CODE OF
VENDORCONDUCTTABLE OF
CONTENTS
3OVERVIEW

5PROVISIONS & STANDARDS5COMPLIANCE WITH LAWS

9ENVIRONMENT

12

LABOR

28

OCCUPATIONAL HEALTH AND SAFETY

36

MANAGEMENT SYSTEMS2OVERVIEW

3

GAP INC. CODE OF VENDOR CONDUCT| OVERVIEWThis Code of Vendor Conduct (COVC)
applies to all facilities that produce goods
for Gap Inc. or any of its subsidiaries,
divisions, affiliates or agents. Gap Inc.
recognizes that there are different
legal and cultural environments inwhich facilities operate throughout theworld. This Code sets forth the basic
requirements that all facilities must meetin order to do business with Gap Inc.
This Code is based on internationally accepted labor
standards and guidance, including the International
Labour Organization (ILO)’s core conventions, the Universal
Declaration of Human Rights, and the United Nations (UN)Guiding Principles for Business and Human Rights. This
Code also supports Gap Inc.’s human rights commitments,
as outlined in the company’s Human Rights Policy. This Codeprovides the foundation for Gap Inc.’s ongoing evaluationof a facility’s employment practices and environmental
compliance.
Facility assessments promote increased awareness of labor
conditions to Gap Inc., facilitate greater partnership with thecompany’s suppliers, drive improvements in sustainability
performance, and ultimately generate positive change.
4PROVISIONS & STANDARDSCOMPLIANCE
WITH LAWS

5GAP INC. CODE OF VENDOR CONDUCT| CO MPLIA NCE WITH LAWS

The facilities that produce goods for
Gap Inc. shall operate in full compliancewith the laws of their respective countries
and with all other applicable laws, rules
and regulations as a condition of doing
business with Gap Inc. Should there be adifference in the requirements set out by
local legislation and those in the Gap Inc.
COVC, the more stringent requirement
shall apply. Vendor and Vendor Affiliates
shall use only Gap Inc.-approved facilities
for the production of goods. Vendors
shall obtain written authorization fromGap Inc. to use these facilities prior to
the start of production.

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GAP INC. CODE OF VENDOR CONDUCT| CO MPLIA NCE WITH LAWSCOMPLIANCE WITH LAWS
The facility shall operate in full compliance with all applicable laws, rules, andregulations including those relating to labor, worker health and safety, andthe environment.
WORKER INTERVIEWS
The management at the facility shall not coach or require workers to provide
certain answers to assessors during confidential worker interviews.
BRIBERY
The facility shall not tolerate, permit, or engage in bribery, corruption, fraud,or unethical business practices in dealing with business partners, public
officials, or any Gap Inc. representatives.
U.S. FOREIGN CORRUPT PRACTICES ACT (FCPA)The facility shall comply with the U.S. Foreign Corrupt Practices Act (FCPA)and must not engage in corrupt or unethical practices, such as accepting oroffering bribes in exchange for preferential treatment or employment.
TRANSPARENCY
The facility shall be transparent with their policies, processes, and records
applicable to their operations and compliance levels with the Gap Inc. COVC
and any Supplemental Requirements. All records and documents provided
to Gap Inc. representatives, including but not limited to payroll and timekeeping records, should be complete and accurate.
UNRESTRICTED ACCESS
The facility shall allow Gap Inc. representatives or agents unrestricted accessto its’ facilities, workers for interviews, and the review of relevant records at all
times, regardless of whether advance notice is provided.
EMPLOYMENT CONTRACTS
The facility shall keep all applicable records and documentation referenced inthis standard on-site and available to Gap Inc. representatives for at least 12
months from termination date of an employee.
SUB-CONTRACTING
Vendors shall only use Gap Inc.-approved facilities for the production of
goods. Vendors shall obtain written authorization from Gap Inc. to use thesefacilities prior to the start of production.

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GAP INC. CODE OF VENDOR CONDUCT| CO MPLIA NCE WITH LAWS

FACILITY EXPANSIONIn the case of expansion of the existing approved facility, the facility/vendor
shall inform Gap Inc.’s Supplier Sustainability team as soon as the expansion
is ready. The vendor shall not move any Gap Inc. production to the expanded
area before receiving written approval from Gap Inc.
SUBCONTRACTOR MONITORING (HANDWORK)The facility shall engage in monitoring and verification of their handwork
subcontractors to assess and address any risk associated with all sections of
the COVC.
GAP INC. COVC POSTER
The facility shall ensure that Gap Inc.’s COVC poster is posted in at least one
conspicuous location in the facility that is regularly accessible to workers andis written in the predominant language(s) of the workers.
WORKER-MANAGEMENTCOMMUNICATION

The facility shall constitute and manage worker-management communication
forums in compliance with applicable laws.
CHILD CARE FACILITIESThe facility shall provide childcare facilities wherever required by law.
APPRENTICE AND VOCATIONAL PROGRAMS
Any apprenticeship or vocational education programs provided at the facility
shall be legal, documented, and designed for the educational benefit of theworkers.

