Corporate Compliance

Gap Inc. was founded on the principle of doing business responsibly, honestly and ethically. We take corporate compliance very seriously. Our comprehensive corporate compliance program is designed to ensure that all employees and the company's Board of Directors (directors) not only meet legal requirements around the world, but also operate responsibly and with integrity in everything they do.

A combination of written guidelines, formal processes and management oversight helps us ensure that "strong corporate compliance" aren't just words on paper, but a way of doing business at Gap Inc.

California Transparency in Supply Chains Act (SB 657)

Learn about how Gap Inc. supports the California Transparency in Supply Chains Act (SB 657).

Code of Business Conduct

  • Our Code of Business Conduct has been the foundation of our corporate compliance program since 1998. Some highlights:
  • Each employee and director of the company is responsible for complying with the Code of Business Conduct.
  • All of our employees around the world receive a copy of the Code when they join the company and agree in writing to comply with it.
  • Each employee worldwide is required to complete the Principles of Integrity: Code of Business Conduct Overview training course, which reinforces the company's commitment to the Code.
  • On an annual basis, senior employees must certify their compliance with the Code.
  • All employees are regularly reminded of the Code and are encouraged to report any suspected violations through the company's Open Door process, the Global_Integrity@gap.com mailbox or the Code Hotline.
  • Reflecting the global reach of our company and diversity of our employees, the Code is published in eight languages.

Global Integrity Department

  • To enhance our existing corporate compliance program, in 2003 the company created a compliance department โ€“ recently renamed Global Integrity.
  • The department's objective is to embed compliance infrastructure and the company's commitment to integrity into global business solutions and culture.
  • Under the guidance of the Chief Compliance Officer, Michelle Banks, the department leads the company's efforts to promote and enforce compliance with our Code of Business Conduct. Ms. Banks reports directly to Gap Inc.'s CEO.
  • Global Integrity works closely with other departments โ€” including Human Resources, Global Corporate Affairs, Internal Audit, Loss Prevention and Corporate Security โ€” to raise Code awareness through communication and education, to monitor and audit Code compliance, and to investigate and respond to all suspected Code violations.
  • The department may be contacted at Global_Integrity@gap.com.

Global Integrity Committee

ยท         Gap Inc. has a Global Integrity Committee, a group of senior leaders from various company divisions and functions that focuses on monitoring the effectiveness of and providing input into the company's Code of Business Conduct compliance program, as well as compliance-related risks. The company's Chief Compliance Officer chairs this committee.

Political Engagement Policy

  • 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 support Gap Inc.'s strategies through public policy and government advocacy. We participate in political activities and advocate for legislation when it affects our ability to grow our business in a way that is consistent with our values, legal obligations, and Codes of Business Conduct and Vendor Conduct. Read the PDF for the full text of our political engagement policy.

Reporting

  • The head of Global Integrity periodically reports to the Audit and Finance Committee of Gap Inc.'s Board of Directors on the effectiveness of the company's corporate compliance program. The Audit and Finance Committee has oversight responsibility for the compliance program.
  • We are committed to continually evolving our corporate compliance program in line with legal and regulatory requirements, corporate ethics best practices, and our own high standards.

To report suspected violations of our Code of Business Conduct, see the Code Hotline page.

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