[Infroneer Holdings Compliance Hotline (Real Name Report)] Your Inquiry Has Been Received
Date/Time: April 13, 2025 – 08:34 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 Neglect of Internal Whistleblowing and Indication of Disciplinary Action
Relationship to the Company: Maeda Corporation, Kansai Branch, Facilities Department, Chief Engineer
Date of Incident: November 2024 – March 2025
Location of Incident: Maeda Corporation Headquarters / Kansai Branch
Responsible Parties: Maeda Corporation, Administration Headquarters, Director Akao and others
■ Report Details:
This is a whistleblower report regarding the fact that, after I reported concealment of labor accidents and legal violations internally, the company suggested possible disciplinary action against me, and that the company’s response was oppressive and institutionally inappropriate.
In November 2024, I submitted a real-name internal whistleblower report to Maeda Corporation regarding labor accident concealment and compliance violations.
In January 2025, the company prepared an “internal report” which recorded the possibility of disciplinary action against me, explicitly showing that the whistleblower report was “considered as subject to disciplinary measures.”
This record was created during the internal investigation based on my report, and for me, it was equivalent to a “manifestation of retaliatory intent in response to whistleblowing.”
Although the company ultimately did not execute this disciplinary policy, the mere fact that disadvantageous measures were once considered internally due to my report raises serious doubts about the integrity of the whistleblowing system.
Related materials are retained, including the relevant passages of the internal report, whistleblowing records, and subsequent internal notices.
■ Matters to be Confirmed / Investigated:
- Has your company recognized the existence of “disciplinary consideration records” arising from whistleblowing at the subsidiary?
- Did the parent company conduct corrective guidance or audit responses treating such records as indications of unfavorable treatment?
- Did your whistleblower protection system function with guidelines and operations preventing unfair treatment following a report?
- Has this matter been reported to your Audit Committee, Legal Department, or Board of Directors, or is it planned to be reported?
■ Response Deadline:
Please respond to this report by Friday, April 18, 2025, 17:00 JST.
If no response is received, this matter will be formally recorded as a “system non-response (unprocessed count)” and may be formally used as evidence of system violation submitted to the Consumer Affairs Agency, administrative authorities, or media stakeholders.
■ Supplement:
The most important element of any whistleblower protection system is the prevention of retaliation and oppression resulting from reports.
The disciplinary consideration acts in this case directly undermine the credibility of the system, corporate ethics, and accountability, and strongly call into question the integrity of your company’s framework.
Applicable Laws and Regulations:
- Whistleblower Protection Act (Japan):
- Labor Contract Act (Japan):
- Corporate Governance Code:
- Article 5 (Prohibition of Unfavorable Treatment)
- Regarding illegality of disciplinary action without reasonable grounds
- Principle 2-2 (Implementation of Corporate Ethics)
- Principle 4-3 (Supervision of the Whistleblowing System)
📘 Applicable International Frameworks
- OECD Guidelines for Multinational Enterprises:
- UNCAC (United Nations Convention against Corruption):
- Chapter II (General Policies): Paragraphs 2, 7, 11
- Chapter IV (Human Rights): Paragraph 4
- Chapter V (Employment and Industrial Relations): Paragraph 6
- Article 33: Protection of Reporting Persons