8

PROVISIONS & STANDARDSENVIRONMENT

9GAP INC. CODE OF VENDOR CONDUCT| ENVIRON MENTThe facility shall comply with all applicable
environmental laws and regulations.
The facility must manage their environmental
impacts, including energy and greenhousegas (GHG) emissions, air pollution(air emissions), water consumption,water quality, wastewater, waste diversion
and disposal, as well as chemical use
and handling.
ENVIRONMENTAL MANAGEMENT SYSTEM
The facility shall have an Environmental Management System (EMS).
ENVIRONMENTAL EMERGENCY PLAN
The facility shall have an Environmental Emergency Plan (EEP) that includes
procedures for notifying local community authorities in case of accidental
discharge or any other environmental emergency.
WASTEWATER TREATMENT POLICY AND PROCEDURE
The facility shall maintain an up-to-date Wastewater Treatment Policy andProcedure. All industrial and domestic wastewater shall be treated to meet thedischarge requirements of local laws. In addition, the facility shall comply withall applicable monitoring and reporting requirements. As such, the treatment
facility must be appropriately sized to process effluent of all production
processes and shall not be left idle during production times.
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GAP INC. CODE OF VENDOR CONDUCT| ENVIRON MENTWATER QUALITY PROGRAM
The denim laundry facilities shall comply with the requirements of theGap Inc. Water Quality Program (WQP).
CHEMICALS INVENTORY
The facility shall maintain a current Chemical Inventory that lists all chemicals
used in the facility and the supplier’s name.
RESTRICTED SUBSTANCES LIST
The facility shall adhere to chemical restrictions, as described in the
Gap Inc. Restricted Substances List (RSL), and shall prohibit the use ofbanned chemicals in manufacturing processes, as described in the
Zero Discharge of Hazardous Chemicals - Manufacturing Restricted
Substances List (ZDHC MRSL).
CHEMICALS STORAGE
The facility shall ensure that the chemicals and hazardous substance storage
areas are maintained in an organized and safe manner, with clear and properlabelling of chemical containers.
CHEMICAL HANDLING PROCEDURES
The facility shall have defined safe chemical handling procedures and shalltrain workers on these procedures and the hazards of chemical exposure.
CHEMICAL DISPOSAL
The facility shall segregate hazardous from non-hazardous materials and shalldispose of both types of materials in a safe and legal manner.
SAC HIGG INDEX FACILITY ENVI RONMENT MODULE
The facility shall complete and submit the Higg Index Facility Environment
Module as per Gap Inc.’s required timeline.

11

PROVISIONS & STANDARDS

LABOR

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GAP INC. CODE OF VENDOR CONDUCT | LABOR

The facility shall only employ workers whomeet the applicable minimum legal age
requirements or who are at least 15 years ofage, whichever is greater. The facility mustalso comply with all other applicable childlabor laws. The facility is encouraged todevelop lawful workplace apprenticeshipprograms for the educational benefit of
their workers, provided that all participants
meet both Gap Inc.’s minimum age
standard of 15 and/or the minimum legal
age requirement.

13

GAP INC. CODE OF VENDOR CONDUCT | LABORCHILD LABORAt the facility, all workers shall meet the applicable legal minimum age
requirements or are at least 15 years of age, whichever is greater. If theminimum legal age is higher under local law, the higher age applies.
No workers under the age for mandatory schooling shall be employed by
the facility.
Facility management shall have a rigorous age verification procedurethat includes maintaining copies of official government-authenticateddocumentation for every worker and confirmation of the worker’s date ofbirth. In countries where official proof-of-age documents, birth certificates,or government-issued IDs are not available, the facility shall employ
independent and reliable means for determining workers’ age.
In countries where no reliable documentation exists, the facility shall
implement a recruitment system that appropriately assesses the age ofpotential workers.
The facility shall take all necessary precautions to ensure that young/juvenile
workers, under the age of 18, are protected from working conditions that could
pose a danger to their health, safety, or development (this includes restrictions
on night work, any job function considered hazardous, etc.).
The facility shall obtain necessary authorizations and pay the appropriate
minimum wages, overtime, and legally entitled bonuses for workers. The
facility shall follow legal exceptions to the minimum wage and any legally
entitled bonuses and/or benefits of young workers.
The facility shall obtain necessary legal approvals (permits/medical check-up
records, etc.) for all young/juvenile workers.
The facility shall have the required tracking system for all young/juvenile
workers (e.g. young worker register).
The facility shall comply with all education-related government programs.

