2021 ESG REPORT
INCLUSIVE, 
BY DESIGN

3
14
25
33
46
THE BIG PICTURE 
 
About Gap Inc. 
3
Our Commitment to ESG,  
CEO Message
4
2021 Highlights 
5
Our Approach – Judy Adler, VP ESG
6
Our Purpose-Led Brands 
7
Old Navy
8
Gap 
9
Banana Republic 
10
Athleta 
11
Goals and Progress  
12
ENRICHING COMMUNITIES
 
Water Stewardship 
35
Women + Water
36
Resource Efficiency and   
Manufacturing
37
Chemicals Management
38
Climate Stewardship
39
Raw Materials and Product
42
Circularity and Waste
44
EMPOWERING WOMEN  
Gap Inc. P.A.C.E. 
16
Human Rights and Social Dialogue
19
Helping Keep Our Supply Chain 
Safe During COVID-19
24
GOVERNANCE
 
ESG Oversight
47
Responsible Business Practices
49
Stakeholder Engagement
50
Product Life Cycle
51
ESG Appendix and  
Forward-Looking Statements
52
Global Reporting Initiative  
(GRI) Index
53
Sustainability Accounting 
Standards Board (SASB) Index
64
Task Force on Climate-Related  
Financial Disclosures (TCFD) Index
72
ENABLING OPPORTUNITY
 
This Way ONward 
27
Talent Development
29
Equality & Belonging 
31
Employees and Community Impact
32
CONTENTS
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
2

Our Athleta brand is a certified B Corp, and 
we have amended Athleta’s legal charter 
to become a Delaware public benefit 
corporation to further uphold the brand’s 
commitment to people and the planet. 
As of the end of fiscal 2021, we purchase 
private-label and nonprivate-label 
merchandise from about 250 vendors 
that have facilities in approximately 
25 countries. As of January 29, 2022, 
we had a workforce of approximately 
97,000 employees. 
THE BIG PICTURE
Founded in San Francisco in 1969, Gap 
Inc. is a collection of purpose-led lifestyle 
brands offering apparel, accessories, home 
goods, and personal care products for 
women, men, and children from Old Navy, 
Gap, Banana Republic, and Athleta. 
ABOUT THIS REPORT 
This report covers Gap Inc.’s global operations for fiscal 2021, which 
ended on January 29, 2022, unless otherwise noted. Our last report 
covered fiscal 2020 and is available with our past sustainability reports 
on our website. This report focuses on developments and actions for our 
key programs, progress toward our corporate and brand goals during 
the 2021 fiscal year, preparations for activities in 2021 and 2022, and an 
analysis of trends and business impacts where available. For our many 
programs, we provide detailed information on objectives, operations and 
our management approach which can be accessed via links in each section. 
Through this report, we define sustainability as a priority that guides our 
efforts to operate responsibly and ensure the future health of the planet 
and society. Through this report, ESG (Environment, Social, and Governance) 
is used to refer to the Gap Inc. central team that owns and supports all work 
related to the ESG issues impacting the company’s performance. 
We sought to prepare this report in reference to the Global Reporting 
Initiative (GRI) Standards and in alignment with the Sustainable 
Accounting Standards Board (SASB) Standards and the Task Force on 
Climate-Related Financial Disclosures (TCFD). Gap Inc. is committed to 
the United Nations Global Compact (UNGC) Ten Principles, and this report 
serves as our Communication on Progress. We have not obtained external 
assurance for this report, but its contents have been confirmed by an 
internal quality review. 
The inclusion of information contained in this report is being made in 
good faith based on information that is available and is valid to Gap Inc. 
as of January 29, 2022 (unless otherwise specified). The scope of these 
disclosures does not include the Gap Home collection. Given the inherent 
uncertainty in predicting and modeling future conditions, caution should 
be exercised when interpreting the information provided in this report. 
In addition, the controls, processes, practices, and infrastructures 
described in this report are not intended to constitute any representation, 
warranty, or other assurance that such controls, processes, practices and 
infrastructures will result in any specific outcome, result, or achievement 
of a stated target or goal. Images of groups of people in this report 
that do not include face masks were taken either prior to the COVID-19 
pandemic or in line with relevant CDC guidance and recommendations. 
For questions regarding Gap Inc.’s sustainability efforts or the content of 
this report, please contact sustainability@gap.com.
Gap Inc. is an omni-channel retailer, 
with sales to customers both in stores 
and online, through company-operated 
and franchise stores, company-owned 
websites, and third-party arrangements. 
LEARN MORE 
> Annual Filings
ABOUT GAP INC. 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
3

OUR COMMITMENT TO 
ENVIRONMENT, SOCIAL,  
AND GOVERNANCE (ESG) 
“We take pride in creating products our customers 
love while doing right by our customers, our 
community, and the planet. As founders, a key 
part of Doris and Don Fisher’s vision of success 
was creating opportunities for the people and 
communities touched by our business throughout 
the world. Today, we’re working harder than 
ever to make our business more sustainable by 
setting bold goals, designing new programs, and 
partnering with others to change our industry for 
the better.
“Each of our brands has made strong 
commitments to help us achieve our purpose – 
to be Inclusive, by Design – and each now has 
an executive sustainability steering committee 
in place. We recognize that commitments are 
not enough, and we are dedicated to showing 
progress against our goals and impact 
through use of innovation, collaboration across 
the industry, and partnership with expert 
organizations and the communities in which  
we operate.”  
Sally Gilligan  
Chief Growth Transformation Officer 
“As a global company that reaches millions 
of people around the world, Gap Inc. has a 
responsibility – and an opportunity – to drive 
positive change for our stakeholders. We bring 
our purpose – Inclusive, by Design – to life through 
the work we do with our partners to create a more 
sustainable business and more equitable industry.  
“In this report, we demonstrate our progress 
against clear and ambitious goals in three 
focus areas: empowering women, enabling 
opportunity, and enriching communities. 
Our partnerships – across industries and 
governments, and alongside other signatories 
of the UN Global Compact – have enabled us 
to scale our impact. This year marked major 
milestones: 1 million women and girls have now 
completed our signature skills-training program, 
P.A.C.E.; our partnership with USAID’s Women + 
Water Alliance helped 1.5 million people improve 
their access to clean water and sanitation; and, 
guided by our robust ESG framework, we set 
future targets on climate in line with science-
based goals. 
“We know there is more work to do, and we are 
committed to growing our business in a way 
that protects the planet and supports healthy 
communities for generations to come. There 
has never been a more important moment for 
“There has never been a 
more important moment 
for businesses to step up.”
“Today, we’re working harder 
than ever to make our business 
more sustainable...”
businesses to step up. It’s what our customers 
and communities expect of us – and it’s what we 
demand of ourselves as a values-led company 
with the power to shape peoples’ ways of life.”
Sonia Syngal  
CEO
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
4

EMPOWERING WOMEN
ENABLING OPPORTUNITY
ENRICHING COMMUNITIES
*Green-rated indicates high-performing facilities with few violations, none of 
which were critical. Learn more on p. 20.
90%
of our factories have completed gender awareness 
training for middle and top management.
Released first
EQUALITY & BELONGING
Report, found here. 
92%
of fabrics with a PFC-based finish were successfully 
converted or exited, and we are on track to reach 
100% by 2023.
79%
of cotton sourced from more sustainable sources.
10%
of polyester sourced from recycled sources.
1 MILLION+
women and girls reached by P.A.C.E. since 2007, 
achieving our 2022 goal.
10,600+
youths hired by This Way ONward since 2007, on 
track to reach the program's goal of 20,000 by 2025. 
This Way ONward hires represent 3% of Old Navy’s 
entry-level store employees, on track to meet its goal 
of 5% by 2025.
A-RATING
received for CDP Climate and Water.
68%
of our sourcing went to green-rated* facilities, on track 
to reach 80% by 2025.
75%
of our Tier 1 factories are participating 
in ILO Better Work and/or SLCP (Social 
and Labor Convergence Program).
1.5 MILLION+ 
people reached on our journey to empower 2 million 
people with improved water access through Women + 
Water (since 2017).
2021 HIGHLIGHTS 
SUPPORTING  
OPPORTUNITY HIRING
In 2021, we engaged with Tent Partnership for 
Refugees, Second Chance Business Coalition, 
and STARs (skilled through alternative routes).
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
5

OUR APPROACH
At Gap Inc., our ESG team’s vision is to be 
a driving force in the industry, collectively 
building a more sustainable future for 
our business, global community, people, 
and planet. 
JUDY ADLER, VP, ESG
At Gap Inc., we lead with our values and 
think holistically about how environmental 
and social responsibility connects 
with our business and the world – 
particularly the lives of people from 
underrepresented groups. 
This intersectional thinking guides our 
approach to each of our three focus areas: 
1.	We empower women and girls through 
our Personal Advancement & Career 
Enhancement (P.A.C.E.) program, which 
establishes a foundation from which 
women can reach their full potential 
and help change the power structures 
that hold them back at work and in their 
communities. This program – which 
has reached over 1 million women and 
girls since 2007 – supports people from 
communities in our supply chain and 
beyond who face greater risks due to 
gender discrimination, lack of access 
to education and healthcare, and the 
worsening effects of climate change and 
the water crisis. By tackling these issues 
together, we can make exponential 
progress on them all.
2.	We enable opportunity by fostering 
an inclusive culture with our Equality 
& Belonging team and using the scale 
of our business to create sustainable 
economies accessible to everyone. 
Through programs like Old Navy’s This 
Way ONward, we are providing valuable 
first-job experience for youths from 
underrepresented groups. At the same 
time, we’re applying what we learn 
across Gap Inc. to help address systemic 
barriers to employment. 
3.	We enrich communities by aiming 
to create a net positive impact in 
areas disproportionately affected 
by environmental issues like climate 
change and the water crisis. Our 2050 
environmental goals are ultimately 
about protecting the world’s natural 
resources for generations to come. 
We have programs like the USAID Gap 
Inc. Women + Water Alliance, which 
combines objectives to empower women 
and improve community water resilience 
in a part of India where water stress 
and poverty are acute aspects of daily 
life. With the support of our partners 
– CARE, Water.org, WaterAid, and the 
Institute for Sustainable Communities 
– this program already has improved 
access to clean water and sanitation for 
1.5 million people in Madhya Pradesh 
and Maharashtra.
Our brands are also leading the way, from 
Banana Republic’s collaboration with 
Charles Harbison on a more sustainable 
clothing line that celebrates Black women 
to Athleta’s investments in renewable 
electricity that now offsets all of its North 
American retail stores, to Old Navy’s 
commitment to amplify diverse voices from 
the 15 Percent Pledge network to Gap’s 
more sustainable product assortment, 
Generation Good.
By elevating the role of sustainability in our 
business, we can deepen our positive impact 
on people, our communities, and the planet.
Judy Adler
To do this, we leverage the scale of our business and strength of 
our brands to empower women, enable opportunity, and enrich 
communities. We view our work as a lens through which we can 
imagine and create a thriving business and a better world.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
6

OUR  
PURPOSE-
LED BRANDS 
Our brands are built to have a lasting 
positive impact on people and the planet. 
Our approach builds on our rich history 
of women’s empowerment, unlocking 
opportunities for people to succeed in the 
workforce and responsible environmental 
stewardship. Each of our brands is a 
leader in empowering women, enabling 
opportunity, and enriching communities. 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
7

1.
	The Imagine Mission Fund is a donor-advised fund (DAF) at T. Rowe Price Charitable. A DAF is a giving vehicle: a separately identified fund or account maintained and operated by a section 501(c)(3) organization (i.e. the sponsoring organization). 
EMPOWERING WOMEN
A More Inclusive Future
Old Navy, alongside Gap Inc., made a 
commitment to change for its employees, 
its brand, and its communities. In 2021, 
Old Navy introduced BODEQUALITY 
to redefine size inclusion. Old Navy now 
offers every one of its women’s styles in 
every size, with no price difference. Old 
Navy is the first value retailer to offer sizes 
0-30 and XS-4X for all women’s styles at 
price parity. We reinvented our fit process 
and size standards to create the most 
democratic, comfortable, and consistent 
size run and fit ever for the brand.
ENABLING OPPORTUNITY
A Brighter Future
This Way ONward fuels the next 
generation of leaders with the skills and 
confidence they need to succeed in the 
workplace. Tasked with providing 20,000 
job opportunities by 2025 to youths 
from underrepresented communities, 
Old Navy is already halfway to delivering 
on its commitment, with over 10,600 
graduates of the program. This past 
year, Old Navy donated $1.3 million to  
the Imagine Mission Fund1 to support 
This Way ONward. 
Old Navy is a global apparel and 
accessories brand that makes current 
American essentials accessible to every 
family. Originated in 1994, the brand 
celebrates the democracy of style 
and service for all through on-trend, 
playfully optimistic, affordable, and 
high-quality products. Old Navy is on  
a mission to imagine a better future  
for future generations.
ENRICHING COMMUNITIES
A Greener Future 
WATER
As of the end of 2021, 96 percent 
of Old Navy’s denim assortment 
incorporates water-saving techniques, 
with over 2 billion liters of water saved 
since 2019.
TEXTILES 
Old Navy is on track toward its goal 
of having 100 percent of its cotton 
sustainably sourced in 2022 and is 
committed to an increased use of 
recycled cotton in its denim assortment. 
Additionally, the brand is committed to 
converting 60 percent of its traditional 
polyester into recycled polyester by 2025. 
PLASTIC 
Old Navy is reducing plastic waste across 
its supply chain and is on track to eliminate 
all plastic shopping bags in U.S. and 
Canadian stores by 2023. 
LEARN MORE 
> Old Navy Imagine
$3.8M
total raised 
and donated 
to the Imagine 
Mission Fund 
to support This 
Way ONward
96%
of Old Navy’s 
denim 
assortment 
incorporates 
water-saving 
techniques
In 2021, Old Navy launched the Imagine 
Mission Fund to support the brand’s 
values work. The fund comprises 
Old Navy and customer donations, 
Navyist rewards points giving, and 
customer donations at checkout.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
8

GAP’S  
NEW GOALS
100%  
Regenerative, organic, in 
conversion to organic, or 
recycled cotton by 2030
100%  
Recycled polyester by 
2030; 50% by 2025
100%  
Washwell™ Denim2  
and woven bottoms  
by 2025
EMPOWERING WOMEN
Empower@Work
In 2021, Gap committed that 100 percent 
of its finished goods factories will be 
participating in Empower@Work by 
2025. Empower@Work (see p. 18) 
focuses on building and deploying 
sustainable, systemic, and scalable 
programs that promote gender equity in 
global supply chains to uplift women and 
their families for generations to come.
Water is a Human Right
Through the USAID Gap Inc. Women + 
Water Alliance (see p. 36), Gap brand is 
working with nonprofit partners in India 
to empower farmers, like Pramila, and 
their communities to improve their access 
to clean water and sanitation, supporting 
long-term water resilience in places that 
are aligned with our supply chain.
ENRICHING COMMUNITIES
Washwell™
Compared to conventional wash 
methods, Gap’s Washwell™ program 
uses at least 20 percent less water. 
Gap believes it should be a force for 
good – for people and our planet. 
Gap’s purpose is to create sustainable 
change, enrich communities, and be 
better for this generation and the next. 
From water to wash, fiber to factory, 
the clothes you love to live in are made 
responsibly and with respect for the 
planet we all share.
Sustainability is an imperfect journey. 
Gap promises to lead, not react. To use 
less, not more.
“My dream 
and goal is 
to provide 
clean water 
to those who 
don’t have 
access to it.” 
 
Pramila Ahoriya, a farmer 
and university student in 
Karajwani village, India, 
where women on average 
spend 1.5 hours per day 
fetching water for their 
families.
Since 2016, the brand has saved 
approximately 500 million liters of water. 
Better Materials
In 2021, Gap began supporting 
farmers with training and procurement 
commitments during their three-year 
transition toward certified organic farming 
and away from conventional agricultural 
practices, which do not use harmful 
synthetic pesticides and fertilizers.
Gap signed up to Textile Exchange’s 2025 
Recycled Polyester Challenge, which asks 
apparel brands to collectively commit to 
increasing the percentage of recycled 
polyester in the industry to 45 percent by 
2025. Gap has set an even higher target  
of 50 percent by 2025.
Circularity
In 2021, Gap renewed its commitment 
to the Ellen MacArthur Foundation’s 
Jeans Redesign challenge to design 
long-lasting, more sustainably produced 
denim that’s made to be reused and 
recycled. To help keep products in use for 
as long as possible, Gap partners with 
thredUP® and Give Back Box. Customers 
can pack up gently used clothing, shoes, 
and accessories, then print a free shipping 
label to send products on to their next life.
LEARN MORE 
> Gap for good
2.	
100 percent of eligible denim by 2021 (86 percent of all denim).
100%
Washwell™ 
Denim2
100%
more sustainable 
cotton
Achieved
GOAL 
BY 2021
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
9

Banana Republic is committed to 
making better decisions about its 
products. Discover more about its 
legacy of upcycling, conservation 
efforts, sustainable styles, and  
initiatives to make the world better, 
one garment at a time.
Water
Banana Republic implemented the 
Washwell™ program, which has 
helped the brand save approximately 
34 million liters of water since 2020. 
The brand also uses conscious dyeing 
techniques and wash methods that 
ensure cleaner waterways and 
reduce water usage by including the 
implementation of bio-softeners and 
foam dye.
Partnerships
Banana Republic is continually 
exploring associations that help 
support its key sustainability pillars.   
Current examples include:
 In-Conversion Cotton Farms: The brand 
made a long-term commitment to source 
in-conversion and organic cotton from 
approximately 1,500 partner farmers in 
the Madhya Pradesh regions of Alirajpur, 
Kundanpur, and Udaigarh (India). Alongside 
Arvind Limited, Banana Republic is funding 
the work of Action for Social Advancement 
(ASA), a non-governmental organization 
(NGO) that trains farmers on converting to 
organic practices. 
 World Wildlife Fund® (WWF): In 2021, 
Banana Republic chose WWF as its 
designated charity partner for Gap Inc.’s 
Do Good loyalty rewards membership 
feature to help build a better world for 
people and the planet. 
thredUP®: Banana Republic partnered 
with the independent reseller of like-new 
clothing and accessories. Customers can 
bring unwanted items to stores for resale 
on thredUP®’s platform, providing an easy 
way to reduce environmental impact by 
extending the life of pre-loved clothing.
 Paravel: Banana Republic debuted a 
limited edition partnership with the 
luggage essentials brand, featuring 
products made with more sustainable 
practices and materials.
Banana Republic is building on its legacy of 
upcycling and continuing to make progress 
with sustainable partnerships, initiatives,  
and practices.
LEARN MORE 
> Banana Republic
34 
million 
liters of water  
have been saved, 
approximately,  
since 2020
ENRICHING COMMUNITIES
Our founders traveled the world upcycling clothes to mend, 
modernize, and make their own. That spirit of adventure and 
singular vision for sustainability continues today.
Circular Economy
Banana Republic is committed to using more sustainable 
cotton and polyester and designing products constructed with 
recyclability in mind. To work toward this, the brand participated 
in the Ellen MacArthur Foundation’s Jeans Redesign project to 
reimagine organic cotton denim. The brand also launched BR 
Vintage with two collections of over 200 pieces handpicked from 
archives. The capsule will evolve each season with all-new styles 
curated by third-party partner vendors.
Raw Materials
Banana Republic aligned with The Responsible Wool Standard 
program to protect sheep and the land they graze when 
creating our wool products. The brand also committed to 
supporting responsible leather manufacturing worldwide and 
is a proud member of the Leather Working Group. Banana 
Republic signed on to become a member of the Good Cashmere 
Standard®, which aims to improve the welfare of cashmere 
goats, the lives of farmers and farming communities, and the 
environment in which they live. 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
10

ENRICHING COMMUNITIES 
Renewable Energy
As of 2021, 100 percent of Athleta’s 
company-operated stores in North 
America are offset by renewable electricity 
from Fern Solar, a 7.5-megawatt offsite 
solar project in North Carolina.
Recycled Polyester
Athleta signed on to the Textile Exchange 
Recycled Polyester Challenge to use 
45 percent recycled polyester by 2025 
and 90 percent by 2030.
thredUP®
The brand celebrated its second year 
of participation, activating 57,000 Clean 
Out Kits with 897,000 garments in 2021 
(1.1 million total since 2020 launch). 
This partnership extends the life of our 
clothes through circular business models.
LEARN MORE 
> Athleta 
As a certified B Corp, Athleta is 
committed to using business as a 
force for good toward its mission: 
to ignite the limitless potential of 
all women and girls. Athleta seeks 
progress through its core values of 
inclusion, women supporting women,  
and environmental impact.
EMPOWERING WOMEN
Power of She Fund
Through the Power of She Fund, in 
partnership with the Women’s Sports 
Foundation, we awarded an additional 
66 grants impacting 43 organizations 
and more than 25,000 women and girls in 
2021. Since the Fund‘s inception in 2020, 
we have awarded 79 grants impacting 
over 56 organizations and more than 
30,000 women and girls across areas 
including fostering multi-generational 
movement and connections, driving 
access to well-being resources, and 
supporting athlete child care expenses. 
Gap Inc. P.A.C.E. Program
In 2021, Athleta committed to 
integrate P.A.C.E. and Empower@Work 
in 100 percent of its factories by 2025 
(see more on p. 18).
ENABLING OPPORTUNITY
Fair Trade CertifiedTM 
Athleta announced the addition of two 
new fair trade factories in Vietnam, 
bringing the total to four (with another 
two in Sri Lanka). The brand has 
contributed $1.3 million to community 
development since 2016 ($371,000 in 
2021), impacting 6,200 women. 
Amplify Artist Series
Athleta developed a collection of 
product collaborations to further its 
commitment to empower and amplify 
the voices of Black, indigenous, and 
people of color (BIPOC) women and 
girls. In 2021, Athleta collaborated 
with four Black female artists to create 
limited edition products and donated 
to nonprofits selected by the artists.
100% 
renewable 
electricity offset 
Athleta's North 
American retail 
stores in 2021
30,000 
women and girls 
impacted by 79 
grants awarded 
through the 
Power of She 
Fund since 2020
1.1 
million 
garments 
collected through 
thredUP® since 
2020 partnership 
launch
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
11

