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 Corporate Compliance
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Corporate Compliance
Last updated 4/29/08
We take corporate compliance very seriously. Our comprehensive corporate
compliance program is designed to ensure that all employees and the Board of
Directors (directors) of the company not only meet legal requirements around
the world, but also operate responsibly and with integrity in everything they
do.
A combination of written guidelines, formal processes and management
oversight helps us ensure that strong corporate compliance isn't just words on
paper, but a way of doing business at Gap Inc.
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Code of Business Conduct
Our Code of Business
Conduct has been the foundation of our corporate compliance program since
1998. Some highlights:
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| Each employee and director of the company is responsible for complying with
the Code of Business Conduct. |
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| All of our employees around the world receive a copy of the Code when they
join the company and agree in writing to comply with it. |
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| Each employee worldwide is required to complete the Principles of
Integrity: Code of Business Conduct Overview training course, which reinforces
the company's commitment to the Code. |
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| On an annual basis, senior employees must certify their compliance with the
Code. |
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| All employees are periodically reminded of the Code and are encouraged to
report any suspected violations through the company's Open Door process, the corporate_compliance@gap.com
mailbox or by utilizing the Code Hotline. |
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| Reflecting the global reach of our company and diversity of our employees,
the Code is published in seven languages. |
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Corporate Compliance Department
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| To enhance our existing corporate compliance program, the company created a
Corporate Compliance department in 2003. |
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| The department's objective is to embed compliance infrastructure and the
company's integrity value into global business solutions and culture. |
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| Under the guidance of the Chief Compliance Officer, Michelle Banks, the department
leads the company's efforts to promote and enforce compliance with our Code of
Business Conduct. Banks reports directly to Gap Inc.'s CEO. |
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| Corporate Compliance works closely with other departments — including Human
Resources, Communications, Internal Audit, Loss Prevention and Corporate
Security — to raise Code awareness through communication and education, monitor
and audit Code compliance, and to investigate and respond to all suspected Code
violations. |
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| The department may be contacted at corporate_compliance@gap.com. |
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Corporate Compliance Committee
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| Gap Inc. has a Corporate Compliance Committee, a group of senior leaders
from various company divisions and functions that focuses on monitoring the
effectiveness of and providing input into the company's corporate compliance
program, as well as compliance-related risks. The Chief Compliance Officer,
Michelle Banks, chairs this committee. |
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Political Engagement Policy
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| We believe that it is important to participate in political and regulatory
processes on issues that affect our business and community interests. We work
proactively to enable Gap Inc.’s strategies through public policy and
government advocacy, and participate in political activities and advocate for
legislation when there is a connection to our ability to grow our business in a
way that is consistent with our values, our legal obligations, and our Codes of
Business Conduct and Vendor Conduct.
Read the PDF for the full text of our political engagement policy. |
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Reporting
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| Ms. Banks and the head of Corporate Compliance periodically report to the
Audit and Finance
Committee of Gap Inc.'s Board of Directors on the effectiveness of the
company's corporate compliance program. The Audit and Finance Committee has
ultimate responsibility for compliance. |
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| We are committed to continually evolving our corporate compliance program
in line with legal and regulatory requirements, corporate ethics best practices
— and our own high standards. |
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Code of Business Conduct
(PDF: 1182k)
Choose language
To report suspected violations of our Code of Business Conduct, see the
Code Hotline page.
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