GOALS AND PROGRESS | Supply chain | Overview

Gap Inc.
2011/2012 Social& Environmental
Responsibility Report
Full Report

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1

TABLE OF CONTENTS								PagesCOMPANYCEO LETTER

5OUR COMPANY

7

OUR LEADERSHIP

9STAKEHOLDER ENGAGEMENT11

REPORTING & MATERIALITY

13

HUMAN RIGHTS POLICY & CODE OF VENDOR CONDUCT

17

CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT

19

POLITICAL ENGAGEMENT & PUBLIC POLICY

22

CODE OF BUSINESS CONDUCT24

PRODUCT SAFETY

26

HUMAN RIGHTSOPERATING CONTEXT & STRATEGY28

UN GUIDING PRINCIPLES ON BUSINESS & HUMAN RIGHTS

32

WORKING WITH FACTORIES

34

MONITORING & REMEDIATION37

CAPACITY BUILDING41

BANGLADESH FIRE AND BUILDING SAFETY

43

FREEDOM OF ASSOCIATION

48

FORCED LABOR

51

CHILD LABOR

53

PURCHASING PRACTICES

56

GOALS

58

DATA

60

ENVIRONMENTOPERATING CONTEXT & STRATEGY75

OUR FOOTPRINT

78

ENERGY AND CLIMATE

80

WATER

82

WASTE

86

PRODUCT

88

GOALS

90

DATA

92

EMPLOYEESOPERATING CONTEXT & STRATEGY98

DIVERSITY AND INCLUSION

99

CAREER DEVELOPMENT

101

RECOGNITION103

BENEFITS AND REWARDS

104

GOALS

108

DATA

110

2

TABLE OF CONTENTS								PagesCOMMUNITYOPERATING CONTEXT & STRATEGY

119

PARTNERSHIPS

121

VOLUNTEERING

122

YOUTH

124

ADVANCING WOMEN

126

GOALS

129

DATA

131

APPENDIXPUBLIC REPORTING WORKING GROUP STATEMENT136

INDEPENDENT COMMENT FROM SHIFT138

GRI-G4 CONTENT INDEX

140

RECOGNITION

145

3

GOALS AND PROGRESS | Supply chain | Overview

Company
Full Section

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praesed mincin er sit lum do consecte consequipsum dolendit volorper sissequ ismodipis ad tem ing eu feu facip
enisse minit praestrud tat.

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tincilit at, quat vendre te molorti sciduis acing ex elenibh er sum ipsum vullaortio core veliqui pisiscil utatum
doloreros adio elesse dolortisi erat. Ut elenisl ute tem nonsed ent velit vullam in ut wisse esto doloborer sustrud et
acidui blaortio eu feu feuguero odoloreetue vulluptatem veliquisisl iurem digna faccum zzriurem velit vulla commy
nim quam dio od magna feu facing eu facil utpat. Ibh et, quatue minim vulla feuiscipit wisi.

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volenim dunt alit nullamconsed min vendipsum niat.
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Gap Inc. 2011/2012 Social and Environmental Responsibility Report
4

COMPANY | CEO LETTER
In 2004, Gap Inc. issued our first Social Responsibility report.
We have approached each report in the same way – a candid, open assessment of our progress as a company and as
a collaborative partner to address the complex issues of operating a global business in a responsible, ethical way.
I am proud of our achievements as a business, and I’m equally proud of how we do business. At Gap Inc., we are
deeply committed to social and environmental responsibility, and to ensuring that each day, we live up to the values
on which the company was founded in 1969. That’s why this report is so meaningful to me and to our company’s
more than 135,000 employees.
In the two years since our last Social & Environmental Responsibility Report, Gap Inc. has made great strides in our
mission to “be the world’s favorite for American style.”
Our portfolio of brands now includes Gap, Banana Republic, Old Navy, Athleta, Piperlime, and our newest brand,
Intermix. With stores in about 50 countries, we expanded our presence in China, opened Athleta stores throughout
the U.S., launched Old Navy in Japan, its first location outside North America, and introduced Gap to South America.
With each step we take to expand our business, we ensure that our social and environmental policies and our
cultural heritage of community investment and support are integrated into each store and country.
Wherever they’re located, our brands, stores and employees around the world are bound together by our promise, as
voiced by our co-founder, Don Fisher, to “do more than sell clothes.”
Our employees embrace our philanthropic heritage by investing their time and contributions in our communities.
In 2012, more than 70,000 employees volunteered about 460,000 hours. Along with a company donation of morethan $1 million in funds and clothing following the devastation of Superstorm Sandy, employees are building Habitatfor Humanity houses for those who lost their homes.
To address social and environmental issues, we’ve strengthened partnerships in the belief that our combined efforts
and resources can lead to comprehensive answers to multifaceted issues. We continue to press for greater accountability across all industries as a strong supporter of the United Nations Global Compact and its ten guiding principles.
Over the years, we’ve entered and invested in a number of countries and we’re gratified to be part of their successstories. One example is our partnership with the International Labour Organization Better Work Program to support
vendor compliance with labor standards and laws, which launched in Cambodia in 2004, and has expanded to Haiti,
Indonesia, Jordan, Lesotho, Nicaragua and Vietnam.
In Bangladesh, where recent tragedies underscore a country safety record that is unacceptable, we are dedicated toinvesting the time, effort and funding to bring about lasting change for garment workers. Gap Inc. was one of thefirst companies to implement our own four-point fire and safety program in the Bangladesh factories that make our
products. Through a collaborative process, led by former U.S. Senators George Mitchell and Olympia Snowe, Gap Inc.
and leading retailers and apparel companies founded the Alliance for Bangladesh Worker Safety, making a commitment to a binding, five-year fire and safety initiative that provides a $45 million worker safety fund, in addition to themore than $100 million in access to low-cost capital being offered by some companies in order to ensure that safety
remediation at factories they work with is done in a timely manner. We acknowledge there is more work to be done,
but believe these two initiatives represent an important step forward in helping to achieve sustainable reform in the
country’s garment industry.

5

COMPANY | CEO LETTER
Our conviction that advancing women advances the world is reflected by the 20,000 female garment workers who
have completed training through the Gap Inc. P.A.C.E. (Personal Advancement, Career Enhancement) program since2007. By 2015, we’re committed to 10,000 new participants.
As part of our ongoing sustainability strategy, we continue to explore ways to reduce our environmental footprint.
Our Mills Engagement Program, developed in conjunction with the Natural Resources Defense Council, is aclean-water initiative aimed at establishing standards to mitigate the environmental effects of dyeing and finishingfacilities. After reducing our greenhouse gas emissions by 20 percent from 2003 to 2008, we’re taking the next stepby pledging to reduce GHG emissions by another 20 percent, based on our 2008 levels, by 2015.
On this website, we share recent achievements to build upon for the future, areas that need greater attention, andthe tangible goals we are working towards to improve the lives of those who work at and with Gap Inc., and thecommunities in which we do business. I invite you to read through our report, and learn, in more detail, about oursocial and environmental responsibility efforts.
Thank you for your time and your interest.
Sincerely
Glenn Murphy

6

COMPANY | OUR COMPANYKey Takeaways:• Gap Inc. has embarked on a global growth strategy to position the company as the world’s favorite for
American style.
• A core tenet of our global expansion is ensuring that we grow in a way that supports people, communities,
and our environment.
Gap Inc. is one of the world’s largest specialty retailers, with more than 135,000 employees and 3,400 stores in
47 countries as of the end of 2012. Headquartered in San Francisco, California, our family of brands includes Gap,
Banana Republic, Old Navy, Piperlime, Athleta, and Intermix. We aspire to be the world’s favorite for American style,and our global growth strategy over the past two years reflects that ambition. Our net sales for fiscal year 2011 were
$14.5 billion, and were $15.7 billion for 2012.

2012 milestones- 45 Gap stores in China- 300 franchise stores globally- Banana Republic flagship store on the Champs Elysees in Paris- Our first international Old Navy store in Tokyo- Our very first Piperlime store, in New York City
- 35 Athleta stores in the United States- Acquisition of the multi-brand luxury retailer Intermix

In October 2012, we announced a new global brand structure designed to fuel our company’s long-term growth. With
the start of the 2013 fiscal year, the company brought together our North American, International, Online, Outlet, andFranchise divisions under a single global executive for each of its Gap, Banana Republic, and Old Navy brands. In addition, Gap Inc. formed a new Growth, Innovation, and Digital team to build on our online and technology advances.
Our evolving global business strategy aligns with our social and environmental responsibility efforts in significant
ways. One prime example is the shift we began making in 2012 to a sourcing strategy centered on category management. By sourcing across brands in shared categories such as denim and knits, we are putting greater emphasis on
creating deeper relationships with our vendors worldwide. We have found that such relationships support our efforts
to improve working conditions, as we can help vendors implement—and own—solutions to such issues.
Social and environmental responsibility is one of several key criteria we are using in our partnerships with vendors
7

COMPANY | OUR COMPANY
to implement category management and support our global growth strategy.
In 2012, Yahoo! Finance recognized our positive momentum by awarding its first ever “Company of the Year” award to
Gap Inc. A key aspect of our performance in 2012 acknowledged by the award was our ongoing commitment to socialand environmental responsibility. As stated by Yahoo! Finance, Gap Inc. “wants to be known as a corporation with aconscience—and it walks the walk.”
While we are proud of what we achieved in 2012, we recognize that with growth and opportunity come greater
challenges, wider impacts, and a heightened focus on more deeply incorporating social and environmental
responsibility into our core business. We know that we must continue to adapt and innovate if our business is tothrive. This report covers how we are doing so in a way that carefully considers our impact on people, communities,
and the environment.

8

COMPANY | OUR LEADERSHIPKey Takeaways:• Strong corporate governance is a fundamental part of how our company operates, including the role it plays
in overseeing our social and environmental responsibility efforts.
• Gap Inc.’s Social and Environmental Responsibility team is comprised of proven leaders and passionate
individuals who have experience working for non-governmental organizations, apparel factories, trade unions,socially responsible investment firms, government, and other companies.
• The team works closely with departments across Gap Inc., which helps drive integration of our values into ourcore business.