EMPOWERING WOMEN
GOALS
TARGET YEAR
STATUS
PROGRESS
Reach 1 million women and girls through P.A.C.E.
2022
As of the end of fiscal 2021, over 1 million women and girls had been reached 
through P.A.C.E.
100% of workers employed in our strategic factories will have 
their voices heard through representative, gender-equitable 
workplace committees
2025
We have developed the following key performance indicators (KPIs):
% strategic factories where workplace committees have gender-equitable 
representation
% strategic factories where workplace committees are meeting at least 70% of relevant 
Better Work Academy Social Dialogue Indicators (SDIs) and meet minimum requirement 
indicators (SDI 9, SDI 17, and SDI 18)
100% of our strategic factories3 are investing in women’s 
empowerment through participation in Empower@Work
2025
% of strategic factories where at least 50% of the factory’s female workers have been 
enrolled in P.A.C.E./Empower@Work curriculum
% of strategic factories that have institutionalized Empower@Work as part of their HR 
management systems
100% of our strategic factories will have achieved gender  
parity at the supervisor level
2025
% of strategic factories have achieved gender parity at the supervisor level
% of supervisors in our suppliers’ strategic factories that are women, globally
100% of our factories will have prevention and response 
management systems and trainings in place to address 
gender‑based violence
2025
100% of our factories have prevention and response management systems and 70% 
have internal trainers in place to address gender-based violence
% of sourcing factories that have a functioning grievance mechanism for encouraging 
employee complaints and suggestions, including to report incidents of gender-based 
violence, harassment, and abuse
% of sourcing factories where 100% of employees are trained on gender-based violence 
prevention and response each fiscal year
80% of Gap Inc. sourcing will be allocated to green-rated 
factories
2025
68% of our business spend is allocated to green-rated factories
By 2023, 100% of our Tier 1 facilities will participate in 
industrywide efforts, including SLCP and/or ILO-IFC Better 
Work, and 100% of Tier 2 strategic mills will participate by 2025.
2023/2025
75% of Tier 1 factories are participating
40% of Tier 2 strategic mills are participating
100% of vendors comprising 90%* of Gap Inc.’s business spend 
are invited to participate in Better Buying, with scores isolated 
across brands, working toward annual public reporting on 
purchasing practices improvements. 
2025
* Our previous goal applied to 100% of Gap Inc. vendors. In 2021 we decided to revise the 
goal to apply to the vendors comprising the top 90% of our business spend in order to 
focus on the vendors where we have the greatest influence and impact.
GOALS AND PROGRESS
3.	
 “Strategic factories” are those representing 80 percent of our total business spend (defined as: Purchase Order first cost).
On track 
Establishing baseline
New goal
Achieved
Needs attention
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
12

ENRICHING COMMUNITIES
WATER
Net-positive 
water impact 
in water-
stressed 
regions by 
2050.
Support a water-resilient supply chain
2030
Establishing baselines and context-based targets
Empower 2 million people - including 1 million women - 
with access to improved drinking water and sanitation
2023
As of the end of fiscal 2021, we have empowered 1.5 million people
Work toward  zero discharge of hazardous chemicals in 
our supply chain: eliminate PFC-based finishes from our 
supply chain 
2023
38% of products with water- or stain-repellent finishes were made using 
non‑PFC‑based finishes. Gap Inc. successfully converted or exited 92% of fabrics 
with a PFC‑based finish, and is on track to reach 100% by 2023
CLIMATE
Carbon neutral 
across our 
value chain 
by 2050
Reduce Scope 3 greenhouse gas (GHG) emissions from 
purchased goods and services by 30% from a 2017 baseline
2030
2020 Scope 3 data will be available in 2022
Reduce Scope 1 and 2 GHG emissions by 90% from a 
2017 baseline
2030
Our 2020 Scope 1 and 2 emissions were reduced by 39% from a 2017 baseline.  
2021 Scope 1 and 2 data will be available on our website later this year
Source 100% renewable energy for our company-operated 
facilities globally
2030
In 2020, 17% of our energy was produced from renewable sources. 2021 data will be 
available on our website later this year
PRODUCT
Source 100% of cotton from more sustainable sources4
2025
79% of cotton was sourced from more sustainable sources
Source at least 45% of polyester from recycled sources (rPET). 
(Some brands have higher goals)
2025
10% of polyester was sourced from recycled sources
WASTE AND 
CIRCULARITY
Eliminate unnecessary and problematic plastic
2030
Tracking in progress
On track 
Establishing baseline
New goal
Achieved
Needs attention
ENABLING OPPORTUNITY 
GOALS
TARGET YEAR
STATUS
PROGRESS
Hire 5% of Old Navy store entry-level employees from This Way 
ONward annually
2025
In 2021, 3% of Old Navy entry-level store employees were hired through 
This Way ONward
Reach 20,000 youths through This Way ONward
2025
Over 10,600 youths have participated since the program launched in 2007, with 1,170 
hired in 2021
4.	
 Defined as: Better Cotton (formerly BCI), verified U.S.-grown cotton (USCTP), organic, in conversion (to verified organic), recycled, and regenerative.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
13

EMPOWERING 
WOMEN &  
HUMAN RIGHTS 
For more than a dozen years, we 
have led initiatives that unlock new 
possibilities for women and girls and 
support workers in our supply chain. 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
14

“The mission of P.A.C.E. is to ignite 
a community of active, healthy, 
confident women and girls who 
empower each other to reach their 
limitless potential. P.A.C.E. gives 
women a voice and an opportunity to 
positively change lives – their families‘, 
their communities‘, and their own.”  	
Mary Beth Laughton, President and CEO, Athleta
These programs work together to protect 
human rights, remove barriers, and enhance 
women’s empowerment and opportunity. 
They address gender inequality and gender 
violence by enhancing industrial relations 
in facilities and providing opportunities for 
women workers to gain the skills, agency, 
and confidence needed to advance at 
work and live better lives. These are 
complementary interventions that can be 
implemented alone or in tandem depending 
on the needs of a given facility’s workforce.
Together, these programs provide a 
comprehensive and holistic engagement 
model for facilities to improve labor 
standards, benefit women workers,  
and support the business continuity  
and resiliency of our supply chain.
Our collaborative approach has led to 
pioneering programs and innovative 
partnerships with suppliers, industry 
peers, government organizations, 
educational institutions, and NGOs. 
> 	Gap Inc. P.A.C.E. 
16		
Empower@Work
18
> 	Human Rights and Social Dialogue 
19		
Assessment and Remediation
20
	
	
Capability Building
21		
Workforce Engagement Program
21		
Supervisory Skills Training
22 		
Gender-Based Violence Prevention and Response 
23		
Digital Wage Payments 
23 
> 	Helping Keep Our Supply Chain Safe During COVID-19
24
HOW WE EMPOWER WOMEN  
AND SUPPORT HUMAN RIGHTS
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
15

GAP INC. P.A.C.E.
Our Gap Inc. Personal Advancement & Career 
Enhancement (P.A.C.E.) program partners with 
vendor facilities to give women foundational life 
skills, technical training, and support to advance 
at work and in their lives. 
We deliver our P.A.C.E. workplace and 
community programs across multiple 
industries and settings around the 
world in partnership with local NGOs, 
governments, brands, and schools. 
In 2021, we celebrated 10 exemplary 
partners and individuals around the 
globe as part of our second annual 
P.A.C.E. Awards.
We have expanded P.A.C.E. workplace 
programs by integrating P.A.C.E. into our 
larger Supplier Sustainability program. 
This puts P.A.C.E. participation and 
performance on the Gap Inc. vendor 
scorecard and signals to vendors that 
the program is both a strategic priority 
and an expectation of our commercial 
partnership with them. 
We continue to grow P.A.C.E. in 
the community through strategic 
partnerships with governmental, 
educational, and other institutions. 
Through these collaborations, our 
program now also reaches men and  
boys by providing them access to existing 
curriculum on topics like finance and new 
courses designed to help them better 
understand the experiences of women 
and girls, cultivating a culture of  
gender equality. 
Find more about P.A.C.E. on our website.
GOAL 
ACHIEVED
Reach 1 million 
women and girls 
through P.A.C.E. 
by 2022.
In 2021, we achieved a milestone in the 14-year history 
of P.A.C.E., reaching 1 million direct program participants 
worldwide with foundational life skills and technical 
training – a year ahead of schedule. P.A.C.E. has helped 
change the course of their lives and work. We are now 
bringing a version of the program to the U.S. while 
we continue developing new goals to engage with 
communities and workplaces around the world and 
empower the next generation of women and girls.
PROGRAM SPOTLIGHT
In 2019, P.A.C.E. trainer Seeta Patel 
visited Karamthalai, a village in a 
remote part of Madhya Pradesh, 
India. During her visit, she became 
trapped after the only bridge leading 
out of the area was washed away in a 
storm, something that happens every 
year during the rainy season. 
The women in P.A.C.E. training asked 
Seeta if she could help them petition 
the government for a new bridge. 
She encouraged the women to use 
skills they had learned from P.A.C.E. 
and helped them write a letter to the 
government about the perilous bridge. 
As a result of the women’s collective 
action, the government completed a 
new bridge in April 2021, improving 
access in and out of the village and 
ensuring the entire community can 
take advantage of opportunities for 
life-saving healthcare and education 
all year round. 
P.A.C.E. SKILLS 
IN ACTION
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
16

PROGRESS SINCE 2007
GROWTH PER YEAR
2021 IMPACT
5.	
Execution skills knowledge is defined as the knowledge of how to apply newly learned skills from the P.A.C.E. learning modules in real contexts, particularly in the workplace. Percentage represents increase in proficiency after participating in the P.A.C.E. program.
6.	
According to a sample of 40 facilities. 
7.	
P.A.C.E. programming and participation were limited in 2020 and 2021 due to COVID-19 in-person gathering restrictions across many of our implementing locations.
1 MILLION+
women and girls reached
4,451 
certified P.A.C.E. 
trainers
In 2021, we continued our three-year 
partnership with India’s Ministry of Rural 
Development, which we plan to expand 
across all Indian states in 2022. We 
adapted to COVID-19 by using a virtual 
program to train 84 trainers, including 
46 master trainers who will offer state-
level trainings. 
Ultimately, all vocational training under 
India’s flagship DDU-GKY (Deen Dayal 
Upadhyaya Grameen Kaushalya Yojana) 
program will be able to offer P.A.C.E. life 
skills courses, supporting the employability 
and job retention of workers. Through this 
partnership, we have gained important 
insights about translating P.A.C.E. into 
different languages – 24 in India alone – 
and strengthening government technology 
systems to deliver the curriculum.
Also in India, our partner, the Self-
Employed Women’s Association (SEWA), 
achieved its goal of training over 271,000 
women across Gujarat, Bihar, and 
Rajasthan. SEWA will now deliver P.A.C.E. 
in eight new countries: Ethiopia, Ghana, 
Haiti, Kenya, Nepal, Nigeria, Sri Lanka, 
and Tanzania.
In Cambodia, we continued our programs 
with Kampuchea Action to Promote 
Education. The Ministry of Education in 
Cambodia passed an official order to 
incorporate the P.A.C.E. girls’ curriculum 
into all primary and secondary schools 
over the next two years, ultimately 
reaching 150 schools and almost 
15,000 girls. 
4.6%
turnover rate for P.A.C.E.-
trained women6 compared 
to 11.3% among their peers
2021 P.A.C.E. PROGRESS
In Indonesia, Gap Inc. and New Balance 
are funding a program led by CARE 
International to integrate P.A.C.E. into 
the junior school counseling curriculum, 
reaching 50 schools in Badung regency. 
We hope to expand into other districts in 
the future. 
In Bangladesh, CARE International has 
led a P.A.C.E. community program that 
has reached 37,198 women in Gazipur 
since 2014. An evaluation of this program 
revealed that 48 percent of P.A.C.E. 
participants reported having bank 
accounts (non-participants: 26 percent). 
Moreover, 88 percent of P.A.C.E. program 
participants felt comfortable speaking 
up about their needs in the workplace 
after their training (non-participants: 
18 percent). 
In 2021, we built a learning management 
system that we plan to launch in 2022 
to continue digitizing the program with 
in-person, virtual, and hybrid training 
sessions. In 2022, we also plan to use 
elements of the P.A.C.E. program to 
address women’s needs in the U.S.
2018
178,000
61
17
2018
2018
279,000
68
28
2019
2019
199,000
110
31
2020
2020
173,7007
119
35
2021
2021
2019
2020
2021
WOMEN AND 
GIRLS REACHED
COMMUNITY PARTNERS
VENDORS
77+23+L
56+44+L
73+27+L
communications 
knowledge
execution skills5  
knowledge 
financial literacy 
+77%
+56%
+73%
PROGRAM SPOTLIGHT
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
17

Gap Inc., along with BSR (Business for Social Responsibility), 
HERproject, CARE International, and ILO-IFC Better 
Work, founded Empower@Work in 2019. Leveraging 
our P.A.C.E. program, Empower@Work harnesses 
the power of collective action to deploy sustainable, 
systemic, and scalable programs that empower women 
workers, embed gender equality in business practice, and 
catalyze policy and systems change by aligning women’s 
empowerment training and skill-building efforts across the 
apparel industry.
Since its launch, Empower@Work 
has published an open-source 
Worker Training Toolkit that is 
recognized as a best-practice curriculum 
for women’s empowerment training 
in the apparel supply chain. In 2021, 
Empower@Work focused on creating 
a robust implementation and impact 
model that seeks to drive market change 
and influence the wider ecosystem 
to make lasting, positive changes for 
women workers.
In 2022, we plan to develop a strategy  
to transition our P.A.C.E. in the Workplace 
program to Empower@Work.
GOALS BY 2025
100%
of our strategic 
factories8 will 
invest in women‘s 
empowerment through 
participation in 
Empower@Work9
100%
of Athleta and Gap brand 
factories will participate 
in Empower@Work 
8.	
Factories representing 80 percent of our total business spend (defined as: Purchase Order first cost). 
9.
	We will measure performance against our Empower@Work target by assessing the percentage of factories with at least 50 percent enrolled female workers. We will further assess the extent to which factories are institutionalizing Empower@Work as part of their 
HR management processes, including how they introduce it to workers and demonstrate commitment to the program from the top levels of management. 
PROGRAM SPOTLIGHT
Critical skills gained through P.A.C.E. 
gave Florah Magwa the confidence to 
run for a special position to represent 
women in her local government council 
in Tanzania. Initially, Florah didn’t believe 
that she had the skills or confidence to 
stand in front of people and ask for their 
votes. But after P.A.C.E., she decided to 
run against 25 other women and was 
among seven selected to represent 
women in the Musoma District. “If it 
were not for these interventions, I 
probably would not be where I am today 
and where I aspire to be in the future,” 
said Florah.
Women in India also used their P.A.C.E. 
training to pursue election. In January 
2021, 167 participants in the program 
were elected to the panchayat (regional 
assembly) in Maharashtra state, with 
fourteen elected as sarpanch (decision-
makers), who are the focal point of 
contact between government officers 
and the village community.
P.A.C.E. COMMUNITY FACILITATORS VENTURE 
INTO LOCAL POLITICS
Establishing baseline
Establishing baseline
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
18

Our holistic approach begins with our 
Human Rights Policy and Code of Vendor 
Conduct (COVC). Both are based on 
internationally accepted labor standards 
and guidance, including the Universal 
Declaration of Human Rights (UDHR), 
UN Guiding Principles on Business and 
Human Rights, UNGC, Organisation for 
Economic Co-operation and Development 
(OECD) Guidelines for Multinational 
Enterprises, and the International Labour 
Organization’s (ILO) Core Conventions. 
Our policies also account for local labor 
laws in each country where we do business. 
HUMAN RIGHTS 
AND SOCIAL 
DIALOGUE
To uphold these policies and improve supply chain working 
conditions, we focus on two areas: 
Assessment and Remediation 
Through transparency and partnership across our supply chain, 
we can improve workers’ well-being, protect human rights, reduce 
environmental impacts, and improve business performance. 
Capability Building 
In partnership with ILO-IFC Better Work, suppliers, NGOs, 
and others, we have established programs to improve worker 
representation and leadership involvement. These cover 
issues such as workplace cooperation, supervisory skills, 
and empowering women. We also support our facilities with 
environmental capability-building programs, which can be found 
in the Resource Efficiency and Manufacturing section (p. 37). 
Detailed information on our human rights policies, management 
approach, and resolution actions for our key human rights issues  
is available on our website. 
>	 Child Labor and Young Workers 
>	 Discrimination and Harassment 
>	 Wages and Benefits
>	 Fire, Building and Electrical Safety
>	 Grievance Mechanisms 
>	 Short-Term Contracts 
>	 Human Trafficking and 	Forced Labor 
>	 Working Hours 
>	 Humane Treatment 
>	 Freedom of Association
>	 Foreign Contract Workers and Recruitment 
>	 Unauthorized Subcontracting 
We are committed to upholding and 
progressing human rights and cultivating 
social dialogue to create a resilient supply 
chain that respects workers. Our goal is 
to design, collaborate on, and implement 
industry-leading programs that transform 
outcomes for workers and enterprises 
across the sector. 
OUR KEY HUMAN RIGHTS ISSUES
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
19

ASSESSMENT AND REMEDIATION
We use our Assessment and 
Remediation Program to 
evaluate our suppliers and 
incentivize improvements by 
directing more business toward 
the highest-performing facilities. 
Our approach begins with assessments 
conducted by Gap Inc. (32 percent of 
assessments), ILO-IFC Better Work  
(26 percent), and the SLCP (43 percent). 
Through these assessments, we rate  
each facility using a color-coded system: 
> 	Green for high-performing facilities with 
few violations, none of which were critical.
>	 Yellow for average performers.
> 	Red for those that need to address 
one or more serious issues. 
When an issue is reported or found during 
our assessments, our global field teams 
develop a tailored remediation process  that 
considers local contextual factors such as 
workers’ education level, cultural norms, and 
ways of communication. For example, we may 
conduct interviews in workers’ communities 
to better understand their needs, enabling us 
to more effectively address violations within 
our global supply chain.
Critical and severe 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 
action a responsible exit plan and continue to 
monitor the facility to address pending issues 
during and following deactivation.
SOCIAL & LABOR 
CONVERGENCE  
PROGRAM (SLCP)
As a signatory to the SLCP, we support 
ways to improve working conditions in 
global supply chains by encouraging 
the wider adoption of the SLCP tool, 
which helps assess the social and 
labor performance of manufacturing 
facilities while reducing the duplication 
of industry efforts. 
In 2021, we used the SLCP tool 
in Better Work assessments in 
Indonesia, Bangladesh, and Vietnam. 
We aim to increase this across all 
Better Work countries, supporting 
our goal to have all our Tier 1 facilities 
and Tier 2 strategic mills involved in 
industrywide efforts by early 2023. 
2021 Progress
Between 2016 and 2020, we worked 
toward a goal of sourcing from facilities 
rated yellow or green; today, only 1 percent 
of facilities we work with are rated red, 
compared to 16 percent in 2016. In 
2021, we raised our ambition to drive 
performance improvement by setting 
a goal to source at least 80 percent 
of business spend from green-rated 
factories by 2025; we are on track, with 
68 percent at the end of 2021. 
By the end of 2021, 84 percent of COVC 
issues had been resolved. We resolve 
these violations by integrating this work 
into our sourcing decisions, which drives 
increased vendor ownership in resolving 
issues promptly. Our dedicated Supplier 
Sustainability team trains global sourcing 
employees on human rights policies and 
procedures, building awareness on COVC 
requirements and ways to manage vendor 
performance. We also train and educate 
key vendors on how to implement measures 
that prevent COVC issues from arising.
GOAL BY 2023/2025
GOAL BY 2025
PROGRESS IN 2021
68% 
of our business spend is 
allocated to green-rated 
factories
75%
of Tier 1 
factories are 
participating
100%
By 2023, 100% of our Tier 1 facilities will 
participate in industrywide efforts, including 
SLCP and/or ILO-IFC Better Work, and 100% 
of Tier 2 strategic mills will participate by 2025. 
80%
of Gap Inc. sourcing will be allocated 
to green-rated factories
On track 
Needs attention
40%
of Tier 2 
strategic 
mills are 
participating
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
20

