0 WHISTLEBLOWING REPORT CONCERNING EMBEZZMENT AND CRIMINAL CODE MISCONDUCT INDONESIAN LAW BY TOP MANAGEMENT STRICTLY CONFIDENTIAL Submitted to : Mr. Yasutaka Hasegawa President Director Of PT. MEIDOH INDONESIA Kawasan Industri Surya Cipta, Jalan Surya Utama Kav. I-40AB, Karawang Timur Submitted by: Confidential Whistleblower (Identity to be Treated as Strictly Confidential) Legal Basis in Japan : Law No. 62 of 2025 amended Act No. 122 of 2004 concerning of Whistleblower Protection Legal Basis in Republic of Indonesia : 1. Article 374 KUHP jo. Article 55 (1) KUHP, Article 20 No. 1 of 2023 concerning of Embezzlement (Criminal Code) KUHP 2. Japanese (Foreign National Violation) Article 122 Law No. 6 of 2011 concerning of Immigration 3. Government Regulation No. 34 of 2021 concerning of Foreign Worker Utilization 4. Articles 1320, 1321 and 1323 through 1327 of the Indonesian Civil Code concerning of the Legal Requirements for a Valid Agreement and The Invalidly or Void Ability of Agreements Executed under Duress 5. Articles 52,54,185 of Law No. 13 of 2003 as amended by Law No. 6 of 2023 Job Creation Law 6. Article 1 (5), Article 5 and Article 10 of Law No. 3 of 2026 concerning the Protection of Witnesses and Victims
1 CONTENTS INTRODUCTION 1 LETTER PURPOSE OF THIS REPORT 2 ROOT LEGAL BASIS OF PT MEIDOH INDONESIA 3 LEGAL CHRONOLOGY AND STATEMENTS OF FACTS 20 ACTUAL WORKFLOW OPERATIONAL MEIDOH 29 DIGITAL FORENSIC INVESTIGATION 32 VENDOR SUPPLIER STEERING 34 FAKE SUPPLIER AND VENDOR FOR BIAS 41 EVERY EMPLOYEE HAS ONE COMPANY 50 TAX OFFICE FROM MADYA TO PMA2 60 CONCLUSION ON INVESTAGION FINDINGS 63 FINANCIAL LOSS AND ASSET 64
2 Jakarta, 08 – 08 – 2026 With Due Respect, Mr. Yasutaka Hasegawa President Director PT. Meidoh Indonesia Please accept my sincere apologies for submitting this report directly to you as the owner of PT. Meidoh Indonesia. Hereby, I acknowledge that I understand and given high respect that under Japanese Corporate Culture implemented the Shinrai Principle and organization hierarchy relationship. Bypassing the direct channel is viewed as disresepectful and this Whistleblowing Report is pursued and extraordinary recourse, necessitated by the fact that the existing Internal Mechanism have failed to Prevent to Cease or Resolve the violations that have occurred I am acting objectively in my capacity as a witness to these events started n 7th August 2026. By way of Introduction, my name is Gita Pravita Sari.,B.Sc.Tourism.,L.LB. the Daughter of Mrs. Happy who has been employed by PT. Meidoh Indonesia since 4 March 2013. The chronology begun started in July 2026. Her employment contract expired on 8 August 2026 at which point she asked to revision the contract and proceed to renewal it on 5th August 2026. However the contract attached on email explained under condition 50% sallary reduction and the mandatory transfer all of MCRI duties to Fidel Castro as General Manager by verbally resulted of the
3 meeting which held in 17th and 27th July 2026. On behalf of Managament the final decision that she shall be accepting the contract with reduction 50% based on her age which born in 08.08.1963. meetings held on July 17th and July 27th, 2026., Subsequently, on the 7th, sent a follow-up email to the General Manager, Mr. X. However, since that email was sent by the Vice President, Mr. X, there has been no further email correspondence from F or the HR Department. This constitutes a clear and severe legal violation, as Foreign Workers (TKA) are strictly prohibited from holding personnel positions or managing HR affairs under Article 46 of Law No. 13 of 2003 on Manpower as amended by Law No. 6 of 2023 on Job Creation and Law No. 6 of 2011 concerning of Immigration. This violation carries serious legal consequences, including the deportation of the foreign national, revocation of foreign worker utilization permits (RPTKA) and a freeze/blacklist on the company's authorization to employ foreign nationals. This critical issue prompted me to conduct a deeper investigation. The findings of this investigation reveal a far more severe and complex situation, you are at immediate risk of losing control of your assets to Top Management Fidel Castro, Aris Tyanto, Zulik Ihwanudin and all Indonesian employees are families, relatives, 70% all exisiting supplier by their networks e.g IATF. Prompted by these circumstances events, I requested access to Mrs. Happy the employment agreement between Mrs. Happy and PT. Meidoh Indonesia as my capacity of a witness. Upon reviewing the draft agreement, I noted
4 the contract signed by a foreign nationality specifically titled Professional Work Agreement as an Advisor with following periods of 2025 – 2026 and 2020 – 2021 and 2021 – 2022 and I noted that there was Statements of Retirement letter issued in 2018 signed by Aris Tyanto as a Human Resources Department. I noted that the clauses and articles contents on employement agreement executed terms are invalid under Indonesian law and Null and Void ab intio. As the intentional alteration of clauses and manipulation of facts constitue fraud under Article 378 and Document forgery under Article 263 of the Indonesian Criminal Code Kitab Undang Undang Hukum Pidana. Futhermore, the deliberate erasure of terms and deceptive tactics demonstrate bad faith (mens rea) transforming this matter from a civil dispute into a criminal offense. Leveraging my professional experience in legal practice, I conducted a thorough review of the matter. The investigation revealed far more severe and complex issues, including misconduct of Conspiracy, Corporate Embezzlement and Systematic Manipulation designed to conceal Bias which potentially expose PT Meidoh Indonesia’s Asset Confiscation and Share Forfeiture Given. The gravity of investigation findings an immediate and Independent Investigation and Covert Investigation is highly required. Strictly exluding Current TOP Management as well as Japanese Personnel currently employed or who have been repatriated to Japan upon completion of their tenure. I would like to present this report using my own Whistleblowing version
5 as a witness of aggrieved party Mrs. Happy an employee at PT. Meidoh Indonesia. This Faction is undertaken with the Utmost Respect, Good Faith, and Sole Dedication to preserving the integrity, dignity and reputation of the company, as well as ensure the business continuity, sound accountability and adherence to the principles Good Corporate Governance at PT. Meidoh indonesia as Private Enterprise. Notwithstanding such familial relationship, I declare that I am not, and have never been, an employee, officer, representative, agent, affiliate, or any other person authorized to act for or on behalf of any employee at PT Meidoh Indonesia. All information and data contained in this whistleblowing report are presented on a strictly limited basis solely to support the Investigation Process. This report does not disclose trade secrets and is not intended to be leaked, distributed or misused for personal gain in any form whatsover. The identity of the whistleblower acting as a witness for the aggrieved party is strictly confidential in accordance Article 5(1) Law No 31 of 2014 concerning the Protection of Witnesses and Victims and Accordingly, I possess no actual, implied, or apparent authority to represent the company and this report is submitted solely in my personal capacity as a witness of Aggrieved Party is my mother who employeed by PT. Meidoh Indonesia and in good faith as a whistleblower. This report is submitted solely for the purpose of facilitating an independent, impartial and lawful investigation into the matters described herein,
6 without prejudice to the rights of any party and without any intention to defame, harm, or improperly influence the company and in objectiveness.
