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About
ABOUT GAP INC.

ABOUT THIS REPORTFounded in San Francisco in 1969, Gap Inc.
is a leading global retailer offering clothing,accessories and personal care products formen, women and children under the Old Navy,
Gap, Banana Republic, Athleta, Intermix, Janieand Jack and Hill City brands.

This report covers Gap Inc.’s global
operations for fiscal 2019, which ended on
February 1, 2020.

Our Athleta brand is a certified B Corp,
demonstrating our commitment to usingbusiness as a force for good by meeting
rigorous standards across social andenvironmental performance, accountability
and transparency. We have amended Athleta's
legal charter to become a Delaware Public
Benefit Corporation to further uphold thebrand’s commitment to people and the planet.
Our Hill City brand was also a certified B Corp,
but we made the difficult decision to wind
down operations by the end of 2020.
We purchase private-label and non-privatelabel merchandise from about 800 vendors.
Our vendors have facilities in about 30
countries.
At the end of fiscal 2019, we had
approximately 129,000 part-time and full-time
employees. Our products were available forpurchase in more than 90 countries through3,345 Company-operated stores, 574
franchise stores, and e-commerce sites.

Our last report covered fiscal 2018 and isavailable with our other past sustainability
reports.
This report focuses on developments andactions for our key programs, progress
toward our corporate and brand goals
during the 2019 fiscal year, preparations
for activities in 2020, and an analysisof trends and business impacts whereavailable. For our many programs, we
provide detailed information on objectives,operations and our management approachat gapincsustainability.com, which can beaccessed via links in each section.
We sought to prepare this report inaccordance with the Global Reporting
Initiative (GRI) Standards: Core option.
Gap Inc. is committed to the United Nations(UN) Global Compact Ten Principles andthis report serves as our Communication
on Progress (CoP). We have not obtained
external assurance for this report.

Learn more
> Annual Filings

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CEO Letter
If 2020 has taught us anything, it’s that crisis
has the potential to create opportunities
to unlock necessary change. We’re facing
the worst crisis in our history – one thathas been destabilizing for not only ourindustry, but for our employees, customers,
partners and communities around the world.
This global health crisis has magnified theseverity and complexity of other social andcultural imperatives, including addressing
ongoing impacts of climate change andsystemic racism. Yet, the enormous
challenges brought on by COVID-19 havealso accelerated the pace of much-neededtransformation – both within our company
and in society on a global scale.
While we can’t ignore that this global
pandemic will have lasting consequenceson all of us, it’s also true that this has beena time of greater collaboration, clarity andunity. I have witnessed untold kindness
and intrepidness, and experienced boldinnovation and creativity. I am seeing thatshow up in countless ways as we design for
the future – one we can all be proud of.
In reflecting on Gap Inc.’s role in creating
positive change, the very premise of ourcompany is what we look to. Our founders,
Doris and Don Fisher, built this company in1969 on a single need: fit. When Don could
not find a pair of jeans that fit him, they
opened a store as an equal partnership that
became a company of purpose-led brands
that shape people's way of life, guided by the
belief that we can not only bridge the gaps
between us, but future generations. They
believed Gap Inc. would achieve success by
being open to all, and creating opportunities
for the people and communities connected

to our business. Over the years, their vision
has guided our company to imagine how we
can do more to support sustainable societies
and a resilient planet. Our foundational values
are more important than ever and they fuel ourcommitment to being a force for good – to help
people, planet and communities.

"Our foundational values
are more important thanever and they fuel ourcommitment to being aforce for good — to help
people, planet andcommunities."
Earlier this year, Gap Inc. took necessary
actions to survive and emerge from this period
even stronger, including temporarily closing
stores to protect the health of employees andcustomers. We didn’t make decisions lightly
because so many depend on our business.
Guided by our values, we worked quickly to reopen stores safely, bring our teams back, andmitigate impacts to our supplier partners andgarment workers.
Another critical lesson of 2020 has been
the need to create space to learn and tohelp break down the centuries-old systems
that have held back our Black and Brown
communities. In June, we outlined a new setof commitments to drive systemic change bothin and outside our walls, and enable a cultureof belonging for our teams, customers andcommunities. We look forward to sharing ourprogress on this journey.
Not only do we have an enormous opportunity
to build on our legacy of doing more thanselling clothes, our brands are leading the way
by amplifying our values and connecting with
consumers in creative, compelling and relevant
ways. Through designing sustainability into our
products, reducing water use in manufacturing,and developing climate strategies for ourbusiness, our sustainability work matters – tous and to our stakeholders.
Enclosed in this report is a detailed account ofour progress. As a company co-founded by awoman and led by women at every level of thecompany, I am especially proud of the ways
in which our company continues to support
the women who create the world’s clothes.
We have greatly expanded our P.A.C.E.
program, which has reached over half a million
women and girls, and I’m excited the program
will potentially reach even more, including
through a new initiative whose members
collectively engage 4.5 million women in
the global supply chain. From achieving ourgoal to save 10 billion liters of water throughsustainable manufacturing processes aheadof schedule, to developing major renewableenergy projects, to hiring young people whowill become our future leaders for their firstjob from our This Way Ahead program, toestablishing Gap Inc.’s first science-basedtargets, we accomplished a great deal in 2019.
We have achieved progress thanks to thededication of our employees, partners andindustrywide collaboration. We cannot do
this work alone, and we are grateful for those
who guide us, stand behind us and beside us,

including our ongoing engagement with othersignatories of the UN Global Compact, who’ve
defined the path for the industry to contributeto sustainable change.
The experiences of 2020 have been
generation-defining and, in the face of still somuch uncertainty, I know what we’re made of:resilient teams and a company of powerful,
purpose-led lifestyle brands. Now, more thanever, we have the opportunity to leverage
our size and scale to win and position us for
growth in the future. I believe in our ability to
be a force for good.

Sonia Syngal
CEO, Gap Inc.
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AppendixContents
OVERVIEW

SOCIALENVIRONMENT
Water Stewardship Strategy		47
50

Highlights

6

Our Employees:

Our Purpose-Led Brands		

7

Talent20

Women + Water			

Goals + Progress			

8

Equality + Belonging			22

Resource Efficiency + Manufacturing 52

Employee Engagement		

27

Chemicals Management		

56

This Way Ahead: First Jobs		

29

Climate

59

Waste

62

Circularity

63

STRATEGY
Sustainability Strategy		

12Core Focus Areas			

13

Materiality

14

Product Life Cycle			15

Management Approach		

16

Governance
Stakeholder Engagement		Supply Chain + Communities:
Supplier Sustainability

32

Assessment + Remediation		

33

Capability Building

39

P.A.C.E.: Empowering Women		

43

PRODUCT
Product Sustainability

66

17

Raw Materials

67

18

Brand Goals

69

APPENDIX
Sustainable Development Goals

75

SASB Reference Table			76

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Overview
Highlights

6

Our Purpose-Led Brands

7

Goals + Progress		

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Highlights
PEOPLEENVIRONMENTPRODUCT

Advancing people + communities

A healthy planet is a human rightGreat product designedwith sustainability in mind

Our Employees

Water

Chemicals Management

1,600+

11.2B

0

We hired over 1,600 youth facing barriers
to employment through This Way Ahead(p.29), our first-jobs program.

In early 2020, we achieved our goal to save 10 billion
liters of water (p.55) in manufacturing since 2014.

We committed to eliminate PFC-based
finishes (p.57) from our products by 2023.

youth hired

liters of water saved
in manufacturing

Supply Chain Workers

PFC-basedfinishes by 2023

ClimateCircularity

98%

90MW

1X1

We sourced almost exclusively from facilities
rated green or yellow (p.33) as evaluatedagainst our Code of Vendor Conduct (COVC).

We signed a 90-megawatt wind project(p.61), which will generate enough clean energy
to power half of our stores starting in late 2020.

Our collaboration with the Hong Kong ResearchInstitute of Textiles and Apparel (HKRITA) will
accelerate circularity (p.63) models for textiles.

sourcing facilities
rated green or yellow

renewable-energy
generation

Communities

textile circularity
collaboration

Waste

Raw Materials

580K+

0

100%

We continued our commitment to scale our P.A.C.E.
program (p.43), empowering over 580,000 womenand girls since the program launched in 2007.

We committed to eliminate single-use plastics(p.62) by 2030 as part of our efforts to reduce
plastic packaging across our brands.

We committed to source all of our cotton from
more sustainable sources (p.68) including Better
Cotton Initiative (BCI), recycled and organic cotton.

women + girls
empoweredsingle-use plastics
by 2030

sustainable cottonby 20252019 Global Sustainability Report

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Our Purpose-Led Brands
We grow purpose-led, billion-dollar brands that have lasting
impact on people and the planet.
For every brand within Gap Inc., sustainability is a businesspriority and a critical way to express each brand’s values.
All of our brands have established executive sustainability
steering committees, defined their own priorities andgoals, and led sustainability-strategy workshops withcross-functional teams. This work has empowered eachbrand to build a strategy true to its identity while pursuingmeaningful environmental and social impact.

We believe in the
democracy of style.

ModernAmericanOptimism

WILL WORK FOR A
BETTER REPUBLIC

POWER OF SHE

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On track
Needs attention
New goal since last report

Goals + Progress
Holding ourselves accountable is fundamental to ourapproach to sustainability.
Below is a snapshot of key goals, our progress to date
and where we are heading in the future. All target years
are fiscal year end. Report data is through fiscal 2019
(February 1, 2020) unless otherwise noted. Additional
detail can be found in respective sections of this report.

TargetYear

Status

FY2019 Progress (unless otherwise noted)

Double the representation of Black and Latinx employees at
our U.S. headquarters offices

2025

NEW

New goal. Progress to date:
14% of employees at our U.S. headquarters offices are Black or Latinx

Increase the representation of Black employees in U.S. store
leader roles by 50%

2025

NEW

New goal. Progress to date:
9% of U.S. store leaders are Black (2019 baseline)

Support $15 million in annual employee-driven community
investment

Ongoing

SOCIAL
Our
Employees

Supply Chain +Community$12.2 million in employee-driven community investment (volunteer hours,
employee financial donations and Gap Inc. matching of time and money)

Reach 20,000 youth through This Way Ahead(Previous goal: Reach 10,000 youth by 2020)

2025

8,201 youth have participated since the program launched in 2007

Hire 5% of entry-level employees from This Way Ahead
annually2025

2.3% of entry-level employees were hired from This Way Ahead

100% of supplier facilities producing branded apparel are
rated yellow or green

2020

98% of supplier facilities were rated yellow or green

100% of Tier 1 suppliers transition to digital wage payments

2020

92% of suppliers paid wages via mobile wallet, bank account or debit card

Reach 1 million women through P.A.C.E.

2022

Over 580,000 women and girls have participated in P.A.C.E. since theprogram launched in 20072019 Global Sustainability Report

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On track
Needs attention
New goal since last report

Goals + Progress
TargetYear

ENVIRONMENT
Water

ClimateWaste

PRODUCT

Appendix

Status

FY2019 Progress (unless otherwise noted)

Save 10 billion liters of water in manufacturing, from a2014 baseline

2020

Water-resilient value chain

2030

NEW

New commitment. Establishing baselines and context-based targets

Net-positive water impact in water-stressed regions

2050

NEW

New commitment. Establishing baselines and context-based targets

Work toward zero discharge of hazardous chemicals in our
supply chain

2020

Eliminate all PFC-based finishes from our supply chain

2023

Carbon neutral across our value chain

2050

New commitment. Tracking in progress

Reduce GHG emissions by 50% in our owned and operated
facilities globally, from a 2015 baseline

2020

23% cumulative GHG emissions reduction (363,586 metric tons CO2e)
since 2015; 100.5 megawatts of energy secured through renewable-energy
contracts or Virtual Power Purchase Agreements (VPPAs)

Source 100% renewable electricity for our owned andoperated facilities globally, from a 2017 baseline

2030

NEW

New goal. Progress to date:
The VPPAs mentioned above will help us meet this goal.

Reduce absolute Scope 1 and 2 GHG emissions by 90%,
from a 2017 baseline

2030

NEW

New goal. Progress to date:
10.3% GHG emissions reduction (2017 baseline)

Reduce Scope 3 GHG emissions from purchased goods andservices by 30%, from a 2017 baseline

2030

NEW

New goal. Progress to date:
5.18 million metric tons CO2e in Scope 3 GHG emissions (2017 baseline)

Divert 80% of waste from landfill across our U.S. facilities

2020

Eliminate single-use plastics

2030

Eliminate the use of wood-derived fibers sourced fromancient and endangered forests2025

86% of our cellulosic-fiber volume was compliant with our commitment

Source 100% of cotton from more sustainable sources

2025

New goal. Progress to date:
57% of cotton was sourced from more sustainable sources in Q1 2020

11.2 billion liters of water saved since 2014 (achieved in early 2020)

Strategic facilities must comply with the ZDHC MRSL and verify throughwastewater testing.
NEW

New goal. Tracking in progress

65% of waste diverted from landfill; On track to meet goal FY2021

NEW

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On track
Needs attention
New goal since last report

Goals + Progress
TargetYear

Status

FY2019 Progress (unless otherwise noted)

Source 100% of cotton from more sustainable sources

2022

NEW

New goal. Progress to date:
56% of cotton was sourced from more sustainable sources

Make 100% of denim products using water-saving
techniques

2022

NEW

New goal. Progress to date:
88% of denim products were made using water-saving techniques

Source 100% of cotton from more sustainable sources

2021

67% of cotton was sourced from more sustainable sources

Make 75% of qualifying products using Washwell™ watersaving techniques2021

42% of qualifying denim products were made using Washwell™

Source 100% of cotton from more sustainable sources

2023

NEW

New goal. Progress to date:
75% of cotton was sourced from more sustainable sources

Make 50% of products with more sustainable fibers

2023

NEW

New goal. Progress to date:
55% of products were made with sustainable fibers

Make 50% of products using water-saving techniques andcleaner chemistry practices in our supply chain

2025

NEW

New goal. Progress to date: 1.4% of Spring 2020 products were made withtechniques that save water or preserve water quality

Make more eco-friendly denim

2023

NEW

New goal. Progress to date:
68% of denim was eco-friendly in Q2 2020

Make 80% of materials with sustainable fibers

2020

70% of materials used in product were made with more sustainable fibers

Make 25% of products using water-saving techniques

2020

4% of products were made using water-saving techniques

Divert 80% of store waste from landfill

2020

72% of store waste was diverted from landfill

Empower 10,000 women through P.A.C.E. and Fair Trade

2020

16,555 women have participated in P.A.C.E. or received premiums fromFair Trade USA since 2007

OUR PURPOSE-LED BRANDS

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Strategy
Sustainability Strategy		

12Core Focus Areas			

13

Materiality

14

Product Life Cycle			15

Management Approach		

16

Governance17

Stakeholder Engagement		

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Sustainability Strategy
As one of the world's leading apparel retailers, werecognize that we contribute to and have the opportunity
to address systemic social and environmental challenges.
We continue to be committed to contributing to ourbusiness; enabling safe, fair working conditions forthe people who make our products; minimizing ourenvironmental impact; and working with our industry
to achieve progress on global goals. We do this byaddressing impacts in our owned and operated facilities
and collaborating throughout our value chain and acrossgovernment, business and civil society. Recognizing theimportance of engaging customers and employees, weare also communicating through our brands in our effort
to build a more sustainable world.
We align our strategy with the international sustainability
agenda. Guided by frameworks including but not limited
to the UN Guiding Principles on Business and Human
Rights, the UN Sustainable Development Goals (SDGs)
and the Paris Agreement on climate change, we haveidentified the issues that are most important to ourbusiness and where we have the most influence.

“The health of our business and thehealth of our planet are undeniably
connected. We are investing in Gap Inc.
for the future – a portfolio of brands thatis resilient, sustainable and reflective ofour diverse customer base.”
Katrina O’Connell
Chief Financial Officer, Gap Inc.

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Core Focus Areas
We recognize that wecannot lead on every
issue. Given our business
operations and strengths,
we prioritize our greatest
opportunities forleadership to maximize
impact.

SOCIALENVIRONMENTPRODUCT

Our Employees

Water

Product Sustainability

We aim to create opportunities for theemployees who support our business inour stores and headquarters offices.

Water is essential for our business andthe people and communities where we
operate. We look for ways to address
water impacts throughout our value chain
and in communities.

We work with our Product Designers
and Developers to balance the needs ofgetting great product into our customers’
hands, with efforts to reduce our impact
on the environment.

Communities

ClimateRaw Materials

Gap Inc.’s sustainability
materiality assessment
sets our overarchingsustainability agenda
and helped to establish
our core focus areas.
Our P.A.C.E. (Personal Advancement& Career Enhancement) program gives
women and girls the foundational life
skills, technical training and support theyneed to advance in the workplace and intheir communities.

We are reducing our greenhouse gas(GHG) emissions through renewableenergy projects; and we work with our
logistics and procurement partners to
improve efficiency and environmental
performance.

Supply Chain

Waste

By partnering with our suppliers, we strive
to provide safe, fair and healthy working
conditions for the individuals who create
our clothes.

We are reducing waste throughout our value
chain and building circularity programs toredefine the life cycle of our products inorder to reduce resource consumption.

We believe great products are createdwith sustainability at their core, whichmeans going all the way down to theearliest stages of the product life cycle
to reduce impacts.

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Materiality
We integrate sustainability deeply into our business tocreate greater impact across our value chain.
Within sustainability, materiality* refers to the areasof heightened concern from our internal and external
stakeholders compared to relevant environmental, socialand governance issues. Our material issues, viewed
alongside our value chain, demonstrate focus areas
where we can develop programs more directly targetedto the areas of greatest impact.
We prioritize the sustainability opportunities andchallenges that matter most to our stakeholders andbusiness.
We periodically refresh our materiality assessment inorder to:• Identify the most material sustainability issues for
Gap Inc. in terms of business value, risks andopportunities for long-term planning• Understand how sustainability and key business issues
intersect• Inform future sustainability commitments andresource allocation• Support Gap Inc.’s engagement with external
stakeholders
Our material issues fall into three categories: governanceand operating context; human rights and social
impact; and resource use, scarcity and impacts. Fifteen
sustainability-related aspects guide our strategy.

MATERIAL ISSUES
Governance + Operating Context
•
•
•
•
•

Corporate GovernanceTransparency
Technology + Product Innovation
Resiliency
Country / Regional Legal + Economic
Conditions

Human Rights + Social Impact
•
•
•
•
•

Worker Rights + Well-being
Income, Wages + Inequality
Human Capital + Development
Diversity + Inclusion
Reputation + Consumer Engagement

Resource Use, Scarcity + Impacts
•
•
•
•
•

Water
Chemicals Management + Compliance
Energy + Climate Stewardship
Waste + Circularity
Sustainable Materials Sourcing

Learn more
> Materiality*Materiality in this report refers to the definition fromthe Global Reporting Initiative (GRI) Standards, andis not the definition of materiality used for filings
with the U.S. Securities and Exchange Commission(SEC). Issues deemed material in this report may not
be considered material for SEC reporting purposes.

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Life Cycle
Each stage of a garment’s
life – from the first design
sketches to end of use –presents opportunities toimprove the sustainability
performance of ourbusiness.

StrategySocialDesign +Development
Most of a product’s environmental impacts
are determined at the concept phase.
Thus, our designers’ creative vision canhave a significant impact on people andthe environment. Our production andsourcing teams bring this vision to life byplacing orders with independent suppliers.
These teams are trained on sustainability
principles and have significant influence
over who makes our clothes. This affords
Gap Inc. the ability to improve working
conditions in facilities and address our larger
environmental footprint.
Our Programs> Water Stewardship Strategy (p.47)> Chemicals Management (p.56)> Product Sustainability (p.66)> Circularity (p.63)

Product +Finishing

Logistics +Distribution

Environment

Product

Appendix

Raw Materials +Processing

TextileManufacturing

Tier 3 Suppliers

Tier 2 Suppliers

Our products use many types of fibers –natural fibers like cotton and wool, synthetic
fibers like polyester and spandex, andpulp-based manufactured cellulosic fibers
like rayon and modal. We work to minimize
the social and environmental impacts uniqueto each fiber. We place a special focus on
cotton, given its importance to many of our
products and water-intensive production
process. We are also taking steps to ensurethat we source more sustainable synthetic
and man-made cellulosic fibers.

Fabric mills use large quantities of energy
and water, and the chemicals used to dye
and finish fabrics may pose a risk to local
watersheds if not treated properly. Our
Mill Sustainability Program establishes
clear environmental standards, which we
integrate into our sourcing decisions. We
also aim to scale improvements across theindustry by working with our peers to identify
and share best practices for the responsible
use of water, chemicals and energy.