CAPABILITY BUILDING
To provide safe, fair, and 
healthy working conditions in 
our supply chain, we partner 
with our branded-apparel 
suppliers and key stakeholders 
through a variety of country-
specific capability-building 
programs. These approaches 
catalyze improvements in 
workers’ grievance mechanisms, 
gender equity in leadership, 
safety, and well-being. 
In 2021, we announced several women’s 
empowerment goals for 2025 regarding 
our capability-building programs. While 
the ongoing effects of COVID-19 on our 
supply chain partners slowed the start 
of this work, we have now developed 
strategies and key performance indicators 
for each goal (p. 12) and are in the process 
of collecting baseline data, starting with 
the last quarter of 2021. 
We seek to understand and address our 
workers’ needs in the supply chain by 
learning from and sharing resources  
with our peers to enhance industry 
knowledge and practices. For example,  
we have measured worker engagement 
using Nike’s Engagement and Wellbeing 
survey since 2019. In 2021, 32 factories 
collected responses. 
ILO-IFC Better Work Academy 
Gap Inc. is a founding member of the 
ILO-IFC Better Work program, which is 
an important partner in our key sourcing 
markets. We also helped establish the 
Better Work Academy, which trains staff 
in global apparel brands on key issues 
related to social dialogue. This enables 
participating companies to deliver 
training and consultation to factories 
beyond Better Work’s scope. The 
Academy empowers facilities to make 
improvements based on participant 
feedback, with brands serving as 
advisors and partners.
The Academy has reached 441 facilities 
in 18 countries, with eleven companies 
– including Gap Inc. – now participating. 
We have actively supported its 
expansion by sharing insights and 
providing training materials that brands 
can customize for their own programs. 
Together with Better Work, we have 
developed our Workplace Cooperation 
Program, which facilitates dialogue 
between workers and management, 
and our Supervisory Skills Training (SST) 
program, which improves the skills of 
supervisors and middle managers and 
fosters gender parity in supervisory 
positions. To support all our capability-
building programs, we use our Workforce 
Engagement Program mobile tools 
(see sidebar). 
The WEP supports our capability-building 
programs in two ways: (1) the mobile  
technology enables our suppliers to deliver 
important information and training, and  
(2) it provides a platform for workers to share 
feedback with facilities. 
By the end of 2021, WEP was active in 54 
facilities. We share best practices with suppliers 
in Vietnam, Cambodia, China, Indonesia, and 
Guatemala. In 2022, we plan to use WEP in 
pilot programs in Bangladesh, China, and 
Indonesia to test different models for delivering 
our capability-building programs, including 
in-person, fully digital, and hybrid models. We’re 
also participating in an SLCP pilot to integrate 
worker voices using similar technologies.
WORKFORCE ENGAGEMENT 
PROGRAM (WEP): A DIGITAL TOOL 
FOR CAPABILITY BUILDING
54 
facilities use 
the Workforce 
Engagment 
Program (WEP)
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
21

SST is a three-day training program launched in 2018 with 
Better Work that helps supervisors and middle managers 
improve communication skills, build good relationships, and 
supervise workers effectively. The reach of the program is 
amplified by facilities delivering the same trainings after 
completing Training of Trainers. Some vendors also have 
their own equivalent programs, which we vet to ensure 
they meet or exceed Gap Inc.’s SST requirements. As a 
result, an additional 25 facilities have been covered under 
the program.  
We use production-efficiency data and supervisor and 
worker surveys to measure the program’s impact. Together, 
they help reveal the extent to which participants thought the 
training was effective, and whether it led to any behavior 
change or production improvements. 
In our strategic facilities, women comprise a minority of 
supervisor positions, even though they represent the 
majority of our total supply chain workforce. We believe 
that we can support future women leaders through our 
SST training.  
In 2021, we set a goal to cultivate women’s empowerment 
among our strategic facilities and prioritize training 
opportunities for women. We will measure this target 
by assessing the percentage of factories with gender-
equitable representation at the supervisor level, with the 
gender ratio reflecting that of the factory’s total workforce. 
100%
of workers employed in our strategic 
factories will have their voices heard 
through representative, gender-
equitable workplace committees 
Since 2017,
3,361
grievances 
raised and
97%
resolved  
(3,261 issues) 
within the same 
quarter
Through elected committees, WCP 
facilitates dialogue between workers 
and management on a variety of issues 
ranging from overtime and well-being to 
washroom sanitation and canteen food. 
This program educates participants on 
communication and negotiation skills to 
help them feel more comfortable voicing 
their grievances to senior management. 
After scaling back WCP in 2020, we 
ramped up the program again in 2021, 
using virtual training when appropriate. 
WCP has been implemented in 241 
facilities across 12 countries since 2016, 
including 65 percent of our strategic 
factories. We now plan to expand the 
program to our strategic vendors’ owned 
and authorized subcontracted facilities. 
Workplace Cooperation Program (WCP)
Supervisory Skills Training (SST)
GOAL BY 2025
100%
of our strategic factories will 
have achieved gender parity  
at the supervisor level 
63
new facilities 
for a total of 
228 facilities 
implementing SST 
(target: 220)
Cumulative 
impact: 
7,100
supervisors 
trained
2021 active 
participants:
182
facilities in  
9 countries
GOAL BY 2025
Establishing baseline
Establishing baseline
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
22

Over the years, our regular facility 
assessments have revealed violations 
related to gender-based discrimination 
and harassment. We recognize that it’s 
not enough to rely solely on auditing to 
detect and address these issues, which 
is why we developed our GBV Prevention 
and Response Program with Better 
Work to help enforce our zero-tolerance 
policy on physical, psychological, and 
sexual harassment. 
Our GBV Prevention and Response 
Program focuses on training managers 
and workers as a key part of our 
strategy. In 2021, we set a goal of 
ensuring that all our factories have 
GBV training, prevention, and response 
systems in place by 2025. By 2023, 
we aim to ensure that all workers 
in factories where our clothes are 
produced undergo GBV prevention and 
response training annually. 
Looking ahead, we will further assess 
the extent to which factories have a 
functioning grievance mechanism for 
workers to report incidents of GBV, 
harassment, and abuse. To have an 
impact beyond the facilities we work 
with, we are also exploring partnerships 
to further accelerate this work across 
the industry with expert organizations 
and other major apparel brands. 
100%
of our factories will have prevention 
and response management 
systems and trainings in place to 
address gender-based violence 
44%
of our factories have started 
training on GBV Prevention and 
Response, reaching over 231,500 
workers (26% of our supply chain)   
90%
of our factories had completed 
gender awareness training for 
middle and top management
Gender-Based Violence (GBV) 
Prevention and Response
Digital Wage Payments
We work closely with partners and participate in the UN’s 
Better Than Cash Alliance to address ongoing regulatory 
and infrastructure constraints on digital wage payments. 
We continue to prioritize digital wage payments with 
new Tier 1 suppliers and support financial inclusion more 
broadly by offering digital financial literacy sessions in our 
P.A.C.E. curriculum.
Since starting our Digital Wage Program in 2017, we have 
increased the share of our eligible Tier 1 suppliers that 
offer digital wage payment systems from 68 to 96 percent 
(which includes mobile wallets, bank accounts, debit cards, 
and other digitally accessible methods). 
96% 
of our eligible 
Tier 1 suppliers 
(that provided 
data) offer 
digital wage 
payments
GOAL BY 2025
PROGRESS IN 2021
Establishing baseline
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
23

HELPING KEEP OUR 
SUPPLY CHAIN SAFE 
DURING COVID-19
Since the pandemic hit in 2020, we have 
taken several steps to support our supply 
chain partners and prioritize the health and 
safety of people working in our supply chain. 
We continue to distribute COVID-19 guidelines to our 
suppliers and factories and, when needed, we adapt our 
social and labor programs, offering virtual options that 
ensure continuity while keeping everyone safe.
We have also continued to enforce important COVC 
standards, including the provision of sick leave and other 
relevant benefits, functioning grievance mechanisms, 
requirements related to non-discriminatory employment 
practices and ethical practices around virus-related layoffs 
and furloughs. 
We support vaccine distribution and uptake in key sourcing 
markets as part of the Business Roundtable’s CEO COVID-19 
Task Force. This group has mobilized the private sector to 
urge governments to invest in vaccine funding and get more 
vaccines into underserved markets. In addition, we have 
integrated vaccine education into the P.A.C.E. platform.
COVID-19 RESILIENCE FUND FOR WOMEN 
In 2021, the Gap Foundation 
continued its support of the 
COVID-19 Resilience Fund for 
Women in Global Value Chains, 
a collaborative effort to help with 
pandemic recovery and advance 
long-term, systemic changes that 
build resilience for girls, women,  
and communities. 
We became a founding partner of the 
fund in 2020, which contributes to 
a pool of investments from multiple 
sources to support local woman-led 
organizations. In 2021, we made 
our second investment, this time 
of $250,000, while our first round 
of funding was already supporting 
projects in India and Bangladesh.
$250 ,000 
in COVID-19 resilience 
funding for women
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
24

ENABLING 
OPPORTUNITY
We believe that enabling opportunity means 
ensuring employees have the skills they 
need to build truly fulfilling careers with us. 
Our purpose to be Inclusive, by Design drives 
our work on programs that ensure diversity 
is a major feature of our talent pipeline. 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
25

“When you shop at a store, you 
want to see the store team reflect 
the community, and This Way 
ONward helps create a space 
where customers feel comfortable. 
They feel like they are being seen, 
their needs are being met – it’s 
someone from their community. They 
understand what product they are 
looking for, and that translates to 
sales because we have people who 
connect with the community.” 	
Chantal Horton, Senior Recruiter, This Way ONward
>	 This Way ONward
27
>	 Talent Development
29		
Opportunity Hiring 
30
>	 Equality & Belonging
31
>	 Employees and Community Impact
32
We use the assets and scale of our 
business to enable access to opportunities 
for the people and communities we serve. 
Our programs and partnerships open 
doors to underrepresented talent across 
gender, race, age, and more.
In addition to developing skills, we create 
a sense of belonging for employees, 
enabling them to be part of a supportive 
team where they can fulfill their potential. 
We do this by cultivating a workplace 
culture that meets our employees‘ 
professional and personal needs. 
We also champion initiatives and ideas 
that encourage volunteering and ensure 
that we give something back to the 
communities and places where we  
work and our employees live.
Gap Inc. prioritizes fostering a culture 
of equality and belonging and 
developing sustainable economies. 
HOW WE ENABLE OPPORTUNITY
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
26

THIS WAY ONWARD 
 “It was satisfying to see the money in 
my bank account continue to climb, 
but eventually, it was more about the 
relationships I developed with people.”
A self-described optimist, high school 
senior Richard Greene felt discouraged 
after being rejected for job after job. 
He was applying for work so he could 
save money for college. The director 
of the Boys & Girls Club he attended 
encouraged him to apply for This Way 
ONward, and with support from his 
parents, he was successful.
When Richard started work at Old 
Navy, he found himself surrounded by 
a supportive team, including his store 
leader, a job coach, and a “Big Sib” 
coworker. Richard was in his element 
and enjoyed interacting with customers 
and sharpening his leadership skills. His 
worries about college, and life began to 
drop away. “Having a job you enjoy keeps 
you present,” he said. “It helped me leave 
the stress of the world behind. This Way 
ONward really taught me not to look at a 
job as a job, but as an opportunity.” 
Richard also began to see that the real 
impact of work wasn’t the paycheck 
but the people. “It was satisfying to see 
the money in my bank account continue 
to climb,” he said, “but eventually, it 
was more about the relationships I 
developed with people.”
THIS WAY ONWARD TEACHES 
RICHARD GREENE ABOUT THE 
POWER OF RELATIONSHIPS  
PROGRAM SPOTLIGHT
10. 	We have moved to a biennial cadence for the evaluation survey due to consistently positive results. The next evaluation is planned for 2022.
Old Navy believes that 
opportunity should be for 
all, not just the few. Through 
This Way ONward, Old Navy 
is continuing its journey to 
become the world’s most 
inclusive brand.
Old Navy has been expanding This Way 
ONward since 2007 to create the next 
generation of leaders. Through a growing 
network of partners, including Boys & 
Girls Clubs of America, the program 
tackles systemic barriers to employment. 
This Way ONward provides young 
people aged between 16 and 24 with 
structured training and valuable 
first-job experience. The program also 
develops mentors’ leadership skills. 
Research confirms that the program 
works. Alumni stay with the company 
twice as long as their peers, and store 
managers say This Way ONward hires 
are top performers. Our latest evaluation 
survey10 revealed that new hires also feel 
a sense of belonging at Old Navy, feel 
supported by their managers, and are 
excited about their work. 
Find more about This Way ONward on 
our website.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
27

THIS WAY ONWARD REACH AND GROWTH
2017
1,148
274
2,713
3,900
8,201
10,672
0
2,000
4,000
6,000
8,000
10,000
1,700
444
2018
2,524
576
2019
471
912
2020
1,170
452
2021 12
Stores 
Youths
Cumulative 
since 2007 
5,677
In 2021, 37 percent (450+) 
of Old Navy stores across 
North America hired This Way 
ONward associates. Old Navy 
raised and donated a total of 
approximately $3.8 million for 
the program.
To engage more people to join, Old Navy 
has invested in high-profile storytelling 
campaigns that promote the power of 
mentorship. These stories explore the idea 
that hiring for potential, not credential, is 
critical to expanding the talent pipeline 
and cultivating a talent strategy that 
prioritizes diversity, inclusion, equality,  
and belonging. 
In one national ad campaign, basketball 
superstar Magic Johnson invited 
communities to “imagine a brighter future 
where every kid gets a foot in the door.” 
This Way ONward Influencers have shared 
their stories on social media, showing how 
the program improved their confidence, 
taught them new skills, helped them see 
their potential, and enabled them to pay it 
forward by mentoring others.
In 2021, our This Way ONward alumni 
advancement pilot launched. The program 
aims to give members access to the 
networks, mentoring, and skills that will 
take them from their first jobs to career 
rockets. Select alumni in the U.S. and 
Canada participated in this program, 
which we will expand in the coming years.
This Way ONward continues to provide Old 
Navy with a diverse and reliable source of 
talent. In 2021, 39 percent of all program 
applicants were hired, compared with less 
than 10 percent of applicants from other 
sources. The program also supports Gap 
Inc.’s Equality & Belonging goal to achieve 
diverse representation in our pipeline. 
More than 1,294 This Way ONward alumni 
(14.6% of our total participant population 
since 2007) are now Gap Inc. employees, 
the majority of whom identify as people  
of color.13 
Gap Inc. continues to integrate insights 
and new resource tools from This Way 
ONward into our talent strategy. In 
addition to hiring for potential and 
cultivating talent pipelines, we apply 
lessons learned to ensure we provide the 
right post-hire support to help entry-level 
retail store employees thrive, particularly 
those who are from underrepresented or 
marginalized groups.
In response to the pandemic, This Way 
ONward supports innovative recruitment, 
hiring, and training. Tools such as virtual 
career fairs, interviews, job-readiness 
workshops, and volunteer and mentorship 
opportunities have helped make the 
program accessible to more people, 
including participants, field leaders, 
Old Navy leadership teams, nonprofit 
partners, and mentors and volunteers.
11.	
The numbers are cumulative since program launch. 
12. 	Numbers for 2020 and 2021 are lower due to the program’s shift to Old Navy stores exclusively, as well as temporary store closures during the COVID-19 pandemic.
13.	 Excludes those who did not disclose their ethnicity or otherwise have not submitted one.
The value of hiring 
for potential - not 
credential
20,000 youths 
reached through  
This Way ONward11
PROGRAM SPOTLIGHT
5% of Old Navy 
store entry-level 
employees hired 
from This Way 
ONward annually 
2017
0.9%
1.4%
2.1%
2.1%
3%
2018
2019
2020
2021
GOALS BY 2025
PROGRESS IN 2021
On track 
On track 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
28

2,000+
HQ Pulse survey 
participants and 
23,000+ store 
Pulse survey 
participants14
8,000+
total learning 
courses taken
6,000+
on LinkedIn 
Learning
We converted several key training 
programs into virtual experiences, 
including our Rotational Management 
Program (high-potential entry-level talent), 
Leadership Essentials Program (first-time 
leaders), and coaching programs for 
mid-level leaders. We continue to see our 
Rotational Management Program as a 
pipeline for emerging and diverse talent, 
with 64 percent Black, Latinx, and Asian 
and with 82 percent female participation. 
We have recently embedded ESG training 
within the Rotational Management 
Program to train our managers on the 
issues that will define their futures. 
All of our full-time employees receive 
regular performance reviews. To support  
individual learning, we implemented the 
Workday platform, which empowers 
leaders and employees with access to 
employee and team information they need. 
TALENT 
DEVELOPMENT
By putting people first, we increase employee 
engagement and create business value. We 
do this by cultivating a workplace culture and 
providing benefits that meet the professional 
and personal needs of our employees and 
their families. This includes offering financial 
incentives and designing work schedules that 
give in-store staff greater stability, flexibility, 
and work-life balance. 
With the ongoing pandemic, we continue to listen to our 
employees through the Pulse survey and offer our Be You, 
Be Well benefits program. It includes access to counseling and 
our Be Well + Stay Connected speaker series, featuring thought 
leaders, meditation programs, and fitness classes to support 
the physical and mental well-being of our people.
We are excited about building a better future of work that 
helps Gap Inc. establish a performance culture anchored in 
excellence, grow our purpose-led brands, and enable our 
employees to meet their professional aspirations. 
Find more about how we support and develop our exceptional 
people on our website.
2021 PROGRESS
Our Future of Work model brings us 
closer to our customers and each other. 
The model supports employees working 
in a combination of in-office and virtual 
settings based on where they deliver their 
best work for the customer – ultimately 
unlocking creativity, collaboration, and 
agility. We are examining every facet of 
the employee experience – including tools, 
policies, ways of working, technology, 
and physical workspaces – to support a 
culture of performance and connection, 
while delivering innovative work, living our 
values, and attracting best-in-class talent. 
As part of our ongoing commitment to 
equality and belonging, we continue to 
build an inclusive leadership culture, 
cultivate a sense of belonging for all, 
and foster workplace equity (read more 
in our Equality & Belonging Report in 
June 2022). 
We tailor training programs and 
resources to employees’ levels and 
needs, including investing in first-time 
leaders through mid-level leader 
coaching and development. We provide 
seven hours of onboarding for all new 
leaders, 44 hours of education and 
cohort experience for new leaders in our 
Distribution Centers; and one to six weeks 
of training for our Product functions. We 
also provide individual coaching for more 
than 170 of our leaders. We also continue 
to offer access to the LinkedIn Learning 
program, which offers free online courses 
with topics ranging from technical skills to 
professional development.
14.	 A representative sample was obtained for both groups.
95%
average score for 
“I am proud to work 
here” and 89% 
“I intend to stay for 
the foreseeable 
future” from 
Pulse survey 
participants
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
29

OPPORTUNITY HIRING
We think it is important to hire people who we believe will bring 
value to the organization, regardless of their background or 
experience. We see diversifying and supporting the potential 
of our global workforce as a critical part of our 21st century job 
advancement and corporate talent strategy.
assessment process. These assessments 
allow candidates to provide evidence that 
a conviction is not related to their ability 
to perform a job and let us determine 
whether a criminal record is specifically 
related to the position that a candidate 
has applied for. 
In April 2021, we joined the Second Chance 
Business Coalition, which promotes 
the benefits of employment and career 
advancement for people with criminal 
records. As part of this, we participated 
in Dave’s Killer Bread’s Second Chance 
Corporate Cohort, which further informed 
our work in second chance hiring with 
current leading practices and frameworks 
to support our hiring the best person for 
the job, regardless of their conviction 
history. We also launched a pilot in 
December 2021 with Honest Jobs, the 
largest fair-chance employment platform 
in the U.S., with a goal of hiring and 
retaining individuals who were previously 
incarcerated or justice-involved as part  
of our Distribution Centers. 
STARS
In 2021, Gap Foundation, together with 
other funders, supported the development 
of workers who are skilled through 
alternative routes (STARs). The campaign, 
which will run in 2022, is aimed at helping 
employers perceive STARs as individuals 
who represent a high-potential talent 
source with valuable skills and experience.
>	 Bloomberg Gender-Equality Index:
Included for the fourth consecutive year
> 	Refinitiv:
Named among the top 100 of the world’s most diverse
and inclusive companies
> 	Corporate Equality Index:
Received a perfect score for the 16th year in a row
> 	Fortune Change the World:
Athleta recognized and ranked 43rd
AWARDS
TENT PARTNERSHIP 
FOR REFUGEES 
Tent is a nonprofit with over 170 member 
companies that was launched in 2016 to 
mobilize the global business community  
to include refugees in their workforces. 
In 2021, Gap Inc. signed on to the Tent 
Coalition for Afghan Refugees,  
a commitment to train and hire Afghan 
refugees as they begin their new lives in 
the U.S. In 2021, we piloted a refugee hiring 
program at one of our Distribution Centers, 
and we are exploring ways to expand 
programs like this across our operations  
in the U.S. 
We have also continued providing life 
skills education and technical training 
to refugee women through our P.A.C.E. 
program (read more on p. 16). 
SECOND CHANCE  
BUSINESS COALITION 
We believe every applicant deserves an 
opportunity at a career with our company. 
In 2016, Gap Inc. signed a White House 
pledge (AP Leadership) to commit 
to providing individuals with criminal 
records, including formerly incarcerated 
individuals, a fair chance to participate in 
the American economy. 
Our background screening program 
partners with local organizations to help 
candidates through the individualized 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
30