7 LEGAL BASIS PT. MEIDOH INDONESIA I apologize for the length of this report, however a comprehensive account is necessary to address the root cause under the governing laws applicable to PT. Meidoh Indonesia, thereby eliminating any potential bias in interpreting the contract and the investigative findings. NO ROOT OF EXPLAINATION CORE LEGAL BASIS PT. MEIDOH INDONESIA 1 The Purpose of Law To ensure legal certainty and legal protection. If the requirments of legal certainty and legal protection are not met, legal penalties shall applied 2 The Hierarchy of Laws and Regulations 1. (UUD 1945) The 1945 Constitution of the Republic of Indonesia {the supreme written law of the state serving as the foundational legal basis} 2. Decrees of the People Consultative Assembly (Enforceable MPR decrees as recognized) 3. Laws or Government Regulations in Lieu of Law {Peraturan Pemerintah Pengganti Undang Undang} 4. Government Regulations {Peraturan Pemerintah} 5. Presidential Regulations {Peraturan Presiden} 6. Provincial Regional Regulations {Peraturan Daerah Provinsi}
8 7. Regency/Municipal Regional Regulations {Peraturan Daerah Kabupaten Kota} 3 Ideology Republic of Indonesia Pancasila and The 1945 Consitution represent the written foundation of Pancasila. The drafting of the 1945 Constitution originated from Japan’s pledge of Independence of the Indonesian nation, marked by the establishment of Dokuritsu Junbi Cosakai which serves as the historical bedrock of the strong bilateral relations. Japan fulfil their promises to help indonesia Independency. 4 Commercial Law This falls under commercial law which is a specialized branch of civil law. Civil Law, in turn constitutes private law. 5 Is it possible to shift a Civil Law dispute into Criminal Law Proceedings and Vice Versa? Permissible Circumstances {Fulfilment of Elements}. A legal relationship that initially arises from a civil matter e.g. An Agreement or Business Contract may enter the criminal domain from the outset, there was a criminal intent {mens rea}, fraudulent, misrepresentation or bad faith that meets the elements of a specific criminal offense. Case : Mrs. Happy’s employment contract agreement (A trap Clause), A party enters into
9 a contract or business partnership but from the beginning uses a false identity / a fraudulent pretext / or deceitful tactics to induce the other party into enter the agreement, If the evidence shows that the party had fraudulent intent from the outset and that the conduct fulfils the legal elements of fraud, the matter may constitute a criminal offense rather than merely a a civil dispute. Under these conditions, the action satisfies the statutory elements of Article 378 of the Indonesian Criminal Code (Fraud) or Article 372 of the Indonesian Criminal Code (Embezzlement) thereby subjected it to criminal prosecution. Limitation Ultimum Remedium if the administrative sanctions hasn’t applied within the days with both contract’s agreement. 6 Why Civil Law Classified as Private Law ? Civil Law is categorized as private law because it governs disputes occurring strictly between private legal subjects 1, Individual to Individual (Person to Person) 2. Individual to Legal Entity (Person to Legal Entity) 3. Legal Entity to Legal Entity {Legal Entity to Legal Entity} 7 Legal Basis of Civil Law 1. The Civil Code {Kitab Undang Undang Hukum Perdata}
10 2. Legislation governing procedural Civil Law, namely the Indonesian Civil Code {Burgerlijk Wetbook}. Rv currently referred to as the Code of Civil Procedure as well as other specific statutory laws governing specialized matters. 8. Substantive Civil Law {Hukum Perdata Materiil} Civil Law, in principle, regulates legal rights and obligations which is referred to as substantive civil law. Alignment with Pancasila and the 1945 Constitution, which is referred to as substantive civil law. Pancasila serves as the State Ideology of Indonesia. Consequently, the Indonesian Civil Code (KUHPerdata) must derive its values from and strictly refrain from contradicting, the principles of Pancasila namely Divinity. Humanity, Unity, Democracy, Social Justice. 9 Civil law that regulates the procedures for exercising and enforcing rights and obligations is known as formal civil law Civil Procedural Law refers to the set of legal rules that governs the mechanism for enforcing and upholding substantive civil law through judicial court proceedings 10 What is Civil Law? Civil law is a branch of private law that regulates the rights, duties, and legal relationships between private legal subjects whether between individuals, between an individual and a legal entity or between legal entities.
11 11 The Indonesian Civil Code consists of four Books Codification in Book III (Law of Obligations): Civil law and business (commercial) law are fundamentally governed under Book III of the Indonesian Civil Code, which addresses the Law of Obligations (Hukum Perikatan). Statutory Distribution and Amendments The legal provisions regulating civil matters are dispersed across various legislative enactments. Certain statutory laws explicitly repeal specific provisions of the Civil Code, whereas others function as supplementary legislation, expanding the regulatory framework without amending the original provisions. 12 There are Two Types of Legal Subjects 1. Natural Person (Mrs. Happy) 2. Legal Entity (PT. Meidoh Indonesia) 13 PT. Meidoh Indonesia prior to becoming Legal Subject 1. Legislation & Incorporation Process Through the legal incorporation process executed before a Notary, registered with the Ministry of Trade, and approved by the Ministry of Law and Human Rights (Kemenkumham). 2. Corporate Management / Governing Body
12 The executive management (Board of Directors / Officers) responsible for and representing the legal entity. 3. Corporate Domicile Court Jurisdiction 4. The legal domicile (registered address) of the legal entity and the corresponding Court Jurisdiction (Competence of the Court). 14 PT. Meidoh Indonesia as a recognized legal subject {legal entity} 1. Notarial Deed of Establishment Pursuant to Law No. 2 of 2014 on Amendments to Law No. 30 of 2004 on the Position of Notaries. 2. Decree of the Ministry of Law and Human Rights (SK Kemenkumham) Pursuant to Law No. 40 of 2007 on Limited Liability Companies. 3. Business Identification Number (Nomor Induk Berusaha / NIB) Pursuant to Law No. 6 of 2023 on Job Creation and Government Regulation No. 5 of 2021 on the Implementation of Risk-Based Business Licensing.
