Evidence No.02

[Infroneer Holdings Compliance Hotline (Whistleblower Report)] Your Inquiry Has Been Received

Date/Time: April 13, 2025 – 08:07 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 on Lack of Effectiveness and History of Neglect Regarding the Whistleblower System

Relationship to the Company: Employee of a subsidiary of Infroneer Holdings

Date of Incident: Since March 16, 2025 – Ongoing lack of response

Location of Incident: Compliance reporting channels of your group (web form / email)

Responsible Party: Head of Compliance at Infroneer Holdings

Report Details:

This is a whistleblower report concerning the fact that, although your whistleblower system formally exists, it is not functioning in practice.

Since March 16, 2025, I have submitted multiple reports under my real name through your group’s reporting channels, including but not limited to:

• Concealment of workplace accidents
• Falsification of financial statements
• Retaliatory personnel measures
• Audit deficiencies

However, the following actions have not been observed:

• Notice of investigation commencement
• Contact to coordinate hearings
• Disclosure of feedback or investigation results
• Explanation regarding system review or reform

Even if an automated reply was sent, it would amount only to “formal receipt processing”, and I am forced to conclude that the system is not being practically operated.

This situation may constitute a serious failure to comply with the “obligation to establish an effective system” under Article 11 of the Whistleblower Protection Act.

■ Items to Confirm / Investigate:

• Has your company retained processing logs or investigation records for reports received since March 16, 2025?
• Please explain how your system is designed and operated for initial responses after a report is received (e.g., initiation of investigation, contact, documentation).
• Please indicate whether there are any planned revisions, restructuring, or recurrence prevention measures related to this matter.

■ Response Deadline:

Please respond to this report by Friday, April 18, 2025 at 17:00 JST.

If no response is received by the deadline, this matter will be formally recorded as a "system non-response (unprocessed count)", and may be included in:

• Consumer Affairs Agency’s system improvement verification materials
• Supplementary materials for police reports
• Documents submitted to media organizations

■ Supplement:

The whistleblower system must not merely exist in name but must function effectively in practice.

Please recognize that institutional trust is grounded in concrete actions and improvements in response to reports—not just in the installation of contact points or retention of reception logs.

Applicable Legal Framework:

• Whistleblower Protection Act (Japan):

- Article 5: Prohibition of Unfavorable Treatment

- Article 11: Obligation to Establish an Effective Internal Reporting System

• Industrial Safety and Health Act (Japan):

- Article 97: Right to File a Complaint

- Article 100: Obligation to Report

- Article 120: Penal Provisions

• Financial Instruments and Exchange Act:

- Article 158: False Statements

- Article 193-2: Auditor Responsibility

• Companies Act (Japan):

- Article 423: Liability for Damages by Directors

- Article 962: Criminal Penalty for False Statements

• Labor Contract Act:

- Regarding illegality of disciplinary action or reassignment without reasonable grounds

• Corporate Governance Code (2021 Revision):

- Principle 2-2: Ensuring Corporate Ethics

- Principle 4-3: Board of Directors’ Supervisory Responsibilities

- Principle 4-4: Independence of Audit Committees

- Principle 5-2: Responsibility to Explain Management Strategy

📎 The original Japanese evidence document (PDF) is attached below for reference.