What guarantees do "the history of the TSE" and "consulted with" provide?
"There are people who have been involved in listing reviews at the Tokyo Stock Exchange," "I have consulted with the Ministry of Economy, Trade and Industry," "I have also consulted with the police's Organized Crime Unit." When these words are strung together, they sound reassuring. But what you really want to know is not the prestige of the institutions mentioned in the names, but who explained what, what work was done, and where the rewards were received.
This time, the Last Mile Labor Union is asking for answers from Asane Co. CEO Mr. Yoshiaki Uejido and Mr. Satoshi Saito, who was in charge of the Last Mile’s day-to-day operations. There are doubts regarding the business relationship between the two, the explanation of their respective positions to their respective companies, the channels of contracts and compensation, and the sharing of information. I would like to know specifically whether this was a matter of cooperation between certified public accountants, or whether there were any additional tasks or financial flows that were omitted from the explanation.
Next, there is the incident in which Sir Kichiku of Nakano spoke of consulting the police and inquiring with the Ministry of Economy, Trade and Industry about the Angel Tax system. If we could add the names of the people consulted one by one, the number of questions about the actual actions would not decrease. On the contrary, if we did consult, there would be more records to check and more information to be explained.
Mr. Hirofumi Uehashi's history of working at the Tokyo Stock Exchange is public. Next, please explain the actual work.
Regarding Mr. Hideo Ueki, Ashenine saidCompany announcement dated November 28, 2024In it, they describe him as the "Executive Officer, Head of the IPO Promotion Office, and Chief Financial and Accounting Officer." This is a person whose duties related to IPO preparations and finance and accounting are publicly announced by the company itself.
Also,The person's public profileThe document describes that in 2011, he joined the current EY New Japan Limited Liability Audit Firm and engaged in auditing and listing support; from 2017 to 2019, he worked at the Listing Review Division of the Japan Exchange Group; after that, he returned to the audit firm and joined Asane in 2021.
What can be confirmed here are the published details. The profile does not include details such as that Mr. Oeido was responsible for the final mile listing review or that he supported the company on behalf of the Tokyo Stock Exchange. Therefore, it is necessary to separate the details of his position at the time, the period in which he was involved, and the work he performed.
It is valuable for experts who know the procedures for listing companies to assist companies in their preparations. If they can explain the value directly, the client, contract, deliverables, remuneration, and necessary approvals should also be explained in the same way. If the only section of the resume is highly detailed and only the job description section is detailed, it will be difficult for both the client and the employee to understand.
A career of "knowing about the review process" should be used to ensure that the necessary explanations for the review are accurately prepared. It is not a career of thinking about what could be done without explaining anything. Mr. Oeido would like you to first present, in your own words and records, how you used that experience to be involved in the last-mile work.
What was the explanation given to whom regarding the business and compensation handled through Saito Goshi-shi?
In the survey and request for responses published by the union, Saito points out that, at the time, he had involved Wudou, who was then affiliated with EY New Japan, in last-mile operations without explicitly informing his former employer. He also requests an investigation, citing information that Saito was not paying Wudou directly from the company but was distributing the proceeds from the compensation Saito received.
In the same public post, they are also seeking confirmation regarding the acquisition of information related to audits and listing reviews, and the possibility that this information was shared with Mr. Nobuaki Watanabe. Both of these matters are raised as matters that should be verified based on the actual operations and records.
What is needed to answer this question is not just an explanation of the relationship of "cooperation among acquaintances." Who commissioned the work, and who bore the costs? What did Saito compile, and what did Eto handle? Did the company have a clear understanding of the actual workers and their payees? Please provide evidence of the relationship between these actions.
Even if the payment is made through Saito, the specific form of the transaction must be confirmed, such as subcontracting or joint responsibility for the work. Rather than deciding that it is illegal simply because it was made through someone else, it means examining the contractual roles, company approval, reporting to the company, and whether the actual work matches what was described in the official explanation. If the explanation was formally provided, you can provide evidence of that explanation and approval.