13 4. Corporate Taxpayer Identification Number (NPWP Badan Hukum - PT. Meidoh Indonesia) Based on Law No. 6 of 1983 on General Provisions and Tax Procedures (as amended) and Law No. 7 of 2021 on the Harmonization of Tax Regulations. This regulation affirms the Taxpayer Identification Number (NPWP) as a formal identity for taxpayers within tax administration. 5. Governing Body Responsible for the Legal Entity Governed via the General Meeting of Shareholders (GMS/RUPS) and the Board of Directors/Commissioners. 6. Legal Domicile of the Legal Entity Located at Jalan Surya Cipta I-40AB, East Karawang. 7. Court Jurisdiction (Absolute Jurisdiction and Relative Jurisdiction) The nature of the legal case must be filed within the appropriate court having proper jurisdiction. Failure to do so will result in the lawsuit being declared inadmissible (Niet Ontvankelijk
14 Verklaard / NO) by the judge, rather than rendering a final and binding judgment (Inzake / Inkrah). Prior to submitting a claim to the District Court, a party must ascertain whether the matter falls under specialized civil jurisdiction (perdata khusus) or general civil jurisdiction (perdata biasa). 15 PT. Meidoh Indonesia has category of KBLI 29300 in terms of Laws for Operation, Employees, Scrap, Waste, Environmental Impact, Regulation Factory & Premises, Primary Laws and Regulations Governing of the Operation 1. Law No. 6 of 2023 on the Enactment of Government Regulations om Lieu of Law No. 2 of 2022 on Job Creation into Law {Regulates Risk-Based Business Licensing administered through the Online Single Submission system {OSS-RBA} 2. Government Regulation No. 5 of 2021 on the Implementation of Risk-Based Business Licensing Regulates the risk classification for business licensing under KBLI 29300 {Henerally categorized as Medium Low to Medium-High risk, depending on the scale of investment and environmental/operational {impact}
15 3. Minister of Industry Regulation No. 9 of 2021 on Business and/or Product Activity Standards in the Implementation of Risk Based Business Licensing within the Industrial Sector { Established technical requirements, standard certificates, and specific operational standards for business entities operating under KBLI 29300 Primary Laws Regulations Governing Labor and Workforce Related This is important at Human Resources Department 4. Ministry of Health → Law No. 24 of 2011 on the Social Security Administering Bodies (BPJS) Mandatory enrollment of all employees in BPJS Ketenagakerjaan (Work Accident, Death, Old-Age, Pension, and Job Loss Security) and BPJS Kesehatan (Health Insurance) → it refers to K3 HSE and against Government Regulation for Factory. Ministry of ManPower → Government Regulation No. 34 of 2021 concerning Foreign Labor Ministry of ManPower → Law No. 13 of 2003 on Manpower (as amended by Law No. 6 of 2023 on Job Creation) as follows :
16 5. Employment Agreements: Rules governing Fixed-Term Employment Contracts (PKWT / Contract) and Indefinite Term Employment Contracts (PKWTT / Permanent). 6. Remuneration & Overtime: Regional Minimum Wage (UMK), statutory overtime calculation formulas for factory operations, and Religious Holiday Allowance (Tunjangan Hari Raya / THR). 7. Termination & Severance: Regulations and calculation formulas for severance pay (uang pesangon), service appreciation pay (uang penghargaan masa kerja / UPMK), and employment termination procedures. 8. Working Hours: Factory shift work arrangements (8 hours per day or 40 hours per week). Ministry of ManPower → Government Regulation No. 35 of 2021: Regulates details reegarding Fixed- Term Employment Contracts (PKWT), Outsourcing, Working Hours/Overtime, and Termination of Employment. Ministry of ManPower → Government Regulation No. 36 of 2021 on Wages: Regulates
17 the mechanisms for setting minimum wages and establishing structure and scale of wages. Ministry of Environmental→ Governing Scrap, Waste, and Environmental Impact (Pengelolaan Limbah & Scrap) Law No. 32 of 2009 on Environmental Protection and Management (PPLH) (as amended by Law No. 6 of 2023 on Job Creation): Mandates Environmental Assessment Documents (AMDAL or UKL-UPL) prior to factory operations. Ministry of Environmental Government Regulation No. 22 of 2021 on Environmental Protection and Management: Hazardous and Toxic Waste (Limbah B3): Regulates the handling of used oil, chemical liquids, and used coolant (requires a Temporary Storage Permit / TPS Limbah B3 and engagement with licensed third-party waste management vendors). 9. Non-Hazardous Waste (Non-B3 Metal/Plastic Scrap): Regulates
18 procedures for the utilization, sale, or processing of solid production scrap to prevent environmental contamination Emission & Wastewater Standards: Regulates industrial chimney/smokestack emissions and Wastewater Treatment Plant (WWTP / IPAL) discharges. Ministry of Public Works → Regulations Governing Factory Premises & Infrastructure (Gedung Pabrik & Domicile) Regulates the physical operations of factory buildings and machinery at the plant location: Law No. 28 of 2002 on Buildings (as amended by Law No. 6 of 2023, Law No. 6 of 2023 on Job Creation (Industrial Estates Provisions): o If the KBLI 29300 facility is situated within an industrial zone (e.g., SURYACIPTA PARK or KIIC Karawang), it must strictly comply with the applicable Estate Regulations. Directorate General of Taxes
19 1. Law No. 28 of 2007 Concerning of General Provisions and TAX Procedures → this regulation updated through Law No. 7 of 2021 concerning the Harmonization of Tax Regulations 2. Law No. 7 of 1983 concerning Corporate Income Tax & Withholding Taxes → this regulation updated through Law No. 7 of 2021 concerning the Harmonization of Tax Regulations 3. Minister of Finance Regulation No. 212/PMK.03/2023 (superseding PMK 213/PMK.03/2016) and Director General of Taxes Regulation No. PER- 43/PJ/2010. And relevant Laws applied the company depends on nature’s business scope.
20LEGAL CHRONOLOGY AND STATEMENTS OF FACT EVENT 1
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29 INVESTIGATION FINDINGS ANALYSIS – WORKFLOW OPERATIONAL CHART Based on my investigation, I created this workflow chart using Paint to easily demonstrate the actual operational process at PT. Meidoh Indonesia. The division of roles and chain of command within the organization are structured into several main functions Based on my legal analysis of Meidoh’s operational mapping, this chart illustrates the core competencies, factual data, and strategic benefits for the company 1. Executive Leadership & Management • Shachou (President/CEO): Holds the top position and serves as the ultimate head of the company → This is critical to running a manufacturing business. However, every President Director possesses unique competencies and capabilities, which are evident through transparent processes and delivered results. • General Manager (Fidel): Manages overall daily operations under the direction of the Shachou.