EQUALITY & 
BELONGING
Since publishing our inaugural Equality & Belonging 
Report in 2021, we have launched a number of initiatives 
and programs that support a new equality agenda for our 
employees, customers, and communities.
OUR EMPLOYEES 
At Gap Inc., we’re committed to making space for candid 
conversations where employees feel valued, safe, and a deep 
sense of belonging. Fostering an inclusive culture where employees 
feel a deep sense of belonging and community has been our 
priority since the formation of our first Equality & Belonging Group 
more than 15 years ago.
In 2021, we continued strategic investment in programs and 
partnerships that support the elimination of discrimination and 
harassment and that empower our employees to create an  
inclusive, equitable, and just environment. Later in 2022, we  
plan to release our annual update on Gap Inc.’s equality and 
belonging commitments.
OUR CUSTOMERS
It is our collective responsibility to 
ensure that all customers are both 
seen and valued across our portfolio of 
brands. We work to create products and 
customer experiences that authentically 
reflect the diversity of our customers.
Since we became a founding member 
of Open to All in 2018, we have helped 
develop industry tools and resources 
to ensure the inclusion, safety, and 
respect of all customers, employees, and 
communities. In 2021, we supported the 
launch of the groundbreaking Inclusive 
Retail initiative, which features two new 
tools: the Customer Action Center, which 
teaches customers how to be allies 
and intervene when needed, and the 
Inclusive Retail Business Toolkit, which 
equips retail staff with tactics proven to 
mitigate racial bias.
OUR COMMUNITIES
We are optimizing our platform 
to support and advance our most 
historically marginalized communities 
and help end racial inequality. Through 
our multi-pronged partnership strategy, 
we strive to support and elevate 
our communities by building critical 
awareness of what creates barriers to 
access and opportunity. Our established 
partnerships, with organizations focused 
on racial and social equity initiatives, 
work to drive our ambitions forward 
and deliver on our commitments to the 
communities we serve.
At Gap Inc., our purpose is to be Inclusive, by 
Design. With inclusion built into our DNA, we 
began by hoping to bridge a generation. Today, 
we believe inclusion is going to change the world.
15 
years ago we 
formed our 
first Equality 
& Belonging 
Group (EBG)
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
31

30,000+
employees 
volunteered in 2021 
266,000+
contributed hours 
volunteering 
3,000+
NGOs supported by 
direct donations
More than
$1.3M
Gap Inc. funded 
donations
EMPLOYEES AND 
COMMUNITY IMPACT
We promote Gap Inc.’s values to 
be a force for good in the world, 
while our legacy of community 
involvement cultivates a culture 
of employee engagement and 
community impact. 
We provide opportunities for employees to learn and connect 
with each other and their local communities, and to support social 
and environmental issues that are meaningful to them and our 
company. This includes company- and employee-led activities, 
rallies, events to raise awareness and money, opportunities to 
volunteer, and more.
Our exempt, salaried employees are enabled to volunteer for five 
“on the clock” hours per month, which we match through monetary 
donations, empowering our people to support the causes they  
care about in ways that work best for them. 
We are also creating 
a new employee 
engagement and 
community impact 
strategy that will 
further integrate 
our company values 
and ESG work to help 
employees meet 
our purpose to be 
Inclusive, by Design.
Learn more on our 
website.  
2021 PROGRESS
In January, we curated a campaign in 
honor of Martin Luther King, Jr., which 
included opportunities for employees to 
learn more about Dr. King and volunteer in 
ways that use his legacy to inspire action. 
This campaign also included a fundraising 
element, in which Gap Inc. matched any 
donation of $10 or more (for a total of nearly 
$2,000) to the Enterprise for Youth, a job-
readiness training program for young 
people in San Francisco.
For World Water Day in March, we held 
another Walk for Water that helped raise 
awareness and funds to address the 
challenges that women around the globe 
face accessing water. More than 7,941 
employees from nine countries completed 
a 1.2-mile walk, a distance that represents 
the average distance women around the 
world walk every day for water. For each 
participant, Gap Inc. pledged $12 to our 
Women + Water Alliance partner 
WaterAid, up to a total of $12,000.
In honor of our founder Doris Fisher's 90th 
birthday in August, we held the inaugural 
Doris Day of Service, with 11 events 
led by employees in our San Francisco 
headquarters. Our annual Volunteer Rally 
saw nearly 14,000 employees give over 
60,000 hours of their time and talents 
to their communities. Some contributed 
to community projects to beautify local 
parks and beaches, while more than 450 
took part in a “closet cleanout” to highlight 
opportunities to donate and reuse 
clothing. In China, 300 of our employees 
contributed 600 volunteer hours making 
gift bags for children with cancer and 
sorting clothes for recycling or donation. 
Our brands also led their own activations: 
Athleta held two sales for employees to 
shop at a discounted price from the brand’s 
collection of samples, which raised $157,000 
for the Selvage Fund.15 For the sixth year 
in a row, every Old Navy store logged 
volunteer hours with the brand, contributing 
more than 217,000 hours in 2021. 
In addition to these events, our global 
team supported a variety of causes 
through donations to organizations 
supporting racial justice and equality, 
including $100,000 to Stop AAPI Hate and 
the National Coalition for Asian Pacific 
American Community Development.
DISASTER RELIEF 
In 2021, The Gap Foundation provided nearly $2 million in grants to nonprofits 
and NGOs, including $500,000 for disaster relief following the California wildfires, 
ice storms, and power outages in Texas, and Hurricane Ida. Additionally, the 
foundation donated $150,000 to support team members in India during the 
COVID-19 pandemic. In response to the widespread damage and devastation 
caused by a series of tornadoes in the Midwest and Southeast U.S., in December 
2021, Gap Foundation made a $100,000 donation to the Center for Disaster 
Philanthropy. This helped support the physical, emotional, and economic recovery 
of individuals and families impacted by this natural disaster.
15. 	Named after the tightly woven edge of a fabric that prevents it from unraveling or fraying, the Selvage Fund was created to support Gap Inc. employees in times of need. 
In 2021, the fund made over 300 grants for a total of over $250,000 to support employees during COVID-19.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
32

ENRICHING 
COMMUNITIES
We believe that a clean and healthy planet is 
a fundamental human right. Climate change 
and water scarcity are global challenges 
that transcend boundaries, affecting people 
and communities everywhere.  
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
33

Our environmental approach centers 
on addressing climate, waste and water 
issues by creating more sustainable 
products. These are the issues where 
we see significant potential to positively 
impact people’s lives and enrich the 
world’s communities.
Many of our initiatives, especially around 
water, positively impact the lives of women 
by increasing the opportunities available 
to them and recognizing the central role 
they play in every step of the production 
of the garments we sell. Protecting our 
planet is fundamental to our sustainable 
business strategy and central to our 
company’s future. 
Through our work to achieve our bold 
goals, we take steps every day, including 
incorporating more sustainable practices 
into product development and partnering 
with businesses, nonprofits, governments, 
and community organizations, to do our 
part in building a thriving planet. 
“We believe water is a human right and it is a 
critical natural resource for our business. Water 
is used to cultivate and process raw materials like 
cotton, it is consumed in the mills and laundries 
that manufacture our products, and it is used by 
customers to wash their clothes. Water is also 
critical to the health and well-being of the people 
who make our products, the majority of whom 
are women. That is why Gap is taking steps to 
reduce our water use and ensure that we are 
contributing to a more sustainable future.” 
	 Mark Breitbard, President and CEO of Gap Brand
>	 Water Stewardship 
35
	
	
Women + Water 
36
>	 Resource Efficiency and Manufacturing	
37 
	
	
Mill Sustainability Program 
37
	
	
Water Quality Program
37
	
	
Washwell™
37
>	 Chemicals Management 
38
>	 Climate Stewardship 
39
>	 Raw Materials and Product
42
>	 Circularity and Waste
44
HOW WE ENRICH COMMUNITIES
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
34

For this reason, much of our water 
stewardship work focuses on high-volume 
suppliers operating in areas of water 
risk, where we can partner to introduce 
innovative local solutions.
By engaging with our suppliers, we 
can help them to implement industry 
and Gap Inc. programs (such as our 
Mill Sustainability and Water Quality 
programs) around water quality and 
efficiency, so that they can meet our 
water-savings targets. As a founding 
member of the Water Resilience Coalition, 
we support its ambitious 2050 goals: 
>	 Positive water impact in water-stressed 
regions. 
>	 Water-resilient value chains 
> 	 Global leadership to raise the ambition  
of water resilience 
We work strategically to use water more 
efficiently in our products, especially 
through raw material sourcing and 
manufacturing. We aim to eliminate water 
contamination from chemicals, improve 
awareness and access to water and 
sanitation (particularly among women), 
and invest in opportunities to build 
community water resilience and catalyze 
water innovation.
Our programs and collaborations are 
designed to tackle different water 
challenges, mobilize broader business 
action, and raise awareness of these 
critical issues. We focus on three 
interconnected areas:
1.	 Women + Water (p. 36)
2.	Resource Efficiency and  
Manufacturing (p. 37) 
3.	Raw Materials and Product (p. 37)
2021 Progress
In 2021, we embarked on a water 
strategy-setting process with corporate 
water stewardship experts at the 
Water Foundry. We also engaged more 
than 20 leading stakeholders and water 
experts to gather feedback on our 
preliminary water strategy across raw 
materials, manufacturing, and customer 
communities through a roundtable 
discussion facilitated by Ceres. 
To guide our future strategy, we are 
working with World Wildlife Fund (WWF) 
to concentrate our water stewardship 
activities in water-stressed regions along 
our value chain and develop a framework 
for community water resilience. WWF is 
also helping us assess our macro-level 
water risk across our supply chain and  
set new context-based water goals  
PARTNERSHIPS FOR ADVOCACY 
AND INDUSTRY CHANGE
We collaborate in several initiatives to 
address water scarcity, improve access 
to water and sanitation, and support 
water-saving innovation in manufacturing, 
such as Water Resilience Coalition, 
WASH4Work, and Ceres Connect the 
Drops. Highlights of our additional 
engagements include:
•	 World Water Day: In March 2021, Mark 
Breitbard, President and CEO of Gap 
brand, spoke at a UNGC CEO Water 
Mandate event to highlight the value  
of water for business. 
•	 World Water Week: In August 2021, 
we participated in seven SIWI World 
Water Week panels. Among the areas 
covered were the business case for 
building community water resilience, 
how water strategy can drive strategic 
business value, partnerships to catalyze 
innovation in water use in apparel 
manufacturing, and how we’re tackling 
the water and climate crises with more 
sustainable cotton sourcing.
•	 Water Innovation Center for 
Apparel: Together with global textile 
manufacturer Arvind Limited, we are 
building an 18,000-square-foot Water 
Innovation Center for Apparel in India. 
The center, due to open in 2022, will 
showcase water-management best 
practices and recycling technologies. 
In recognition of our 
efforts to manage the 
risks and opportunities 
related to water security, 
we received an A- rating 
from CDP Water in 2021. 
WATER 
STEWARDSHIP
Water is essential for our business. However, the garment 
industry often sources from locations where demand for 
water is high and water stress is often a major issue. 
that will serve as the foundation for 
long-term science-based targets 
(SBTs) for water. 
Looking forward, we plan to build 
upon these expert insights, our 
strong foundation of community 
water-resilience work from the USAID 
Gap Inc. Women + Water Alliance, 
and our water‑saving practices in 
manufacturing as we pursue a path 
to building a more water-resilient 
value chain. 
Find more about our approach to 
working with suppliers, our industry 
partnerships, and the tools we use  
to enhance water stewardship on  
our website. 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
35

GOAL BY 2023
PROGRESS IN 2021
We have a particular focus on India, an 
important location for both growing 
cotton and making textiles. Through the 
USAID Gap Inc. Women + Water Alliance, a 
public-private partnership, we collaborate 
with CARE, Water.org, WaterAid, and the 
Institute for Sustainable Communities 
to improve access to WASH services for 
women in the water-stressed Ganges, 
Godavari, and Narmada river basins in 
Madhya Pradesh and Maharashtra, India.
Following a six-month pause in work 
due to COVID-19, Women + Water 
Alliance partners agreed to extend 
the initiative for an extra year, until 
January 2023. Looking ahead, we will 
be using insights from this program to 
build out the Gap Inc. community water 
resilience strategy to support our 2050 
water goals of creating positive impact 
in water-stressed regions and building 
water-resilient value chains.
“From the time we have saved every day by not 
walking for water, the women of the village and 
I can now spend that time with our families and 
take time out for ourselves, too. With the time 
that we have left, we work in our farms, which 
has resulted in a growth in our incomes.”
	 Pooja Doriya, cotton-grower in Jamgod village  
in Madhya Pradesh, India
The majority of people who make our clothes are women, and access to and 
the affordability of water, sanitation, and hygiene (WASH) services is a major 
challenge for many women in our key sourcing countries. As women in those 
communities are largely responsible for household duties such as cooking, 
cleaning, and collecting water, they bear a disproportionate burden when it 
comes to water stress.
47,000
women trained  
on WASH 
practices 
through P.A.C.E.
4,100
farmers 
adopted water 
stewardship
Empower 2 million people - 
including 1 million women - with 
access to improved drinking 
water and sanitation 
1.5 million people reached 
with improved water 
access since 2017, including 
938,000+ people in 2021 
On track 
More than 47,000 women in 
cotton-growing communities 
trained on WASH practices 
through P.A.C.E. in 2021 (162,000+ 
since 2017)
Prepared more than 2,100 village 
action plans for water access in 
India in collaboration with the 
national government and local 
governments
Catalyzed $6.1 million in WASH 
financing through more than 
31,700 micro-loans ($12.7 million  
in 66,100 loans since 2017)
More than 4,100 farmers adopted 
water-stewardship best practices 
as a result of water training
HIGHLIGHTS
PROGRAM SPOTLIGHT
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
36

RESOURCE 
EFFICIENCY AND 
MANUFACTURING
We are working to map our supply chain further upstream to better 
understand our water impacts at the beginning of our product life 
cycle. This enables us to connect our manufacturing footprint with 
the geographical areas where raw materials are grown. 
Many water issues are based on local context, and with better 
visibility, we aim to enhance transparency, set more ambitious 
targets, and improve water impacts across our supply chain. 
We have mapped all preferred wet-processing facilities — 
representing 100 percent of our business for Tier 1 and about 
65 percent for Tier 2 — against the WWF Water Basin Risk 
Assessment to help us prioritize areas of focus.
Through our Mill Sustainability Program, we engage our strategic 
mills using key industry tools and initiatives to help us meet our 
long-term commitments. All our strategic mills must participate, 
enabling us to align our approach with industry standards, 
increase transparency, and drive innovation. 
We also work with the Apparel Impact Institute (Aii) on platforms and 
pilots that have helped facilities reduce water use. And through 
our Water Quality Program (WQP), we actively monitor and improve 
wastewater quality at denim laundries. The program has evolved 
to include chemicals management, a key component of water quality 
(see p. 38). 
2021 PROGRESS
In 2021, we began working with WWF and our preferred wet-
processing suppliers to set context-based water targets and 
develop water-reduction strategies for their facilities. 
Across our manufacturing, we aim to use all 
resources in a sustainable way, ultimately 
creating more while using less.
13.8B
liters of 
water saved 
since 2014
WATER SAVINGS PROGRAMS IN KEY SOURCING COUNTRIES
1
3
2
4
5
Country
Programs
China
Natural Resources Defense Council Clean by Design
China Mill Efficiency Program
India
Arvind Water Partnership
India Water Partnership
Vietnam
Vietnam Improvement Program
Race to the Top
Pakistan
IFC Partnership for Cleaner Textile (PaCT)
Bangladesh
PaCT
By the end of 2021, 99 percent of our 
Tier 1 and 91 percent of our strategic 
Tier 2 suppliers used the Sustainable 
Apparel Coalition’s Higg Index 3.0 Facility 
Environmental Module self-assessment 
to communicate their water and energy 
use from 2020, along with chemicals 
and waste management; 64 percent 
(463 facilities) verified their responses. 
In 2021, wastewater quality tests revealed 
that out of 53 priority denim laundries, 
94 percent achieved Foundational level 
or better for all Conventional parameters 
and had no detections of ZDHC MRSL 
(Zero Discharge of Hazardous Chemicals 
Manufacturing Restricted Substances  
List) parameters.
In total, 89 facilities have participated and 
completed our resource efficiency programs. 
As COVID-19 continued to affect our supply 
chain partners, we offered flexible and 
lower-cost ways to join our programs and 
report their results. Find more about our 
partnerships to help suppliers address 
emissions in our Scope 3 Emissions section. 
In 2020, we surpassed our goal to save  
10 billion liters of water from a 2014 baseline. 
Total savings reached 13.8 billion liters in 
2021 thanks to continued partnerships with 
fabric mill and wet-processing partners. 
For example, we’ve saved 1.7 billion liters 
of water since 2019 through a partnership 
with Arvind Limited’s Naroda denim mill, 
which uses reclaimed wastewater from the 
city of Ahmedabad, India. 
RAW MATERIALS AND PRODUCT
As our brands continue to reduce 
their individual impacts, they are also 
contributing to Gap Inc.’s overall water 
strategy and long-term business goals. 
For instance, they are reducing their 
water impacts through the expansion of 
programs such as Washwell™ for denim, 
which reduces the water used in garment 
finishing by at least 20 percent compared 
to conventional wash methods. Gap 
brand pioneered this technology in 2016 
and all Gap jeans featured in the Fall and 
Holiday 2021 lines were made through the 
Washwell™ program.
For more information on our approach to 
water-saving materials selection, see p. 42.
4
5
3
1
2
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
37

CHEMICALS 
MANAGEMENT
INPUT 
MANAGEMENT
The selection of 
better chemical 
inputs and starting 
materials is essential 
to reducing the use 
and discharge of 
hazardous chemicals.
PROCESS 
MANAGEMENT
Adherence 
to chemical 
management best 
practices during 
manufacturing is 
critical for reducing 
both human and 
environmental risks.
OUTPUT 
MANAGEMENT
The outputs of 
apparel and footwear 
manufacturing 
include finished 
products and 
wastewater.
1. 
2.
3.
1
2
3
The retail industry is a contributor to 
global industrial water pollution. To reduce 
environmental impact and improve access 
to clean, safe water, we aim to eliminate 
the discharge of hazardous chemicals 
within our supply chain. We also recognize 
the importance of safely managing and 
handling chemicals, and of identifying and 
scaling the use of inherently safe chemicals 
in manufacturing. 
We expect our suppliers to comply 
with industry guidelines including the  
Apparel and Footwear International RSL 
Management (AFIRM) Group Restricted 
Substances List (RSL), the ZDHC 
Manufacturing Restricted Substances 
List (MRSL), and the ZDHC Wastewater 
Guidelines. Additionally, we expect priority 
suppliers16 to complete the Higg Index 
3.0 Facility Environmental Module, which, 
among other aspects of environmental 
management, evaluates chemical inventory, 
usage data and management practices. 
Find more about our approach to 
chemicals management on our website. 
2021 PROGRESS
Supply Chain
For more than 15 years, we have required 
our denim laundries to participate in our 
Water Quality Program, which allows 
us to actively monitor and improve 
wastewater quality. 
In addition to continuing to drive implementation of the 
ZDHC MRSL and ZDHC Wastewater Guidelines, we laid 
the groundwork to increase training and capability-
building opportunities for our suppliers. 
Chemicals and Circularity
To support our circularity efforts in 2020 we joined a 
study convened by Inter IKEA and H&M Group to improve 
understanding of the chemical content of recycled textile 
materials. We and other participating brands collected 
samples of post-consumer recycled fibers and tested 
them for chemicals on the AFIRM Group RSL. The study 
organizers communicated high-level findings in October 
2021. More research and work is needed to understand 
the role of chemicals in a circular economy, but this  
study illustrated how industry collaboration can 
contribute to solutions.
Learn more about the study on Sustainable Brands.  
Elimination of PFC-Based Finishes
We are working to phase out chemicals of particular 
concern and are on track to eliminate all PFC-based 
finishes from our supply chain by 2023. Our Brand R&D, 
Product Quality, and Mill Management teams set a 
baseline of fabrics with PFC-based finishes that needed 
to be converted to a non-PFC-based finish or retired 
from use. These teams worked cross-functionally to 
define best practices, create internal procedures for 
fabric conversion, and connect with chemical suppliers 
for technical support. We also maintain an internal list 
of acceptable non-PFC-based finishes, which we share 
with our suppliers.
16.	 “Priority suppliers” are all Tier 1 suppliers as well as fabric suppliers comprising at least 70 percent of fabric production.
GOAL BY 2023
ELIMINATE 
PFC-based 
finishes  
from our 
supply chain
PROGRESS BY 2021
<2% 
of fabrics used 
across our 
brands had 
potentially 
PFC-based 
finishes. 
38%
of products 
with water- or 
stain-repellent 
finishes were 
made using 
non-PFC 
based finishes 
compared to 
7% in 2020.
92%
Gap Inc. 
fabrics with 
a PFC-based 
finish were 
successfully 
converted  
or exited.
On track 
HOW WE MANAGE CHEMICALS
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
38

CLIMATE 
STEWARDSHIP
GOAL BY 2050
100% renewable energy  
sourced for our company-
operated facilities globally  
from a 2017 baseline 
 