Gap Inc. Board of Directors
We believe that strong corporate governance goes hand-in-hand with good management. A well-managed company
delivers better business results and, ultimately, greater shareholder value. For us, good governance begins with astrong Board of Directors that has an independent perspective on the business and oversight of company management, including our social and environmental responsibility efforts.
As of the end of our 2012 fiscal year, our board had ten directors, nine of whom are independent, including a leadindependent director. At each board meeting, time is set aside for independent directors to meet in executive session.
In addition, only independent directors sit on board committees. To read more about the composition of our board
and how we define independence, please click here.
The board’s Governance and Nominating Committee oversees the company’s corporate governance practices.
We invite anyone to communicate governance concerns directly to the board by emailing: board@gap.com.
All emails are reviewed by our board chair, the board’s lead independent director, and our corporate secretary’s office.
Read more about our governance practices.

Gap Inc. Social and Environmental Responsibility leadership
Our Social and Environmental Responsibility Department is directed by knowledgeable leaders with proven trackrecords in business and sustainability.
Bobbi Silten, Senior Vice President of Global Responsibility at Gap Inc. and President of Gap Foundation, oversees
our Social and Environmental Responsibility department. Bobbi reports to Eva Sage-Gavin, Executive Vice President,
Global Human Resources and Corporate Affairs, who reports to Gap Inc. CEO Glenn Murphy. Gap Inc.’s Board of Directors oversees our company’s social and environmental responsibility efforts, receiving annual updates from Bobbi.
Our Social and Environmental Responsibility team is comprised of people with diverse backgrounds and skill sets
who have worked for non-governmental organizations, apparel factories, trade unions, socially responsible investment firms, government agencies, and other companies. We believe that bringing together people of varied backgrounds and perspectives helps spur innovation and foster accountability, allowing us to better analyze, understand,and address the social and environmental issues we face.
Our organizational structure also requires particularly close collaboration across key departments at Gap Inc., which
is why our Social and Environmental Responsibility department works in close partnership with our Supply Chain,
Corporate Affairs, Legal, and Gap Foundation teams, among others. Many of those teams include sustainability professionals who are helping our company integrate our efforts across all facets of our operations.
9COMPANY | OUR LEADERSHIP

S&ER Department

Number of full-time employees

Leadership and administrative support

2

Monitoring and Vendor Development

48

Fire and Building Safety

2Strategic Planning and Communications

4

Environmental Affairs and Brand Engagement

4

Global Partnerships and Public Policy

6

Social and Community Investment

4Gap Foundation

12

Total

82

Note:
As of end of fiscal year 201210

COMPANY | STAKEHOLDER ENGAGEMENTKey Takeaways:• Our partnerships—with non-governmental organizations, multi-stakeholder initiatives, trade unions, andothers—are a key driver of our progress on social and environmental responsibility.
• Working with diverse groups and organizations not only helps us make a greater positive impact, it also
supports our business by providing valuable perspective to make smarter and more informed decisions.
In our 2003 Social Responsibility Report, the first ever published by Gap Inc., we stated:
We are convinced that collaborative, multi-stakeholder engagement is the only way to create sustainable change
industry-wide.
Ten years ago, such a perspective was not necessarily an obvious one. But after more than a decade of action, we
have benefited from the value this approach creates. We continue to be inspired by the new, innovative partnershipsthat span industries and sectors, and we believe that networks of collaboration will be a driving force in addressing
the urgent social, environmental, and economic challenges of the 21st century. Collaborative engagement continues
to be a guiding principle of both our business strategy and our social and environmental initiatives.
While Gap Inc. has an experienced team of people working in our Social and Environmental Responsibility
department, it is impossible for them alone to effectively identify, understand, and address the varied issues facing
workers, their communities, and the environmental impacts of the products we source. Working with others is
critical to ensuring we are focused on the right issues, in the right places, with the right approach. Partnership is alsoa primary source of innovation for addressing social and environmental issues.

We are partnering with the Natural Resources Defense Council (NRDC)
to address mill sustainability.

We work with CARE International and the International Center for Research on
Women (ICRW) to help female garment workers succeed in work and in life throughthe Gap Inc. P.A.C.E. program.

We are active members of the Ethical Trading Initiative and Social Accountability
International, both alliances of companies, trade unions, and non-governmentalorganizations working to improve the lives of workers who make consumer goods.

Through various types of partnerships—with labor rights organizations, environmental groups, multi-stakeholder
initiatives, community-based organizations, trade unions, industry associations, investors, academics, factory owners

11

COMPANY | STAKEHOLDER ENGAGEMENT
and managers, workers, shareholders, governments, and other companies—we are better able to make sense of theuniverse of issues we proactively seek to address. Working with such diverse groups and organizations not only helps
us make a greater impact on key social and environmental issues, it also helps our business operate in a smarter,
more informed manner.
Stakeholders help us create value by providing:• Expert perspectives on material issues, as well as our strategies and goals for making an impact while helping
		 ensure accountability for our actions and for the actions of others in our industry.
• The increased influence to make greater impact and the partnership to address systemic issues through		 industry-wide solutions when appropriate.
• Insight into local communities where we source products and assistance in implementing and		 evaluating programs.
We are involved in many forms of engagement and partnership. Through formal memberships in multi-stakeholder
initiatives such as Ceres, the Ethical Trading Initiative and others, we are able to address systemic social andenvironmental issues that require a broad set of actors from many sectors. On a less formal basis, we partner withkey labor rights organizations or environmental groups to address singular issues that require remediation. The
nature of our engagement depends on the demands of a given issue.
We also contribute to collective efforts in a variety of ways. We believe that being an effective contributor to any
multi-stakeholder effort requires knowing when to lead, and when to follow. We are at the forefront in several
collective efforts, and we have also followed other companies and stakeholders when their expertise and assets are
better suited to take the lead.
While we prefer to address social and environmental issues in partnership with others, there are rare occasions when
we believe that independent action is the most effective way to get a project off the ground. For example, in 2012 webegan implementing our own Fire and Building Safety Action Plan in Bangladesh. Since that time, we have joinedwith other leading apparel brands and retailers, fire and building safety experts, the Bangladeshi government, policy
makers, and leading non-governmental organizations to address fire and building safety in Bangladesh through theAlliance for Bangladesh Worker Safety.

12

COMPANY | REPORTING & MATERIALITY
Key Takeaways:• By providing an account of our business, our social and environmental impacts, our ongoing challenges, andwhere we are headed, we are in a stronger position to create positive change.
• To help ensure that our reporting continuously improves and meets our stakeholders’ expectations, we regularly
assess which issues are most important to our company, our stakeholders, and society at large. In 2012, we
conducted a materiality assessment of our sustainability initiatives. The issues covered in this report were foundto be “highly or moderately material” from a sustainability perspective.

Why we report
Our 2003 Social Responsibility Report was recognized in its time as a first in the apparel sector for its honesty andoverall transparency. One of our goals with that initial report was to shift the debate on working conditions awayfrom whether there were urgent labor rights issues in apparel factories, toward a constructive dialogue on how to fix
them. It was not a risk-free decision at the time, but it proved to be a valuable one. Based on that experience, we havelearned just how valuable reporting is—both as a process and in outcome.
Since that inaugural report, we have continued to build our reporting on the principles of transparency,
accountability, and honesty. We believe the value of reporting can only be fully captured when it frankly discusses
successes and failures, challenges and opportunities.

How we understand and use these reports can have widespread ramifications. First, it is important to
see the report as the culmination of a process. It is not merely the assembly of information and ideas. It
is the exploration of what the data tells us and how its use will inform work for the future. What needs
to be adapted, changed, modified; what new challenges exist and how will they be addressed? Who else
needs to be brought into the work and in what way? These are just some of the ongoing questions raisedby a report such as this one.—2009-10 PUBLIC REPORTING WORKING GROUP Statement
Over the past decade, we have derived greater value from each subsequent report. By providing a public account ofour business, operating context, and social and environmental impacts, we have become a better company. Reporting
generates tangible value for our company by:• Building trust with stakeholders, which helps us collaborate to address issues.
• Contributing to a broader culture of accountability and responsibility across Gap Inc.
• Providing a platform for us to set public goals, enabling us to stay focused and enlist help in achieving them.
• Giving us the opportunity to reflect on lessons learned and incorporate those learnings into our programs.
• Keeping our executives and board members up-to-date on changes in the sustainability landscape, which		 informs our business strategy and enhances its implementation.
Several of our advances in reporting are the result of broader evolution in the reporting landscape. The innovative
efforts of the Global Reporting Initiative (GRI) to create and disseminate a global framework for sustainability reports
have helped shape our own efforts. We are pleased to include a GRI G4 Content Indices in this report.
Concurrently, the work by the International Integrated Reporting Council (IIRC) to advance integrated reporting
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COMPANY | REPORTING & MATERIALITY
has also helped mature the reporting landscape. While we do not have immediate plans to release an integrated
financial and sustainability report, we continue to monitor how this framework evolves. We are committed to using
the reporting approach that brings the greatest value to our company and our stakeholders.

Scope
We publish a new Social and Environmental Responsibility Report every two years, while updating our data annually.
In our view, biennial reporting is an appropriate timeframe given the systemic and global nature of the issues ourcompany seeks to proactively address. It also allows us to devote the optimal allocation of resources to doing andcommunicating.
The scope of our 2011-12 report covers our efforts companywide and globally, across our Gap, Banana Republic,
Old Navy, Piperlime, and Athleta brands. Our acquisition of Intermix on December 31, 2012, and the role this brandplays in our overall social and environmental responsibility efforts, will be included in our next report. Unlessotherwise noted, data in this report relates to Gap Inc.’s fiscal years 2011 and 2012, which ran from January 30, 2011,
to February 2, 2013.

Materiality
We regularly review the universe of issues we could report on in order to focus on those most important to ourcompany, our stakeholders, and society at large. In 2012, we conducted a materiality assessment of oursustainability initiatives that found the issues we cover in this report to be “highly or moderately material” froma sustainability perspective.
In our sustainability reporting, we define materiality by the degree to which an issue is significant to society
and our interested stakeholders, and the degree to which it is relevant to Gap Inc.’s scope of operations andethical commitments. As part of our assessment, we analyzed indicators from key frameworks, indexes, andsurveys including those from the Global Reporting Initiative (GRI), the Dow Jones Sustainability Index, Corporate
Responsibility Officer, Ethical Trading Initiative, Social Accountability International, As You Sow, and Free2Work.
We then rated each issue according to its aggregate score along each of the following dimensions:
Significance to society:• Awareness of issue• Significance to key stakeholders• Evidence and impact of issue• Industry and peer response
Relevance to Gap Inc.:• Potential short- and long-term business impacts• Ethical relevance and policy commitments

14

COMPANY | REPORTING & MATERIALITY• Peer-based and social norms• Stakeholder activity and reputational risk

Significance to Society

HIGH
MATERIALITY
Topics within themedium and highmateriality sections
are those that Gap Inc.
could be expected toreport on

MEDIUM
MATERIALITY

Topics within the lowmateriality section do
not need to be
included in our report.