30 • Assistant General Manager (Muiz): Assists the General Manager in overseeing and coordinating cross-departmental operations. 2. Marketing, QC, and Production Line (Led by Zulik) This division focuses on commercial operations, quality assurance, and production readiness: • Sales & Marketing (Ulan, Ghesa, etc.): Manages sales workflows, client relations, and product marketing strategies. • IATF (Rika): Responsible for compliance with automotive industry quality management standards (IATF 16949). • QC (Quality Control): Ensures the quality of manufactured goods aligns with established standards. • Dies (Andris & Wawan): Handles technical maintenance and tooling of dies that support the production line. 3. Administration, Finance, HR, GA & IT Line (Led by Aris) The operational support system is divided into two primary tracks: • HR, GA, IT & HSE (Sonny, Angga): o HR & GA: Manages human resources, general affairs, and facility operations. o IT: Ensures the smooth operation of internal information systems and network infrastructure. o HSE: Maintains health, safety, and environmental standards. • Finance, Accounting & Tax (Eri, Defi, Ajeng, Sopi, Lucky): o Finance & Accounting: Handles cash flow, daily financial transactions, and bookkeeping. o Coretax & Tax: Dedicated to handling tax reporting, administration, and compliance. 4. Daily Operations & Procurement • Supervisor (Sulis) & Operations (Anna): Oversee daily technical execution and coordinate cross-functional operational needs.
31 • Purchasing Order (Wati): Manages procurement processes based on production and operational requirements. 5. External Relations & Support Services (Left Column) The HR/GA team coordinates external relations and facility management with third parties, including: • Security & Transportation: Security personnel and Drivers. • Government & Legal Agencies: Ministry of Investment, Ministry of Trade, Ministry of Industrial, Ministry of Environment, Tax Officer, Immigration Officer, Ministry of Manpower → Both central and regional are fundamentals • Community & Associations: Local organizations (GMPI Karawang), Suryacipta HR Association, Automotive Industry Associations, and residential accommodation (Rent Apartment), All supplier Muiz is not the primary operational lead. the central figure is Sulis. Sulis was directly trained and mentored by Happy, who developed her capabilities to where they are today. Regarding career advancement, the General Manager rapidly promoted Muiz. Nevertheless, Key Performance Indicators (KPIs) prove that Sulis is the true center of competence, handling critical responsibilities such as creating the Monthly Production Plan (Getshudo). Meanwhile, the HR division operates within the financial realm by distorting data, information, and invoices, while Zulik controls Production and ISO, directly overseeing 90% of the production workforce. The investigation findings reveal fraudulent invoices, price manipulation, and the withholding of official company deeds. A General Manager's primary duty is to direct business activities to prevent financial losses; however, my analysis indicates that General Manager Fidel Castro is virtually absent from email correspondence regarding labor disputes, tax matters, or supplier audits. Furthermore, IATF and all suppliers are his personal friends or close relations.
32 INVESTIGATION FINDINGS (Digital & Cyber Forensic Investigation) I used to work for Tour and Travel sector affiliated with JTB Tours in Tokyo, working alongside with Indonesian staff and Japanese staff. That was positive, professional
33 experience stands in stark contrast to the environment at PT. Meidoh Indonesia, where intimidation, aggression, and personal attacks originate directly from the individuals in whom you have placed your trust. A number of production employees has resigned and a similar trend of forced resignations is being experienced by numerous other staff members. E.g Laboratory personnel from Owari Group and he decided to leave end of August 2026 was even explicitly requested to resign by Mr. Zulik Ihwanudin . Upper management appears to have been entirely monopolized by Mr. Aris, Mr. Fidel, and their inner circle. Indications suggest that certain Japanese expatriates are fully aware of this situation yet deliberately choose to turn a blind eye. Former Owari staff member, Ms. Upi, who possessed an exemplary performance record, managed to stay for only 4 months due to an unbearable working environment and intimidation from Mr. Aris. Meanwhile, Mr. Aris himself carries a history of unresolved issues and scandals within the Suryacipta HR Association everyone questions abt his job. Ironically, based on internal findings 3 Japanese expatriates conduct Indonesia are suspected of colluding with Mr. Fidel, Mr. Aris, and Mr. Zulik and he approved ething. Mr. Fidel is evaluated to lack sufficient operational capability and Ms. Sulis (previously trained by Mr. Happy).
34 This pattern raises serious concerns regarding potential abuse of authority aimed at appropriating the assets of PT. Meidoh Indonesia. As the owner of the company, do you not feel empathy for the loyal employees who have contributed dedicatedly and healthily, only to have their aspirations of building a strong enterprise crushed simply due to Japanese language barriers? VENDOR SUPPLIER STEERING The Director of Jaya Gas Mr. Pugar called me, He informed that Meidoh S.A force the employee of supplier Jaya Gas to acknowledge amount that H received per month. He kept saying. H never ask for the money. S.A Meidoh didn’t believe it. He asked multiple times so Mr Pugar called H and H said to Mr Pugar just ignore it. Afterwards, Supplier Jaya Gas replace to another supplier and due to H warn to Presiden Director : ‘ why did you approve it? This was risky please replace to the previous one. There’s no feedback at all, few months later. The contract with Jaya Gas officially started again DIGITAL EVIDENCE DESTRUCTION Year 2015 Case I JAYA GAS (Supplier) – Defamation & Accusation Div. & Name HR.GA – Sonny Ardinata – Cousin of Fidel Year 2018 Case II SoftBank Jakarta Div. & Name HR.GA – Irfan Cousin of Aris (refers to email below)
35 Thursday, July 26, 2018 at 16.16pm : The renewal of the 45 Google Email accounts was finalized by SoftBank. Upon completion, SoftBank requested the execution of a Certificate of Completion. Siti was awaiting the form, Irfan instructed that it be signed and company stamped in advance → Investigation find out the terms of signature workflow at PT. Meidoh Indonesia without stamp in advance. Monday, July 30, 2018 at 14.04 pm : Softbank sent a follow-up email inquiring about the status of the form of completion, which has not yet been received for signing
36 Given my background in law, this pattern is clearly criminology studies that glaringly obvious and easy to decipher. SoftBank followed up after their previous email in July to inquire about the Google email renewal. It is strongly suspected that Sonny Kalakso called SoftBank to request a price markup by phone (verbally) and the stamp asked for scanned to computer and editing to manipulate the data for the price. Once inflated, the invoice was presented to the President Director. Investigation findings from 2018 reveal that upon seeing the excessively high price, Mr. Soleh from SoftBank applied the markup at Sonny Kalakso's request. When this price was submitted to Mr. Mizutani, it was predictably rejected. The revised quote was subsequently resubmitted through Irfan, who inquired, 'What is this?' Mirroring Mr. Mizutani’s exact reaction. Mr. Soleh responded on email Pak Sonny Kalakso lebih tau that means Sonny knew precisely
37 what it was and contract termination. (Kindly be advised to find the attachment of conversation)
38 In 2020, Happy reported an issue to the President Director regarding email outages and missing emails, specifically critical communications from the government. Mr. Mizutani confirmed that several emails had disappeared, including those from the 'All Items' folder. Upon inspecting the matter at her request, I informed her that the email service was no longer provided by SoftBank, having been migrated to a budget provider typically suited for Micro, Small, and Medium Enterprises (MSMEs). We personally visited the provider's office after the account happy@meidoh.co.id was forcibly compromised and taken over by HR IT Dept. Although H escalated this issue to the President Director, the matter reached a deadlock as system administration was governed strictly by the IT Department. Drawing on my prior experience as an IT Helpdesk Support for a Dutch enterprise in Bali for 2 years in 2011, I accompanied to Rumah Web during pandemic, Ive known NTT, Softbank which elaborate with the previous company. This provider caters to small-to-medium businesses rather than international corporate standards. However, the IT staff merely redirected us to contact Eri. Today, I attempted to retrieve the pricing details for these internet service payments through Mr. X, who previously worked with the HR IT Acct GA dept, he resigned in 2025 and kindly please find the organizational structure.
