1. Executive Summary Since 2025, Sukimare Consulting has provided independent mediation and labor dispute support — largely on a pro bono basis — to Japanese nationals employed in Malaysia’s business process outsourcing (BPO) and call center sector. Over this period, the total number of consultations received has exceeded 100. Of these, between 30 and 50 are documented to a standard that allows them to be provided as case materials and supporting information, and 16 cases have been fully documented as signed case files, with the client’s own consent and signature, spanning nine major multinational employers: Concentrix Malaysia, Teleperformance, TDCX, TaskUs, Startek, Tech Mahindra, AirAsia, Agoda, and Transcosmos. Consultations for which a signed file has not yet been completed are also retained — as consultation records or as reports volunteered through social media — and are used to corroborate and contextualize the structural patterns described below. The remaining consultations — including cases that were self-resolved by the worker, discontinued by the worker before substantive engagement, or otherwise not pursued to documentation — are excluded from the documented case counts and are not relied upon in this report’s findings. This casework reveals a consistent set of structural practices that recur across multiple independent employers, regardless of the human rights and labor policies each company publicly espouses. Representative examples include: (1) the arbitrary application of high-value contractual resignation penalties and notice-period penalties; (2) the rejection or unduly strict scrutiny of valid medical certificates issued by physicians; (3) prolonged non-payment of wages, bonuses, and statutory contributions on the grounds of an unissued tax clearance letter (LHDN’s CP621) or employer-caused delay; (4) psychological and economic retaliation that exploits a worker’s dependence on their Employment Pass; (5) the de facto penalization of physician-certified medical leave through attendance-scoring (KRA/KPI) systems; (6) the stripping of statutory benefits by classifying workers who are, in substance, employees as independent contractors; (7) the retroactive reduction of salary terms offered at the recruitment stage (so-called salary bait-and-switch); (8) prolonged denial of access to tools that are essential to the job, such as a personal social media account; (9) coercive collective-bargaining tactics that tie a colleague’s contractual rights or outcomes to an individual worker’s consent; and (10) the opaque weaponization of internal performance and attendance policies. Section 4 of this report details these and other patterns, totaling 15 categories in all, each supported by concrete case evidence. These findings do not rest on any single testimony; they are based on the cross-referencing of multiple independent sources of evidence. These include signed questionnaires and feedback forms completed with client consent after each consultation; direct accompaniment of clients to Malaysian government agencies such as JTK (Department of Labour), SOCSO (Social Security Organisation), LHDN (Inland Revenue Board), and KWSP (EPF); contemporaneous written communications between workers and employers; and recordings, internal policy documents, employment contracts, and medical records voluntarily provided by workers (see Section 2.2 for full methodology). All personally identifying information has been removed or generalized, and the underlying case files can be made available, under appropriate confidentiality safeguards, at the request of accredited investigative or supervisory bodies. This white paper consolidates this casework into a single, pattern-level analysis and records the concrete steps taken, as of July 2026, to move from individual case support toward the pursuit of structural accountability. These steps include: the initiation of engagement with Tenaganita, Malaysia’s leading migrant workers’ rights organization; the filing of a formal complaint with the United States National Contact Point (NCP) for the OECD Guidelines for Multinational Enterprises (with equivalent filings to the French and Japanese NCPs also underway); and the consolidation of the case load into a structured, anonymized dataset that enables pattern-level reporting to NGOs, government bodies, and OECD NCPs. In addition, this report records the first fully documented resolution of a government-agency (LHDN) misclassification case through direct representative negotiation (Sections 5 and 6.7), supported by signed client testimony and official LHDN documentation. This document is a deliverable from that dataset and will be updated continuously as further cases accumulate. This report is not intended to single out or condemn any one employer. Its purpose is to demonstrate, on the basis of consistent evidence spanning multiple independent employers, that the misconduct described is not an isolated administrative failing but a structural pattern that runs across the sector as a whole. At the same time, it invites the engagement and cooperation of organizations positioned to pursue accountability and redress — including the Embassy of Japan in Malaysia and other government bodies, Malaysia’s labor and human rights oversight authorities, OECD NCPs, and international human rights and labor organizations. Sukimare Consulting — White Paper (July 2026) Page 2