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GAP INC. CODE OF VENDOR CONDUCT | LABORFOREIGN CONTRACT LABOR
The facility shall ensure, if it recruits or employs Foreign Contract Workers,
that these workers are treated fairly and on an equal basis with its local workers.
The facility shall ensure that migrant workers are not subject to any form offorced, compulsory, bonded, or indentured labor. The facility shall ensurethat all work must be voluntary and workers must be free to terminate theiremployment at any time, without penalty. The facility shall ensure that
migrant workers (or their family members) shall not be threatened withdenunciation to authorities to coerce them into taking up employment or
preventing them from voluntarily terminating their employment, at any time,
without penalty.
EMPLOYMENT CONTRACTS
The facility shall ensure that employment contracts are legally enforceable,clear, written in the employee’s language, and executable the worker’s
home country. The facility shall ensure that applicants have an opportunity
to review or are guided through the provisions before signing andreceiving a copy of the contract. The facility shall provide each applicant
with a contract for employment (“Employment Contract”) and ensure thatthe terms and conditions of the contract do not contravene applicablelaws or the Foreign Contract Labor standards of this Code.
EMPLOYMENT TERMS
The facility shall ensure that Employment Contracts are aligned with all
requirements in this Code and must specify:– Worker’s name– Passport details– Detailed address in home country– Secondary contact (contact for emergencies)– Type of work to be performed, job title, occupation category if
applicable, and location– Term (duration) of the contract– Minimum and overtime wage rates to be paid
– Bonuses, any indemnities, or allowance to be paid
– Maximum allowable overtime hours consistent with the laws of thehost country and Gap Inc. COVC
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GAP INC. CODE OF VENDOR CONDUCT | LABOR– All benefits to be provided (including medical coverage, sick leave,annual leave, and holidays)– All deductions to be taken (including charges for food and housing)– Estimated minimum net pay that the worker can expect per month– Summary of the living conditions– Detailed information on any Medical Testing that is required by lawsof workers’ home country or host country– Payments to be received at the end of contract, including transportation– Terms of recourse for early contract termination with and without
reasonable notice by the employer or the employee with regards topayments due and travel expenses for repatriation.
HOST COUNTRY EMPLOYMENT CONTRACT
The facility shall not modify or impose any additional terms or
requirements on the worker after the Employment Contract is signed
unless expressly required by law. Under no circumstances is contract
substitution permitted. If the receiving/host country law requires anadditional contract to be signed, the facility shall ensure that it contains
exactly the same content and provisions as that signed in the sending/home country.
ORIENTATION TRAINING
The facility shall ensure that Orientation Training is provided for all foreign
contract workers (where possible, Orientation Training is provided in
the home country prior to departure). In all cases, Orientation Training
shall include the following and be in a language the worker understands:
Employment terms and conditions; Living conditions in the host country;
Dormitory rules; Workplace conditions; Rights and responsibilities; andRequired job skills.
RECRUITMENT AGENCIES
If the facility uses recruitment agencies, they shall only be used under
the following conditions: A) The agency is licensed by the home country
government, and where applicable the host country government.
B) A written contract exists between the facility and the recruitment agency
that clearly defines all hiring practices. C) Recruitment agency discloses all
the information regarding the use of any sub-contractors, sub-agents or

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GAP INC. CODE OF VENDOR CONDUCT | LABOR

any individual for recruiting workers for the facility. D) The facility (including
its employees and representatives) does not accept any reimbursements,
kickbacks or other amounts from the recruitment agency or other person
involved in the recruiting process.
RECRUITMENT AGENCY DUE DILIGENCE
The facility shall have in place a mechanism to ensure that all third-party
employment agencies (in sending and receiving countries, as applicable)
recruit workers ethically and in compliance with relevant laws and theCOVC. The facility shall maintain documentation demonstrating third-party
employment agencies’ abide to relevant laws and the COVC.
HOST COUNTRY FEES
The facility shall pay all fees and costs payable to the host government forthe documentation of Foriegn Contact Worker’s employment in the hostcountry, including any levies, fees for work permit, and fees for renewing
work documents. The facility shall not at any point deduct from wages,
charge workers, or otherwise accept reimbursements to re-coup thesefees. The facility or the recruitment agency shall not collect from Foreign
Contract Workers a deposit or bond or withhold part of Foreign Contract
Workers’ earnings at any point of their employment.
CONTROL OF EARNINGS
The facility shall allow workers full and complete control over earnings andshall not withhold any “guarantee money” or recruitment fee sums frompay otherwise due to Foreign Contract Workers.
RECRUITMENT FEE CHARGEBACKThe facility shall pay all fees and costs payable to the Foreign Contract
Workers’ home government for the documentation of their deployment
to the host country, including recruitment agency fees, visa fees, medical
checks, and any costs that are not the legal responsibility of the worker.
The facility shall not at any point deduct from wages, charge workers orotherwise accept reimbursement to re-coup these fees (including thosepayable to the home government).
TRANSPORTATION
The facility shall arrange and pay for all of the workers’ airfare and/or otherreasonable transportation costs back to the workers’ home country at theend of the contract term or if the contract is terminated by the facility.

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GAP INC. CODE OF VENDOR CONDUCT | LABOR

In cases where the worker wishes to leave the facility prior to the end ofcontract for any reason, the travel costs shall be paid on a pro-rata basis,
as agreed in the contract. The facility shall not at any point deduct fromwages, charge workers, or otherwise accept reimbursement to re-coupthese fees.
FINAL PAYMENT AND RETURN FEE
The facility shall ensure that at the end of the worker contract, workers
are paid and receive all settlement owed to them, including last-salary
payments, return fee (if applicable), end of service bonus, and any annual
leave days owed to the worker.
NEW FACILITIES—FOREIGN CONTRACT LABOR REQUIREMENTS
For all existing contract workers that paid home country fees, recruitment fees,or host country fees prior to facility’s approval by Gap Inc., the facility must:
A) Pay to the worker a “Return Fee” in addition to any wages, benefits,
or other amounts due and owing to the worker at the time of his/her
return to the home country based on the completion of their contract.
B) Reimburse any host country fees paid by existing workers. C) Provide
written communication to the worker with the amount of the Return Fee andconditions of payment.
CONTROL OF PASSPORTS
The facility shall allow the worker full control over his or her identity papers,
passports or similar documentation and shall provide the worker with alocked and secure storage space in which to keep this documentation.
FOREIGN CONTRACT WORKER DISCRIMINATION
The facility shall not engage in discriminatory practices against foreign
contract workers on the basis of their status as Foreign Contract Workers.
Foreign Contract Workers shall be given equal treatment as local workers,
having equal access to opportunities to working conditions, such as wages
and benefits, as legally permissible as possible.
DOCUMENTATION
The facility shall ensure that the recruitment and employment of Foreign
Contract Workers complies with applicable laws. The facility shall maintainthat the Foreign Contract Workers have the proper legal documents as totheir stay and employment in the host country.

