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Exhibit 19

Policy – Koppers

Securities

Insider Trading and Securities Compliance

Effective Date: 5/8/2025

Purpose:

It is important for all employees – and especially employees who are also shareholders – to

become familiar with the rules concerning insider trading and securities compliance. This

Policy states the basic rules that apply in this important area.

Scope:

This Policy applies to all employees, officers, directors and other personnel of Koppers

Holdings Inc., Koppers Inc. and all subsidiaries of Koppers Inc. (together referred to as

“Koppers” or the “Company”). The terms “employee” or “personnel” as used in the Policy, are

intended to encompass all employees, officers, directors and other personnel of Koppers.

Policy Summary:

If you have any material non-public information relating to the Company, it is the Company’s

policy that, subject to Section IV below, you must not purchase, sell, gift or otherwise acquire,

dispose or transfer, or advise any other person to purchase, sell, gift or otherwise acquire,

dispose or transfer, securities issued by the Company, including the Company’s Common

Stock. If you have any such information, it is also the Company’s policy that you must not

communicate the material non-public information to any other person unless the person has a

need to know the information for legitimate, Company-related reasons. Transactions that may

be necessary or justifiable for your independent reasons (such as the need to raise money for

an emergency expenditure) are no exception. Even the appearance of an improper

transaction must be avoided. Special rules apply to those persons who are designated as

being in the “Window Group” or the “Restricted Group”. Securities laws will also apply if

employees trade in securities of other companies on the basis of insider information about

those companies (e.g. who are customers or suppliers to the Company) gained through their

work with the Company. For purposes of this Policy, all gifts and other acquisitions,

dispositions or transfers of securities issued by the Company are to be treated in the same

manner as open market purchases or sales of such securities.

Policy:

The Company and its employees shall comply fully with all applicable securities laws. Koppers

expects all employees to become familiar with and to guard against any violations of such laws.

I.Trading in Koppers Securities

A.General Rule

Securities laws regulate the sale and purchase of securities in the interest of

protecting the investing public. In particular, securities laws require the Company, its

officers and directors, and other employees to be responsible to ensure that

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information about Koppers is not used unlawfully in the purchase and sale of

securities in Koppers.

All employees must pay close attention to the laws against trading on “inside”

information. These laws are based upon the belief that all persons trading in a

company’s securities should have equal access to all “material” information about

that company. If an employee knows material, nonpublic information about a

company, subject to Section IV below, that employee is prohibited from buying or

selling stock in the company, or divulging the information to another person for the

purpose of buying or selling stock in the company, until the information has been

disclosed to the public.

The general rule can be stated as follows: Except as provided in Section IV below, it

is a violation of the securities laws for any person to buy or sell securities if he or

she is in possession of material inside information regarding the issuer of those

securities. Information is deemed “material” if it would be considered to be important

by a reasonable investor in deciding whether to buy, sell, or refrain from any activity

regarding the Company’s securities. By way of example, it is probable that the

following information, in most circumstances, would be deemed material: annual or

quarterly financial results; a significant change in earnings or earnings projections;

unusual gains or losses in major operations; negotiations and agreements regarding

significant acquisitions, divestitures, or business combinations; a payment of

dividends on the Company’s stock; and major management changes. You should

remember that if your purchases or sales become the subject of scrutiny, they will

be viewed after-the-fact. As a result, before engaging in any transaction, you should

carefully consider how regulators and others might view your transaction with the

benefit of hindsight. When in doubt, information should be presumed to be material.

It is inside information if it has not been publicly disclosed.

Furthermore, it is illegal for any person in possession of material inside information

to provide other people with such information or to recommend that they buy or sell

the securities. This is called “tipping”. Both the “tipper” and the “tippee” will be held

liable.

Inside information does not belong to the individual directors, officers or other

employees who may handle it or otherwise become knowledgeable about it. For any

person to use such information for personal benefit or to disclose it to others outside

the Company violates the Company’s interests.

B.Applicability

The prohibition against trading or otherwise transacting in or transferring

securities on inside information applies to directors, officers, and all other

employees of the Company, and to other people outside the Company who gain

access to that information. The Company’s policy applies with equal force to any

person, trust or estate, company or other entity whose actions you do or could

influence. It is also applicable to any relative of yours, as well as any person to

whom you may have communicated (contrary to this Policy) any material non-

public information. As used herein, the term “employee” includes all such persons.