39 From SoftBank's office in Jakarta's to Yogyakarta (located 512 km from Suryacipta, Karawang). Back in 2016, while managing my e-commerce business. Rumhweb is a platform popular among Small Enterprise home scale and I used their services. During that time, I accompanied H to meet with the Finance and IT departments to investigate an issue regarding her emai was unable to access. Mr. X informed her Angga’s friend that there were numerous fraudulent invoices and revealed that every employee has company. PT.Dwitia belongs to Angga (fake invoice)
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42 Jababeka is a pioneer industrial park and this where we received an order for garment industry export to Australia, UK etc previously secured numerous orders for the garment industry, building a strong network with companies such as Mattel Group, Epson and others. I believe Suryacipta appointed Jababeka for the UKL-UPL project precisely because of its reputation as a pioneer in Indonesia's industrial sector. I strongly suspect and conduct, with 99.99% certainty, that Aris called Diana from Jababeka to ask for assistance regarding price commissions and the manipulation Year 2018 Case III JABABEKA UKL UPL Div. & Name HR.GA.ACCOUNTING.IT – ARIS
43 of a cancelled form. This is what prompted Diana to respond so firmly via email, advising them to seek another vendor. The operation involved deliberate misdirection and camouflage (drama). However, during the course of my investigation over the past several days, I found no record of any email correspondence from the General Manager neither to acknowledge the decision nor to seek clarification regarding its cancellation supplier.
44 SUPREME RULING COURT Year 2022 Case IV Scrap PT. TENANG JAYA vs PT. Meidoh Indonesia Div. & Name Happy’s reported to President Director Nakashima
45 PT. TENANG JAYA VS PT. MEIDOH INDONESIA (This verdict it can be access on http://putusan3.mahkamahagung.go.id) Having studied The verdict is formally defective PT. Meidoh Indonesia and PT. Tenang Jaya. The judges refused to declare it final and binding (inkracht). Exercise extreme caution with any fee demands, this entire case shows clear signs of collusion. How could a lawyer draft a lawsuit so poorly on the merits that it gets dismissed as obscuur libel?
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47 LSM GMPI History of GMPI GMPI stands for Gerakan Militansi Pejuang Indonesia (Indonesian Fighters' Militancy Movement), founded by H. Muhammad Sayegi Dewa Sena. Dewa Sena himself was previously a local businessman who ran for Regent in 2023 for the 2024–2029 term, but failed to get elected. Running for Regent in Indonesia requires substantial political funding through the Regional Representative Council, involving a significant financial cost. Consequently, after failing to be elected, Dewa Sena returned to business with his remaining funds. Driven by concern over unemployment, he initiated the establishment of a mass organization (Organisasi Masyarakat). Later, he supported local political elections in the Karawang region. 2024 : As the general chairman of GMPI, Sena voiced his readiness to oppose policies enacted by the Regional Representative Council. 2025 : GMPI member Pipik Taufik Ismail was elected to the West Java Provincial Regional People's Representative Council (DPRD). 2026 : GMPI was reorganized and centralized the team member and centralized Dewan Perwakilan Pusat (source: https://dewasenanews.id/gmpi-lakukan-reorganisasi- dpd-karawang-dilebur-ke-dpp) In Indonesia, Mass Organizations (Organisasi Kemasyarakatan or Ormas) are governed and protected by Law No. 17 of 2013 on Mass Organizations, as amended by Law No. 16 of 2017 (which enacted Government Regulation in Lieu of Law No. 2 of 2017 into law). At the constitutional level, the existence and protection of Ormas are grounded in Article 28E Paragraph (3) of the 1945 Constitution of Indonesia, which guarantees that "Every person shall have the right to the freedom of association, assembly, and expression of opinion.
48 PT. MEIDOH INDONESIA In following of Verdict NO Supreme Court Ruling statement by Sonny Kalakso as HR-GA-IT-Finance Department Investigation Findings, 1. After the ruling was dismissed by the judge with an Niet Ontvankelijke Verklaard (NO / inadmissible) verdict, this lawsuit can still be reopened at any time under the competent judicial court procedure. Investigation findings, collected valid information informed that the procedural disposal of scrap was weighed at the security post before being loaded onto vehicles and transported away. 2. Aris is an affiliated with GMPI 3. Scrap waste disposal is handled directly by Aris, which is an open secret among the factory workers. However, no one can do anything about it because almost all factory employees are under the control of Iwan Zulik. 4. Please refer to my conclusion on the last page 5. Aside of this Court Rulling in 2022, There was another ruling court recorded in 2022 which I noted There was no Aoyama Fastener Joined
49 The title : Opposing the Regional People's Representative Council's (DPRD) decision regarding the minimum wage for workers under the automotive association, even though upon checking, the association turned out to be unverified by the state.
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51 ZULIK IHWANUDIN OWNS THIS COMPANY & HE’S AS Q/C MKT MEIDOH ESTABLISHED IN 2022
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59 INVESTIGATION FINDINGS PT. RAJA TEKNIK MANDIRI Year Chronology of Facts 2017 Zulik Ihwanudin had an order for plastic hose that was supposed to be processed for the supplier. → this was totally acceptable depends on the Policy of The Enterprises, hence let’s examine these methods as follows : 2018 Slowly but surely, Zulik replaced existing employees with staff chosen by Zulik and Aris. 2022 (recorded on Ministry of Human Rights) PT. RAJA TEKNIK MANDIRI was incorporated and approved by the Ministry of Law and Human Rights → Where did the capital and machinery to operate the business come from? What about PT. Meidoh’s trade secrets? Meanwhile, he lives in Tambun, where his financial situation was a matter of concern. Some of my relatives and family lives in Tambun this is the strongly reason for raising these points in terms of Financial source. 2024 – 2025 As she heard, President Director Yamauchi-San forced to sign the contract by Zulik Ihwanudin, Yamauchi-San need evaluate but he forced (Investigation Finding verbally by ex-employee) . Oct 2025 Owari Seiki Indonesia Appx 12 staff moved to Meidoh Indonesia ,
60 Tentative either Acquisition or Merger. 2026 Owari Staff who worked for Production division forced to resignation by Zulik Ihwanudin 2026 Lab Production Staff forced to resign by Zulik Ihwanudin, As of my Investigation findings, Owari staff in charge at Lab and He will be leaving end of August 2026 2026 The Investigation Findings high turn over employee at factory 85% hired by Iwan Zulik and Aris. Require investigation which year Investigation findings TUV repaced to SAI Global, SAI Global in Indonesia IATF ISO named Mr. Fata Antariksa is a friend of Zulik Ihwanudin. Investigation Finding result in 7 August 2026.