Our Programs> Water Stewardship Strategy (p.47)> Climate (p.59)> Product Sustainability (p.66)

RetailStoresOur Programs> Assessment + Remediation (p.33)> P.A.C.E.: Empowering Women (p.43)> Water Stewardship Strategy (p.47)> Chemicals Management (p.56)> Climate (p.59)

Consumer Use +Circularity

Tier 1 Suppliers
We believe in a comprehensive approach
for improving working conditions in our
supply chain, combining facility-monitoring
and capability-building programs to help
our suppliers continually improve. We also
engage closely with all of our vendors tomeasure and address their environmental
impact.
Our Programs> Assessment + Remediation (p.33)> Capability Building (p.39)> P.A.C.E.: Empowering Women (p.43)> Water Stewardship Strategy (p.47)> Chemicals Management (p.56)> Climate (p.59)> Product Sustainability (p.66)

We ship products through a combination ofsea, air, truck and rail from supplier facilities
to our distribution centers and then on to
stores or directly to customers. We use theoptimal mix of shipping options based on
speed, cost and sustainability and havetaken steps to conserve energy and reduce
waste at our distribution centers, the largest
facilities we own and operate.
Our Programs> Climate (p.59)> Waste (p.62)

Our stores express who we are – from ourstyle to our commitment to operating ina way that cares for both people and theenvironment. They are where we sell our
products and communicate directly with our
employees and customers. As part of ourowned and operated footprint, they offer
an opportunity to reduce our environmental
impact. We also run our This Way Ahead
program at our stores to help young people
experiencing barriers to employment obtain
their first jobs.
Our Programs> Equality + Belonging (p.22)> This Way Ahead: First Jobs (p.29)> Climate (p.59)> Waste (p.62)> Product Sustainability (p.66)

How our customers wear, care for anddiscard their clothes accounts for a portionof our products’ total environmental
footprint. We use product labeling, catalogs,
social media and blog posts to share
our efforts to improve sustainability. This
informs customers about our work, inspires
them to consider water use in their daily
lives, and communicates the urgency of
our environmental and social initiatives.
Recognizing that we have an opportunity
to improve circularity, we engage in andcontribute to industrywide solutions to endof-life impacts.
Our Programs> Circularity (p.63)

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Management Approach
Given our company's size, we recognize our responsibility
to the planet and to the people touched by our business.
Our global scale provides an opportunity to make a realdifference. We do this by enabling long-term businessperformance through managing risks, advancing
greater equality and opportunity, developing social andenvironmental innovations that allow people to fulfill theirpotential, and scaling these innovations by integratingthem into our business and products.
In addition to aligning our goals with the UN Global
Sustainable Development agenda, we take an intentional
approach in all of our social and environmental programs.

OUR APPROACHRISK MANAGEMENT

1. Integrate sustainability into
our business

Gap Inc. has developed systems andprocedures focused on identifying andmanaging risks, including those related tosustainability.

We create broader accountability for oursustainability strategy by creating sharedgoals and targets across Gap Inc. with therelevant business units. While we maintaina centralized Global Sustainability function,
we integrate our approaches wherever it
helps to deepen or broaden our impact.

2. Set ambitious goals
We focus on key indicators across thecompany so that we can measure ourprogress on delivering real benefits to thepeople and communities we serve.

3. Make progress toward ourcommitments
We contribute in a meaningful way to thepeople and communities we rely on for ourbusiness – which also helps our company
succeed.

4. Form partnerships withcivil society, governments
and other sectors to increase
collective impact

Our Global Sustainability team works withbusiness partners and experts to assess
the importance of potential social andenvironmental risks and opportunities for ourbusiness and external stakeholders, including
suppliers and the people who make our
products. These include the risks that climate
and environmental impacts could pose to
our business. The team uses tools to help
prioritize risks and opportunities, including
a sustainability materiality assessment, anassessment of representative products and astakeholder-engagement process.
For these materiality and other risk
assessments, we consider such factors as
the magnitude, likelihood and time horizonof potential impacts on our business andstakeholders. We also create country-specificstrategies that take into consideration local
context when developing our program andaddressing key issues.
Learn more
> Our risk-management process

By partnering with organizations from thelocal to the global level, we deliver impact
on a bigger scale and create long-term,
sustainable progress.

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Governance
SUSTAINABILITY
GOVERNANCE

CODE OF BUSINESSCONDUCTOur governance structure ensures that our
Global Sustainability program both meetsthe company’s social and environmental
goals and supports our business.

Our Global Code of Business Conduct (COBC)
serves as our ethical compass, articulating ourcommitment to high standards.

Gap Inc.’s Board of Directors, particularly
the Governance and Sustainability
Committee, oversees our Global
Sustainability program. The board
receives regular updates from Chief Legal,
Compliance and Sustainability Officer,
Julie Gruber, and the leaders of the Global
Sustainability team. Julie reports directly to
Gap Inc. CEO, Sonia Syngal, and meetsregularly with Gap Inc. Chief Operating
Officer, Shawn Curran.
Our organizational structure allows
collaboration across key departments. Our
Global Sustainability team works closelywith our brands’ Product and Marketing
teams, as well as our Supply Chain,
Corporate Strategy, Government Affairs,
Public Affairs, Legal and Gap Foundation
teams, among others.
Learn more
> Sustainability Governance> Corporate GovernanceWe encourage our employees to use our
open-door process for discussing concernswith their supervisor, next-level manager orhuman resources representative. Employees
may also contact our Global Integrity
team, which oversees our COBC program.
Additionally, we provide a confidential COBC
Hotline: a telephone and web-based reporting
system that is available 24 hours a day, sevendays a week to employees and anyone who
conducts business with Gap Inc. or is affectedby our business. We have investigative teams
that log, process and address complaints
received through any channel, including our
COBC Hotline.
Key aspects of how we implement our COBC:•

All employees globally are required to takea COBC overview course within 30 days of
their initial hire date.

•

We provide ongoing compliance training
to relevant employees on topics of
nondiscrimination and harassment,
wage and hour compliance, workplaceaccommodations, anti-corruption,competition law compliance, and data
privacy and security. Our Global Integrity
team also conducts periodic live training
sessions throughout the year.

•

We provide a variety of online self-help
tools for compliance education andcommunication, including guidance
for leaders on how to have effective
conversations with their teams, FAQs,
policy links and contacts.

••

Our Global Integrity team conducts
annual interviews with employees invarious business units and offices
and select suppliers. These interviews
allow us to gauge how well our
employees understand our COBC,
remind employees and suppliers of their
responsibilities and our expectations of
how we engage with one another, andensure that employees know how toreport COBC violations.
Senior-level employees must certify
their COBC compliance annually andare briefed on relevant compliance andintegrity topics to raise their awareness.

We are diligent about addressing corruption
risks, particularly in developing countries
with limited rule of law. We have acompanywide program for monitoring,
enforcing and addressing any issues related
to our Anti-Corruption / Anti-Bribery
Policy, which combines elements from our
COBC with anti-bribery requirements under
the Foreign Corrupt Practices Act (FCPA)and other similar laws around the world.
The policy and related training programs
help employees recognize and avoid corrupt
business practices in all aspects of Gap
Inc.’s business.
Learn more
> Code of Business Conduct (COBC)> Policies

DATA PRIVACY
We believe that trust is a cornerstone ofa great brand and respecting the privacy
rights of our customers and employees is
an integral part of building that trust. Our
comprehensive privacy program includes
policies, standards and practices focused on
keeping the data we collect secure andrespecting privacy rights around the globe.
As a global company, 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 fortheir clarity and simplicity, and we continue
to put privacy at the center of our customer
experience.
Maintaining brand trust is paramount as we
continue to embrace technology. Our goal isto provide the highest quality experience to
our customers while respecting theirprivacy. We have adopted sevenprinciples that guide our choices as we
adopt new products and services. These
principles include consent, control,
fairness, minimization, confidentiality,
access and accountability. We also knowthat security is at the center of any good
privacy program. We use widely accepted
security standards and practices to guideour decisions around securing personal
information.
Learn more
> Privacy Policy

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Stakeholder Engagement
Advancing progresson systemic issues in
the apparel sector –such as water access,climate change, women’s
empowerment, and safeand fair working conditions– demands collaborationand jointly developed
approaches.

We have a multitude of key stakeholders: thepeople who make our clothes, customers,
suppliers and facilities, employees, unions,
governments, multilateral institutions, NGOs,
industry associations, investors, communities
and others. We also belong to a numberof organizations that enable us to more
effectively collaborate with and learn fromstakeholders. Multistakeholder initiatives
bring together organizations and people fromdifferent sectors, all of whom play a key role infinding new approaches and creating collective
action.

We engage stakeholders
and establish partnerships
with diverse groups ofexperts and organizations
to more clearly understandcomplex issues and local
conditions in the countries
where we do business.
This dialogue helps us to
improve our programs,
refine strategies, reveal
unexplored issues andscale industry solutions.

Having operated a variety of facility-focusedprograms in the 25 years since our Global
Sustainability team was established, we
have developed a comprehensive networkof stakeholders on whom we rely for insight,
guidance and accountability.
One area where stakeholder engagement
has supported progress is improving labor
standards in our supply chain. We regularly
partner, both formally and informally, with abroad set of stakeholders to help us ensurethat we are maximizing our impact. These
stakeholders range from local trade unions
in the countries from which we source, tointernational NGOs and multilateral institutions,each with a specific expertise and focus.
Within this diverse group, our approaches andpractices are not always agreed upon, but weremain open and willing to work with any entity,
provided it will help us achieve our objectives:to improve worker well-being, labor standards,
working conditions and the overall social
performance of our suppliers’ facilities.

Our approach to working with stakeholders
is guided by both a proactive engagement
strategy, and our belief that it is importantto respond to any credible inquiry that isrelevant to potential misconduct in our supply
chain. Our Global Partnerships team, alongwith our Supplier Sustainability team, is
responsible for managing and implementing
our stakeholder engagement strategy, andis in regular dialogue with expert labor andhuman-rights organizations around the world.
Our Supplier Sustainability team engages with
community-based organizations, NGOs andtrade unions at the local level enabling themto gather insight into facilities’ employment
practices and working conditions. This insighthelps augment the findings we gather throughthe assessments, training and surveys that we
conduct at our suppliers’ facilities around theworld. These networks and the issues that they
surface are one of the primary inputs into how
we evolve and improve our programs focusedon catalyzing improvements in labor standards
and working conditions.

With over two decades of experience inengaging stakeholders, we know there
is no single formula for the frequency ormode of engagement that we pursue. We
balance regularly scheduled meetingsand calls – to systematically capture andrespond to stakeholder feedback – with
dialogue and engagement in the moment
as issues arise. Importantly, we havedeveloped the relationships and connections
necessary to bring a broader perspective andmultistakeholder approach to the issues withwhich we wrestle.
Learn more
> Our stakeholder-engagement approach> A full list of our initiatives and partnerorganizations

When issues arise, we seek to work with
suppliers, unions, worker-representative
organizations, and local and internationalNGOs that have expertise and connections inthat area. Our aim is to prioritize the impact
on affected parties and come to a resolutionthat is fair and ethical given the events thattranspired. We take what we learn fromthese experiences to continually improve ourprocesses and protocols in responding tofuture issues, and seek to partner with otherbuyers, governments and stakeholders toapply these lessons more broadly.

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AppendixSocialOur Employees:
Talent20

Equality + Belonging		

22

Employee Engagement

27

This Way Ahead: First Jobs

29

Supply Chain + Communities:
Supplier Sustainability		32

Assessment + Remediation

33

Capability Building		

39

P.A.C.E.: Empowering Women 43

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TalentOur business success depends on our people.

OUR APPROACH

We cultivate a culture that attracts and engages talented
employees and gives them opportunities to achieve
their work and life goals, and we provide programs andcustomized experiences to help our people achieve theirfull potential.

Our workplace culture and benefits aredesigned to meet the professional andpersonal needs of our employees and theirfamilies.

Our talent practices are aimed at developing a diverse
pipeline of employees, giving individuals new challenges tohelp them grow into roles with greater responsibility, andcultivating great leaders who can build great teams. We
believe in our employees’ potential and provide myriad
career opportunities for those who want to learn andgrow with us.
Learn more
> How we help our employees realize their potential

Over the years, we have built on our
foundation of putting people first. This includes
improving wages and scheduling practices
so that the people who work in our stores
experience greater stability and flexibility.
We also offer financial incentives, work-life
integration and benefits that help employees
make the most of their professional andpersonal lives. This all supports employees

and increases their engagement at work,
which contributes value to our business.
We invest in new programs to expand andenhance our training programs and resources
and we are adopting a new approach toseeking employee feedback: more frequent
surveys that help us check the pulse of ourpeople and respond more quickly to theirneeds.
Looking ahead to 2020 and beyond, we will be
exploring strategies and programs focused onbuilding the workplace of the future, with ourpeople at the center.

Old Navy Named a 2019 Best Workplace in RetailGreat Place to Work and Fortune named Old Navy on its list of 2019 Best Workplaces
in Retail for the third consecutive year, an honor that came the same year the brandcelebrated its 25th anniversary. Great Place to Work, the global people analytics andconsulting firm, determined the honorees based on the results of an anonymous surveyof more than 694,000 employees working at Great Place to Work-certified organizationsin the retail industry.
In 2019, Old Navy focused on fostering a purpose-led culture by creating powerful
moments that bring fun and creativity into work every day. As part of its 25th birthday
celebration, Old Navy demonstrated its core value of belonging by being the first retailer
to extend the Open to All pledge beyond the U.S. to Old Navy stores in Mexico andCanada. Old Navy is one of the founding partners to sign the pledge, which is a public
commitment to protect customers from discrimination. Old Navy is proud to be open foreveryone, and open to ideas, differences, dialogue and change.
The brand has also invested in employee programs focused on learning, creativity andwellness. Old Navy is home to Gap Inc.’s successful This Way Ahead program (p.29),
which helps young people with barriers to employment obtain their first jobs.

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Talent
BUILDING TALENT
We invest in Gap Inc. people at every level ofour organization through accessible resources
and structured training programs that offer
all employees opportunities for development.
By delivering best-in-class training, we aim to
inspire and engage Gap Inc. talent througha consistent framework that empowers
employees to drive their work forward whilebuilding strong relationships.
Our enterprise-wide approach to building talent
meets employees wherever they are on theirprofessional journey: individual contributor,
new or seasoned manager, director or
executive.
We create, manage or offer over 16,000
courses for employees that cover a range ofsubjects: goal setting, how to be a great boss,
situational leadership, unconscious bias andinclusive leadership, how to have powerfulconversations and more. Our enterpriselearning efforts combine classroom-based
experiences with virtual learning, homework,hands-on workshops and ongoing learning
opportunities.
In 2019, we expanded our training for midlevel managers through a one-to-one coaching
program that prepares these managers forsenior leadership roles. Through a virtual
platform, employees ranging from manager
to vice president connect with experienced
coaches to receive customized guidance
that takes into account each participant’s
unique situation. In 2019, over 150 employees
benefited from coaching and 89 percent ofparticipants reported reaching their coaching
objectives.

In 2019, we also continued our LinkedIn
Learning program for the second year,
providing employees with access to
micro-courses on topics from strategic
thinking and mental agility, to equality
and belonging and communicatingwith confidence. Through this platform,
employees can work through courses
based on their development interests andrecommendations by Gap Inc. and theirpeers. To date, over 4,000 employees
have accessed the platform and since its
October 2018 launch, our employees haveviewed more than 40,000 courses.

GREAT BOSSES
We know that one of the primary reasonspeople stay in their jobs is because they
have great bosses. Great bosses build
great teams, and great teams contribute
great value to the company. We focus ondeveloping our leaders’ ability to connect,
listen to feedback and continually improve.
Our Great Bosses program focuses on
10 practical ways our people can “bossbetter,” like rewarding successes; being
honest, curious, and open-minded; andunderstanding that progress is better thanperfection.
Additionally, our Great Boss Survey is avehicle for managers to receive actionable
feedback directly from the people they lead.
In the spirit of continuous improvement, we
conduct this survey twice a year and theresults go directly to managers.

EMPLOYEE OPINION SURVEY
We value our employees’ feedback and use
opinion surveys as a critical component of
our ongoing listening strategy. We use these
insights to understand what is important to ouremployees and to determine where we should
focus our investments and build new programs
and strategies that help us create a thriving,productive work environment.
We are modernizing our approach to soliciting
employee feedback, shifting from an annualcompanywide opinion survey to more frequent
pulse surveys on topical issues. This allows
us to capture real-time data so we canunderstand and respond faster to employees’
immediate needs. We now issue surveys torepresentative samples of employees basedon the topic, with an aim to have all employees
participate in at least one survey every quarter.
Each survey is fewer than 20 questions,and we share results through our ongoing
employee communications.

FIELD TO HQ
Fueling our entry-level headquarters roles withincredible talent is important to our success,and field employees are a key source of talent
for these roles.
Our diverse field employees work withcustomers every day and understand what
they need and want. Their connection tocustomers and understanding of how ourstores work is invaluable at our headquarters.

72%
employee opinion survey
participation(up from 62% in 2018)81%
employees reported
active engagement(up from 69% in 2018)

We have always encouraged hiring store
employees to our headquarters teams and,in 2017, formalized a program in which
we actively market opportunities to store
employees, support candidates through therecruiting process, and provide a custom
onboarding experience to ensure a successfultransition. In 2019, 1.5 percent of our entrylevel headquarters roles were filled by field
employees. Though we had a goal to fill 20
percent by 2020, shifting corporate priorities
have led to uncertain hiring needs, making it
challenging to meet this goal.

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Equality + Belonging
Since our founding, we have embraced core company values
that include celebrating individuality, diversity and treating
all people equally – with respect, dignity and fairness.
Being an inclusive company is both a moral and a business
imperative: It sends a message to the world that we standfor equality for all and that business can and should be aforce for good. And it makes us a better, stronger company
that reflects and serves the world in which we operate.
We know we are not perfect, but we are committed tomaking the necessary changes within our company andbeyond. We see an opportunity to stand alongside our
employees and other industry leaders to work toward
greater equality and a sense of belonging for everyone.
This helps our company attract and retain the best
employees, create great products for all of our customers,
foster creativity and innovation, and contribute to a more
inclusive and just world.
Our ongoing empowerment, employee and workforce
programs support the rights and well-being of the people
who embody and drive our business, ensuring they
have equal opportunity and support to develop – both
personally and professionally. Our new commitments,
made in 2020, reflect our ambition to do better, listen
more and drive greater change – starting within ourcompany and using our influence to enact systems change.
We are devoted to creating a culture of belonging for ourteams, our customers and future generations.
Learn more
> Our commitment to equality and opportunity

Banana Republic's inclusive rangeof nude necessities –True Hues –is designed for every skin tone.

New Goal

New Goal

Double the representationof Black and Latinx
employees at our U.S.
headquarters offices
by 2025

Increase the representationof Black employees in U.S.
store leader roles by 50%
by 202514%

9%Black + Latinx
employees at our U.S.
headquarters offices

Black employees
in U.S. store leader roles2019 baseline

2019 baseline
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Equality + Belonging
OUR APPROACH

Step 1

Step 2

Step 3We have a long history of striving
for equality, and in 2019 and 2020,
deepened our commitments andengagement, elevating our ambition
in response to rightful calls that real
progress on racial justice is long overdue.
In addition to continuing our strong
programs and resource groups that foster
diversity and inclusion, Gap Inc. hastaken three important steps in 2020.

First, we acknowledged that we have morework to do, taking time to listen to feedback
from our employees. We appreciate those
who engaged in these conversations –they have helped our company understandmore deeply what it means to be an ally.

Those conversations informed our second
step: setting bold new commitmentsthat will foster change in our company
and beyond. We have establishedcommitments in three areas (below).

The last step we have taken is toward greatertransparency. Since 2007, we have publicly
reported our global employee gender data andoverall U.S. race and ethnicity data. Startingin 2020, we will regularly share additional dataon how our employees identify their race andethnicity at both stores and headquarters. We
will also create a new Equality and Belonging
report in 2021 to talk openly about ourprogress and the lessons we have learned
along the way.

Commitment 1: Our Employees

Commitment 2: Our Brands

Commitment 3: Our Communities

By 2025, we will double the representation ofBlack and Latinx employees at all levels in our
U.S. headquarters offices, and increase therepresentation of Black employees by 50 percent
in store leader roles in the U.S. We are proud toemploy a 76-percent female workforce globally, andthat 56 percent of our U.S. staff identify as peopleof color.

We believe it is our responsibility to ensure thateveryone feels seen in the products we make andsell.

The third pillar of our commitments relates tosystems change. We see three opportunities for
Gap Inc. to support progress beyond our business:through civic engagement; investments that improve
the apparel industry’s accessibility and talentpipeline; and policy and advocacy aimed at ending
racial inequality.

But we have more work to do to fully represent thecommunities we serve. Improving representationis one step, but hiring the right talent is notenough. We will continue our efforts to cultivate
a deep sense of belonging, and also increase
our investment in pay equity. Since 2014, wehave conducted annual reviews of our pay databy gender and, starting in 2020, we will have an
external firm assess our pay data by race for all
U.S. employees. We are committed to fixing any
disparities we find.

Our brands are committed to building and expanding
initiatives such as True Hues, a product-inclusion
strategy with a focus on Black consumers. It iscurrently developing capsule collections featuring
Black designers and artists. True Hues was initiatedby the Color Proud Council, a cross-enterprise bodyfounded by employees in 2018 to focus on inclusion
in product design, merchandising and marketing. In
2020, we formalized the Color Proud Council within
our brands as a critical and necessary partner inachieving a 'best product, best experience' approachto the product life cycle. Our brands are committed
to creating online and store experiences thatauthentically serve all customers and communities
and amplify Black voices. We are also including antiracism training as part of our ongoing employee- andcustomer-belonging initiatives.

We are making it easier for our employees toparticipate in the democratic process, including
providing paid time off for voting. We are also
partnering with organizations such as Open to All,
the NAACP and Embrace Race to engage with ourcustomers, schools and communities on racism andsocial justice. Our longstanding This Way Ahead
program (p.29), 95 percent of whose alumni
identify as people of color, is helping to create adiverse pipeline of talented future leaders. We arealso proud to continue our partnership with Harlem’s
Fashion Row to champion the next generation ofdesigners.

