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United States securities and exchange commission logo
September 15, 2021
Joel Wine
Chief Financial Officer
Matson, Inc.
1411 Sand Island Parkway
Honolulu, HI 96819
Re: Matson, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 26,
2021
File No. 001-34187
Dear Mr. Wine:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2020
General
1. We note that you
provided more expansive disclosure in your CSR report than you
provided in your SEC
filings. Please advise us what consideration you gave to providing
the same type of
climate-related disclosure in your SEC filings as you provided in your
CSR report.
Management Discussion and Analysis of Financial Condition and Results of
Operations, page 26
2. Please revise your
disclosure to identify any material past and/or future capital
expenditures for
climate-related projects. If material, please quantify these expenditures.
3. To the extent that you
expect decreased demand for your services that produce significant
greenhouse gas
emissions or are related to carbon-based energy sources, please disclose
any material expected
effect on your business, financial condition, and results of
Joel Wine
Matson, Inc.
September 15, 2021
Page 2
operations.
4. If applicable and to the extent material, discuss the significant
physical effects of climate
change on your operations and results. This disclosure may include the
following:
quantification of material weather-related damages to your
property or operations;
and
potential for indirect weather-related impacts that have affected
or may affect your
major customers or suppliers.
5. Quantify any material increased compliance costs related to climate
change.
6. If material, provide disclosure about your purchase or sale of carbon
credits or offsets and
any material effects on your business, financial condition, and
results of operations.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Ethan
Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding
comments.
FirstName LastNameJoel Wine Sincerely,
Comapany NameMatson, Inc.
Division of
Corporation Finance
September 15, 2021 Page 2 Office of
Energy & Transportation
FirstName LastName