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GAP INC. CODE OF VENDOR CONDUCT | LABORFOREIGN CONTRACT WORKER LIST
The facility shall maintain and update relevant documentation of its
Foreign Contract Workers, including a register of Foreign Contract
Workers/roster with details on contract dates, validity of work
permit, passports, etc.
DISCRIMINATION
The facility shall employ workers on the basis of their ability to do thejob, not on the basis of their personal characteristics or beliefs.
DISCRIMINATORY EMPLOYMENT PRACTICESThe facility shall hire, promote, pay wages and benefits, terminate,
and provide access to trainings, without regard to race, color, gender,
nationality, religion, age, maternity, marital status, indigenous
status, ethnicity, social origin, disability, sexual orientation, HIV/AIDS
status, or membership in workers organizations including unions orpolitical affiliation. The facility shall ensure that hiring, promotion,and other human resource decisions shall be made on the workers’
qualifications, skills, ability, productivity, and overall job performance.
The facility shall comply with applicable wage and hour labor laws
and regulations governing worker compensation and working
hours. Workers with the same qualifications, skills, experience, andperformance shall receive equal pay for equal work in accordancewith applicable labor laws.
DISCRIMINATION: RECRUITMENT PROCESSThe facility shall ensure that hiring notices and job descriptions do
not specify discriminatory factors, such as gender, age, race, etc.
DISCRIMINATORY MEDICAL EXAMINATIONS
The facility shall ensure that the use of medical examinations, such as
pregnancy or HIV/AIDS tests, to prevent a worker from being hired
is prohibited. Medical tests, if required by law, shall comply withrequirements and shall not be used in any discriminatory manner.
DISCRIMINATION FOR PREGNANCY AND MATERNITY
The facility shall ensure that pregnancy shall not be used as a basis
for discriminatory practices like termination/demotion/pay cuts etc.

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GAP INC. CODE OF VENDOR CONDUCT | LABORRELIGIOUS OBSERVANCES
The facility shall ensure that religious observances, prayer breaks, andreligious holidays are not prohibited.
FORCED LABOR
The facility shall not use involuntary labor of any kind, including prison labor,
debt bondage, slave labor, or forced labor by governments.
FREE EGRESSThe facility shall ensure that if entrances are guarded for security reasons,workers shall have free egress at all times.
RESTRICTIONS TO VOLUNTARILY ENDING EMPLOYMENTThe facility shall not employ tactics to prevent workers from leaving at will,such as withholding salary as a “year-end bonus” or charging a penalty
when workers terminate their contract, or by withholding any personal
identification documents such as IDs and passports.
RESTRICTIONS ON WORKER MOVEMENT
The facility shall ensure that beyond reasonable restrictions, workers canmove freely within the facility to use the toilets, drink water, and takedesignated breaks.
WORKER TIME OFF DUE TO EMERGENCIESThe facility shall ensure that workers are allowed to leave freely at the endof the shift or during the shift under extenuating circumstances like illness
or family emergencies.
FREEDOM OF ASSOCIATION
The facility shall recognize that workers are free to join associations of their own
choosing. The facility shall not interfere with workers who wish to lawfully andpeacefully associate, organize, or bargain collectively. The facility shall support
that the decision whether or not to do so shall be made solely by the workers.
COMPLIANCE WITH APPLICABLE LAWS
The facility shall ensure that workers are free to choose whether or not tolawfully organize and join associations. If freedom of association and/orcollective bargaining are restricted by law, workers shall be free to develop
parallel means for independent and free association and collective bargaining.

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GAP INC. CODE OF VENDOR CONDUCT | LABORTHREATS TO FREEDOM OF ASSOCIATION
The facility shall not threaten, penalize, restrict, or interfere with workers
lawful efforts to join associations of their choosing, carry out their union
activities including union meetings, demonstrations, and lawful strikes.
COLLECTIVE BARGAINING
The facility shall ensure that workers have the right to negotiate acollective bargaining agreement. If a collective bargaining agreement
exists, the facility shall comply with all contractual provisions.
DEDUCTING UNION MEMBERSHIP FEES
The facility shall not deduct union membership dues, fees, or fines fromworkers’ wages without the express and written consent of the individual,
unless otherwise specified in a freely negotiated and valid collective
bargaining agreement or when required by law.
INTERFERENCE WITH ASSOCIATION PROCESSThe facility shall ensure workers have the right to elect leaders andrepresentatives of their unions without management interference.
SPECIAL PROTECTION TO WORKERS
The facility shall ensure worker representatives are not discriminatedagainst and have regular access to company management in order toaddress grievances and other issues.
ACCESS TO FACILITIESThe facility shall not prohibit representatives of the trade union frominteracting with workers so long as the terms of the engagement meetthe conditions established by the law or mutual agreement between thefacility and the union.
FREEDOM TO CHOOSE ORGANIZATIONS
The facility shall not interfere where more than one union exists within afacility and shall not favor one union over another.

