Our Approach 

We promote an ethical and responsible supply chain through our Vendor Compliance program, which  monitors and helps to improve suppliers’ social and environmental performance through assessments, remediation, training, and responsible purchasing practices informed by vendor scorecards.  

Assessment and Remediation 

We conduct assessments of 100% of our Tier 1 suppliers annually. 

We monitor compliance to the Gap Inc. Code of Vendor Conduct standards through multiple types of assessments. Where available, we align with industry frameworks such as the Social & Labor Convergence Program (SLCP) and ILO-IFC Better Work to reduce duplication and support broader industry consistency. When issues are identified, suppliers are required to implement corrective actions within defined timeframes. Severe issues are addressed immediately, while other corrective actions are expected within set periods, with longer-term prevention plans developed as appropriate. We work with suppliers to support remediation and conduct follow-up assessments to verify progress. 

Cases of persistent or egregious noncompliance may result in escalation, including supplier exit. During this process, we continue to monitor facilities to support resolution of outstanding issues and reinforce alignment with our standards. 

Governance 

Oversight of human rights risks is integrated into Gap Inc.’s governance and risk management processes. These risks are identified and assessed through the company’s Enterprise Risk Management (ERM) framework, where they are evaluated alongside other enterprise-level risks. 

The Board of Directors, through its Governance and Sustainability Committee, provides oversight of the company’s human rights strategy and progress. Senior leadership is responsible for implementing this strategy and monitoring performance, including the identification and management of salient human rights risks across the supply chain. 

This governance structure supports regular review of human rights priorities, alignment with company policies and standards, and integration of human rights considerations into broader business decision-making.

Salient Human Rights Issues 

Salient human rights issues inform our policies and guide our due diligence, monitoring, assessment, and remediation across our supply chain.

Child Labor and Young Workers 

Our COVC prohibits the use of child labor. We require our supplier facilities to establish robust age-verification processes to prevent employment of children or underage workers. We also work to ensure that facilities respect local laws and international standards related to employing younger workers who are not children.  

During facility assessments, we interview a subset of workers and managers about recruitment and hiring, labor practices, and working conditions for young workers and we check for lawful, unaltered documents that verify workers’ ages, since workers can go to great lengths to obtain counterfeit documents. We also monitor whether facilities are upholding labor laws and standards for legal young workers.  

In the rare event that we encounter child labor at an approved facility, we take immediate action to resolve the issue by removing these workers from the facility, making sure they have access to education or appropriate training, and are guaranteed a job if they choose to work at the facility when they are older; and requiring the offending supplier to pay for all remediation costs.

Discrimination and Harassment, Gender-Based Violence and Harassment, Gender Equality, and Inclusion 

Our COVC prohibits any form of discrimination related to hiring, compensation, access to training, promotion, termination, or retirement based on race, color, gender, nationality, religion, age, maternity status, marital status, indigenous status, ethnicity, social origin, disability, sexual orientation, HIV/AIDS status, or membership in worker organizations, including unions or political affiliation. We conduct assessments of all branded apparel suppliers on a regular basis to check for any signs of discrimination. We also identify common risks and best practices for pregnant or nursing women, including rearranging working hours, adjusting overtime hours and offering greater flexibility for break times. 

Our Gender-Based Violence and Harassment (GBVH) Prevention and Response program was developed with ILO Better Work and has been a critical part of our gender strategy, helping enforce our zero-tolerance policy on physical, psychological and sexual harassment. The program supports facilities to: raise awareness of gender-based violence, why it happens and what can be done about it; invest in preventing and addressing the issue in the workplace; and use our prevention and response spectrum to identify, address and remediate issues immediately.  

If a GBVH case is identified, we collaborate with the facility to investigate, provide protection for the survivor, resolve issues, and prevent recurrence. Perpetrators face consequences and possible dismissal, as outlined in Gap Inc.’s policy. Our top priority is safeguarding survivors, working to guarantee their job security, and fostering a safe environment for employees to report cases without fear of retaliation.

Foreign Contract Workers and Responsible Recruitment

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. We are committed to ensuring that foreign migrant workers are treated fairly and on an equal basis with local workers.  

Responsible Recruitment Standards  

Gap Inc.’s Foreign Contract Worker Requirements, which form part of our COVC, establish clear expectations for suppliers that employ foreign migrant workers. 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.

Freedom of Association 

Our COVC supports workers' rights to freedom of association and collective bargaining through open dialogue between workers and managers, and partnerships with workers' rights groups and trade unions when appropriate and allowed by local law.