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Equality + Belonging
EQUALITY + BELONGINGNETWORK GROUPS
Gap Inc. Equality + Belonging Network Groups
are employee-led, company-sponsoredcommunities representing employees fromdiverse backgrounds. They express, represent
and advocate for equality and belonging for
Gap Inc. employees.
These groups provide opportunities for crosscultural learning, mentoring and relationshipbuilding. They organize networking andvolunteering events to encourage belonging,
foster awareness of under-represented
groups, and provide personal and professional
development.
Our network groups also help build aworkforce that reflects our customers and thecommunities where we do business, aswell as develop a company culture thatembraces differences and individuality.
Gap Inc. proudly supports the following
Equality and Belonging Network Groups:

•
•
•
•
•
•

AANG: African American Networking
Group
ASIA: Asians Supporting Inclusion andAwareness
GEAR: Gay Employees, Allies andResources, an LGBTQ employee andally group
Gap Parents
GAPWIL: Women in Leadership
HOLA: Honoring Our Latino Ancestry

Learn more
> Equality + Belonging Network Groups

TRAINING + RESOURCES
Inclusion Training
In 2017, we launched a series of unconsciousbias trainings to employees that we expanded
to our global workforce in 2018. We also
created curricula and accessible resourcesthat support equality and belonging. We want
our leaders and employees to identify how
unconscious bias and other issues present intheir everyday work. Through our commitment
to the CEO Action for Diversity & Inclusion,
we continued to provide unique and engaging
education opportunities.

Be One. Get One.
At Gap Inc., we value mentorship as adevelopmental process that helps build
incredible careers. We view it as a personal
journey that works best when people connect
organically, instead of relying on matchingsystems and formalized reports. In 2018, welaunched our Be One. Get One. program toempower employees to take an active role intheir own development and the developmentof others.

SUPPLIER INCLUSIONPROGRAMWe are committed to increasing the diversityof the suppliers we use, helping diverse
businesses become competitive industry
leaders and enhancing the economic vibrancyof the communities we serve. Our Supplier
Inclusion Program, launched in January 2018,provides a framework to increase our workwith companies that are owned by or employ
a large percentage of minorities, veterans,
women and people with disabilities. Throughthis program, we are forming new partnerships
to expand our networks to connect with a morediverse set of companies.
Learn more
> Supplier Inclusion Program

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Equality + Belonging
PUBLIC COMMITMENTS

AWARDSUN Human Rights LGBTI
Corporate Standards ofConduct for Business

Bloomberg Gender-Equality Index
As a company working for a more equal, diverse
and inclusive future for all, we’re proud to be
included in the 2019 Bloomberg GenderEquality Index for the second consecutive year.
Bloomberg listed Gap Inc. as one of 230 global
companies committed to transparency in genderreporting and advancing women’s equality.

As the first global apparel retail company
to sign on to the standards, we bolstered
our efforts to support and lead on issues
that impact the Gap Inc. lesbian, gay,bisexual, transgender and intersex (LGBTI)
community around the world.

CEO Action for Diversity & Inclusion

Open to All

In August 2017, we took the pledge, committing
to advance diversity and inclusion in theworkplace. The pledge aims to rally the business
community to work collectively toward that goal
and outlines a specific set of actions, such as
unconscious-bias education. Companies areencouraged to share practices for cultivating atrusting environment where all ideas are welcomeand employees feel comfortable and empowered
to discuss diversity and inclusion. In 2019, we
hosted the Check Your Blind Spots UnconsciousBias Tour, which offered a unique, technologyenabled multimedia experience focused on blind
spots that can potentially influence everyday
decision making.

In October 2018, Gap Inc. and our family ofbrands announced that we joined a coalition of
advocacy organizations and companies by signing
the Open to All Business Pledge. The pledge
reaffirms that our workplaces and stores arewelcoming spaces for everyone, and each U.S.
store displays the Open to All sticker.
For us, this is nothing new and is in line with our
Code of Business Conduct and Zero Means Zeropolicy. We are proud to join with other businesses
and national social-justice groups like the NAACP,
HRC, ACLU and Anti-Defamation League to showthat we are open to all.

Refinitiv Diversity & Inclusion Index
Gap Inc. was named one of the world's mostdiverse and inclusive companies for the third
consecutive year in Refinitiv's Diversity& Inclusion Index, previously produced byThomson Reuters. Gap Inc. was ranked ninth
out of 7,000 international corporations, according
to Refinitiv, which scored companies acrossfour key categories: diversity, inclusion, people
development and news controversies.

Human Rights Campaign
Corporate Equality Index (CEI)
For the 14th year in a row, in 2019, Gap Inc.
received a perfect score on the CEI, an annual
benchmarking survey and report on corporate
policies and practices related to lesbian, gay,bisexual, transgender and queer (LGBTQ)
workplace equality.

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Equality + Belonging
WORKPLACE DATA

Ethnic Diversity

We believe diversity increases creativity andinnovation, promotes high-quality decisions
and enhances economic growth.
We track and disclose data on comparable
workplace information to enable us tomonitor trends and the effectiveness of ourstrategy.
In an effort toward greater transparency,
we will regularly share additional data on
how our employees identify their race andethnicity at stores and headquarters througha new Equality and Belonging report to bereleased in 2021.
Learn more
> Workplace Data

56%
of U.S. employees identify
as people of colorWhite
All Employees
Management		
New Hires		Asian
All Employees
Management		
New Hires		

Promotion Rates by Gender

Gender Representation

United States*

United States

Global20162017 2018 2019

48%
72%
44%

47%
71%
41%

7%
10%
6%

7%
10%
6%

45% 44%
69% 68%
41% 41%

7%
10%
6%

7%
11%
6%

Black
All Employees
Management		
New Hires		

19%
6%
24%

20%
6%
25%

19% 18%7%7%
24% 23%

Hispanic
All Employees
Management		
New Hires		

21%
10%
19%

22%
11%
21%

24% 25%
12% 12%
22% 23%

Other Minorities*
All Employees
5%Management		
2%
New Hires		
6%

5%
2%
6%

5%
2%
7%

All Minorities
All Employees
Management		
New Hires		

54%
29%
58%

55% 56%
31% 32%
59% 59%

52%
28%
56%

5%
2%
7%

*U.S. full-time and part-time, non-seasonal
employees. Data on ethnic diversity is not available
outside the U.S.
**Other Minorities include: American Indian, PacificIslander and 2+ races.

2016 2017 2018 2019

		2016 2017 2018 2019

VP + Above
Women		
Men		

51%
49%

50%
50%

54%
46%

58%
42%

VP + Above
Women		3%Men		7%

4%
11%

3%
8%

1%
3%

Sr. / Director
Women		
Men		

61%
39%

61%
39%

62%
38%

62%
38%

Sr. / Director
Women		10%Men		12%

9%
6%

7%
6%

6%
7%

Sr. / Manager
Women		
Men		

61%
39%

61%
39%

59%
41%

58%
42%

Sr. / Manager
Women		16%Men		14%

13%
13%

11%
7%

12%
11%

Store Management
Women		
68%
Men		
32%

68%
32%

70%
30%

72%
28%

Professional
Women		7%Men		8%

8%
8%

8%
8%

8%
8%

New Hires
Women		
Men		

74%
26%

74%
26%

74%
26%

75%
25%

Overall
Women		7%Men		8%

8%
8%

8%
8%

8%
8%

Overall
Women		
Men		

75%
25%

76%
24%

76%
24%

76%
24%

Promotions are defined as movement to a highergrade level. Promotion rate is the number ofpromotions during the year, divided by the average
headcount for that year.

76%
female workforce
globally
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Employee Engagement
We empower Gap Inc. employees to support the potentialof people in their communities through donations of time,
talent and money.
Every year, we work to ensure that our legacy ofcommunity involvement remains strong and we areproud that this spirit is ingrained in our company culture.
Encouraging our employees to volunteer or donate helps
build strong communities as well as attract and retain
talented, engaged people for Gap Inc.
Getting involved in the community is easy for our
employees, as we build in time for them to volunteer: Allsalaried employees can volunteer five hours per month“on the clock.” In addition, we match donations of bothtime and money so employees can support the causes
they care about in the way that works best for them.
We measure the dollar value of employee donations oftime and money, and the company match to both; werefer to this aggregate as “employee-driven community
investment.”
Learn more
> How we invest in others and ourselves

2019 PROGRESSIn 2019, we are proud that through the effortsof our global team, we met our goal for
employee volunteer hours, even as we fell
short of our larger employee-driven community
investment goal. In total, 28 percent of ourglobal employees logged more than 350,000
hours volunteering.
Despite shortfalls in our employeeengagement goals, which came during a yearof significant change across our business,
we are proud of the employee volunteer anddonation efforts that have helped us exceed
these goals in past years, and we especiallyvalue the contributions that have come during
more difficult years such as 2019.
We are pleased that our network of 2,700
Community Leaders is still running strong.
These individuals serve as Gap Foundationambassadors and drive volunteerism forteams in our stores, corporate offices anddistribution centers around the world. They
also build partnerships with local nonprofits –relationships that frequently span many years
and move beyond good intentions, deliveringtrue impact by leveraging the expertise of ourworldwide teams.
We are also energized by the enthusiasm
displayed by our global employees incompanywide campaigns like our Volunteer
Rally, during which individual districts andregions, as well as teams from Gap Inc.
headquarters compete to achieve the highest
employee participation over the course of six
and a half weeks. In 2019, teams participatedin a variety of causes, from an Old Navy teamin Mexico that decorated a playroom in achildren’s hospital, to staff in India who planted
trees, donated blood and distributed mealkits to those in need. In total our employees
around the world contributed 67,000 volunteer
hours during the rally. As an added incentive,
any region with three or more employee
volunteers from every store in that region
received a $2,500 grant from Gap Foundation
for the nonprofit of their choice, and the teamwith the highest participation also received
a grant for the nonprofit of their choice. In
addition to the volunteer hours, this campaign
supported $19,000 in Gap Foundation grants
to charities including Kids Door in Japan,
Operation Smile in China, and SacramentoChildren’s Home in California.
In recent years, we have evolved ourapproach, integrating our ability to giveback even more deeply into our culture
and expanding our notion of what it means
to give back. Beyond donating time andmoney, we have used campaigns such as#LoveYourWater (p.50) to encourage
employees to think more broadly about all theways that they can have a positive impact intheir communities through choices that they
make in their daily lives.
Today, each Gap Inc. function has at least one
representative on our Employee Engagement
Committee. These representatives are
responsible for setting goals for volunteer
hours, employee participation and total
employee-driven community investment.
We share monthly reports with these
representatives to help keep teams
accountable for their goals.

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Employee Engagement
Goal

Support $15 million in
annual employee-driven
community investment*
Employee-Driven
Community Investment

2019 Employee-Driven
Community Investment

25% of Gap Inc. employees
volunteer annually% Employees Volunteered$12.2M

2017 $14.8 M

2017 23%2018 25%2018 $15.6 M

2019 28%2019 $12.2 M
Ongoing
Goal$15M*Comprises volunteer hours,
employee financial donationsand Gap Inc. matching of timeand money

Key Metric

OngoingGoal$9M in volunteer hours(the financial equivalent ofover 355,000 volunteer hours)

25%$1.1M in employee
financial donations$2.1M in Gap Inc. matching ofvolunteer hours + employee
financial donations

Key Metric

Gap Inc. employees log
430,000 volunteer hours
annually
Employee Volunteer Hours
2017 421,000
2018 431,000
2019 355,000
Ongoing
Goal

430K

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This Way Ahead: First Jobs
This Way Ahead is opening doors for the next generation
with first jobs, mentoring and building the confidence
needed to make their dreams a reality.
Through structured training and paid work experience at
our stores and distribution centers, This Way Ahead helps
youth (ages 16 to 24) facing barriers to employment geta foot in the door for a life-changing first job. Beyond
a paycheck, the program gives participants life skills
and valuable first-job experience, helping to build theirconfidence for the future.

At the same time, the program builds leadership skills
among the This Way Ahead mentors, allowing our company
to grow and stay competitive while delivering benefits
across our business. Since 2007, the program has helped
Gap Inc. build a valuable pipeline of future employees whiledeveloping best practices for managing talent that can beapplied across the company.
Learn more
> How we developed our program + how we approach implementation

8,201

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have participatedsince 20072019 Global Sustainability Report

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This Way Ahead: First Jobs
2019 PROGRESSIn 2019, we saw great progress across This
Way Ahead, building on the program’s growthin 2018 through a national partnership with
the Boys & Girls Clubs of America, which
expanded the number of cities where theprogram runs. In 2019, more than 2,500 youth
participated in the program across 576 storesin 70 cities, up from 444 stores and 53 cities
in 2018.
We dedicated time to evaluating how we could
make an even bigger impact through This
Way Ahead and decided to shift the programfrom several brands in our portfolio solely
to Old Navy. Building on Old Navy’s strong
leadership in the program, its partnership with
the Boys & Girls Clubs of America, and thebrand’s presence of more than 1,200 stores,
this transition will raise our opportunity for
impact while supporting Old Navy’s businessmodel for recruiting and developing talent. For
Old Navy, This Way Ahead is the first place
to look for talent when it comes to hiring new
associates.

More broadly, Gap Inc. expects the
expansion of This Way Ahead tosupport our company goal to increase
representation of Black employees by 50
percent in store leader roles in the U.S. by2025. This Way Ahead alumni – 95 percentof whom are people of color – represent
immense potential for our leadershippipeline.
Also in 2019, we published the Gap Inc.
This Way Ahead Playbook, distilling
lessons from the program’s 10-plus years
to outline four key steps our stores cantake to find and hire untapped talent. The
playbook also includes resources like aninterview guide and a checklist for things to
do as a mentor.
Participant and mentor evaluations ofThis Way Ahead continue to demonstrate
the program’s impact, with 68 percent
of participants reporting an increase inconfidence and 84 percent of mentors
reporting improved creative-thinking andproblem-solving skills.

Karen Diosa:
From This Way Ahead Intern to
Old Navy Store General Manager
When Karen Diosa started as a This Way
Ahead intern at Old Navy’s flagship store
in Manhattan, she was a shy 16-year-old
high-school junior with a strong work ethic.
“I started working at a young age because I
wanted to both work hard for what I needed
and also be able to one day provide for myfamily,” says Diosa, whose own parents,
immigrants to New York from Colombia,
inspired her and her three siblings.

This Way Ahead alumna,
Karen Diosa, and Old NavyHead of Stores, Steve Stickel

Nine years and several promotions later, Diosahas become the first This Way Ahead graduate
to become a store general manager. “I saw
this opportunity to grow with the company, so I
said, ‘Nothing to lose here, I’ll go for it!’” Diosarecalls.

the store floor to her leadership positions. “If
it weren’t for This Way Ahead, I wouldn’t behere right now,” Diosa says. “The program
helped me come out of my shell. The Old Navyand This Way Ahead partnership is like a big
family.”Diosa, who studied health science, psychology
and sports science in college – all whileworking at Old Navy – credits Louis Reyes,
her then store director, for mentoring her fromNow Diosa is supporting the next generationof This Way Ahead interns by sharing her own
story. “I encourage them to ask questions,” shesays. “It’s very rewarding to be a role model.”2019 IMPACT**These results were reported
by a third-party evaluator.

68%

84%

72%

of youth reported
a significant increasein confidenceof mentors reported
improved creative-thinking+ problem-solving skillsof alumni have secured
stable employment
compared to 55% of their peers,
according to a study of 10 years of alumni
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This Way Ahead: First Jobs
2019 REACH + GROWTH
Youth2017 1,148

Goal

Reach 20,000 youth
through This Way Ahead
by 2025
This Way Ahead Participants

2018 1,700+

2007

2019 2,524

2016 2018
2,713 5,677

Stores

2017
3,900

2019
8,201

2025
Goal

20K

Previous goal: Reach 10,000 youth throughThis Way Ahead by 20202017 2742018 444
2019 576

Goal

Cities2017 152018 53
2019 70

Hire 5% of entry-level
employees from This Way
Ahead annually by 2025
Entry-Level Hires from This Way Ahead

2017 0.9% (668)2018 1.4% (1,107)
2019 2.1% (1,618)
2025
Goal

5%

Gloire Yahve:‘I’m all about moving up.’
When Gloire Yahve was 6 years old, she
resolved that she would be the first person
in her family to graduate from college. The
daughter of immigrants who came to Houston
after fleeing the Congolese genocide in 1999,
Yahve saw how hard her parents had to work
just to get by, sometimes holding two or three
low-paying jobs. Yahve’s father always told
her: “Education is key to a new beginning anda better life.”
Yahve’s parents gave their eight children
everything they could and would not allow
them to work so that they could focus on
their studies. So when Yahve’s godmothersuggested that she apply for This Way Ahead– and Yahve got the internship – she didn’t tellher parents. “But when I started bringing home
clothes from Old Navy for the family, they
asked if I had a job,” she says.
At first, her father was opposed to the idea of
Yahve working. But when he realized that she
was still making good grades and had earned
enough to open a savings account and start
paying for the dance lessons she had quit
years ago when her family couldn’t afford thefees, he was happy for her. She even earned
enough to help pay family bills and buy sports
gear for her siblings. “Some people say you
can’t do it all: You can’t get your siblings toschool every day, volunteer, help pay the bills,
dance and work,” she says. “But I did, and I
still do.”When she started at Old Navy, Yahve says she
was shy and reserved, but she soon learned
new skills and was promoted from her start inThis Way Ahead alumna,
Gloire Yahve

the fitting room to her current job in loss
prevention. Outside of her achievements atwork, she has continued to apply herself inschool, and was accepted into six colleges.
“I’m all about moving up,” she says,
laughing.
Yahve credits her first boss, Adriana
Fuentes, and her manager, Anthony
Cooremans, with helping her become theleader she is today. “This Way Ahead was
my golden ticket,” she says. “It’s not justabout the job. You can go somewhere elseand get paid. It’s a fresh start and a second
chance for so many kids. If I hadn’t foundthis program, if I didn’t learn how to talk to
people and make friends, I’m honestly notsure I’d even be here today.”2019 Global Sustainability Report

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Supplier Sustainability
We partner with all of our branded-apparel suppliers
and other key stakeholders – including peer companies,
employees, unions, governments, multilateral
institutions, NGOs, industry associations, investors andcommunities – to help provide safe, fair and healthy
working conditions for the women and men who create
our clothes.
Using a holistic approach, we implement a variety of
programs for monitoring facilities and building suppliercapabilities to help catalyze improvements in working
conditions, taking country-specific approaches whereappropriate. Our Human Rights Policy guides our overall
approach to developing a supply chain that is resilient,
responsive and respectful of the workers who make our
products.
Gap Inc. has developed and implemented a dedicatedprogram for assessing and remediating issues insourcing facilities; we have also established a suiteof capability-building programs focused on women’s
empowerment, social dialogue and supervisory skills.
Field teams in our key sourcing countries enable us topartner closely with facilities and local stakeholders,providing thorough, on-the-ground insight into our
suppliers' performance and the salient issues thatworkers in our supply chain face.
Our goal is to design, collaborate on and implement
industry-leading programs that drive transformative
innovation for the apparel-manufacturing sector.

Alongside our industry partners, we’re investing in initiatives
focused on a range of interventions: improving worker andmanagement relations, innovating how we assess andimprove working conditions, and using technology to directly
engage with workers and respond to their needs.
Learn more
> How we're improving working conditions

OUR APPROACH

2. Capability Building

We believe in a comprehensive approach to
improving working conditions in our supply
chain, combining facility-monitoring andcapability-building programs to help our
suppliers continually improve.

In partnership with our suppliers, NGOs
and others, we have established a suiteof programs that aim to develop facilities’
capabilities for worker representation andleadership involvement. Initiatives such as
our Workplace Cooperation Program andWorkforce Engagement Program – which
we developed with Better Work and Verité,
respectively – focus on maturing industrial
relations in facilities and providing functioning
grievance mechanisms while also measuring
and improving the degree to which garment
workers feel valued and engaged at work.
Our life-skills program, P.A.C.E., gives womentraining and support to advance in theirprofessional and personal lives. In addition
to our cornerstone programs, we manage orparticipate in a broad set of initiatives that
address country-specific labor issues.

1. Assessment + Remediation
Our approach to improving working conditions
is based on transparency, partnership andimpact. We believe that by working together,
we can achieve our commitments to improve
workers’ well-being, protect human rights,
reduce environmental impacts and improvebusiness performance.
Read more> Assessment + Remediation (p.33)

Read more> Capability Building (p.39)

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Assessment + Remediation
We monitor the adherence of the facilities operated byour suppliers to the Gap Inc. Code of Vendor Conduct(COVC) before initial approval and then annually. This is inconjunction with our efforts to build innovative programs
that create supportive, empowering workplaces.
Our Assessment and Remediation program is thefoundation on which we evaluate our suppliers’ abilities
to meet our sustainability expectations. The programprovides insight on what issues workers may be facing
and additional programs that would be beneficial. We
primarily evaluate facilities through our own field teams’
assessments and our partnership with the International
Labour Organization (ILO) Better Work (p.35) in countries
where it operates. Our global field team is locatedprimarily in the countries from which we source, giving usa direct, on-the-ground understanding of worker needs
and facility performance. We also support the adoption
and institutionalization of new industrywide tools, such as
the Social & Labor Convergence Program (SLCP) to help
assess factory performance.

