Evidence No.61

Subject: Raising Concerns Regarding Violations of the OECD Guidelines for Multinational Enterprises (Infroneer Holdings Group)

Date: October 10, 2025, 17:07 JST

From: JAPANESE NCP jpn-ncp@mofa.go.jp

To: "shukku9998@gmail.com"

Cc: JAPANESE NCP jpn-ncp@mofa.go.jp

Dear Mr. Shunsuke Kimura,

Thank you very much for contacting us.

We confirm that your email and the attached documents have been received by the Japanese NCP. We are currently reviewing the contents, which will take some time. Once the review is completed, we will contact you again.

Please note that this email does not constitute a formal acknowledgment of acceptance of your submission.

We appreciate your continued cooperation.

Sincerely,

Japanese NCP

From: Shunsuke Kimura shukku9998@gmail.com

Sent: Monday, September 15, 2025, 08:00 JST

To: JAPANESE NCP jpn-ncp@mofa.go.jp

Subject: [Free e-mail] Raising Concerns Regarding Violations of the OECD Guidelines for Multinational Enterprises (Infroneer Holdings Group)

This mail is sent from a free e-mail address. Please carefully check the sender’s address and contents.

To the Japanese NCP,

As a whistleblower, I hereby formally raise concerns regarding serious non-compliance by Infroneer Holdings Corporation (and its subsidiary, Maeda Corporation).

1. Deviation from International Standards

Under the OECD Guidelines Chapter II (General Policies), Chapter III (Disclosure), Chapter IV (Human Rights), and Chapter XI (Compliance), as well as UNCAC Article 33, companies are obligated to maintain effective internal whistleblowing mechanisms and to protect whistleblowers from retaliation.

However, the revised Japanese Whistleblower Protection Act (effective June 11, 2025) is limited to the "existence of a system," and the requirement for effectiveness evaluation has been removed.

As a result, the domestic framework fails to meet international standards, making institutional remedy for whistleblowers structurally impossible.

1. Response from Domestic Administrative Agencies

Despite submitting formal reports, all responsible agencies — the Consumer Affairs Agency, Ministry of Health, Labour and Welfare, Financial Services Agency, Ministry of Economy, Trade and Industry, and Ministry of Land, Infrastructure, Transport and Tourism — treated the case as "outside jurisdiction" and effectively refused to act.

• Consumer Affairs Agency: Only confirmed receipt; claimed no authority to intervene in retaliation or dismissal
• MHLW: Referred all issues regarding industrial accidents and dismissal to the Consumer Affairs Agency
• FSA / METI / MLIT: Abdicated governance and financial oversight responsibilities

The entire domestic framework is structurally devoid of effective whistleblower protection.

1. Corporate Non-Compliance Confirmed

Through official corporate documents, the Infroneer Holdings Group has demonstrated the following:

• Concealment of 52 labor accidents
• Three consecutive years of accounting fraud
• False accusation that the whistleblower made a "20 billion yen demand"
• Dismissal notice explicitly based on the whistleblowing act

This constitutes clear evidence that the company has negated the very purpose of the whistleblower protection system.

1. Ineffectiveness of Domestic Legal Remedies

Any legal proceedings based on the Whistleblower Protection Act are inherently void because:

• The effectiveness evaluation requirement has been removed
• No mechanism exists for post-retaliation remedies (compensation, reinstatement, corrective orders)
• OECD and UNCAC provisions are not reflected in domestic law

Thus, pursuing litigation within Japan is structurally meaningless, and the domestic system itself proves to be in violation of international obligations.

1. Requests to the Japanese NCP

In light of the above, I request the following actions:

2. That this case not be dismissed as "outside domestic legal jurisdiction," but instead be accepted as an international case of OECD Guidelines violations;
3. That mediation and corrective actions be initiated under the OECD Guidelines;
4. That, if necessary, this case be reviewed jointly with other NCPs.
5. Deadline

Please provide a response regarding acceptance and intended course of action by Wednesday, October 15, 2025, 17:00 JST.

Please note: mere confirmation, review, or referral to the company does not meet the effectiveness requirement under the OECD Guidelines and will be interpreted as institutional non-performance.

This case has surpassed the limits of domestic law and constitutes confirmed international non-compliance. If the Japanese NCP does not respond appropriately, joint review with other NCPs will become inevitable.

Evidence Materials

• Evidence Timeline: Evidence No.00–No.57
• Attached Files:
• File No.000204226 (docx/PDF): Japanese NCP submission form (detailed case description)
• File No.100799831 (xlsx/PDF): List of submitted evidence (excerpt)

Sincerely,

Shunsuke Kimura

Phone: [Redacted for privacy]

Postal Code: [Redacted for privacy]

Address: [Redacted for privacy]

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