Many workers have limited experience exercising these rights and few income alternatives, making these rights to collectively advocate for fair wages, benefits, and decent working conditions a critical enabler—especially in countries with weaker legal protections.
 

Grievance Mechanisms 

Supporting worker voice is a key part of our human rights approach.  

We have a zero-tolerance policy for retaliation against workers or other stakeholders for raising concerns, whether about labor or human rights, working conditions, or any other issue. This includes a prohibition on any kind of threats or actions, including any form of economic retaliation, legal action, physical or other forms of violence, or actions that could negatively impact a complainant’s livelihood or reputation. We expect suppliers to take the same approach to non-retaliation.  

We provide all suppliers with information on effectively operating grievance mechanisms, including: 

• How they identify, prevent, and remediate facility floor issues
• ​How they support workers' ability to raise concerns and seek remedy
• ​How they enable management to address issues before escalation 

Workers in our supply chain have access to multiple channels and are free to choose a workplace, judicial, or non-judicial mechanism. Additionally, we are responsive to third parties that raise grievances with us via any of our communication channels.

• 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: The Workplace Cooperation Program strengthens communication and problem-solving between workers and management. Developed with ILO-IFC Better Work, it trains worker-management committees on workplace communication, risk assessment, health and safety, gender dynamics, and core labor standards. Evaluations indicate that participating committees are better able to raise and address workplace issues, helping build trust and improve conditions. Learn more about our Capability-Building Programs. 

• 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.

If a valid complaint involves Gap Inc., we commit to engaging in the process and attempting to resolve underlying issues. If an individual approaches Gap Inc., we do not require them to permanently waive their legal rights to other judicial or non-judicial processes as a condition to participating in the grievance process and do not require confidentiality provisions with respect to human rights grievances.

Human Trafficking and Forced Labor

Our COVC prohibits the use of forced labor in any stage of product manufacturing within our supply chain. To learn more, see our statement of compliance with the California Transparency in Supply Chains Act, UK Modern Slavery Act, and Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act.
 

Occupational Health and Safety (including Fire, Building, and Electrical Safety)

Levels of fire and building safety vary greatly across the global apparel industry and depend on several factors, including local laws and regulations, building maintenance, the technical capabilities of local experts and the expectations and actions of suppliers and brands. We established our fire, building and electrical safety program in 2014 to reduce risks inherent in apparel manufacturing and to protect workers in high-risk sourcing countries. Preventing catastrophic events is critical for worker safety and business continuity. We are members of the following organizations which support safety at supplier facilities through assessment, remediation, and capability building: 

• Nirapon in Bangladesh, which continues the fire, building, and electrical safety work of the Alliance for Bangladesh Worker Safety
• ​Pakistan Accord of the International Accord for Health and Safety in the Textile and Garment Industry
• ​Life and Building Safety Initiative (LABS), which operates in Vietnam, India, Cambodia, and Indonesia
   

Unauthorized Subcontracting

Unauthorized subcontracting poses risks when suppliers use unapproved facilities that don't meet our safety and labor standards. In high-risk countries, we provide specialized training and conduct site visits to verify production occurs in approved facilities. Violations result in financial chargebacks or, for severe/repeat cases, supplier termination. Chargeback funds support supply chain and industry working condition improvements. 

High-risk incidents are immediately escalated through the following process: 

• Halt production at unauthorized facility
• Return all goods to Gap Inc.-approved facility for segregation
• ​Investigate unauthorized facility for critical issues
• Require approved facility to complete management systems training as prevention 

Wages and Benefits 

Our COVC aligns with ILO Conventions C131 and C95, and the United Nations Universal Declaration of Human Rights (UN UDHR) Articles 23-24. We require suppliers to pay at least the legal minimum or industry wage, whichever is higher. 

Violations include insufficient overtime premiums, illegal deductions, and unclear pay communications. We review factory records, interview management and workers, and assess production quotas, wage calculations, contract terms, and leave policies. Suppliers must remedy violations or face consequences up to relationship termination. 

Working Hours 

While overtime is understood to be a prevalent practice in garment production, supplier facilities must carry out operations in ways that limit overtime to a level that ensures humane and productive working conditions and follows all applicable laws. Through our COVC we require that: 

• Workers can refuse overtime without penalty or punishment
• Workers cannot work more than six consecutive days
• Facilities must address excessive overtime through root cause analysis, adjusted production schedules, and improved management systems
• ​Total weekly hours (including overtime) must comply with country-specific laws