90% reduction in Scope 1  
and 2 GHG emissions from  
a 2017 baseline  
 
30% reduction in Scope 3 GHG 
emissions from purchased goods 
and services from a 2017 baseline 
17% of energy usage in 2020 was 
purchased from renewable sources. 
2021 data will be available on our 
website later this year. 
39% reduction in Scope 1 and Scope 2 
emissions in 2020 from a 2017 baseline. 
2021 Scope 1 and Scope 2 data will be 
available on our website later this year.  
2021 Scope 3 data will be available  
later this year.
We have a responsibility to address climate change by  
aligning our goals and strategies with the best science and 
industry practices. At the foundation of our approach are 
goals that align with the scientific consensus of the Paris 
Agreement to pursue efforts to limit global temperature  
rise to less than 1.5 degrees Celsius. 
ATHLETA: POWERED BY RENEWABLES
As of 2021, 100 percent of Athleta’s company-operated stores in North America are 
offset by renewable electricity from Fern Solar, a 7.5-megawatt offsite solar project 
in North Carolina. This project began in 2018 with an agreement between Salesforce, 
Bloomberg, Workday, and Cox Enterprises to combine buying power and collectively act 
as the anchor tenant for the renewable energy project. This innovative project garnered 
two awards: Smart Energy Decisions’ Innovation Award and the Center for Resource 
Solutions’ Green Power Leadership Award. 
On track 
On track 
As a member of the Science Based Targets initiative (SBTi), our 
comprehensive SBTs for reducing emissions across Scope 1 (direct 
emissions from company facilities from the use of natural gas, jet 
fuel, etc.), Scope 2 (primarily purchased electricity), and Scope 3 
(supply chain emissions from products) were approved in 2017. 
To meet these targets, we have built a strategy to address 
emissions and invest in renewable energy projects to reduce our 
Scope 1 and 2 footprint. For Scope 3 emissions, we focus on robust 
data collection from manufacturing facilities, product impact 
modeling, and enhanced transparency to understand and pursue 
opportunities for emissions reductions. We also work closely 
with our suppliers on programs to enhance energy efficiency and 
strategy- and goal-setting around climate change, and provide 
education and resources that help them set their own SBTs. 
Find more about our approach to climate and energy stewardship 
on our website. 
Carbon neutral 
across our value chain 
GOALS BY 2030
PROGRESS IN 2021
In recognition 
of our efforts to 
manage the risks 
and opportunities 
related to 
climate change, 
we received an 
A- rating from 
CDP Climate 
in 2021. 
On track 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
39

2021 PROGRESS 
We are exploring climate adaptation strategies 
that mitigate the financial and physical impacts 
of climate change while building business and 
community resilience. These include renewable 
energy projects within our supply chain and 
accelerating the transition to raw materials 
with a lower carbon footprint, such as recycled 
polyester (see more on p. 42). 
The ongoing effects of COVID-19 have slowed progress on 
our Scope 3 supply chain energy-efficiency programs, as 
we paused them to reduce the cost burden to our suppliers. 
However, our ongoing partnerships are driving meaningful 
reductions across our Asia-based Tier 1 and Tier 2 facilities 
and identifying future areas of action. 
Our 2021 GHG data and progress toward our 2030 goals will be 
available later this year and shared on our website (ESG Resources).
Addressing Emissions: Scope 1 and 2
Retail stores generate approximately 
85 percent of Gap Inc.’s direct (Scope 1 
and 2) GHG emissions and are the focus 
of our operational energy program. We 
continue to invest in energy-efficiency 
programs, and have rated all stores to 
prioritize retrofit projects and established 
protocols for new buildings. 
Our renewable energy projects, power 
purchase agreements, and onsite 
installations generated over 80,000 
megawatt hours of clean energy in 2020. 
These projects make us one of the largest 
purchasers of clean energy in the U.S. 
retail industry. 
Addressing Emissions: Scope 3
The majority of our climate impacts 
lie within our supply chain emissions, 
which are directly tied to our production. 
We work closely with our Product 
Development teams and suppliers to 
address material and facility emissions. 
In addition to implementing energy-
efficiency programming across our 
supplier base, we are also engaging 
our strategic suppliers to commit to 
emissions reduction strategies and 
explore renewable energy opportunities.
A strong part of our approach to reducing 
Scope 3 emissions is partnerships with 
industry organizations that work in our 
key supplier markets:
Apparel Impact Institute (Aii): Our 
partnership with Aii and its predecessor 
(Clean By Design) has resulted in an 
emissions reduction of 56,368 metric 
tons of carbon dioxide equivalents, 
helping support our Scope 3 SBTs. 
In 2020, Gap Inc. joined Aii’s new Carbon 
Leadership Program, through which five 
of our facilities have completed a pilot 
to understand their emissions reduction 
targets and plans. 
We also work with Aii, IDH (The 
Sustainable Trade Initiative), and CEIA 
(Clean Energy Investment Accelerator) 
alongside other brands to identify 
rooftop solar opportunities for facilities 
in Vietnam
cKinetics: We have been working with 
cKinetics to identify top mills and vendors 
to get clarity on their emissions reduction 
targets and strategies. We aim to collect 
more accurate facility-level data so that 
we can create more robust strategies to 
help our suppliers set SBTs and support 
our own goals.
Schneider Electric: We worked with 
Schneider Electric in 2021 to conduct 
renewable energy opportunity 
assessments in key supply chain markets 
to identify strategies for collaboration 
with our vendors in those regions.
Generated over
80,000
megawatt hours of 
clean energy in 2020.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
40

OUR EXTERNAL 
COMMITMENTS
We engage in advocacy with industry 
organizations to encourage policy-
makers to raise their ambitions. All 
of our work is driven by ambitious 
goals, public commitments, strong 
partnerships, and leadership from 
our purpose-led brands.
•	 Arctic Corporate Shipping Pledge: 
In 2019, we signed the Ocean 
Conservancy’s pledge and 
committed to never intentionally 
send ships through the Arctic’s 
fragile ecosystem.
•	 EPA SmartWay Partner: In 2011, 
we became a Partner of the EPA’s 
SmartWay program, which helps 
companies advance supply chain 
sustainability by measuring, 
benchmarking, and improving 
freight transportation efficiency. 
•	 Fashion Pact: This coalition of 
leading apparel and textile 
companies has established a 
common agenda to reach 100 
percent renewable energy use, 
reduce GHG emissions, increase 
biodiversity, and focus on resilient 
development by 2050. Additionally, 
our CEO Sonia Syngal was on the 
Pact’s steering committee in 2021.
•	 UNFCCC: Gap Inc. has committed to 
carbon neutrality by 2050 as part 
of the United Nations Framework 
Convention on Climate Change.
•	 UN Fashion Industry Charter for 
Climate Action: We are signatories 
to the charter, which has a vision to 
achieve net-zero emissions in the 
fashion industry by 2050.
•	 Textile Exchange: We signed on to 
a letter asking global governments 
to use trade policy to incentivize 
the fashion industry to use more 
environmentally preferred 
materials, including low-carbon 
fibers. We were also one of 50 
organizations that signed on to 
support emissions reductions 
through the sourcing of more 
sustainable materials.
•	 UNGC’s Business Ambition for 1.5oC: 
In 2021, we joined this campaign to 
ensure our current and future goals 
align to a 1.5°C scenario.
•	 National Oceanic and Atmospheric 
Administration (NOAA): We 
attended a NOAA meeting in 2021 
to discuss possible climate impacts 
on our business, from droughts 
impacting cotton to the effect of 
snowstorms on logistics. See more 
about our advocacy work in our 
Public Policy section. 
•	 We also partner on advocacy 
for climate policy in key sourcing 
markets. For instance, together 
with more than 20 other brands, 
we signed a call to the government 
of Vietnam to simplify and expand 
access to renewable energy. 
TASK FORCE ON 
CLIMATE-RELATED 
FINANCIAL 
DISCLOSURES (TCFD)
The TCFD outlines how 
companies should report on 
climate-related risks and 
mitigation strategies. 
This year we are aligning our report to 
TCFD and have outlined our governance, 
strategy, risk management, and metrics 
and targets for Gap Inc.’s climate-related 
risks. See the TCFD index at the back of 
this report for our disclosures in full; we 
also share information in our latest CDP 
Climate Change Disclosure Response and 
the ESG Oversight section of this report.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
41

RAW  
MATERIALS  
AND PRODUCT
PREFERRED FIBERS STRATEGY
Our preferred fibers strategy aims for 
resilient supply chains that have a lower 
impact on the environment and support 
social well-being. We support this work 
by developing impact measurements 
that allow better decision-making 
by our Product Development teams, 
collaborating with our supply chain 
partners, and participating in industry 
initiatives. This strategy enables our 
brands to make decisions to source more 
preferred fibers, especially cotton and 
recycled polyester. 
To identify preferred fibers, we use life 
cycle assessment data on indicators 
including global warming potential, 
water use, and eutrophication, as well 
as evaluating biodiversity, potential for 
circularity, chemistry, land-use change, 
and social conditions within production. 
To support this, we use industry tools such 
as the Sustainable Apparel Coalition’s 
Higg Materials Sustainability Index (MSI) 
and Textile Exchange’s Preferred Fiber 
and Material Matrix. 
A critical component of our work is 
collaboration with our suppliers to develop 
sustainable fabric and manufacturing 
processes. We report transparently 
via the Open Apparel Registry on all 
Tier 1 suppliers, and we have more than 
65 percent visibility into Tier 2. 
In addition, our Product Development 
teams depend on resources that allow 
them to make informed decisions 
about low-impact raw materials. These 
resources include recorded training 
sessions, regularly updated fiber 
consumption reports, an extensive 
internal Product Claims Toolkit, and a new 
calculator that enables them to estimate 
how the selection of different fibers will 
affect a product’s footprint. 
Our brands are empowered to set their 
own raw materials goals and integrate 
sustainable solutions into product 
development, where more than 80 percent 
of impact decisions are made. This has 
resulted in new 2021 product lines with more 
sustainable product attributes, including 
Gap Teen, Gap’s Generation Good, and 
the Yeezy Gap Round Jacket; Athleta’s 
featherweight stretch with recycled poly; 
Old Navy’s sugarcane-derived EVA-foam 
flip flop; and Banana Republic’s recycled 
materials travel collection with Paravel.
Find more about our approach to 
sustainable materials sourcing on 
our website.
PROTECTING BIODIVERSITY
A number of our environmental goals support our commitment 
to biodiversity. We also partner with nearly a dozen different 
coalitions that are committed to protecting nature, including 
the World Resources Institute, WWF, and Textile Exchange. 
We are committed to supporting the development of SBTs 
on nature, and looking ahead, we plan to develop a Gap Inc. 
biodiversity strategy that will help us meet them.
We are committed to selecting fibers that 
have a lower carbon footprint, use less 
water, create less waste, and support 
efforts to protect biodiversity. 
We focus on the materials that account for nearly all 
(approximately 97 percent) of our fiber consumption: 
natural fibers (cotton, linen, etc.), synthetics (polyester, 
nylon, elastane, etc.), and manufactured cellulosics  
(viscose, rayon, modal, etc.). 
97%
of our fiber 
consumption 
is from 
natural fibers, 
synthetics, and 
manufactured 
cellulosics - this 
is where we focus 
our preferred 
fibers strategy
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
42

GOALS BY 2025
100% of cotton17 sourced 
from more sustainable 
sources
At least 45% of polyester 
sourced from recycled 
sources (rPET).
Some Gap Inc. brands have higher goals.
On track 
On track 
79%
of cotton was sourced 
from more sustainable 
sources
10%
of polyester was 
sourced from recycled 
sources
17.	  Defined as: Better Cotton (formerly BCI), verified U.S.-grown cotton (USCTP), organic, in conversion (to verified organic), recycled, and regenerative.
Award at the 2022 International Exhibition of Inventions of Geneva, 
which recognizes inventions and research around the world under 
the patronage of the World Intellectual Property Organization 
(WIPO), the Swiss Government, and the City of Geneva.
We were the first brand to sign up to the new U.S. Cotton Trust 
Protocol (USCTP), in 2020, and are now leading a pilot to deploy 
USCTP’s platform for tracing products with U.S.-grown cotton 
through the supply chain. In partnership with technology provider 
TextileGenesis™, we successfully traced over 140,000 garments 
and will expand on this pilot in 2022. We also joined nine other 
brands on a panel dedicated to advancing traceability with  
Better Cotton. 
Our brands are leading the way on natural fibers. Gap has set an 
ambitious new 2030 goal to source 100% regenerative, organic, 
in conversion to organic, or recycled cotton and Banana Republic 
has partnered with Arvind Limited in a multi-year investment to 
support a farm in India that is transitioning to growing certified 
organic cotton. In 2021, Banana Republic also joined the Good 
Cashmere Standard® and Leather Working Group to source 
responsible animal-derived materials. In addition, Banana 
Republic also partners with the Responsible Wool Standard, while 
Athleta uses the Responsible Down Standard. 
Synthetics 
All our brands have committed to increasing 
their sourcing of recycled polyester to at 
least 45 percent of polyester used by 2025, 
with some brands, such as Old Navy, setting 
an even higher target. We are also an active 
member of Textile Exchange’s rPET Round 
Table and Biosynthetics Working Group, 
which help drive industry innovation on 
more sustainable fibers. We are especially 
interested in advancing opportunities 
around lower-impact nylon and elastane, 
two critical performance fibers with few 
existing alternative options. As R&D evolves 
on microfiber and microplastics shedding 
in garments, we will incorporate the latest 
insights into our preferred fiber strategies.
Manufactured Cellulosics 
We have worked closely with our fiber 
suppliers to eliminate production that 
uses wood-derived fibers from ancient, 
endangered, high conservation value, and 
high carbon stock forests. We continue 
to work with the CanopyStyle initiative to 
encourage global suppliers to set policies 
and complete audits to guarantee they are 
not sourcing from ancient and endangered 
forests in their production. We are 
also partnering with Canopy on next-
generation fiber sourcing, which prioritizes 
alternative inputs such as recycled 
textiles and waste materials. Our aim is to 
consolidate our business to only work with 
suppliers that receive Canopy’s highest 
“green shirt” ranking, which indicates they 
meet the criteria for best practices in 
protecting forests.
We will continue to explore ways to 
develop definitions and a validated 
approach to adopting regenerative 
agriculture and alternatives to fossil  
fuel-derived raw materials. Find out  
more in our 2021 SASB Index.
PROGRESS IN 2021
2021 PROGRESS
To help streamline industry approaches and expand best practices in 
raw materials sourcing, Textile Exchange made a beta version of the 
Preferred Fiber and Material Matrix (based on the Gap Inc. Preferred 
Fiber Toolkit, which we donated to Textile Exchange in 2020). 
We also piloted the SAC’s Higg Product Environmental Module to 
understand the impacts of selected products and sought to create 
robust estimates of environmental impacts where possible. As well 
as this, we developed an internal calculator for all our brands that 
uses MSI data to provide a more holistic picture of a raw material’s 
climate and water impact for baselining and goal tracking. 
Natural Fibers
To achieve our goals, we take a portfolio approach to sourcing 
materials in order to scale multiple options and develop fiber 
security. In addition, we work with industry partners to increase 
the traceability of the sustainable cotton options available to our 
brands. For example, the Hong Kong Research Institute of Textiles 
and Apparel Limited (HKRITA) is studying the desired hydroponic 
farming conditions for growing extra long staple (ELS) cotton in 
an urban environment to enable a consistent, stable, transparent 
supply of cotton in an urban environment, supporting our goals 
for fiber security and traceability. This 2021 project won the Silver 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
43

1.	 Design for Circularity
	
Our brands are leading the way on 
circularity. In 2021, Gap and Banana 
Republic launched denim lines created for 
the Ellen MacArthur Foundation (EMF) 
Jeans Redesign project. The denim 
was produced according to EMF’s three 
principles of circularity, which state 
that the jeans should be used more, 
made to be made again, and made from 
safe and recycled or renewable inputs. 
Insights from our experience designing 
for durability, recyclability, and circular 
materials were included in EMF’s Circular 
Design For Fashion book, published in 
December 2021. 
3.	Advanced Resource Recovery
	
We are on the steering committee of 
Accelerating Circularity, a collaborative 
industry project. The group uses research, 
mapping, supply chain modeling, pilot 
projects, and more to jumpstart circular 
solutions for apparel. In 2021, Banana 
Republic and Old Navy began testing 
ways to recycle fiber from the textile 
waste stream into new products. We’re 
also working with Accelerating Circularity 
to develop knowledge on textile-to-textile 
recycling, anticipating the transition to 
advanced chemical recycling techniques. 
	
We co-founded a collaborative initiative 
focused on building the circular economy 
for fashion in California that is planned to 
be launched in 2022. 
2.	Materials and Manufacturing
	
Together with the HKRITA, we are 
developing more sustainable production 
processes and technology solutions 
that enable the industry to advance 
circular models across the life cycle of 
textiles. Firstly, HKRITA is partnering with 
Artistic Milliners, one of our key suppliers, 
to develop an environmentally safe 
dissolution method to remove spandex 
from used garments. Secondly, HKRITA 
is working with Arvind Limited, another 
key supplier, to create a new method of 
removing indigo dye from cotton so that 
denim waste can be more easily reused 
or re-dyed. 
	
In 2021, we signed on to the Microfibre 
Roadmap as part of our commitment 
to The Microfibre Consortium (TMC). 
We are also contributing fiber samples 
for a research collaboration between 
TMC and the University of Leeds (U.K.) 
to improve understanding of techniques 
that reduce shedding of microplastics 
and microfibers in garment production.
4.	Circular Business Models
	
Through our partnerships with thredUP®, 
Give Back Box, and How2Recycle, we 
engage customers in reselling old clothes 
and donating clothes to people in need. 
Gap brand customers have donated 
2,616 pounds through the Give Back Box 
program since March 2021. Working with 
thredUP®, which gives used clothes a 
second life, our Gap, Athleta, and Banana 
Republic customers sent in over 80,000 
Clean Out Kits, resulting in 1.25 million 
items listed for resale in 2021.
	
Also in 2021, Athleta held two sample 
sales to reduce waste and raised more 
than $157,000 for the Gap Inc. Selvage 
Fund (see more on p. 9). Banana Republic 
Vintage launched in June 2021 as a 
platform to resell 200+ sought-after 
heritage pieces from past collections.
CIRCULARITY 
AND WASTE
We recognize that we must address the full life cycle  
of our garments, from raw materials to end of life –  
and back again.
Since defining our strategy in 2020, we 
have been working with our partners and 
brand teams on circularity initiatives and 
goals, and all our brands have embraced 
work that aligns with at least one pillar of 
the strategy. 
As part of our circularity efforts, we also 
tackle different waste streams. We continue 
to reduce, eliminate, and recycle packaging 
waste, and have signed The Fashion Pact’s 
commitment on single-use plastics.
Read more about our circularity and waste 
efforts on our website. 
Four pillars form the foundation of  
our work on circularity: 
 
1.	 Design for Circularity: Giving our 
design teams the tools to make 
choices that can positively impact 
product longevity, reuse, and 
recyclability (read about our 
sourcing approach on p. 42).
2.	 Materials and Manufacturing: 
Increasing the use of safe, 
renewable, and recycled 
materials, and supporting 
innovation in circular 
manufacturing.
3.	 Advanced Resource Recovery: 
Supporting systems for collecting, 
sorting, and recycling worn textiles 
into new materials for the fashion 
industry.
4.	 Circular Business Models: 
Decoupling profits from the use 
of natural resources, resulting in 
new value propositions for the 
customer.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
44

PACKAGING WASTE AND SINGLE-USE PLASTICS
We prioritize addressing plastic 
waste in the critical areas that 
account for 70 percent of our 
single-use plastic: hangers, 
polybags, shopping bags, and 
e-commerce mailers. 
GOALS BY 2030
Eliminate unnecessary and problematic 
plastic by 2030
Fashion Pact Commitments:
Elimination of unnecessary or problematic 
plastics in packaging to consumers by 2025, 
and in packaging to businesses by 2030
Ensure at least half of all plastic packaging 
is 100% recycled content, for packaging to 
consumers by 2025, and in packaging to 
businesses by 2030
After rolling out new polymailers that 
contain 50 percent recycled content 
(compared to 35 percent in 2020), the 
team decided to commission a life cycle 
assessment to compare the impacts and 
performance of three alternatives to our 
current mailer: paper, bio-based, and 
reusable. This will ensure a data-backed 
strategy going forward. 
In 2021, we joined The Fashion Pact’s 
cross-brand working group to help fund 
their research and development of paper-
based alternatives to polybags.
One of our biggest plastic-reduction 
initiatives has been spearheaded by Old 
Navy, which expanded its hanger-recycling 
program to 789 stores – about 65 percent 
of stores – enabling the brand to divert  
2.5 million pounds of plastic from landfill 
between June 2019 and November 2021. 
Old Navy has also removed all apparel 
hang tags, saving approximately 190 tons 
of paper, and the brand saved 105 tons  
of plastic by using recycled yarns and  
label tape instead of virgin plastic.  
In addition, the brand published a goal  
to eliminate plastic shopping bags in U.S. 
and Canadaian stores by 2023.
Needs attention
Our cross-functional task force is working to find solutions for 
these high-impact categories, and we also invest in innovative 
packaging design, product labeling, and recycling systems. 
We continue to test solutions that take into account the fact 
that only a handful of U.S. municipalities are able to recycle 
soft plastics. These include better communication with store 
employees about current recycling opportunities at their 
location, creating in-store marketing materials with recyclability 
in mind, and collaboration across our vendors to reduce the size 
of polybags shipped to stores. 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
45