It is also important to determine whether Mr. Hiyou was in charge of the audit himself or provided support separate from the audit work. It is also important to clarify which information was accessed; stating that "I am an accountant, so it's fine" or "I was at an audit firm, so everything is illegal" does not provide a clear explanation of the situation.
What the union is asking for is not a reduction in the employee’s record, but the addition of additional information about the job. If the work was done at the company’s expense, make sure the company has someone who can explain the responsibilities and compensation. It’s welcome if there are two experts to help with the accounting, but if it makes it harder to figure out who paid for it, you need to verify it.
The term "tokuriu" refers to the actual conduct, not the title.
"Tokryu" is an abbreviation for anonymous and mobile crime groups.Police White Paper by the Police AgencyIt explains the characteristics of how the core part that collects criminal proceeds is anonymized, and how members who carry out the activities are rotated, among other things. This does not simply mean that multiple experts collaborated or that the person in charge of the work changed.
This article does not present any evidence that the police have determined that Mr. Oeido and Mr. Saito were involved in such criminal groups. The question posed in this article is specific to the details of the work that the two men carried out together, their involvement without explaining their affiliation to the company, inappropriate information sharing, and whether they cooperated with explanations that differed from the facts.
When discussing involvement in criminal groups, it is first necessary to determine what specific crimes were committed, who recognized their purpose and content, who shared in the profits, and who benefited. It is impossible to omit this verification based solely on the impression of a title; conversely, it is also impossible to dismiss verification on the grounds that a prestigious title justifies it.
Therefore, our union asks the two gentlemen to answer whether the work they jointly performed was properly explained and approved. A mere refutation of the term "Tocruu" is not sufficient to answer the questions about the contract and compensation. We would like you to confirm the facts asked one by one and indicate what is different if there is any difference.
If you want to use the fact that it’s a job for a publicly listed company and the involvement of an expert as a reassuring factor, you need to ensure that the content of that job also appears the same way. Even though the face photo and the resume are clearly visible, only the person in charge, the payer, and the source of the materials are visible. Don’t fill in such verbal gaps with company signage.
If you want to use your experience at the Tokyo Stock Exchange as a basis for your argument, please check what you explained to the Tokyo Stock Exchange.
The union previously questioned the consistency between Watanabe’s role as an outside director and his actual execution of duties. The article reports that, when asked for clarification during the listing review, Watanabe instructed Ishikawa Kokihei and Saito to stick to the explanation that he had always been an adjunct director.
Whether Mr. Hideo was involved in this particular answer should be confirmed with the person himself and the company. If he was working on IPO preparations, please distinguish whether he created which documents, checked which explanations, and was involved in which decisions. This is not meant to hold him responsible for work he was not involved in, but to identify the actual scope of responsibility.
If the expert assisted with the responses to the review, it is important to know what original documents and explanations were received from the company and how they were verified. Was the company’s explanation written down in its entirety, or was it cross-referenced with actual duties and decisions, and when discrepancies were discovered, were corrections requested? By reviewing the process, it becomes clear who made what decisions.
Furthermore, there is a clear difference between a person’s history of working at the Tokyo Stock Exchange and the work they perform on behalf of the exchange. There is a clear difference between using past employment experience as an explanation for professional skills and explaining that the current individual transactions have the approval and guarantee of the Tokyo Stock Exchange. If someone has made such an explanation, please check who, under what circumstances, and what they conveyed.
Please use the credibility of your professional experience to provide a detailed explanation. If you can introduce that the person involved is from the Tokyo Stock Exchange, you should also be able to answer what that person verified. The Tokyo Stock Exchange seal is not a certification stamp that allows individuals to freely engage in work they are interested in.
What did Sir Nakano explain to the organization crime countermeasures department when he was explaining what he had consulted with them about?
The union of prosecutors from the other media outlet, "The Wolf Union,"An article stating that Lord Nakano was talking to people about his relationship with the policeAccording to the same article, Nakano reportedly repeatedly mentioned his intention to establish close ties with the police by consulting with the Kagoshima Prefectural Police’s Organized Crime Countermeasure Division.
