EQUAL EMPLOYMENT OPPORTUNITY, DISABILITY AND COVERED VETERANS AFFIRMATIVE ACTION, AND RELATED POLICY DIRECTIVES
EQUAL EMPLOYMENT OPPORTUNITY, DISABILITY AND COVERED VETRANS AFFIRMATIVE ACTION, AND RELATED POLICY DIRECTIVES
EQUAL EMPLOYMENT OPPORTUNITY, DISABILITY AND COVERED VETERANS AFFIRMATIVE ACTION, AND RELATED DIRECTIVES
Purpose
Union Pacific is committed to creating an inclusive environment of mutual respect where equal employment opportunities are available without regard to race, color, sex, national origin, age, disability, religion, military and veteran status, sexual orientation, gender identity, gender expression, pregnancy, or genetic information, so that all employees can contribute to their fullest potential. We seek to recruit, develop and retain the most talented people based on merit and performance. These policy directives explain what Union Pacific expects of its employees.
Prohibition of Discrimination or Harassment
Union Pacific strictly prohibits 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, pregnancy, genetic information, or any other basis prohibited by law ("protected status"). This policy covers all aspects of employment, including hiring, promotions, terminations, pay, and the work environment.
Sexual Harassment. Union Pacific prohibits sexual harassment of employees, contractors, interns, volunteers, customers, visitors, or others whom employees may come into contact while working, representing the Company or while on Company travel.
Sexual Harassment can be words, actions, or both. It includes obvious things, like requests for dates or sex, deliberate touching, patting, or grabbing. It can also include more subtle behaviors like repeated comments about a person's physical appearance, sexually explicit pictures or magazines displayed in the work area, or conversations about sexual habits and fantasies.
Union Pacific prohibits unwelcome sexual advances, requests for sexual favors, and other verbal or physical behavior of a sexual nature when:
- Submission to or rejection of such conduct is made either explicitly or implicitly a term or condition of a person's job, pay or career;
- Submission to or rejection of such conduct by a person is used as a basis for career or employment decisions affecting that person;
- Such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creates an intimidating, hostile, or offensive work environment.
Prohibition of Offensive Behavior & Remarks
Union Pacific is committed to providing a work environment free from offensive behavior and statements directed toward any other protected status. This policy prohibits such offensive behavior or statements in the workplace, while representing Union Pacific, including but not limited to interactions with any Union Pacific vendor, customer or the community; while using any social media provided by or sponsored by Union Pacific; or during travel or overnight stays paid for by Union Pacific even if no one present is offended by the behavior or remark. Additionally, offensive conduct that is intended to, or can reasonably be expected to, create a hostile work environment may be considered a violation of this policy, even if the conduct occurs off-duty, off property, or through an employee’s private electronic devices.
Prohibition of Retaliation
There will be no retaliation, including intimidation or threats, against any employee for making a good faith report of alleged violations of our Company's policy against discrimination, harassment, or offensive behavior; opposing any practice believed in good faith to be unlawful; or assisting in or participating in an internal or government investigation of prohibited behavior. Any employee who engages in prohibited retaliation will be disciplined, up to and including termination.
No Tolerance
Union Pacific does not tolerate any type of discrimination, harassment, or offensive behavior based on a protected status. All substantiated violations of Union Pacific's policies against discrimination, harassment, and offensive behavior will result in appropriate discipline of the employee, up to and including termination.
Reporting Violations and Questions
Any person who believes they are being subjected to behavior or actions of this nature, or any person aware of such prohibited conduct, has an obligation to report the matter. Employees MUST come forward when violations occur or when there is a need for further information or assistance. Any alleged policy violations will be investigated. Employees MUST either call the toll-free, 24-hour hotline at 1-866-877-3362 [1-866-UPR-EEOC] or file a complaint online. For matters concerning employee relations and respect, employees should address directly with their coworker if they are comfortable doing so. If not, address with a supervisor, Human Resource Business Partner or use the Values Line for resolution.
Americans with Disabilities Act (ADA)
The Americans with Disabilities Act (ADA) is a federal law that prohibits employers with 15 or more employees from discriminating against a qualified individual on the basis of disability in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training, and other terms, conditions, and privileges of employment.
It is the policy of Union Pacific to comply with all federal and state laws concerning the employment of persons with disabilities and to act in accordance with regulations and guidance issued by the state and local authorities. Furthermore, it is Union Pacific’s policy not to discriminate against qualified individuals with disabilities in their employment. If any applicant or employee believes he or she has been discriminated against based on disability, he or she should immediately make a report to Union Pacific.
Under the ADA, covered employers must make reasonable accommodations for an otherwise qualified individual with a disability if necessary to provide the person an equal opportunity in employment where such accommodation can be made without undue hardship. Any applicant or employee with a disability may request a reasonable accommodation from Union Pacific. Union Pacific will provide reasonable accommodation to an otherwise qualified individual with a disability that is necessary to provide the person an equal opportunity in hiring and/or employment processes unless doing so (1) poses a direct threat to the person or others and the threat cannot be eliminated by reasonable accommodation or (2) imposes an undue hardship to Union Pacific.
Union Pacific will engage in the interactive process with any person requesting a reasonable accommodation. This interactive process may include a request for reasonable medical documentation to allow Union Pacific to ascertain whether the individual has a qualified disability under the ADA, whether the disability necessitates accommodation, and/or what appropriate accommodations may be available. Union Pacific will conduct an individualized assessment of each request for a reasonable accommodation considering all submitted information from the individual, the individual’s medical provider, and any other pertinent information necessary to evaluate the request.
An applicant or employee may request a reasonable accommodation by contacting Health and Medical Services, including the vocational case managers, fitness for duty nurses, occupational health nurses or make a request online. Union Pacific will process requests for reasonable accommodations and will provide reasonable accommodations where necessary in a prompt and efficient manner. Union Pacific’s EEO Staff will administer the policy. Health and Medical Services personnel will implement the reasonable accommodation program system-wide in coordination with supervisors and managers.
Religious Accommodations
The Company will also make reasonable accommodation for the religious needs of employees where such accommodation can be made without undue hardship. Persons wishing to request reasonable accommodation based on religious beliefs should submit a TRM Ticket.
Application of Equal Opportunity and Disability and Covered Veterans Affirmative Action
Union Pacific is committed to equal employment opportunities. Union Pacific administers its affirmative action plan for individuals with disabilities and covered veterans and equal employment opportunities procedures to support these principles. Persons who would like more information are invited to contact the Human Resources Staff at (402) 544-0050.
Government Agencies
In addition to reporting complaints of discrimination or harassment to the Union Pacific EEO Staff via a complaint online or calling the toll-free, 24-hour hotline at 1-866-877-3362 [1-866-UPR-EEOC], you have the right to file a complaint with various federal and state agencies. Telephone numbers for these agencies may be obtained from the posters at each facility, the EEO Staff website or from the EEO Staff.
Compliance Expectations
Union Pacific expects each of its employees to be thoroughly familiar with these policy directives and make certain that they comply. Violation of these policies will result in appropriate discipline, up to and including termination.
Responsibility for Implementation
As CEO, I am committed to the implementation of the Company’s equal opportunity and affirmative action for individuals with disabilities and covered veterans policies. I have delegated overall responsibility for these policies to our Senior Vice President and Chief Human Resources Officer.
Effective Date: 04/02/2025
Last Updated: 06/10/2025
Last Reviewed: 07/16/2025