[Infroneer Holdings Compliance Hotline (Real Name Report)] Acknowledgement of Inquiry
Date/Time:April 13, 2025, 08:04 JST
From: no-reply@contact.infroneer.com
To: shukku9998@gmail.com
Thank you very much for your inquiry via this website.
Below is the content of your inquiry:
Name: Shunsuke Kimura
Email Address: shukku9998@gmail.com
Email Address (Confirmation): shukku9998@gmail.com
Phone Number: [Redacted for privacy]
Postal Code: [Redacted for privacy]
Address: [Redacted for privacy]
Title: Report Regarding the Parent Company's Neglect of Whistleblowing System and Supervisory Duties
If possible, please describe your relationship with our company: Employee of a subsidiary of Infroneer Holdings
Approximate date when the reported act occurred: Ongoing since March 16, 2025
Location of the incident (e.g., department): Your company’s compliance hotline (Infroneer Holdings)
Who committed the act: Responsible personnel in charge of compliance at Infroneer Holdings
Details of the Report:
This is an official whistleblower report regarding the parent company, Infroneer Holdings Corporation, having failed to take any substantive action or respond following receipt of prior reports.
Since March 16, 2025, I have submitted the following reports to the compliance hotline of your corporate group:
- Concealment of industrial accidents, falsified accounting, and retaliation against whistleblowing at the subsidiary, Maeda Corporation
- Official reports have already been submitted to seven administrative bodies (including the Ministry of Health, Labour and Welfare, the Financial Services Agency, the Ministry of Economy, Trade and Industry, the Consumer Affairs Agency, the Ministry of Land, Infrastructure, Transport and Tourism, etc.)
- Criminal complaint scheduled, with evidence already submitted to the police
- Raising concerns about obligations related to the establishment of whistleblower protection systems
However, your company has not yet taken any of the following substantive actions:
- Contact for hearing/interview
- Notice of investigation commencement
- Presentation of investigation results
- Explanation of feedback or corrective measures
Regardless of whether an automated response was sent, no “effective action” has been taken; the situation remains as merely formal receipt.
This situation is highly likely to be evaluated as a violation of the “duty to establish an effective system” under Article 11 of the Whistleblower Protection Act.
■ Matters to be confirmed and investigated:
- Whether there are any records of processing or investigation related to the report received on or after March 16, 2025
- Whether any internal audits or reporting instructions regarding misconduct at Maeda Corporation were issued
- Whether there is any plan for reviewing, redesigning, or improving the whistleblower system
■ Response Deadline:
Please respond to this report by Friday, April 18, 2025, 17:00 JST.
If no response is received by the deadline, this report will be formally categorized as a "Record of Non-Response (Unaddressed Count)", and may be included in the following materials:
- Documentation for the Consumer Affairs Agency’s confirmation investigation on system implementation
- Supplementary materials submitted to the police
- Documents submitted to the media
■ Supplement:
The stance of your company, as the parent company, directly affects the credibility of the group’s whistleblower system as a whole.
The "duty to establish a system" under the law refers not merely to setting up a contact point, but to whether the system is functionally effective.
Please note:
Your company’s response to this report will serve as a direct measure of the effectiveness of your whistleblower system and may influence future administrative decisions.
■ Applicable Legal Framework:
- Whistleblower Protection Act of Japan, Article 11 (Obligation to establish a system)
- Corporate Governance Code:
- Principle 4-3 (Responsibility of the Board of Directors for Supervision)
- Principle 5-2 (Accountability for Management Strategy)
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📘 Applicable International Frameworks:
- OECD Guidelines for Multinational Enterprises:
- Chapter II (General Policies): Paragraphs 2, 7, 11
- Chapter III (Disclosure): Paragraphs 1, 4
- UNCAC (United Nations Convention against Corruption):
- Article 33: Protection of Reporting Persons
- Article 12: Private Sector Accountability