The Gap Inc. Code of Business Conduct (COBC) is our foundation for promoting a responsible and ethical work environment. The Global Integrity & Compliance team is responsible for overseeing the program that brings the COBC to life.
Our co-founder Don Fisher once said, “The thing I’m the most proud of is the integrity of the company.” The COBC sets forth the company’s expectation that our employees do what’s right and act with integrity in all that they do. Among other things, the COBC informs our employees on how to prevent conflicts of interest, ensure compliance with laws and protect the company's information and assets. The COBC encourages employees to speak up if they have questions about the COBC or see improper conduct or behaviors.
Within 30 days of their initial hire date, all employees worldwide are required to take a COBC overview course, and every two years, select personnel globally are required to participate in an online refresher course. Additionally, we provide compliance training to various targeted audiences on topics of non-discrimination and harassment, wage and hour compliance, workplace accommodations, anti-corruption and competition law compliance. In 2011 we intend to launch a course on privacy. We also provide a variety of online tools for compliance training, including Leader Tools (which guide leaders in how to have effective conversations with their teams), FAQs, policy links and contacts.
Each year, our Global Integrity & Compliance team conducts over a hundred interviews with employees and selected vendors to gauge how well our business units understand our COBC, remind our employees and vendors of their responsibility, and ensure that they know how to report code violations. The team also conducts in-person compliance training sessions, and senior level employees must certify their COBC compliance annually.
We also expect that our vendors (including non-merchandise vendors) and others with whom we do business share our values and comply with the law. We continue to find ways to examine our higher-risk relationships closely prior to entering into them, and set forth our expectations in our contracts and other communications with them.
We encourage employees to report all violations or suspected violations to their supervisor or a human resources representative, email our Global Integrity & Compliance department or call a confidential hotline which is available 24/7 to all employees worldwide, with interpreters available in multiple languages. All allegations are taken seriously, appropriately investigated, and resolved. Our anti-retaliation policy protects individuals who report suspected violations.
In 2010, in honor of Doris and Don Fisher, we awarded our first annual Fisher Award for Integrity to an employee who embodied our integrity value and doing what’s right.
In addition to the Global Integrity & Compliance Team, we have a Corporate Compliance Committee, made up of senior leaders, that meets quarterly to provide program guidance, and a committee of the Board of Directors receives at least semi-annual updates on the compliance program.
Learn more about our Code of Business Conduct.
