[Maeda Corporation Compliance Hotline (Identified Report)] Inquiry Received
Date/Time: April 10, 2025, 11:02
From: Shunsuke Kimura shukku9998@gmail.com
To: ATOMURA atomura.k-gs@nhk.or.jp
Mr. Keisuke Atomura (NHK Osaka Broadcasting Station)
My name is Shunsuke Kimura. Thank you for your continued support.
Regarding the whistleblowing matter I have consulted with you about concerning Maeda Corporation and the Infroneer Holdings Group,
today I confirmed an official action on the system side (Consumer Affairs Agency), so I would like to report it to you.
■ Summary of the content:
With respect to the “inquiry regarding violation of the obligation to establish internal systems” that I submitted to the Consumer Affairs Agency on March 28, 2025,
today, I received an official response from the Office of the Director (Whistleblower Protection and Cooperation),
stating: “We will confirm whether there is any violation concerning the internal system development required of the business operator.”
At this point, institutionally, it means that the “confirmation process based on Article 11 (obligation to establish internal systems)” has begun.
■ Structural facts at this time (as of April 10, 2025):
- Parent company: Infroneer Holdings Corporation
- Wholly-owned subsidiaries (excluding Maeda Corporation): 4 out of 5 companies
- Consumer Affairs Agency: Formally confirming the presence or absence of violation of the obligation to establish internal systems
- Whistleblower side: Administrative reports, corporate reports, and all evidence records retained
→ Identified reports submitted / continued silence (multiple reports submitted, zero response)
→ None have a reporting contact window on their official websites; systems are not established
→ Identified reporting attempted to each (or attempts not possible)
→ Target bodies: Ministry of Health, Labour and Welfare / Financial Services Agency / Ministry of Economy, Trade and Industry / Ministry of Land, Infrastructure, Transport and Tourism / Consumer Affairs Agency / Police / Media
■ Attachments to be provided:
- Original email from the Consumer Affairs Agency (received April 10, 2025)
- If necessary, I can also provide a structural report / table of unestablished systems / chronology of corporate responses.
This is not merely a report of internal misconduct; rather,
it is a report aimed at visualizing that “the whistleblowing system was not functioning within the corporate group,”
and that “there is a structural record showing that the company did not comply with the system.”
With the system now in motion,
we have entered a phase in which corporate responses, the legitimacy of the system, and administrative determinations will be tested.
If you are interested,
I am fully available for continued information sharing and cooperation with coverage.
Thank you very much for your consideration.
Shunsuke Kimura
📘 OECD/UNCAC Legal Reference
- OECD Guidelines for Multinational Enterprises
- Chapter II (General Policies): Enterprises should establish and maintain effective internal controls and compliance systems, and respond in good faith to legitimate stakeholder concerns.
- Chapter III (Disclosure): Requires timely, accurate, and verifiable disclosure about material matters, including risk management and compliance systems.
- Chapter IV (Human Rights): Enterprises should avoid adverse impacts and provide for remediation—retaliation or non-response to whistleblowing undermines due diligence duties.
- UNCAC (United Nations Convention against Corruption)
- Article 13 (Participation of Society): Calls for enabling environments and channels for reporting, including cooperation with media, to enhance transparency and accountability.
- Article 33 (Protection of Reporting Persons): Encourages protection against unjustified treatment for persons who, in good faith, report facts concerning corruption or misconduct.