What this article indicates is that Mr. Nakano said that. It is not clear what information the police obtained, whether they discussed the joint work of Mr. Wado and Mr. Saito, or whether they discussed another issue. Without checking the details of the consultation, it is impossible to know what facts the police have gathered. This is the part where we ask those who heard Mr. Nakano’s explanation or those who are in a position to understand the details of the consultation.
If during the consultation, you mentioned last-mile delivery, Saito-san and Uedofuji-san’s roles, or the flow of compensation or information, then depending on who you consulted about which actions and which documents, what kind of meaning does it have? The meaning depends greatly on whether you were claiming damage against yourself or reporting the actions of others, or whether you were explaining business relationships.
The fact that the person in question spoke of "consulting" cannot be summarized in the same sentence as what the police heard, what they checked, and what they answered. Furthermore, it is necessary to verify how that answer was explained to those around them. If the person who accepted the consultation was simply saying that the business or transaction as a whole had been approved, then the explanation given by that person becomes problematic.
Consulting the police is a necessary action for people who are experiencing harm or anxiety. What we are asking here is whether the name of the person you consult was not used as a material to reassure another business partner or to keep specific questions from being asked. Consulting with the contact point is different from having the person you consult take on the role of the guarantor for the entire business.
Inquiries to the Ministry of Economy, Trade and Industry and the subsequent Angel Tax System incident have left questions
Regarding inquiries to the Ministry of Economy, Trade and Industry, the same thing was also reported by the media organization, the Prosecutor's Union.The information that Nakano inquired about the system before investing and recorded the answers to show them to the shareholders.This issue is also being examined in criminal cases surrounding the Angel Tax, as it is important to understand what kind of checks are carried out before an investment is made and how investors understand the content of those checks.
The Last One Mile Labor Union also reported that Saito and Nakano explained the system to Kono, and that they were involved in introducing investors and in the practicalities of investing. It is important to separate the people who explained what and who did what, and who knew what from those who explained it to investors.
If there is a history of the Ministry of Economy and Trade being consulted beforehand but then being treated as a matter of tax evasion later, it is important to verify without erasing the administrative inquiry record. Without examining the facts that were assumed in the question, the conditions under which answers were received, and the actual transactions that were conducted, it is impossible to accurately determine the perception of those who believed the explanation or the responsibility of the person who provided it.
Did they consult with the company to show the exact details of the transaction, and did they act in accordance with the administrative response? Did they present the general system explanation as an answer that guaranteed the transfer of funds even to the individual? Did the transaction terms change after the inquiry? These are different facts. Both of these are responses that ignore the fact that the “consulted” word or the completion of the verification with that word are not the same.
This point does not change regarding consulting with the police either. If there is a consultation, you can use that record to confirm specific facts. You do not need to print out only the name of the organization that consulted and make it smaller. What matters is not the size of the office’s sign, but the content of the consultation form.
As the person responsible for explaining the system, I would like Mr. Saito to explain whether the assumptions presented to the administration and the investors were consistent. I would also like Mr. Oeido to clarify the scope of his involvement if he was involved in related operations or information sharing. Rather than assuming involvement based on connections between individuals, it is necessary to record which jobs he participated in and which he did not.
The independence of certified public accountants does not mean working in secret to their employers.
Regarding the work of certified public accountants, the system provides clear direction. Article 1 of the Certified Public Accountants Act states as follows:
Certified public accountants, as experts in auditing and accounting, are tasked with ensuring the reliability of financial documents and other financial information in an independent position, thereby contributing to the sound development of the national economy by ensuring the fair business activities of companies and protecting investors and creditors.
An explanation of the independence of the Japan Institute of Certified Public AccountantsHowever, I explain to the auditor that in addition to an impartial attitude, they are required to avoid specific interests and any appearance of a conflict of interest. In practice, which discipline applies depends on the duties at the time, involvement in auditing, and the need to verify financial relationships.