We use a color-coded system to rate facilities’
performance based on assessments.
High-performing facilities with no criticaland few violations are rated green; average
performers are rated yellow; facilities thatneed improvement on one or more serious
issues are rated red. Critical, severe and key
violations have a greater negative impact
on a facility’s rating than more technical“noncompliance” violations.

Goal

In 2017, Gap Inc. set a goal to not work withany red-rated facilities by 2020. We havemade significant strides toward this goal,moving from 16 percent red-rated facilities
in 2016 to less than 2 percent by the end of
fiscal 2018. We maintained that percentageof red-rated facilities in 2019. In 2020, we will
work toward our goal of zero red-rated facilities
by continuing to build on our establishedmanagement practices, including our work with
our supply-chain partners, which has helped
us progress over the years. We create realistic
corrective action plans to help red-rated
facilities resolve their challenges and improvein a timely manner. We have learned thatsetting big goals and having the management
systems to provide visibility and accountability
leads to sustained improvement. We willcontinue to provide that visibility through tools
such as integrated scorecards that prioritize
sustainability and business performance.

2016 84%

While we didn’t reduce the percentage of
red-rated facilities in 2019, the numberof green-rated facilities increased by 6
percentage points between 2018 and 2019.
Our analysis shows that the majority of thesegreen-rated facilities are our more establishedvendors, and a good percentage of them also
participate in our capability-building programs,
including our Workplace Cooperation Programand P.A.C.E.

100% of supplier facilities
producing branded
apparel are rated yellow
or green by 2020
% Supplier Facilities
Rated Yellow or Green2017 95%2018 98%
2019 98%
2020
Goal

100%
2019 Facility Ratings

737

Facilities

45% Green-Rated Facilities
53%Yellow-Rated Facilities
2% Red-Rated Facilities

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Assessment + Remediation
We have been able to achieve successclosing out COVC violations in a sustainable,
responsible way by integrating this work
more deeply into our sourcing decisions andconcentrating our business with preferredvendors. In addition to a dedicated Supplier
Sustainability team that engages directlywith facilities on these issues and targets,
we train global sourcing employees onhuman rights policies and procedures,
building companywide awareness on COVC
requirements and collaborating internallyto manage vendor performance and drive
sustained performance. Through training
and education, we also work closely with key
vendors to build their capacity for continual
improvement and help them implement
proactive measures that will prevent COVC
issues from arising in the first place.
We have created internal systems todevelop a close partnership between our
Sustainability and Global Supply Chain
teams. This integration is supported withdata analysis, which allows us to track andanalyze major trends and the effectiveness of
our programs. When we identify concerning
trends or hot spots, we develop specific actionplans to build awareness with our suppliers,
collaborate with all affected stakeholders, andformalize systems to address the issue.
In 2019, an independent study by researchersat the University of Oxford and the Universityof Toronto confirmed that our approach ofaligning sourcing decisions and accountability
with social-compliance goals is an effectivemodel to improve supplier performanceagainst our COVC criteria. The researchers
indicated that the improvement in performance
under this aligned approach appears to begreater than when supplier sustainability andpurchasing operate independently.
We use a strict approval process to reduce
the possibility of any red-rated facility
entering our sourcing base, and we prioritize
improvements with any facilities that do slip
into red-rated categories. We are committed
to reassessing those facilities more
frequently, and we empower our teams towork with all facilities to meet our standards
and continually improve so that we can build
a high-quality supplier base. While we arepleased with the impact of our efforts toward
our goal of 100 percent green- and yellowrated facilities, we also recognize that at any
given time, some facilities may slip below our
COVC standards – and we are committed tocontinuing to monitor and work closely with
our suppliers to remediate issues. Achievinga baseline performance level allows us tokeep a closer eye on concerning issues
and focus on capability-building programs,
such as enhancing bipartite committees(our Workplace Cooperation Program) andsoliciting direct worker engagement (ourWorkforce Engagement Program).
As we strive toward our goal, we also
recognize that the best way to address mostserious issues is to partner with our vendor
or their facility to remediate. However, inthe event that a facility or vendor fails to
address persistent noncompliance or otheregregious issues over an extended period oftime, we will create a responsible exit plan.
In that case, we give notice to the facility thatorders will not be re-placed, so as to minimize
disruption to workers. In these situations, wewill continue to monitor the facility and workon pending issues through and following
deactivation.

SUPPLIER PERFORMANCE
We analyze our suppliers’ performanceagainst our Code of Vendor Conduct(COVC) and use the consolidated, countrylevel results to track and analyze progressor areas of concern for these issues. Our
analysis showed that we resolved 82 percent
of issues within 12 months, for those issues
that were open as of Feb. 1, 2019. As wemonitor areas of concern for emerging issues
or trends, we partner with our suppliers
to implement changes to our systems ordevelop new policies or programs.

82%
of COVC
issues resolved were
within 12 months

Resolution of Facility COVC Issues Open as of 2/1/2019
2/1/2019

Bangladesh
Cambodia
China
GuatemalaIndia
Indonesia
Pakistan		
Sri Lanka		
United States
Vietnam		
Other		Total

5/1/2019(3 months)

8/1/2019(6 months)

1/31/2020(12 months)

Open
IssuesOpen%
Issues Resolved

Open%
Issues Resolved

Open
Issues%Resolved

378
504
553
0
667
338
55
71
5
943
160
3,674

313
486
418
0
599
131
51
49
0
754
131
2,932

240
449
126
0
421
76
48
32
0
477
87
1,956

128
68
45
0
164
57
11
21
0
130
43
667

66%
87%
92%
–
75%
83%
80%
70%
100%
86%
73%
82%

17%
4%
24%
–
10%
61%
7%
31%
100%
20%
18%
20%

37%
11%
77%
–
37%
78%
13%
55%
100%
49%
46%
47%

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Assessment + Remediation
INTERNATIONAL LABOURORGANIZATION (ILO)
BETTER WORKSOCIAL & LABORCONVERGENCE PROGRAM(SLCP)

As part of our efforts to go above and beyond
assessment and remediation and work morecollaboratively with our suppliers and otherstakeholders, we have played a leading rolein multistakeholder collaborations such as
the ILO Better Work program. As a founding
member of this program, we view the ILO
team as our key partner in every country
where it operates, representing several of
our key sourcing markets. Better Work takes
an advisory approach to monitoring facilities,
with an emphasis on protecting worker rights
and well-being by helping companies andgovernments uphold the ILO’s core labor
standards and national labor laws. Better
Work leads facility assessments and helps
to address and remediate issues in Vietnam,
Cambodia, Indonesia, Bangladesh, Jordan,
Haiti and Nicaragua. We also work closelywith Better Work on the Better Work Academy,
which we helped found to move beyond
an “assessment-only” approach to facility
monitoring.

As a signatory to this collaboration among
apparel and footwear brands, retailers,industry groups and civil society organizations,
we support a shared data-collection tool thatassesses the social and labor performanceof manufacturing facilities across the appareland footwear supply chain and reduces the
duplication of industry efforts. In 2019, we
joined the SLCP Council and are active inworkstreams to accelerate adoption of the tool.

Read more> ILO Better Work and Supervisory Skills
Training (p.41)> Better Work Academy (p. 41)

Gap Inc. is committed to supporting the
expansion and sectoral adoption of the
SLCP; we continue to allocate resources toinstitutionalize the program across our supply
chain to promote supplier ownership of social
performance.

In 2018, we participated in a pilot program totest the first version of this tool, and in 2019,
expanded our implementation by inviting 65
mill facilities in China, Taiwan and India tocomplete the SLCP; 28 mill facilities did so. To
support the wider adoption of the tool, we haveapplied lessons from the pilots to streamline
communication and simplify materials that our
staff use to train suppliers. As the program
grows, we continue to seek new ways todemonstrate the benefits of this initiative tosuppliers.

2019 Assessments in ILO Better Work Markets
Facilities Assessedby ILO Better Work
Bangladesh
Cambodia
Haiti
Indonesia
JordanNicaragua
Vietnam
Total

33
41
6
54
4
5
94
237

69%
79%
100%
82%
100%
100%
60%
70%

Facilities Assessed
by Gap Inc.
15
11
0
12
0
0
62
100

31%
21%
0%
18%
0%
0%
40%
30%

Total
48
52
6
66
4
5
156
337

Mill Sustainability Program
Our supply chain is complex and reaches far beyond our Tier 1 suppliers– the cut-and-sew facilities from which we directly source, as well as theirsupporting embroidery, screen printing and laundry facilities. Since 2017, we’ve
expanded our efforts to monitor the social and environmental performanceof our Tier 2 suppliers – the mills that provide our fabric – through our Mill
Sustainability Program. The program puts supplier ownership at its center anduses three industry programs, including SLCP, to improve our mills’ social andenvironmental performance. The other two industry programs we use are theSustainable Apparel Coalition’s (SAC) Higg Facility Environmental Module(FEM) 3.0, and the Zero Discharge of Hazardous Chemicals’ (ZDHC) Roadmap
to Zero Programme.
Our first step on this journey was to comprehensively map the mills from which
we source raw materials and group them into three categories: preferred mills(which represent the majority of our business volume), secondary mills, andniche and new mills. We have a comprehensive understanding of our Tier 2
supplier base, mapping over 200 facilities that represent a significant portion of
our business volume. We continue to engage with them and incorporate theirperformance into our business decisions.
Read more> Mill Sustainability Program (p.54)

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Assessment + Remediation
KEY ISSUES
We are proud to support the principles
outlined in the Universal Declaration of
Human Rights (UDHR), the UN Global
Compact, the Organisation for Economic
Co-operation and Development (OECD)
Guidelines for Multinational Enterprises,
and the ILO's Core Conventions.
These principles form the foundation of our
Human Rights Policy, which defines ourapproach and activities to respect humanrights and prohibit human-rights abuses.
In addition to the programmatic updates
in this report, detailed information on
our human-rights policies, management
approach and resolution actions for key
issues is available at the links below.
Learn more
> 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 andRecruitment> Unauthorized Subcontracting

Fire, Building and Electrical
Safety Program
We established our fire, building and electricalsafety (FB+ES) program to reduce the risks
inherent in the industrial process of apparel
manufacturing. Our program is intended
to protect workers, especially in our key
sourcing countries and countries where these
dangers pose a high risk. Reducing the risk ofcatastrophic events is paramount, and we seean opportunity to avoid supply disruptions fromsmall-scale incidents that could result in lostworking days, worker injury or displacement,
and product damage.
Our approach is to lead local initiatives andpartner with other brands, when possible, tosupport scalable solutions. In recent years, wehave expanded our FB+ES approach beyond
Bangladesh, where we had focused our efforts
since 2014. In Bangladesh, we are a memberof Nirapon, the organization created to carryforward the important FB+ES improvementsthat the Alliance for Bangladesh Worker Safety
has achieved.

created improvement plans for over 74 of the
top strategic facilities that manufacture our
product.

Grievance Mechanisms
Being able to raise concerns to facility
management or to Gap Inc. is essential
to ensuring that workers have a voice intheir workplace. We have developed acomprehensive suite of programs thatprovide myriad workplace benefits andchannels where workers can effectively raisegrievances. Within each program, workers are
given a voice to raise concerns with facility
management and outside parties, via various
channels:•

Our Workforce Engagement Program(p.41) offers an approach in which
individuals can confidentially report
workplace-related grievances to facility
management via worker surveys,
interviews and messaging applications.

•

Our Workplace Cooperation Program(p.40) provides training for workers
and management on how to improveindustrial relations, with an emphasis on
how to develop and implement grievancemechanisms. Our goal is to deliver thisprogram to 200 facilities by 2020; as ofthe end of 2019, we had reached 182
facilities. We assess grievances raised via
this program, including the amount of time
taken to remediate, channels used andoutcomes.

•

Our Assessment and Remediation
program (p.33) evaluates the efficacy
and use of grievance mechanisms. Our

We joined the Life and Building Safety(LABS) initiative, which currently operates inIndia and Vietnam. In 2019, LABS assessed
15 facilities in India and 29 in Vietnam forfire and building safety. We are proud tohelp spearhead LABS’ work in its portfolio offacilities, half of which are Gap Inc. suppliers.
We have also worked with expert service
providers to conduct assessments of our own
in other key sourcing countries, including
Cambodia, Egypt, Indonesia, Jordan, Pakistan
and Sri Lanka. To date, these providers
have conducted FB+ES assessments andSupplier Sustainability team provides
contact information to workers in thefacilities from which we source, so they
are able to reach out to Gap Inc. directly ifthere are issues that require our attention.
We believe that context-specific approaches
to grievance mechanisms will increase thelikelihood that workers use them. We are in the
midst of evaluating additional service providers
that can help to implement technologybased solutions in other sourcing markets.
Additionally, we are responsive to third parties
that raise grievances with us via any of ourcommunication channels.

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Assessment + Remediation
Freedom of Association
Our Code of Vendor Conduct (COVC) andHuman Rights Policy explicitly support
freedom of association and the rights ofworkers to lawfully and peacefully associate,
organize and bargain collectively.
We use a wide range of approaches in seeking
to ensure that freedom of association rights
are respected, from supporting open dialogue
between facility workers and managers, topartnering with workers’ rights groups andtrade unions when appropriate.
In January 2018, we joined with The Arbitration
Council and ILO Better Factories Cambodia
to lead a workshop on freedom of associationfor our Cambodian suppliers and the unions
represented in their facilities. The purpose wasto improve employee-employer relationships
through a mutual understanding of freedomof association, workplace cooperation,and dispute-prevention and -resolution
mechanisms in the workplace. This workshop
included in-depth trainings for factory
management, union representatives and otherworker representatives on how they can better
partner to jointly resolve workplace disputes.
We look forward to scaling these types oftrainings in additional countries in the future.
It also provided an overview of Gap Inc.’s
Workplace Cooperation Program (p.40),
which aims to improve worker-management
dialogue at facilities. In 2019, we built on these
efforts by supporting the Arbitration Council’s
development of the “Guidebook to CambodianLabor Law,” which will be launched in thesecond half of 2020.

Also in 2019, we launched a new partnershipwith the ILO and Better Work Bangladesh. This
three-year initiative, the ILO Bangladesh Social
Dialogue Project, will be implemented by the
ILO in all facilities from which Gap Inc. sourcesin Bangladesh. It helps to build the capability offactory management, compliance staff, union
members and workplace-committee members
through training sessions on a range of topics
including: freedom of association, collective
bargaining, international labor standards, andcommunication and negotiation techniques.
It will also help to increase understandingof the Bangladesh Labour Act. In 2019, we
supported training in 28 facilities, an effort we
will continue to expand, when feasible, to meetour goal of reaching 50 facilities.

Working Hours
One of the compliance issues we frequently
encounter relates to worker overtime, which
fluctuates but remains an issue of concern
year after year. Overtime is a complex
challenge to address: Many workers want torequest overtime because they seek hours
in order to earn premium overtime pay, while
facilities seek to optimize their production
capacity across multiple buyers. In addition,buyers themselves, including Gap Inc., cannegatively impact work hours when requiringchanges that increase or decrease the size ofan order.
We continue to address the role that ourbuying practices have on overtime hours,
including through Better Buying, an initiative
to understand the impact of our businessplanning, as well as other aspects of thedesign and development process. After we
received our results, we shared our findings

with our sourcing teams, enabling them to
examine how their planning affects lead times
and our visibility into our supplier’s capacity
to fulfill orders. Gap Inc. Sourcing teams
are working to develop systems that canmore appropriately place orders depending
on our suppliers’ capabilities to fulfill them;these learnings are helping us to implement
improvements while we continue to solicit
supplier feedback.

Gender-Based Discriminationand Harassment
Women comprise the majority of the global
garment workforce, face challenges in theworkplace, especially regarding harassment.
Over the years, we have conducted regularassessments of the facilities with which
we work and have found serious violations
related to gender-based discrimination andharassment. These issues require all relevant
stakeholders in our industry to invest moretime and resources to address.

discrimination and harassment in Bangladesh,
Cambodia, China, El Salvador, Guatemala,Haiti, Honduras, Indonesia, Jordan, Nicaragua
and Vietnam. We are working with partners inthese countries to implement the training.
By the end of 2019, we had conducted training
for more than 500 facilities in our global supply
chain – about 70 percent of all facilities.
To review progress, Gap Inc. assessments
include components on POSH and determining
areas for improvement, if needed, within a
remediation plan.
Looking ahead, we will build on this program
to focus on women’s empowerment, which
we will link to Empower@Work (p.44), ourcollaborative effort with BSR HERproject,
ILO Better Work, CARE, ICRW and Walmart.
It aims to use common curriculum and bestpractices to advance women’s empowerment
and gender equity in global supply chains.

To help move the needle, in 2018, Gap Inc.’s
Supplier Sustainability team worked with our
suppliers in India. We helped them build anenvironment where they clearly define andimplement policies on Prevention of Sexual
Harassment (POSH) and create an Internal
Complaints Committee, both of which arerequired under local law. Our aim was to help
our suppliers raise awareness about this issue
and the rights and responsibilities of male andfemale employees, including managers.
Given the urgency and importance of thisissue in other key sourcing countries, wehave taken our learnings and expanded
these trainings to address gender-based

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Assessment + Remediation
Child and Forced Labor
We continue to maintain a strong focus onprotecting human rights, including issues
such as forced and child labor. Under nocircumstance is it acceptable for child, forced
or trafficked labor to be employed within
our operations or used in the production of
any Gap Inc. product. Recent legislation
has supported global awareness and weannually report our actions to uncover andprotect against these issues within our 2019
U.K. Modern Slavery Act and California
Transparency in Supply Chain Act disclosures.
While we have not discovered instancesof forced or child labor in our supply chain
in recent years, we remain vigilant about
these issues and detail our comprehensive
management approaches to both.

As part of our deep commitment to responsible
and ethical practices and our strict policies
against the use of involuntary labor of any
kind in our supply chain, we are monitoring
concerns about China’s Xinjiang Uyghur
Autonomous Region (XUAR) region, wherea significant amount of the world’s cotton
is grown and spun. We can confirm that
we do not directly source any materials or
garments from the region and we are taking
steps to better understand how our global
supply chain may be indirectly impacted.
This includes working with our suppliers andactively engaging with industry trade groups,
expert stakeholders and other partners to learn
more and advance our shared commitment torespecting human rights.
Learn more
> California Transparency in Supply Chains
Act / UK Modern Slavery Act Statements

Uzbek and Turkmen Cotton
It has been well established that the governments of Uzbekistan and Turkmenistan
have long relied on forced child labor and/or forced labor to harvest their country’s
cotton. We have worked to educate and influence our suppliers and facilities on
this issue, making it clear that we will not accept any clothing manufactured withfabrics that were made from Uzbek or Turkmen cotton. We were pleased to readreports from the ILO that acknowledged significant improvements in Uzbekistan’s
cotton sector. We recognize that further reforms are necessary, but we are pleased
to see progress on this critical issue.

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Capability Building
We work with our manufacturing partners to implementa suite of programs aimed at providing the tools andresources to continually improve industrial relations, worker
engagement and facility compliance.

Together, these programs provide a comprehensive andholistic engagement model for facilities to improve labor
standards, benefit workers, and support the business
continuity and resiliency of our supply chain.

When we approach our suppliers about human rights andworking conditions, we are sharing our conviction in enabling
safe, productive and responsive workplaces. We seek towork with facilities where workers feel valued and engaged
at work, where they have a voice to express concerns andsee their grievances addressed, and where workers andmanagers can communicate effectively.

Learn more
> How we're working with suppliers

Gap Inc. coordinates with external partners – including
NGOs, unions, multilateral agencies, peer companies andsuppliers – to deliver our P.A.C.E. program, Workplace
Cooperation Program, Workforce Engagement Programand Supervisory Skills Training. These programs can help
empower women workers, enhance industrial relations infacilities, provide functioning grievance mechanisms, stabilize
our sourcing operations, and create platforms for measuring
and improving the degree to which garment workers
feel valued and engaged at work. These complementaryinterventions can be implemented alone or together
depending on a facility’s needs.
In addition, we participate in broader initiatives that support
the individual programs, including the Better Work Academy
and the Better Than Cash Alliance’s digital-wage program.
These can be implemented in available markets to heighten
our suppliers’ ability to adapt to their workforce's needs.
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Capability Building
WORKPLACECOOPERATION PROGRAM
Our Workplace Cooperation Program (WCP)
facilitates dialogue between workers andmanagement to address workplace issues,
from overtime and worker well-being, towashroom sanitation and better-quality food in
the canteen. This training program works withelected bipartite committees, comprising both
workers and management representatives
who collaborate to build good industrial
relations. Inherent in this training program is arecognition that workers in many facilities do
not feel comfortable voicing their grievances in
the presence of upper-level management. Our
approach, designed in partnership with ILO
Better Work, seeks to address those relations
by developing the skills of committee members
and to help guide effective meetings. We also
provide guidance on how to best respect andabide by workers’ fundamental rights at work,
as defined in the ILO’s Core Conventions.
In 2019, we focused on expanding and refining
this program, as well as analyzing data that wecollect quarterly. Since launching the programin 2016, we have reached 182 facilities – 61 in2019 – in 11 countries. We continue to expand
to our strategic vendors’ owned and subcontracted facilities for even greater impact.
Our goal is to reach 200 facilities by 2020.
Building on changes made in 2018, we havecontinued to offer an abbreviated training
period of 12 to 16 months instead of two
years. This gives facilities more flexibility inoffering the training modules, as teams can
opt to combine two half-day training modules
into one all-day training, reducing the time forprogram completion.

