Our Commitment
Foreign migrant workers and recruitment practices are identified as important human rights issues within the apparel supply chain. We recognize that foreign migrant workers may face heightened risks, particularly in relation to recruitment fees, unclear hiring practices, and control over personal documents.
Ensuring that foreign migrant workers are treated fairly and on an equal basis with local workers is part of Gap Inc.’s broader commitment to respect human rights and foster a safer, more equitable environment for all workers across our supply chain. Our policies and standards align with internationally recognized frameworks, including:
- UN Guiding Principles on Business and Human Rights
- UN Global Compact (UNGC)
- Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises
- The International Labour Organization (ILO) Core Conventions
Our Approach
We address risks affecting foreign migrant workers through clear standards, rigorous monitoring, and effective grievance mechanisms across our supply chain – alongside industry partnerships and collaboration.
Responsible Recruitment Standards
Gap Inc.’s Foreign Contract Worker Requirements (FCWR), which form part of our Code of Vendor Conduct (COVC), establish clear expectations for suppliers that employ foreign migrant workers.
Under the FCWR, suppliers must:
- Provide each foreign migrant worker with an employment contract in the worker’s home country and execute that contract in the worker’s home country. No additional terms may be imposed after signing unless required by law.
- Ensure the employment contract is in the worker’s local language and clearly outlines key terms, including wages, overtime limits, benefits, deductions, estimated minimum net pay, recruitment fee restrictions (if required by law), and a summary of the living conditions.
- Pay all host country fees and costs associated with the use of foreign labor and must not charge recruitment-related fees to workers or recover such costs from workers in any form.
- Avoid the use of recruitment agencies where possible and hire workers directly or transfer existing employees. Where recruitment agents are used, suppliers remain responsible for ensuring recruitment practices align with our standards.
- Not accept reimbursements, kickbacks, or other payments from recruitment agencies or others involved in the recruitment process.
- Pay transportation costs to and from the host country, including return transportation if a worker chooses to return home for any reason and at any time.
- Allow workers full control over their passports and similar documentation. Passport retention must not be a condition of employment and secure storage must be provided.
- Allow workers full control over the wages they earn and not withhold “guarantee money” or recruitment-related sums from pay otherwise due.
- Pay foreign migrant workers the same minimum wage as local workers in the same job category.
- Maintain transparency regarding foreign migrant worker employment and provide information to Gap Inc. upon request.
In addition to these requirements, suppliers are expected to implement recruitment practices that are transparent, lawful, and consistent with international labor standards.
Monitoring & Accountability
We monitor compliance with our standards through the Gap Inc. Vendor Compliance program. This includes:
- Initial assessment prior to approving a facility
- Regular compliance assessments thereafter
- Follow-up reviews and corrective action plans
Where issues are identified, we work with suppliers to implement corrective actions within defined timeframes. Persistent or serious violations may result in escalation, including potential termination of the business relationship.
Oversight of human rights risks, including those affecting foreign migrant workers, is integrated into Gap Inc.’s governance structure. Senior leadership and the Board’s Governance and Sustainability Committee regularly review our human rights strategy and progress.
Grievance Mechanisms
Supporting worker voice is a key part of our human rights approach. Workers in our supply chain have access to multiple channels to raise concerns safely and without fear of retaliation.
- Workplace Grievance Channels: Through our COVC, Gap Inc. requires suppliers to maintain effective grievance mechanisms that are accessible to all workers — including foreign migrant workers. These systems must be available in languages workers understand, offer multiple reporting options, and allow for confidentiality and anonymity where appropriate. The grievance system shall include addressing grievances in a timely manner and documenting grievances and management action on grievances.
- Workplace Committees: Through our factory programs, including the Workplace Cooperation Program developed in partnership with ILO-IFC Better Work, we support the effectiveness and representativeness of workplace committees. These programs provide training to bipartite worker-management committees on communication, problem-solving, occupational health and safety, gender dynamics, and the ILO’s Core Conventions. Survey results indicate that strengthened committees help workers raise concerns more confidently and support more timely and constructive resolution of issues.
- Gap Inc.’s Confidential Hotline: In addition to factory-level systems, anyone who conducts business with or is affected by Gap Inc. may raise concerns through our confidential, 24/7 Code of Business Conduct (COBC) Hotline, managed by an independent third party. Reports may be made anonymously where permitted by law.
We have a zero-tolerance policy for retaliation against workers or other stakeholders for raising concerns. We do not tolerate threats or attacks against human rights defenders.
Industry Collaboration
We recognize that risks affecting foreign migrant workers are often linked to broader structural challenges in global labor markets. Addressing these risks requires collaboration beyond any single company or supply chain.
We participate in industry and multi-stakeholder initiatives that support responsible recruitment, promote alignment with international labor standards, and strengthen due diligence systems across the sector. Through these efforts, we contribute to shared expectations and support greater transparency and accountability in recruitment practices.
Strengthening Oversight Beyond Tier 1
Industry Challenges
Foreign migrant workers are often present in upstream facilities, including fabric mills (Tier 2). This creates additional challenges for visibility and oversight.
Our Progress
In 2024, we launched a Mill Compliance Agreement (MCA) to expand oversight to Tier 2 mill facilities nominated by Tier 1 suppliers.
Through this initiative, we have:
- Increased visibility into upstream mills where foreign migrant workers may be present
- Conducted targeted mill audits to assess compliance with our human rights and recruitment standards
- Reinforced expectations within this additional tier of our supply chain
To support implementation, we have hosted workshops with mill vendors and facilities to review our approval process and clarify expectations related to foreign migrant worker protections. These actions reflect our efforts to strengthen oversight beyond Tier 1 facilities.