Evidence No.29

March 7, 2025

To: Mr. Shunsuke Kimura

Compliance Inspection Office, Financial Services Agency

Regarding the Information Provided to the Financial Services Agency

We hereby notify you that the information you sent on March 6, 2025 to the whistleblowing hotline of the Financial Services Agency was received by the Compliance Inspection Office of the FSA on March 6, 2025.

Our Office will examine whether the information received satisfies the requirements of a “whistleblowing report” as defined in Article 2, Paragraph 1 of the Whistleblower Protection Act (Act No.122 of 2004).

In this regard, we kindly request that you provide the following communications and documents, either by postal mail or through this Crypto-bin service.

Please note the following in advance:

〇 In your information dated March 6, 2025, you listed the following as “names of laws believed to have been violated”: Financial Instruments and Exchange Act, Companies Act, Industrial Safety and Health Act, FSA Guidelines (Corporate Governance / Compliance Guidelines).

However, regarding the Companies Act (Act No.86 of 2005), the FSA is not the “administrative organ having authority to impose dispositions or recommendations concerning the reported facts” (Whistleblower Protection Act, Article 2, Paragraph 1, main clause). The correct reporting authority is the Prefectural Police Headquarters, as indicated at the following link:

https://koueki-search-result.caa.go.jp/prod/kensaku-sys?cgi=view&index=410

〇 Regarding the Industrial Safety and Health Act (Act No.57 of 1972), the FSA is likewise not the “administrative organ having authority to impose dispositions or recommendations concerning the reported facts.” The correct reporting authorities are the Prefectural Police Headquarters or the Labour Standards Inspection Office, as indicated at the following link:

https://koueki-search-result.caa.go.jp/prod/kensaku-sys?cgi=view&index=241

〇 You stated: “Directors and executives of the company systematically neglected industrial accident concealment and power harassment issues, and ignored related internal reports.” Please note that, as indicated at the following link, reports regarding workplace power harassment are not considered “whistleblowing” under the law:

https://www.caa.go.jp/policies/policy/consumer_partnerships/whisleblower_protection_system/faq/faq_002#q2

〇 From now on, we will contact you at the email address (shukku9998@gmail.com) listed in your information dated March 6, 2025. If you agree, please confirm this; if you prefer another email address, please provide it.

Please avoid using your workplace email address, as we cannot contact you there for reasons of whistleblower protection.

〇 Please submit materials to prove that you qualify as a “worker” under Article 2, Paragraph 1, Item 1 of the Whistleblower Protection Act, and that Maeda Corporation qualifies as a “business operator” that employs such worker. For example, please submit a copy of your most recent payslip showing both your name and the corporate name “Maeda Corporation.”

You may black out the monetary amounts. Please refrain from submitting a business card, as it does not constitute proof.

〇 Please submit materials to confirm the matters listed in Article 3, Item 2(i) of the Whistleblower Protection Act (the whistleblower’s name and address or residence). For example, a copy of both sides of your driver’s license or a copy of the front of your Individual Number Card.

Please absolutely do not submit a copy of the back side of the Individual Number Card, as it contains your personal number.

〇 In your information dated March 6, 2025, you listed “suspected violation of the Financial Instruments and Exchange Act (false statements, improper disclosure of information to investors).” Please confirm whether it is correct to understand that such violation at Maeda Corporation occurred only up to the second quarterly report of Fiscal Year 77 (April 1, 2021 – March 31, 2022), since the company was delisted on September 29, 2021 due to becoming a wholly-owned subsidiary of Infroneer Holdings:

https://www.jpx.co.jp/listing/stocks/delisted/archives-04.html

〇 In your information, you listed “FSA Guidelines (Corporate Governance / Compliance Guidelines).” Since we could not locate such guidelines, please provide the exact name. (Perhaps you are referring to the Corporate Governance Code:

https://www.jpx.co.jp/equities/listing/cg/tvdivq0000008jdy-att/nlsgeu000005lnul.pdf )

＜Address for submission＞

Postal Mail:

[Redacted for privacy]

Compliance Inspector, Financial Services Agency (Please mark as “Whistleblowing Report”)

※ If submitting materials, please attach them through this Crypto-bin service rather than by ordinary email.

(Notes)

This request does not obligate you to respond. However, if you do not respond, and if we do not receive any reply by March 14, 2025, we will consider your information to be simply “information provided” to the FSA, and will assume that you do not wish for it to be examined as a “whistleblowing report.” In such case, the Office will refrain from further contact with you.

Nevertheless, even if handled as “information provided,” the details will be shared with relevant departments and used in future financial administration.

(For Reference)

(1) Regarding the whistleblower protection system, please refer to the Consumer Affairs Agency’s dedicated website:

https://www.caa.go.jp/policies/policy/consumer_partnerships/whisleblower_protection_system/

(2) Administrative officials are prohibited under the National Public Service Act (Act No.120 of 1947) from disclosing secrets obtained in the course of their duties. Whistleblower confidentiality will be preserved. Furthermore, the whistleblower’s name and personal information will also be protected under the Act on Access to Information Held by Administrative Organs (Act No.42 of 1999).

https://www.caa.go.jp/policies/policy/consumer_partnerships/whisleblower_protection_system/faq/faq_004#q10

※ This document contains special information intended only for the recipient. If you are not the intended recipient, please refrain from printing or copying the information. In such case, please immediately notify the sender and destroy all contents. Dissemination or diversion of this information is prohibited.

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