistleblowing.

🟫 NHK

NHK Acknowledges Whistleblower Dismissal Evidence and Notes Possible Follow-up

NHK acknowledged receiving and reviewing documentation regarding the dismissal. The station indicated that it would consider possible follow-up depending on the government’s actions.

🟫 NHK

Retaliatory Dismissal Justified by Whistleblowing Activities and Procedural Irregularities

The dismissal was later explicitly justified by Maeda Corporation as being based on Mr. Kimura’s disclosures, despite the company’s failure to explain the basis beforehand—demonstrating a clear case of retaliatory termination and procedural breach.

🟫 NHK

Initiation of Government Confirmation Investigation into Infroneer’s Whistleblowing System by the Consumer Affairs Agency

The CAA subsequently expanded its confirmation process into a full investigation into Infroneer Holdings’ whistleblower system, confirming long-term structural non-responsiveness and exposing system-level failures.

🟫 NHK

NHK's Official Refusal to Report on the Whistleblower Case

Despite receiving detailed documentation and acknowledging the significance of the case, NHK ultimately declined to report on the matter. This non-engagement reflects a broader pattern of systemic failure in Japan’s whistleblower protection landscape.

🟪 Mitsubishi UFJ Financial Group, Inc.

Whistleblower Report to MUFG Audit Hotline on Systemic Concealment and Retaliatory Dismissal at Infroneer Holdings Group

A whistleblower formally notified MUFG’s audit hotline of systemic concealment of industrial accidents, retaliatory dismissal, and exclusion of related costs from financial reports at Infroneer Holdings and Maeda Corporation, requesting internal review in light of ESG and audit compliance risks.

🟪 Mitsubishi UFJ Financial Group, Inc.

MUFG Acknowledges Whistleblower Report and Requests Consent for Identity Disclosure

The MUFG Accounting Audit Hotline formally acknowledged receipt of the whistleblower’s report regarding Infroneer Holdings and Maeda Corporation and requested consent to disclose the whistleblower’s identity and contact details to MUFG.

🟪 Mitsubishi UFJ Financial Group, Inc.

Consent for Disclosure of Whistleblower Identity to MUFG Audit Hotline

The whistleblower formally consented to the disclosure of their name and email address to MUFG, enabling the internal transfer of the reported concerns regarding the collapse of the whistleblowing system and false financial reporting by Infroneer Holdings and Maeda Corporation.

🟪 Mitsubishi UFJ Financial Group, Inc.

MUFG Acknowledges Receipt but Declines to Investigate Whistleblower Report on Infroneer and Maeda Corporation

This evidence documents MUFG’s (Mitsubishi UFJ Financial Group) acknowledgment of a whistleblower report concerning systemic misconduct at Infroneer Holdings and Maeda Corporation, and its subsequent refusal to address the matter directly, citing scope limitations, while indicating intent to forward the issue to an appropriate internal department.

🟪 Mitsubishi UFJ Financial Group, Inc.

Request for Internal Referral within MUFG Regarding Governance and Loan Risk Issues

The whistleblower reaffirmed that the reported misconduct involves not only accounting and audit failures but also significant corporate governance and loan risk issues, and requested internal referral to the appropriate MUFG department.

🟪 Mitsubishi UFJ Financial Group, Inc.

CAA’s Formal Notice Concluding Investigation and Requesting Corrective Action on Infroneer Holdings' Whistleblower System

This evidence documents the Japanese Consumer Affairs Agency’s formal notification concluding its response and requesting Infroneer Holdings to ensure effective implementation of its internal whistleblower system, thereby confirming the legitimacy of the whistleblower’s claims and the need for corporate corrective action.

🟪 Mitsubishi UFJ Financial Group, Inc.

MUFG Acknowledgement of CAA's Corrective Notice on Whistleblower System Failures

The Consumer Affairs Agency formally issued a corrective notice confirming systemic failures in the internal whistleblower response framework of Infroneer Holdings, which MUFG’s audit hotline acknowledged and agreed to coordinate with relevant departments.

🟪 Mitsubishi UFJ Financial Group, Inc.

Notification of Remedial Request by Consumer Affairs Agency Regarding Whistleblower System Failure

The whistleblower informed MUFG’s audit hotline that Japan’s Consumer Affairs Agency had officially issued a remedial request regarding the failure of internal whistleblower systems, marking a critical development for corporate governance accountability.

🟪 Mitsubishi UFJ Financial Group, Inc.

Company Finalized Dismissal Despite Formal Objection Following Government Remedial Notice

The whistleblower reported that Maeda Corporation, immediately after receiving the remedial notice from the Consumer Affairs Agency, unilaterally finalized the dismissal process despite a formally submitted objection to the reason for separation, demonstrating a clear disregard for the intended effective operation of the whistleblower protection system.

🟪 Mitsubishi UFJ Financial Group, Inc.

Company’s Immediate Finalization of Dismissal Following Government Corrective Notice, Ignoring Whistleblower’s Objection

This evidence documents that immediately after the Japanese government issued a corrective notice regarding whistleblower protection, the company unilaterally finalized the reporter’s dismissal—ignoring his formal objection and thereby violating the intended effectiveness of the corrective action.

🟥Japan NCP

Specific Instance Submission to Japan NCP – Allegations of Structural Non-Compliance and Request for Joint Mediation

The whistleblower formally submitted a Specific Instance to the Japan NCP, alleging systemic violations of the OECD Guidelines (Ch. II, III, IV, XI) and UNCAC Article 33 by Infroneer Holdings Corporation and its subsidiary Maeda Corporation. The report highlights four major issues: (1) Japan’s domestic whistleblower law lacks any requirement for effectiveness evaluation, rendering internal systems ineffective by design; (2) all relevant ministries (CAA, MHLW, FSA, METI, MLIT) refused substantive intervention by citing jurisdictional limitations; (3) the company left formal records of retaliation, industrial accident concealment, and accounting fraud; and (4) Japan’s judicial system offers no redress due to the structural limitations of the revised whistleblower law. The report requests that the Japan NCP accept the case as an international violation, initiate mediation and corrective action, and coordinate with other NCPs if necessary. A deadline of October 15, 2025, was set for formal response.

🟥Japan NCP

Specific Instance Submission to the Japanese NCP – OECD Guidelines Violations by Infroneer Holdings (Filed by Whistleblower Shunsuke Kimura, September 15, 2025)

This submission, filed on September 15, 2025, to the Japanese NCP by whistleblower Shunsuke Kimura, outlines systemic violations of the OECD Guidelines by Infroneer Holdings Corporation—including labor accident concealment, accounting fraud, and retaliatory dismissal—and asserts that Japan’s whistleblower protection framework lacks effective remedies, thereby necessitating international mediation and corrective action.

🟥Japan NCP

Consolidated Records of Concealment, Retaliatory Dismissal, and Government Corrective Notice

This evidence submission (Evidence No.60) consolidates five key documents—from records of 52 unreported labor accidents to government corrective notices—that collectively demonstrate Infroneer Holdings’ systemic concealment, retaliatory dismissal, and official confirmation of internal whistleblowing system deficiencies, constituting clear violations of the OECD Guidelines and UNCAC Article 33.