LOW
MATERIALITY

Relevance to Gap Inc.

Our assessment revealed that while we had been appropriately focusing our previous reporting on material issues,
we were not sufficiently emphasizing our goals or our strategies to achieve them. In this report, we aim to address
this by more clearly discussing our strategies, and by ensuring that our goals are easier to find on our website.
This assessment reconfirmed the enormous value that stakeholders contribute to our efforts. By keeping in close,
direct contact with stakeholders from across the social and environmental responsibility spectrum, we are better
able to proactively address the issues that most urgently demand our attention. While conducting a materiality
assessment is a valuable exercise, there are no greater assets in identifying “what matters” than having an internalteam with deep social and environmental expertise, and the external relationships and partnerships we build withexperts around the world.

Stakeholder review of our reporting
We could not have produced this report without the help of our stakeholders. The Public Reporting Working Group(PRWG) was instrumental in providing feedback on content, insights into our overall message, and perspective
on our data and progress, including areas where we need to do more. This group—comprised of experts on social
15

COMPANY | REPORTING & MATERIALITY
and environmental issues from a number of non-governmental organizations and socially responsible investment
firms—has been collaborating with us for more than ten years in our work to achieve greater transparency andsustainability.
The members of the Public Reporting Working Group are:• Adam Kanzer—Managing Director and General Counsel—Domini Social Investments• Mike Lombardo—Senior Sustainability Analyst and Manager, Calvert Social Index—Calvert Investments• Ruth Rosenbaum—Executive Director—Center for Reflection, Education, and Action• David Schilling—Director of Human Rights and Resources Programs—Interfaith Center on		 Corporate Responsibility
Included with the release of every Gap Inc. Social and Environmental Responsibility Report is a statement draftedby the PRWG that offers its assessment of our report in the context of our social and environmental responsibility
efforts. The PRWG does not assure data or audit results.
Experts at Ceres also reviewed and gave input on our report. In the years since we first partnered with Ceres in 2007,
the organization has provided valuable guidance and held us accountable on evolving our environmental initiatives.
We are grateful for their help in offering critical feedback on this report. The Ceres staff members who reviewed thisreport are:
• Andrea Moffat—Vice President, Corporate Program—Ceres• Kristen Lang—Senior Manager, Corporate Program—Ceres

Additional reporting
In addition to our public report, we provide regular, separate reports on our social and environmental progressto the Carbon Disclosure Project, the Clinton Global Initiative, the Ethical Trading Initiative, Social Accountability
International, and the United Nations Global Compact (UNGC). Providing these issue-specific reports to key
stakeholders helps focus and advance our work with them to continually improve our social and environmental
responsibility efforts.

Supplier Reporting
In early 2013, we began the process of more explicitly encouraging our branded apparel suppliers to issue publicsustainability reports. Just as we provide transparency in our own Social and Environmental Responsibility Report, we
believe that it is good practice for our apparel suppliers to provide reporting for their interested stakeholders. To that
end, we sent a letter to all suppliers making Gap Inc. branded apparel encouraging them to issue public sustainability
reports. We provided information on how to report, where to find additional resources, and whom to contact at
Gap Inc. should a supplier want to learn more about reporting processes. We also informed our suppliers that publicsustainability reporting earns best practice credit on our Code of Vendor Conduct ratings.

16

COMPANY | HUMAN RIGHTS POLICY & CODE OF VENDOR CONDUCTKey Takeaways:• Gap Inc. created its Human Rights Policy in 2010. The policy underscores our longstanding commitment torespect and promote fundamental human rights in every aspect of our business, including our wholly owned
operations and across our branded apparel supply chain.
• Our Code of Vendor Conduct seeks to safeguard workers’ rights in the factories where Gap Inc. products are
made. We have a dedicated team of approximately 50 people within our Social and Environmental
Responsibility department who focus on its enforcement.
Gap Inc. seeks to ensure that the people who work at our company and in our supply chain are treated with fairness,dignity and respect—an aspiration that is born out of the belief that each life is of equal value, despite the systemic
inequities around the world. As part of upholding this belief, we have a Human Rights Policy at Gap Inc. to help
promote equality and respect the rights of our employees, and the workers in our supply chain.
Our Human Rights Policy applies globally within our wholly-owned operations and across our branded apparel supply
chain. It highlights our commitment to respect fundamental human rights throughout these operations, as wellas our intent to promote human rights within our sphere of influence. For example, we have direct influence over
how we respect the human rights of our employees, moderate influence in the factories where our garments areproduced, and less influence over human rights issues that may occur farther upstream in our supply chain, suchas the labor conditions where raw cotton is harvested. Our policy recognizes and draws upon the United Nations
Guiding Principles on Business and Human Rights, as well as other recognized international policy frameworks.
Enforcing our Code of Vendor Conduct (COVC) is one of the most powerful ways for us to bring our Human Rights
Policy to life. Our COVC seeks to safeguard workers’ rights in the factories where Gap Inc. products are made,and approximately two-thirds of our Social and Environmental Responsibility department are responsible for its
enforcement. This team also helps drive our collaboration with organizations such as Better Work, a partnership
between the International Labour Organization and the World Bank Group.

Gap Inc. Sandblasting Policy. In 2011, we implemented a policy banning sandblasting in our supply
chain. Sandblasting is a finishing technique that is used to achieve a “worn” look for new denim. It is
potentially harmful because the sand used can cause silicosis and other respiratory illnesses if nothandled in accordance with proper safety protocols. Upon investigating this issue and listening tostakeholder concerns, we agreed that sandblasting posed too great of a potential health risk to workers.
Our policy includes not just sand but also all types of abrasives, including aluminum oxide, aluminumsilicate, silicon carbide, copper slag, and garnet. Our Monitoring and Vendor Development teamenforces the policy globally.
Our ongoing practices to advance human rights in our supply chain go beyond enforcement alone. We pursue
strong remediation and capacity building in apparel factories by conducting worker trainings, participating in multistakeholder initiatives, and forging partnerships with expert stakeholders and suppliers to address specific humanrights issues.
We believe that the value of a policy lies in the action and behavior it spurs. We continue to look for new and betterways to develop practices across our business operations and supply chain that support our Human Rights Policy and
our Code of Vendor Conduct. To read more about how our efforts have evolved since we began this work nearly 20
years ago, please read the Operating Context and Strategy article in our Human Rights section.

17

COMPANY | HUMAN RIGHTS POLICY & CODE OF VENDOR CONDUCTWe are committed to staying on top of important changes taking place in the broader business and human rights
landscape. We support the UN Guiding Principles on Business and Human Rights, and have followed its evolution
under the leadership of John Ruggie. As a part of our effort to better understand how we can integrate the Guiding
Principles into our policies and programs, Gap Inc. asked Shift to review our Social & Environmental Responsibility
report and offer reflections on the implications of the UN Guiding Principles for our efforts to respect human rights in
our global supply chain. Shift is a leading non-governmental organization that works with governments, businesses,
and stakeholders to put the UN Guiding Principles into practice. To learn more, please visit the UN Guiding Principles
article in this report.

18

COMPANY | CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACTKey Takeaways:• Forced, child, and trafficked labor are unacceptable practices that are not allowed to be used in the production of
any Gap Inc. product.
• To address this urgent issue, in 2012 we monitored 96.4 percent of the factories that produce our branded
apparel, and we partner with expert stakeholders including the Interfaith Center on Corporate Responsibility,
the Not For Sale Campaign, the Responsible Sourcing Network, and the UN Global Initiative to Fight Trafficking.
On January 1, 2012, California enacted a new law requiring companies of a certain size to publicly disclose the steps
they are taking to identify and eradicate forced labor in their supply chains. Gap Inc. supported this legislation, andwe see it as a policy lever that will assist in the global fight against human trafficking.
Under no circumstance is it acceptable for child, forced, or trafficked labor to be used in the production of any Gap
Inc. product. We believe that no person should be subject to a situation where basic needs and fundamental rights
are denied.
Our efforts to address human trafficking in the apparel industry are guided by our Human Rights Policy, which isfounded on the principles outlined in the United Nations Universal Declaration of Human Rights (UDHR) and theInternational Labour Organization’s Declaration on Fundamental Principles and Rights at Work (often referred to as
the “ILO Core Conventions”). Our policy applies to both our wholly owned operations and our branded apparel
supply chain.
Gap Inc. has a Code of Vendor Conduct (COVC or “code”) that explicitly states that forced labor of any kind is strictly
prohibited. All Gap Inc. branded apparel vendors must abide by this code. Our COVC and the enforcement behind it is
an important mechanism that brings our Human Rights Policy to life within our supply chain. We have a Monitoringand Vendor Development team, comprised of approximately 50 people located in more than 20 countries, that monitors working conditions in these factories and works with management to help ensure that they abide by our code.
The United States’ Victims of Trafficking and Violence Protections Reauthorization Act (TVPRA) of 2000 defines
human trafficking as:“Any recruitment, harboring, transportation, provision, or obtaining of a person for labor services, through theuse of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage,or slavery.”We have additional requirements designed to protect foreign contract workers employed by vendors. We monitor
how foreign contract labor is used at factories producing Gap Inc. branded apparel to help ensure that people arefree to work as they choose. On the ground, our Social Responsibility Specialists have a deep knowledge of the issue
from interviewing workers, gaining their trust, and learning over time which agents and factories have good or bad
reputations and practices.
The majority of our Social Responsibility Specialists are locally-hired and speak the local languages in the regions
where they work. In 2012 alone, our team monitored more than 923 active, full-year factories, seeking to ensure
adherence to our COVC. Comprehensive data on our monitoring can be found in the Human Rights data section ofthis report.
Our efforts to address human trafficking are not limited to our factory monitoring and remediation program.
For example, we are members of the multi-stakeholder network seeking to end forced child labor in Uzbekistan’s
cotton sector. We have also supported handwork centers in Northern India where at-risk women can work safely,
19