We also continued to use the dataassessments we launched in 2017 to
examine how many grievances have been
received and addressed, which channels
were used, and how long it took to address
the issues. Our analysis shows that once
functioning bipartite committees are inplace, workers feel more empowered toraise concerns, and that these concerns
are more quickly addressed. In addition, ourdata show that once these committees havebeen trained, grievances rise for a period
and then diminish in frequency, illustrating
the comfort workers feel in voicing
complaints and the subsequent actions
taken to address their concerns.
We believe that improving worker andmanagement relationships and addressing
workers’ concerns can increase morale,
which could improve our suppliers’ businessperformance. To understand whether the
WCP is indeed impacting productivity,
efficiency and quality among our suppliers,
we have been collecting data for analysis.
We created a quarterly data-collection tool
and asked participating facilities to track andshare data on business indicators, such as
absenteeism, number of grievances andproductivity.
In 2019, researchers from York University
and Better Work conducted an evaluationof the program, revealing that the training
has translated into workplace improvementsin three areas: communication andcooperative work relationships, enhanced
ability for workers and managers to address
workplace concerns, and a better businesscase for workplace cooperation. Workers
reported feeling more motivated, safer intheir work environment and happier coming
to work. They also reported feeling that they
were listened to and had a voice in decision
making.

Key Metric

Reach 200 supplierfacilities with our
Workplace Cooperation
Program by 2020
Supplier Facilities Reached with WCP

8,323

grievances raisedby workers in facilities
participating in WCP
from 2018-2019

88%

2016 31

issues resolved
within thesame quarter2017 69
2018 1292019 182
2020
Goal

200

11%
repeat issues
This data is self-reported by factories on aquarterly basis. It includes grievances reported
through any mechanism (i.e. suggestion box,
bipartite committee, union, hotline/helpline,
mobile app, HR or a supervisor, an external partyor any other mechanism).

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Capability Building
SUPERVISORYSKILLS TRAINING
We have continued our partnership with ILO
Better Work on Supervisory Skills Training(SST), which we launched in 2018 to engage a
key group of employees: mid-level managers.
This program helps facility managers improvetheir communication with workers, who typicallycontact middle management first to discussproblems or make suggestions to improve
working conditions. SST fills an important gap
in management training, since many facility
supervisors are promoted based on technicalskills, but are not provided training in the people
skills that are critical for effective management.
The three-day training program is designed
to give supervisors and middle managers adeeper understanding of important leadershipand supervisory concepts: being a professional
supervisor, building good relationships,
influencing and managing workers effectively.
Participants are trained to avoid a passive or
authoritarian style of leadership, and instead
strike a balance between the interests of thecompany and the interests of staff. As a result,
we expect participating supervisors to shift their
management style from “timid" or “domineering"
to "professional," yielding higher worker
motivation and retention, and ultimately more
efficient production.
In 2019, our team trained 1,298 supervisors– nearly triple the number trained in 2018. Asof 2019, 111 facilities in seven countries wereactive in the program. In Better Work countries,
where Better Work delivers the training, we
also encourage our facilities to nominate theirsupervisors to participate in SST.

In 2019, we implemented a program-evaluation
methodology that uses supervisor and worker
surveys and production-efficiency data fromfacilities to measure several things: the extent
to which participants reported trainings to beeffective, the extent to which they learned
new concepts, whether this learning led
to any behavior change, whether workers
acknowledged that change, and whether
behavior changes impacted production
efficiency.

WORKFORCEENGAGEMENT PROGRAM
By engaging workers to amplify their voices
and understand how they feel at work, theWorkforce Engagement Program (WEP) seeks
to increase worker engagement and empower
facilities to make worker-centric improvements.
By the end of 2019, we had reached 45 facilities
by supporting mobile-engagement tools,
applying lessons from our 2017 technologyenabled pilots. This builds on the 100 facilities
that we had reached previously through earlier
non-mobile-based iterations of the program.
We have learned from our experiences
engaging workers and have adjusted ourapproach to better fit the needs of individuals,
their workplaces and our business. We havetested a variety of approaches, including worker
discussion groups, pen-and-paper surveys andvarious mobile technologies. We now focus ona supplier-led model that uses scalable mobile
technology, allowing workers’ voices to be heard
directly by those who are able to respond. To
sustainably expand the program, we are sharing
best practices across suppliers, from Vietnam to
China to Indonesia to Guatemala.

Gap Inc. hosts WEP workshops in each region
to bring together our suppliers and WEP
service providers. During these workshops,
our Supplier Sustainability team sharesthe importance of worker engagement andhow it can help our suppliers’ business.
Research on worker engagement supports
supplier adoption: Improved engagement
has been correlated with business outcomes
like reduced absenteeism and turnover.
Additionally, suppliers can learn from theirworkforce to make improvements that aregood for business, whether that’s identifying

a problem before it escalates or becomes alarge risk, or hearing workers’ ideas about
opportunities to improve efficiency, safety andmore.
We recognize that there are many ways tomeasure worker engagement. To increase
brand collaboration and avoid the proliferationof tools with a similar purpose, we adopted
Nike’s survey tool in 2019 and plan to share
best practices and resources to enhanceindustry knowledge going forward.

Better Work Academy
As a founding member of the Better Work Academy, we are dedicated to moving beyond“assessment-only” facility monitoring to support comprehensive solutions that improveindustrial relations in facilities. By including leadership in capability-building programs,
appropriate individuals are able to take action to address worker feedback provided
through new grievance mechanisms.
To date, the Academy has reached 300 facilities in 18 countries, with eight brands now
participating, including Gap Inc. As a proud ambassador for the program, we have played
an active role in supporting its expansion. One of the ways we do this is by onboarding
other brands, sharing our insights, and providing training materials that brands cancustomize for their own programs.
Based on feedback from participating brands, the Academy is helping to empower
facilities to make improvements themselves, with brands serving as advisers andpartners. Facilities report improved communication with workers, fewer worker complaints
and better production performance and output.
Looking ahead, we believe it is important to continue growing the modules and to focus
areas of Better Work Academy for consistency and harmony with other capability-building
programs in our industry. For example, we see significant opportunity for the Academy
to focus on developing management training, as having mechanisms to provide worker
feedback can only help if management is prepared to receive it and make improvements.

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Capability Building
DIGITAL WAGE PAYMENTS
In 2018, we set a goal for all of our Tier 1
suppliers to transition from a cash-based
wage-payment system to a digital wagepayment system by 2020. As of the end of
2019, 92 percent of our suppliers were using
digital wage payments, and we had rolled out
programs in 23 countries. (We define digital
wage payments as mobile wallets, bankaccounts, debit cards and other methods thatare digitally accessible.)
To support our commitment, we joined theUN’s Better Than Cash Alliance (BTCA),
which works with the private sector,
governments and international organizations
to accelerate the transition to digital payments,
which can help reduce poverty, build financial
inclusion and support inclusive growth. It
also advances supply-chain efficiency andtransparency.
In addition to costing more time and moneyfor facilities, cash payments present a variety
of security risks to workers and contribute tofinancial exclusion. Globally, more than 30
percent of working-age adults lack access toformal financial services, with rates of financial
exclusion higher among women.
By committing to work with our suppliers
to use digital wage-payment methods, wehope to increase the number of people inour supply chain – particularly women – whohave access to formal financial products andservices, including bank and savings accounts,
credit and insurance. This gives workers
greater control over their finances and offers
them a safer way to save, spend and invest
their money. Our suppliers benefit from costsavings via a faster, more efficient payment
system. Digital wages also help to increaseaccountability and transparency across thegarment sector. Since financial inclusion
requires both access to financial services andknowledge about how to use those products
and services, we are evaluating how we
can tie our digital wage-payment work tofinancial-literacy training programs, which our
P.A.C.E. program (p.43) provides.
We are pleased to see that our efforts havecreated a positive impact for workers andsupply-chain facilities alike: In India, where
100 percent of the facilities we work with now
provide digital wage payments, time spent on
payroll is down 10 percent for Finance teams
and 25 percent for HR teams at our suppliers.
Digital wage systems have also supported
more transparency in worker payments,
including overtime, which has helped workers
get paid what they earned. As a result,
worker attrition and turnover has dropped 15
to 20 percent.
While we are seeing good progress in most of
our sourcing countries, we are encountering
different barriers to progress in countries
such as Cambodia, Haiti and Jordan. In
Haiti, for instance, there’s a lack of banking
infrastructure for workers to access accounts.
Other countries face high transaction costs
that create barriers for low-wage garment
workers, or lack banking infrastructure inrural areas where workers may want to sendmoney to support their families.
We recognize that we cannot solve
challenges across the banking ecosystem
alone, and as we work toward our goal,
we are partnering with a broad set ofstakeholders to develop working groups
in countries that presently lack the
infrastructure or capital investment
required to make digital wages a scalable,
cost-effective model for garment workers.
In addition to our collaboration with the
BTCA, we have partnered with the Bill
& Melinda Gates Foundation and BSR
in Bangladesh, in tandem with otherinternational buyers, to identify solutions
that can help us address some of the key
systemic barriers to digitization in the years
ahead.

Goal

100% of Tier 1 suppliers
transition to digital wage
payments* by 2020
% Tier 1 Suppliers Paying Digital Wages*
2017 68%2018 80%2019 92%
2020
Goal

100%
*Mobile wallets, bank accounts, debit cards andother methods that are digitally accessible

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P.A.C.E.: Empowering Women
Our P.A.C.E. (Personal Advancement & Career
Enhancement) program gives women the foundational life
skills, technical training and support they need to advancein the workplace and in their personal lives.
We launched P.A.C.E. globally in vendor facilities in 2007
and have since expanded the program to community
settings and more countries, unlocking new possibilities
for women and adolescent girls around the world. Our
goal is to reach 1 million women and girls through vendor
and community partnerships by 2022.
Learn more
> How we're supporting women

REACH SINCE 2007

580K+

women + girls

3,000+
trainers

80%
of oursupply-chain vendors
have made 2022
commitments
to implement
P.A.C.E. training

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P.A.C.E.: Empowering Women2019 PROGRESSIn 2019, P.A.C.E. achieved an importantmilestone of reaching more than 580,000
women and girls, including more than
279,000 in 2019 alone. We were able to
make such significant progress scaling
P.A.C.E. through innovative collaborations
that included strategic partnerships withlocal governments and other brands, aswell as a new multistakeholder initiative.
We also invested in open-source tools andmeasurement and evaluation frameworks
that will continue to ensure sustainability inquality and affordability even as P.A.C.E.
grows. Also in 2019, we began to see thefruits of our investments in adolescent
girl’s curriculum, as some of these girls
transitioned into the women’s program,demonstrating the impact of P.A.C.E.
through different stages of their lives.
In 2019, we extended the reach of P.A.C.E.
in three ways:
Gap Inc. partnered with Business forSocial Responsibility's (BSR) HERproject,International Labour Organization (ILO)
Better Work, Cooperative for Assistance andRelief Everywhere (CARE), International
Center for Research on Women (ICRW)and Walmart to launch Empower@Work, acollaborative effort dedicated to empowering
women and advancing gender equity inglobal supply chains through the sharingof knowledge, skills and networks. Thiseffort aims to unlock the reach of leading
women’s empowerment programs thathave collectively engaged more than 4.5
million workers in global supply chains. By
harnessing the power of our collective reachand pooling our knowledge and resources,
we aim to support economic independence
and a better future for the more than 80
million women working in the apparel industry
worldwide. The approach is built on threepillars: Act to encourage and share bestpractices in worker training, innovate bysharing successes and failures to develop newbest practices, and advocate by amplifying ourcollective voice for policy-level change. Late in
the year, Empower@Work released an opensource worker training open-source worker
training toolkit for women’s empowermentthat includes our P.A.C.E. women’s curriculum,as well as expertise and training from the otherpartners.
We are also using the open-source concept
to scale P.A.C.E. through collaboration withother brands. We are offering no-fee license
agreements for the use of P.A.C.E. curriculum
and training methodologies to our brandpartners, including Abercrombie & Fitch Co.,
Avery Dennison, Hasbro, New Balance, PVH
Corp., and the Chinese food and beveragecompany, Want Want Group.
Lastly, we are extending the program’s reachby partnering with governments to deliver
P.A.C.E. in new settings where it can haveincreased impact for women:••

Through a collaboration with the UN HighCommissioner for Refugees (UNHCR) that
we began in Jordan in 2018 and expanded
to Turkey in 2019, P.A.C.E. curriculum
is now benefiting people who have been
forcibly displaced in refugee settlements.
In Bangladesh, Gap Inc. and theInternational Organization for Migration(IOM) signed an agreement to implement
P.A.C.E. curriculum modules for migrant
workers and in refugee sites.

•

In Cambodia, we licensed our curriculum
to Kampuchea Action to Promote
Education (KAPE), which will reach
100,000 girls in the next couple of years.

•

In India, we launched a pilot with the
Ministry of Rural Development (MoRD)
that will standardize the P.A.C.E.
life-skills curriculum across MoRD’s
implementing partners around thecountry under a social and economic
program focused on rural youth.

•

In Indonesia, our program partner,
CARE Indonesia, received a government
award for successfully integrating androlling out the P.A.C.E. adolescent girl’scurriculum into a school district thatreaches more than 5,000 girls.

To help ensure quality and sustainability at
scale, we have launched an online learning
platform that has supported the training andcertification of 3,000 P.A.C.E. trainers. This
platform allows partners to manage theirown trainer base, while maintaining P.A.C.E.
program quality through a standardized
curriculum. In 2019, we also funded thedevelopment of community and workplacemeasurement and evaluation frameworks by
ICRW to demonstrate the impact of P.A.C.E.
in a systematic and credible way. Theseframeworks will enable our community
partners and vendors to better accessand use data and analysis to improve andvalidate the social and business impact of
P.A.C.E. programs.

We plan to build on the successes and lessons
learned from 2019 by continuing the use ofopen-source, no-fee license partnerships,
increasing opportunities to demonstrate
impact through qualitative and quantitative
assessment tools, and embedding P.A.C.E.
programming into our Supplier Sustainability
team in facility settings. This positions the
program as a business priority that contributes
to supply-chain capability building, efficiencies
and enhancements.
In 2019, we raised more than $200,000 for
our P.A.C.E. implementing partners, CARE,
through a campaign for International Women’sDay led by our Gap, Banana Republic andAthleta brands. As we expand the P.A.C.E.
program, we plan to continue exploring new
ways to engage our employees and others.

Goal

Reach 1 million women
through P.A.C.E. by 2022
P.A.C.E. Participants
2007
2016
68K
2017
122K

2018
300K

2019
580K

2022
Goal

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P.A.C.E.: Empowering Women
REACH + GROWTH

2019 IMPACT*
2019 Active Community Partners

Women + Girls2018 178,000

79%↑2019 279,000Countries
2018 17in communication skills

79%↑

2019 17

Vendors

in execution skills

2018 612019 68

Community Partners

87%↑2018 17in financial literacy skills

2019 28

Sourcing Dollars
Percentage of sourcing dollars
spent with PACE vendors
2018 72%2019 81%*According to 2019 assessments that participants are
asked to complete before and after each P.A.C.E. module

5.3%

turnover rate for
P.A.C.E.-trained womencompared to 10.1 percent among their peers,
according to a sample set of 74 facilities

•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

Apparel Training & Design Centre
Association for Solidarity with Asylum-Seekers and Migrants (ASAM)
Beijing Social Work Development Center for Facilitators
CARE
China Women's University
Fujian Hwa Nan Women's College
Gram Tarang Employability Training Services
Hainan Tropical Ocean University
Hebei Women's Vocational College
Heifer International
Hunan Women's University
Inno Community Development Organisation
Jordanian Hashemite Fund for Human Development (JOHUD)
Kampuchean Action for Primary Education (KAPE)
MAMTA Health Institute for Mother and Child
Martha Tilaar GroupMϋlteci Destek Derneği Refugee Support Center (MUDEM-RSC)
Nanjing Normal University
Project Concern International (PCI)
Self-Employed Women's Association (SEWA)
Shaanxi Women and Children's Development Foundation
Shantou University
ShareHopeTechnoServe
Want Want Group
Women WinWorld Vision Honduras
Xi'an Peihua University

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Water Stewardship Strategy		

47

Women + Water			50

Resource Efficiency + Manufacturing 52
Chemicals Management		

56

Climate

59

Waste

62

Circularity

63

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Water Stewardship Strategy
Few resources are as essential to human health andwell-being as water.
Our water stewardship strategy is built on the principlethat clean, safe water is an environmental concern,a basic human right and a business imperative. We
have a responsibility and an opportunity to catalyze
innovation in water for the industry.
Water is also a critical natural resource for ourbusiness: it is used in the cultivation process of raw
materials like cotton; consumed in the mills andlaundries that manufacture our products; and usedby customers to wash their clothes. It is also critical tothe health and well-being of the people who make our
products, a majority of whom are women.
To help build the resiliency of our company, our supply
chain and the people who make our clothes, we areworking strategically to use water more efficiently in
product design and manufacturing, eliminate watercontamination, and promote education about waterand sanitation, particularly among women.
Learn more
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Water Stewardship Strategy
OUR APPROACH
Our water stewardship strategy lies at
the intersection of the apparel industry’s
significant use of water and our belief thataccess to clean, safe water is a basic right.
Gap Inc.’s strategy is focused on three key
areas: women’s access to water, sanitationand hygiene (WASH); water stewardshipin manufacturing; and designing productsthat use less water to create.

Women + Water
We partner with organizations to support
women’s access to water, sanitation andhygiene (WASH) services and productsin India through the USAID and Gap Inc.
Women + Water Alliance.
We also educate the women who makeour clothes about safe water-handlingpractices through our P.A.C.E. (Personal
Advancement & Career Enhancement)
program and key local organizations.
Including our partnership with CARE,
we reached over 134,000 women witheducation on WASH practices through
P.A.C.E. in 2019.
Read more> Women + Water (p.50)

134K+

women trainedon WASH practices
in 2019

Resource Efficiency +Manufacturing
We partner with strategic fabric mills, cutand-sew facilities and laundries to reduce
manufacturing impacts through programs
focused on energy and water efficiency,
and water quality.
In 2019, we worked with 47 mills, four cutand-sew facilities and 12 denim laundries
through various sustainability programs.
This reduced the amount of water used in
manufacturing by 3.8 billion liters, helping
us reach our goal to save 10 billion litersof water by 2020.
Read more> Resource Efficiency + Manufacturing(p.52)

3.8B

liters of water saved
at mills, cut-and-sew
facilities + denim
laundries in 2019

Product
We look for opportunities to expand theuse of water-saving innovations across allof our brands and, where possible, we areshifting to water-efficient raw materials.
Our program to reduce the water used infinishing denim saves at least 20 percent
of water used in the laundry stage of
production. Since it began in 2016 forGap brand, Washwell™ (p.70) has been
adopted by Athleta, Old Navy and Banana
Republic.
We are also designing products that use
more sustainable raw materials that savewater, with a designer-focused PreferredFibers Toolkit (p.66), and training
programs for our employees.

634M

liters of water saved
through Washwell™
in 2019 across
Gap Inc. brands

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Water Stewardship Strategy
2019 PROGRESSIn 2019, we continued directing resources towater-savings programs to help us progress
toward an ambitious goal to conserve 10 billion
liters of water by the end of 2020 throughsustainable manufacturing practices. This
volume is equivalent to providing drinking
water for 5 billion people for one day.
Our primary strategy to achieve this goal isto engage with the mills and laundries in our
supply chain and use water-saving methods
in the production of our clothing. We achieved
8.36 billion liters of water savings by theend of 2019, from a 2014 baseline. Throughcontinued partnership with our manufacturers,
we are proud to have achieved this goal inearly 2020 (p.55) with 11.2 billion liters ofwater saved.
During the year, we also expanded andamplified our efforts to deliver water, sanitationand hygiene (WASH) education to
women via the United States Agency
for International Development (USAID)
and Gap Inc. Women + Water Allianceby welcoming WaterAid to the alliance.
WaterAid is an implementing partner
focused on capacity building of local
institutions and stakeholders to improveaccess to clean drinking water. We also
continued to further our outreach to women
via our P.A.C.E. program.
Through our brands, Washwell™ andother programs help to connect ourdesign decisions with manufacturing
improvements, enabling us to save waterin our supply chain while also educating
our customers about water impacts andreductions.
Learn more
> Detailed disclosures about our water
programs

CEO Water Mandate
We are a signatory to the CEO Water
Mandate, a UN Global Compact initiative,
joining with other companies, governments,
civil society and others to address
challenges related to water scarcity, quality
and governance, and access to water andsanitation.
In 2019, we collaborated with the CEO
Water Mandate and seven other signatorycompanies – AB InBev, Diageo, Dow Inc.,
Ecolab, Microsoft, PVH Corp. and Cargill– to form the Water Resilience Coalition,
pledging our commitment to collective
action and net-positive water impact
by 2050. Launched in March 2020, thecoalition pledges to preserve the freshwater
resources in water-stressed regions throughambitious, quantifiable commitments thatdeliver on three goals:•

Net-Positive Water Impact: Deliver
measurable net positive impact in waterstressed basins. Net-positive water
impact means contributing more to basin
health than what is taken from it.

•

Water-Resilient Value Chain: Develop,
implement and enable water resilience
practices across 100 percent of ourcompany’s global value chain.

•

Global Leadership: Raise the ambitionof water resilience through public andcorporate outreach, as well as inspireother industry leaders to join the
Coalition.