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GAP INC. CODE OF VENDOR CONDUCT | LABORHUMANE TREATMENT AND DISCIPLINARY PRACTICESThe facility shall treat all workers with respect and dignity. The facility shall notuse corporal punishment or any other form of physical or psychological coercion.
PHYSICAL ABUSE
The facility shall not use physical corporal punishment, force that causes bodily
harm or pain, or other forms of physical contact to punish or coerce workers.
VERBAL AND SEXUAL ABUSE
The facility shall not engage in or permit psychological coercion or any
other form of non-physical abuse, including threats of violence, sexual
harassment, screaming, or other verbal abuse.
DISCIPLINARY ACTIONS
The facility shall have a policy that clarifies and standardizes discipline.
Disciplinary actions and processes shall consist of an escalating series ofactions, starting with warnings, followed by disciplinary actions (e.g. fromverbal warning, written notice, to suspension and termination). The facility
shall maintain written records of disciplinary actions taken. Discipline,
either in policy or in practice, shall meet applicable laws and requirementsof this Code. The facility shall formally communicate with workers the rules
and disciplinary processes at the time of hire.
GRIEVANCE CHANNELS AND RETALIATION
The facility shall ensure that workers have means to report grievances
to management, including a channel that provides for confidentiality
and anonymity. The facility shall also ensure workers can bring tomanagement’s attention grievances through means other than their
immediate supervisor. The grievance system shall include addressing
grievances in a timely manner and documenting grievances andmanagement action on grievances.
The facility shall provide for a system for addressing disputes in theworkplace, whether between co-workers or between workers andsupervisor or manager. The facility shall ensure that such grievancechannels and mechanisms for resolving disputes and grievances provide
for protection from retaliation.

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GAP INC. CODE OF VENDOR CONDUCT | LABORSECURITY PERSONNEL
The facility shall ensure that on-site security personnel, including workers
hired directly by the facility or workers hired by a third-party service
provider, conduct routine and emergency activities in a way that ensures
the highest levels of safety and security while also protecting the dignity of
the worker.
The facility shall ensure that no force is used except in self-defense and insituations where there is a clear and present danger to themselves or otherworkers. The use of force in these limited circumstances is proportional to
the situation and within the boundaries of the law.
PAT-DOWNS
The facility shall ensure that should worker searches, such as “pat-downs”
or hand bag searches be necessary, all worker searches are conducted in
the open and any physical searches are performed by security personnel
who are of the same gender as the worker. The facility shall ensure thatsuch searches are applied equally to all workers regardless of position.
HARASSMENT AND ABUSE POLICY
The facility shall have a policy that defines and prohibits all forms ofharassment and abuse and includes a list of penalties for violations.
WAGES, BENEFITS, AND TERMS OF EMPLOYMENTThe facility shall pay wages and overtime premiums in compliance with allapplicable laws. Workers shall be paid at least the minimum legal wage or awage that meets local industry standards, whichever is greater. The facility is
encouraged to provide wages and benefits that are sufficient to cover workers’
basic needs and some discretionary income.
MINIMUM WAGE REQUIREMENT
The facility shall ensure workers are paid at least the minimum legal wage
or a wage that meets local industry standards, whichever is greater.
UNREASONABLE PRODUCTION QUOTAS
The facility shall not set production quotas or piecework rates at such alevel that workers need to work beyond regular working hours (excluding
overtime) to earn the legal minimum wage or prevailing industry wage.
Any quotas or rates must be reasonable for workers to meet within aregular shift.

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GAP INC. CODE OF VENDOR CONDUCT | LABOROVERTIME AND INCENTIVE RATESThe facility shall pay overtime and any incentive (or piece) rates that meet
all legal requirements or the local industry prevailing standard, whicheveris greater. Hourly wage rates for overtime must be higher than the rates forthe regular work shift.
UNPAID OVERTIME ADJUSTMENTS
The facility shall ensure that overtime hours not be adjusted against
leaves/holidays/absent days unless permitted by local law.
OVERTIME ALLOWANCES
The facility shall ensure that workers are paid all legally applicable
overtime allowances.
DISPLAY OF LEGAL MINIMUM WAGES AND WAGE CALCULATION
The facility shall ensure that Legal Minimum wage rates, overtime rates
and wage calculation shall be displayed prominently throughout the facility
in the local language of workers.
ON-TIME AND DIRECT PAYMENT TO WORKERS
The facility shall ensure that workers are paid directly and at least once permonth within no more than 31 days after the end of the previous month orwithin the legally mandated period, whichever is earlier.
The facility shall ensure payments must be made in cash, and “in-kind”
payments are prohibited.
MONETIZE OR ENCASH BENEFITS
The facility shall not monetize/encash any benefit or allowance as outlined
under local law.
WAGE STATEMENTS
The facility shall ensure that for each pay period, workers are provided
understandable wage statements that includes all relevant details written
in a language they understand.
RIGHT TO REFUSE EMPLOYER SERVICES
The facility shall ensure that workers have the right to use or not to use
employer provided services, such as housing or meals.

