Climate change and the transition to a low-carbon economy pose critical risks to investors. All companies should appraise and disclose physical and transitional climate risks. The Company’s current disclosures are insufficient for investors to fully appraise climate-related risks and opportunities.

At the 2021 annual meeting, where a significant majority of non-insider shareholders supported a similar version of this resolution, the Company stated that climate disclosure at the parent Company level is unnecessary given the Company’s selective and partial subsidiary climate disclosures. However, shareholders can purchase shares only in the combined parent-company entity, not in the individual subsidiaries that may or may not have climate risk exposure. A parent Company climate risk disclosure to investors does not exist, is needed, and entails a modest degree of reporting centralization. Over 2,600 companies globally support the TCFD recommendations, with 98 of the Climate Action 100+ companies already reporting in line with this framework. Over 1,000 corporations have joined the Science Based Targets Initiative (SBTi) to set verifiable GHG reduction targets consistent with limiting global emissions to well-below 2°C. We welcome railroad subsidiary BNSF’s SBTi commitment.

Also, the Securities and Exchange Commission has said climate-related disclosures may yield information material to investors and companies navigating the low carbon transition and may become mandatory in the near term.