Goal

Save 10 billion liters of waterin manufacturing by 2020,
from a 2014 baseline

2020 GOAL
ACHIEVED

Liters of Water Saved

liters ofwater saved
since 2014

2014
2016
668M

2017
3.3B

2018
5.7B

2019
8.36B
2020
Goal

11.2B

Q1 2020
11.2B
Read more> How we got there (p.55)

New Goal

Water-resilient value chain
by 2030
New GoalNet-positive water impact
in water-stressed regions
by 2050

10B
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Women + Water
We seek to improve access to water, sanitation andhygiene (WASH) for women and communities touched byour business.
Roughly 80 percent of the people who make our clothes
are women, and access and affordability to WASH is amajor challenge in many of our key sourcing countries. In
many parts of the world, women are largely responsible
for household duties such as cooking and cleaning; theyshoulder a disproportionate burden when it comes towater stress.
India, an important country for both growing cottonand making textiles, is experiencing a significant waterand sanitation crisis that is expected to worsen overthe next five years. Across the country, more than halfof all people face water stress: 163 million lack accessto improved water sources and 210 million lack accessto proper sanitation. Through water-risk assessments,
we have identified India as a critical location for WASH
services, which is why we focus many of our programs incotton-growing and textile-manufacturing communities
in India’s Godavari, Narmada and Ganges-Brahmaputra
River Basins.

SUPPORTING WOMEN'SACCESS TO WATER,SANITATION + HYGIENE
Alongside our strategic implementation
partners, we lead a suite of programs toprovide education, access to services andfinancing to women and communities toaddress their WASH needs. Within Gap Inc.
partner facilities, our Code of Vendor Conduct(COVC) requires that key WASH needsof garment workers are met. In addition,
our P.A.C.E. (Personal Advancement &Career Enhancement) program, aimed atworkers in our supply chain as well as global
communities, provides additional capability tobring WASH education to women globally inboth manufacturing facilities and communities.
We are also spearheading the Women +Water (W+W) Global Development Alliance(p.51) with the United States Agency forInternational Development (USAID), which
supports water stewardship and accelerates
women’s access to WASH financing andimproved services.

WASH4WORK
Gap Inc. is a partner in WASH4Work, adiverse group of stakeholders from the public
and private sectors that aims to mobilize
businesses that are working together tostrengthen business contributions towardachieving Sustainable Development Goal
(SDG) 6. It aims to improve access to WASH
in the workplace, in the communities where
workers live and across supply chains.

RAISING AWARENESS
In addition to mobilizing business throughWASH4Work, we are committed to raisingawareness about the water crisis in our
industry and beyond. In 2019, Gap Inc.
brought together stakeholders from the W+W
Alliance to talk about women’s leadership on
WASH at World Water Week in Stockholm.
We also engaged our employees in the#LoveYourWater campaign, encouraging themto share simple ways to reduce their own
water use by making small changes in theireveryday lives.

The programs we lead tackle different aspects of thewater and sanitation challenges, and we also collaborate
to mobilize broader business action and raise awarenessof these critical issues.

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Women + Water
USAID AND GAP INC.
WOMEN + WATER ALLIANCE
In 2017, we launched the Women + Water(W+W) Global Development Alliance with
the United States Agency for International
Development (USAID) to improve andsustain the health and well-being of womenand communities touched by the apparelindustry.
Over the course of this five-year program,
Gap Inc. is serving as the co-funder andprimary program manager. The W+W
Alliance operates in two Indian states criticalto the apparel industry – Maharashtra, a key
cotton-growing state, and Madhya Pradesh,a textile-industry hub. Four implementing
partners – CARE, Water.org, Institute for
Sustainability Communities (ISC) and
WaterAid – are helping the program work
toward two objectives, where women’s selfefficacy and agency plays a critical role to:••2019 PROGRESSIn the Alliance’s third year, we deepened ourcollaboration and expanded the capabilitiesof our partnership network by formalizing ourpartnership with WaterAid and aligning ourefforts with the Indian government’s robust
new water agenda. Each of our partners
applies unique expertise that allows the W+W
Alliance to address the holistic needs of waterstressed communities while using adaptive
management as a strategy to deliver focusedinterventions that respond to the uniquechallenges in each location.

•

Encourage communities to adopt key
WASH practices.
Build access to and sustainably manage
quality water resources and sanitation
services.

This pioneering public-private partnershipaligns closely to our goals related tosustainable water stewardship andempowering women with WASH education,
services and products. The program is being
implemented primarily in communities where
cotton is grown and fabric mills are located.
Through rigorous monitoring and evaluation,
we are deepening our understanding of
the WASH needs of women and girls in

3,100 farmers – 45 percent of whom are
women – on cotton-cultivation practices
including the use of organic fertilizers andpesticides as a future livelihood opportunity
for these women. Through this project,
ISC helped the communities save 400,000
liters of water through water budgeting,smarter irrigation practices, and repair
and renovation projects. In the otherproject, ISC worked with one of Gap Inc.’sstrategic fabric mill partners, Vardham
Mills, to develop a long-term water-security
plan in partnership with local community
stakeholders for the Budhni watershed.
This plan is one of the first of its kind for amill partner.

communities while improving our ability todeliver programs that support their well-being.
To catalyze progress, we are also learning andsharing best practices for WASH and water
stewardship across the apparel industry andbeyond.

•WaterAid: In 2019, WaterAid helped leadthe creation of 60 water-security plans
benefiting over 120,000 people, with thesupport of government funding. WaterAidalso trained local women and youth tocomplete water-equality testing in 757
villages and supported collaboration withlocal government on solutions. We also
worked with WaterAid, as well as othercompanies and consultants, to implementa framework we developed together
in 2018 on the supply-chain businesscase for WASH. We are now testing theframework at a partner facility in India.
Institute for Sustainable Communities:
Another implementing partner, ISC,
worked on two water-stewardship bestpractices projects. In one, ISC engaged•

Water.org: To support access to finance,
Water.org brought on a new microfinancepartner and is working to get women
access to funding for WASH needs. In
2019, Water.org’s financing model helped
catalyze over $2.4 million in financing,
benefiting more than 55,000 individuals to
address their WASH needs.

•

CARE: For its part, CARE surpassed its
annual target for the number of womencompleting the P.A.C.E. curriculum andcontinued to enroll more women and men
into the program. In 2019, CARE helped
us reach more than 62,000 women withGap Inc.’s P.A.C.E. program, putting us
39 percent of the way toward our program
goal to enroll 200,000 women by 2022.

access across India by 2024. As part of thisagenda, the government identified areas
experiencing acute water stress, eight of which
overlap with our program. WaterAid supported
the government’s water-conservation
campaign in two districts, which resulted in
the construction of 215 rainwater-harvesting
structures across W+W Alliance districts todate. Moving forward, WaterAid will workwith the over 3,000 communities where we
implement to create village-level water actionplans to improve access to safe drinking water
to be funded by the government.
We continued to advance work on evaluation,
applying and sharing what we havelearned to improve and scale our impact.
The International Center for Research on
Women (ICRW) completed the first part of alongitudinal study on the impact of P.A.C.E.
and WASH behavior change. The evaluation ofthese findings is helping us continually improve
our trainings to P.A.C.E. CARE educators.
Additionally, the Institute for Development
Impact (I4DI) completed a baseline study in
Maharashtra and presented the findings at
World Water Week.

In 2019, we also enhanced our engagementwith the Indian government and aligned ouractivities with the government’s new Ministryof Jal Shakti, Abhiyan, which announced an
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Resource Efficiency + Manufacturing
2019 PROGRESSIn early 2020, we achieved our ambitious
goal to conserve 10 billion liters of water
through sustainable manufacturing
practices, including through an innovativetechnology deployed in 2019 at ourlongtime sourcing and franchise partner
Arvind Limited’s denim mill in India.
Also in 2019, we established Gap Inc.’sscience-based goal for Scope 3 supplychain emissions (p.60), a process thatinvolved deep collaboration with crossfunctional teams within our company aswell as partnership with our suppliers.
In 2018, we set our sights high, committing
to save 10 billion liters of water and weare proud that we met this goal in the firstquarter of 2020. Our success was due toa simple but powerful strategy of engaging

10B liters ofwater saved(our goal)=
5B peoples’
drinking waterfor one daywith the mills and laundries in our supply
chain through a suite of water-efficiency
programs that support proven watersaving methods in the production of ourclothing. In 2019 alone, we achieved 3.8
million liters of water savings – more thandouble the savings we saw in 2018.
Through our brands and our expansion of
Washwell™ and other programs, we havehelped to connect our design decisions
with manufacturing improvements andinnovative dye techniques, enabling us
to save water in our supply chain while
also educating our customers about water
impacts and reductions.
Learn more
> Detailed disclosures about our water
programs

RESOURCE EFFICIENCY
Through our resource-efficiency programs, we
collaborate with strategic mills and laundries tosignificantly reduce their water impacts.
The facilities saw average water-use
reductions of 20 percent through theirimplemented efficiency programs. As many
water issues are based on local context andneeds, we have mapped all preferred facilities,
representing 85 percent of our business,against the World Resources Institute’s (WRI)
Aqueduct Water Risk Atlas to help prioritizeareas of focus and drive countrywide or basinspecific approaches.
Our resource-efficiency efforts comprise thefollowing programs:

Clean by Design +Apparel Impact InstituteWe have collaborated with the Natural
Resources Defense Council (NRDC) on its
Clean by Design program since 2014. In
2018, we helped create the program’s new
home: the Apparel Impact Institute (Aii). Today,
Aii is an important platform for cross-brandcollaboration to support facilities in improving
their operational efficiency and reducing
their water, energy and chemicals use. The
following programs were completed in 2019and future work will be transitioned andstreamlined under the Aii umbrella:•••

In 2019, we participated in the creation of
the Clean by Design Plus program in China,
which works with mills that have graduatedfrom the original program and want to capture
additional, deeper opportunities for operational
efficiency and sustainability. This new program
not only focuses on energy and water
reductions, but also establishes an in-houseprogram to enhance continual improvementand develop long-range GHG- and waterreduction goals. Aii programming also
expanded to India with a new pilot focused onwater and chemistry efficiency.

Partnership for Cleaner Textile(PaCT)In Bangladesh and Pakistan, we workwith PaCT to improve the environmental
performance of the textile wet-processing
sector. In 2019, we continued phase two of the
PaCT Bangladesh program, which culminatedin early 2020. PaCT Pakistan was one of thefirst industrywide programs in that country
at its 2018 launch, and we are proud of the
impacts realized in 2019.
Learn more
> Resource efficiency programs in our supply
chain

China Mill Efficiency Program
Taiwan Mill Efficiency Program
Race to the Top (Vietnam)

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Resource Efficiency + Manufacturing
How We’re Saving 8 Million Liters of Water a Day:
Using Reclaimed Wastewater at a Denim Mill in India
In 2019, we were able to make such significant gains in water reduction, in part,through our partnership with Arvind Limited and its innovative water-treatment facility.
Instead of freshwater, Arvind’s denim mill now uses reclaimed wastewater from thecity of Ahmedabad.
By the end of 2020, this facility is projected to save nearly 2 billion liters offreshwater, helping to preserve the local community’s vital resource. It will also
support sustainability more broadly by using a chemical-free treatment method toclean domestic wastewater drawn from the surrounding community. Moreover, thissustainable approach will build business resilience for Arvind, Gap Inc. and otherbrands that source from the mill. As climate change and population growth contributeto water scarcity in countries like India – where 54 percent of the population faces
high to extremely high water risk – the apparel sector must create solutions that
reduce impacts on freshwater resources.
Looking ahead, we are working with Arvind to build an innovation center in 2020
that will promote the adoption of proven techniques and technologies to reducewater use in the textile-manufacturing industry. The 18,000-square-foot space willfeature installations showcasing water-management best practices and recycling
technologies; a library, lab and classroom; and conference spaces for apparelcompanies, manufacturing suppliers and vendors, and sustainability experts toadvance water stewardship across the apparel sector.

Water-treatment facility at Arvind Limited

Future innovation center at Arvind Limited

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Resource Efficiency + Manufacturing
MANUFACTURING

WATER QUALITY PROGRAM

Our partnerships with suppliers support
our water goal through improvements
in resource efficiency, water quality andoverall sustainability.

We actively monitor and help to improve
wastewater quality at denim laundries throughour Water Quality Program (WQP), which
has been a requirement for over 15 years.
All of the denim laundries from which wesource must achieve our WQP standard,
which requires complete compliance with
Zero Discharge of Hazardous Chemicals(ZDHC) Wastewater Guidelines and chemical
data reporting. In 2019, 48 denim laundries
participated, with 87.5 percent of facilities
meeting all conventional parameters and79.2 percent of facilities meeting all ZDHCManufacturing Restricted Substances List
(MRSL) parameters. Appropriate corrective
actions were undertaken to address noncompliance to our ZDHC requirements.

In 2019, we sharpened our understandingof the environmental impact of our mill
suppliers through our use of the Higg FEM
3.0 and applied this knowledge to create
our first science-based target for Scope 3
emissions.
Today, 97 percent of our cut-and-sew
manufacturers and 91 percent of fabricmills and dyehouses use the Higg FEM 3.0– among the highest response rates of any
brand SAC members.
By deepening our engagement with
suppliers through these programs, we aim
to spur innovation so that our suppliers
contribute additional ideas and pilot
new technologies to reduce social andenvironmental impacts.

Read more> ZDHC (p.56)

MILL SUSTAINABILITYPROGRAM
Our Mill Sustainability Program began throughpilots in 2013 and in 2018, became a strategic
initiative. We engage in three key industrywide
efforts to help us meet our sustainability goals:
the Sustainable Apparel Coalition (SAC), Zero
Discharge of Hazardous Chemicals (ZDHC)and the Social & Labor Convergence Program(SLCP).
Since that transition, our strategic mills havebeen required to participate, enabling Gap Inc.
to align our approach with industry standards
that help us increase transparency and drive
innovation. By leveraging our partnerships, we
can analyze and improve the environmental
performance of our supply chain. We haveasked our wet-processing facilities to register
for a chemicals-management platform to better
track their ZDHC performance.

Our suppliers’ involvement is key to our ability
to calculate our energy, greenhouse gas andwater baselines, helping us drive social andenvironmental performance. The data wegather using these tools is also instrumental in
our sustainability strategy and goal setting. In
2019, we established a science-based target
that includes our Scope 3 GHG emissions.
We created a robust supply-chain climate
strategy using real data from the SAC’s Higg
Facility Environmental Module (FEM) 3.0. We
appreciate our suppliers’ partnership and
Gap Inc.’s cross-functional collaboration thatmade this important process possible.
Read more> Our climate and energy programs (p.59)> Our social programs (p.35)
We leverage three key industrywide efforts to
support our Mill Sustainability Program:Sustainable Apparel
Coalition (SAC)

Zero Discharge of Hazardous
Chemicals (ZDHC)Social & Labor Convergence
Program (SLCP)As a founding member of the SAC, we
use the Higg Index to evaluate suppliers’
environmental performance and engage
them to meet our goals. Since 2017, wehave expanded our use of the Higg Facility
Environmental Module (FEM) 3.0 to collectdata from mills’ self-assessments. Increasingly,
these self-assessments are verified by a third
party. In 2019, over 90 percent of our supplying
mills completed the Higg FEM 3.0. We now
ask our strategic mills, which represent over
75 percent of our total business, to complete
the Higg FEM 3.0 annually.

We joined ZDHC’s Roadmap to Zerocommitment in 2014 to work toward theelimination of hazardous chemicals inour supply chain. We integrated ZDHC
Roadmap to Zero Programme tools andresources, such as the Manufacturing
Restricted Substances List (MRSL) and
Wastewater Guidelines, into our Mill
Sustainability Program. Since 2018, we
have required our strategic mills to test theirwastewater twice a year and publish theresults through the ZDHC Gateway.
> Read more (p.56)

As a signatory to this collaboration
among apparel and footwear brands,
retailers, industry groups and civil society
organizations, we continue to work with ourstrategic mills in key geographies to use
the SLCP social and labor assessment.
We support the shared data-collection
tool that can assess the social and labor
performance of manufacturing facilities
across the apparel and footwear supply
chain. Additionally, 28 mills participated in
the SLCP pilot in 2019.
> Read more (p.35)

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Resource Efficiency + Manufacturing
HOW WE ACHIEVED
10 BILLION LITERS OF
WATER SAVINGS

China

TOTAL WATER SAVINGS FROM:
NRDC
Clean by Design
2.46B liters

Resource Efficiency Programs

On Earth Day 2020, we announced that we
had reached our 2020 goal to save 10 billion
liters of water in manufacturing, achieved
through product innovation and strategic
business partnerships.

Total Water Savings Since 2014

China Mill Efficiency
Program
1.44B liters

Pakistan
PaCT
871M liters

10.2B
LitersSaved

1B

Processing +Product
Innovation

10B
Goal

11.2B

Liters ofWater Saved
Since 2014

10.2B

Resource
Efficiency
Programs

Country

Liters
Saved

China
India
Vietnam
Pakistan
Bangladesh

3.89B
3.16B
1.61B
871M
656M

VietnamIndia
Arvind Water
Partnership
1.74B liters(annual)Bangladesh
PaCT
656M liters

India Water
Partnership
1.42B liters↓126K
Metric Tons
CO2e

1B

Liters
Saved

Process

Race to the Top
677M liters

PROGRAM REACH

Processing + Product Innovation
GHG Emissions Reductions
resulting from our Resource
Efficiency Programs

Vietnam
Improvement
Program
938M liters

Liters Saved

Washwell(sustainable denim wash)
Various Innovative Dyeing +Wet-Processing Techniques

979M
30M

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Chemicals Management
We aim to eliminate the discharge of hazardous chemicals
within our supply chain to reduce our environmental
impact and improve access to clean, safe water in thecommunities where our suppliers’ facilities and mills
operate.
The global apparel industry accounts for high amountsof chemical use in manufacturing, and the discharge ofthese chemicals can threaten local water sources andaffect the people working with them and living nearby.
Learn more
> How we're reducing the impact of chemicals

OUR APPROACH
Our approach to chemicals management
includes three key components:

1. Industry partnerships
We partner with industry groups, including
Zero Discharge of Hazardous Chemicals(ZDHC), 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
the use of safer chemicals. In addition to
helping us achieve our water and sustainability
commitments, these partnerships help
advance progress across the industry.
Gap Inc. chemical restrictions are informedby global regulations as well as hazard- andrisk-based considerations. They include
our Restricted Substances List (RSL) and
Manufacturing Restricted Substances List
(MRSL). Since 2008, Gap Inc. suppliers
have been expected to comply with our RSL,
and in 2016, we adopted the AFIRM Group
RSL. Since 2015, we have required all of our
suppliers to comply with the ZDHC MRSL.

chain programs like our Water Quality Programand Mill Sustainability Program.

3. Compliance and monitoring
Through third-party testing of products, productcomponents and wastewater effluent, as wellas the use of industry data platforms, wemonitor the performance of our supply chain
and verify compliance with global chemical
regulations and Gap Inc. chemical restrictions.
Performance in our chemistry programs
informs facility evaluation.

Goal

Work toward zero
discharge of hazardous
chemicals in our supply
chain by 2020

2. Working with suppliers
We communicate chemical safety and usage
requirements to our suppliers through our
Code of Vendor Conduct (COVC) and Mill
Minimum Expectations, and we require our
suppliers to acknowledge and comply withthese conditions. These requirements havebeen incorporated into our existing supply-

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Chemicals Management
2019 PROGRESS

Industry Tools

Commitment to Eliminate
PFC-Based Finishes

We adopted new platforms to support thecollection and analysis of chemical inventory
and usage data from 150 of our strategic
vendors and mill facilities. These online tools
complement the ZDHC Gateway, an industry
platform that houses information related to
the ZDHC Roadmap to Zero Programme,
including Manufacturing Restricted
Substances List (MRSL) conformance ofcommercially available chemical formulations.
These platforms will provide Gap Inc. andour suppliers insight into conformance to the
ZDHC MRSL and enable our transition to moresustainable chemistry.

Increasing evidence shows that short-chain
perfluoroalkyl and polyfluoroalkyl chemicals(PFCs) – which traditionally have beenused in apparel to provide effects such as
water repellency and stain protection – canhave negative environmental impacts. In
2019, Gap Inc. committed to eliminating all
PFC-based finishes from our supply chain by
2023. This expands our 2016 commitment to
ban long-chain PFCs.
In 2019, we identified the primary usesof short-chain PFC-based finishes in ourbranded apparel and accessories andbegan communicating our intent to eliminate
PFCs to our supply-chain facilities. We arecommitted to working with our suppliers
to identify alternatives and solutions thatprovide similar performance benefits without
the use of PFCs.
Learn more
> Our PFC Policy

New GoalEliminate all PFC-based
finishes from our supply
chain by 2023

Apparel Impact Institute andClean by Design Chemicals andWastewater Pilot
As a founding member of the Apparel Impact
Institute (p.52), we nominated three of our
supplier facilities in India to participate in the2019 Chemicals and Wastewater Pilot, which
focused on determining opportunities to reduce
environmental and human-health impacts
relevant to wastewater compliance andhazardous chemical formulations. The goalsof this new program are two-fold: to optimize
and reduce chemicals used within the facility,
and to improve monitoring and operations at
the wastewater-effluent treatment plant. Initial
results are promising and we are eager toexpand the program to additional facilities in
the coming years.

