Suppliers Code of Conduct

Union Pacific Corporation (UP) is committed to high standards of ethical business conduct. As a condition of doing business with UP, all Suppliers (suppliers, vendors, contractors, subcontractors, consultants, agents and other providers of materials and/or services) must fully comply with all federal, state, and local laws, rules, regulations, orders, codes and ordinances as outlined in the contract as well as UP’s Supplier Code of Conduct.

Suppliers must immediately report any violation of this Code to UP’s Values Line at: 1 (800) 998-2000. If you have any questions, please call or email the Service Procurement Center at: (402)544-0772 or SPC@up.com. A Supplier’s failure to comply with UP’s Supplier Code of Conduct may result in UP pursuing legal action and/or discontinuing the business relationship.

The Code is divided into the following categories: (1) Ethical Standards, (2) Environmental Stewardship, (3) Human and Labor Rights, and (4) Union Pacific Anti-Bribery and Anti-Corruption Policy.

Ethical Standards

  • Suppliers must comply with antitrust laws and compete fairly for UP’s business without paying bribes, kickbacks or giving anything of value to UP employees or their relatives in order to secure an improper advantage or create the appearance of gaining an improper advantage.
  • Suppliers must independently develop proposals and bid responses, without consultation with other bidders, other potential bidders, or UP personnel outside the bounds of the bidding process.
  • Suppliers are prohibited from asking UP employees for another supplier’s price or any other sensitive contractual information.
  • Suppliers must not directly or indirectly enter into any business transaction with UP employees or their relatives without the UP Supply Chain department’s prior written consent. All potential business conflicts are to be reported as required on UP's supplier portal.
  • Suppliers must not use any UP-owned material, equipment, or leased equipment without the UP Supply Chain department’s prior written consent, or take ownership of any of the above unless Suppliers have executed an agreement generated by UP’s Supply Chain department that authorizes such action.
  • Suppliers must not subcontract any part of the work to be performed for UP: to a subsidiary or affiliate, a relative, or any entity owned, controlled by, or under common control with, the Supplier or a relative, without the informed, express prior written consent of the Vice President - Supply Chain. To receive this required consent, Supplier must provide a detailed written description of the nature of the subcontractor’s relationship to Supplier in the format required by the UP Supply Chain department. UP will review the information formally submitted and/or require any additional information before approving this subcontractor arrangement.
  • Suppliers must ensure that their personnel assigned to perform work on UP property act in a professional and respectful manner, keeping the workplace free from harassment including verbal, physical, and written misconduct.
  • Suppliers may only access information through UP computer systems as authorized; must ensure the information security and confidentiality of all information obtained through such authorized access; and may not use any UP information other than for the purposes authorized by UP.
  • Suppliers may not use UP’s name, logo, images or other assets conveying the UP brand in promotional or marketing materials without prior written approval, including but not limited to the following: external websites; social media platforms; printed or electronic media used in trade shows, recruiting activities, and all other marketing efforts; signs or banners; video; print, electronic, digital or any other kind of advertising; news releases, media interviews or any other news media forum; or newsletters distributed to outside parties without written consent of UP.
  • Suppliers must ensure an approved Purchase Order has been issued and must adhere to all applicable Purchase Order terms and conditions prior to providing any material, equipment, or services to UP, unless it is an UP deemed emergency situation.
  • Suppliers must maintain a safety portal ISN, E-RAILSAFE Profile, E-Verify Profile training records, and safety records, as required by UP.
  • Suppliers are responsible for maintaining updated company records required by UP. Some examples include: contact information, legal information, tax information, financial records, FRA records, UP reporting requirements, and billing records.
  • Suppliers are expected to demonstrate compliance with Code of Conduct upon UP's request. UP reserves the right to verify compliance including through on-site visits and inspections by designated personnel. 
  • A supplier’s failure to comply with UP’s audit review process or falsification of any documents provided during an UP audit may result in UP pursuing legal action and/or discontinuing the business relationship.

Environmental Stewardship

  • Suppliers must adhere to and comply with all relevant environmental laws and regulations.
  • Suppliers are expected to efficiently manage resources, conserve energy, responsibly manage biodiversity, minimize waste and avoid pollution.
  • Suppliers are encouraged to develop and implement an environmental policy of their own, one which is relevant and appropriate to their operations, and consistent with Railroad requirements.
  • Suppliers are encouraged to measure their carbon footprint using the Greenhouse Gas (GHG) Protocol carbon accounting framework, and to develop strategies to reduce their emissions.
  • Suppliers are also encouraged to report to Union Pacific the amount of the supplier's Scope 1 and 2 emissions that are attributable to Union Pacific (Scope 3 emissions).

Human & Labor Rights

  • Suppliers must adhere to all applicable UP policies while working on UP property including but not limited to general safety practices, E-Railsafe requirements, and UP’s no smoking policy.
  • Suppliers must prohibit in hiring and employment practices and customer service practices any discrimination or harassment based on a person's race, color, gender, national origin, age, disability, religion, military and veteran status, sexual orientation, gender identity, gender expression, genetic information, pregnancy, or any other ground prohibited by law ("protected status").
  • Suppliers must effectively distribute and communicate UP’s Supplier Code of Conduct to all employees and subcontractors involved in doing business with UP.
  • Suppliers must have a human rights policy that follows international standards and addresses forced labor, child labor, freedom of association and collective bargaining, working conditions and equal remuneration.
  • Suppliers must comply with applicable wage and working hours in accordance with local laws. 
  • Suppliers must have policies in place that enforce occupational health and safety standards for all of their employees.
  • Suppliers are expected to demonstrate compliance with the human rights components of this Code of Conduct upon UP's request. UP reserves the right to verify compliance including through on-site visits and inspections by designated personnel.

Union Pacific Anti-Bribery and Anti-Corruption Policy

Union Pacific's Values Statement emphasizes high ethical standards to ensure that the Company maintains and enhances its reputation as one of America's leading and most recognizable companies. As part of this commitment to values, Union Pacific, its employees and its business partners are bound to comply with the United States Foreign Corrupt Practices Act (FCPA) and all other applicable anti-bribery and anti-corruption laws, including the National Anti-Corruption System in Mexico.

 

Last Updated: 10/01/2024

Last Reviewed: 10/01/2024