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Our global COBC, which is published in languages, sets out the policies, values, and principles we expect all Gap Inc. employees to uphold and comply with.
Additional training based on location, level, and role is required.
It includes specific issues such as sexual harassment, non-discrimination and harassment, wage and hour compliance, workplace accommodations, anti-corruption, and data privacy and security.
TO SPEAK UP We encourage our employees to report any suspected violations through our Open Door process.
Employees can raise concerns with their manager, next-level manager, local human resources, our Global Integrity team, or our confidential COBC Hotline.
The hotline is a telephone and web-based reporting system available who conducts business with Gap Inc.
Our companywide system monitors and addresses anti-corruption risks and enforces our internal Anti-Corruption and Anti-Bribery Policies.
We deliver anti-corruption training (available to all employees) to specific levels and high-risk markets to help employees recognize and avoid corrupt practices.
The COVC also sets out our basic expectations for environmental standards to all Tier whom Gap Inc. conducts business.
DATA PRIVACY As a global brand built on the foundation of customer trust, we respect the privacy rights of our customers.
We follow seven principles in our approach to data use, new technologies, and services: consent, control, fairness, minimization, confidentiality, access, and accountability.
Our Privacy Policy adheres to laws across the jurisdictions where we do business.
While these rights may vary, we make reasonable efforts to honor requests even if a country or jurisdiction does not require us to do so.
Our privacy policies have received accolades for their clarity and simplicity.
We also know that security is at the center of any good privacy program.
We use widely accepted security standards and practices to guide our decisions around securing personal information.
to our ESG strategy – as is maximizing our positive impact through our programs.
We regularly partner with a broad set of stakeholders to better understand the complex issues that affect them, our industry landscape, and society.
This dialogue helps us improve our strategies, set goals, focus our action, and scale up industry solutions.
Find more about our initiatives and partner organizations on our website.
IN OUR SUPPLY CHAIN Our Supplier Sustainability and Human Rights and Labor teams are responsible for managing and implementing our human rights and labor stakeholder engagement strategy.
Supplier Relationships We regularly engage with our suppliers to advocate for human rights and drive better practices.
To enable a clear understanding of our Human Rights Policy, practices, and grievance channels, we provide all relevant information in local languages through an online platform and offer in-person and virtual support wherever needed.
COMMUNICATING WITH WORKERS We routinely engage with workers in our Tier assessments, including formal interviews, and through the informal relationships that our teams have created with worker representatives.
We also encourage the people who work in our supply chain to share their thoughts and experiences, and we use digital technology to make the feedback process as easy as possible.
These regular check-ins enable us to learn about specific human rights issues or to mitigate any risks proactively.
In addition, we interview workers as we develop and improve our programs focused on workers’ rights and empowering women.
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.
We also participate in political activities and advocate for legislation when there is a connection to our business and our ability to grow the business in a way that is consistent with our values, our legal obligations, and our Codes of Business Conduct and Vendor Conduct.
For example, Gap Inc. CEO Mark Breitbard met Vice President Kamala Harris at the White House in policies to boost the care economy and its impact on workers in the postpandemic environment.
Additionally, in the past we have been active in policy discussions and have lobbied on issues related to trade, tax policy, ports/infrastructure, and environmental issues.
Gap Inc. only takes positions on ballot measures, initiatives, or propositions that have a direct impact on our business.
Convening industry and stakeholder partners on systemic issues that require collaboration.
Implementing formal and informal consultations with expert organizations on material issues. 3.
trained to design and manufacture more sustainable products, and have significant influence over who makes our clothes.
This enables us to address our wider environmental footprint and improve working conditions in facilities.
See more about our assessment, water, chemicals management, materials, and circularity practices in our Enriching Communities and Empowering Women & Human Rights sections.
To minimize the impacts of the fibers we use in our products, we place a special focus on cotton, and we are also taking steps to source more sustainable synthetic and manufactured cellulosic fibers.
energy and water, as well as chemicals that may impact local watersheds if not treated properly.