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Because of their access to confidential information on a regular basis, Company

policy subjects two groups of employees to additional restrictions on trading in

securities of Koppers. The restrictions for these two groups of employees (the

“Window Group” and the “Restricted Group”) are discussed in Section III.F and

III.G below. In addition, certain employees with inside knowledge of material

information may be subject to ad hoc restrictions on trading or otherwise

transferring securities from time to time.

Management of the Company may from time to time determine to impose event-

specific blackout periods upon such groups of employees as management may

deem appropriate for the purpose of reducing the potential for trading on the basis

of material nonpublic information. The imposition of any such event-specific

blackout periods and the lifting of such periods will be communicated to the

employees subject to such periods by the General Counsel or his or her

designee. In management’s discretion, the reason for the imposition or lifting of

such event-specific blackout periods may not be communicated to the employees

subject to such periods.

II.Other Companies’ Securities

The rules regarding insider trading also apply to other companies’ securities.

Employees who learn material information about suppliers, customers, or

competitors through their work at the Company must keep it confidential and not

buy or sell securities in such companies until the information becomes public.

Employees must not give tips about such securities.

III.Guidelines

The following guidelines are to be followed in order to ensure compliance with

applicable laws and with the Company’s Policies.

A.Nondisclosure

Material non-public information must not be disclosed to anyone, except to persons

within the Company whose positions require them to know it or by management of

the Company to the Company’s relevant advisors.

B.Trading in Securities of Koppers

Subject to Section IV below, no employee should place a purchase or sale order, or

recommend that another person place a purchase or sale order, for securities of

Koppers when he or she has knowledge of material information concerning

Koppers that has not been disclosed to the public. Likewise, subject to Section IV

below, no employee should gift or otherwise acquire, dispose or transfer, or

recommend that another person gift or otherwise acquire, dispose or transfer,

securities of Koppers when he or she has knowledge of material information

concerning Koppers that has not been disclosed to the public. The exercise of

employee stock options is not subject to this policy. Cashless exercises of options,

which require the sale of all or a portion of the stock subject to the options, are

subject to this policy. In addition, stock that was acquired upon exercise of a stock

option will be treated like any other stock, and may only be sold in accordance with

this policy. Any employee who possesses material inside information should wait

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one business day after the information has been released publicly before trading,

gifting or otherwise transacting in securities of Koppers.

C.Avoid Speculation

Employees should avoid speculating in securities of Koppers. Employees should

also avoid frequent trading in securities of Koppers. Speculating in securities of

Koppers is not part of the Company culture.

D.Trading in Other Securities

No employee should place a purchase or sale order, or recommend that another

person place a purchase or sale order, in the securities of another corporation if the

employee learns in the course of his or her employment information about the

other corporation that is not generally available and that could be expected to

affect the value of those securities. This prohibition also applies to gifts or other

acquisitions, dispositions or transfers of the securities of another corporation. For

example, it would be a violation of securities laws if an employee learned through

Company sources that the Company intended to purchase assets from another

corporation and then bought or sold stock in that other corporation because of an

expected increase or decrease in the value of its securities.

E.Additional Prohibited Transactions

For the protection of the Company and its employees, it is important to avoid the

appearance as well as the fact of insider trading or disclosure of material non-public

information. Employees are prohibited from directly or indirectly participating in

transactions involving trading activities that by their nature are aggressive,

speculative, or may give rise to an appearance of impropriety. Accordingly,

employees may not engage in any of the following transactions:

(a)Hedging Transactions – Certain forms of hedging or monetization

transactions, such as prepaid variable forward contracts, equity swaps,

collars and exchange funds, allow an employee to hedge or offset any

decrease in the market value of Company securities. These transactions

allow an employee to continue to own Company securities, but without

the full risks and rewards of ownership. When that occurs, the employee

may no longer have the same objectives as the Company’s other

shareholders. Therefore, employees are prohibited from engaging in such

transactions.

(b)Short Sales – Short sales of the Company’s securities evidence an

expectation that the securities will decline in value and may signal to the

market that the seller has no confidence in the Company or its short-term

prospects. Short sales may also reduce the seller’s incentive to improve

the Company’s performance. Therefore, employees are prohibited from

engaging in short sales of the Company’s securities. In addition, Section

16(c) of the Securities Exchange Act of 1934, as amended, prohibits

officers and directors from engaging in short sales.