GOVERNANCE
Operating as a sustainable business today 
means creating resilience for tomorrow –  
for Gap Inc., and our planet and 
communities. Good governance is at the 
center of how we evolve, keep pace, and 
push ourselves for change while always 
acting with the highest ethical values.
By ensuring that our business operates as ethically 
and transparently as possible, we can in turn enrich 
communities, enable the further empowerment of  
women, and create opportunity in the world around us. 
IN THIS SECTION 
ESG Oversight
47
Responsible Business Practices	 
49 
Stakeholder Engagement	

50
Product Life Cycle 	

51
ESG Appendix and Forward-Looking Statements	

52
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
46

ESG OVERSIGHT
As we integrate sustainability throughout our business,  
we hold ourselves accountable with our strong governance 
structure and management oversight approach. 
INTEGRATING ESG INTO OUR 
CORPORATE STRATEGY 
Our policies and sustainability frameworks 
guide as as we strive to meet the 
company's social and environmental goals.
We take a forward-looking approach 
to governance, prioritizing a structure 
that includes Board oversight facilitated 
and enabled by the Strategic Growth 
Office (SGO). Our robust management 
processes and policies are the foundation 
of a responsible, future-fit business. 
In 2021, Gap Inc. transformed our 
organizational structure to place the 
ESG team within Gap Inc.’s SGO, a unit 
of the company charged with thinking 
beyond its core business to meet the 
consumer and industry demands of the 
future. The SGO brings together Gap 
Inc.’s Strategy, Environment, Social 
& Governance, Government Affairs, 
Corporate Development, and New 
Business functions to drive sustainable 
growth aligned with the company’s mission 
and values. We have established an 
ESG steering committee of leaders from 
critical functions across our organization. 
Bringing ESG into the SGO was designed 
to maximize cross-departmental 
collaboration, a crucial part of our ESG 
team’s work. The ESG team engages a 
broad spectrum of teams across Gap 
Inc., including our brands’ Product and 
Marketing teams and our Equality & 
Belonging, Human Resources, Supply 
Chain Strategy, Government Affairs,  
Legal, and Gap Foundation teams.
OUR OVERSIGHT STRUCTURE 
At Gap Inc., good governance begins 
with a strong Board of Directors18 
that has delegated its oversight of our 
Sustainability Program to its Governance 
and Sustainability Committee, which 
comprises independent directors. The 
Governance and Sustainability Committee 
provides an independent perspective 
on our Sustainability Program in concert 
with our overarching strategic objective 
and oversees our internal ESG team’s 
management of the Program. 
Learn more on our website.
GOVERNANCE AND SUSTAINABILITY COMMITTEE OF  
GAP INC.’S BOARD OF DIRECTORS
Board of Directors 
Oversight of Gap Inc.’s ESG Program is overseen by the Governance and Sustainability 
Committee of the Board of Directors, which provides regular updates to the Board 
of Directors regarding Gap Inc.’s sustainability programs. To assist in its oversight 
responsibilities, the Governance and Sustainability Committee receives updates  
from our Chief Growth Transformation Officer.
Sally Gilligan, Chief Growth Transformation Officer 
Meets with leaders across the company from Sourcing, Production,  
Brand and Operations, and the ESG team.
18.	  As of the date of this report, Gap Inc.’s Board of Directors which comprises 12 members 10 of whom are independent under NYSE rules. Five are women, and three are people of color.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
47

Integrate into our 
business 
To ensure sustainability is a business 
imperative at Gap Inc., we have 
embedded it into our business 
strategy. Our ESG team works across 
our brands and operations.
Set ambitious 
goals 
We have set annual KPIs and long-
term goals for the company to drive 
our work forward, measure our 
progress, and ensure accountability.
Measure progress 
toward our 
commitments 
We strive to always move forward 
in creating long-term, sustainable 
progress and delivering real benefits 
to the people and communities we 
rely on for our business, which also 
helps our company succeed. Our 
approach to data and measurement 
ensures we capture this progress and 
are able to report to our stakeholders 
transparently in alignment with 
reporting frameworks such as GRI  
and SASB.
Form partnerships 
with civil society, 
governments, and 
other sectors to 
increase collective 
impact 
By partnering with organizations 
from the local to the global level, we 
fuel sustainable solutions, create 
greater equality, and scale impact 
throughout our business, across our 
industry, and beyond.
MANAGEMENT APPROACH 
To create long-term value for all our 
stakeholders and enable our business and 
society to thrive for generations to come,  
we apply the following approach to all  
our environmental and social activities:
ENTERPRISE  
RISK MANAGEMENT 
PROCESS
Internal Audit team 
conducts ERA
Risk Committee 
analyzes ERA
CEO, Board of Directors and 
Senior Leadership team 
review results to monitor and 
mitigate risks
ERA informs annual Internal 
Audit Plan and ongoing  
Board oversight
Risk Management 
Each year, management and Internal Audit work together 
to identify and assess the greatest existing and emerging 
risks that could impact the company’s operations or ability 
to achieve its objectives. 
The Risk Committee, made up of leaders that represent the 
Senior Leadership team, provides oversight of the annual 
Enterprise Risk Assessment (ERA) process:
• 	Senior executives and VPs provide input on risks and 
mitigations via an online questionnaire or an interview. 
• 	The Risk Committee reviews results, identifies any 
other key risks, and prioritizes them in the appropriate 
quadrants based on risk exposure and mitigation 
maturity.
• 	The CEO, Board of Directors, and Senior Leadership 
team use the ERA to monitor and mitigate risks, as well 
as to update policies and include in Business Continuity 
Planning where required. 
We also develop country-specific strategies that take into 
consideration local context, and we are setting up a new Risk 
Intelligence Office to focus on supply chain-related risks. 
Learn more on our website.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
48

RESPONSIBLE 
BUSINESS 
PRACTICES
At Gap Inc., integrity is woven into every aspect of our 
business. We hold ourselves to the highest standards of ethics, 
transparency, and compliance through a strong set of policies.
CODE OF BUSINESS  
CONDUCT (COBC) 
We create a culture of integrity and trust 
by Doing the Right Thing: doing business 
responsibly, ethically, and honestly. Our 
global COBC, which is published in 10 
languages, sets out the policies, values, and 
principles we expect all Gap Inc. employees 
to uphold and comply with. The Global 
Integrity team oversees our COBC program.
EMPLOYEE TRAINING
We provide all new employees with access 
to the COBC when they join, and require 
the completion of a COBC Overview 
e-learning module within 30 days of hire. 
Additional training based on location, 
level, and role is required. It includes 
specific issues such as sexual harassment, 
non-discrimination and harassment, 
wage and hour compliance, workplace 
accommodations, anti-corruption, and 
data privacy and security. Our Global 
Integrity team also conducts ad hoc 
periodic training sessions throughout  
the year.
ENABLING EMPLOYEES  
TO SPEAK UP 
We encourage our employees to report 
any suspected violations through our 
Open Door process. Employees can raise 
concerns with their manager, next-level 
manager, local human resources, our 
Global Integrity team, or our confidential 
COBC Hotline. The hotline is a telephone 
and web-based reporting system 
available 24/7 to employees and anyone 
who conducts business with Gap Inc.  
or is affected by our business.
We have investigative teams that log, 
process, and address complaints received, 
and the Global Integrity and Internal  
Audit teams conduct broad investigations 
where required. 
ANTI-CORRUPTION AND  
ANTI-BRIBERY 
We are committed to maintaining a 
compliance program that diligently 
addresses corruption risks throughout  
our global operations. 
Our companywide system monitors and 
addresses anti-corruption risks and 
enforces our internal Anti-Corruption 
and Anti-Bribery Policies. We deliver 
anti-corruption training (available to all 
employees) to specific levels and high-risk 
markets to help employees recognize and 
avoid corrupt practices. Our Legal team 
carries out a risk assessment exercise  
with corruption as a critical component. 
Learn more on our Policies website.
CODE OF VENDOR CONDUCT (COVC)
To ensure that our partners act in line with 
our standards, we require that all facilities 
that produce goods for Gap Inc. meet our 
COVC requirements and Human Rights 
Policy, which defines our approach and 
activities to protect against human  
rights abuses. 
We support, and base our policies on, 
the principles outlined in the UDHR, 
UNGC, OECD Guidelines for Multinational 
Enterprises, and the ILO’s Core Conventions. 
The COVC also sets out our basic 
expectations for environmental standards 
to all Tier 1 vendors and suppliers with 
whom Gap Inc. conducts business. We 
expect all facilities to comply with relevant 
environmental laws and regulations, 
manage their energy use and water 
impacts, and complete the Higg Index 
Facility Environmental Module annually. 
DATA PRIVACY
As a global brand built on the foundation 
of customer trust, we respect the privacy 
rights of our customers. We follow 
seven principles in our approach to data 
use, new technologies, and services: 
consent, control, fairness, minimization, 
confidentiality, access, and accountability. 
Our Privacy Policy adheres to laws across 
the jurisdictions where we do business. 
While these rights may vary, we make 
reasonable efforts to honor requests even if 
a country or jurisdiction does not require us 
to do so. Our privacy policies have received 
accolades for their clarity and simplicity. 
We also know that security is at the center 
of any good privacy program. We use 
widely accepted security standards and 
practices to guide our decisions around 
securing personal information. 
Learn more on our Privacy Policy website.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
49

STAKEHOLDER 
ENGAGEMENT
Talking to stakeholders and establishing partnerships with 
expert organizations at both global and local levels is critical  
to our ESG strategy – as is maximizing our positive impact 
through our programs. 
We regularly partner with a broad set 
of stakeholders to better understand 
the complex issues that affect them, our 
industry landscape, and society. This 
dialogue helps us improve our strategies, 
set goals, focus our action, and scale up 
industry solutions.
Find more about our initiatives and 
partner organizations on our website. 
To capture feedback, respond accordingly, 
and drive improvements across our 
business, we use several methods for 
stakeholder engagement, including:
HUMAN RIGHTS ENGAGEMENT  
IN OUR SUPPLY CHAIN
Our Supplier Sustainability and Human 
Rights and Labor teams are responsible 
for managing and implementing our 
human rights and labor stakeholder 
engagement strategy.
Supplier Relationships 
We regularly engage with our suppliers to 
advocate for human rights and drive better 
practices. To enable a clear understanding 
of our Human Rights Policy, practices, and 
grievance channels, we provide all relevant 
information in local languages through an 
online platform and offer in-person and 
virtual support wherever needed.
COMMUNICATING WITH WORKERS
We routinely engage with workers in 
our Tier 1 supply chain through our 
assessments, including formal interviews, 
and through the informal relationships 
that our teams have created with worker 
representatives. We also encourage the 
people who work in our supply chain to 
share their thoughts and experiences, 
and we use digital technology to make 
the feedback process as easy as possible. 
These regular check-ins enable us to learn 
about specific human rights issues or to 
mitigate any risks proactively.
In addition, we interview workers as we 
develop and improve our programs focused 
on workers’ rights and empowering women.
LEARN MORE
> Human Rights 
> Empower@Work
PUBLIC POLICY INVOLVEMENT 
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 enable Gap 
Inc.’s strategies through public policy 
and government advocacy. 
We also participate in political 
activities and advocate for legislation 
when there is a connection to our 
business and our ability to grow the 
business in a way that is consistent 
with our values, our legal obligations, 
and our Codes of Business Conduct 
and Vendor Conduct. For example, 
Gap Inc. CEO Mark Breitbard met 
Vice President Kamala Harris at 
the White House in 2021 to discuss 
policies to boost the care economy 
and its impact on workers in the post-
pandemic environment.  
Additionally, in the past we have been 
active in policy discussions and have 
lobbied on issues related to trade, 
tax policy, ports/infrastructure, and 
environmental issues. Gap Inc. only 
takes positions on ballot measures, 
initiatives, or propositions that have a 
direct impact on our business.
READ MORE
> Climate advocacy work in partnership 
with NOAA
> Gap Inc.’s Political Contributions 
disclosure in our appendix
> Public Engagement Policy
1.	Convening industry and stakeholder 
partners on systemic issues that 
require collaboration.
2.	Implementing formal and 
informal consultations with expert 
organizations on material issues.
3.	Contributing our voice to ESG-related 
policy issues through government 
engagement.
Find more about our approach  
to stakeholder engagement on  
our website.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
50

1 
  D
ES
IG
N 
AN
D
DE
VE
LO
P
M
EN
T
2 
  R
A
W 
M
AT
ER
IA
LS
A
N
D 
PR
O
CE
SS
IN
G
M
AN
UF
AC
TU
RI
NG
3 
  T
EX
TI
LE
AN
D 
FI
NI
SH
IN
G
4 
  
PR
O
D
U
CT
AN
D 
DI
ST
RI
BU
TI
ON
5 
  
LO
GI
ST
IC
S
6 
  R
ET
AI
L
ST
O
RE
S
7 
  C
ON
SU
ME
R 
US
E
A
N
D 
CI
RC
UL
A
RI
TY
 
DESIGN AND DEVELOPMENT
Our Product Development teams are 
trained to design and manufacture more 
sustainable products, and have significant 
influence over who makes our clothes. 
This enables us to address our wider 
environmental footprint and improve working 
conditions in facilities. See more about our 
assessment, water, chemicals management, 
materials, and circularity practices in our 
Enriching Communities and Empowering 
Women & Human Rights sections.  
1
RAW MATERIALS AND 
PROCESSING (TIER 3 SUPPLIERS)
To minimize the impacts of the fibers 
we use in our products, we place a 
special focus on cotton, and we are also 
taking steps to source more sustainable 
synthetic and manufactured cellulosic 
fibers. See more about our water and 
climate practices in our Enriching 
Communities section. 
2
TEXTILE MANUFACTURING  
(TIER 2 SUPPLIERS) 
Fabric mills use large quantities of  
energy and water, as well as chemicals 
that may impact local watersheds if 
not treated properly. Through our Mill 
Sustainability Program, we integrate 
clear environmental standards into our 
sourcing decisions. See more about our 
assessment, P.A.C.E., water, chemical, 
and climate practices in our Enriching 
Communities and Empowering Women & 
Human Rights sections. 
3
PRODUCT AND FINISHING  
(TIER 1 SUPPLIERS)
Our comprehensive approach for 
improving working conditions in our supply 
chain combines facility-monitoring and 
capability-building programs that engage 
our vendors to measure and address their 
environmental and social impacts. See 
more about our assessment, capability 
building, P.A.C.E., water, chemical, and 
climate practices in our Enriching 
Communities and Empowering Women & 
Human Rights sections. 
4
LOGISTICS AND DISTRIBUTION
We use an optimal mix of 
transportation methods via sea, air, truck, 
and rail to move products from suppliers 
to our distribution centers, and then to 
stores and customers. We are working to 
conserve energy and reduce waste at our 
distribution centers, the largest facilities 
we own and operate. See more about our 
circularity and climate practices in our 
Enriching Communities section. 
5
CONSUMER USE AND CIRCULARITY
We use product labeling, catalogs, 
social media, and blog posts to educate 
our customers on how they can wear,  
care for, and discard their clothes to 
reduce our products’ total environmental 
footprint. We also engage in and 
contribute to industrywide solutions to 
reduce end-of-life impacts. See more 
about our circularity in our Enriching 
Communities section. 
7
PRODUCT 
LIFE CYCLE
RETAIL STORES
We are working to reduce our 
environmental impact at our company-
operated stores. We also run This Way 
ONward at our Old Navy stores, helping 
young people experiencing barriers to 
employment obtain their first jobs. See 
more about Equality & Belonging,  
This Way ONward, climate, circularity, and 
materials in our Enriching Communities 
and Enabling Opportunities sections. 
6
Through product design, we seek  
to reduce our environmental footprint 
and improve the human impact of our 
business at every stage of a product’s 
life – from the very first design 
concepts through materials  
sourcing, manufacture, and  
distribution to sale, use,  
and end of life.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
51

ESG APPENDIX AND FORWARD-
LOOKING STATEMENTS
MATERIALITY 
In a rapidly changing world, we want to 
address issues where Gap Inc. can have 
the greatest impact and influence. 
We prioritize the sustainability issues 
that matter most to our stakeholders and 
business. These are our material issues 
and they guide our ESG team’s strategy 
and programs. 
We carried out our most recent materiality 
analysis in 2021 with a third-party 
expert consultancy. 
For clarity, the identification of our material 
issues that guide our sustainability strategy 
and programs should not be construed as a 
characterization regarding the materiality 
or financial impact of such issues or related 
information to investors in Gap Inc. For a 
discussion of the risks that are material to 
investors in Gap Inc., please see our Annual 
Report on Form 10-K for the year ended 
January 29, 2022 filed with the Securities 
and Exchange Commission, our subsequent 
Quarterly Reports on Form 10-Q, and our 
Current Reports on Form 8-K. 
LEARN MORE 
> 2021 Materiality Matrix 
> SEC Filings
ESG FRAMEWORKS
Global Reporting Initiative (GRI) 
We have prepared this report in 
accordance with the GRI Standards.
LEARN MORE 
> GRI Index
Sustainability Accounting Standards 
Board (SASB) 
Our SASB Index references the Standard 
for the Apparel, Accessories & Footwear 
industry as defined by SASB’s Sustainable 
Industry Classification System – 
E-Commerce, Multiline and Specialty 
Retailers & Distributors, and Apparel, 
Accessories and Footwear, with the location 
of that information in Gap Inc.’s ESG Report 
and our website. 
LEARN MORE 
> SASB Index
Task Force on Climate-Related Financial 
Disclosures (TCFD) 
The TCFD is a framework of 
recommendations for companies to 
make more effective climate-related 
disclosures that could promote more 
informed investment, credit, and insurance 
underwriting decisions. We are reporting to 
the TCFD for the first time this year, and our 
TCFD Index, detailing our climate-related 
risk disclosures, can be found on p. 72. 
LEARN MORE 
> TCFD Index 
TOPIC
LINK
Board and Shareholder Rights
> Gap Inc. Governance
ESG Disclosures
> ESG Resources
Enterprise Risk Management and Compliance
> Managing Risks
> SEC Filings
> Corporate Compliance Policies
> ESG Resources
Privacy and Information Security
> Gap Inc. Privacy Policy
Learn More
CAUTIONARY NOTE ON FORWARD-LOOKING STATEMENTS
This report and related comments by 
management may include “forward-
looking statements” within the meaning of 
the U.S. federal securities laws. Forward-
looking statements are any statements 
other than statements of historical fact. 
Forward-looking statements represent 
our current judgment about possible 
future events and are often identified 
by words such as “anticipate,” “appears,” 
“approximately,” “believe,” “continue,” 
“could,” “designed,” “effect,” “estimate,” 
“evaluate,” “expect,” “forecast,” “goal,” 
“initiative,” “intend,” “may,” “objective,” 
“outlook,” “plan,” “potential,” “priorities,” 
“project,” “pursue,” “seek,” “should,” 
“target,” “when,” “will,” “would,” or the 
negative of any of those words or  
similar expressions.
In making these statements, we rely upon 
assumptions and analysis based on our 
experience and perception of historical 
trends, current conditions, and expected 
future developments, as well as other 
factors we consider appropriate under 
the circumstances. We believe these 
judgments are reasonable, but these 
statements are not guarantees of any 
future events or financial results, and 
our actual results may differ materially 
due to a variety of factors, many of which 
are described in our most recent Annual 
Report on Form 10-K and our other filings 
with the U.S. Securities and Exchange 
Commission. We caution readers not to 
place undue reliance on forward-looking 
statements. Forward-looking statements 
speak only as of the date they are made, 
and we undertake no obligation to update 
publicly or otherwise revise any forward-
looking statements, whether as a result 
of new information, future events, or 
other factors that affect the subject of 
these statements, except where we are 
expressly required to do so by law.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
52

GAP INC. 2021 GRI INDEX –  
2016 UNIVERSAL STANDARDS
We sought to prepare the report in reference with the Global Reporting Initiative (GRI) Standards. Note: ESG Report refers to Gap Inc.’s 2021 ESG Report; 
Sustainability Webpages refer to our Global Website, which hosts our Environment, Social, and Governance (ESG) Hub and Equality & Belonging Report; 
Annual Report refers to Gap Inc.’s Annual Report on Form 10-K for the fiscal year ended January 29, 2022; and Proxy Statement refers to the Notice of 
Annual Meeting of Gap Inc. Shareholders 2021 and 2022 Proxy Statements. Please find more information on our Investor Relations Webpages.
GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
GENERAL DISCLOSURES
Organization Profile
102-1
Name of the Organization
Annual Report
Part I, Item 1. Business
1
102-2
Description of the organization’s activities; primary brands, 
products, and services, including an explanation of any products  
or services that are banned in certain markets
Annual Report
Part I, Item 1. Business
1
102-3
Location of organization’s headquarters
Annual Report
Part I, Item 2. Properties
23
102-4
Location of operations: Number of countries where the 
organization operates, and names of countries where it has 
significant operations and/or that are relevant to the topics 
covered in the report
Annual Report
Part I, Item 2. Properties
23
102-5
Nature of ownership and legal form
Annual Report
Part II, Item 5. Market for Registrant’s Common Equity, Related 
Stockholder Matters and Issuer Purchases of Equity Securities
24
102-6
Markets served, including geographic breakdown, sectors  
served, and types of customers/beneficiaries
Annual Report
Part I, Item 1. Business, and Item 2. Properties
1, 23
102-7
Scale of the reporting organization
Annual Report
Part I, Item 1. Business, and Part II, Item 7. Management’s Discussion 
and Analysis of Financial Condition and Results of Operations
1, 26
102-8
Information on employees and other workers
Annual Report 
Sustainability 
Webpages
Part I, Item 1. Business
Measuring Our Progress: Employees
What We’re Made Of
1
102-9
Describe the organization’s supply chain
ESG Report
Governance: Product Life Cycle
51
102-10
Significant changes regarding the organization’s size, structure, 
ownership, or its supply chain
ESG Report
Governance: ESG Oversight 
47
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
53

