In 2010, a law was passed in the state of California requiring companies to disclose what they are doing to address human trafficking in their supply chains. Referred to as SB 657, the California Transparency in Supply Chains Act seeks to “educate consumers on how to purchase goods produced by companies that responsibly manage their supply chains … to improve the lives of victims of slavery and human trafficking.”
Under no circumstance is it acceptable for child, forced or trafficked labor to be used in the production of any Gap Inc. product. We believe that no person should be subject to a situation where basic needs and fundamental rights are denied.
Our efforts to address human trafficking in the apparel industry are guided by our Human Rights Policy, which is founded upon the principles outlined in the United Nations Universal Declaration of Human Rights (UDHR), and the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work (often referred to as the “ILO Core Conventions”), and applies to both our wholly-owned operations and our apparel supply chain.
Gap Inc. has a Code of Vendor Conduct (COVC or “code”) that all of our branded apparel vendors must abide by, which explicitly states that forced labor of any kind is strictly prohibited. Our COVC and the enforcement behind it is an important mechanism that brings our Human Rights Policy to life within our supply chain. We have a team of approximately 50 Social Responsibility Specialists located in over 20 countries who monitor working conditions in these factories, and work with management to help ensure that they abide by our code.
The United States’ Victims of Trafficking and Violence Protections Act (TVPA) of 2000 defines human trafficking as:
“Any recruitment, harboring, transportation, provision, or obtaining of a person for labor services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery.”
For vendors that employ foreign contract workers, we have additional rigorous requirements that are designed to protect these workers. We monitor how foreign contract labor is used at factories that produce Gap Inc. branded apparel to help ensure that people are free to work as they choose. On the ground, our Social Responsibility Specialists have a deep knowledge of the issue from interviewing workers, gaining their trust, and learning over time about which agents and factories have good or bad reputations.
The majority of our Social Responsibility Specialists are locally hired and speak the local languages in the regions where they work. In 2010 alone, our team monitored over 1300 factories, seeking to ensure our COVC was abided by. Comprehensive data on our monitoring can be found on our Social and Environmental Responsibility website, which is available here.
Our involvement in efforts to address various forms of human trafficking is not limited to our comprehensive factory monitoring and remediation program. For example, we are active members of the multi-stakeholder network seeking to end forced child labor in Uzbekistan’s cotton sector. We also support handwork centers in Northern India where at-risk women can safely work, as well as a regional education initiative that helps raise awareness of how to avoid traffickers.
Because of the complexity of this problem, we know that confronting it will require collaboration across industries, and must include partnership among public, private, and non-profit sectors. Accordingly, we have a long history of working with a number of entities that are actively addressing various facets of human trafficking problems, including the Interfaith Center on Corporate Responsibility, the Not For Sale Campaign, the Responsible Sourcing Network, and the UN Global Initiative to Fight Trafficking. We encourage you to visit their websites and view the initiatives they are advancing to fight various forms of human trafficking.
A sustained, collaborative effort is required to bring about an end to this global, urgent issue. We are committed to continuing to work with NGOs, companies, and other entities to ensure that we are effectively contributing to the global fight against human trafficking.
The points outlined below in bold highlight each of the five pillars of the California Transparency in Supply Chains Act, followed by an explanation of what Gap Inc. is doing to address each pillar.
Company engages in verification of product supply chains to evaluate and address risks of human trafficking and slavery. The disclosure shall specify if the verification was not conducted by a third party.
Gap Inc. monitors nearly 100 percent of the garment factories that produce Gap Inc. branded apparel. We verify our product supply chains through both announced and unannounced visits to measure factories’ compliance with our Code of Vendor Conduct, which includes strict prohibition of “forced labor … or involuntary labor of any kind.”
Most of Gap Inc.’s audits are conducted by our own internal team of Social Responsibility Specialists. A number of factories producing our branded apparel are participating in the International Labor Organization’s Better Work program, which will be operational in seven countries by the end of 2011. More information on the Better Work program is available here.
Company conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking and slavery in supply chains. The disclosure shall specify if the verification was not an independent, unannounced audit.
Gap Inc. conducts both announced and unannounced audits in factories that we monitor. These audits are primarily conducted by Gap Inc. staff. Gap Inc.’s company standards on labor laws and human rights are outlined in our COVC and our Human Rights Policy. Our COVC, with which all facilities producing Gap Inc. branded product must comply, explicitly states that vendors must not use “forced labor … or involuntary labor of any kind”. Human trafficking and slavery fall under the categorization of “forced labor” and “involuntary labor.” Our COVC further states that factories must allow “Gap Inc. and/or any of its representatives or agents unrestricted access to its facilities and to all relevant records at all times, whether or not notice is provided in advance.”
Company requires direct suppliers to certify that materials incorporated into the product comply with the laws regarding slavery and human trafficking of the country or countries in which they are doing business.
Prior to accepting any order for Gap Inc. branded product, our suppliers are required to sign our Vendor Compliance Agreement and agree to be bound by our Code of Vendor Conduct. Gap Inc.’s COVC states that:
“Factories that produce goods for Gap Inc. shall operate in full compliance with the laws of their respective countries and with all other applicable laws, rules and regulations … including those relating to labor, worker health and safety, and the environment.”
In signing Gap Inc.’s Vendor Compliance Agreement, which also incorporates the COVC, Gap Inc. suppliers agree to comply with the following:
“All applicable laws, rules and regulations … these laws include, but are not limited to, laws relating to the employment conditions of their respective employee such as: (1) wage and hour, labor, child labor, and forced labor requirements; (2) health and safety; (3) immigration; (4) discrimination; (5) labor or workers’ rights in general and (6) environmental laws and regulations.”
Company maintains internal accountability standards and procedures for employees or contractors failing to meet company standards regarding slavery and trafficking.
Failure of employees to abide by Gap Inc.’s Code of Business Conduct can result in corrective action up to and including termination of employment. Failure of vendors to abide by Gap Inc.’s Code of Vendor Conduct and/or Vendor Compliance Agreement can result in corrective action up to and including the “termination of all existing and future business.”
Company provides company employees and management, who have direct responsibility for supply chain management, training on human trafficking and slavery, particularly with respect to mitigating risks within the supply chains of products.
Gap Inc.’s Monitoring and Vendor Development team works directly with factory management and workers in the factories that we monitor. Gap Inc.’s Code of Vendor Conduct (COVC) explicitly states that facilities producing Gap Inc. branded product must “not use involuntary labor of any kind,” of which human trafficking is one kind. Our COVC also has stringent requirements around “contract labor,” which can sometimes be exploited to create instances of indentured servitude for workers. Our Social Responsibility Specialists are trained in how to identify these potentially abusive situations.