Through our Mill Sustainability Program, we integrate clear environmental standards into our sourcing decisions.
Our comprehensive approach for improving working conditions in our supply chain combines facility-monitoring and capability-building programs that engage our vendors to measure and address their environmental and social impacts.
We use an optimal mix of transportation methods via sea, air, truck, and rail to move products from suppliers to our distribution centers, and then to stores and customers.
We are working to conserve energy and reduce waste at our distribution centers, the largest facilities we own and operate.
care for, and discard their clothes to reduce our products’ total environmental footprint.
We also engage in and contribute to industrywide solutions to reduce end-of-life impacts.
We also run This Way ONward at our Old Navy stores, helping young people experiencing barriers to employment obtain their first jobs.
This Way ONward, climate, circularity, and materials in our Enriching Communities and Enabling Opportunities sections.
In a rapidly changing world, we want to address issues where Gap Inc. can have the greatest impact and influence.
We prioritize the sustainability issues that matter most to our stakeholders and business.
These are our material issues and they guide our ESG team’s strategy and programs.
We carried out our most recent materiality analysis in expert consultancy.
For clarity, the identification of our material issues that guide our sustainability strategy and programs should not be construed as a characterization regarding the materiality or financial impact of such issues or related information to investors in Gap Inc.
Our SASB Index references the Standard for the Apparel, Accessories & Footwear industry as defined by SASB’s Sustainable Industry Classification System – E-Commerce, Multiline and Specialty Retailers & Distributors, and Apparel, Accessories and Footwear, with the location of that information in Gap Inc.’s ESG Report an...
The TCFD is a framework of recommendations for companies to make more effective climate-related disclosures that could promote more informed investment, credit, and insurance underwriting decisions.
We are reporting to the TCFD for the first time this year, and our TCFD Index, detailing our climate-related risk disclosures, can be found on p.
CAUTIONARY NOTE ON FORWARD-LOOKING STATEMENTS This report and related comments by management may include “forwardlooking statements” within the meaning of the U.S. federal securities laws.
Forwardlooking statements are any statements other than statements of historical fact.
In making these statements, we rely upon assumptions and analysis based on our experience and perception of historical trends, current conditions, and expected future developments, as well as other factors we consider appropriate under the circumstances.
We believe these judgments are reasonable, but these statements are not guarantees of any future events or financial results, and our actual results may differ materially due to a variety of factors, many of which are described in our most recent Annual Report on Form with the U.S. Securities and Exchange Commission.
We caution readers not to place undue reliance on forward-looking statements.
Forward-looking statements speak only as of the date they are made, and we undertake no obligation to update publicly or otherwise revise any forwardlooking statements, whether as a result of new information, future events, or other factors that affect the subject of these statements, except where we are expressly requ...
We sought to prepare the report in reference with the Global Reporting Initiative (GRI) Standards.
Note: ESG Report refers to Gap Inc.’s Sustainability Webpages refer to our Global Website, which hosts our Environment, Social, and Governance (ESG) Hub and Equality & Belonging Report; Annual Report refers to Gap Inc.’s Annual Report on Form 10-K for the fiscal year ended January 29, 2022; and Proxy Statement refers t...
Please find more information on our Investor Relations Webpages.
or services that are banned in certain markets Annual Report Part I, Item 1.
Properties 102-4 Location of operations: Number of countries where the organization operates, and names of countries where it has significant operations and/or that are relevant to the topics covered in the report Annual Report Part I, Item 2.
Properties 102-5 Nature of ownership and legal form Annual Report Part II, Item 5.
served, and types of customers/beneficiaries Annual Report Part I, Item 1. Business, and Item 2.
Gap Inc. applies the precautionary principle to its use of chemicals through testing of its products and its commitment to the elimination of PFC-based finishes.
