Suppliers Code of Conduct

Union Pacific Railroad Company (UPRR) is committed to high standards of ethical business conduct. As a condition of doing business with UPRR, 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 UPRR’s Supplier Code of Conduct.

Suppliers must submit the Vendor Statement of Business and Legal Relationships (VSBL) annually. When a supplier fails to adequately complete the VSBL, Union Pacific will follow-up with said supplier.

Suppliers must immediately report any violation of this Code to UPRR’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 A Supplier’s failure to comply with UPRR’s Supplier Code of Conduct may result in UPRR pursuing legal action and/or discontinuing the business relationship.

The Code is divided into the following categories: (1) Ethical Standards, (2) Environmental Stewardship and (3) Human and Labor Rights:

Ethical Standards

  • Suppliers must compete fairly for UPRR’s business without paying bribes, kickbacks or giving anything of value to UPRR 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 UPRR personnel outside the bounds of the standard bidding process.
  • Suppliers are prohibited from asking UPRR employees for another supplier’s price or any other sensitive contractual information.
  • Suppliers must not directly or indirectly enter into any business transaction with UPRR employees or their relatives without the UPRR Supply Chain department’s prior written consent. All potential business conflicts are to be reported as required on UPRR Sourcehub Vendor portal.
  • Suppliers must not use any UPRR-owned: material, equipment, or leased equipment without the UPRR Supply Chain department’s prior written consent, or take ownership of any of the above unless Suppliers have executed an agreement generated by UPRR’s Supply Chain department that authorizes such action.
  • Suppliers must not subcontract any part of the work to be performed for UPRR: 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 Assistant Vice President of UPRR’s Supply Chain department. To receive this required consent, Supplier must provide to the UPRR’s Assistant Vice President of Supply Chain a detailed written description of the nature of the subcontractor’s relationship to Supplier, in the format required by the UPRR Supply Chain department. UPRR 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 UPRR 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 UPRR computer systems as authorized; must ensure the information security and confidentiality of all information obtained through such authorized access; and may not use any UPRR information other than for the purposes authorized by UPRR.
  • Suppliers may not use UPRR’s name, logo, images or other assets conveying the UPRR brand in promotional or marketing materials 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
  • 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 UPRR, unless it is an UPRR deemed emergency situation
  • Suppliers must provide an updated Statement of Business and Legal Relationships (VSBL) annually or when changes occur as required by UPRR.
  • Suppliers must maintain an Avetta Safety Portal, E-RAILSAFE Profile, E-Verify Profile training records, and safety records, as required by UPRR.
  • Suppliers are responsible for maintaining updated company records required by UPRR. Some examples are: contact information, legal information, tax information, financial records, FRA records, UPRR reporting requirements, and billing records.
  • A supplier’s failure to comply with UPRR’s audit review process or falsification of any documents provided during an UPRR Audit, may result in UPRR pursuing legal action and/or discontinuing the business relationship

Environmental Stewardship

  • Suppliers must adhere to and comply with all relevant environmental laws and regulations
  • In addition, 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.

Human & Labor Rights

  • Suppliers must adhere to all applicable UPRR policies while working on UPRR property including but not limited to general safety practices, E-Railsafe requirements, and UPRR’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 UPRR’s Supplier Code of Conduct to all employees and subcontractors involved in doing business with UPRR.
  • Suppliers must have a human rights policy that follows international standards and addresses child labor, freedom of association, working conditions and equal remuneration.
  • Suppliers must have policies in place that enforce occupational health and safety standards for all of their employees.

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 solid 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.


Revised September 2022