Evidence No.27

RE: [WEB CAS formulator] Registered Data Transmission [(5270) Public Interest Whistleblowing Reception] 0709-006

Date/Time: July 11, 2025, 18:21

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 the content of your report:

• If this is a report concerning unfair dismissal, please consult the Labour Standards Inspection Office that has jurisdiction over the workplace.

<Labour Standards Inspection Office> https://www.mhlw.go.jp/stf/seisakunitsuite/bunya/koyou_roudou/roudoukijun/location.html

In addition,

• If this is a case where you experienced disadvantageous treatment due to reporting to the company’s internal whistleblowing window, please consult the Consumer Affairs Agency, which has jurisdiction over the 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: Wednesday, July 9, 2025, 7:51 PM

To: Public Interest Whistleblowing (External) kouekitu@mhlw.go.jp

Subject: [WEB CAS formulator] Registered Data Transmission [(5270) Public Interest Whistleblowing Reception] 0709-006

━┫Registered Data Transmission┣━━━━━━━━━━━━━━━━━━━━

Form ID: 5270

Form Name: Public Interest Whistleblowing Reception

━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━━

It is recommended to view this in a monospaced font.

Registration Date/Time : 2025/07/09 19:50:41

IP Address : 172.16.11.73

Browser Info : Mozilla/5.0 (Windows NT 10.0; Win64; x64) AppleWebKit/537.36 (KHTML, like Gecko) Chrome/138.0.0.0 Safari/537.36

Referrer :

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▼Name of the company or institution to be reported

Maeda Corporation

Infroneer Holdings Corporation

▼Relationship between you and the company, etc. to be reported

I was a worker employed by the company to be reported, but resigned within the past year.

▼Overview of acts suspected to constitute legal violations or risk of violations

[Re-reporting]

This is a report concerning structural legal violations at Maeda Corporation and its parent company Infroneer Holdings Corporation, where systemic retaliation against the whistleblower and disregard of the whistleblowing system continue, yet neither company has fulfilled its duty to investigate or correct these issues. Due to the nature of this case, it cannot be addressed by civil litigation or labor court proceedings, and requires systemic action by the Ministry of Health, Labour and Welfare headquarters.

This report follows the public interest whistleblowing submitted to the Ministry on July 8, 2025 (Subject: [WEB CAS formulator] Registered Data Transmission [(5270) Public Interest Whistleblowing Reception] 0708-006).

Based on the Ministry’s response received on July 9, 2025, the necessity for institutional judgment and evaluation has further increased, and this submission is positioned as a re-report.

■ Main Points of this Case:

Formal existence and disregard of the whistleblowing system

• March 16, 2025: First report to parent company (Infroneer HD) (falsified accounting, concealment of labor accidents, etc.)
• April 13, 2025: Seven reports submitted by structural theme (system deficiencies, audit failures, ignored reports, costs for system reconstruction, etc.)
• April 16, 2025: A document rejecting response was sent, stating “This is not a forum for monetary demands,” dismissing systemic response.

(Note: None of these reports contained demands for settlement money, hush money, or other monetary claims.)

Across all reports, no substantive response was provided, and abandonment of system operation is evident.

Dismissal based on whistleblowing

• In the “Dismissal Reason Notice” dated April 25, 2025, it was explicitly recorded that “reports to multiple administrative agencies damaged honor and credibility.”

Whistleblowing itself was officially documented as the reason for dismissal.

Ignoring corrective notice by the Consumer Affairs Agency

• May 29, 2025: The Consumer Affairs Agency issued a corrective notice demanding “establishment and effective operation of whistleblowing systems.”

However, the company gave no response.

From the Consumer Affairs Agency’s Director (Whistleblower Protection and Cooperation):

“We confirmed with the reported business operator, as the subject of the report, the status of internal whistleblowing system establishment under the Whistleblower Protection Act, and requested the business operator to comply with the Act and related guidelines, and to ensure effective operation of internal whistleblowing systems.”

■ Regarding the Ministry of Health, Labour and Welfare’s initial response (July 9, 2025):

On July 9, 2025, the Ministry provided the following formal reply:

“Regarding violations of the Whistleblower Protection Act, the Ministry of Health, Labour and Welfare cannot handle such matters. Please consult the Consumer Affairs Agency, which has jurisdiction over the law.”

In response, the following counter-argument is formally presented:

[Counter-Argument: On the Responsibility for Handling Whistleblower Reports]

The Consumer Affairs Agency is in charge of confirming “system establishment” under the Whistleblower Protection Act. However, responsibility for substantive investigation, correction, and relief regarding violations and retaliation (dismissal) lies with the competent ministries, including the Ministry of Health, Labour and Welfare.

In particular, the following three points are clearly under the jurisdiction of the Ministry of Health, Labour and Welfare:

• Dismissal based on whistleblowing (disciplinary action under Work Rules Article 61)
• Disregard and deficiencies in the whistleblowing system
• Administrative evaluation in the area of labor contracts and worker protection

Therefore, within the structure where “if the Ministry does not act, no one acts,” abandoning responsibility for this matter amounts to condoning the collapse of the system.

Additionally, on July 7, 2025, the Consumer Affairs Agency presented its official view that “dismissal based on whistleblowing falls under the jurisdiction of the Ministry of Health, Labour and Welfare.” Thus, transferring this matter to the Consumer Affairs Agency constitutes irresponsible buck-passing.

■ Consistency with OECD Council Recommendations:

OECD Recommendation on Whistleblower Protection, Part II, Paragraph 20:

(Whistleblowers who suffer retaliation should be provided with compensation and remedial measures.)

In this case, despite being dismissed for whistleblowing, the Ministry of Health, Labour and Welfare is refusing to provide compensation or relief, which violates international obligations for corrective action.

■ Declaration (from the standpoint of the whistleblower):

This report does not simply express dissatisfaction or seek resolution of an individual case, but demands evaluation of the overall effectiveness and credibility of the system.

The Ministry of Health, Labour and Welfare faces a choice between “saving the system” or “being recorded as having destroyed the system.”

If, after reading this far, the Ministry chooses “not to respond,” then the responsibility that “they knowingly allowed systemic collapse” will be recorded at the individual staff level.

Whether to prioritize short-term self-preservation by recognizing systemic collapse, or to protect long-term trust and the value of the system through action.

I intend to submit this record of actions to OECD headquarters, the Japan NCP, and media organizations.

This report is based on Articles 3 and 11 of the Whistleblower Protection Act and seeks “administrative correction of systemic failures,” which cannot be achieved through civil law measures.

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