Endorsement Policy

March, 2025

The Gap, Inc. and its affiliated brands (Old Navy, Gap, Banana Republic, and Athleta) (“Gap Inc.,” “we,” or “us”) are committed to complying with laws and regulations related to advertising, endorsements, and testimonials. This Endorsement Policy (“Policy”) provides guidelines for all non-employees (customers, independent contractors, brand ambassadors, bloggers, influencers, etc., whether they are engaged directly by Gap Inc., or through an agency or other affiliate) publicly endorsing Gap Inc. products or services (“you” or “Endorser”).

An endorsement is any statement, product review, audio or video recording, online message, or other public communication that someone else is likely to believe reflects the Endorser’s opinions about products or services. Gap Inc. reserves the right to change, alter, or modify this Policy at any time without prior notice. If you do not agree to this Policy, then do not make an endorsement.

Endorsers are responsible for their own content and may be held personally liable for any commentary that violates the law. Gap Inc. may audit endorsements and may require amendments or terminate its relationship with you in the event of non-compliance with this Policy.

Endorsement Requirements:

  • You may not make statements about a product or service you have not personally used, examined, or evaluated.
  • You may only make statements that reflect your bona fide, honest opinions, findings, beliefs, or experiences. Endorsements by organizations must reflect the collective judgment of the organization.
  • You may not make deceptive, misleading, untruthful, or unsubstantiated claims about Gap Inc. products or services.
  • You may not use Gap Inc.’s intellectual property (e.g., trademarks, logos, designs, or images) without the prior written consent of Gap Inc.
  • If you have access to proprietary or confidential information about Gap Inc. (including product, design, business, or financial information), you must keep it confidential, except as required by law
  • You may not publish nor provide any content when endorsing Gap Inc. brands that:
    • contains content that is, or may reasonably be considered to be, hate speech, or promotes bigotry, racism, hatred or harm against any group or individual or promotes discrimination based on race, gender, religion, nationality, disability, sexual orientation, age, family status, or any other legally protected class;
    • is lewd, obscene, sexually explicit, pornographic, inappropriate, or indecent;
    • is hateful, tortious, defamatory, slanderous or libelous;
    • is related to tobacco, alcohol, illegal drugs, any criminal or illegal activity;
    • discloses sensitive or personal data, either your own or others
    • infringes on the intellectual property, privacy, or publicity rights of others; or
    • violates local, state, or federal laws or regulations, (including the Federal Trade Commission’s Guides Concerning the Use of Endorsements and Testimonials in Advertising and related FAQs).

Disclosures: Endorsers must “clearly and conspicuously” disclose any “material connections” to Gap Inc. in all messages and communications concerning Gap Inc. products or services.

  • “Clear and conspicuous” means a disclosure that is difficult to miss and easy to understand. Disclosures should:
  • Match the format of the associated endorsement.  If the endorsement is visual, the disclosure should be too.  If the endorsement is spoken, the disclosure should be too.  If the endorsement is video (audio AND visual), the endorsement should be too.
  • Stand out from any other text or visual elements so that it is easily noticed.
    • Use differing size, contrast, location, etc. where possible.
    • Don’t mix a disclosure hashtag into a group of hashtags or links.
    • For video endorsements, superimpose the disclosure over the video in a reasonable font size (i.e., larger than standard captions) with contrast against the background of the video.
    • On Snapchat and Instagram Stories, you should superimpose the disclosure over the images on these platforms in a manner that is easy for your followers to read during the time that they see the image.
  • Be easily heard and understood.
  • Be unavoidable.
    • Don’t bury disclosures below a “read more” button
    • Include disclosures in each and every post, even if they are already in your profile or in prior communications.
    • Don’t assume a social media platform’s disclosure tool makes the disclosure unavoidable.
    • If an endorsement video is longer than a few minutes in duration, you should include multiple disclosures.
    • If an endorsement video will have on-screen ads, you should place the visual disclosure where it will not be obscured by those ads.
  • Not contradict or be inconsistent with anything else in the endorsement.
  • The following hashtags are not acceptable for purposes of disclosing your material connection to Gap Inc.: #Thanks, #Collab, #Spon, #Ambassador, #Sweeps, or #Endorsement.
  • A “material connection” is a relationship between you and Gap Inc. that may affect the weight or credibility of your endorsement if that connection is not reasonably expected by the audience. Material connections include:
    • Receiving payment;
    • Receiving free or discounted products;
    • Receiving other benefits like early access to a product, travel, or event access;
    • Receiving entry into a contest or sweepstakes or other chance at benefits; or
    • Contractual, familial, or personal relationship between you and Gap Inc.

Last Updated: March, 2025