Our approach to addressing labor conditions, facilitating greater partnerships with our suppliers and improving sustainability performance begins with assessments and facility audits. These are conducted by Gap Inc., ILO Better Work and the Social & Labor Convergence (SLCP) Program. Our Supplier Sustainability Assessment Manual outlines the protocols these teams use to assess and remediate issues related to labor or working conditions.
We conduct three types of assessments: (1) Initial assessment: first full assessment carried out for a facility that has been offered for assessment and approval; (2) Full assessment: covers all sections of Gap Inc. COVC (Code of Vendor Conduct); and (3) Follow-up assessment: assesses progress made by facilities on issues identified during the initial or full assessment. These assessments may also record and report new issues.
We take a risk-based approach to assessing active manufacturers of our branded products. While most facilities receive a full assessment every fiscal year, some facilities classified as low risk are assessed every other year. Each assessment includes interviews with managers, confidential interviews with workers, visual observations, and reviews of documents and records. We conduct announced, unannounced and semi-announced assessments.
After each assessment, a color-coded rating is calculated based on criteria within five categories: Compliance with Laws, Environment, Labor Standards, Occupational Health and Safety, and Management Systems.
Green: high-performing facilities with no critical and few violations
Yellow: average performers
Red: facilities that need to address one or more serious issues
Critical, severe and repeat violations have a greater negative impact on a facility’s rating than “noncompliance” violations. Our strict approval process discourages red-rated facilities from entering our sourcing base. If a red rating occurs, we provide corrective action plans and a realistic time frame to resolve any issues. Should a facility or vendor fail to address persistent noncompliance, we create a responsible exit plan and continue to monitor the facility to address pending issues during deactivation.
A key tenet of our approach to partnering with facilities is that we work to fix what we find.
When a grievance channel, assessment, external stakeholder or other reporting mechanism reveals a serious issue or allegation impacting worker rights, we begin processing immediately, but may take up to one week. Once a request has been received, the relevant parties, including our internal business, will be notified of the issue’s status and immediate next steps. Our local Supplier Sustainability team assesses the risk to determine the responsible party or parties and conduct further investigations and due diligence. Then, we work with the complainant(s), the facility and vendor, local and international stakeholder groups, and with other brands sourcing from the same facility to conduct a detailed root cause analysis and assess facility-management systems. We also have the facility immediately stop all actions related to the alleged violation.
If the issue is a violation of our COVC or a breach our Human Rights Policy, the parties are informed of the results of any investigation, and corrective action plans are developed that include follow-up with management on any additional remedial actions taken. Gap Inc. considers the grievance or complaint closed when the issue has been resolved and Gap Inc. has determined through its Assessment and Remediation framework that the appropriate remedy has been provided in accordance with our COVC and Human Rights Policy expectations.
The corrective action plan submitted by each facility must include the following information:
- A plan to address findings that are noted in the assessment report from Gap Inc.
- Specific corrective actions to eliminate the cause of the finding. This could include developing or updating written policies or procedures, capability-building and any other relevant actions.
- If a root cause analysis has been conducted, corrective actions should target the root cause(s).
- Information on who is accountable for each corrective action implementation at the facility.
- A deadline for completing each corrective action.
The Gap Inc. assessor will follow up with the facility on the corrective action plan according to the timeline set by the facility. The facility is responsible for sending to the Gap Inc. Supplier Sustainability team evidence of corrective actions taken as per the timelines for each issue reported in the assessment report. The assessor will review the evidence and update the facility on whether the issue can be resolved by offsite review of evidence, or if an on-site verification is required.
We monitor progress through follow-up assessments. Should there be outstanding or overdue issues, our Supplier Sustainability and Global Supply Chain teams escalate further intervention. However, if critical or severe issues remain unresolved, we may halt future order placement or discontinue the supplier relationship.