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Chemicals Management
INDUSTRY INITIATIVES + STRATEGY
Input Management

Process Management

Our suppliers' input chemicals
must comply with the

Our suppliers must respond to the

Our suppliers must comply with the

ZDHC MRSL

Upon request, key suppliers must
adopt and use chemicals-management
data platforms.

Higg Index FEM 3.0

ZDHC
Wastewater
Guidelines

and other Gap Inc. policies

Selection of better chemical inputs andstarting materials is an essential partof reducing the use and discharge ofhazardous chemicals.
As a ZDHC Signatory Brand, we require
our suppliers to follow the ZDHC Roadmap
to Zero Programme, which includes
registering with the ZDHC Gateway,
maintaining a chemical inventory list andusing input chemicals that comply with the
ZDHC MRSL.
We also have additional policies related
to specific chemical formulations that go
beyond the MRSL. In 2019, we publicly
announced our commitment to phase out
all PFC-based finishes.

Adherence to chemicals-management bestpractices during manufacturing is critical for
reducing human and environmental risks.
To support best practices in our supply
chain, our COVC and Mill Minimum
Expectations outline a number of
expectations for chemical use and handling.
We require all Tier 1 cut-and-sew suppliers
and strategic Tier 2 fabric mill suppliers to
respond to the Higg Index FEM 3.0, whichenables us to evaluate suppliers basedon whether they follow specific chemicalsmanagement practices.
In 2019, we rolled out third-party chemicalsmanagement platforms to monitor andevaluate suppliers’ chemical inputs andsupport best practices.

Output Management

Finished products
must comply with the

AFIRM RSL

Outputs of apparel and footwear manufacturing include finished products as well as
wastewater discharge. Managing these outputs is a foundational component of reducing
discharge of hazardous chemicals.
To address wastewater discharge, wehave adopted and integrated ZDHC tools
and resources for output management.
Our strategic mills and laundries are
required to test their wastewater to ZDHC
Wastewater Guidelines and publish theresults through the ZDHC Gateway, adata-sharing platform that allows brands
to monitor supplier wastewater data. The
ZDHC Gateway is also a repository for
information on chemical formulations’
MRSL conformance.

Finished products manufactured forour brands should comply with the
AFIRM RSL; we use certified labs to test
products to ensure they meet regulatory
standards established by the countries
where we sell our products.

We use our chemicals program data to
inform the evolution of Gap Inc.’s chemicalsmanagement strategy.

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ClimateClimate change is a global challenge that transcends
boundaries, affecting people and communities everywhere.
Climate risk is the key sustainability issue of our time and isboth a human and environmental challenge. Managing thisrisk is critical for the long-term success of our business. We
feel an ethical responsibility to address climate change byaligning our goals and strategies with the best science andindustry practices.
As an apparel company, the vast majority of our climate
impacts lie within our supply chain, and we are working
closely with our suppliers to address those emissions andimprove the efficiency of their facilities.
In recognition of the need to align our efforts with thescientific consensus and core commitment of the Paris
Agreement to pursue efforts to limit global temperature riseto less than 1.5 degrees Celsius, we signed on to the Science
Based Targets initiative (SBTi) in 2017. SBTi – a partnership
between CDP, World Resources Institute, World Wildlife
Fund, and UN Global Compact – is leading an effort that
now includes nearly 1,000 companies that have committed
to emissions-reductions targets in line with climate science.
In 2020, we established our comprehensive science-basedtargets for reducing emissions, which were approved by
SBTi. Our goals include a target for our Scope 3 supply-chain
emissions.
Looking ahead, we recognize the urgent need to transition
to a low-carbon future, and we are exploring efficiency andrenewable-energy opportunities in our supply chain in theyears to come.
Learn more
> How we're doing our part on climate

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Climate2019 PROGRESSIn 2019, we made significant progress
toward our 2020 GHG-reduction goalby executing three renewable energy
deals totaling 100.5 megawatts; theseare expected to begin generating power
in 2020. We also achieved an importantmilestone by establishing our first sciencebased target, including a target addressing
our Scope 3 supply-chain emissions.
In addition to these achievements, we
continued investments that improveenergy efficiency at our stores, offices anddistribution networks. We also continued
our efforts to support better climate policy
and transition across the industry.

Scope 3 Supply-Chain
GHG Emissions
Baseline (2017)

5.18M
Metric Tons
CO2eFiber Production
Yarn Production
Knitting + Weaving
Fabric Dyeing,
Printing + Finishing
Garment Assembly

SCIENCE BASED TARGETS
INITIATIVE (SBTI)In 2017, Gap Inc. signed on to the Science
Based Targets initiative (SBTi) to align our
climate goals with the scientific consensus andcore commitment of the Paris Agreement tolimit global warming to less than 1.5 degrees
Celsius. In 2020, through detailed work togather and analyze emissions data across ouroperations and supply chain, we establishedour science-based targets for reducing
emissions: Gap Inc. commits to reduce
absolute Scope 1 and 2 GHG emissions by
90 percent and Scope 3 GHG emissions frompurchased goods and services by 30 percent
by 2030, from a 2017 baseline. Gap Inc.
also commits to increase annual sourcing of
renewable electricity from 0 percent in 2017
to 100 percent by 2030 for our owned andoperated facilities globally.
In developing our target for Scope 3
emissions, which comprise the vast majorityof our emissions impacts, it was importantthat we worked from an accurate baseline.
To arrive at these figures, we analyzed
environmental data collected from ourfinished product (Tier 1) and textile
manufacturing (Tier 2) suppliers using the
Sustainable Apparel Coalition’s (SAC) Higg
index, a self-reporting tool that evaluatesenvironmental performance and helps
identify opportunities for improvement.
Where actual data were not available,
we used our known production volumes,
coupled with leading industry data sources,
to approximate our impact. The processof pulling and analyzing real data andintegrating the work of our cross-functional
teams allowed us to create a robust goaland strategy for tackling the biggest
opportunities across our supply chain.
Looking ahead, we will be using this data
to work closely with our top facilities toimprove their energy efficiency. We will
also explore investments and partnerships
in renewable energy where the policy
landscape enables those opportunities.

New Goal

Carbon neutral acrossour value chain by 2050

New Goal

Source 100% renewableelectricity for our owned
and operated facilities
globally by 2030, froma 2017 baseline

New Goal

Reduce absolute Scope
1 and 2 GHG emissions
by 90% by 2030, froma 2017 baseline

New Goal

13%
22%
20%
38%

Reduce Scope 3
GHG emissions frompurchased goods andservices by 30% by2030, from a 2017baseline

7%

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ClimateRENEWABLE ENERGY•

We were intentionally ambitious in setting our2020 goal: to reduce greenhouse gas (GHG)
emissions by 50 percent from our owned andoperated facilities, from a 2015 baseline. For
years, we have invested in energy-efficiency
programs that have reduced the impacts of
our operations, and the three renewableenergy deals that we secured in 2018 and2019 have been the next phase of ourjourney, putting us on the path to achieve our2020 goal. We are also pleased that this bold
action will make Gap Inc. one of the largest
purchasers of clean energy in the American
retail industry.
Over the course of 20 months, we signed
three contracts for projects that, once fully
operational, will generate 400,000 megawatt
hours of clean energy annually – enough topower 1,800 of our approximately 3,300 retailstores. These projects are:•

Aurora Wind Project: We signed this90-megawatt off-site wind project in April
2019 and it will begin generating power inlate 2020. This North Dakota wind farm –one of the largest utility-scale installations
ever contracted by a retail company – will
generate enough clean power to address
nearly 50 percent of our North Americanenergy use across Gap Inc. The project,made possible through Gap Inc.’scommitment to purchase power from it
for the next 12 years, will also green theelectricity grid, supporting our nation’stransition to a low-carbon economy.

•

Fern Solar Project: We signed this
7.5-megawatt off-site solar project inDecember 2018 and it will come online
and start generating power in late 2020.
The site will generate enough power tooffset 100 percent of our Athleta brand's
retail energy use. The innovative natureof this deal’s contract structure – for which
we partnered with Salesforce, Bloomberg,
Workday and Cox Enterprise to combine
our buying power and make this project
possible – was highlighted in two awards:
Smart Energy Decisions’ Innovation Awardand the Center for Resource Solutions’
Green Power Leadership Award. It has
also become a case study for other leadersin renewable energy to learn from ourcollaboration.
Gap Inc. Fresno Distribution Center Solar
Project: We signed this 3-megawatt onsite solar project at our Fresno, California,
distribution center in June 2018 and power
generation began the first quarter of 2020.
The project will generate more than half ofthe building’s energy.

We recognize the urgent need to transition toa low-carbon future and we are excited about
continuing these efforts, including by exploringenergy-efficiency and renewable-energy
opportunities in our supply chain in the years
to come.

ENERGY EFFICIENCYCDP CLIMATE CHANGE

In 2019, we achieved a 23 percent
cumulative reduction of GHG emissions in
our owned and operated facilities, putting
us nearly halfway toward our 2020 goal toreduce GHG emissions by 50 percent froma 2015 baseline. In absolute terms, wereduced our GHG emissions by 107,715
metric tons of carbon-dioxide equivalents.
We made progress on these reductions
by transforming the energy-management
systems of 207 stores in 2019 (bringing
the total to 630 stores) and by replacing
HVAC units with more energy-efficientmodels in 73 stores.

Our CDP Climate Change response
includes detailed information on our
strategy and performance, which
incorporates recommendations from theTask Force on Climate-related Financial
Disclosures (TCFD).

ARCTIC SHIPPING PLEDGE
In partnership with the Ocean
Conservancy, we signed the Arctic
Shipping Pledge and committed to notintentionally sending ships through the
Arctic’s fragile ecosystem.

Goal

Reduce GHG emissions by 50% in our owned and operated
facilities globally by 2020, from a 2015 baseline
Metric Tons CO2e GHG Emissions, Scope 1 and 2, Global Market-Based500

471,301
447,687450

405,503400

387,644363,586

350
300
250

2020
Goal

200

50%↓
2015
baseline

2016
7%↓

2017
16%↓

2018
18%↓

2019
23%↓

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Waste
We have a responsibility to help prevent waste in ouroperations, which can negatively impact the environment
and add unnecessary cost to our business.
In North America, 90 percent of our waste is discarded
by our stores, and we are exploring ways to reduce anddivert our packaging waste. By innovating to optimize
packaging, reduce volume, lower business costs andsupport industrywide change, we aim to divert more than
30 million pounds of material from landfill every year.
Learn more
> How we're diverting waste

Goal

New Goal

Divert 80% of waste fromlandfill across our U.S.
facilities by 2020

Eliminate single-use
plastics by 2030

2019 PROGRESSIn response to growing global conversations
around plastic waste, Gap Inc. is striving to do
our part to reduce plastic, both upstream anddownstream, in our business. We are placing
particular emphasis on the need to reduce
single-use plastics, an issue that has drawn
greater attention in recent years. In 2019, we
conducted a complete inventory of our plastic
consumption and engaged in multiple efforts
to reduce the quantity and volume of plastic
packaging across our brands. We are also
continuing to invest in recycling solutions.
To tackle this challenge, we are focusing on
steps we can take as a company to innovate
our packaging design, product labeling andrecycling systems. One of the major changes
we are making is implementing stringent
requirements on retail polybag size andthickness, with an expected elimination of 5
million pounds of plastic every year.
Our brands are also taking action:•% Waste Diverted from Landfill

2017 47%2018 47%2019 65%

•

2020
Goal

80%

Cardboard hangers replaced plastic
packaging for Gap brand's line of baby
essentials, First Favorites.

Old Navy, Gap brand and Banana Republic
have begun using 100-percent recycled
tape for all content and care labels, achange that is projected to save over 830
tons of plastic annually. These brands havealso implemented a new price ticket withsmaller dimensions using FSC-certified
paper, which saves 120 tons of paper.
Old Navy is on track toward its
commitment to recycle hangers from 500
stores. At the end of 2019, recycling wasavailable at over 100 Old Navy locations
and the brand had recycled 124,000
pounds of hangers. Old Navy is also

updating its standards on how apparel isfolded for packaging and shipping, whichis expected to reduce more than 40,000
pounds of plastic annually.

•

In 2019, Gap brand’s First Favorites line
tested alternative materials, moving fromplastic packaging to cardboard hangers,which eliminates more than 16,000 poundsof plastic every year.

•

Banana Republic introduced recycledplastic into its woven product labelingsaving 24 tons of plastic annually.

In addition to these efforts, we are continuing
to test a suite of solutions that account for thefact that only a portion of our store locations
are able to recycle soft plastics. Our ongoingsolutions include better communication withstore employees about current recycling
opportunities at their location, collaboration
across our brands to reduce the quantity ofpolybags shipped to stores, and creating andselecting in-store marketing materials withrecyclability in mind. We are also continuing
to engage the industry and our landlords todevelop longer-term solutions to reduce waste
and expand opportunities for recycling acrossthe retail industry.
Looking ahead to 2020, we will be deepening
our waste-reduction efforts by increasing
the recycled content of polybags we use forshipping logistics, researching ways to further
reduce our use of plastic packaging in online
orders, and using more recycled content andpaper for hangers across different brands,
while expanding Old Navy’s hanger-recycling
program.

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Circularity
In order to create truly sustainable fashion, we recognizethat we must address the full life cycle of our garments,from raw materials to end of life – and back again.
We are addressing product end of life because of thesignificant environmental impact of textiles – the majorityof which end up in landfills or incinerated. Our programs
and partnerships to address product end of life andcreate circular design systems are aimed at reducing
waste and increasing recycling, upcycling and reuse.
Learn more
> How we map the product life cycle

2019 PROGRESS
Our brands and Gap Inc. joined partnerships
with different organizations, including thredUP,
the Global Fashion Agenda (GFA) and Hong
Kong Research Institute of Textiles andApparel (HKRITA) to tackle clothing waste andsolving technical challenges in textile recycling.

INDUSTRY COLLABORATION

is recycled to make new clothes. In early
2020, we announced a new partnershipwith thredUP, the fashion-resale platform,
to encourage customers to turn in secondhand clothes in exchange for shopping credit
that can be redeemed at our Gap, Banana
Republic, Athleta or Janie and Jack brands.
thredUP is committed to reselling all clothingthat meets its quality standards, which
mitigates the carbon, waste and water footprintof a garment by increasing its usable life.

Gap Inc. is committed to joining partnershipsthat advance circular business models,create innovative solutions to outstanding
issues, engage customers and scale newtechnologies.

Make Fashion Circular
We are collaborating with leaders in thecircular economy, including as a core
partner in the Ellen MacArthur Foundation’s
Make Fashion Circular initiative. Throughthis initiative, we have made a three-year
commitment to focus on safe and reusable
inputs, sustainable-fiber models and recycling
old clothing. Through our involvement, weparticipated in a textile-collection effort
in New York City (p.64) that encouraged
customers to bring their spent garments toselect Athleta, Banana Republic and Gap
brand stores for recycling.

thredUP
Artistic Garment
Industries recycles
denim into yarnthat is used to makerecycled Gap jeans.

In 2019 and early 2020, we took these
efforts further through a partnership to tackle
clothing waste. Today, more than 70 percent
of materials used to make clothes end up in
landfills or are burned at the end of their firstlife, and less than 1 percent of old clothing
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Circularity
Hong Kong Research Institute of
Textiles and ApparelIn 2019, we embarked on a new partnershipwith the Hong Kong Research Institute of
Textiles and Apparel (HKRITA) to address
the technology challenge of recycling certain
materials. Our shared mission is to develop
more sustainable production processes andtechnology solutions that enable the industry
to advance circular models across the life
cycle of textiles. We have identified two initialpriorities: separating spandex from usedgarments and decolorizing denim for recycling.
Spandex is commonly used to add stretch andimprove the comfort of fabrics, but currently it
is difficult to separate it from blended fabrics.
HKRITA is partnering with Artistic Milliners,
one of our key suppliers, to develop an
environmentally safe method of separation
using bio-solvents.
To create a new method of denim
decolorization, which traditionally relies on
chemical treatment that can be harmful tothe environment, HKRITA is working with
Arvind Limited, another key supplier. Thismill has also pioneered a method to use
wastewater instead of freshwater indenim manufacturing (p.53). We hope theseinvestments make it easier to recycle, reuseor re-dye textiles that currently end up in thewaste stream.

Global Fashion Agenda

CUSTOMER ENGAGEMENT

In addition to these partnerships, we
continued our engagement with Fashion
Positive and Global Fashion Agenda (GFA)
to explore circularity opportunities. ThroughFashion Positive Plus, we helped create
the first Standard for Circular Materials
guidance.

We are building on our communication withcustomers for a deeper form of engagementthat encourages people who buy our clothing
to make sustainable choices, beginningwith what they purchase and ending withwhat they do with the clothes that they nolonger wear. We communicate our productsustainability efforts through store displays,
product descriptions, product labeling,social media and other channels, as well as
educational campaigns and media around
events like Earth Day and World Water Day.

As part of our 2020 Circular Fashion
Commitment with GFA, we have set threecommitments to achieve by 2020:•

We will train our cross-functional
Product teams for each of our brands
on circular-design techniques and bestpractices.

•

We will help to increase the volumeof used garments collected globally
through participation in pre-competitive,
industry-led collection pilots.

•

We will identify the most promising
recycling technologies for postconsumer materials across multiple
product categories and start scaling
them in our supply chain.

These partnerships are supporting ourstrategy and setting the stage for largescale industry-level innovation.

We addressed clothing waste in 2019
through Make Fashion Circular’s #WearNext
campaign in collaboration with other brands.
For this three-month initiative, our Athleta,
Banana Republic and Gap brand stores in
New York City hosted recycling bins fromthe Department of Sanitation for customers
to drop off unwanted clothing for recycling
or repurposing. In total, our brands involvedin the effort collected and recycled over
two tons of clothing from more than 1,100
collection points.

2 TONSof clothingcollected + recycled
at our NYC storesthrough the#WearNext campaign

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Product Sustainability
We design great products with sustainability in mind while
collaborating across our business and throughout our
industry to improve the sustainability performance of ourbrands and the apparel sector as a whole.
Our brands approach impact reduction throughout
the product life cycle, examining the materials theysource, the products they design and the supplierswith which they work. Each brand takes ownershipof its sustainability journey and uses its unique voice
to communicate directly with its customers on theimportance and impact of producing responsibly andshifting toward a circular economy. Together with ourbrands, Gap Inc. is making our efforts toward developing
more sustainable products accessible and visible to ourcustomers.
Learn more
> Our work on product sustainability

2019 PROGRESSIn 2019, all of our brands enhanced their
dedication through new goals, expandedefforts to embed sustainability into productdesign and raw-materials selection, anddeeper engagement in industry-leading
initiatives. In doing this, our brands arestrengthening their ownership of sustainability
as a unique expression of their brand value totheir customers.
We have several highlights from 2019 and theearly part of 2020:•

Gap Inc. established a new goal to moresustainably source 100 percent of cotton
for all of our brands by 2025.

•

Banana Republic and Old Navy set theirfirst public sustainability goals in honor of
Earth Day.

•

Our Washwell™ technology, which
debuted with Gap brand in 2016 and has
now expanded to Old Navy, Athleta and
Banana Republic, contributed a savings ofmore than 1 billion liters of water toward
our goal of conserving 10 billion liters ofwater, which we achieved in early 2020.

PREFERRED FIBER +MATERIALS TOOLKIT AND
TRAINING
Since launching our internal Preferred Fiber &Materials Toolkit – which we created alongside
Textile Exchange and MADE-BY in 2018 – wehave continued to empower our Product teams
to select the best fibers based on sustainability
impacts through expanded trainings that are

integrated into our companywide learning anddevelopment program. This strategic approachallows us to support progress in a holistic
way by building a sustainability mindset in our
employees, and by giving them the resources
they need to make decisions and take actions
that improve the sustainability of our products.
In addition to life-cycle assessment dataon global-warming potential, water use andeutrophication, we consider a holistic set ofindicators while evaluating our preferred-fibers
strategy including biodiversity, potential for
circularity, chemistry, land-use change andsocial conditions within production.
In 2019, we trained more than 400 Product
Design and Development employees
through our workshops: Sustainability 101,
Sustainability Claims, Fiber Sustainability,
Conscious Design for Circularity, Sustainable
Wet Processing and Sustainable Denim. To
date, we’ve reached over 1,800 employeeswith these workshops. We also continued ourmonthly newsletter on product sustainability,
which now provides the latest sustainability
developments and best practices to 450
employees. In line with our support of the
Circular Fashion Commitment with Global
Fashion Agenda (p.64), we hosted intensive
workshops for many of our Designers andother product-focused teams on how toincorporate circular thinking and sustainability
into their product-creation process.

1,867

Product Design +Development employees
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Raw Materials
We believe great products are created with sustainability
at their core – which means going all the way down to theearliest stages of the product life cycle to reduce impacts.
Our brands are empowered to improve the sustainabilityof their products by selecting the best raw materials thatmeet garments’ performance requirements, while also
meeting Gap Inc. standards for social and environmental
sustainability. We continue to refine and evolve ourstrategy and engage in industry partnerships that focus
on preferred raw materials and circular approaches tomaterials use and end of life.
Learn more
> How we source more sustainable raw materials

2019 PROGRESS

Sustainable Fiber Sourcing

As in previous years, we continued ourstrategy in 2019 to focus on the materials
that account for approximately 97 percent
of our fiber consumption: cotton, polyester,nylon and manufactured cellulosics, suchas rayon and modal.

