Integrity

We Care About Integrity
At BNSF, we operate our company to comply with the highest standards of business ethics and integrity.

A Culture of Integrity

Our team members recognize the important shared value of continuously improving by striving to do the right thing safely and efficiently. As a company, we’ve built a strong reputation for doing the right thing in our relationships with customers, suppliers, team members and our communities.

All BNSF employees are accountable for our actions and are responsible for promoting honest and ethical conduct and complying with company policy, legal and regulatory obligations.

Code of Conduct

Our culture of integrity is manifested in our Code of Conduct. Each year, all exempt employees are required to certify to the Code of Conduct, confirming that they understand and agree to comply with company policies and expectations regarding employee conduct.

The BNSF Code of Conduct provides standards and guidelines for:

  • Workplace Conduct
  • Business Ethics
  • Conflicts of Interest

Our Code works hand in hand with our policies to define our expectations for acceptable conduct at BNSF regarding:

  • Gifts and Entertainment
  • Bribery and Corruption
  • Cybersecurity
  • Confidential Information and Intellectual Property
  • Records and Information Management
  • Antitrust and Dealing with Competitors
  • Environmental, Health and Safety

Anti-Bribery, Anti-Corruption & Prohibited Business Practices

Compliance with anti-corruption, international trade and anti-money laundering laws are key requirements for BNSF. Our compliance procedures include conducting third-party due diligence, monitoring accounts payables and receivables and travel and entertainment expenses, and periodic training of employees. Every two years, select BNSF exempt employees are required to complete an Anti-Bribery, Anti-Corruption, and Prohibited Business Practices Training Course. This training is intended to give employees the knowledge and tools necessary to conduct business in compliance with these laws and provide awareness of export control, sanctions, anti-boycott, and customs laws.

Avoiding Conflicts of Interest

As part of the annual Code of Conduct review and certification process, employees must report any relationships or activities that may create a potential or actual conflict of interest. Employees are required to keep their conflicts of interest disclosures current throughout the year and report any new or changed conflicts of interest as soon as it is known. Potential conflicts of interest reviewed include vendor and family relationships, industry and board memberships, and secondary employment. Potential conflicts are reviewed by our Compliance Team and the employee’s leadership, and employees are provided with safeguards to ensure the reported relationship or other activity doesn’t become or appear to become a conflict of interest.

Reporting Unethical Behavior

At BNSF, everyone can contribute to sustaining our culture of integrity by watching for and speaking out about behavior that is unethical, illegal or in conflict with our Vision and Values or Code of Conduct. We have strong controls to prevent and detect fraud and abuse, but nothing can replace a vigilant workforce. Employees are encouraged to raise concerns with their supervisor or department leadership. If they are unable to talk with their leadership, they can reach out to our Human Resources or Compliance teams. One tool always available is the BNSF Hotline (800-533-BNSF or brk-hotline.com). Hotline reports may be made anonymously and are thoroughly investigated. We prohibit retaliation for good faith reporting of apparent or actual illegal or unethical conduct.

Policies & Corporate Rules

BNSF Policies, Rules and Procedures help define employee expectations and provide guidance to ensure we are in alignment with our Code of Conduct and Vision and Values. All BNSF employees are required to understand and comply with applicable BNSF policies, which identify high-level requirements. Corporate rules provide details supporting the policies and procedures lay out instructions for complying.

BNSF policies address areas including:

  • Anti-Corruption and Prohibited Business Practices
  • Anti-Retaliation
  • Antitrust Compliance
  • Confidentiality of Medical Information and PHI
  • Contracts and Payments
  • Corporate Relations
  • Environmental, Health and Safety
  • Equal Employment Opportunity, Anti-Discrimination and Harassment
  • Gifts and Entertainment
  • Information Governance and Confidentiality
  • Information Security
  • Intellectual Property
  • Investment Activities
  • Purchasing and Payment Methods
  • Records and Information Management
  • Secure Facility Access
  • Social Media
  • Travel and Entertainment Expenses
  • Use of Alcohol and Drugs
  • Violence in the Workplace

Role of Board of Directors & Executive Team

As well as overseeing the execution of our Vision & Values, Leadership Model, and overall strategic direction of the company, the Board of Directors has a formal role in annually approving the Code of Conduct and all disclosed conflicts in respective areas of responsibility. The Executive Team is responsible for leading by example in all areas of ethical business activity and for ensuring policies are in place that promote the highest levels of business ethics and integrity. They also review all new policies and policy changes.