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
102-11
Whether and how the organization applies the precautionary 
approach or principle
Sustainability 
Webpages
Gap Inc. applies the precautionary principle to its use of chemicals 
through testing of its products and its commitment to the 
elimination of PFC-based finishes. For more information, please see 
Chemicals Management and Responsible Business Practices.
102-12
List externally developed economic, environmental, and social 
charters, principles, or other initiatives to which the organization 
subscribes or endorses
Sustainability 
Webpages
ESG Resources 
Memberships and Partner Organizations. We support and base 
our policies on the principles outlined in the Universal Declaration of 
Human Rights (UDHR), the UN Global Compact (UNGC), the OECD 
Guidelines for Multinational Enterprises and the International 
Labour Organization’s (ILO) Core Conventions.
102-13
Memberships in industry or other associations, and national or 
international advocacy organizations
Sustainability 
Webpages
Memberships and Partner Organizations
Strategy
102-14
Statement from the most senior decision-maker of the organization
ESG Report
The Big Picture: Our Commitment to Environmental, Social, and 
Governance (ESG)
The Big Picture: Our Approach
4
6
102-15
Description of key impacts, risks, and opportunities
ESG Report
Sustainability 
Webpages
Governance: ESG Appendix and Forward-Looking Statements 
Responsible Business Practices
Materiality
CDP Climate Disclosure 2021 (C2.2a, C2.3a C2.4a)
52
Ethics and Integrity
102-16
Describe the organization´s values, principles, standards and 
norms of behavior
ESG Report
Sustainability 
Webpages
Governance: Responsible Business Practices
Responsible Business Practices
49
Governance
102-18
Report the governance structure of the organization, including 
committees of the highest governance body and committees 
responsible for decision-making on economic, environmental and 
social impacts
ESG Report
Investor Relations 
Webpages
Governance: ESG Oversight
Corporate Governance Fact Sheet 
Committee Composition
47
102-21
Report the processes for consultation between stakeholders and 
the highest governance body on economic, environmental, and 
social topics
ESG Report
Sustainability 
Webpages
Governance: Stakeholder Engagement
Responsible Business Practices
50
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
54

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
102-26
Report the highest governance body’s and senior executives’ roles 
in the development, approval, and updating of the organization’s 
purpose, value or mission statements, strategies, policies, and 
goals related to economic, environmental, and social topics
Sustainability 
Webpages
Investor Relations 
Webpages
Management Approach 
 
Corporate Governance Guidelines
102-29
Report the highest governance body’s role in identifying and 
managing economic, environmental, and social topics and 
their impacts, risks, and opportunities – including its role in the 
implementation of due diligence processes
Report whether stakeholder consultation is used to support the 
highest governance body’s identification and management of 
economic, environmental, and social topics and their impacts, risks, 
and opportunities
ESG Report
Sustainability 
Webpages
Governance: Risk Management
Governance: ESG Oversight
Responsible Business Practices
Management Approach 
48
47
102-30
Report the highest governance body’s role in reviewing the 
effectiveness of the organization’s risk management processes  
for economic, environmental, and social topics
ESG Report
Sustainability 
Webpages
Governance: Risk Management
Responsible Business Practices
48
102-32
The highest committee or position that formally reviews and 
approves the organization’s sustainability report and ensures  
that all material topics are covered
ESG Report
Governance: ESG Oversight
47
102-33
Process for communicating critical concerns to the highest 
governance body
ESG Report
Governance: ESG Oversight
47
102-38
Annual total compensation ratio
Proxy Statement
2021 CEO Pay Ratio
75
Stakeholder Engagement
102-40
List of stakeholder groups engaged by the organization
ESG Report
Sustainability 
Webpages
Governance: Stakeholder Engagement
Memberships and Partner Organizations
50
102-42
Basis for identification and selection of stakeholders with  
whom to engage
ESG Report
Governance: Stakeholder Engagement
50
102-43
Approaches to stakeholder engagement, including frequency  
of engagement by type and by stakeholder group
ESG Report
Sustainability 
Webpages
Governance: Stakeholder Engagement
Responsible Business Practices
50
102-44
Key topics and concerns that have been raised through stakeholder 
engagement, and how the organization has responded to those key 
topics and concerns, including through its reporting
ESG Report
Sustainability 
Webpages
Governance: Stakeholder Engagement
Governance: ESG Appendix and Forward-Looking Statements 
Materiality
50
52
102-45
List all entities included in the organization´s consolidated financial 
statement; report whether any entity is not covered in the report
Annual Report
Part I, Item 1. Business
Exhibit 21 'Subsidiaries of Registrant'
1
102-46
Process for defining report content and topic boundaries; explain 
how the organization has implemented the Reporting Principles  
for defining report content 
ESG Report
The Big Picture: About This Report
3
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
55

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
102-47
List the material topics identified in the process for defining report 
content
ESG Report
Sustainability 
Webpages
Governance: ESG Appendix and Forward-Looking Statements 
Materiality
52
102-48
The effect of any restatements of information given in the previous 
reports, and the reasons for such restatements
N/A
There are no restatements from the previous report.
102-49
Significant changes from previous reporting periods in the list of 
material topics and topic Boundaries
ESG Report
Governance: ESG Appendix and Forward-Looking Statements 
52
102-50
Reporting period for information provided
ESG Report
The Big Picture: About This Report
3
102-51
Date of most recent previous report
ESG Report
The Big Picture: About This Report
3
102-52
Reporting cycle (annual, biennial, etc.)
ESG Report
The Big Picture: About This Report
3
102-53
Contact point for questions regarding the report or its contents
ESG Report
The Big Picture: About This Report
3
102-55
The GRI content index
Sustainability 
Webpages
GRI Content Index
ECONOMIC
Economic Performance
103-1
103-2
103-3
Management and approach
Annual Report
Part II, Item 7. Management’s Discussion and Analysis of Financial
Condition and Results of Operations
Part II, Item 7A. Quantitative and Qualitative Disclosures About 
Market Risk
26
40
201-1
Direct economic value generated and distributed 
Annual Report
Part II, Item 7. Management’s Discussion and Analysis of Financial
Condition and Results of Operations
40
201-2
Financial implications and other risks and opportunities due to 
climate change
Sustainability 
Webpages
CDP Climate Disclosure 2021 (C2.1b, C2.2, C2.2a, C2.3, C2.3a, 
C2.4, C2.4a, C3.1, C3.4)
CDP Water Security Disclosure 2021 (W3.3b, W3.3c, W3.3d, W4.1, 
W4.1a, W4.2b, W4.2c, W4.3, W4.3a)
Aspect: Market Presence
103-1
103-2
103-3
Management and approach
Sustainability 
Webpages
Perks & Benefits
Management Approach 
Aspect: Indirect Economic Impacts
103-1
103-2
103-3
Management and approach
Sustainability 
Webpages
ESG Report
Materiality
Enabling Opportunity: Employees and Community Impact
Gap Inc. performs an assessment for the This Way ONward 
program biennally, so please refer to the 2020 Global 
Sustainability Report p. 25 for program participant percentage 
increase in skills/knowledge. 
32
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
56

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
203-2
Significant indirect economic impacts, including the extent of 
impacts
ESG Report
Empowering Women: Gap Inc. P.A.C.E.
Enabling Opportunity: This Way ONward
16
27
Procurement Practices
103-1
103-2
103-3
Management and approach
Sustainability 
Webpages
Materiality
Purchasing Practices
Anti-Corruption
103-1 
103-2
103-3
Management and approach
Sustainability 
Webpages
ESG Report
Responsible Business Practices
 
Governance: Responsible Business Practices
To evaluate the effectiveness of Gap Inc.’s anti-corruption program, 
questions related to anti-corruption/anti-bribery are featured in 
Gap Inc.’s Code of Business Conduct (COBC) Assessments. COBC 
Assessments are conducted each year, with different markets/
functions identified to assess. The objective of the COBC Assessments 
is to gain an understanding of the impact of the COBC program.  
 
49
205-1
Operations assessed for risks related to corruption
We conduct Anti-Corruption Due Diligence (ACDD) in high-risk 
markets. Within these markets, our policy requires that any third 
party that interacts with government officials on behalf of Gap Inc., 
and/or third-party distributors, have an ACDD report.
205-2
Communication and training about anti-corruption policies  
and procedures
Sustainability 
Webpages
ESG Report
Responsible Business Practices
 
Governance: Responsible Business Practices
Gap Inc. has two internal-facing anti-corruption policies: 1) a global 
policy, and 2) a China Retail policy (high-risk market). Gap Inc. 
also has an anti-corruption training program, delivered to global 
directors and above, managers and above in high-risk functions, 
and all levels of HQ in high-risk markets (China, Mexico, and Italy). 
There is a separate course for the China employees, with content 
specific to the risks in China. This course is delivered at hire or 
promotion into role, and is required annually in high-risk markets 
and every two years globally. At times, Gap Inc. also delivers ad hoc 
anti-corruption training when there is opportunity (e.g. when we are 
traveling in market).
Anti-corruption training is available to 100 percent  of employees at  
Gap Inc.
 
49
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
57

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
ENVIRONMENTAL
Materials
103 -1
103-2
103-3
Management and approach 
Sustainability 
Webpages
ESG Report 
Raw Materials and Product
Enriching Communities: Sustainable Materials Sourcing 
42
301-1
Materials used by weight or volume
2019
2020
2021
Natural fibers
Percentage of cotton: 
more sustainable 
cotton* 
60
54
79
Percentage of wool: 
recycled wool
16
11
14
Synthetics
Percentage of nylon: 
recycled nylon
7
10
10
Percentage of 
polyester: recycled 
polyester
1
6
10
Manufactured 
cellulosics
Percentage of 
cellulosics: more 
sustainable viscose, 
modal, lyocell, 
TENCEL™, lenzing
8
9
13
301-2
Recycled input materials used
Gap Inc. Sustainable Fiber Sourcing: Synthetics
2019
2020
2021
Recycled nylon
7%
10%
10%
Recycled polyester
1%
6%
10%
301-3
Reclaimed products and their packaging materials
ESG Report       
Sustainability 
Webpages                        
Enriching Communities: Circularity and Waste
Circularity and Waste
44
Energy
103-1
103-2
103-3
Management and approach
Sustainability 
Webpages
ESG Report 
Climate
CDP Climate Disclosure 2021 (C1.3a, C2.2, C2.2a, C2.3a, C2.4a, 
C3.2b, C3.3, C3.4, C4.3c)
Enriching Communities: Climate Stewardship 
 
39
302-1
Energy consumption within the organization
Sustainability 
Webpages
Measuring Our Progress: Environment
302-2
Energy consumption outside of the organization
Sustainability 
Webpages
Measuring Our Progress: Environment
*Defined as: Better Cotton (formerly BCI), verified US-grown cotton (USCTP), organic, in-conversion (to verified organic), recycled and regenerative.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
58

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
302-3
Energy intensity
Sustainability 
Webpages
Measuring Our Progress: Environment
302-4
Reduction of energy consumption
Sustainability 
Webpages
Measuring Our Progress: Environment
Aspect: Water
303-2
Water sources significantly affected by withdrawal of water
Sustainability 
Webpages
Water Stewardship 
CDP Water Security Disclosure 2021 (W3.3b, W3.3d)
303-5
Water consumption
Water Consumption from Supply Chain Facilities (does not 
include company-operated locations such as stores, offices,  
or distribution centers)
WWF (overall risk) ** 
Sum of Gap - Total Water 
(FEM2020) (in cubic meters)
x<2.5
620,371 (2%)
2.5<=x<3.5
19,428,941 (75%)
3.5<=x<4.5
4,829,301 (19%)
New facility included on Higg  
(yet to conduct risk assessment)
1,020,027 (4%) - no data for 
most of the new facilities
Grand total
25,898,640 
**We consider High Risk to be above 3.5, which includes sourcing 
countries: China, Egypt, India, Jordan, and Pakistan.
Emissions
103 -1
103-2
103-3
Management and approach 
Sustainability 
Webpages
 
ESG Report 
Climate
CDP Climate Disclosure 2021 (C1.3a, C2.2, C2.2a, C2.3a, C2.4a, 
C3.2b, C3.3, C3.4, C4.3c)
Enriching Communities: Climate Stewardship 
 
39
305-1
Direct (Scope 1) GHG emissions
Sustainability 
Webpages
Scope 1 and 2 emissions data for fiscal 2021 will be available on 
our website in 2022. Our GHG data for previous years is currently 
available at the ESG Resources.
305-2
Energy indirect (Scope 2) greenhouse gas emissions
Sustainability 
Webpages
Scope 1 and 2 emissions data for fiscal 2021 will be available on 
our website in 2022. Our GHG data for previous years is currently 
available at the ESG Resources.
305-3
Other indirect (Scope 3) greenhouse gas emissions
Sustainability 
Webpages
Scope 3 emissions data for fiscal 2020 will be available on our 
website in 2022 at the ESG Resources.
305-4
GHG emissions intensity
Sustainability 
Webpages
Measuring Our Progress: Environment
305-5
Reduction of GHG emissions
Sustainability 
Webpages
CDP Climate Disclosure 2021 (C2.4a, C4.1a, C4.2a, C4.3a, C4.3b)
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
59

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
Waste
103 -1
103-2
103-3
Management and approach 
Sustainability 
Webpages
ESG Report 
Circularity and Waste
Enriching Communities: Circularity and Waste
44
306-2
Management of significant waste-related impacts
ESG Report
Enriching Communities: Circularity and Waste
44
306-3
Waste generated
ESG Report
Enriching Communities: Circularity and Waste
Gap Inc. is currently developing a data collection strategy for 
our waste management with the help of our waste management 
partner and Distribution Center Operations team, which will detail 
our waste generated data. 
44
306-4
Waste diverted from disposal
ESG Report
Enriching Communities: Circularity and Waste
Gap Inc. is currently developing a data collection strategy for 
our waste management with the help of our waste management 
partner and Distribution Center Operations team, which will detail 
our waste diverted from disposal data.
44
306-5
Waste directed to disposal
ESG Report
Gap Inc. is currently developing a data collection strategy for 
our waste management with the help of our waste management 
partner and Distribution Center Operations team, which will detail 
our waste directed to disposal data.
Supplier Environmental Assessment
103 -1
103-2
103-3
Management and approach 
Sustainability 
Webpages
ESG Report 
Management Approach
Assessment and Remediation 
Empowering Women: Human Rights and Social Dialogue
19
308-1
New suppliers that were screened using environmental criteria
Sustainability 
Webpages
SASB Reference Table (CG-AA-430a.2)
Assessment and Remediation
308-2
Negative environmental impacts in the supply chain and  
actions taken 
Sustainability 
Webpages
ESG Report 
Water Stewardship
Chemicals Management
Empowering Women: Assessment and Remediation 
20
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
60

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
SOCIAL
Employment
103-1
103-2
103-3
Management and approach
Sustainability 
Webpages
ESG Report 
Talent Development 
Enabling Opportunity: Talent Development 
29
401-1
New employee hires and employee turnover
Proxy Statement
Proxy Statement 2022 
401-2
Benefits provided to full-time employees that are not provided to 
temporary or part-time employees
Sustainability 
Webpages
Talent Development
Measuring Our Progress: Employees
401-3
Parental leave
Sustainability 
Webpages
Talent Development
Occupational Health and Safety
103-1
103-2
103-3
Management and approach
Sustainability 
Webpages
Talent Development
Training and Education
103-1
103-2
103-3
Management and approach
Sustainability 
Webpages 
ESG Report 
Talent Development
This Way ONward
Enabling Opportunity: Talent Development
Enabling Opportunity: This Way ONward
29
27
404-3
Percentage of employees receiving regular performance and 
career development reviews
Sustainability 
Webpages
2021 Equality & 
Belonging Report
Talent Development 
Measuring Our Progress: Employees
Please see Gap Inc.’s 2021 Equality & Belonging Report, which  
will be made available later in 2022.
Aspect: Diversity & Equal Opportunity
103-1
103-2
103-3
Management and approach
Sustainability 
Webpages
2021 Equality & 
Belonging Report
ESG Report
Equality & Belonging 
Please see Gap Inc.’s 2021 Equality & Belonging Report, which  
will be made available later in 2022. 
Enabling Opportunity: Equality & Belonging 
31
405-1
Diversity of governance bodies and employees
Proxy Statement
Sustainability 
Webpages
2021 Equality & 
Belonging Report
2022 Key Director Attributes
Measuring Our Progress: Employees
What We’re Made Of
Please see Gap Inc.’s 2021 Equality & Belonging Report, which  
will be made available later in 2022. 
10
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
61

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
405-2
Ratio of basic salary and remuneration of women to men
Sustainability 
Webpages
ESG Report
Gender Equality & Empowerment
Enabling Opportunity: Talent Development
29
Non-discrimination 
103-1
103-2
103-3
Management and approach
Sustainability 
Webpages
Discrimination and Harassment
406-1 
Total number of incidents of discrimination and corrective  
actions taken
Sustainability 
Webpages 
 
 
ESG Report 
Discrimination and Harassment
Assessment and Remediation
Supplier Capability Building Programs
Empowering Women: Human Rights and Social Dialogue
19
Aspect: Freedom of Association and Collective Bargaining 
407-1
Operations and suppliers in which workers’ rights to exercise 
freedom of association or collective bargaining may be violated  
or at significant risk
Sustainability 
Webpages
Freedom of Association
Policies and Approaches for Human Rights
Child Labor
103-1
103-2
103-3
Management and approach 
Sustainability 
Webpages 
 
 
ESG Report 
Assessment and Remediation
Child Labor and Young Workers
Policies and Approaches for Human Rights 
Empowering Women: Human Rights and Social Dialogue
19
408-1
Operations and suppliers at significant risk for incidents of  
child labor
Sustainability 
Webpages
Child Labor and Young Workers
Assessment and Remediation
Forced or Compulsory Labor
103-1
103-2
103-3
Management and approach 
Sustainability 
Webpages
ESG Report 
Assessment and Remediation
Human Trafficking and Forced Labor
Policies and Approaches for Human Rights 
California Transparency In Supply Chains Act & UK Modern 
Slavery Act Statement
Empowering Women: Human Rights and Social Dialogue
 
19
409-1
Operations and suppliers identified as having significant risk for 
incidents of forced or compulsory labor
Sustainability 
Webpages
Human Trafficking and Forced Labor
Assessment and Remediation
COVC Issues at Assessed Factories
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
62

GRI Indicator
Description
Disclosure Source
Section(s)
Page(s)
Human Rights Assessments
103-1
103-2
103-3
Management and approach 
Sustainability 
Webpages
ESG Report 
Assessment and Remediation
Policies and Approaches for Human Rights 
Empowering Women: Human Rights and Social Dialogue
19
Local Communities
103-1
103-2
103-3
Management and approach 
Sustainability 
Webpages
ESG Report 
Employees and Community Impact
P.A.C.E. and Empower@Work
Enabling Opportunity: Employees and Community Impact
32
413-1
Percentage of operations with implemented local community 
engagement, impact assessments and/or development programs
Sustainability 
Webpages
Measuring Our Progress: Community
Supplier Social Assessments
103-1
103-2
103-3
Management and approach 
Sustainability 
Webpages
ESG Report 
Assessment and Remediation
Policies and Approaches for Human Rights 
Empowering Women: Human Rights and Social Dialogue
19
414-1
Percentage of new suppliers that were screened using human 
rights criteria
Sustainability 
Webpages
SASB Reference Table (CG-AA-430b.1)
Assessment and Remediation
Gap Inc. screens 100 percent of new suppliers using human rights 
criteria. Learn more about our process on the above sustainability 
webpages.
414-2
Negative social impacts in the supply chain and actions taken
Sustainability 
Webpages
ESG Report 
Assessment and Remediation
COVC Issues at Assessed Factories
Empowering Women: Human Rights and Social Dialogue
19
Public Policy
103-1
103-2
103-3
Management and approach 
Sustainability 
Webpages
Political Engagement Policy
415-1
Political contributions
Sustainability 
Webpages
Political Engagement Policy
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
63

