RE: [WEB CAS formulator] Registered Data Transmission [(5270) Public Interest Whistleblowing Reception] 0708-006
Date/Time: July 9, 2025, 18:22
From: Public Interest Whistleblowing (External) kouekitu@mhlw.go.jp
To: "shukku9998@gmail.com" shukku9998@gmail.com
Dear Whistleblower,
This is the Administrative Consultation Office of the Ministry of Health, Labour and Welfare.
A “public interest whistleblowing” refers to a system in which workers, etc. employed at a business establishment where a violation is occurring, report such violations to an administrative agency that has the authority to impose sanctions or take measures against such violations.
Regarding violations of the Whistleblower Protection Act, we regret to inform you that the Ministry of Health, Labour and Welfare cannot handle such matters. Therefore, we kindly ask that you consult the Consumer Affairs Agency, which is the authority responsible for this law.
<Consumer Affairs Agency – Whistleblower Protection System Consultation Dial (Unified Consultation Window)>
https://www.caa.go.jp/policies/policy/consumer_partnerships/whisleblower_protection_system/contact
This concludes our response.
Thank you for your understanding.
----Original Message-----
From: webq-admin@mhlw.go.jp webq-admin@mhlw.go.jp
Sent: Tuesday, July 8, 2025, 2:28 PM
To: Public Interest Whistleblowing (External) kouekitu@mhlw.go.jp
Subject: [WEB CAS formulator] Registered Data Transmission [(5270) Public Interest Whistleblowing Reception] 0708-006
━┫Registered Data Transmission┣━━━━━━━━━━━━━━━━━━━━
Form ID: 5270
Form Name: Public Interest Whistleblowing Reception
━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━
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Registration Date/Time : 2025/07/08 14:27:31
IP Address : 172.16.11.73
Browser Info : Mozilla/5.0 (Windows NT 10.0; Win64; x64) AppleWebKit/537.36 (KHTML, like Gecko) Chrome/137.0.0.0 Safari/537.36
Referrer : https://www.mhlw.go.jp/shinsei_boshu/kouekitsuhousha/
▼Overview of the acts suspected to constitute legal violations or risk of violations
This report concerns Maeda Corporation and its parent company Infroneer Holdings Corporation. Despite ongoing systemic retaliation against the whistleblower and the complete disregard of the whistleblowing system itself, neither company has fulfilled its obligations to investigate or maintain such systems. Furthermore, this is a structural legal violation that cannot be addressed through civil litigation or labor court proceedings. Therefore, corrective action and investigation in the areas under the sole competence of the Ministry of Health, Labour and Welfare are being requested.
Specifically, the following three points cannot be addressed by a Labour Standards Inspection Office, and require an institutional determination by the Ministry headquarters:
- Formal existence and disregard of the whistleblowing system
- “Ordinary dismissal” based on whistleblowing
- Ignoring the corrective notice by the Consumer Affairs Agency
Since March 2025, multiple whistleblowing reports have been submitted to both companies. None of these have received substantive responses. Aside from automated replies, no actual reaction has been provided, and the whistleblowing system exists only in form, without being operational in practice.
On April 23, 2025, an ordinary dismissal was issued, followed by a dismissal reason notice dated April 25, 2025. In this notice, the whistleblower was accused of “sending multiple reports to administrative agencies that damage the company’s honor and credibility.” Based on this, dismissal was carried out under Work Rules Article 61 (defamation, etc.).
This constitutes treating whistleblowing itself as grounds for discipline and exclusion, and is a clear violation of the Whistleblower Protection Act.
On May 29, 2025, the Consumer Affairs Agency officially issued a notice to the company requiring “establishment and effective operation of the whistleblowing system.” However, the company has not complied with this corrective request and continues to abandon its system maintenance obligations.
These circumstances are not matters to be resolved through civil settlements or litigation, but rather symbolize a “structural defect arising from the very design of the whistleblowing system.”
In particular, this case contains the grave contradiction of “workers using the whistleblowing system being excluded by the system itself,” fundamentally undermining the credibility and sustainability of the system.
Therefore, this matter raises questions about the national effectiveness of the whistleblower protection system, and requires institutional judgment and administrative evaluation at the Ministry headquarters.
This report concerns systemic evaluation of flaws in system design and structures excluding whistleblowers, and is clearly distinct from individual labor violation cases handled by the Labour Standards Inspection Office.
【Evidence Materials】Available to be submitted separately or by mail if necessary.
- Dismissal Reason Notice (dated April 25, 2025)
- Corrective Notice by the Consumer Affairs Agency (dated May 29, 2025)
- Whistleblowing Records (report texts, transmission history, emails, etc.)
Document explicitly stating dismissal “due to administrative whistleblowing,” citing Work Rules Article 61 (defamation, etc.) as grounds.
Formal notification requiring establishment and effective operation of whistleblowing systems.
Materials documenting multiple whistleblowing submissions to both companies and the fact of no responses.
Other supplementary materials (to be submitted if necessary):
- Chronological records showing developments after reporting, communications leading to dismissal, and evidence of systemic disregard.
This report is based on Articles 3 and 11 of the Whistleblower Protection Act. It is not intended as a private law procedure such as civil litigation or labor tribunal, but rather seeks “administrative correction of systemic failures.”
📘 OECD/UNCAC Legal Reference
- OECD Guidelines for Multinational Enterprises
- Chapter II (General Policies): Enterprises should develop and maintain effective internal systems to prevent retaliation and ensure compliance.
- Chapter IV (Human Rights): Retaliation or dismissal for whistleblowing constitutes an adverse human rights impact.
- OECD Anti-Bribery Recommendation (2009)
- Annex II: Calls for reliable, confidential, and effectively functioning internal reporting mechanisms.
- UNCAC Article 33
- Encourages States Parties to provide protection against unjustified treatment for whistleblowers acting in good faith.