BNSF Board of Directors:

  • Warren Buffett
  • Marc Hamburg
  • Gregory Abel
  • Carl Ice
  • Katie Farmer
  • Paul Bischler
  • Steve Bobb
  • Matt Igoe
  • Jill Mulligan

BNSF Executive Team (as of December 31, 2023):

Katie Farmer – President and Chief Executive Officer
Steve Bobb – Executive Vice President and Chief Marketing Officer
Matt Igoe – Executive Vice President and Chief Operations Officer
Jill Mulligan – Executive Vice President and Chief Legal Officer
Paul Bischler – Executive Vice President and Chief Financial Officer
Judy Carter – Senior Vice President and Chief Human Resources Officer
Zak Andersen – Chief of Staff and Vice President, Communications

Financial Transparency

The management of BNSF is responsible for establishing and maintaining adequate internal control over financial reporting. Our internal controls over financial reporting are designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of BNSF’s financial statements for external reporting purposes in accordance with accounting principles in the United States of America.

Reporting includes:

  • SEC Filings
  • Surface Transportation Board Reports (STB) R-1 Annual Reports
  • Consolidated Financial Statements
  • Quarterly Performance Summaries

Learn more

Regulatory Compliance

BNSF Railway’s rail operations are subject to the regulatory jurisdiction of the Surface Transportation Board (STB), the Federal Railroad Administration of the United States Department of Transportation (DOT), the Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA), as well as other federal and state regulatory agencies and Canadian regulatory agencies for operations in Canada.

The STB has jurisdiction over disputes and complaints involving certain rates, routes and services, the sale or abandonment of rail lines, applications for line extensions and construction, and consolidation or merger with, or acquisition of control of, rail common carriers.

DOT, OSHA, and EPA have jurisdiction under several federal statutes over a number of safety, health, and environmental aspects of rail operations, including the transportation of hazardous materials. State agencies regulate some health, safety, and environmental aspects of rail operations in areas not otherwise preempted by federal law.

Enterprise Risk Management (ERM)

Effective Enterprise Risk Management is at the foundation of BNSF’s compliance and audit functions, and our strategic corporate initiatives. On an annual basis, the Compliance team leads the formal review of our enterprise risks, analyzing changes in our business and the broader risk landscape, and seeking input from departmental and executive leadership. Results are discussed with BNSF’s senior leadership to ensure appropriate management activities and initiatives are in place to mitigate identified risks. Results are also used by the Compliance and Audit Department to shape the annual compliance and audit plans, and results are shared with Berkshire Hathaway.

Some examples of how we identify and mitigate risks include designing and implementing an enhanced monitoring program for BNSF’s key material and service providers to mitigate material risks associated with potential vendor disruption or nonperformance. We also establish cross-functional coordination within BNSF in response to increased criminal activity impacting our network and implement a strategy to collaboratively engage industry participants, law enforcement and government agencies to seek long-term solutions.

Enhancing Data Privacy

We are committed to continuing to enhance our data privacy compliance program responsive to the evolving federal and state data privacy laws by protecting the privacy and security of the personal information of our employees, customers, vendors and other third parties.

The BNSF Privacy Statement is posted on BNSF.com, and it shares our commitment to protecting privacy and data for those visiting our Internet site and using our services. It provides details on the information we collect, our use of that information and our data security practices. The information we collect is used only for internal business purposes. We do not, nor do we plan to, sell any information collected through our website. Further, we do not plan to divulge information to any party other than BNSF affiliates, service providers and other third parties we use to help run our business.
Learn More