[Additional Report on Corporate Response Immediately Following Corrective Notice] Abandonment of Handling the Objection Regarding Reason for Separation
Date/Time: June 10, 2025, 10:04
From: MUFG Accounting Audit Hotline mufg-accounting-audit-hotline@hokusei-law.com
To: Shunsuke Kimura shukku9998@gmail.com
Dear Mr. Shunsuke Kimura,
We have reviewed the contents of your follow-up communication.
The materials you sent this time contain not a small amount of your important personal information. Therefore, we regret to inform you that we will refrain from handing them over to the bank’s responsible department as we have done until now.
Accordingly, we would like to limit what we convey to the bank’s responsible department to only the following: that you have separated from the business operator, and, in connection therewith, that with respect to the reason for separation “dismissal” entered by the business operator on the employment insurance application documents, you have filed an “objection.”
Please also understand that the principal matters of your complaint have already been coordinated (shared), and that such handling would depart from the original role of this contact point. We therefore respectfully ask that you refrain from contacting us for the purpose of providing subsequent progress reports or reference information. We appreciate your understanding.
June 10, 2025
MUFG Accounting Audit Hotline Contact
Hokusei Law Office (Bengoshi Hojin Hokusei Law Office)
From: Shunsuke Kimura shukku9998@gmail.comSent: Monday, June 9, 2025 8:13 AM
To: MUFG Accounting Audit Hotline mufg-accounting-audit-hotline@hokusei-law.com
Subject: Fwd: [Additional Report on Corporate Response Immediately Following Corrective Notice] Abandonment of Handling the Objection Regarding Reason for Separation
To: Hokusei Law Office
(Attn: MUFG Accounting Audit Hotline Representative)
I hope this message finds you well.
This is Shunsuke Kimura, the whistleblower.
At 8:00 AM today, June 9, 2025, I formally sent the email below to the Office of the Director (Whistleblower Protection and Cooperation), Consumer Affairs Agency, and I am sharing it for your reference.
The email records the facts that, in response to the “Corrective Notice” issued by your Agency on May 29, 2025, the subject company (Maeda Corporation) unilaterally and formally proceeded with procedures on the same day, and that, despite the “objection regarding the reason for separation” having been formally entered and returned during the process, the handling was finalized as “dismissal.”
I regard this response as clearly contrary to the intent of the corrective notice concerning the “effective operation” of the internal whistleblowing system, and as a serious act that may be evaluated as an institutional abandonment of compliance.
Accordingly, in future audits, risk assessments, and reviews of corporate governance systems, I respectfully request that you confirm the facts so that this matter can serve as one of the decision-making materials.
Below is the full text already sent to the Consumer Affairs Agency.
--------- Forwarded message ---------From: Shunsuke Kimura mailto:shukku9998@gmail.com
Date: Monday, June 9, 2025 8:00
Subject: [Additional Report on Corporate Response Immediately Following Corrective Notice] Abandonment of Handling the Objection Regarding Reason for Separation
To: Whistleblower Protection Office mailto:g.koueki24@caa.go.jp Consumer Affairs Agency
Office of the Director (Whistleblower Protection and Cooperation)
This is Shunsuke Kimura, the whistleblower.
With respect to the “Corrective Notice” received from your Agency in the morning of May 29, 2025, on the same day the subject company, Maeda Corporation, sent the following set of documents.
These included a full set of formal dismissal procedures, including a written confirmation to check with the whistleblower regarding the “presence/absence of an objection regarding the reason for separation.” It is confirmed that the procedures were unilaterally advanced on the same day without any trace of confirmation or adjustment in response to the corrective notice.
In the attached “Cover Letter for Social Insurance-Related Documents,” the date is clearly stated as May 29, 2025, formally recording that it is the same date as the corrective notice from your Agency. Meanwhile, the actual delivery/receipt date was May 30, 2025, which suggests that the company prioritized formal processing without considering the corrective content.
【List of Attached Documents】
① Cover Letter for Social Insurance-Related Documents (dated May 29, 2025)
② Confirmation Letter Regarding Reason for Separation (dated June 2, 2025)
③ Employment Insurance Separation Notice – Form 2 (Excerpt: Reason for Separation column) *Issued on June 6, 2025
We returned item ② above on June 2, 2025, with a formal entry of “objection to the reason for separation column.”
Subsequently, in item ③ “Employment Insurance Insured Person’s Separation Notice – Form 2,” issued and sent on June 6, 2025, it is clearly stated that the whistleblower personally has lodged an objection, as follows.
【Contents Recorded in Separation Notice – Form 2 (Excerpt)】
(16) Judgment by the separated person (select one)
☑ Objection to the reason for separation entered by the employer
Name: Shunsuke Kimura
Column for description of specific circumstances (for employer):
“Dismissal”
As described above, despite the formal entry in the separation notice that the whistleblower has clearly lodged an objection, the company fixed the reason entry as “dismissal,” finalized the processing as submitted documents to Hello Work (public employment office), and completed it without re-examination/adjustment of the contents or confirmation with your Agency.
This series of actions, taken immediately after the issuance of your Agency’s corrective notice, is understood as having processed the obligation of “effective operation of the internal whistleblowing response system” only formally, and in substance having abandoned it.
Accordingly, I would be grateful if you could confirm and record this matter, and, as necessary, consider supplementing the system review or reflecting it in reporting records.
If there are any points your Agency wishes to confirm in the future, I will respond promptly. I appreciate your continued cooperation.
Shunsuke Kimura
mailto:shukku9998@gmail.com
📘 OECD/UNCAC Legal Reference
- OECD Guidelines for Multinational Enterprises
- Chapter II (General Policies): Maintain effective internal controls and compliance; do not undermine corrective processes.
- Chapter III (Disclosure): Ensure accurate and reliable disclosure in material labor/governance matters.
- Chapter IV (Human Rights): Retaliation or detrimental treatment of whistleblowers is an adverse human rights impact requiring prevention and remedy.
- OECD Anti-Bribery Recommendation (2009)
- Annex II: Establish effective, confidential internal reporting channels and ensure appropriate follow-up.
- UNCAC Article 33
- Provide protection against unjustified treatment for persons who report in good faith and on reasonable grounds.
