View:
United States securities and exchange commission logo
September 17, 2021
Jennifer L. Hamann
Chief Financial Officer
Union Pacific Corporation
1400 Douglas Street
Omaha, Nebraska 68179
Re: Union Pacific
Corporation
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 5,
2021
File No. 001-06075
Dear Ms. Hamann:
We have reviewed your filing and have the following comments. In
some of our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
1. We note that you
generally refer to past and/or future capital expenditures. If material,
please separately
quantify any climate-related capital expenditures, such as investments in
new technologies.
2. If material, disclose
any anticipated reputational risks resulting from your operations that
produce material
greenhouse gas emissions.
3. If material, discuss
the significant physical effects of climate change on your operations
and results. This
disclosure may include the following:
quantification of
material weather-related damages to your property or operations;
the impact to your
business of decreased agricultural production capacity of your
customers located
in areas affected by drought or other weather-related changes; and
any weather-related
impacts on the cost or availability of insurance.
4. If applicable and
material, provide disclosure about any purchase or sale of carbon credits
or offsets and any
material effects on your business, financial condition, and results of
operations.
Jennifer L. Hamann
Union Pacific Corporation
September 17, 2021
Page 2
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
You may contact Diane Fritz (Staff Accountant) at (202) 551-3331 or Brad
Skinner
(Office Chief) at (202) 551-3489 if you have questions.
FirstName LastNameJennifer L. Hamann Sincerely,
Comapany NameUnion Pacific Corporation
Division of
Corporation Finance
September 17, 2021 Page 2 Office of Energy &
Transportation
FirstName LastName