What is needed to confirm this is the actual nature of the work and the compensation being requested. Whether the relevant parties are understood and whether necessary approvals have been obtained; how access to information and its provision to outside parties is managed. If the records are provided, it is possible to separate the parts that were appropriate work from those that require explanation or rectification.
Independence does not mean working independently without letting anyone know about your work. As much as possible, you should be able to have external parties verify your roles and interests. Just because experts know each other does not mean they know everything—from the company’s approval officers to the oversight authorities.
Regarding Ashenne, we will coordinate inquiries with the appropriate channel with Mr. Uejido himself, and we will also ask him to check, to the extent necessary, whether there are matters related to his current duties or the company’s information management. It is not possible to treat past work at another company as the entire conduct of the current workplace. Therefore, we would like to have him clarify to us exactly what part of his past work is his own and what part relates to the current company.
The purpose of this is not to list the current place of employment. We are asking those who have disclosed their listed history of being listed on the stock exchange or their financial history to answer specific tasks related to that history. This is separate from the fact that they have changed jobs and the fact that they no longer need to describe their past work.
Questions to companies related to Mr. Hideo Wado and Mr. Ryoichi Saito
The Last One Mile Union requests a response that distinguishes between the facts known and the basis for the judgment regarding the following matters. If there are matters that are not involved, please specifically indicate which parts are not involved. Please provide an explanation for responding to the question after properly handling confidential information and information from unrelated third parties.
Questions to Wafuda Yasuhya and Saito Goshi
- Are there any tasks that the two of you carried out jointly regarding the last mile? If so, please indicate the start date, the client, the contractual parties, the scope of work, the deliverables, the person responsible, and the reporting channel.
- Regarding Mr. Wado’s involvement, what kind of explanation or declaration did you make to the EY New Japan where you were employed at the time? If you have received the necessary approval and confirmation of independence, please explain the timing and scope of the matter.
- Is it true that the consideration paid to Mr. Hideo was distributed from the compensation received by Mr. Saito? If so, please indicate the source of funds, the reason for payment, the contractual position, and the approval of the company in that period.
- Did you share any information related to audits or listing reviews between the two individuals or with Last One Mile, Watanabe? Please explain the sources of the information, the rights of access, the purposes of use, and the existence of a consideration.
- Is there any evidence that the two individuals were jointly involved in accepting tasks without explaining them to their respective superiors, providing information without authority, or creating and submitting review responses that were inconsistent with the facts? If you deny the allegations, please provide a response based on the contract, approval, deliverables, and other verifiable facts.
- Do you understand that Mr. Oeido’s transfer to the Tokyo Stock Exchange Group was used to explain the last-mile delivery and the credibility of the related transactions? If there was a description that seemed to indicate that there was approval or guarantee from the Tokyo Stock Exchange, please clarify the details and the response.
- Regarding what you have learned about what Mr. Nakano said he was consulting with the Organized Crime Prevention Division, do you know whether the consultation included their respective duties, the Last Mile transaction, or information sharing? Please distinguish between what you know and what you speculate.
- Are there any facts involved in the inquiry regarding the Angel Tax system, the explanation to investors, the preparation of materials, or the granting or receiving of funds? If there is any involvement, how did you verify that the conditions presented to the administration matched the actual transaction?
Last-mile and questions to the contact
- How did the Last One Mile explain the actual operations, remuneration, and information sharing of the two individuals to the board of directors, the audit committee, and the accounting auditor? Who verifies the consistency between the explanation at the time and the information obtained this time?
- Is there any plan to verify the details regarding the new EY Japan that need confirmation from the company’s side, or will the company set up a system that cannot be completed by simply verifying the information provided by the target entity?
- Ashenine will confirm from the person concerned whether there are any matters related to the duties, information, resources, or interests of the company in connection with this matter. It requests that the company differentiate between matters related to the company and matters belonging to the past business activities of other companies.