61 CASE TAXES USING CONSULTAN PT. MEIDOH INDOENSIA Upon passing the certification examination, tax consultants become members of a professional tax association and are granted an official practice license by the Ministry of Finance IKPI (Ikatan Konsultan Pajak Indonesia), AKP2I (Asosiasi Konsultan Pajak Publik Indonesia), PERKOPPI (Perkumpulan Konsultan Pajak Publik Indonesia). Using Tax Consultant in Indonesia has Advantages (Pros) and (Cons) as follows : Disadvantages (Cons) 1. Service Costs Hiring a tax consultant incurs extra expenses (whether through a monthly retainer or project-based fees). For MSMEs or individuals with simple transactions, this cost can be significant. 2. Risk to Financial Data Privacy The process requires sharing financial statements and internal transaction data. Working with an unproven or unprofessional consultant may pose a risk to your data privacy. 3. High Dependency Over-relying on a consultant can prevent your internal team from developing a basic understanding of your own business's tax health and compliance. 4. Varying Quality and Reputation Not all consultants offer the same level of competence or integrity. Hiring an unlicensed or unverified consultant can lead to compliance issues or complications with tax authorities.
62 Advantages (Pros) 1. Time Efficiency & Business Focus Managing tax affairs (calculations, reporting, and filing) is time-consuming. Delegating these tasks to a consultant allows you and your team to focus on growing your core business. 2. Minimizing Errors & Penalty Risks Tax regulations are complex and frequently updated. Tax consultants possess deep regulatory knowledge, reducing the risk of calculation errors or late filings that lead to fines and administrative penalties. 3. Legal Tax Optimization (Tax Planning) A tax consultant can help design legal tax strategies (tax avoidance) to lower your tax burden efficiently without violating tax laws (tax evasion). 4. Assistance During Audits or Disputes In the event of a tax audit, corrections by tax authorities, or an appeal process, a consultant can represent you and bridge communication between you and the tax authorities. 5. Access to Expert Insights You gain expert advice regarding the latest tax incentives, exemption facilities, and business transaction restructuring to remain tax-efficient. CHRONOLOGY OF TAX EVENTS (source : Kindly open page 76-77 and website on footnote) 2014 PT. Meidoh Indonesia recorded under Madya Tax Office (regional) 2026 PT. Meidoh Indonesia relocated to PMA 2 Office located in Jakarta, Assigned by Director General of Taxes LEGAL BASIS AND DESCRIPTION 2026 I visited to Tax Office to proceed MCRI, The staff informed me without any requested, PT.Meidoh Indonesia has
63 relocated to PMA2 and the tax officer explained the reasofor migrate to PMA2 due PT. Meidoh Indonesia conduct didn’t do compliance to Government for the specification the tax officer informed “PT Meidoh Indonesia requested Pendahuluan Pajak without Penelitian Pajak” and I Informed PT. Meidoh Indonesia using Tax Consultant and the officer informed “If PT.Meidoh Indonesia is under review, the tax consultant will not be subject to state sanctions”. Legal Basis Law on General Provisions and Tax Procedures (UU KUP), namely Law No. 6 of 1983 as amended several times, most recently by Law No. 7 of 2021 on the Harmonization of Tax Regulations (UU HPP) EXPLAINATION on LEGAL BASIS Penelitian Perpajakan (Administrative Verification) Article 1 point 27 of the Taxes Law : Stipulates the definition of Verification (Penelitian), which is a series of activities conducted to assess the completeness of the Tax Return (SPT) filings and their attachments, as well as the correctness of the writing and mathematical calculations. Article 43A of the Taxes Law: Regulates preliminary investigations when there are indications of tax crimes before proceeding to the formal criminal investigation stage. Article 43 of the Taxes Law: Stipulates that criminal/legal tax sanctions can also be imposed on parties who order, incite, or assist in committing tax crimes (including tax consultants if proven to be involved). Minister of Finance Regulation (PMK No. 175/PMK.01/2014): Regulates administrative sanctions (written warnings, license suspensions, up to the revocation of practice licenses) for tax consultants who violate the code of ethics or tax regulations.
64 FINAL CONCLUSION OF INVESTIGATION FINDINGS Criminal Tactics and Divide and Rule Strategy Divide et Impera This matter should not be viewed solely as an ordinary civil dispute, operational inefficiency, failure of Kaizen, management incompatibility, or a conventional industrial relations problem. Based on the findings below, there are indications of a coordinated scheme designed to create circumstances that could facilitate the unlawful transfer, concealment or control of corporate assets through a series of planned tactics. 1. Exploitation of Corporate Trust (Shinrai) The alleged actors exploited the Japanese corporate governance environment, which places significant emphasis on trust and personal relationships, to minimize formal scrutiny and establish extensive internal control over daily workflows without immediately triggering suspicion from the parent company. The culture of trust was allegedly used to reduce independent verification, allowing certain individuals to exercise disproportionate control over operational, financial, personnel, supplier and administrative processes. 2. Communication System Migration and Alleged Destruction of Historical Records In 2020, the company’s email system, which had previously used SoftBank, was allegedly transferred to RumahWeb. The investigation indicates that this transition resulted in the permanent loss or disappearance of email channels
65 belonging to the President Director in 2020 and Advisor’s email who possessed important historical records concerning PT. Meidoh Indonesia. Technical access to the RumahWeb system was allegedly restricted, except through direct communication with the designated office PIC. Email and Password belongs to Advisor has changed and unable to use it during pandemic covid but recovery and reinstalled again after few months. Investigation shows the location rumahweb situated in Yogyakarta which is very far from Karawang the distance appx 518kms, the question arise if this is personal concern to marked up the price, why they didn’t choose another supplier in Jakarta instead of Yogyakarta (Central Java) in business ? For your information Yogyakarta district has special regulation this is the reason Yogyakarta following with Daerah Istimewa, the autonomy of Yogyakarta managed by Sultan Hamengkubuwono, President under President. This is concerning of Law of the Republic of Indonesia Number 13 of 2012 on the Special Region of Yogyakarta's Special Status (Law No. 13/2012) grants Yogyakarta its legal framework for special autonomy within the Unitary State of the Republic of Indonesia. (source: kindly open Page 39) 4. Manipulation of Corporate Data and Company Information The investigation findings that operational, administrative, financial, personnel and other corporate data may have been manipulated or selectively presented in order to create a misleading representation of the company’s actual condition. Such alleged manipulation may include:
66 • Altering or selectively presenting corporate data. • Controlling access to company records. • Withholding information from legitimate corporate decision-makers. • Creating inconsistent versions of documents or records. • Manipulating operational or financial information. • Using incomplete information to influence decisions by the parent company. • Creating an artificial documentary record that could later be used to justify actions already taken. The alleged manipulation of data is particularly significant because it may have enabled the concealment of transactions, conflicts of interest, personnel decisions, and other activities from the legitimate owners or authorized representatives of the company e.g. Bank. 5. Acting in the Name of the Company Without Proper Authorization (it refers to excel attachment in accordance OSS System) The investigation also raises concerns that certain individuals may have acted in the name of PT. Meidoh Indonesia, representing the company to employees, suppliers, consultants, government institutions, external parties, and other stakeholders without appropriate authorization or without adequately disclosing the limits of their authority. The alleged misuse of the company’s name could have been used to : • Make representations to third parties.
