Evidence No.33

[Ministry of Land, Infrastructure, Transport and Tourism] Notification to the Whistleblower Contact Point

March 17, 2025, 08:15 (JST)

From: Ministry of Land, Infrastructure, Transport and Tourism – Whistleblower Contact Point stationmaster-r2u7@mlit.go.jp

To: shukku9998@gmail.com

※This is a no-reply email address. Please note that any replies will not be answered.

Thank you very much for your message to the whistleblower contact point at the Ministry of Land, Infrastructure, Transport and Tourism (MLIT).

We have received your submission as follows:

• Reference Number: 250317B100001
• Whistleblower Name: Shunsuke Kimura
• Affiliated Company or Institution: Maeda Corporation
• Postal Code: [Redacted for privacy]
• Prefecture: [Redacted for privacy]
• Contact Information:
• Residence: [Redacted for privacy]
• FAX: [Redacted for privacy]
• Email: shukku9998@gmail.com
• Preferred Contact Method: Japan

• Date Whistleblower Became Aware of Incident: November 10, 2022

• Name of Subject(s) of the Report: (Not specified)

• Company or Institution of the Subject: Maeda Corporation

Employment Relationship Evidence

• Existence of Employment Proof: Yes
• Types of Proof: Pay slips, tax withholding statements, employee ID
• Relationship Between Whistleblower and Subject: Full-time employee

Overview of Suspected Legal Violations

1. Summary of Violations

At Maeda Corporation, acts of workplace accident concealment, accounting fraud, and retaliatory personnel actions have been confirmed.

These actions not only endangered worker safety, but also led to fraudulent financial reporting, causing severe damage to corporate trust.

The case has already been reported to the Ministry of Health, Labour and Welfare, Ministry of Economy, Trade and Industry, Financial Services Agency, Consumer Affairs Agency, and Labour Standards Inspection Office.

Given the oversight responsibility of the MLIT, your administrative response is requested.

The possibility of issuing a business suspension order under the Construction Business Act must also be considered.

2. Relevant Legal Violations

• Industrial Safety and Health Act (for workplace accident concealment and breach of safety obligations)
• Article 97 (Workers’ Right to Report) → Obstruction of accident reporting; false declarations
• Article 100 (Reporting Obligation) → False reporting to labor authorities; breach of duty to report
• Article 120 (Penalties) → Fines up to 500,000 JPY or imprisonment up to 6 months for violations
• Whistleblower Protection Act (for retaliatory personnel actions and unfair treatment of whistleblowers)
• Article 5 → Prohibition of disadvantageous treatment (e.g., demotion, salary reduction, forced resignation, punitive transfer)
• Construction Business Act (for governance failure and inappropriate business conduct)
• Article 28 → Possible issuance of a business suspension order by MLIT for serious misconduct
• Article 28, Paragraph 3 → Suspension up to one year for confirmed violations
• Financial Instruments and Exchange Act (for false financial reporting due to accounting fraud)
• Article 158 → Criminal penalties if financial statements contain intentional falsehoods
• Article 193-2 → Liability of auditing firms for fraudulent audits
• Companies Act (for corporate and shareholder responsibilities)
• Article 423 → Directors' liability for damages due to breach of duty; subject to shareholder derivative lawsuits
• Article 962 → Criminal penalties for false statements (up to 10 years imprisonment or 10 million JPY fine)
• Corporate Governance Code (for failure in executive oversight and internal controls)
• Principle 4-3 → Failure of the Board of Directors to fulfill oversight responsibilities
• Supplementary Principle 4-3-2 → Failure to manage labor risk properly, harming company trust
• Principle 2-2 → Breakdown of corporate ethics due to concealment and harassment
• Principle 4-4 → Dysfunctional audit committee and lack of internal control
• Principle 5-2 → Lack of transparent disclosure regarding long-term corporate sustainability

Reason Why MLIT Action is Required

This case is highly likely to warrant a business suspension order under Article 28 of the Construction Business Act, and thus calls for a strict administrative response from the MLIT.

• Date(s) of Incident: (Not specified)
• Location of Incident: Compliance Department (Head Office, Chiyoda-ku, Tokyo)
• How the Whistleblower Became Aware:

While working at the company, I confirmed the concealment of workplace accidents. Despite internal reporting, no correction was made, and I was subjected to retaliatory actions.

Subsequently, I identified suspected accounting fraud due to the omission of accident-related expenses and collected evidence. I decided to report to the authorities.

Evidence Availability

• Existence of Evidence: Yes
• Types of Evidence:

Email history, internal reports, audio recordings, unreported accident list, medical certificates, attendance records

• Means of Submission: E-mail

Instructions for Submitting Evidence (as stated in original)

If you wish to submit evidence separately, please use one of the following methods:

■ By Post

To : Whistleblower Contact Point

Ministry of Land, Infrastructure, Transport and Tourism

B1, Central Gov’t Building No.3, 2-1-3 Kasumigaseki, Chiyoda-ku, Tokyo 100-8918

Please be sure to include the reference number on the envelope or package.

■ By E-mail

To: hqt-koueki1103@gxb.mlit.go.jp

Please include the reference number in the subject line.

■ By Fax

Fax: 03-5253-8031

Please include the reference number within the document.

■ By Direct Submission

Whistleblower Contact Point

Ministry of Land, Infrastructure, Transport and Tourism

B1, Central Gov’t Building No.3, 2-1-3 Kasumigaseki, Chiyoda-ku, Tokyo

Thank you for your cooperation.

Ministry of Land, Infrastructure, Transport and Tourism

Whistleblower Contact Point

TEL: 03-5253-8124 / FAX: 03-5253-8031

Kasumigaseki 2-1-3, Chiyoda-ku, Tokyo 100-8918

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