- Based on the results of the survey, if it is confirmed that there are issues with explanations during listing review, the prerequisites for audits, or current information management, what reporting, consultation, or corrective measures will be taken? Please indicate the decision-maker and the verification procedures.
To protect the company's reputation and employees, we require verification through records.
For Last One Mile to remain a healthy company going into its next round of public trading, it must maintain a position where it can explain the practicalities of its listing and the current state of its information management. Just because external experts or former employees are involved, it becomes difficult to know what the company has requested, what it has received, and what it has paid.
The principles for handling incidents by the Japan Exchange Group’s self-regulatory organizationFurthermore, we emphasize clarifying the facts and causes when identifying doubts, establishing appropriate investigation systems, preventing recurrence, and disclosing information. If you are using the name of the system as a trust, I would like you to be willing to comply with the verification requirements of that system as well.
- Maintain records of contracts, payment of fees, work instructions, deliverables, reporting to and approval by the department, and information acquisition and sharing to ensure consistency between actual work and the description.
- In addition to the two individuals, please also verify the company’s decision to request and approve work tasks, as well as the information received and used. If Watanabe’s involvement is identified as a subject for investigation, please ensure that an independent decision-making process is established.
- If you use advice to administrative authorities or the police as an explanation for external credibility, please verify the details of the advice, the response, the actual action, and the information you conveyed to a third party, and if there is any discrepancy in the explanation, please correct it.
- Prevent any adverse treatment of employees who have reported a problem or cooperated in the investigation, and explain the verified facts and corrective measures while protecting personal information and confidential information.
Employees and business partners who were responsible for the practical work should separate and organize the instructions they received directly from the explanations they heard later. Records of who requested work, which documents were handed over, and who checked the finished work will be material for accurately confirming roles later. There is no need to rewrite your memory to match the explanation of a high-ranking person.
Other organizationsThe Saito Goshi Victims' AssociationIn addition, we are seeking explanations that can verify responsibilities and accountability, and are collecting information from relevant parties. If you have any questions about the work involved or the explanations provided, please organize your contracts, payment records, actual achievements, and the details of the explanations you requested, and convey them to the appropriate person for consultation.
The purpose of the union is not to damage the company’s signs. The goal is to reveal how the company’s reputation is used, and what instructions employees have followed to work. If there are any problems, the union can rectify them. By explaining things, the union can prevent unrelated employees and even legitimate professionals from being drawn into the same confusion.
Next to the Ministry of Economy, Trade and Industry is the Organized Crime Countermeasure Division. Please ask for the next line to be "consulted."
In the Angel Tax System, there was a history of having previously inquired with the Ministry of Economy, Trade and Industry, but subsequently, the actual nature of the investment was questioned in a criminal case. Therefore, what is necessary is not only eliminating the existence of the consultation, but also reconciling the premise of the consultation with the actual transaction, as this alone will determine the matter.
Now there is information that Nakano was reportedly consulting with the Organized Crime Countermeasures Department. If that consultation was used as a basis to guarantee the activities of all those involved, it could turn into a story of impressive consultation results, with the question of whether he was a member of a criminal group being asked even though he consulted the Ministry of Economy, Trade and Industry. This is not a matter of the group being found to be a criminal organization, but the fact that just naming the agency that consulted cannot end the questioning about the actual actions.
Before we engage in this kind of back-and-forth naming, I would like Mr. Oeido and Mr. Saito to please indicate what we were doing together, what we explained to our respective companies, what compensation we received, and what information we passed on to whom. A description of the appropriate work will be conveyed more clearly than a repetition of the details of my time at the Tokyo Stock Exchange or the names of the police departments, as it relates to the contract, approval, and completion of deliverables.
"I consulted with them." This is the starting point for the consultation. Next, write down what you consulted about, what you were told, and what actions you took afterwards. There is no system in place where even after going back to the same administrative agency several times, the stamp card for accountability remains valid and becomes a voucher. What you want to show next is not the sign of the person you consulted with, but the substance of your own work.