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GAP INC. CODE OF VENDOR CONDUCT | LABOREXCESS CHARGE FOR GOODS AND SERVICES
The facility shall ensure that deductions for services/goods to employees(housing, meals, and supplies) provided by the employer shall not exceed
the actual cost.
SHORT TERM/TEMPORARY/FIXED TERM CONTRACTS
The facility shall ensure that where training wages are legally allowed, they
are for a limited time frame and the facility shall not modify or terminate
worker contracts (including the signing of a series of short-term contracts
in immediate succession), work schedules, or location for the sole purposeof avoiding wage requirements.
USAGE OF LAYOFFS AND REHIRING TO AVOID BENEFITS
The facility shall not modify or terminate worker contracts, work schedules,
or location for the purpose of avoiding wage requirements.
SUSPENSION/TERMINATION OF CONTRACTS
The facility shall ensure that contract suspension/terminations are inaccordance with the law and with full payment of legal termination benefits.
ILLEGAL DEDUCTION FROM WORKER WAGES
The facility shall ensure that deductions from wages as a disciplinary
measure are not permitted, including wage deductions for tardiness thatexceed the wage equivalent of actual time missed.
LEAVES AND HOLIDAYS
The facility shall provide paid leaves and holidays as required by law orthat meet the local industry standard, whichever is greater.
LEAVE PROCEDURES
The facility shall have clearly written leave procedures and these must be
made accessible and communicated to workers in their local language.
LEAVE/HOLIDAY/WEEKLY OFF PAYMENTS
The facility shall ensure that workers be paid for their leave not taken in addition
to the leave days/holidays/weekly off days worked, as required by local law.
LEAVE RECORDS
The facility shall maintain all documentation related to worker eligibility forleaves and leaves availed accurately and up to date.

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GAP INC. CODE OF VENDOR CONDUCT | LABORPAYMENT OF BENEFITS
The facility shall ensure that benefits, such as social insurance, retirement
benefits, severance, maternity benefits, etc., are paid on time and inaccordance with local law.
LEGALLY REQUIRED WITHHOLDINGSThe facility shall ensure that deductions or withholdings for benefits must
be remitted to the proper authority in the time period required by law.
WORKER TOOLS PROVIDED FREE OF CHARGE
The facility shall ensure that work tools be provided free of charge at thetime of employment.
TAKING WORK HOME
The facility shall ensure that workers not take work home or to their
dormitories, even if this work is voluntary.
WORKING HOURS
The facility shall set working hours in compliance with all applicable laws.
While it is understood that overtime is often required in garment production,
the facility shall carry out operations in ways that limit overtime to a level that
ensures humane and productive working conditions.
NORMAL WORK SCHEDULE
The facility shall comply with all applicable laws, regulations, and industry
standards on working hours. The maximum allowable working hours in any
week shall be the lesser of a) what is permitted by national law or b) a totalof 60 hours of work in any consecutive 7-day period.
OVERTIME HOURS
The facility shall ensure that overtime hours not exceed legal limits or 12hours in a week, whichever is lesser.
INVOLUNTARY OVERTIME
The facility shall support workers refusal of overtime work without any
threat of penalty, punishment, or dismissal. Under no circumstances shall afacility impose punitive measures such as salary deductions, apply coercionof any kind, deny future opportunities for overtime, or take disciplinary
action against workers for refusing overtime.

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GAP INC. CODE OF VENDOR CONDUCT | LABOROVERTIME AS CONDITION OF EMPLOYMENTThe facility shall not allow workers to sign a document agreeing to workovertime on demand as a condition of employment.
TIMEKEEPING SYSTEM AND RECORDS
The facility shall have a functioning, reliable, and accurate timekeeping
system that allows workers to record their regular and overtime hours.
Timekeeping records shall be maintained and workers shall have access totheir attendance records upon request.
WORKING HOURS ONE DAY OFF IN SEVEN
The facility shall allow workers at least one day off in seven days, or the
local legal standard if more stringent. A day off must be at least 24 hours ofcontinuous rest.
DAILY REST PERIODS
The facility shall ensure that all legally required daily rest periods areprovided to all workers.
OVERTIME MANAGEMENT SYSTEM
The facility shall have a system that demonstrates that all overtime hours
are voluntary.

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PROVISIONS & STANDARDSOCCUPATIONALHEALTH &SAFETY28

GAP INC. CODE OF VENDOR CONDUCT | OCCUPATIONAL HEALTH & SAFETY

The facility shall comply with all applicablelaws and regulations regarding working
conditions and shall provide workers witha safe and healthy environment.
COMPLIANCE WITH LAWS
The facility shall comply with all applicable laws and/or manufacturer
instructions regarding working conditions, including personal protective
equipment, machine safety, chemical handling and safety, first aid, medicalcare, food service, emergency preparedness, fire safety, structural, andelectrical safety.
HEALTH AND SAFETY COMMITTEE
The facility shall, if required by law, have a health and safety committee
available in accordance with local law. The facility shall ensure that meetinglogs are maintained.
GENERAL SAFETY
The facility shall comply with all applicable laws regarding risk protection.
VENTILATION
The facility shall ensure that adequate and effective ventilation exists forthe comfort of workers and that there is proper circulation of air, especiallyin areas of frequent or heavy use of chemicals and paints, or in areas withsignificant dust and material particles.

