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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.05
Evidence No.05

Evidence No.05

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

Date/Time: April 13, 2025 – 08:25 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 False Statements in Financial Reporting at Maeda Corporation

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

Date of Incident: From FY2022 settlement through FY2024 (three consecutive fiscal years)

Location of Incident: Maeda Corporation Headquarters, Accounting Department

Responsible Parties: Maeda Corporation Accounting Department and Management

■ Report Details:

This is a whistleblower report regarding the possibility that Maeda Corporation continuously disclosed financial information that diverged from actual conditions.

Since FY2022, the following treatments were not properly reflected in accounting, raising serious suspicions of falsification:

  • Due to concealment of labor accidents, related expenditures were unrecorded by treating them as private sickness cases
  • Exclusion of internal control costs such as whistleblowing system operation expenses and disciplinary action records
  • Intentional omission of corrective costs related to administrative and internal whistleblowing from reports
  • Despite the involvement of an auditing firm, whistleblowing cases were not reflected in audit materials

These manipulations and omissions strongly suggest that the financial reports for FY2022–2024 were false representations, constituting a serious situation that undermines accountability to investors, shareholders, and supervisory authorities.

Related materials, including whistleblowing records and internal reports, are retained.

■ Matters to be Confirmed / Investigated by Your Company (Parent Company):

  • Whether your company had an established and functioning governance system over the subsidiary’s financial statements
  • The recognition and reporting status of labor accident and whistleblowing-related expenses in the above three fiscal years
  • Whether the parent company issued any corrective guidance or verification instructions to the auditing firm or subsidiary
  • Future policy for fulfilling the parent company’s accountability if inquiries are raised by investors or regulatory authorities

■ 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 included in materials submitted to the Consumer Affairs Agency, Financial Services Agency, media, and shareholder-related institutions.

This matter fundamentally calls into question the group’s financial transparency, auditing system, and accountability framework.

We strongly request a sincere and institutional response from your company.

Applicable Laws and Regulations:

  • Financial Instruments and Exchange Act:
  • - Article 158 (False Statements)

  • Companies Act (Japan):
  • - Article 423 (Liability for Damages by Directors)

    - Article 962 (Criminal Penalty for False Statements)

  • 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)

📘 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 8:25 AM (GMT+9)
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Stakeholder Tag

🟦 INFRONEER Holdings Inc.

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Summary

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).

Title

Report No. 5 – False Financial Reporting and Control Gaps