Union Pacific is committed to high standards of ethical business conduct. As a condition of doing business with Union Pacific, 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 the railroad's Supplier Code of Conduct.
Suppliers must immediately report any violation of this code to Union Pacific’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 Union Pacific’s Supplier Code of Conduct may result in Union Pacific 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 Union Pacific’s business. Prohibited actions include but are not limited to paying bribes, kickbacks or giving anything of value to railroad employees or their relatives or any other person that would 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 Union Pacific personnel outside the bounds of the bidding process.
- Suppliers are prohibited from asking Union Pacific employees for another supplier’s price or any other sensitive contractual information.
- Suppliers must not directly or indirectly enter into any business transaction with Union Pacific employees or their relatives without the express, prior written consent of the Vice President- Supply Chain. In addition, all Union Pacific employees should report any conflicts of interest to their supervisor and via the annual Conflict of Interest disclosure if a management or ARASA employee.
- Suppliers must not use any Union Pacific-owned material, equipment, or leased equipment without the Supply Chain department’s prior written consent or take ownership of any of the above unless Suppliers have executed an agreement that authorizes such action.
- Suppliers must not subcontract any part of the work to be performed for Union Pacific: 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 Supply Chain department. Union Pacific 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 Union Pacific property act in a professional and respectful manner, keeping the workplace free from harassment including verbal, physical, and written misconduct.
- If a supplier knowingly hires a former Union Pacific employee to work on the railroad’s business, the supplier must notify Union Pacific prior to the employee starting work on the company’s behalf.
- Suppliers may only access information through Union Pacific computer systems as authorized; must ensure the information security and confidentiality of all information obtained through such authorized access; and may not use any Union Pacific information other than for the purposes authorized by the company.
- Suppliers may not use Union Pacific’s name, logo, images or other assets conveying the railroad’s 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.
- 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 Union Pacific, unless it is a railroad deemed emergency situation
- Suppliers must maintain a safety portal (ISN), E-RAILSAFE Profile, E-Verify Profile, training records, and safety records, as required by Union Pacific.
- Suppliers are responsible for maintaining updated company records required by Union Pacific. Some examples include: contact information, legal information, tax information, financial records, Federal Railroad Administration records, Union Pacific reporting requirements, and billing records.
- Suppliers are expected to demonstrate compliance with the Code of Conduct upon Union Pacific’s request. The railroad reserves the right to verify compliance including through on-site visits and inspections by designated personnel.
- A supplier’s failure to comply with Union Pacific’s audit review process or falsification of any documents provided during an audit may result in the company pursuing legal action and/or discontinuing the business relationship.
- Suppliers should have a policy for reporting workplace concerns. The policy and process should be transparent and understandable and should protect reporting and participating individuals from retaliation.
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 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) upon request.
Human & Labor Rights
- Suppliers must adhere to all applicable Union Pacific policies while working on the company’s property including but not limited to general safety practices, E-Railsafe requirements, and Union Pacific’s no smoking policy.
- Suppliers must prohibit any discrimination or harassment based on a person's race, color, sex, 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 Union Pacific’s Supplier Code of Conduct to all employees and subcontractors involved in doing business with the company.
- 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 Union Pacific’s request. The company 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:09/18/2025
Last Reviewed: 10/01/2025