67 • Execute or facilitate transactions. • Communicate instructions as if they originated from legitimate corporate management. • Influence government or administrative processes. • Create obligations or liabilities for the company. • Legitimize actions that were allegedly undertaken for the benefit of particular individuals or groups rather than for the legitimate interests of the company. 5. Conduct Conspiracy to Government and Third Party The actors reportedly developed relationships with consultants, public notaries, third party vendors, and potentially certain public officials through improper practices. This network of alleged gatekeepers was reportedly used to influence or control administrative, legal, licensing, personnel, and operational channels outside the company. If substantiated, such conduct could have enabled the alleged network to control the flow of information between PT. Meidoh Indonesia and external institutions while limiting the ability of the legitimate owners or authorized representatives to independently verify corporate activities. 6. Structured Intimidation, Internal Intelligence and the "Savior" Scenario (Conspiracy) The investigation indicates that the causes of high employee and driver
68 turnover may have been progressively concealed since before 2015 in order to avoid attracting suspicion. The previous driver in few years ago reportedly used the driver A,B,C assigned to the President Director to gather internal information and influence or direct the President Director and offer for entertainment Blok M area of South Jakarta and Play Gold. This is normal and the question raise from HR’s community affiliate to HR Forum Suryacipta Karawang “Whats actually HR position at PT. Meidoh Indonesia meanwhile the fee for playing golf costs at IDR. 3.000.000,-.” The investigation further alleges that certain organizations and ormas GMPI (refers to page 47) personnel were used to intimidate employees and Japanese nationals who opposed or questioned particular business activities. e.g Ito-san had incident there was someone sneaked him at Apartment. Due to Ito-san has analytical thinker and debate with HR. According to the alleged pattern, situations of danger or conflict were created or amplified, after which the General Manager / HR appeared as a "savior", thereby strengthening personal dependence, sympath, and trust toward the General Manager. 7. Divide and Rule Strategy Between Japanese Employees and Internal Personnel A significant element of the alleged scheme involves a divide and rule (divide et impera) strategy between Japanese employees/management and Indonesian internal personnel. The alleged strategy involved manipulating information, selectively communicating issues, creating misunderstandings,
69 and presenting different versions of events to different groups within the company. The objective of such alleged conduct would be to: 1. Create distrust between Japanese management and Indonesian employees and isolate employees who questioned management decisions. 2. Portray certain employees as disloyal or problematic. 3. Prevent employees from communicating directly with Japanese management and create internal factions. 4. Discourage collective reporting of irregularities and maintain centralized control by preventing employees from forming a unified understanding of the company’s actual circumstances. The alleged manipulation of communication between Japanese personnel and Indonesian employees is particularly relevant because it may have prevented the legitimate owners and Japanese management from receiving accurate and complete information concerning internal operations. (kindly find the next document which title ‘Happy’), Thank you. 8. Manipulation of Employment Documents and Misuse of RPTKA/Work-Permit Processes The network reportedly prepared employment contracts and supplier agreements containing legal or procedural deficiencies, potentially creating a "legal trap" intended to weaken or defeat future employee claims before the Industrial Relations Court (PHI).
70 President Director signed the contract as a Human Resource Department. If substantiated, such conduct could constitute an abuse of delegated authority and could potentially expose the company to regulatory sanctions, licensing consequences, or other governmental measures. The alleged strategy appears particularly concerning because violations may have been deliberately created or accumulated and subsequently used against the legitimate business owners as a basis for complaints to the Ministry of Manpower or other government institutions. (refer to Happy’s case) 9. Falsification or Misrepresentation of Professional and Educational Credentials The investigation reportedly identified concerns regarding the General Manager’s claimed educational background, including an allegation that the General Manager could not be located in the relevant university records corresponding to the qualification previously claimed. The investigation also raises concerns regarding the selection of certain key personnel whose educational backgrounds may not correspond to the qualifications ordinarily expected for their respective positions, including: • HR personnel reportedly holding a D3 qualification in Business Administration. • QC/Marketing personnel reportedly holding an SMK-level qualification without a directly relevant educational background. These matters require independent documentary verification before being
71 characterized as established falsification. 10. Self-Dealing, Allegedly Fictitious Suppliers, and Conflicts of Interest The investigation identified several companies allegedly connected to employees or members of the internal network that were appointed as official suppliers of PT. Meidoh Indonesia. There are allegations that supplier prices were substantially manipulated above prevailing market prices (price-fixing or inflated pricing), potentially creating financial benefits for individuals or entities connected to the internal network. If substantiated, these transactions may represent significant conflicts of interest, self-dealing, abuse of corporate authority, and potential misappropriation of corporate funds. 11. Manipulation of Financial Data, Inventory Mark-Ups, and Potential Money Laundering Indicators The investigation identified allegations of manipulation of financial and operational data, allegedly taking advantage of gaps or weaknesses in internal regulations and corporate controls. Specific indicators reportedly include: • An alleged scheme involving the sale of a company vehicle/inventory asset valued at approximately IDR 550,000,000 in which the official price recorded in the company’s books was allegedly reduced or manipulated. • Potential concealment or diversion of the difference between the actual
72 transaction value and the value recorded in the company’s accounting records. • Significant increases in personal assets during the 2022–2024 period that allegedly appear disproportionate to known income sources, including the General Manager’s reported acquisition of property valued at approximately IDR 2–3 billion and the reported acquisition by the HRD of two luxury vehicles (including a Mazda CX-series vehicle and a Toyota Fortuner). These circumstances should be subjected to a formal forensic accounting investigation, including source-of-funds analysis, bank-record tracing, beneficial-ownership analysis, tax-record verification, and reconciliation with company transactions before any conclusion of money laundering is legally established. 12. Alleged Concealment of Knowledge and Cooperation by Five Employees The investigation further identifies five employees who are alleged to have been aware of, or to have had knowledge concerning, the practices described above but failed to report them to the legitimate management or owners. There are also indications that these five individuals may have cooperated with or facilitated certain activities associated with the alleged internal network. Their respective roles, knowledge, communications, financial relationships, instructions received, and actions should be examined