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(c)Publicly Traded Options – Publicly traded options (such as puts, calls and

other derivative securities) are, in effect, a bet on the short-term

movement of the Company’s stock and can therefore create the

appearance that an employee is trading based on material non-public

information. Transactions in options may also focus the employee’s

attention on short-term performance at the expense of the Company’s

long-term objectives. Therefore, employees are prohibited from engaging

in transactions in publicly traded options on Company securities on an

exchange or in any other organized market. For the avoidance of doubt,

employee stock options are not considered to be publicly traded options

for purposes of this prohibition.

(d)Margin Accounts and Pledges – Employees are prohibited from pledging

Company securities as collateral for a loan or from holding Company

securities in margin accounts or a brokerage account with a “margin

feature” (unless the margin feature is not utilized, Company securities are

otherwise excluded from being pledged or the account holder does not

engage in any transaction that results in a lien upon the Company

securities in the account) because pledged securities or securities held in

a margin account may be sold by the broker or lender without your

consent if you fail to meet a margin call or default on the loan and any

such sale may occur at a time when you are aware of material non-public

information or otherwise are not permitted to trade in Company securities.

F.Restrictions on the Window Group

The Window Group consists of the directors and elected officers of

Koppers Holdings Inc. and Koppers Inc. and the executive assistants of

such officers and such other employees of the Company as may be

designated from time to time by Koppers Holdings Inc.’s Chief Executive

Officer, Chief Financial Officer, Secretary or Assistant Secretary. In

addition to the general restrictions on all employees, the Window Group

is also subject to the following restrictions on trading in Company

securities:

-subject to Section IV below, trading, gifting and other

acquisitions, dispositions and transfers are only permitted

during the period beginning one day after an earnings

release for the preceding fiscal period until the end of the

twentieth day of the third month of a fiscal quarter (the

“Window”) and upon obtaining advance clearance for all

trades from the Secretary or Assistant Secretary of Koppers

Holdings Inc.

G.Restrictions on the Restricted Group

The Restricted Group consists of those persons who report directly to a

member of the Window Group and the administrative assistants of such

persons and such other employees as may be designated from time-to-

time by Koppers Holdings Inc.’s Chief Executive Officer, Chief Financial

Officer, Secretary or Assistant Secretary. In addition to the general

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restrictions on all employees, the Restricted Group is subject to the

following restriction on trading in Company securities:

- Subject to Section IV below, trading, gifting and other

acquisitions, dispositions and transfers are only permitted

during the Window.

H.Additional Restrictions on the Window Group and the Restricted Group

Subject to Section IV below, members of the Window Group and the Restricted

Group are not permitted to engage in trading, gifting or otherwise acquiring,

disposing or transferring securities issued by the Company outside the Window

except upon prior review and approval by the Secretary or Assistant Secretary of

Koppers Holdings Inc.

IV.Permitted Transactions

A.Employee Stock Purchase Plan

Except as otherwise provided in this paragraph, this Policy’s trading restrictions

do not apply to purchases of Common Stock through the Koppers Holdings Inc.

Employee Stock Purchase Plan (the “ESPP”) resulting from your periodic or lump

sum contributions to the ESPP under an election made at the time of enrollment

in the ESPP. The trading restrictions under this Policy do apply, however, to your

initial election to participate in the ESPP, changes to your election to participate in

the ESPP, and to your sales of Common Stock purchased under the ESPP.

Therefore, Window Group members should enroll in the ESPP, change any of

their previously made elections under the ESPP and sell any Common Stock

purchased under the ESPP only after having obtained preclearance under this

Policy and only during a Window period. Similarly, Restricted Group members

should enroll in the ESPP, change any of their previously made elections under

the ESPP and sell any Common Stock purchased under the ESPP only during a

Window period.

