Evidence No.07

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

Date/Time: April 13, 2025 – 08:49 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 Structural Compensation Costs Accompanying the Reconstruction of the Whistleblower System

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

Date of Incident: Accumulated institutional failures between 2022 and 2025

Location of Incident: Maeda Corporation and your corporate group as a whole

Responsible Parties: Infroneer Holdings Corporation Management and Compliance Division

■ Report Details:

This is a whistleblower report intended to present and discuss symbolic compensation (system reconstruction costs) in response to the grave systemic deficiencies within your group that have been neglected or condoned until now, including:

• Abandonment of obligations to respond to whistleblowing
• Consideration of retaliation
• Breakdown of internal controls

■ Factual Background:

• 52 unreported labor accidents and inducements to treat them as private sickness cases
• Accounting deficiencies across three consecutive fiscal years, including possible falsified processing
• Consideration of disciplinary measures and retaliatory structures suppressing the system after whistleblowing
• Parent company refusal of hearings, no initiation of investigations, only formalistic responses
• Six group companies with dysfunctional or absent whistleblowing channels (still unprepared after legal amendments)

These are not isolated problems but cumulative damages caused by structural governance collapse, and therefore we judge that both system reform and compensatory action must be pursued simultaneously.

■ Requests:

We request that your company provide institutional views and a stance toward discussions regarding:

• Recognition of the scope of corporate responsibility for the prolonged neglect of the system
• Policy for redesigning the group’s whistleblowing system and sharing the associated costs
• Evaluation of the legitimacy of a “structural damage + symbolic compensation” model
• Whether negotiations or discussions may begin based on the calculation model below

■ Calculation Model (Symbolic Presentation):

[Structural Damage Model (Preventive Compensation + System Reconstruction Costs)]

• Cumulative losses from abandonment of the labor accident system
• Secondary damages caused by lack of a whistleblowing system
• Operational burdens on whistleblowers and administrative authorities caused by non-response

Estimated Total: JPY 5 to 9 billion (approximately USD 33–62 million)

(symbolic proposal, negotiable)

※ This amount is a deterrent model proposal to secure the social effectiveness of whistleblower system reform.

■ Materials Already Reported to Administrative Authorities:

(Reports and evidence formally submitted to the Ministry of Health, Labour and Welfare, Financial Services Agency, Ministry of Economy, Trade and Industry, Consumer Affairs Agency, Ministry of Land, Infrastructure, Transport and Tourism, and Osaka Prefectural Police)

┗ Covering labor accident concealment, accounting fraud, retaliatory personnel measures, neglect of whistleblowing, and audit failures

■ 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 recorded and organized as structural abandonment of responsibility, and may be used as institutional evaluation material for the Consumer Affairs Agency, administrative authorities, financial regulators, and media.

■ Supplement:

This report is not intended for financial negotiation or private settlement.

It is a presentation of the “institutional symbolic cost” necessary to restore trust in the group’s system.

If your company continues to abandon institutional responses, that in itself will be regarded as the formation of a new violation structure.

Applicable Laws and Regulations:

• Whistleblower Protection Act (Act No. 122 of 2004):

- Article 5: Prohibition of Unfavorable Treatment

- Article 11: Obligation to Establish Systems (establishment of acceptance, investigation, and recurrence prevention frameworks by companies)

• Industrial Accident Compensation Insurance Act:

- Article 7: Obligation to Provide Compensation for Work-Related Injury or Illness

- Article 12-5: Reporting Obligations by Employers

- Article 29: Penal Provisions for False Reporting

• Financial Instruments and Exchange Act:

- Article 158: Prohibition of False Statements (Securities Reports)

- Article 193-2: Liability of Auditors

• Companies Act:

- Article 423: Liability for Damages by Directors

- Article 962: Criminal Penalties for False Statements

• Audit Firm Oversight Guidelines (FSA Guidelines):

- 3-2-1: Ensuring Accuracy of Financial Statements

- 3-5-2: Obligation to Verify Internal Controls

- 3-7-1: Obligation to Prevent Accounting Fraud

• Labor Contract Act:

- Article 3: Duty of Good Faith and Reasonable Consideration

- Article 15: Requirements of Reasonableness for Disciplinary Action

• Corporate Governance Code (2021 Revision):

- Principle 2-2: Emphasis on Corporate Ethics and Compliance

- Principle 4-3: Supervision of Management by the Board of Directors

- Principle 4-4: Independence and Role of Audit Committees

- Principle 5-2: Medium- to Long-Term Management Strategy and Accountability

• Policy References on System Reform and Preventive Compensation:

- Consumer Affairs Agency: “Handbook for Officials Engaged in Whistleblower Response (FY2022)”

- Ministry of Economy, Trade and Industry: “Research Report on Corporate Misconduct Response and Operation of Whistleblowing Systems”

- OECD: “Whistleblower Protection and Corporate Governance”

- ESG-based Case Studies of Domestic Listed Companies (2020s–)

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