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⚖️ Legal Gaps – Japan’s Whistleblower Law

🟦 Infroneer Non-Compliance

🟩 Government Non-Compliance

🟫 Media Non-Compliance

🟪 Finance Non-Compliance

🟥 Japan NCP Non-Performance

🟦 U.S. NCP Non-Performance

📘 Evidence Timeline

Evidence No.03
Evidence No.03

Evidence No.03

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

Date/Time: April 13, 2025 – 08:11 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 Concerning Maeda Corporation’s Response to Auditors and Failure of Internal Controls

Relationship to the Company: Maeda Corporation, Kansai Branch, Facilities Department, Chief Engineer

Date of Incident: At the time of fiscal year-end settlement for 2022–2024

Location of Incident: Maeda Corporation Headquarters, Audit Firm Liaison Department

Responsible Parties: Maeda Corporation Accounting Department and Audit Liaison Department

■ Report Details:

This is a whistleblower report concerning serious concerns about the adequacy of accounting practices and the effectiveness of audit responses at Maeda Corporation.

Between fiscal years 2022 and 2024, the following internal control deficiencies have been continuously observed:

  • Expenses related to industrial accidents, corrective measures, and whistleblower system responses were not recorded in financial statements.
  • Processing of occupational accidents as private injuries and delayed reporting led to habitual postponement of expenses.
  • Records of administrative reports and internal whistleblowing were not reflected at all in audit reports.

In response to these circumstances, there is no evidence that the auditing firm required corrections, and the actual handling is unclear. For this reason, there is a very strong suspicion that the audit function has been rendered substantially ineffective.

Related materials are retained, including administrative reports, whistleblower records, and comparative analysis records of accounting treatments.

■ Matters to Confirm / Investigate:

  • Whether there are any records of comments or instructions issued by the auditing firm to Maeda Corporation, and the location of such records.
  • Why unreported industrial accidents and failures to address whistleblowing were not reflected in audit reports or financial statements.
  • Whether, as the parent company, there exists a review and checking system for financial reporting and audit content.
  • Whether there are future plans for reassessment, reinvestigation, or corrective instructions directed to the auditing firm.

■ Response Deadline:

Please respond to this report by Friday, April 18, 2025, 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 submitted to the Consumer Affairs Agency, Financial Services Agency, media, and other relevant institutions as a violation of auditing oversight guidelines and corporate governance.

■ Supplement:

The suspicion of three consecutive years of falsified processing at Maeda Corporation strongly indicates the collapse of audit functions and internal controls.

If an unqualified audit opinion has been issued, its reliability itself is in question.

As the parent company, you must clarify at which point within internal controls, disclosure, or audit systems a functional breakdown occurred.

Applicable Laws and Regulations:

  • Financial Instruments and Exchange Act:
  • - Article 193-2 (Liability of Auditors)

  • Audit Firm Oversight Guidelines:
  • - 3-2-1 (Accuracy of Financial Statements)

    - 3-5-2 (Obligation to Verify Internal Controls)

    - 3-7-1 (Obligation to Prevent Falsified Financial Statements)

  • Corporate Governance Code:
  • - Principle 4-4 (Independence of Audit Committees)

    - Principle 5-2 (Responsibility for Explaining Management Strategy and Governance)

📘 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

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

Date
2025/04/13 8:11 AM (GMT+9)
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Stakeholder Tag

🟦 INFRONEER Holdings Inc.

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Summary

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).

Title

Report No. 3 – Audit Breakdown and Accounting Misstatements