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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.37
Evidence No.37

Evidence No.37

Submission of Official Report to Financial Services Agency – Shared with NHK

Date/Time: March 10, 2025, 15:40

From: Shunsuke Kimura shukku9998@gmail.com

To: ATOMURA atomura.k-gs@nhk.or.jp

NHK Osaka Broadcasting Station

Mr. Atomura,

Thank you very much for your message.

Today, I am attaching the official report that I formally submitted to the Financial Services Agency (FSA).

This report has been officially filed with the FSA and contains content that may proceed to review by a public authority.

Main contents:

  • Specific methods and background of concealed labor accidents (obstruction of labor accident applications, inducement to use private injury/illness allowances)
  • Corporate response (actions after the report, evidence of misconduct, realities of retaliatory acts)
  • Fraudulent financial reporting and possible accounting fraud (non-recording of labor accident-related costs, responsibility of the auditing firm)
  • FSA’s request for investigation and current response (corporate governance, timely disclosure obligations, impact on the market)

Particularly important points:

  • Effects of labor accident concealment on the financial reports for FY2022 and FY2023 (possibility of accounting fraud)
  • November 2024 internal whistleblowing → corporate internal response and evidence (indications of retaliation by company lawyers, internal email records)
  • FSA’s actions → today, a formal report has been submitted; further progress in investigation is expected.

Additionally, there are related pieces of evidence (internal emails, audio recordings, etc.). However, due to their large size, I am considering sending them via Takumail (large file transfer service).

If NHK has a preferred method of receiving these, please let me know so that I can adjust accordingly.

Please review, and if you have any questions, do not hesitate to let me know.

Sincerely,

Shunsuke Kimura

(March 10, 2025 (Mon) 14:57, ATOMURA atomura.k-gs@nhk.or.jp)

📘 OECD/UNCAC Legal Reference

  • OECD Guidelines for Multinational Enterprises
    • Chapter II (General Policies): Enterprises must conduct business with transparency and integrity, avoiding concealment of material facts.
    • Chapter III (Disclosure): Requires timely, accurate, and verifiable disclosure of financial performance and non-financial risks (including labor safety issues).
    • Chapter V (Employment and Industrial Relations): Enterprises should ensure occupational health and safety, avoiding concealment of workplace accidents.
  • UNCAC (United Nations Convention against Corruption)
    • Article 13 (Participation of Society): Ensures the role of media and public oversight in exposing corruption and corporate misconduct.
    • Article 33 (Protection of Reporting Persons): Calls for protection of whistleblowers who, in good faith, report misconduct and corruption.

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

Date
2025/03/10 3:40 PM (GMT+9)
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Stakeholder Tag

🟫 NHK

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Summary

Mr. Kimura then informed NHK that he had submitted a formal report to Japan’s Financial Services Agency (FSA), detailing allegations of industrial accident concealment, retaliatory actions, and possible financial misstatements. A copy of the report was shared with NHK.

Title

Submission of Formal Report to Financial Services Agency and Notification to NHK