Evidence No.09

[Receipt Report] Infroneer Holdings Compliance Hotline (Real Name Report)

Date/Time: April 16, 2025 – 17:57 JST

From: Compliance Hotline Inquiry compliancehl@infroneer.com

To: Shunsuke Kimura shukku9998@gmail.com

Dear Mr. Shunsuke Kimura,

On April 13, we received seven reports, and on March 16, one report, for a total of eight reports (excluding those submitted to other subsidiaries) through our Compliance Hotline.

This hotline is a system for appropriately handling reports and consultations regarding organizational or individual misconduct.

This hotline is not a negotiation channel for individuals such as yourself who repeatedly demand payment of “compensation” or “settlement money” in the amount of JPY 20 billion (approximately USD 133–138 million) in order to prevent notification to administrative authorities or media reporting.

We inform you that we cannot respond to such abuse of the reporting system.

Infroneer Holdings Corporation and Group Companies

Internal Whistleblowing Desk Representative

• 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 Neglect of Whistleblowing System and Violation of Supervisory Duties by Parent Company
• Relationship to the Company: Employee of a subsidiary of Infroneer Holdings
• Date of Incident: Since March 16, 2025 – ongoing lack of response
• Location of Incident: Your company’s Compliance Hotline (Infroneer Holdings)
• Subjects: Responsible officers of the Compliance Division of Infroneer Holdings

Report Details:

This is an official whistleblower report regarding the parent company, Infroneer Holdings Corporation, failing to take any substantive action or provide any responses after receiving reports.

Since March 16, 2025, I have submitted the following reports to your group’s compliance hotline:

• Concealment of industrial accidents, accounting fraud, and retaliation against whistleblowing at the subsidiary (Maeda Corporation)
• Official reports already submitted to seven administrative bodies (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; etc.)
• Criminal complaint scheduled, with evidence already submitted to the police
• Raising concerns regarding the obligation to establish whistleblower protection systems

However, to date, none of the following substantive actions by your company have been confirmed:

• Contact for hearing/interview
• Notice of investigation commencement
• Presentation of investigation results
• Explanation of feedback or corrective measures

Regardless of whether automated replies were sent, no “effective response” has been undertaken. The situation remains one of mere formal receipt.

This situation is highly likely to be evaluated as a violation of the “obligation to establish an effective system” under Article 11 of the Whistleblower Protection Act.

■ Matters to be Confirmed / Investigated:

• Whether there are processing records or investigation response histories regarding reports received on or after March 16, 2025
• Whether any internal audits or reporting instructions regarding misconduct at Maeda Corporation were issued
• Whether there are plans for reviewing, redesigning, or improving your whistleblowing system

■ 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:

• Consumer Affairs Agency confirmation materials on system establishment
• Supplementary materials for police submission
• Documents submitted to the media

■ Supplement:

As the parent company, your stance directly impacts the credibility of the group’s whistleblowing system as a whole.

The “obligation to establish a system” under the law refers not merely to setting up a contact point, but to whether it is functionally effective.

Please note that your company’s response to this report will serve as a direct measure of the effectiveness of your whistleblowing system and may influence future administrative decisions.

Applicable Laws and Regulations:

• Whistleblower Protection Act (Japan):

- Article 11 (Obligation to Establish Systems)

• Corporate Governance Code:

- Principle 4-3 (Responsibility of the Board of Directors for Supervision)

- Principle 5-2 (Accountability for Management Strategy)

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