SUSTAINABILITY ACCOUNTING 
STANDARDS BOARD (SASB) INDEX 
The Value Reporting Foundation is an independent, private-sector standards-setting organization dedicated to enhancing 
the efficiency of capital markets by fostering high-quality disclosure of material sustainability information that meets investor 
needs. This table references the Standard for the Apparel, Accessories & Footwear industry, and select relevant disclosures 
from the E-Commerce and Multiline and Specialty Retailers & Distributors industries, as defined by SASB’s Sustainable Industry 
Classification System (SICS), with the location of that information in Gap Inc.’s 2021 ESG Report and our website.
Topic
Accounting Metric
Category
Unit of 
Measure
Code
Data
Reference
Apparel, Accessories & Footwear 
Management 
of Chemicals in 
Product
Description of 
processes to maintain 
compliance with 
restricted substances 
regulations
Discussion 
and Analysis
N/A
CG-AA-250a.1
Gap Inc. chemical restrictions are informed by global regulations, as well 
as hazard- and risk-based considerations. They include our Restricted 
Substances List (RSL) and our Manufacturing Restricted Substances List 
(MRSL). Since 2008, Gap Inc. suppliers have been expected to comply with 
our RSL. Since 2015, we have asked all of our suppliers to comply with the Zero 
Discharge of Hazardous Chemicals (ZDHC) MRSL, and we are aligned with the 
AFIRM Group RSL.
1. 		Industry partnerships and standards: We partner with industry groups, 
including the Apparel and Footwear International RSL Management 
(AFIRM) Group and the Sustainable Apparel Coalition (SAC) to implement 
a consistent set of tools and processes to support best practices, monitor 
supplier performance, and encourage use of safer chemicals. 
2. 	Supplier engagement: We communicate chemical safety and usage 
requirements to our suppliers in our Code of Vendor Conduct (COVC) and 
Mill Minimum Expectations, and we require our suppliers to acknowledge 
and comply with these conditions. 
3. 	Compliance and monitoring: Through third-party testing of products, 
product components and wastewater effluent, as well as the use of industry 
data platforms, we monitor the performance of our supply chain and 
verify compliance with global chemical regulations and Gap Inc. chemical 
restrictions.
Gap Inc. aligns with the AFIRM Group RSL. To learn more about this process, 
please see the Chemicals Management page. 
ESG Report: Chemicals 
Management p. 38
Sustainability 
Webpages: Chemicals 
Management
Discussion of 
processes to assess 
and manage risks and/
or hazards associated 
with chemicals in 
products
Discussion 
and Analysis
N/A
CG-AA-250a.2
Gap Inc. uses the following processes to assess and manage potential risks and 
hazards associated with their product materials and chemicals.
Input Management: The selection of better chemical inputs and starting materials 
is an essential part of reducing the use and discharge of hazardous chemicals.
Process Management: Adherence to chemicals management best practices 
during manufacturing is critical for reducing both human and environmental risks.
Output Management: The outputs of apparel and footwear manufacturing 
include finished products as well as wastewater.
ESG Report: Chemicals 
Management p. 38
Sustainability 
Webpages: Chemicals 
Management
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
64

Topic
Accounting Metric
Category
Unit of 
Measure
Code
Data
Reference
Environmental 
Impacts in the 
Supply Chain
Percentage of (1)  
Tier 1 supplier facilities 
and (2) supplier 
facilities beyond 
Tier 1 in compliance 
with wastewater 
discharge permits 
and/or contractual 
agreements
Quantitative
Percentage 
(%)
CG-AA-430a.1
For more than 15 years, we have required our denim laundries to participate 
in our Water Quality Program, which allows us to actively monitor and improve 
wastewater quality. 
In 2021, out of 53 priority denim laundries that conducted wastewater testing 
per the ZDHC Wastewater Guidelines, 100 percent achieved Foundational level 
or better for all Conventional parameters and 94 percent met all ZDHC MRSL 
parameters.
Year
Total 
participants
% facilities meeting 
Conventional parameters
% meeting ZDHC 
MRSL parameters
2020
54
94
89
2021
53
100
94
ESG Report: Water 
Stewardship p. 35
Sustainability 
Webpages: Chemicals 
Management
Water Stewardship
Percentage of (1) Tier 1 
supplier facilities and 
(2) supplier facilities 
beyond Tier 1 that 
have completed the 
Sustainable Apparel 
Coalition’s Higg Index 
Facility Module (Higg 
FEM) assessment 
or an equivalent 
environmental data 
assessment
Quantitative
Percentage 
(%)
CG-AA-430a.2
By the end of 2022, 99 percent of our Tier 1 and 91 percent of our strategic 
Tier 2 suppliers completed the Sustainable Apparel Coalition’s Higg Index 3.0 
Facility Environmental Module (FEM) self-assessment to communicate their 
water and energy use, along with chemicals and waste management from 
2020. 64 percent of facilities verified their responses. In total, 89 percent of 
facilities participated in our resource efficiency programs.
Year
% Tier 1 branded 
suppliers using  
Higg Index FEM
% Tier 2 suppliers 
using Higg Index FEM
# verified 
responses
2019
97
91
n/a
2020
100
70
280
2021
99 (558)
91 (147)
463 (64%)
(351 Tier 1,  
112 Tier 2)
ESG Report: Resource 
Efficiency and 
Manufacturing p. 37
Sustainability 
Webpages: Chemicals 
Management
Water Stewardship
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
65

Topic
Accounting Metric
Category
Unit of 
Measure
Code
Data
Reference
Labor Conditions 
in the Supply 
Chain
Percentage of (1) Tier 1 
supplier facilities and 
(2) supplier facilities 
beyond Tier 1 that have 
been audited to a labor 
code of conduct,  
(3) percentage of total 
audits conducted by a 
third-party auditor
Quantitative
Percentage 
(%)
CG-AA-430b.1
*	 83 percent of Tier 1 branded apparel suppliers that were active for the  
full year were audited to our COVC during the fiscal year.
•	 68 percent of audits were conducted by a third-party assessor, ILO-IFC 
Better Work and SLCP.
•	 Facilities with a consistently low non-conformance rate may be assessed on 
a biennial basis; all facilities are audited prior to initial production.
Suppliers beyond Tier 1 audited to COVC
•	 N/A
As part of our Mill Sustainability Program, we communicated to our entire mill 
base our expectations of their social and environmental performance, which 
are requirements of doing business with us.
Year
% Tier 1 branded 
suppliers audited  
to COVC 
% of audits conducted 
by third-party 
assessor (ILO-IFC 
Better Work and 
SLCP)
% of suppliers 
beyond Tier 1 
audited to COVC
2019
91
34
N/A
2020
81
71
N/A
2021
83
68
N/A
Priority non-
conformance rate and 
associated corrective 
action rate for 
suppliers’ labor code of 
conduct audits
Quantitative
Rate
CG-AA-430b.2
We use a color-coded system to rate each facility’s performance. High-
performing facilities with few violations, none of which were critical, are rated 
green, average performers are yellow, and those that need to address one or 
more serious issues are red. As of fiscal 2021, fewer than 1 percent of facilities 
received red ratings during assessments against our COVC.
For issues open as of 2/1/2021, 84 percent of corrective action plans were 
resolved by 2/1/2022.
2/1/2021
5/1/2021 (3 months)
8/1/2021 (6 months)
2/1/2022 (1 year)
Sourcing 
Country
# of open 
issues
# of open 
issues
%  
resolution
# of open 
issues
%  
resolution
# of open 
issues
%  
resolution
Bangladesh
231
200
13
170
26
45
81
Cambodia
309
177
43
127
59
40
87
China
209
103
51
44
79
13
94
Guatemala
52
0
100
0
100
0
100
India
550
509
7
383
30
113
79
Indonesia
155
87
44
72
54
50
68
Pakistan
78
78
0
62
21
6
92
Sri Lanka
69
68
1
59
14
10
86
United States
0
0
-
0
-
0
-
Vietnam
694
560
19
284
59
90
87
Other
133
114
14
110
17
36
83
Grand Total
2480
1896
24
1311
47
403
84
Sustainability 
Webpages:  
Assessment and 
Remediation
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
66

Topic
Accounting Metric
Category
Unit of 
Measure
Code
Data
Reference
Labor Conditions 
in the Supply 
Chain 
(continued)
Discussion of greatest 
(1) labor and 
(2) environmental, 
health, and safety risks 
in the supply chain
Discussion 
and Analysis
N/A
CG-AA-430b.3
1. 		The labor practices and working conditions at the third-party suppliers that 
make apparel for Gap Inc. brands can affect reputation, business continuity, 
and operating costs for our brands and the company overall. Most workers 
in our supply chain are women, which is why in addition to labor practices, 
we have strong focus on empowering women to create lasting impact.
2. 	Excessive overtime, fire and structural safety, and gender-based violence 
are high-risk supply chain issues that we have specific programs in place to 
address. The human rights impact of these risks can be severe, while these 
issues can also present operational risk to our supply chain and reputational 
risk to our portfolio of brands.
Sustainability 
Webpages: Policies 
and Approaches for 
Human Rights
Raw Material 
Sourcing
Discussion of 
environmental and 
social risks associated 
with sourcing priority 
raw materials
Discussion 
and Analysis
N/A
CG-AA-440a.1
Gap Inc. uses industry tools such as the Higg Materials Sustainability Index 
(MSI) and Textile Exchange’s Preferred Fibers Matrix. Our holistic preferred 
fibers strategy uses life cycle assessment (LCA) data on indicators including 
global warming potential, water use and eutrophication, as well as evaluations 
for biodiversity, potential for circularity, chemistry, land use change, and social 
conditions within production. We focus our raw materials strategy on the top 
fibers that account for approximately 97 percent of our fiber consumption: 
cotton, polyester, nylon, and manufactured cellulosic fibers.
Fabric mills and laundries use a great deal of water to dye and finish fabric, 
which may cause issues with both water quality and quantity; these issues also 
affect workers and their communities. India faces a high level of water stress 
for some of our preferred mills and the people who work there. In addition, 
most of our products include some cotton, and its production affects both the 
environment and people. Farming and processing cotton typically involves the 
use of large quantities of water and chemicals, and often takes place in regions 
facing water and climate risks.
Changes in water access and water-related events such as drought or flooding 
could affect the cost of cotton, which is used in the majority of Gap Inc.’s 
products, and other raw materials. Gap Inc.’s Supply Chain and Sourcing team 
monitors and responds to risks for key raw materials using a multi-factor model 
that includes cotton prices. The team’s work to develop and maintain a diverse 
supplier base across several countries reduces risk on an ongoing basis.
For more information on how we evaluate water and other environmental risks 
in key sourcing countries, please see our CDP Water response (W3.3b).
Sustainability 
Webpages: Raw 
Materials and Product
ESG Report: 
Sustainable Materials 
Sourcing p. 42
CDP Water Security 
Disclosure 2021 
(W3.3b)
Percentage of raw 
materials third- 
party certified to an 
environmental and/ 
or social sustainability 
standard, by standard
Quantitative
Percentage 
(%) by 
weight
CG-AA-440a.2
2019
2020
2021
Natural fibers
Percentage of cotton: more  
sustainable cotton* 
60
54
79
Percentage of wool: recycled wool
16
11
14
Synthetics
Percentage of nylon: recycled 
nylon
7
10
10
Percentage of polyester: recycled 
polyester
1
6
10
Manufactured 
cellulosics
Percentage of cellulosics: more 
sustainable viscose, modal, lyocell, 
TENCEL™, lenzing
8
9
13
ESG Report: 
Sustainable Materials 
Sourcing p. 42
*Defined as: Better Cotton (formerly BCI), verified US-grown cotton (USCTP), organic, in-conversion (to verified organic), recycled, and regenerative.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
67

Topic
Accounting Metric
Category
Unit of 
Measure
Code
Data
Reference
Activity Metric
Number of (1) Tier  
1 suppliers and  
(2) suppliers beyond 
Tier 1
Quantitative
Number
CG-AA-000.A
As of January 29, 2022 we sourced from 705 Tier 1 branded-apparel 
supplier facilities, defined as direct-relationship cut-and-sew facilities and 
their associated embroidery, laundry and screen-printing facilities. We have 
mapped out 231 mill facilities (Tier 2) that represent about 65 percent of 
our business. 
Year
# of Tier 1 branded-
apparel supplier 
factories
# of mill  
facilities  
(Tier 2)
% of business 
from mill facilities 
(Tier 2) 
2019
737
191
75
2020
659
168
66
2021
705
231
65
ESG Report: Human 
Rights and Social 
Dialogue p. 19
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
68

Topic
Activity Metric
Category
Unit of 
Measure
Code
Data
Reference
E-Commerce
Data Security
Description of 
approach to identifying 
and addressing data 
security risks
Discussion 
and Analysis
N/A
CG-EC-230a.1
We do our best to provide our customers with a safe and convenient shopping 
experience. We have put in place a wide variety of technical and organizational 
security measures to help protect the personal information we collect about 
our customers. 
The Board’s Audit and Finance Committee oversees data privacy and 
cybersecurity programs and regularly briefs the Board on material concerns. 
To respond to the threat of security breaches and cyberattacks, the company 
maintains a program designed to protect and preserve the confidentiality, 
integrity, and continued availability of all information owned by, or in the care 
of, the company. This program also includes a cyber incident response plan 
that provides controls and procedures for timely and accurate reporting of any 
material cybersecurity incident.
For further information, please see Gap Inc.’s Code of Business Conduct.
Sustainability 
Webpages: Privacy 
Policy
2021 Proxy Statement
Employee 
Recruitment, 
Inclusion, & 
Performance
Employee engagement 
as a percentage
Quantitative
Percentage 
(%)
CG-EC-330a.1
2,000+ HQ Pulse survey participants and 23,000+ store Pulse survey 
participants; 95 percent average score for “I am proud to work here” and 
89 percent “I intend to stay for the foreseeable future” from Pulse survey 
participants.
A representative sample was obtained for both groups. This is Gap Inc.’s own 
survey, conducted internally.
Answers are often scored on a Likert scale of 1–5 (strongly disagree -> strongly 
agree). Examples of questions asked in the Pulse survey include:
On a scale of 1–5, to what extent do you agree with the following statements:
-	 I am proud to work here 
-	 I believe this company operates with integrity 
-	 My manager seeks out and values my perspective
How important are the following to you, and how well does Gap Inc. do this:
-	 I am able to have flexibility in my work schedule 
-	 I work for a company with strong reputation and purpose 
-	 My company employs inspiring and effective leaders
ESG Report: Talent 
Development p. 29
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
69

Topic
Activity Metric
Category
Unit of 
Measure
Code
Data
Reference
Product 
Packaging & 
Distribution
Total greenhouse gas 
(GHG) footprint of 
product shipments
Quantitative
Metric tons 
(t) CO2-e
CG-EC-410a.1
Upstream transportation and distribution:
2019
2020
2021
527,081
Available later in 2022
Available in 2023
Emissions calculated using primary metric ton/km information at a haul level 
from Gap internal systems, multiplied by The U.K. Department for Environment, 
Food & Rural Affairs product transportation emission factors. This represents 
emissions from our suppliers to our distribution centers. 
Downstream transportation and distribution:
2019
2020
2021
39,413
130,604
Available later in 2022
Emissions calculated using primary metric ton/km information at a haul level 
from Gap internal systems, multiplied by The U.K. Department for Environment, 
Food & Rural Affairs product transportation emission factors. In 2020, we also 
began to receive additional emissions information from UPS, which represents 
emissions from online shipments from distribution centers to customers or 
from Ship-From-Store methods. The UPS data is verified by SGS.
CDP Climate Disclosure 
2021 (C6.5)
Discussion of 
strategies to reduce 
the environmental 
impact of product 
delivery
Discussion 
and Analysis
N/A
CG-EC-410a.2
Gap Inc. is a signatory of the Arctic Corporate Shipping Pledge, created in 
partnership with the Ocean Conservancy; the pledge is a commitment to never 
intentionally send ships through the Arctic’s fragile ecosystem.
Gap Inc. is also a member of the Environmental Protection Agency’s (EPA) 
SmartWay Transport Partnership, an initiative which empowers businesses 
to move goods in the cleanest, most energy-efficient way possible to protect 
public health and reduce emissions. Gap Inc. was recognized by the EPA with 
the 2020 SmartWay Freight Partner Excellence Award.
ESG Report: Climate 
Stewardship p. 27
Activity Metrics
Entity-defined 
measure of user 
activity
Quantitative
Number
CG-EC-000.A
Total Global Online Orders (excluding Franchise)
FY 2019
55,872,090 
FY 2020
86,261,667 
FY 2021
83,997,807
This data includes orders placed in the United States Specialty (web and app), 
U.S. Factory, Canada, Japan, European Union, and United Kingdom. It does not 
include franchises, cancellations, or returns.
Number of shipments
Quantitative
Number
CG-EC-000.C
Total Packages
FY 2019
77,625,502
FY 2020
145,512,653
FY 2021
124,463,015
This data includes packages transported in the United States, Canada, 
European Union, and Japan.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
70

Topic
Activity Metric
Category
Unit of 
Measure
Code
Data
Reference
Multiline and Specialty Retailers & Distributors 
Product 
Sourcing, 
Packaging & 
Marketing
Discussion of 
strategies to reduce 
the environmental 
impact of packaging
Discussion 
and Analysis
N/A
CG-MR-410a.3
In 2021, Gap Inc. joined a cross-brand working group initiated by The Fashion 
Pact to research and develop paper-based alternatives to polybags.
After rolling out new polymailers that contain 50 percent recycled content 
(compared to 35 percent in 2020), the team decided to commission a life cycle 
assessment, assessing the impacts and performance of three alternatives 
to Gap Inc.’s current mailer: paper, bio-based, and reusable. This will ensure a 
data-backed strategy going forward. 
ESG Report: Circularity 
and Waste p. 44
Sustainability 
Webpages: Circularity 
and Waste
Activity Metrics
Number of: (1) retail 
locations and  
(2) distribution centers
Quantitative
Number
CG-MR-000.A
Data references end-of-year numbers
Retail Locations
2019
2020
2021
Company-
operated stores
3,345
3,100
2,835
Franchises
574
615
564
FY21 10-K p. 30
Total area of:  
(1) retail space and 
(2) distribution centers
Quantitative
Square 
meters (m2)
CG-MR-000.B
2019
2020
2021
Retail space 
(square footage)
37 million
34.6 million
33.3 million
Distribution centers 
(square meters)
3.4 million
3.2 million
3.1 million
FY21 10-K p. 30
FY20 10-K p. 30
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
71

TASK FORCE ON CLIMATE-RELATED  
FINANCIAL DISCLOSURES (TCFD) INDEX
TCFD Metrics
Company Response
GOVERNANCE
a) 		Describe the board’s oversight of climate-related risks and 
opportunities.
2021 CDP Climate Change Disclosure: (C1.1, C1.1a, C1.1b, C1.2, C1.2a) 
ESG Report: Governance > Risk Management (p. 48) 
b) 	Describe management’s role in assessing and managing 
climate-related risks and opportunities.
2021 CDP Climate Change Disclosure: (C1.2, C1.2a, C2.2)
ESG Report: Governance > Oversight Structure (p. 47) 
> Management Approach
STRATEGY
a) 	Describe the climate-related risks and opportunities the 
organization has identified over the short, medium, and long term.
2021 CDP Climate Change Disclosure: (C2.1a, C2.1b, C2.2, C2.2a, C2.3, C2.3a, C2.4a)
> Materiality
> Responsible Business Practices
b) 	Describe the impact of climate-related risks and opportunities on 
the organization’s businesses, strategy, and financial planning.
2021 CDP Climate Change Disclosure: (C2.3a, C2.4a, C3.1, C3.2, C3.2b, C3.3, C3.4)
c) 	Describe the resilience of the organization’s strategy, taking into 
consideration different climate-related scenarios, including a 
2°C or lower scenario.
2021 CDP Climate Change Disclosure: (C2, C3.2b, C3.3)
Gap Inc. is planning to conduct a climate-related scenario analysis in 2022.
The inclusion of information contained in this disclosure should not be construed as a characterization regarding the materiality or financial impact of that information to 
investors in Gap Inc. For a discussion of risks that are material to investors in Gap Inc., please see our Annual Report on Form 10-K for the year ended January 29, 2022 filed 
with the Securities and Exchange Commission (SEC), and subsequent SEC filings. Given the inherent uncertainty in predicting and modeling future conditions, caution should be 
exercised when interpreting the information provided below. In addition, the controls, processes, practices, and infrastructures described in this disclosure are not intended to 
constitute any representation, warranty, or other assurance that such controls, processes, practices, and infrastructures will result in any specific outcome or result.
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
72

TCFD Metrics
Company Response
RISK MANAGEMENT
a) 	Describe the organization’s processes for identifying and 
assessing climate-related risks.
2021 CDP Climate Change Disclosure: (C2.1, C2.2, C2.2a)
> Responsible Business Practices
b) 	Describe the organization’s processes for managing 
climate-related risks.
2021 CDP Climate Change Disclosure: (C2.1, C2.2, C2.3a, C12.1a, C12.1b) 
> Responsible Business Practices
> Materiality
c) 	Describe how processes for identifying, assessing, and 
managing climate-related risks are integrated into the 
organization’s overall risk management.
2021 CDP Climate Change Disclosure: (C1.1b, C2.2, C2.3a)
> Responsible Business Practices
METRICS
a) 	Disclose the metrics used by the organization to assess 
climate-related risks and opportunities in line with its strategy 
and risk management process.
2021 CDP Climate Change Disclosure: (C1.3a, C2.3a, C2.4a, C4.1a, C4.2a, C4.3b, C5, C6, C7, C8, C11)
2021 CDP Climate Change Disclosure: (W8.1a, W8.1b)
b) 	Disclose Scope 1, Scope 2, and, if appropriate, Scope 3 
greenhouse gas (GHG) emissions, and the related risks.
2021 CDP Climate Change Disclosure: (C4.1a, C5.1, C5.2, C6.1, C6.2, C6.3, C6.5, C.7) 
c) 	Describe the targets used by the organization to manage climate-
related risks and opportunities and performance against targets.
2021 CDP Climate Change Disclosure: (C4.1, C4.1a, C4.2, C4.2a) 
2021 CDP Climate Change Disclosure: (W8.1a, W8.1b)
ESG Report: Enriching Communities > Climate Stewardship (p. 39) 
THE BIG PICTURE
EMPOWERING WOMEN
ENRICHING COMMUNITIES
GOVERNANCE
ENABLING OPPORTUNITY
2021 ESG REPORT
73

INCLUSIVE 
BY DESIGN
2021 ESG REPORT