Fiber TypeOver the year, we focused on further
improving our fabric-management
systems to provide detailed data on our
fiber consumption and volumes, and toincrease our team’s awareness throughtraining programs and shared tools.
Sustainable-fiber consumption reports areprovided to internal decision makers ona regular basis to highlight progress andcontinue to drive improvements.

Natural Fibers
Organic Cotton
BCI Cotton
Recycled Wool

% of Fiber Type
2018

2019

0.2%
40%
3.5%

0.3% of cotton
57% of cotton
15.7% of wool

Synthetics
Recycled Nylon
0.3%
Recycled Polyester 0.7%

0.5% of nylon
0.7% of polyester

Manufactured Cellulosics
Lenzing Modal
3.9%
TENCEL
6.1%

2.4% of rayon
5.4% of rayon

Biodiversity
We commit to support the developmentof SBTs on biodiversity and theimplementation of these targets within our
industry to assure our contribution to theprotection and restoration of ecosystems
and the protection of key species.
Specifically, we commit to develop a
Gap Inc. biodiversity strategy to meet
forthcoming SBTs on biodiversity.

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Raw Materials
CottonSynthetics

Manufactured Cellulosics

Goal

Cotton is one of the most importantfibers for Gap Inc. We focus our cotton
strategy around building fiber security andmaintaining a comprehensive evaluation ofcotton-sourcing risks, as well as building amore sustainable source of cotton that isbetter for people and the planet. As a cropthat is primarily grown in high water-stresslocations such as India, China and Pakistan,cotton is especially vulnerable to waterrelated impacts. We are also seeking to use
more sustainable cotton across all of ourbrands with Gap brand, Banana Republic
and Old Navy having committed to use 100
percent sustainable cotton by 2025. As anenterprise, Gap Inc. has also committed
to source 100 percent sustainable cotton.
This includes Better Cotton Initiative (BCI),
recycled and organic cotton.

The synthetic materials in our products,
including polyester, nylon and spandex,
provide essential performance properties.
However, since they are generally derived
from nonrenewable, petroleum-basedsources, there are concerns about theirproduction and processing; they also do
not biodegrade like natural fibers, providing
limited end-of-life options.

We are working closely with our top suppliers
to support our policy to eliminate our useof wood-derived fibers from ancient andendangered forests by 2020. This commitment
helps to protect critical forests and also
supports our efforts to tackle climate change,
as forest ecosystems are vital natural
resources that promote biodiversity, protect
watersheds and help to mitigate the releaseof carbon dioxide into the atmosphere.
Our policy – developed in partnership with
Canopy’s sustainable fashion and forestry
initiative, CanopyStyle – aims to ensure that
our suppliers do not use ancient, endangered,high-conservation or high-carbon-value
forest areas to make cellulose-based textiles,
including rayon, modal, viscose and lyocell.

Eliminate the use of woodderived fibers sourced fromancient and endangered
forests by 2020

Goal

Source 100% of cotton
from more sustainablesources by 2025
% Cotton from More Sustainable Sources*

Q1 2020 57%
2025
Goal

100%

We’re taking steps to source moresustainable synthetic fibers, including
recycled polyester and recycled nylon. We
have been increasing our use of recycled
polyester and nylon where possible, while
also working to understand how to reduce
manufacturing challenges and develop highperformance products with these materials.
We are also an active member of the
Textile Exchange Recycled Polyester andBiosynthetics Working Groups, investigating
industry innovations toward moresustainable fibers. In 2019, we embarked
on a collaboration with the Hong Kong
Research Institute of Textiles and Apparel(HKRITA) (p.64) that aims to innovate aprocess to separate spandex from otherfibers in used garments to increase its
recycling opportunities.

% Products Compliant
with Our Commitment

2018 77%2019 86%
2020
Goal

100%

To achieve our commitment, we are partneringwith mills on the following: identifying our
raw-material suppliers in order to eliminate
sourcing of wood-derived fibers fromancient and endangered forests; leveraging
CanopyStyle’s audit and remediation plan; andencouraging the development of innovative,
more sustainable fabrics. In partnership with
our major suppliers, we are also exploring
ways to integrate recycled cellulosics into
our products. In 2019, we gathered data on
our supply chain representing more than 80
percent of our cellulosic-fiber volume througha detailed survey and follow-up conversations
with suppliers. Through this data, we showthat 86 percent of our cellulosic volume iscompliant with our commitment. We still havework to do to engage additional suppliers totake the Canopy audit, and encourage someengaged suppliers commit to a remediationplan.

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Brand Goals
Old Navy’s Heart Earth messaging,
established in April 2019, targets focus on
two areas of critical importance to the brandand Gap Inc.: water and cotton. Old Navy is
helping to improve and scale water-saving
efforts and sustainable-cotton sourcing,as well as educating customers on theimportance of more sustainable apparelproduction and waste reduction.
In 2019, Old Navy committed to recycling
hangers from 500 stores, diverting 124,000
pounds of hangers from landfill. The brand isalso updating its packaging standards withan aim to reduce more than 40,000 poundsof plastic annually. Old Navy’s Heart Earth
campaign celebrates these achievements
and highlights the importance of everyday
sustainable choices for its customers.

New Goal

New Goal

Source 100% of cotton
from more sustainablesources* by 2022

Make 100% of denim
products using watersaving techniques* by 2022

% Cotton from More Sustainable Sources% Denim Products Made Using
Water-Saving Techniques

2018 40%2018 60%

2019 56%

2019 88%
2022
Goal

2022
Goal

100%
*Primarily through BCI as well asverified, responsibly grown andrecycled cotton

100%*Includes proven wash processes

88 percent of Old Navy’s denim purchased
for Spring 2019 was made using watersaving techniques, saving 20 percent ormore water in the garment-wash stage,compared with conventional methods.

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Brand Goals

Gap for GoodGap brand launched its consumerfacing Gap for Good platform in 2017 tohighlight more sustainable fashion. The
platform builds on Gap’s Earth Day 2017
commitment to source 100 percent of its
cotton from more sustainable sourcesby 2021. In 2019, Gap brand introduced
BetterMade Denim, a collection of iconic
denim pieces made with organic cotton andfinished with 100-percent recycled thread– the brand’s most sustainable denim to
date.

Goal

Goal

Source 100% of cotton
from more sustainablesources* by 2021

Make 75% of qualifying
products* using Washwell™
water-saving techniquesby 2021% Cotton from More Sustainable Sources

113M

liters of water
saved by Gap brandthrough Washwell™
in 2019% Products Made Using Washwell™
Water-Saving Techniques

2018 53%2018 22%2019 67%
2021
Goal*Includes Better Cotton
Initiative (BCI), recycled
and organic cotton

100%

2019 42%*Qualifying products
include denim jeans,jackets and shorts.

2021
Goal

75%

Washwell™
Since Gap brand’s debut of Washwell™
– a denim wash program that conserves
water in the laundry stage of production –the process is now used across all of ourbrands, and has contributed more than 1billion liters of water savings toward ourgoal to save 10 billion liters of water, which
we achieved in early 2020.
In 2019, 24 Gap brand vendors
participated in Washwell™, an increase
from 19 vendors in 2018. We saved 113
million liters of water through Washwell™
in 2019, an increase from 98.9 million liters
in 2018.

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Brand Goals
As a brand, Banana Republic is committed
to creating timeless clothing designed withquality and durability in mind. After working
in 2018 and 2019 to integrate sustainability
into design and manufacturing decisions
to reduce the environmental impacts ofeach garment, Banana Republic unveiled
its sustainability goals on Earth Day 2019:source 100 percent of cotton from moresustainable sources, use environmentally
preferred fibers, reduce water impacts
and promote cleaner chemistry. In honorof Earth Day 2020, the brand introduced
Better Republic, a forward-thinking idealthat underscores the brand’s sustainability
goals and commitment to do better for
people and the planet, along with a
Sustainable Shop on bananarepublic.com.
As part of its commitment to use lesswater and promote cleaner chemistry
in the manufacture of its products,
Banana Republic is partnering with the
Spanish denim mill Tejidos Royo to use
an innovative dyeing technique – Dry
Indigo®. This process reduces water use
by up to 99 percent (requiring just one
teaspoon of water per pair of jeans), uses
89 percent less chemicals, and reduces
energy consumption by 65 percent. The
first products manufactured with thistechnology launched in stores and online
in spring 2019.

New Goal

New Goal

Source 100% of cotton
from more sustainablesources* by 2023

Make 50% of productswith sustainable fibers*
by 2023% Cotton from More Sustainable Sources% Products Made with Sustainable Fibers

2018 45%2018 28%2019 75%*Primarily through Better Cotton
Initiative (BCI), as well as recycled
and organic sources

2023
Goal

2019 55%
2023
Goal

100%

New Goal

Make 50% of products
using water-saving
techniques* and cleaner
chemistry practices** inour supply chain by 2025

50%
*Includes cotton through BCI, as well as
recycled and organic sources; partnering with
Canopy-compliant suppliers to source preferredmanufactured cellulosics; recycled and responsiblewool from vendors that are compliant under the
Responsible Wool Standard; and recycled materials

New Goal

Make more eco-friendly*
denim by 2023

% Spring 2020 Products Made withTechniques that Save Water or
Preserve Water Quality% Denim that is Eco-Friendly

2019 1.4%

Q2 2020 68%*Techniques that save at least
20 percent of water compared
to conventional methods at millfacilities; includes Washwell™
**Through Gap Inc.’s Zero Dischargeof Hazardous Chemicals (ZDHC)
commitment, ongoing efforts toselect preferred chemistry options,and preferred dyeing techniques

2025
Goal

50%

*Includes Washwell™; sustainablecotton primarily through BCI,
as well as recycled and organic
sources; more sustainable dyeing
methods, such as foam dye;eco-friendly finishes, such as biosofteners and laser technology;
and trims made with recycledmaterials

2023
Goal

100%

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Brand Goals
POWER OF SHE
Athleta has a strong commitment toenvironmentally conscious products
and sustainable practices. The brandbelieves in protecting the Earth as anatural playground, positively contributing
to the direction of the apparel industry,offering customers responsible options,driving demand for sustainable goods, andsupporting the empowerment of womenand girls.
Following a significant year in 2018 when
Athleta received its B Corp certificationand formed an internal governancecommittee to support its sustainability
efforts, the brand continued working
toward its goals in 2019 to protect
resources, conserve water, divert waste
and empower women. Athleta also
continued to engage customers in its
sustainability story, using prominent
messaging in stores and catalogs on thebrand’s five core values and progress
toward its 2020 sustainability goals.
In 2019, Athleta joined forces with Allyson
Felix to empower women and girls
through sports. Allyson is one of the mostdecorated track-and-field athletes in U.S.
history and is our first-ever sponsoredathlete. In addition to building confidence
in women and girls and encouraging themto use their voices, Allyson partners on
the design of high-performance productand plays a key role in our Power of She
campaign.

16K+

Goal: Protect Resources

Goal: Conserve Water

Make 80% of materials
with sustainable fibers
by 2020Make 25% of products
using water-saving
techniques by 2020

% Materials Made with 30% or More
Sustainable Fibers% Products Made Using
Water-Saving Techniques2017 35%2017 1%2018 46%2018 4%2019 70%

2019 4%25%

80%

Goal: Divert Waste

Goal: Empower WomenDivert 80% of store wastefrom landfill by 2020

Impact 10,000 women
through P.A.C.E. andFair Trade by 2020

% Waste Diverted from Landfill

Women Who Participated in P.A.C.E. or
Received Premiums from Fair Trade USA*2017 70%
2018 70%

2017
2,503

2019 72%
Allyson Felix: Track andfield athlete, mother,
activist and Athleta partner

2020
Goal

2020
Goal

women reachedthrough P.A.C.E.
and Fair Trade

2020
Goal

2018
3,212

2020
Goal

2019
16,55510K

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Brand Goals
Intermix has taken a leadership rolein sustainability within the multibrandcontemporary market with a mission toeducate its 300+ brand partners on moresustainable sourcing, to reduce single-use
plastic in packaging and to demonstrate howcontemporary fashion can be sourced withmore sustainable raw materials through its
private-label brand.
In 2019, Intermix, in partnership with the
Gap Inc. Global Sustainability team, hosted
its first Sustainability Summit with its New
York-based top brands. At the summit,
Intermix established its commitment tobecome more sustainable and held aworkshop on the first steps that brands cantake to source more responsibly. Since then,Intermix has worked to reduce the numberof garments shipped on plastic hangers andsource a new cardboard hanger to replace
existing plastic hangers. The company
is currently testing this new hanger andencouraging its brand partners to adopt
this more environmentally friendly option,a switch that could have an exponential
impact. Lastly, Intermix has begun to convert
fabrics and yarns used in its private-label
line, Intermix Collection, to more sustainableoptions, such as swapping polyester forrecycled polyester.
Intermix has an internal “Green Team” ofvolunteer employees who champion andoperationalize its sustainability goals.

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Sustainable Development Goals

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Sustainable Development Goals
The Sustainable
Development Goals (SDGs)
developed by the United
Nations are a blueprint toachieve a better and moresustainable future for all.
To meet these goals,
everyone – from business,to government to civilsociety – must do theirpart.
After the SDGs wereadopted, we assessed
Gap Inc.’s opportunities
to advance progress on
the individual targets.
This assessment revealed
that our company’ssustainability efforts alignmost closely with six of thegoals. While some of ourprograms may contributeto other goals, we havemapped Gap Inc. initiatives
and goals against thesesix SDGs to demonstrate
how we are contributing toachieving global targets.

Ensure inclusive
and equitable
quality educationand promote
lifelong learning

Achieve genderequality andempower all
women and girls

Our Work> Talent (p.20)> P.A.C.E.: Empowering Women (p.43)> This Way Ahead: First Jobs (p.29)

Our Work> Equality + Belonging (p.22)> P.A.C.E.: Empowering Women (p.43)> Women + Water (p.50)

Our Goal
Hire 5% of entry-level employees throughThis Way Ahead by 2025

Our Goal
Reach 1 million women through P.A.C.E.
by 2022

Promote inclusive
and sustainableeconomic growth,
employment anddecent work for all

Ensure accessto water andsanitation for all

Our Work> Women + Water (p.50)> Resource Efficiency + Manufacturing (p.52)> Mill Sustainability Program (p.54)> Chemicals Management (p.56)
Our Goal
Save 10 billion liters of water in manufacturing
by 2020, from a 2014 baseline

Ensure sustainableconsumption andproduction patterns

Our Work> Talent (p.20)> Equality + Belonging (p.22)> This Way Ahead: First Jobs (p.29)> Supplier Sustainability (p.32)

Our Work> Chemicals Management (p.56)> Waste (p.62)> Circularity (p.63)> Product Sustainability (p.66)

Our Goal
100% of supplier facilities producing
branded apparel are rated yellow or
green by 2020

Our Goal
Source 100% of cotton from moresustainable sources by 2025

Take urgent action
to combat climatechange and its
impacts

Our Work> Climate (p.59)
Our Goals
Carbon neutral across our value chain by
2050
Reduce absolute Scope 1 and 2 GHG
emissions by 90% and Scope 3 GHG
emissions from purchased goods andservices by 30% by 2030 from a 2017baseline

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SASB Reference Table
The Sustainability Accounting Standards Board (SASB) is an independent, private-sector standards-setting organization dedicated to enhancing the efficiency of the capital markets by fostering highquality disclosure of material sustainability information that meets investor needs. This table references the Standard for the Apparel, Accessories & Footwear industry as defined by SASB’s Sustainable
Industry Classification System (SICS) with the location of that information in Gap Inc.’s Global Sustainability Report (GSR) and gapincsustainability.com.

Topic

Managementof Chemicals in
Product

Environmental
Impacts in the
Supply Chain

Activity Metric

Category

Unit ofMeasureNumber of (1) Tier 1 suppliers and (2)suppliers beyond Tier 1

Quantitative

Description of processes to maintaincompliance with restricted substances
regulations

Code

Data

Reference

NumberCG-AA000.A

As of 2/1/2020 (FY’19), we sourced from 737 Tier
1 branded-apparel supplier facilities, defined as
direct-relationship cut-and-sew facilities and theirassociated embroidery, laundry and screen-printing
facilities. We have mapped out 191 mill facilities that
represent about 75% of our business in 2019.

> Social: Supply Chain> GSR: Assessment + Remediation(p.33)> GSR: Mill Sustainability Program(p.54)

Discussion
and Analysis

N/A

CG-AA250a.1> Environment: Chemicals> GSR: Chemicals Management(p.56)

Discussion of processes to assess
and manage risks and/or hazards
associated with chemicals in products

Discussion
and Analysis

N/A

CG-AA250a.2> Environment: Chemicals> GSR: Chemicals Management(p.56)

Percentage of (1) Tier 1 supplierfacilities and (2) supplier facilities
beyond Tier 1 in compliance with
wastewater discharge permits and/or
contractual agreements

Quantitative

Percentage (%)

CG-AA430a.1

100% of Tier 1 supplier denim laundries are
expected to have wastewater meeting or exceeding
legal requirements, in accordance with our Water
Quality Program (WQP). In 2018, we enhanced theprogram by adopting Zero Discharge of Hazardous
Chemicals (ZDHC) Wastewater Guidelines as
WQP requirements for wastewater sampling andtesting; 48 denim laundries participated, with 87.5%
of facilities meeting conventional parameters and
79.2% of facilities meeting ZDHC parameters.
Supplier Facilities beyond Tier 1• N/A
Through strategic partnerships with the Sustainable
Apparel Coalition (SAC) and Zero Dischargeof Hazardous Chemicals (ZDHC), we expect
strategic Gap Inc.-approved mill facilities to reportcompliance with wastewater-discharge permits and
ZDHC Wastewater Guidelines.

> Environment: Mills + Laundries> GSR: Water Stewardship
Strategy (p.47)> GSR: Resource Efficiency +Manufacturing (p.52)> GSR: Chemicals Management(p.56)

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SASB Reference Table
Topic

Activity Metric

Category

Unit ofMeasureEnvironmental
Impacts in the
Supply Chain(continued)

Percentage of (1) Tier 1 supplierfacilities and (2) supplier facilities
beyond Tier 1 that have completed
the Sustainable Apparel Coalition’s
Higg Index Facility Module (Higg
FEM) assessment or an equivalentenvironmental data assessment

Quantitative

Percentage (%)

Labor Conditions Percentage of (1) Tier 1 supplierin the Supply
facilities and (2) supplier facilities
Chain
beyond Tier 1 that have been audited
to a labor code of conduct, (3)percentage of total audits conductedby a third-party auditor

Priority non-conformance rate andassociated corrective action rate forsuppliers’ labor code of conduct audits

Discussion of greatest (1) labor and (2)environmental, health, and safety risks
in the supply chain

Quantitative

Quantitative

Discussion
and Analysis

Percentage (%)

Rate

N/A

Code

Data

Reference

CG-AA430a.2

100% of Tier 1 suppliers were requested
to complete the SAC’s Higg Index Facility
Environmental Module.
• 97% of active Tier 1 branded apparel suppliers
completed the 2018 data request.
Suppliers beyond Tier 1 were requested to complete
the Higg Index FEM.
• 174 out of 191 Tier 2 mills have completed theHigg Index FEM (91% of strategic mills).

> Measuring Our Progress:
Environment

90.6% of Tier 1 branded apparel suppliers that wereactive for the full year were audited to our Code ofVendor Conduct (COVC) during the fiscal year.
• 34% of audits were conducted by a third-party
assessor, primarily through ILO Better Work.
• Facilities with a consistently low nonconformance rate may be assessed on abiannual basis; all facilities are audited prior toinitial 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.

> Measuring Our Progress:
Working Conditions

As of fiscal year 2019, 2% of facilities received red
ratings during assessments against our Code ofVendor Conduct.
For issues open as of 2/1/2019, 82% of corrective
action plans were resolved by 1/31/2020.

> Measuring Our Progress:
Working Conditions> Environment: Supply Chain> Social: Working Conditions> GSR: Water Stewardship Strategy (p.47)> GSR Supplier Sustainability(p.32)

CG-AA430b.1

CG-AA430b.2

CG-AA430b.3> GSR: Water Stewardship
Strategy (p.47)> GSR: Resource Efficiency +Manufacturing (p.52)> Social: Working Conditions> Gap Inc. Code of Vendor
Conduct (COVC)> Gap Inc. Supplier Facility List
> Environment: Mills + Laundries> GSR: Assessment +Remediation (p.34)> GSR: Assessment +Remediation (p.33)> GSR: Chemicals Management (p.56)

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Topic

Activity Metric

Category

Raw Material
Sourcing

Discussion of environmental and social
risks associated with sourcing priority
raw materials

Discussion
and Analysis

Percentage of raw materials third-party
certified to an environmental and/or social sustainability standard, bystandard

Quantitative

Unit ofMeasureN/A

CodeReference

Data

CG-AA440a.1> Environment: Raw Materials> GSR: Raw Materials (p.68)

Percentage (%)
by weight

CG-AA440a.2

Fiber Type% of Fiber Type

Natural Fibers
Organic Cotton
BCI Cotton
Recycled Wool

0.3% of cotton
57% of cotton
15.7% of wool

> Environment: Raw Materials> GSR: Raw Materials (p.67)

Synthetics
0.5% of nylon
Recycled Nylon
Recycled Polyester 1.1% of polyester
Manufactured Cellulosics
2.4% of rayon
Lenzing Modal
TENCEL		
5.4% of rayon

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