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⚖️ Legal Gaps – Japan’s Whistleblower Law

🟦 Infroneer Non-Compliance

🟩 Government Non-Compliance

🟫 Media Non-Compliance

🟪 Finance Non-Compliance

🟥 Japan NCP Non-Performance

🟦 U.S. NCP Non-Performance

📘 Evidence Timeline

Evidence No.22
Evidence No.22

Evidence No.22

Submission of Dismissal Reason Notice (Material Related to Article 11 Confirmation)

May 12, 2025 – 14:58

From: Shunsuke Kimura shukku9998@gmail.com

To: Whistleblower Protection System Office g.koueki24@caa.go.jp

To: Consumer Affairs Agency

Office of the Director for Whistleblower Protection and Collaboration

Thank you for your continued support.

My name is Shunsuke Kimura, the whistleblower in this matter.

As supplemental material concerning the confirmation of internal system development,

I hereby submit the following documents issued by Maeda Corporation:

“Dismissal Notice” dated April 23, 2025 and “Dismissal Reason Notice” dated April 25, 2025.

Attached file names:

• 20250423_Maeda_Corporation_Dismissal_Notice.pdf

• 20250425_Maeda_Corporation_Dismissal_Reason_Notice.pdf

This submission is made solely for the purpose of providing evidentiary material of record value

in relation to the confirmation of internal system development under Article 11 of the Whistleblower Protection Act.

Please note that this submission does not request any special response or judgment.

The Dismissal Reason Notice clearly states that I submitted whistleblowing reports to multiple administrative agencies,

and it is recorded that the company recognized the existence and content of these reports

and formally included them as acts “damaging to the company’s reputation” in the grounds for dismissal.

Furthermore, the contents of these reports have already been officially submitted to the police as a complete set of evidence since March 2025,

and it has been confirmed that there was no illegality or threatening content involved.

Nevertheless, the company carried out no investigation or response through the proper system,

and proceeded to terminate the whistleblower not through disciplinary action, but as an “ordinary dismissal for company reasons,”

thereby attempting to avoid record accountability.

This response demonstrates:

  • that the company failed to fulfill its institutional obligation to protect despite recognizing the legitimacy of the whistleblowing,
  • that it explicitly documented the whistleblowing as “reputational damage” and used it as grounds for exclusion,
  • and that it deliberately avoided disciplinary measures while undermining the consistency of its internal records.
  • Hence, I consider this to be clear structural evidence of failure to operate the internal compliance system effectively as required under the system development obligations.

I apologize for the intrusion during your busy schedule,

but I would be grateful if you could review this material as a reference in the context of your ongoing confirmation of system development.

Sincerely,

Shunsuke Kimura (Whistleblower)

📧 shukku9998@gmail.com

📅 Date Sent: Monday, May 12, 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

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

Date
2025/05/12 2:58 PM (GMT+9)
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Stakeholder Tag

🟩 Consumer Affairs Agency

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Summary

The whistleblower submitted copies of the dismissal notice and explanation of reasons, which explicitly cited his whistleblowing reports to government authorities as grounds for termination. This provides direct evidence that retaliation was linked to protected whistleblowing, thereby constituting a structural failure of protection obligations under Article 11.

Title

Dismissal Notices Citing Whistleblowing – Structural Retaliation Evident