73 separately. The names and specific involvement of these five employees should be cross-referenced against the findings contained in the Excel investigation file, including relevant dates, transactions, communications, document trails, witness statements, and other supporting evidence. Important: This section should be finalized only after the Excel investigation file is reviewed and the evidence supporting each individual’s alleged knowledge or cooperation is independently verified. 13. Political Purge, Employee Removal and Role Obfuscation The alleged conspiracy reportedly targeted individuals who were vocal, independent, or capable of challenging internal practices. One example reportedly involved an Accounting employee/former Owari employee who was allegedly forced to resign within only one day. The alleged dismissal or removal process was reportedly structured in an ambiguous manner to obscure the underlying reasons and separate decision-makers from the consequences of their actions. This alleged role obfuscation could have been designed so that, if a future law-enforcement investigation occurred, individuals who allegedly directed or benefited from the conduct could appear merely as ordinary witnesses rather than as potential principal actors, facilitators, or beneficiaries. 14. Illegal Asset Control and Potential Corporate License-Freezing Strategy
74 The alleged ultimate objective of the scheme appears to involve the unauthorized control, diversion, concealment, or appropriation of corporate assets and the systematic accumulation or use of evidence of regulatory violations. Through the alleged misuse of powers of attorney and corporate documentation, the network may have accumulated or generated records of regulatory and legal violations that could subsequently be reported to relevant government ministries or authorities. The alleged objective would be to trigger governmental sanctions, suspension or freezing of business licenses, or other regulatory measures capable of weakening the legitimate beneficial owners of PT. Meidoh Indonesia (namely the Hasegawa family) and potentially disrupting or paralyzing the company’s legitimate operations. FINANCIAL LOSS AND ASSET CASES The term whistleblower originated in the 18th century and implemented in United State legislate the Whistleblower Protection Act in 1978. In Japan, The regulation of whistleblower protection have become more significant well structured. According to research and personal experienced, Japan has a series of major
75 corporate scandals in the early 2000’s e.g. Mitsubishi Motors scandal involving the concealment of product recall information. Many scandals happened in Japan started early 2000 became major public issues after employees and business partners reported improper business practices. In response to these Incident, Japan enacted for very first time Whistleblower Protection Act in 2004. Despite this legislative framework, corporate misconduct continued the emerge e.g. Toshiba’s downfall began in 2015 when accounting malpractices in various divisions were revealed, many of which involved top management. Toshiba manipulated its financial statements by overstating the company’s profits by 1.25 Billion Japan Yen (currency in 2015 equivalent at IDR. 24.79 Trillion). In 2020 it was reveled that Toshiba had engaged in fraudulent accounting practices. A year after ini 2021 Investigation found that Toshiba had colluded with Japan’s Ministry to Trade. The Toshiba case illustrates the influence of Japan’s traditional corporate culture whereby reporting corporate misconduct is often perceived as an act of disrespectful toward Top Management. As a result, organizational control is strongly influence by hierarchical relationship. To strengthen whistleblower protection the Japanese Parliament subsequently revised the Whistleblower Protection Act requiring companies in Japan to establish effective internal whistleblowing system with the revised provisions effectively on 1st June 2022. Furthermore Law No. 62 of 2025 amending Act No. 122 of 2004 effectively on December 2026. In Indonesia, Until Today 31 July 2026. There is no standalone legislation that specifically
76 governs whistleblowing. The existing legal framework is still adopted influenced by regulation inherited from the Dutch colonial period with combination of Jurisprudence and in every regulation has Lacuna which means a formal legal in jurisprudence to describe a black space, gap or missing provision is a set of laws. e.g Tax Laws with 2 cases with different stakeholder company. (Case 1 – Refund VAT Tax Bribery Case) in February 2026 PT. Buana Karya Bhakti (BKB) operates nature of business in Plantation sector. This case began with a VAT restitution application by a taxpayer in 20241 with following details : • PT. Buana Karya Bhakti submitted a request for VAT Restitution (refund) for tax year in 2024 with overpayment status. • The Restitution application is submitted to the Banjarmasin Madya Tax Office. • The Tax audit team conducted an audit one of which involved tax officer named is D.J.D works at Banjarmasin Madya Tax Office. • The Tax Audit team conducted an audit, one of which involved tax officer D.J.D. • The examination results shown overpayment amount at IDR 49.49 Billion, Fiscal Correction at IDR 1,14 Billion, Approved Restitution Value at IDR 48,3 Billion. • Allegations of manipulation in the restitution process. 1 Saksi Kembalikan Rp9,5 Miliar, KPK Dalami Aliran Dataxna Kasus KPP Madya Banjarmasin KPK
77 • Allegations of receipt by individuals within Banjarmasin Madya Tax Office. • Finance Manager, PT. Buana Karya Bhakti suspected and detained by the Corruption Eradication Committee in February 2026. • Head of Banjarmasin Tax Office Madya, 2 Officer has arrested and detained by the Corruption Eradication Committee in February 2026. (Case 2 – As a witnesses following Case 1) in April 2026, PT. Energi Batubara Lestari has nature of business in coal mining, logistics, trading etc. The market segmentation are Thailand, China, India, Chile and Slovenia. The company registered under Hasnur Group (Holding Ltd) Public Equity and this company belongs to conglomerate business groups and the company is popular in Indonesia. The case as follow2s : • PT. Energy Batubara Lestari has submitted for restution at the same Madya Tax Office. • PT. Energi Batubara Lestari assigned Tax Consultant. • Internal employee for PT. Energy Batubara Lestari whose dealing with Tax Consultant. • The Corruption Eradication Commission (Komisi Pemberantasan Korupsi / KPK) investigate employee and tax consultants of the Hasnur Group coal mining company regarding alliged corruption in the submission of Value 2 KPK Periksa Pegawai Hasnur Group Terkait Kasus Suap Pajak Banjarmasin
78 Added Tax (VAT) restitution at Tax Office Madya Banjarmasin where same place. • Hasnur Group and Tax Consultant as a witnesses, The KPK Investigate with several queries regards of tax refund. • The Investigation is still on going as part of the tax refund investigation. Despite Lacuna, Tax Laws provide exemptions and impose sanctions for manipulation and non compliance. Normatively in Jurisprudence, The Tax Authorities has the authority to file a bankruptcy petition and has priority rights over tax debts and calculate restitution to pay off tax arrears before the overpayment is disbursed. Thank you