Responsible Business Practices

Managing Risks

We have several systems and procedures to identify and manage risks, including those related to human rights and labor, environmental impacts, and other sustainability issues. To prioritize risks and opportunities, we use tools such as our sustainability materiality assessment.

At the enterprise level, The Risk Committee, made up of leaders that represent the Senior Leadership team, provides oversight of the annual Enterprise Risk Assessment (ERA) process. The ERA begins with our Internal Audit team, who conducts an annual risk-assessment survey of more than 60 of the company’s top executives and Board members. The team also interviews a subset of these executives every quarter. The Risk Committee uses these interviews, as well as a review of external factors affecting our company and industry, to develop heat maps that prioritize risks based on the likelihood and severity of their potential impact on the company’s strategic initiatives and business operations. The CEO, Board of Directors and Senior Leadership team sign off and use the ERA to monitor and mitigate risks, as well as to update policies and include in Business Continuity Planning where required.

At the physical asset level, our Business Continuity Planning (BCP) team analyzes, prioritizes and helps mitigate risks to our owned and operated facilities and stores resulting from extreme weather, natural hazards and other external events. The BCP team uses predictive and actual models from the U.S. National Oceanic and Atmospheric Administration (NOAA) and other national and international agencies, which are overlaid against all of Gap Inc.’s facilities for tracking potential and actual impacts. The team uses a risk-assessment tool to determine the event and company risk and the residual risk remaining after preparedness plans are developed.

Engaging Stakeholders

Advancing progress on systemic issues such as water resilience, climate change, women’s empowerment, and safe and fair working conditions demands collaboration and jointly developed solutions.

Having operated a variety of factory-focused programs for over two decades, we have established a comprehensive network of stakeholders that we rely on for insight, guidance and accountability. The frequency of our engagement with stakeholders is based on their connection to our business, our ability to impact them and the salience of the issue being addressed. For example, we engage with each stakeholder group at different cadences, depending on salient risks, priorities for our stakeholders, and our own priorities. In addition to our regular check-ins with stakeholders, we might also actively seek out stakeholder engagement when there are developing issues related to specific supply chains, countries, or materials. In these instances, we are typically hoping to learn more about a specific human rights issue or stakeholder need, to proactively mitigate potential risks. In other cases, when issues arise, including violations of our Human Rights Policy, COVC, or COBC, we seek to work with suppliers, unions, worker-representative organizations, and local and international NGOs that have expertise and connections in the that area.

When human rights issues arise, we work with suppliers, unions, worker-representative organizations, and local and international NGOs that have expertise and connections in that area. Our aim is to prioritize the impact of affected parties and come to a resolution that is fair and ethical. We use what we learn to improve how we respond to future issues, and we share insights with other buyers, governments and other stakeholders so these lessons can be applied more broadly.

Our stakeholders include:

Local NGOs and trade unions: Our Supplier Sustainability team regularly checks in with these stakeholders in the countries from which we source, particularly when we identify complex labor-related issues in a factory.
International NGOs and trade unions: These organizations help us evolve and improve our labor and human rights policies and practices.
Multilateral institutions, development agencies and governments: These institutions’ policies and investments have a material impact on supply chain working conditions and environmental issues.
Industry initiatives: We are part of initiatives such as the American Apparel and Footwear Association (AAFA) Social Responsibility Committee and the Retail Industry Leaders Association (RILA) ESG Committee, which convene brands to scale and amplify collective efforts related to human rights and environmental impacts.
Suppliers: Our suppliers are critical partners in helping us achieve our goals related to garment workers and supply chain efficiencies:
- Our Global Supply Chain and Supplier Sustainability teams lead our efforts to improve labor standards in our supply chain through a proactive engagement strategy and reactive ethos that underscores the importance of responding to any relevant inquiry. Our sourcing department uses an integrated scorecard to measure our suppliers’ performance, including on social and labor issues.
- We lead regular dialogue with labor and human rights organizations at the international level. At the local level, our Supplier Sustainability team works in about 25 countries to gather insight on factories’ employment practices and working conditions through their relationships with community-based organizations, NGOs and trade unions. These networks augment the findings we gather through the assessments, trainings and surveys that we conduct at our suppliers’ facilities. For example, we engage with workers in our Tier 1 supply chain through formal interviews conducted during our assessments and through informal relationships with worker representatives. We also use worker-centric technologies in several markets, which allow us to receive constant feedback. about specific human rights issues or stakeholder needs to proactively mitigate any risks.
- In addition, we communicate our policies and commitments—including our Human Rights Policy and grievance channels—through multiple touch points (available in local languages and via in-person and virtual support when possible): an online platform that contains all relevant information on our human rights policies and practices; consultative in-person and virtual visits; and interviews and engagement with workers through our portfolio of programs that seek to respect workers’ rights and empower women.
Employees: We engage proactively with our employees quarterly to collect their feedback through surveys distributed by our HR team.
Customers: We also solicit feedback from a sample of customers through representative surveys conducted by our Consumer Insights team, including an annual survey that focuses on issues related to sustainability and our product offerings.