Materiality 52 102-45 List all entities included in the organization´s consolidated financial statement; report whether any entity is not covered in the report Annual Report Part I, Item 1.
Economic Performance 103-2 103-3 Management and approach Annual Report Part II, Item 7.
40 201-1 Direct economic value generated and distributed Annual Report Part II, Item 7.
Employees and Community Impact Gap Inc. performs an assessment for the This Way ONward program biennally, so please refer to the Sustainability Report p. 25 for program participant percentage increase in skills/knowledge.
To evaluate the effectiveness of Gap Inc.’s anti-corruption program, questions related to anti-corruption/anti-bribery are featured in Gap Inc.’s Code of Business Conduct (COBC) Assessments.
COBC Assessments are conducted each year, with different markets/ functions identified to assess.
The objective of the COBC Assessments is to gain an understanding of the impact of the COBC program.
205-1 Operations assessed for risks related to corruption We conduct Anti-Corruption Due Diligence (ACDD) in high-risk markets.
Within these markets, our policy requires that any third party that interacts with government officials on behalf of Gap Inc., and/or third-party distributors, have an ACDD report.
Responsible Business Practices Gap Inc. has two internal-facing anti-corruption policies: policy, and 2) a China Retail policy (high-risk market).
Gap Inc. also has an anti-corruption training program, delivered to global directors and above, managers and above in high-risk functions, and all levels of HQ in high-risk markets (China, Mexico, and Italy).
There is a separate course for the China employees, with content specific to the risks in China.
This course is delivered at hire or promotion into role, and is required annually in high-risk markets and every two years globally.
At times, Gap Inc. also delivers ad hoc anti-corruption training when there is opportunity (e.g. when we are traveling in market).
Measuring Our Progress: Environment *Defined as: Better Cotton (formerly BCI), verified US-grown cotton (USCTP), organic, in-conversion (to verified organic), recycled and regenerative.
We consider High Risk to be above countries: China, Egypt, India, Jordan, and Pakistan.
Our GHG data for previous years is currently available at the ESG Resources.
Scope website in 2022 at the ESG Resources.
Enriching Communities: Circularity and Waste 306-2 Management of significant waste-related impacts ESG Report Enriching Communities: Circularity and Waste 44 306-3 Waste generated ESG Report Enriching Communities: Circularity and Waste Gap Inc. is currently developing a data collection strategy for our waste management...
Learn more about our process on the above sustainability webpages.
ESG REPORT https://www.gapinc.com/en-us/values/sustainability/esg-hub/human-rights-and-supply-chain/assessment-and-remediation https://www.gapinc.com/en-us/values/sustainability/esg-hub/human-rights-and-supply-chain/policies-and-approaches-for-human-rights/child-labor-and-young-workers https://www.gapinc.com/en-us/valu...
They include our Restricted Substances List (RSL) and our Manufacturing Restricted Substances List (MRSL).
including the Apparel and Footwear International RSL Management (AFIRM) Group and the Sustainable Apparel Coalition (SAC) to implement a consistent set of tools and processes to support best practices, monitor supplier performance, and encourage use of safer chemicals.
requirements to our suppliers in our Code of Vendor Conduct (COVC) and Mill Minimum Expectations, and we require our suppliers to acknowledge and comply with these conditions.
product components and wastewater effluent, as well as the use of industry data platforms, we monitor the performance of our supply chain and verify compliance with global chemical regulations and Gap Inc. chemical restrictions.
Gap Inc. aligns with the AFIRM Group RSL.
To learn more about this process, please see the Chemicals Management page.
Discussion of processes to assess and manage risks and/ or hazards associated with chemicals in products Discussion and Analysis N/A CG-AA-hazards associated with their product materials and chemicals.
Input Management: The selection of better chemical inputs and starting materials is an essential part of reducing the use and discharge of hazardous chemicals.
Process Management: Adherence to chemicals management best practices during manufacturing is critical for reducing both human and environmental risks.