COMPANY | CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
and a regional education initiative that helps raise awareness of how to avoid traffickers.
Due to the complexity of this problem, we know that confronting it requires collaboration across industries and must
include partnerships among the public, private, and nonprofit sectors. Accordingly, we have a long history of working
with a number of entities that are actively addressing various facets of human trafficking problems, including theInterfaith Center on Corporate Responsibility, the Not For Sale Campaign, the Responsible Sourcing Network, and the
UN Global Initiative to Fight Trafficking. We encourage you to visit their websites and review their initiatives to fightvarious forms of human trafficking.
Human trafficking is an issue that crosses nearly all sectors, and is an exploitative practice that occurs outside theproduction of goods. For the apparel sector, it will take a sustained and collaborative effort to bring an end to thisglobal issue. We continue to work with NGOs, companies, and other entities to ensure that we are effectively
contributing to the global fight against human trafficking.
Highlighted below are the five pillars of the California Transparency in Supply Chains Act, followed by the actions weare taking to address each one:
1. Company engages in verification of product supply chains to evaluate and address risks of human trafficking
		 and slavery. The disclosure shall specify if the verification was not conducted by a third party.
In 2012, we monitored 96.4 percent of the active, full-year garment factories that produce Gap Inc. branded apparel.
We verify our product supply chains through both unannounced and announced visits to measure factories’
compliance with our Code of Vendor Conduct, which includes strict prohibition of “forced labor … or involuntary laborof any kind.” Most of Gap Inc.’s audits are conducted by our own internal team of Social Responsibility Specialists.
A number of factories producing our branded apparel participate in the Better Work program, a collaborative factory
monitoring initiative led by the International Labour Organization, which is currently operating in seven countries.
Factories participating in Better Work are audited by specialists employed by the International Labour Organization.
2. Company conducts audits of suppliers to evaluate supplier compliance with company standards for trafficking
		 and slavery in supply chains. The disclosure shall specify if the verification was not an independent,
		 unannounced audit.
Gap Inc. conducts both announced and unannounced audits in the factories we monitor. These audits are primarily
conducted by Gap Inc. staff. Gap Inc.’s company standards on labor laws and human rights are outlined in our COVCand our Human Rights Policy. Our COVC, with which all facilities producing Gap Inc. branded product must comply,
explicitly states that vendors must not use “forced labor … or involuntary labor of any kind.” Human trafficking andslavery fall under the category of “forced labor” and “involuntary labor.” Our COVC further states that factories mustallow “Gap Inc. and/or any of its representatives or agents unrestricted access to its facilities and to all relevant
records at all times, whether or not notice is provided in advance.”
3. Company requires direct suppliers to certify that materials incorporated into the product comply with the laws		 regarding slavery and human trafficking of the country or countries in which they are doing business.
Prior to accepting any order for Gap Inc. branded product, our suppliers are required to sign our Vendor ComplianceAgreement and agree to be bound by our COVC. Gap Inc.’s COVC states that:“Factories that produce goods for Gap Inc. shall operate in full compliance with the laws of their respective countries
and with all other applicable laws, rules and regulations … including those relating to labor, worker health andsafety, and the environment.”
20

COMPANY | CALIFORNIA TRANSPARENCY IN SUPPLY CHAINS ACT
In signing Gap Inc.’s Vendor Compliance Agreement, which also incorporates the COVC, Gap Inc. suppliers agree tocomply with the following:“All applicable laws, rules and regulations … these laws include, but are not limited to, laws relating to theemployment conditions of their respective employee such as: (1) wage and hour, labor, child labor, and forced labor
requirements; (2) health and safety; (3) immigration; (4) discrimination; (5) labor or workers’ rights in general; and(6) environmental laws and regulations.”
4. Company maintains internal accountability standards and procedures for employees or contractors failing to		 meet company standards regarding slavery and trafficking.
Failure of employees to abide by Gap Inc.’s Code of Business Conduct can result in corrective action up to and including termination of employment. Failure of vendors to abide by Gap Inc.’s COVC and/or Vendor Compliance Agreement
can result in corrective action up to and including the “termination of all existing and future business.”
5. Company provides company employees and management, who have direct responsibility for supply chain		 management, training on human trafficking and slavery, particularly with respect to mitigating risks within the		 supply chains of products.
Gap Inc.’s Monitoring and Vendor Development team works directly with factory management and workers in thefactories we monitor. Gap Inc.’s COVC explicitly states that facilities producing Gap Inc. branded product must “notuse involuntary labor of any kind,” of which human trafficking is one kind. Our COVC also has stringent requirements
around “contract labor,” which can sometimes be exploited to create instances of indentured servitude for workers.
Our Social Responsibility Specialists are trained to identify these potentially abusive situations.

21

COMPANY | POLITICAL ENGAGEMENT & PUBLIC POLICYKey Takeaways:• We participate in public policy dialogue on key issues that support our business strategies, including thosealigned with our social and environmental responsibility efforts.
• We updated our Political Engagement Policy in 2012 to provide greater transparency about the politicalorganizations, candidates, and industry organizations we support.
We believe that it is important to participate in political and regulatory processes on issues that affect our businessand community interests, and we work proactively to support our strategies through public policy and government
advocacy. This includes providing our perspective on social and environmental responsibility issues that are alignedwith our company values.
In 2011–12, we lent our voice to a number of public policy issues, including:• Environment: We are members of Ceres’ Business for Innovative Climate and Energy Policy (BICEP) coalition,		 a group of more than 20 public and private companies seeking to help pass meaningful energy and climate		 change legislation that is consistent with BICEP’s core principles.
• Community: We served on the White House Council for Community Solutions, an initiative established by
		 President Obama to provide advice to the President on the best ways to mobilize citizens, nonprofits,		 businesses, and government to work more effectively together to solve specific community needs. The focus
		 was creating pathways to education and employment for opportunity youth. We also joined the White House
		 initiative Skills for America’s Future, a bipartisan public-private partnership focused on workforce development
		 and job placement for community college students.
• Trade: We support trade policies that are consistent with our values and enhance the free flow of goods
		 globally. In 2011 and 2012, we supported enactment of free trade agreements with Colombia, Panama, and		 South Korea. We believe that free trade, when legislated responsibly, can spur innovation, growth, and		 economic development through job creation and the expansion of responsible business practices. Consistent		 with these beliefs, U.S. Secretary of Labor Hilda L. Solis appointed a Gap Inc. representative to serve on the U.S.
		 Department of Labor’s National Advisory Committee for Labor Provisions of U.S. Free Trade Agreements in 2011.
• Tax: We worked on the passage of e-fairness legislation in California, which was signed into law in 2011.  
		 This law requires out of-state retailers to collect tax on sales made to California customers. We are supporting		 a similar solution at the federal level.
• Benefits: In 2012, we signed on to an amicus brief with the Ninth Circuit Court of Appeals, challenging the		 constitutionality of the federal defense of Defense of Marriage Act, alongside other leading companies such		 as eBay, Google, Microsoft, and Starbucks.
Our Political Engagement Policy plays a central role in our public policy efforts. We updated this policy in 2012 toprovide greater transparency about the political organizations, candidates, and industry organizations we support.
Key updates to this policy include:• Disclosing a list of the trade associations we support as members, along with our aggregate contributions
		 to them.
• Revising our Candidate Approval Guidelines to expressly include consideration of impacts on our
		 company’s reputation.
22

COMPANY | POLITICAL ENGAGEMENT & PUBLIC POLICY• Clarifying the types of issues on which Gap Inc. may lobby.
In addition to our political participation and advocacy, Gap Inc. maintains a Political Action Committee (PAC).
The Gap Inc. PAC (GPAC) supports candidates whose positions are aligned with the company’s values and businessgoals. In the 2011-2012 U.S. election cycle, the GPAC contributed approximately $7,000 in 2011 and $25,000 in 2012 tofederal candidates in both the Republican and Democratic parties.
We also made $10,600 in corporate contributions in 2011, and $15,000 in 2012. All corporate political contributions are
made at the state and local levels in compliance with our corporate governance practices and applicable laws.
In our commitment to transparency throughout our public policy and government affairs activities, we update thisinformation annually on our corporate website.

23

COMPANY | CODE OF BUSINESS CONDUCTKey Takeaways:• Our Code of Business Conduct is Gap Inc.’s foundation for promoting a responsible and ethical work
environment, helping to ensure that our employees’ actions reflect our company’s integrity and values.
• The greatest value of our Code of Business Conduct lies in its implementation, and we provide a variety of
training approaches to make sure it is understood and adopted by our employees around the world.
Our co-founder Don Fisher once said, “The thing I’m the most proud of is the integrity of the company.” His words
continue to reflect and inspire the way we do business.
The Gap Inc. Code of Business Conduct (COBC) sets forth the company’s expectation that our employees embody our“Do: what’s right” value and act with integrity in all that they do. It is our foundation for promoting a responsible andethical work environment, and helps us seek to ensure that our employees act in ways that reflect our company’s
integrity and values.
Our Global Integrity and Compliance Department manages our COBC program, led by Gap Inc. General Counsel andChief Compliance Officer Michelle Banks, who reports directly to Gap Inc.’s Chairman and CEO.
Among other things, the COBC informs our employees on how to prevent conflicts of interest, support compliancewith the law, and protect the company’s information and assets. We encourage employees to “Speak Up!” if theysee improper conduct or behaviors. The Global Integrity and Compliance Department provides other necessary
leadership, processes, policies, and tools to ensure that our employees act with integrity.
We approach our COBC program as a dynamic structure. As we continue to expand globally, we are constantly
seeking to ensure that our program is attuned to the ever-changing internal and external business and legal
environment. The COBC program is implemented in a way that translates effectively into local contexts and accounts
for cultural differences as needed. Much of this work begins with educating our new employees on our expectations
with respect to how they act and what filters they use when making decisions.
Key aspects of how we implement our COBC include:• Within 30 days of their initial hire date, all employees worldwide are required to take a COBC overview course.
• We provide compliance training to various targeted employee audiences on topics of non-discrimination and		 harassment, wage and hour compliance, workplace accommodations, anti-corruption, competition law
		 compliance, and data privacy and security. Our Global Integrity and Compliance team also conducts general in		 person training sessions through the year. In 2012, we launched a new learning portal that gives our employees		 (and their managers) direct access to their online learning history and upcoming mandatory trainings.
• We provide a variety of online self-help tools for compliance education and communication, including Leader
		 Tools (which guide leaders in how to have effective conversations with their teams), FAQs, policy links,
		 and contacts.
• Each year, our Global Integrity and Compliance team conducts over 100 interviews with employees and		 selected vendors. These interviews allow us to gauge how well our employees understand our COBC, remind		 our employees and vendors of their responsibilities and our expectations as to how we engage with each other,		 and ensure that employees know how to report COBC violations.
• Senior-level employees must certify their COBC compliance annually and are briefed on relevant compliance or		 integrity topics to raise awareness.
24

