The filed complaint alleges that defendants made false statements and/or concealed that: (i) Hawaiian Electric’s wildfire prevention and safety protocols and procedures were inadequate to meet the challenges for which they were ostensibly designed; (ii) accordingly, despite knowing the degree of risk that wildfires posed to Maui, the Company’s inadequate safety protocols and procedures placed Maui at a heightened risk of devastating wildfires; and (iii) as a result, the Company’s public statements were materially false and misleading at all relevant times.