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GAP INC. CODE OF VENDOR CONDUCT | OCCUPATIONAL HEALTH & SAFETY

GENERAL SAFETY: LIGHTING
The facility shall ensure appropriate and sufficient lighting is installed so
workers are aware of their surroundings, are able to perform their work safely,
and are able to see any potential barriers or obstacles on their way to thenearest exits.
FLOOR SAFETY
The facility shall ensure that floors have proper construction, drainage andmaintenance.
SANITATION AND HOUSEKEEPING
The facility shall maintain good housekeeping and sanitation in all areas
including outside stairs/exit paths and corridors.
STAIRWAYS AND RAISED PLATFORM
The facility shall ensure that stairs, platforms, and elevated floors are well
protected to eliminate safety hazards.
CONFINED SPACES
The facility shall ensure that confined spaces do not pose a danger toworker safety.
SEATING AND ERGONOMIC MATS
The facility shall take adequate measures to prevent fatigue and long-term
health problems to workers.
SMOKING
The facility shall ensure that smoking is not permitted in the areas where
smoke may pose health risk for other workers and/or a fire hazard.
PREGNANT AND BREASTFEEDI NG WOMEN
The facility shall take all required measures to ensure the health and safety ofgroups of workers with special requirements.
WORKERS WITH DISABILITY
The facility shall take all required measures to ensure health and safety ofgroups of workers with special requirements.
TOILETSThe facility shall ensure there are an appropriate number of clean, functional,
and sanitary toilet areas and there is no unreasonable restriction of their use.

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GAP INC. CODE OF VENDOR CONDUCT | OCCUPATIONAL HEALTH & SAFETYPERSONAL PROTECTIVE EQUIPMENT
The facility shall ensure that appropriate personal protective equipment suchas masks, gloves, goggles, ear plugs and rubber boots are made available atno cost to all workers and instructions for use are shared with the workers.
MACHINE/EQ UIPMENT SAFETY
The facility shall comply with all laws regarding machine and equiptment
safety and take all steps to ensure safety.
FIRST AID AND MEDICAL FACILITY
The facility shall ensure adequate arrangement for first aid and medical care.
CANTEEN AND EATING AREA
The facility shall make adequate arrangements for provision of food andeating area for workers.
DRINKING WATER
The facility shall make adequate arrangements for provision of sufficient andsafe drinking/potable water for all workers.
FIRE SAFETY CERTIFICATES
The facility shall comply with all applicable laws regarding fire safety.
EXITS/EXIT ROUTES/EMERG ENCY ROUTESThe facility shall ensure there are sufficient, marked exits and clear routes fromall areas of the facility to support safe and smooth evacuation from the facility.
EMERGENCY LIGHTING
The facility shall ensure that sufficient, powered back-up emergency lights areprovided throughout the facility.
FIREFIGHTING EQUIPMENT
The facility shall provide appropriate firefighting equipment in sufficientnumber throughout the facility. These shall be maintained in functional
condition at all times.
FIRE DETECTION AND ALARM SYSTEMSThe facility shall have a functional and well-maintained alarm system for early
emergency warning.

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GAP INC. CODE OF VENDOR CONDUCT | OCCUPATIONAL HEALTH & SAFETY

EMERGENCY PROCEDURES AND EVACUATION DRILLS
The facility shall have an emergency response system and team with defined
responsibilities. The facility shall ensure that emergency evacuation drills are
conducted and recorded.
BUILDING SAFETY
The facility shall comply with all applicable laws regarding structural safety.
The facility shall take all necessary steps to ensure that the facility is
structurally safe and well-maintained.
ELECTRICAL SAFETY
The facility shall comply with all applicable laws regarding electrical safety.
The facility shall ensure that all electrical boards, panels, wiring, circuit
breakers, etc. are adequately marked and protected.
DORMITORY
The facility shall ensure if housing is provided for workers that these facilities
are kept clean and safe.
HEALTH AND SAFETY
The facility shall ensure that dormitory facilities meet all applicablelaws and regulations related to health and safety, including fire safety,
sanitation, risk protection, and electrical, mechanical, and structural safety.
EXITS, EMERGENCY LIGHTING, AND FIRE ALARM
The facility shall ensure that there are at least two clearly marked exits on eachfloor and emergency lighting installed in halls, stairwells, and above each exit.
CLEAR HALLS AND EXITSThe facility shall ensure that halls and exits are kept clear of obstruction forsafe and rapid evacuation in case of fire or other emergencies.
POSTED EVACUATION DIRECTIONS
The facility shall ensure that directions for evacuation in case of fire orother emergencies are posted in all sleeping quarters.
FIRE EXTINGUISHERS
The facility shall ensure that dormitory facilities are adequate and thataccessible fire extinguishers are installed.