COMPANY | CODE OF BUSINESS CONDUCT• We encourage employees to “Speak Up!” and report suspected or alleged violations to their supervisor or a		 human resources representative, email our Global Integrity and Compliance department at global_integrity@		gap.com, or call a confidential, third-party hosted hotline available 24/7 to all employees worldwide, with
		 interpreters available in multiple languages. In 2012, we launched a new web-reporting tool, www.speakup.
		 gapinc.com, with the same third-party provider, giving employees across the globe even more ways to		 confidentially report their concerns. All allegations are taken seriously, appropriately investigated, and resolved.
		 Our anti-retaliation policy protects individuals who report suspected violations.
• Each year, we solicit nominations from our employees across the globe for the Fisher Award for Integrity.
		 The award is named in honor of our co-founders, Don and Doris Fisher, and is given to an employee who has		 embodied our integrity value of “Do: what’s right.”
We also expect our vendors (including non-merchandise vendors) and others with whom we do business to share ourvalues and comply with the law. We continue to embed practices that closely examine our higher-risk relationships
prior to entering into them, and set forth our expectations in our contracts and other communications with them.
In addition to the Global Integrity and Compliance Team, we have a Corporate Compliance Committee of seniorcross-functional leaders. This committee meets quarterly to provide program guidance, offer insights into thebusiness that may impact the COBC program, and raise overall awareness of the COBC within the Company.
A committee of the Board of Directors also receives updates on the compliance program at least semi-annually.
The Board of Directors also receives periodic education on compliance and integrity-related topics.
Learn more about our Code of Business Conduct.

25

COMPANY | PRODUCT SAFETY
Key Takeaways:• Customer safety is a priority for our company, and we have a rigorous testing process in place to help ensure thesafety of our products.
• We maintain a restricted substance list to further ensure customer safety by dictating which chemicals cannot
be used in the production of our clothing.
Product safety is a top priority for Gap Inc. We take pride in designing and selling clothing that meets or exceeds
safety and regulatory requirements in the markets where our products are sold. Our corporate Product Safety teamand global Product Integrity teams work to ensure that our branded products are made to strict safety standards,
employing safety ‘checkpoints’ such as design engineering assessments and laboratory testing during development
and production phases. Products are tested for a variety of potential safety issues, including flammability, physical/
mechanical hazards (ensuring garment construction or trims can withstand certain levels of force and do not become hazards), and toxicity.

Restricted Substance List
From fabric dyeing to creating unique garment finishes, chemicals are used throughout the production cycle ofmost garments. Knowing that certain chemicals can be harmful to consumers, in 2008 we developed a Restricted
Substance List (RSL) that dictates which chemicals must not be used to produce our clothing.
We base this list on both existing and developing legislation as well as toxicity risk assessments. As part of ourongoing monitoring process, we have an independent, accredited third-party lab test for restricted chemicals in ourfinished products. If products do not meet applicable legal chemical requirements and regulations, they will not besold or must be remade to meet our compliance standards. If a supplier’s product is shown to have elevated levelsof these chemicals, we provide test results and guidance to help the supplier remediate its usage of these chemicals
and educate the supplier on our chemical policy.

26

GOALS AND PROGRESS | Supply chain | Overview

Human Rights
Full Section

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Gap Inc. 2011/2012 Social and Environmental Responsibility Report27

HUMAN RIGHTS | OPERATING CONTEXT & STRATEGYKey Takeaways:• We are in the process of evolving our human rights strategy to build on the best of what we have done in thepast while addressing our current operating context and changing business environment.

The landscape has changed
Since Gap Inc. began to focus on social responsibility in the mid 1990s, the business and human rights landscape has
evolved significantly. Over the past two decades, leading companies have exponentially expanded their efforts toembed human rights practices into global supply chains.
We have also seen the global pace of production accelerate, supply chains become more disaggregated, competitionin the apparel industry intensify, and demand for lower-cost, faster fashion rise rapidly. These pressures have made it
more challenging to ensure that workers in diverse regions—with differing laws, cultures, and economies—work insafe and fair conditions.
Many companies have recognized that acting responsibly is now a basic expectation, and that lapses bring significant risk to their reputation and ability to operate. Leading companies are going beyond solely mitigating risk to
considering how improved working conditions can benefit all stakeholders, giving everyone involved the incentive tosustain better practices and build on them in the future.
More frameworks and policies are now in place to support progress, such as the United Nations Guiding Principles
on Business and Human Rights and the California Transparency in Supply Chains Act (CATSCA). The stakeholder
community has evolved its own tools to advance change, with enhanced strategies to monitor and motivate responsible corporate behavior.
Factors contributing to poor working conditions in garment factories
Working conditions
Brand orretailer

Garment
manufacturers

Industry
conditions

Country
conditions

International
conditions• Lack of understanding offactory conditions and howpurchasing decisions canimpact them

• Ineﬃcient processes andoperating practices• Fragmented nature ofgarment industry• Inadequate or outdated
labor laws

• Poor supervisory andmanagement skills• Intense competition andfocus on reducing costs• Insuﬃcient enforcement bylocal government• Global trading requirements, including complex
bi and multilateral
restrictions• Insuﬃcient emphasis onlabor standards in sourcing
decisions• Acceptance of production
orders without full assessment of capacity andcapabilities• Conflicting standards, lackof uniform code of conduct,
and lack of industry coordination• Lack of understanding ofrights among workers• Unreasonable expectations
regarding cost and speed• Lack of modern technology
and equipment• Chronic price deflation• Ineﬃcient buying practices• Poor economic, financial andcivic infrastructure• Lack of regard for the rights
of workers• Tariﬀs• Geographic shifts in
production following
expiration of quotas• Increasing expectations ofconsumers regarding costand selection• Insuﬃcient understandingof labor laws and standards
Significant influence

Some influence

Some influence

Gap Inc. level of influence

28

Some influence

Less influence

HUMAN RIGHTS | OPERATING CONTEXT & STRATEGY
These changes represent progress. Yet we are aware of the complex issues that remain—many of them systemic anddeeply rooted. Recent tragedies have occurred in apparel factories in Bangladesh and Pakistan that underscore theurgent need to dramatically improve working conditions and worker safety in some regions. Creating change in thiscontext will require local and national governments, more companies, and the industry as a whole to take substantive action. Many existing efforts—factory monitoring and capacity building among them—will also have to becarefully analyzed and improved in order to achieve their ultimate goals.
Several major trends are influencing the conditions in which clothes are made. These include:• Insufficient building safety and fire safety preparedness in apparel factories in some markets, particularly
		 Bangladesh. Paired with this is a lack of governmental oversight and accountability with regard to the		 implementation of building codes and fire safety regulations.
• Demand for fast fashion, which can lead to additional pressure on conditions inside factories. As retailers face		 pressure from their customers to constantly deliver on trends, management faces faster turnaround times,		 which can subsequently lead to workers facing longer hours and other potential issues.
• Lack of meaningful consumer awareness and action around these issues. Consumers have the opportunity
		 to take a more active role in “voting with their dollars” and support companies that have effective human		 rights practices in place.
• Increasingly complex and fragmented supply chains, which can have the dual effect of making workers more		 vulnerable to macro-economic trends while diminishing the ability of brands and retailers to assert influence.
• Great variability by country. In some countries, we are seeing efforts to vertically integrate aspects of the supply
		 chain, which can insulate workers from the negative impacts of fluctuations in the global economy.
		 For example, China and India not only have cut-and-sew capabilities, they also spin raw cotton into yarn and		 manufacture fabric in mills. Other countries, such as Cambodia, remain heavily invested in the cut-and		 sew tier, leaving them more vulnerable to the purchasing behaviors of major apparel companies. Also, because
		 Cambodia’s manufacturing sector is based almost exclusively on assembling garments and leverages
		 competitive labor as its “value add,” the country is particularly sensitive to wage issues.
For global companies such as ours, the evolving business landscape is becoming more complex as we balance theneeds and desires of our customers, investors, business partners, governments, and civil society. These varying stakeholders and their diverse priorities make it challenging for business to satisfy everyone. Despite these challenges,
we are constantly working to identify the issues that are most relevant, and seek to identify where we can impact
changes in policy, practice, or both. We are committed to operating responsibly, and we also recognize that what itmeans to be a leader in that capacity is shifting. It is not enough to think only of our own behavior; we must also
contribute to moving the industry forward. In some cases, this may mean taking the first bold step on an issue, whilein others it may mean partnering within a broader coalition to drive industry-wide change.
Respecting human rights in the apparel industry will require thoughtful action by more companies. While many inthe industry are working both individually and collectively to bring about change, many others are not. We encourage
everyone in our sector to join the broad effort to advance equality and respect for human rights.

Our strategy starts with a new vision
Having sought to improve working conditions in the apparel sector for close to 20 years, we draw on valuable experi29

HUMAN RIGHTS | OPERATING CONTEXT & STRATEGY
ence to inform our future direction. In 2012, we began to review our initiatives, strategies, and partnerships focusedon improving working conditions in our supply chain. We took stock of what we have accomplished, where we havefallen short, and where we believe we must go.
As part of this initiative, we have created a new Social and Environmental Responsibility vision for Gap Inc. to “Raise
the bar by creating value for all.”In the context of human rights, this means we aspire to improve working conditions for garment workers by demonstrating how doing so can benefit all stakeholders—from workers being promoted more quickly and receiving higher
wages, to factory managers becoming more efficient and thereby profitable, to customers knowing that their clothing is made by people who are treated fairly. It also means that we will help set a new standard of responsibility inthe areas where we choose to lead.
Our vision compels us to continue investing in credible human rights due diligence processes as described in the
UN Guiding Principles on Business and Human Rights, while forging a strategy in which improving human rights
becomes a driver of business success. Along the way, we will aim to convert challenges into opportunities and to advance equality through innovation and growth. This vision requires focus; we will not succeed if we fail to prioritize.
We believe that it is better to do fewer things very well than it is to be merely adequate at many.
We believe that the key to sustainable change lies in creating value, rather than just protecting it. By seeking todevelop mutually beneficial practices that create value for a broader set of actors—our company, garment workers,
vendors, and other stakeholders—our efforts will become more sustainable and scalable.

