12.	COMMITMENTS AND CONTINGENCIES

December 31, 2018,

the State of Hawaii Department of Health (“DOH”) issued a Notice and Finding of Violation and Order (“Order”) for alleged wastewater effluent violations related to the Company's Upcountry Maui wastewater treatment facility. The facility was built in the

1960's

to serve approximately

200

single-family homes developed for workers in the Company's former agricultural operations. The facility is made up of

two

1.5

-acre wastewater stabilization ponds and surrounding disposal leach fields. The Order includes, among other requirements, payment of a

$230,000

administrative penalty and development of a new wastewater treatment plant, which become final and binding – unless a hearing is requested to contest the alleged violations and penalties.

The DOH agreed to defer the Order without a hearing date while the Company continues working on a previously approved corrective action plan to resolve and remediate the facility's wastewater effluent issues. The construction of additional leach fields was completed as of

December 31, 2020.

Additionally, the installation of a surface aerator, sludge removal system, and natural pond cover using water plants is currently in progress.

hearing date has been set as discussions with the DOH are still ongoing to address any other matters regarding the Order.

The Company is presently unable to estimate the amount, or range of amounts, of any probable liability, if any, related to the Order and

provision has been made in the accompanying consolidated financial statements.

In addition, from time to time, the Company is the subject of various other claims, complaints and other legal actions which arise in the normal course of the Company's business activities. The Company believes the resolution of these other matters, in the aggregate, is

not

likely to have a material adverse effect on the Company's consolidated financial position or operations.

March 2020,

the World Health Organization declared the outbreak of a novel coronavirus (COVID-

) as a pandemic. As a result, public health measures were taken to minimize exposure to the virus. Quarantine, travel restrictions, and other governmental restrictions and guidelines to reduce the spread of COVID-

has caused and is likely to continue to have an adverse impact on economic activity, including business closures, increased unemployment, financial market instability, and reduced tourism to Maui. The duration of the disruption on global, national, and local economies cannot be reasonably estimated at this time. However, should the existence of the COVID-

pandemic continue for an extended period, the Company's future business operations, including the results of operations, cash flows and financial position will be significantly affected.