B.Rule 10b5-1 Plans

Notwithstanding any other provisions of this Policy, an employee who is a member

of the Window Group or Restricted Group may purchase or sell securities issued by

the Company outside of a Window period, if, during a Window period and at a time

when such employee was not aware of any material nonpublic information

concerning the Company or such securities, the employee entered into a written

plan, contract, instruction or arrangement under Rule 10b5-1 that has been

approved as described herein (an “Approved 10b5-1 Plan”);

And the Approved 10b5-1 Plan

(a)specified the amount of securities to be purchased or sold and the price

at which and the date on which the securities were to be purchased or

sold,

(b)included a written formula or algorithm, or computer program, for

determining the amount of securities to be purchased or sold and the

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price at which and the date on which the securities were to be

purchased or sold, or

(c)did not permit the employee to exercise any subsequent influence over

how, when or whether to effect purchases or sales; provided, in

addition, that any other person who, pursuant to the Approved 10b5-1

Plan, did exercise such influence must not have been aware of material

nonpublic information when doing so.

Notwithstanding any other provisions of the Policy, an employee who is not a

member of the Window Group or Restricted Group may purchase or sell securities

issued by the Company outside of a Window period, if, at a time when such

employee was not aware of any material nonpublic information concerning the

Company or such securities, the employee entered into an Approved Rule 10b5-1

Plan as described herein;

And the Approved Rule 10b5-1 Plan

(a)met the requirements enumerated in paragraphs (a), (b) and (c) above

and any requirement set forth in Rule 10b5-1; and

(b)in the case of all employees, the purchase or sale that occurred was

pursuant to the Approved 10b5-1 Plan.

A purchase or sale is not “pursuant to the Approved 10b5-1 Plan” if the

person who entered into the plan altered or deviated from the plan to purchase or sell

securities (whether by changing the amount, price or timing of the purchase or sale),

or entered into or altered a corresponding hedging transaction or position with respect

to those securities.

A transaction pursuant to such an Approved 10b5-1 Plan is permissible

only if (i) the Approved 10b5-1 Plan to purchase or sell securities is not entered into as

part of a plan or scheme to evade provisions of the federal securities laws prohibiting

trading in securities on the basis of material inside information and (ii) the person who

entered into the Approved 10b5-1 Plan has acted in good faith with respect to the

Approved 10b5-1 Plan.

Pursuant to Section I.B. above, management of the company may from

time to time determine to impose event-specific blackout periods which may prohibit

transactions pursuant to any Approved 10b5-1 Plan referred to in this Section IV.

If a member of the Window Group or Restricted Group requests to enter

into, amend or terminate an Approved 10b5-1 Plan, certain additional requirements are

applicable:

(1)Such plan, including any amendment or termination of such plan,

must be reviewed and approved in advance by the Corporate

Secretary or Assistant Secretary or his or her qualified designee.

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(2)In advance of any trades under such a plan, including after any

amendment to such a plan, a minimum waiting period of a length

complying with Rule 10b5-1 must elapse.

(3)An Approved 10b5-1 Plan, as well as any amendments or

terminations by such member of the Window Group or Restricted

Group of any Approved 10b5-1 Plan (other than time-based

expiration or completion of all transactions in accordance with

the terms of such plan), must only be implemented during a

Window period.

(4)After any termination of an Approved 10b5-1 Plan, no new 10b5-1

plan may be entered into by the party to such terminated plan until

the next Window period;

(5)Only one Approved Rule 10b5-1 may be in effect at any given

time for any member of the Window Group or the Restricted

Group and

(6)Only one “single-trade” 10b5-1 plan may be entered into in any 12-

month period. A “single-trade” 10b5-1 plan is a 10b5-1 plan that is

designed to effect the open-market purchase or sale of the total

amount of securities as a single transaction.

V.General Disclosure

Employees may be asked by representatives of the news media or other parties

for information concerning the Company including its position on public issues.

Employees should refer these and all other requests from the news media or any

third party to the Company’s Communications Manager.

In addition, employees may not release information to the news media about the

Company’s activities or the activities of other employees. The Communications

Department has established systems and procedures for responding to the news

media requests and for obtaining management approval for public statements. If

an activity merits or requires public disclosure, its release will be handled by the

Company’s Vice President of External Relations and Vice President of Investor

Relations, after appropriate consultation with the Chief Executive Officer and/or

the Legal Department.

VI.Further Information

Questions regarding the interpretation of the Policy concerning Insider Trading and

Securities Compliance should be directed to the Secretary or Assistant Secretary

of Koppers Holdings Inc., the Director of Compliance, or the Legal Department.