Evolving our human rights strategy
We know that our vision is only the starting point for change. Its value will be measured by the actions it drives andthe impact it achieves over time. As such, we are in the process of translating our vision into an evolved human rights
strategy that maintains the best of what we have done in the past and builds on it to fully account for our current
operating context and changing business environment.
We are basing our human rights strategy on our experience, expertise, impacts, influence, and partnerships, and are
guided by our history of:• Marrying policy and practice: We have a Human Rights Policy and a Code of Vendor Conduct that we enforce
		 through our Monitoring & Vendor Engagement team in conjunction with business units across Gap Inc. and		 with external stakeholders.
• Collaborating and innovating to scale solutions: We were a founding member of the International Labor
		 Organization’s Better Work program, and are now members of its Advisory Council.
• Being transparent about what works and what does not: We have been reporting on our social and		 environmental impacts since 2003.
• Investing where we can achieve the greatest impact: We have focused our efforts on the cut-and-sew level,		 where we have the most influence.
• Contributing to public policy: When relevant, we work to advance Gap Inc.’s human rights strategies through		 public policy and government advocacy.
30

HUMAN RIGHTS | OPERATING CONTEXT & STRATEGY• Identifying opportunities to both respect human rights and advance our business: We seek to develop models
		 of change that create shared value for a broader set of stakeholders.
We are committed to a human rights strategy that builds on what has worked over the past 20 years, addresses what
has not, delivers new solutions, and enhances measurement systems that assess our progress and impact. In manycases, this means collaborating with peers who are striving to make the same improvements and changes that weare, as we know there remain significant opportunities to improve factory practices and working conditions. We lookforward to working with others who share our commitment in order to change the way the sector operates and create a new norm of responsibility.
We are focusing our human rights strategy on two key areas: 1) Vendor Engagement and 2) Fire and Building Safety
in Bangladesh.
Our Vendor Engagement efforts seek to build sustainable human rights practices in garment factories by demonstrating the value we can create for a broad set of stakeholders by investing in workers’ well-being and rights, vendor
capacity building, and factory monitoring and remediation. We are in the process of implementing a case management approach to Vendor Engagement, moving beyond the “one size fits all” approach that has driven many industry
efforts to date. These tailored programs are being rolled out in factories that are either of strategic importance toour business or that have repeated compliance issues against our Code of Vendor Conduct (COVC). Our new sourcing
strategy will also help advance our Vendor Engagement efforts. Centered on category management, this new strategy calls for sourcing based on companywide product categories such as denim or knits. This approach emphasizes
collaboration—across brands, geographies, our internal teams, and other stakeholders throughout our supply chain.
In addition, this approach will help us build closer relationships within our vendor base that support both ourbusiness success and our ability to improve working conditions.
For more information on our Vendor Engagement Program, please visit the Monitoring and Remediation andCapacity Building portions of this report. To read a case study about how shared value can work in the factory
setting, please see the story on our Gap Inc. P.A.C.E. program in the Advancing Women section of this report.
Our efforts to improve fire and building safety in Bangladesh began with our own internal program in 2012, when we
began conducting fire safety assessments at the factories we contract with in the country. To carry out this work, we
hired a team led by one of the world’s foremost fire safety experts, Randolph W. Tucker of the engineering firm ccrd,
who sits on the Board of Governors at the National Fire Protection Association. We also hired a team of structural
engineers from the firm Walter P. Moore to help us assess the structural integrity of these facilities.
While implementing our own program, we also worked with other leading apparel brands and retailers to help create the Alliance for Bangladesh Worker Safety, a comprehensive, multi-stakeholder approach to addressing fire andbuilding safety in Bangladesh. This five-year agreement is designed to fundamentally improve worker conditions in
Bangladesh through comprehensive factory inspections, safety training and readiness, worker empowerment initiatives, and financial assistance to factories and affected workers in Bangladesh. The initiative will not only bring together retailers and brands that play a substantial role in Bangladesh’s garment industry, but will be structured—via
a system of specific benchmarks and incentives—to ensure that the Bangladeshi government has a vested interest in
reinforcing positive change through good governance and the rule of law. For more information on this effort, please
visit www.bangladeshworkersafety.org , and to learn more about our efforts in Bangladesh, read the Bangladesh Fireand Building Safety article in this report.

31

HUMAN RIGHTS | UN GUIDING PRINCIPLES ON BUSINESS & HUMAN RIGHTS
In 2013, Gap Inc. asked Shift to review our Social & Environmental Responsibility report and offer reflections on theimplications of the UN Guiding Principles on Business and Human Rights (Guiding Principles) for Gap Inc.’s efforts torespect human rights in our global supply chain. Shift is a leading non-governmental organization that works withgovernments, businesses, and stakeholders to put the UN Guiding Principles into practice.
The Guiding Principles provide an important framework for how companies should identify and address their humanrights impacts. Shift’s review of our policy and programs was based on documents and interviews with key staff, anddid not involve an assessment of activities on the ground. Shift provided us with several insights that we will consider
as we continue to evolve our human rights strategy. Select learnings include:• The emphasis that the Guiding Principles places on a company first understanding where it has impact and		 then considering how to address those impacts based on its unique levers of influence. This is consistent		 with the approach that we have taken to address human rights issues in our cut and sew facilities (where there		 are significant impacts and we have some influence) and in addressing Uzbek cotton (where there are		 significant impacts but we have less influence). Shift recommends that Gap Inc. further review the potential
		 for significant impacts throughout our apparel and non-apparel supply chain, even where influence may be		 less obvious.
• The importance of integrating worker perspectives into our Monitoring and Capacity Building programs.
		 We rely on local staff (who understand the local language and customs) in the countries where we source to		 help ensure we are interpreting and incorporating worker perspectives into how we address human rights
		 issues. Shift also noted the importance of integrating broader stakeholder concerns into our Risk
		 Assessment processes.
• Our continued use of root cause analysis, which helps us understand the underlying causes of poor working
		 conditions, and analysis of how our own actions, such as purchasing practices, may at times contribute to		 negative human rights impacts.
• Support for our effort to further develop our materiality assessment approach, while urging us to more		 carefully consider how we fully reflect the severity of impacts on affected stakeholders in that approach.
		 We will continue to fulfill the Guiding Principles expectation that, as a company with potentially significant
		 impacts, we formally report on how we address our human rights impacts.
• The importance of maintaining operational-level grievance mechanisms, as a means for affected stakeholders
		 to raise concerns about a company’s impacts in order to seek remedy. Shift noted our respect for and efforts to		 support workers’ freedom of association as important contributions to this. They also noted that we should
		 continue to build on lessons learned from previous experiences in engaging credible third parties to help
		 establish and operate effective grievance mechanisms.
• The urgent need to address fire and building safety in Bangladesh in a collaborative manner. Shift stated their		 regret that many North American brands and retailers felt it necessary to form an agreement separate from		 the European-driven Accord and stressed the need to avoid duplication, inconsistency or confusion. They noted		 that observers will ultimately look for the results that are delivered for workers. Shift also acknowledged that
		 Gap Inc.’s focus on fire and building safety, worker empowerment, and freedom of association should
		 contribute to tangible improvements on the ground. We are now advancing this through our participation in		the Alliance for Bangladesh Worker Safety.

32

HUMAN RIGHTS | UN GUIDING PRINCIPLES ON BUSINESS & HUMAN RIGHTS
You can read Shift’s full review of our human rights practices and policies in the Appendix of this report. The scope of
this review was focused exclusively on our supply chain, and does not represent a full assessment across our owned
and operated facilities (such as stores or corporate offices). We see this review as a meaningful step toward better understanding how our efforts to respect human rights in our supply chain fit within the Guiding Principles framework.

33

HUMAN RIGHTS | WORKING WITH FACTORIESKey Takeaways:• We strive to create long-term solutions—and advance both human rights and our own business goals—byaddressing the underlying causes of human rights issues in the factories that make our branded apparel.
• We continue to go beyond monitoring to create innovative strategies grounded in partnership and sharedaccountability among companies, vendors, workers, and other key stakeholders.
• Monitoring is an essential strategy for improving working conditions, but it needs to become more consistentand effective throughout the apparel industry.
As discussed in the Operating Context & Strategy section of this report, our business landscape has changed dramatically since we first sought to improve working conditions in our supply chain in the mid-1990s. So have the tools
we use to create positive change.

We continue to focus our human rights efforts largely at the cut-and-sew level of the supply chain
because we believe in investing where we have influence and can achieve impact.
We have learned that monitoring and remediation are necessary, but they alone are not enough to create lastingchange. While monitoring is an essential tool for developing a measureable baseline assessment and addressing thesymptoms of poor working conditions, it cannot always adequately address the root causes of these conditions orform the basis for long-term solutions. What’s more, as a policing model, monitoring will periodically fail because
auditors simply cannot identify every problem all of the time.

Recently there has been increased public debate about whether monitoring is an effective way to
improve working conditions in apparel factories. We believe that monitoring is essential, but we also
believe that its execution needs to be more consistent across the industry; there is too much variation in
the degree to which companies enforce their codes of conduct and invest in remediation. For more detail,please see the Monitoring section of this report.
We are working to create long-term solutions—and advance both human rights and our business goals­—by addressing the systemic drivers of issues in the factories that make our branded apparel. We have gone beyond monitoringto create strategies that share accountability among companies, vendors, workers, and other key stakeholders.
For example, in the late 1990s, we joined a new effort to improve labor standards compliance and transparency.
The effort culminated in the creation of the Better Work program, a partnership between the International Labour
Organization (ILO) and the International Finance Corporation (IFC, part of the World Bank Group). Better Work seeks
to help governments, workers, and companies achieve compliance with the ILO’s core labor standards and national
labor law. By promoting innovative and credible systems, Better Work has sustainable impact and directly benefits
the lives of millions of workers. Currently, we sit on the Advisory Board of Better Work representing U.S. buyers, andare committed to seeing this partnership grow beyond the seven countries in which it now operates. For more information on Better Work, please see the case study below.
Over the past ten years, these efforts have ranged from worker training on freedom of association to multi-stakeholder initiatives addressing a wide range of worker rights. While some efforts have generated promising results,
others require further adjustment and innovation in order to make the greatest impact.

34

HUMAN RIGHTS | WORKING WITH FACTORIES
Our work with factories is based on a tiered approach, outlined below, which seeks to address the problems frommultiple angles.