Code of Vendor Conduct (COVC)

Our Human Rights Policy defines our approach and activities to protect against abuses. To ensure that our partners act in line with our standards, we require that all facilities that produce goods for Gap Inc. meet our COVC requirements and Human Rights Policy.

We support and base our policies on the principles outlined in the Universal Declaration of Human Rights (UDHR), the UN Global Compact (UNGC), the OECD Guidelines for Multinational Enterprises and the International Labor Organization’s (ILO) Core Conventions.

Our COVC also sets out our basic expectations for environmental standards to all Tier 1 vendors and suppliers with whom Gap Inc. conducts business. We expect all facilities to comply with relevant environmental laws and regulations, manage their energy use and water impacts, and complete the Higg Index Facility Environment Module annually.

Code of Business Conduct (COBC)

Our global COBC serves as our ethical compass for the commitment to high standards that we make to our stakeholders, customers and one another.

There are several key aspects of how we implement our COBC:

Overview course: All employees are required to take this within 30 days of their hire date.
Compliance training: Our ongoing compliance training provides targeted employee audiences with deeper information on issues such as nondiscrimination and harassment, wage and hour compliance, workplace accommodations, anti-corruption, competition law compliance, and data privacy and security. Our Global Integrity team also conducts general in-person training sessions throughout the year.
Online tools: We provide a variety of self-help tools for compliance education and communication, including leader tools (e.g., how to have effective conversations with teams), FAQs, policy links and contacts.
Interviews: Each year, our Global Integrity team interviews select employees and suppliers to gauge their understanding of our COBC and to remind them of their responsibilities, our expectations and how to report COBC violations.
Certification: Annually, senior-level employees certify their COBC compliance and are briefed on relevant compliance or integrity topics.
Open-door process: We encourage employees to discuss any concerns with their supervisor, next-level manager or human resources representative. Employees may also contact our Global Integrity team, or report any issues via our confidential COBC hotline, email box and web portal, which are available 24 hours a day, seven days a week, to employees and anyone who conducts business with Gap Inc. or is affected by our business. Our investigative teams log, process and address any complaints received.

Anti-Corruption and Anti-Bribery

We are diligent about addressing corruption risks, particularly in developing countries with limited rule of law. We have a company-wide program for monitoring, enforcing and addressing any issues related to our Anti-Corruption / Anti-Bribery Policy (page 11 of our COBC), which combines elements from our COBC with anti-bribery requirements under the U.S. Foreign Corrupt Practices Act (FCPA) and other similar laws. The policy and related training programs help employees recognize and avoid corrupt business practices in all aspects of Gap Inc.’s business.

Data Privacy

Protecting the privacy rights of our customers and employees is an integral part of building trust. Our comprehensive privacy program includes policies, standards and practices focused on keeping the data we collect secure and respecting privacy rights around the globe.

Our Privacy Policy adheres to laws across the jurisdictions where we do business, and we make reasonable efforts to honor requests even if a country or jurisdiction does not require us to do so.

Our goal is to provide the highest quality experience to our customers while respecting their privacy. We have adopted seven principles that guide our choices as we adopt new products and services: consent, control, fairness, minimization, confidentiality, access and accountability. We also know that security is at the center of any good privacy program, and we use widely accepted security standards and practices to secure personal information.