Evidence No.08

Re: Reporting Form | Compliance Whistleblowing Hotline

Date/Time: April 14, 2025 – 11:22 JST

From: Headquarters / Internal Control Department External Whistleblowing Desk maeda-helpline@maedaroad.co.jp

To: shukku9998@gmail.com

Thank you for your report to the Compliance Whistleblowing Hotline.

Your report has been transferred to the Management Audit Department of Infroneer Holdings Co., Ltd., and further handling will be carried out there.

Sincerely,

Maeda Road Co., Ltd. – Compliance Whistleblowing Hotline

Sent via Outlook for iOS

Forwarded Message

From: soumu_h@maedaroad.co.jp

Sent: Thursday, April 10, 2025 – 08:08 JST

To: Headquarters / Internal Control Department External Whistleblowing Desk maeda-helpline@maedaroad.co.jp

Subject: Reporting Form | Compliance Whistleblowing Hotline

■ From Website Inquiry ■

A compliance whistleblowing report has been submitted.

Please review the email content and take appropriate action.

■ Compliance Whistleblowing Report Content ■

• Name (Affiliation) / Address:

Shunsuke Kimura (Maeda Corporation)

[Redacted for privacy]

• Phone Number:

[Redacted for privacy]

• Email Address:

shukku9998@gmail.com

• Regarding Notification of Investigation Results:

Wish to be contacted

• Title:

Report Regarding the Hollowing Out of Infroneer Holdings’ Whistleblowing System and Violation of Group Oversight Obligations

• Relationship to Our Company:

Maeda Corporation (your wholly owned subsidiary), Kansai Branch, Facilities Department, Chief Engineer

• Date of Occurrence:

Since March 16, 2025 – continuing to the present with no response to reports

• Place of Occurrence:

Infroneer Holdings Headquarters (Chiyoda-ku, Tokyo), and whistleblowing system operations across the group

• Subjects:

Responsible officers in the Compliance Division of Infroneer Holdings Co., Ltd.;

Group Governance Supervisory Officers;

Practical managers responsible for whistleblowing response in each group subsidiary

■ Report Details:

This report concerns the hollowing out of the whistleblowing system (internal and public interest reporting) at Infroneer Holdings Co., Ltd., and the lack of group governance functions.

Since March 16, 2025, multiple real-name reports have been repeatedly submitted to your company, including:

• Concealment of labor accidents, retaliatory personnel actions, and accounting fraud at Maeda Corporation (subsidiary)
• Reports to administrative bodies such as the Ministry of Health, Labour and Welfare, Financial Services Agency, and Consumer Affairs Agency
• Inquiries regarding your obligation to establish systems under Article 11 of the Whistleblower Protection Act

However, there has been no notification of investigations, hearings, or feedback, and your company continues to fail to fulfill its system-based “duty to respond.”

Furthermore, despite reports also being submitted to five other group subsidiaries (including Maeda Road), they too have remained unresponsive, demonstrating that the dysfunction of the system is structural and cross-organizational.

If the entire corporate group continues to ignore whistleblowing, it is highly likely that your compliance policies and obligations to establish systems will be judged to have “never substantively existed,” representing a serious institutional defect.

■ Applicable Laws and Regulations:

• Whistleblower Protection Act:

- Article 11 (Obligation to Establish Whistleblowing Systems)

• Corporate Governance Code:

- Principle 4-3: Supervisory Duties of the Board of Directors

- Principle 5-2: Accountability for Management Strategy and Risk

• Companies Act:

- Article 362 (Duties of the Board of Directors)

• Financial Services Agency Supervisory Guidelines:

- Regarding the governance responsibility of parent companies

• Cooperation with Investigation: Possible
• Existence of Evidence: Yes

• Attached:

Original whistleblowing text and transmission history

Administrative report documents / PDF evidence

Chronological log of neglect records (dates, contents, formats)

Group subsidiary whistleblowing records

Chronological summary of lack of company response history

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