SHARED VALUECAPACITY BUILDING

Programs such as P.A.C.E. help factories go beyond monitoring or capacity
building by creating value through investing in the life and professional
skills of their workers.
Our capacity building program seeks to help vendors and factories
take ownership of social responsibility by internalizing many ofthe practices we audit against in our monitoring program.
Our monitoring program seeks to create value throughhelping apparel factories meet a baseline standard ofworking conditions.

MONITORING
AND REMEDIATION

Shifting how and what we measure
We know that the tools we use could be enhanced to give us added insight into our human rights practices.
Accordingly, we are seeking to improve how we measure the outcomes and impacts of our efforts, rather than
measuring success by the number of activities we pursue or the degree to which we implement them. This is a
shift in measurement that will take considerable innovation as we tackle complex questions about what constitutes
impact. For example, is impact the absence of problems or crises? If impact is the creation of value, how do we definethat value? Over the next two years, the answers to such questions will inform how we develop new measurement
and analysis tools.

Case Study: Advancing industry collaboration and consistency
We are working with the Global Social Compliance Programme (GSCP) and other leading apparel retailers to create
an industry-aligned approach to Social and Labor Management Systems that would seek to help vendors meet compliance requirements and engage in continuous improvement programs. This effort, known as the GSCP Social andLabor Management Systems Initiative, seeks to help vendors integrate social compliance into their daily operationsin efficient, systematic ways.
The goal is to collaboratively develop guidelines that will reduce confusion and redundancies, while still allowing
room for variations in different systems. We recognize that organizations such as the Business Social Compliance
Initiative, Ethical Trading Initiative, Fair Labor Association, and Social Accountability International all bring uniquevalue to this area, but we also believe that greater alignment among them would create added efficiencies.
This process is at an early stage, and we look forward to providing detailed updates in our next report.

Case Study: ILO Better Work programFor more than ten years, we have worked with other companies, governments, trade unions, non-governmentalorganizations, governments, and international institutions to advance the quality and consistency of monitoring.
35

HUMAN RIGHTS | WORKING WITH FACTORIES
One way we have sought to do so is by aligning industry-monitoring practices. We believe that, by helping to develop
a consistent industry-wide approach to monitoring, we will be better equipped to advance equality for workers in theapparel sector. We aim to create a baseline standard that is easily understood by companies, vendors, factory managers, and workers so that efforts to improve working conditions will be more focused, inclusive, and successful.
In 2001, we helped form the International Labour Organization’s (ILO) Better Factories Cambodia program, which
has since expanded into the global Better Work program. This highly regarded partnership between the ILO and theInternational Finance Corporation (IFC) seeks to help governments, workers and companies achieve compliance with
the ILO’s core labor standards as well as national labor laws. In 2012, our Vice President of Social and Environmental
Responsibility was elected to a two-year term representing U.S. buyers on Better Work’s Advisory Committee.
In countries where Better Work programs are established, we subscribe to Better Work assessment reports and havestopped our own monitoring at Better Work’s request. This allows us to deploy our internal monitoring team morestrategically, with a focus on remediation and capacity-building efforts.
In 2011–12 Gap Inc. collaborated with Better Work in Cambodia, Haiti, Indonesia, Jordan, Lesotho, Nicaragua, andVietnam to monitor more than 90 factories. The degree to which we rely on the Better Work program varies bycountry. For example, all of our branded apparel suppliers in Jordan, Lesotho, and Haiti participate in the Better Workprogram, whereas in Vietnam, Better Work monitored approximately 30 percent of the factories we source from overthat time period.
Better Work and its members are committed to continually measuring the impact and efficiency of the program.
Better Work publishes a Discussion Paper Series and the Better Work Impact Research to help inform its strategy andpolicy decisions. To read more about Better Work’s evolution, challenges, and opportunities, please click here.

36

HUMAN RIGHTS | MONITORING AND REMEDIATION
Key Takeaways:• Monitoring continues to play a crucial role in helping us improve working conditions in the factories producing
branded apparel for our family of brands.
• One critical feature of our approach is our in-house team of approximately 50 experts within our broader
Social and Environmental Responsibility department, who are responsible for assessing working conditions in
the factories that manufacture our branded apparel.
• At Gap Inc., monitoring does not mean visiting a factory once a year. It means conducting root cause analyses,
implementing long-term remediation plans, and continuously evolving our approach to make it ascomprehensive and effective as possible.
Monitoring continues to play a key role in our strategy for working with factories. While we recognize that monitoring alone is not sufficient to reach all of our goals, it remains foundational to respecting human rights and improving
working conditions in our supply chain, and is a key tool that helps us assess human rights risks through country,
vendor, issue prevalence, and geographical lenses.

2011 audits49%

announced

2012 audits

51%

51%

unannounced

announced

49%

unannounced

In 2011, we conducted 618 unannounced audits and 590 announced audits of suppliers that manufacture branded
apparel for our brands. In 2012, we conducted 563 unannounced audits and 585 announced audits of suppliers that
manufacture branded apparel for our brands.
While Gap Inc. does not own or operate any production facilities, in 2012, we monitored 96.4 percent of the active,
full-year factories that produce our branded apparel, which included 923 factories in 32 countries around the world.
Our monitoring program extends to all authorized sub-contractors at the cut-and-sew level. Our efforts to monitor
all factories producing Gap Inc. branded apparel are complemented by a non-apparel policy that requires all suppliers of Gap Inc. branded product to sign a compliance agreement stating their commitment to abide by our Code ofVendor Conduct (COVC). In order to focus our resources where we can have the greatest impact, we begin monitoring
non-apparel suppliers once their volume reaches an agreed-upon threshold. You can read more about this policy inour 2005–06 report.
Our approach to monitoring relies on a number of tools and procedures that help us assess our human rights
impacts. We assess working conditions throughout the entire duration of our relationship with a given vendor, andanalyze current and emerging issues through the use of regional strategy maps, analysis of audit reports, compliancewith our Code of Vendor Conduct, and evaluation of factory performance to inform where we allocate our resources,
which requires close collaboration between our Social and Environmental Responsibility and Sourcing departments.
37

HUMAN RIGHTS | MONITORING AND REMEDIATION
Further, we understand the potential negative consequences of our own operational decisions (i.e. order changes),and are mindful of vendors’ capacities in our human rights risk assessment processes. Read more information on ourpurchasing practices in this section of the report.
Two key principles guide our approach to monitoring:• We believe that what gets measured gets managed. We monitor factories against the consistent standards of		 our COVC, and we rate their performance over time so that we can more effectively address issues.
• We work to fix what we find. The value of monitoring extends far beyond uncovering problems; it includes all
		 of the actions we take to facilitate remediation in a sustainable way.

Factory Ratings Components

Description

Non-key

Code of Vendor Conduct violations found at
a factory. (i.e. Factory does not maintain copies
of applicable laws)

Key

Code of Vendor Conduct violations found at afactory with higher negative impact to thefactory ratings than Non-key issues. (i.e. Factory
limits or interferes with access to workers)

Non-key

A non-key issue that was resolved
is found again at the factoryKey

A key issue that was resolved
is found again at the factory

IssuesReoccurence

Follow-up

Best practices

If the issue is not resolved by theagreed upon resolution date, the factoryrating will be negatively impacted

Factories that implement best practices
beyond our code or the local law(i.e. free daycare provided for all employees)

Our factory ratings are calculated using multiple inputs such as the type of issue found, the frequency of its
occurrence, and the best-practice points given to factories that go beyond our COVC.

38

Ratings
ImpactHUMAN RIGHTS | MONITORING AND REMEDIATION
We have gained valuable insights over nearly 20 years of monitoring the factories that make our branded apparel:• A tailored approach to monitoring­—based on the frequency of visits and the types of issues we focus on—is		 more effective than a one-size-fits-all model. Each factory may have unique issues driven by unique causes.
• Evaluating factory performance over time uncovers insights and trends that help us determine the optimal
		 frequency and focus of our visits. This insight allows us to allocate our resources more strategically.
• Having an in-house team of experts to monitor factories gives us more control over the quality and consistency
		 of monitoring, allows us to establish better relationships with workers and vendors, and most importantly,
		 enhances our ability to remediate issues. Having an expert team also spurs innovation as our experienced field		 team works with our headquarters staff to reveal insights and new ways of addressing key issues.
• Locally and regionally hired team members are crucial to driving sustainable change because they speak the		 local language and understand the cultural, geographic, and economic issues specific to their regions.
Our monitoring program includes five stages:
1. Approval. Before any factory can manufacture apparel branded by Gap Inc., it must undergo an initial audit
		 assessing its working conditions. Based on this audit, the factory either earns approval or is placed in a pending
		 status while it addresses outstanding issues. In select cases, a factory that has resolved all identified major
		 issues may be granted a one-time, conditional approval, even though it may still have a few minor issues to		 resolve. In 2011 and 2012, we approved a total of 137 factories and rejected 33.
2. Monitoring. We make announced and unannounced visits to conduct audits that assess factory performance		 against the standards outlined in our Code of Vendor Conduct. In 2011–12, approximately 50 percent of our		 visits were unannounced. We tailor the frequency of visits to a factory’s unique needs. For example, a factory
		 that is not performing well may require more visits than a high-performing factory.
3. Rating. Our Monitoring and Vendor Engagement team assesses factory performance during its audits,		 reviewing more than 700 indicators in the process. Our rating system places factories in one of four major color
		 tiers: Green = Top Performer; Light green = Above Average; Yellow = Average; Red = Below Average. Rating		 factories is a rigorous process that requires careful decisions about the weight of various issues. For example,
		 we define “key” violations, such as excessive overtime, as having greater negative impact on a factory’s rating		 than “non-key” violations, such as first-aid kits not being fully stocked. We also award a limited number of		 best-practice points to encourage factories to go beyond basic compliance for initiatives such as offering
		 leadership training to workers or issuing public sustainability reports.
4. Remediation. We emphasize remediation, and we do not allow Code of Vendor Conduct violations to go		 unaddressed. When we find violations, we work with factory management to agree on specific time-bound		 improvement plans. We monitor progress through follow-up visits and on-site meetings with unions if they		 are present in a factory. Because partnerships can often yield better results than one-sided approaches, we		 frequently work with other brands to remediate issues in shared factories. We also collaborate with local
		 stakeholders to help identify and address factory issues when they may have more direct access and influence.
5. Root cause analyses. We conduct root cause analyses and review management systems to assess the		 underlying causes of ongoing violations. We believe that the most sustainable way to address problems over		 the long term is to help vendors understand the conditions that allow violations to recur.

