【Supplementary Submission】Record of Non-Compliance by Maeda Corporation and Infroneer HD (Reports No.0–9)
April 16, 2025, 19:01
Shunsuke Kimura shukku9998@gmail.com
To: Whistleblower Protection System Division g.koueki24@caa.go.jp
To: Consumer Affairs Agency
Director for Whistleblower Protection and Collaboration
Thank you as always for your continued support.
I am Shunsuke Kimura, the whistleblower regarding Maeda Corporation and Infroneer Holdings.
This email is a formal supplementary submission based on your guidance dated March 28, 2025—
“Confirmation of prospects for system development under Article 11 of the Whistleblower Protection Act.”
I am hereby systematically organizing and submitting the previously sent reports (No.0 to No.8) and the parent company’s official response (No.9) as supplementary evidence.
■ Overview of the Records
◼ [Reports No.0–8]
0 (March 16, 2025)
Initial report. Reported misconduct such as industrial accident concealment, accounting fraud, and retaliatory personnel actions to the parent company (Infroneer HD).
→ Only automatic reply received. No investigation notice or hearing.
1–7 (April 13, 2025)
To examine the structural dysfunction of the whistleblower system, the following topics were individually reported:
- System negligence and supervisory responsibility violations
- Lack of effectiveness in the whistleblower protection system
- Audit firm and internal control non-compliance
- Obstruction and concealment of industrial accident reports
- False statements in financial reporting
- Implication of disciplinary action against the whistleblower
- Estimation of structural compensation responsibility (presented as a symbolic model of 5 to 9 billion yen)
→ All received only automatic replies. No investigation or corrective action initiated.
8 (April 14, 2025)
Reported to the subsidiary (Maeda Road) due to the dysfunction of the parent company’s system.
→ The subsidiary replied that the report was “forwarded to the parent company.”
→ Determined to be proof of structural system failure where corrective action is returned to the offender.
◼ [Response Record: No.9]
9 (April 16, 2025)
Received an official statement from the parent company Infroneer HD: “We will not respond to system abuse for the purpose of monetary demands.”
→ The same statement includes: “You have repeatedly demanded 20 billion yen.” In fact, only Report No.7 contains any monetary figure.
That amount was presented solely as a symbolic compensation model necessary for system reconstruction and was not intended for settlement negotiation.
→ Reports No.0–6 and No.8 concern only system deficiencies and supervisory responsibilities and contain no monetary demands.
→ Therefore, rejecting the entire set of reports as “system abuse for monetary gain” is recognized as a serious violation of the obligation to maintain a whistleblower system under Article 11 of the Whistleblower Protection Act.
■ List of Attachments (4 items)
【0_Initial Report】20250316_Record_of_Parent_Company_Ignoring_the_System.pdf
【1-7_Structural Reports】Record_of_Non-Compliance_and_Negligence_in_Whistleblowing.pdf
【8_Transfer Proof】Proof_of_Structural_Collapse_by_Subsidiary.pdf
【9_System Denial】20250416_Official_Email_Denying_the_System_from_Parent_Company.pdf
※ These are submitted as evidence that the company formally expressed a “no response” stance on April 16, two days before the designated response deadline (April 18, 2025).
I hope this will assist your agency’s evaluation of the effectiveness of the whistleblower system at Maeda Corporation and Infroneer Holdings, and contribute to your determination regarding the confirmation of system improvement.
Shunsuke Kimura (Whistleblower)
📧 shukku9998@gmail.com
📅 Date Sent: Wednesday, April 16, 2025
📘 Related Legal Reference
• OECD Guidelines for Multinational Enterprises
- Chapter II: Paragraphs 2, 7, 11
- Chapter IV: Paragraphs 1, 5
• UNCAC Article 33: Protection of Reporting Persons