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GAP INC. CODE OF VENDOR CONDUCT | OCCUPATIONAL HEALTH & SAFETY

FIRE FIGHTING EQUIPMENT
The facility shall ensure that a fire hydrant and other firefighting
equipment, if required by law, are installed and properly maintained.
FIRE DRILLS AND EVACUATION DRILL LOG
The facility shall conduct fire drills are at least once every six months, withappropriate documents maintained.
YELLOW BOX OR MARKINGS
The facility shall ensure a yellow box is painted in all areas with fire
extinguishers or control panels to indicate areas that shall be kept free andwithout obstruction.
FIRST AID KIT
The facility shall ensure that well-stocked first aid kits are provided indormitory facilities.
DORMITORY LOCATION
The facility shall ensure that dormitories are separate from any production
or warehouse locations.
SEGREGATED HAZARD AND COMBUSTIBLE MATERIAL
The facility shall ensure that hazardous and combustible materials used in
the production process are not stored in the dormitory.
FREE ACCESS
The facility shall ensure that dormitory residents are free to come and go
during their off-hours under reasonable limitations imposed for their safety
and comfort. Such limitations may not prohibit workers from entering or
exiting the dormitory at any time.
SEPARATE ROOMS BY GENDER
The facility shall ensure that sleeping quarters are segregated by gender.
SANITATION
The facility shall ensure that all areas in the dormitory are clean andwell-maintained.
SUFFICIENT SPACE
The facility shall ensure that there is sufficient living space per worker inthe sleeping quarters, which at a minimum meets both the minimum legal
requirement and the local industry standard.
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GAP INC. CODE OF VENDOR CONDUCT | OCCUPATIONAL HEALTH & SAFETY

LAUNDRY
The facility shall ensure there is sufficient space provided to dry clothes
and belongings in the open air.
WORKER STORAGE SPACE
The facility shall provide a private and secure storage space for workers,
such as a locker, for valuable personal belongings.
BARE FLOORS AND PERSONAL MATS
The facility shall provide workers their own individual mats or beds, which are
exclusively theirs for the time period that they are employed by the facility.
SUFFICIENT TOILETS AND SHOWERS
The facility shall ensure sufficient toilets and showers are segregated bygender and provided in safe, sanitary, accessible, and private areas.
TOILET SANITATION
The facility shall ensure toilets are clean, sanitary, functioning, andwell-maintained.
PRIVACY
The facility shall ensure that toilets and showers are in covered areas andshielded from view by those outside these areas.
TOILETS BY GENDER
The facility shall ensure that in larger dormitories where there are multiple
toilets in one bathroom, the bathrooms shall be segregated by gender andclearly marked.
KITCHEN FACILITIESThe facility shall ensure that kitchen facilities or facilities used for foodpreparation, such as sinks, shall be separate from the toilet and shower area.
DORMITORY CONDITIONS
The facility shall ensure that dormitory facilities are well ventilated. The
facility shall ensure that there are windows to the outside or fans and/or air
conditioners and/or heaters in all sleeping areas for adequate circulation,
ventilation, and temperature control.

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GAP INC. CODE OF VENDOR CONDUCT | OCCUPATIONAL HEALTH & SAFETY

SUFFICIENT LIGHTING
The facility shall ensure that dormitory facilities have adequate lighting.
WATER
The facility shall ensure that potable water or facilities to boil water areavailable to dormitory residents.

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PROVISIONS & STANDARDSMANAGEMENTSYSTEMS36

GAP INC. CODE OF VENDOR CONDUCT| MANA GEMENT SY STEMSThe facility shall establish sustainability
management systems designed withappropriate operational controls toensure compliance with applicablelaws, regulations, and the COVC.
Management systems shall identify andcontrol sustainability risks, and facilitatecontinuous improvement.
COMPANY STATEMENT AND MANAGEMENT OVERSIGHT
The facility shall have a written statement confirming its commitment tosustainability and to continuous improvement (as embodied in relevantlaws and the COVC). The facility shall ensure there is a senior manager ormanagement team member with designated responsibility for overseeing
implementation of effective labor management systems, and for ensuringthat the facility meets COVC and legal requirements.
MANAGEMENT RESPONSIBI LITY AND WORKER FEEDBACK
The facility shall ensure that responsibilities for meeting COVC requirements
are defined for management and supervisory personnel. The facility shallensure that workers have access to mechanisms to provide feedback onpractices related to the COVC and to facilitate continuous improvement.

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GAP INC. CODE OF VENDOR CONDUCT| MANA GEMENT SY STEMSRISK ASSESSMENT PROCESSThe facility shall ensure there is a risk assessment process in place that
identifies legal and COVC risks associated with facility operations. The facility
shall ensure the process covers significant risks, and results in implementationof appropriate procedural controls to ensure mitigation of identified risks.
MANAGEMENT AND WORKER T RAININGS
The facility shall deliver management and worker training programs that
support effective implementation of sustainability management systems andmeeting of legal and COVC requirements.
PERFORMANCE OBJECTIVES AND TARGETS
The facility shall ensure that there are performance objectives, targets, andimplementation plans for sustainability management systems. These must becomplimented by a management and internal review process to assess andmonitor performance against sustainability requirements, and to effectively
correct issues when they arise and adjust objectives and targets when theseare off track.

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