Union Pacific Corp

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Union Pacific Corp demonstrates a comprehensive level of transparency regarding its climate lobbying activities. The company explicitly names specific policies it has engaged with, such as its collaboration with the California Air Resources Board (CARB) and California's air quality control districts to manage emissions from railroad operations, efforts to modernize locomotives to meet stricter air emission standards, and its lobbying for the Infrastructure Investment and Jobs Act (IIJA), which includes funding for electric-grid and renewable energy programs, locomotive overhauls, and remanufacturing to reduce emissions. Union Pacific also provides detailed information about its lobbying mechanisms and targets, including direct collaboration with CARB, California's air quality control districts, and participation in the California Council on Environmental and Economic Balance (CCEEB) to engage in consultations with government entities and public officials. Additionally, it actively participates in national industry organizations such as the U.S. Chamber of Commerce and the National Association of Manufacturers, and collaborates within the rail industry through groups like The Association of American Railroads (AAR) Decarbonization Working Group. The company is transparent about the specific outcomes it seeks, such as educating policymakers on the environmental benefits of rail transportation, advocating for legislation that reduces greenhouse gas emissions by shifting freight traffic from trucks to trains, and supporting market-based solutions to develop low- and zero-carbon technologies. Union Pacific also aims to align its lobbying activities with the Paris Agreement, as evidenced by its upcoming report analyzing trade association memberships for alignment with climate change policies. These disclosures reflect a clear articulation of desired legislative and regulatory outcomes, mechanisms, and policy engagements.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	Union Pacific demonstrates a defined governance process for climate lobbying alignment, particularly through its oversight structures and proactive measures. The company states that its "Board of Directors provides oversight of our ESG strategy," with the Corporate Governance, Nominating and Sustainability Committee responsible for reviewing ESG developments and recommending modifications to practices, policies, and procedures. Additionally, Union Pacific has formalized a Sustainability Team, which includes "an individual dedicated to overseeing the day-to-day implementation of Union Pacific's ESG strategy." The company ties "key performance indicators in our executive compensation scorecard" to fuel efficiency goals and emissions reductions, embedding accountability into its governance structure. Union Pacific has committed to publishing a report in 2023 that will describe "if, and how, our lobbying activities align with the Paris Agreement," including a "deep dive analysis into our key trade association memberships" to identify alignment and misalignment with climate policies. Furthermore, Union Pacific collaborates within the rail industry through participation in "The Association of American Railroads (AAR) Decarbonization Working Group and Locomotive Committee" to advance policy and technology supporting decarbonization. While these measures reflect strong governance processes for monitoring and managing climate lobbying activities, both direct and indirect, the evidence does not indicate the publication of a detailed lobbying audit or comprehensive review, which would further enhance transparency and accountability.	3