Exhibit 19

Insider Trading, Hedging and Pledging

GP No. 10.07

Last Revised: December 30, 2024

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Matson’s Insiders (as defined below) shall not:

This policy also applies to all Insiders’ spouses or significant others, minor children, adult family members sharing the same household and any person, accounts or entities over which an Insider has investment discretion or control, such as a trust for which the Insider serves as trustee.

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Once information meets these two criteria, it is thereafter treated as “Public Information.”

Insiders may not trade in options, warrants, puts and calls or similar instruments on Matson stock or other securities or sell Matson stock or other securities “short.” The simultaneous sale through a broker of some or all of the shares acquired through the exercise of an option granted under a Matson compensation plan (i.e., a cashless exercise of options) is not considered a short sale, but such activity is subject to the trading restrictions discussed in this policy and other applicable Matson policies.

Insiders are prohibited from entering into hedging or monetization transactions involving Matson stock or other securities.

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Matson’s directors and executive officers are also prohibited from holding Matson stock or securities in a margin account or otherwise pledging Matson stock or securities as collateral for a loan because a margin sale or a sale of pledged Matson securities may occur at a time when the director or executive officer is aware of Material Nonpublic Information or is otherwise not permitted to trade in Matson securities.

To help protect against even the appearance of insider trading, Matson has instituted a trading blackout for directors, executive officers and other select individuals in the organization (“Designated Insiders”). The blackout period begins two weeks before the end of each fiscal quarter and continues through the second business day after the date of the first effective public dissemination of Matson’s earnings. Designated Insiders may not trade any Matson securities until the opening of business on the third business day after the date of the first effective public dissemination of Matson’s earnings, so long as the Designated Insider is not aware of Material Nonpublic Information.

From time to time, other types of Material Nonpublic Information regarding Matson may be pending and not be publicly disclosed. During such time, Matson may impose special blackout periods during which any Insider (or Designated Insider) who has been notified by Matson that he/she is subject to the event-specific blackout will be prohibited from trading in Matson securities.

Designated Insiders must notify the General Counsel or the Corporate Secretary prior to conducting any transactions in Matson securities.

Insiders may trade in Matson securities if the transaction is made pursuant to a pre-arranged trading plan (a “Rule 10b5-1 Trading Plan”) that was entered into when the Insider was not aware of Material Nonpublic Information. A Rule 10b5-1 Trading Plan must be written and shall specify the amount of securities to be traded, the date on which such securities will be traded and the trading price. In the alternative, a Rule 10b5-1 Trading Plan may establish a formula for determining such items. Rule 10b5-1 Trading Plans may not be adopted when the Insider is aware of Material Nonpublic Information. A Rule 10b5-1 Trading Plan may be amended or replaced only during periods when trading is permitted under this policy. All Rule 10b5-1 Trading Plans, and any amendments or terminations, must be pre-approved by the Law Department and comply with the requirements of Rule 10b5-1.

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In addition, the following conditions must be satisfied:

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This policy does not apply in the case of the following transactions (although these transactions may nevertheless be subject to the requirements of Section 16 of the Securities Exchange Act of 1934 applicable to directors and executive officers):

Federal law imposes heavy penalties on those who buy or sell stock or other securities while aware of Material Nonpublic Information or pass the information along to anyone who may use it to buy or sell stock or other securities. Potential penalties include criminal fines, prison terms and civil penalties. In addition, Matson may face liability. Because of the severe consequences for violating the insider trading rules, Insiders who are uncertain about whether they may trade must consult with the General Counsel or Corporate Secretary before initiating a trade.

With the exception of the preclearance requirements discussed above, this policy continues to apply even after termination of an Insider’s service with Matson. If an Insider is aware of Material Nonpublic Information when their service terminates, the Insider may not trade in stock or other securities of Matson until that information is no longer material or has become Public Information.

If you have any questions regarding any aspect of this policy, you should consult with the General Counsel or the Corporate Secretary and abstain from trading in the relevant securities, or from disclosing the information until the General Counsel or the Corporate Secretary confirms the information is not material or is Public Information. If you are aware of or suspect a violation of this policy, you should notify the General Counsel or the Corporate Secretary immediately.

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From time to time, Matson may engage in transactions in its own securities, including share issuances and repurchases. Matson’s practices with respect to share issuances and repurchases, which are overseen by the Treasury and Law Departments (and approved by the Board of Directors or appropriate committee, if required), are designed to promote compliance with applicable insider trading and other securities laws, rules, regulations and listing standards. Transactions pursuant to equity-based compensation arrangements are conducted in accordance with the terms of the plans and agreements.