39

HUMAN RIGHTS | MONITORING AND REMEDIATIONROOT CAUSE ANALYSIS DIAGRAM
STEP BY STEPCASE STUDY

Step 1—Identify the problem. Root cause analysis is especially suited to issues
that have occurred more than once, suggesting the need to address underlying drivers. Issues related to health and safety should be priorities and may
be uncovered by consulting past audit reports. Looking beneath the surface isvaluable even with potential new problems, and it has become an integral partof our work with factories. Increasingly, we encourage factory management toundertake this process themselves.

Workers at one factory were not using filter masks at a spot cleaning station.
This issue recurred and posed a potential health and safety risk to workers.
The reason for not wearing masks was unclear, calling for a deeper inquiry.

Step 2—Decide who needs to be in the room. One of the keys to productive
analysis is making sure that the right people participate. For example, if theissue involves work hours, those responsible for a factory’s production should bepart of the discussion; if the issue concerns broken lights, then the maintenancemanager is more appropriate.

In the case of workers not using filter masks, a range of people were brought
together to look at the issue from different angles: the production manager,
maintenance manager, controller, and representatives of compliance andhuman resources.

Step 3—Ask “why” along with open-ended questions. A root cause analysis is ajourney with no clear destination; questions often lead to more questions, andunderstanding is the ultimate goal. “Why?” is often the best route to success, as
are open-ended questions that do not cast judgment or blame. What not to ask:
questions that can be answered with a quick yes or no.

Why were workers not wearing filter masks? This initial question was broken
down into a number of follow-ups: Why weren’t health risks reviewed withworkers? Why didn’t they understand the need for masks? Why were spot cleaning stations located in places without ventilation? Why hadn’t management
taken disciplinary action?

Step 4—Get to the bottom of the problem. Finding the cause of a problem
requires persistence and open-mindedness. What lies beneath the surface canbe unexpected or difficult to tease out, especially with sensitive issues. In addition, many issues have more than one driver, and it is critical to determine which
drivers are most important.

Workers were not wearing their filter masks because they were uncomfortable
and inconvenient to wear. But this was not the underlying problem. At root,
workers did not understand the need to wear the masks. So they took what
seemed like the easier path and chose not to wear them.

Step 5—Consider and select a solution. Once the cause of a problem is unearthed, creating a solution becomes more straightforward. Is the issue lack ofawareness? A lapse by factory management? A missing procedure or technicalproblem? Effective solutions address more than just symptoms and are thus
more comprehensive.

The factory undertook a thorough health and safety assessment and introduced
an incentive program, awareness campaign, and worker training about the useof masks. We sought to balance the need to inform workers of the risks withoutcausing alarm, while taking clear steps to ensure safety. For example, certain
work areas would start requiring the use of protective gear.

Step 6—Implement and communicate. An improvement plan outlines who is
responsible for taking action and when that action will be completed. In order tobe most effective, such plans need to be specific and include buy-in from factory
management. This is especially true because many issues include the need for
cultural shifts within the factory.

The specific steps outlined above were documented in an improvement plan.
The factory also implemented an awareness campaign for workers about filter
masks, holding meetings and trainings. Corresponding health and safety signs
were posted throughout the factory.

Step 7—Follow up. Since the goal of root cause analysis is to prevent issues fromrecurring, it is essential to track whether that goal has been met. Continuous
self-assessment is an ongoing part of the process, and it may yield new insights
into refining an improvement plan and making it even more effective.

An assessment found that workers gained new understanding of the importanceof wearing filter masks and learned how to use them. In addition, the factory’s
health and safety assessment uncovered the use of hazardous chemicals incertain areas, and these were removed in favor of safer substitutes.

40

HUMAN RIGHTS | CAPACITY BUILDINGKey Takeaways:• Our capacity-building efforts focus on empowering suppliers to have a positive impact on working conditions inways that create value for workers, communities, factories, and brands.
• We base this work on a model of continuous improvement, building on lessons learned and sharing thisknowledge with our suppliers.
• Because challenges at different factories vary greatly, we are developing a tailored approach to make ourcapacity building even more effective.
Because we know that monitoring is only one element of improving working conditions over the long term, we
pursue additional strategies to achieve our human rights goals.
Our Vendor Engagement Program focuses on capacity building and improving management systems in our supplierfactories. Based on a model of continuous improvement, our vision for this program is to empower suppliers to havea positive impact on working conditions in ways that create value for workers, communities, factories, and brands.
Our intent is to leverage the Global Social Compliance Programme’s Social and Labor Management Systems initiative.
This industry-aligned approach seeks to help minimize duplication of compliance and capacity-building efforts whiledeveloping a common understanding and application of different brands’ requirements that pertain to
management systems.

A management system is defined by the Global Social Compliance Programme as “an operational set ofpolicies and procedures that a supplier establishes to achieve and measure continuous improvement inworking conditions. There are many types of management systems, but all share the common aim of
improving efficiency and organizational performance through the application of appropriate policies
and procedures.” We know that improving management systems can often help address the root causeof key issues. For example, if a factory can develop comprehensive planning schedules for its productionlines, it will be better able to ensure that workers stay within the legal number of hours, reducing thechance of excessive overtime.
Created in 2008 in partnership with Verité and further evolved with Social Accountability International in 2011,
our Vendor Engagement Program seeks to help vendors and factory managers:• Detect and remediate specific human rights issues.
• Implement human resource management systems that help prevent issues from occurring in the first place.
• Engage stakeholders to create locally relevant solutions to key issues.
• Invest in their communities and their workers­—both within and outside their work environment.
• Establish goals for social and environmental responsibility.
Gap Inc. has been implementing various capacity building programs for nearly ten years. Our approach is based on
the idea that when social responsibility systems are run internally within a factory or vendor’s operations, they will
become more sustainable.
While we have not measured the impact of these various efforts in a quantifiable way, we have found that our existing “one size fits all” approach to capacity building has limitations. The challenges and opportunities for improve41

HUMAN RIGHTS | CAPACITY BUILDING
ment within a factory can vary greatly, which is why we are in the process of evolving our capacity building efforts
toward a case management approach. We will be implementing tailored programs in factories that are either ofstrategic importance to our business or that have persistent compliance issues against our Code of Vendor Conduct(COVC). Our new sourcing strategy, which calls for working with fewer vendors in a deeper way, will help facilitate
this work by supporting closer relationships that better meet the needs of individual factories.
With a case management approach in mind, we are in the process of designing and implementing a needs-based
assessment to identify our vendors’ capacity building needs. We are in the early stages of this new approach, and willcontinue to partner with the Global Social Compliance Programme to help ensure that our efforts complement otherindustry initiatives.

42

HUMAN RIGHTS | BANGLADESH FIRE AND BUILDING SAFETY
Key Takeaways:• Fire and building safety in Bangladesh’s ready-made garment industry is a key priority for Gap Inc., and we areworking with a broad coalition of stakeholders through the Alliance for Bangladesh Worker Safety to address
this urgent issue.
• We have formed an expert team focused on improving fire and building safety at the factories producing ourbranded apparel in Bangladesh. We are also providing training to help drive worker and management behavior
changes to improve fire safety practices.
In December 2010, a tragic fire broke out at the Hameem Group’s That’s It Sportswear factory in Dhaka, Bangladesh,taking the lives of 29 people and injuring more than 100 others. The factory was a supplier to Gap Inc. and several
other major apparel brands and retailers. This tragedy affected all of us at Gap Inc. deeply, as a fundamental purposeof Gap Inc.’s approach to social and environmental responsibility is to ensure that factories producing our branded
apparel maintain a safe working environment. Since that time, other tragedies have occurred in apparel factories
in Bangladesh that further underscore the imperative for significant change. In 2012 and 2013, major industrial
accidents occurred at two apparel factories, Tazreen Fashions and Rana Plaza, and while we did not source any
products from either facility, we believe that all apparel brands and retailers who source apparel from Bangladesh
have a role to play in bringing about real and lasting change for workers in the country’s ready-made garment sector.

For more information on how Gap Inc. is working with a broad set of stakeholders to address fire andbuilding safety in Bangladesh, please visit the Alliance for Bangladesh Worker Safety website.
We recognize that change is urgently needed and we have marshaled our resources to respond as quickly andeffectively as possible. Our strategy to improve fire and building safety in Bangladesh is focused on two key areas:
1. Improving fire and building safety across our entire factory base in Bangladesh, through extensive inspections
		 and remediation plans.
2. Providing training to drive worker and management behavioral changes to improve fire and building		 safety practices.
We took action in October of 2012 and provided both funding and resources as part of the Gap Inc. Fire and Building
Safety Action Plan. These commitments were taken one step further when we became a founding member ofthe Alliance for Bangladesh Worker Safety in July 2013. These two initiatives evolved from several years of intense
negotiations with a number of stakeholders, and represent our company’s commitment to not only improving safety
at the approximately 70 factories in Bangladesh where we do business, but also ensuring that our impact is broader
than these factories.

History of engagement
Following the 2010 fire in Dhaka, we engaged in many months of discussions with labor rights groups on a pathforward for fire and building safety in Bangladesh. Between the Summer of 2011 and the Fall of 2012, a team within
Gap Inc. devoted hundreds of hours to help find a resolution through good faith negotiations with labor rights
groups, during which we regularly communicated our belief that any final agreement must incorporate the principleof shared responsibility among a broad set of stakeholders, while also expressing concerns about the working
document’s vague language regarding legal and financial liability that could potentially lead to unlimited exposure
43

HUMAN RIGHTS | BANGLADESH FIRE AND BUILDING SAFETY
for our company. We worked closely with labor representatives and other stakeholders to develop specific language
and concepts, work that was ultimately leveraged as the foundation for the Accord on Fire and Building Safety in
Bangladesh that many European retailers endorsed.
Recognizing the importance of taking action with other retailers, Gap Inc. initiated the process that ultimately led to
the five-year partnership with leading North American and other retailers as part of the before-mentioned Alliancefor Bangladesh Worker Safety. It was announced in August 2013 that widely-respected former Representative
Ellen Tauscher, who most recently served as high-ranking leader of the U.S. State Department, will serve as theindependent chair of the Alliance.
The Alliance was developed on the principle of shared accountability among multiple stakeholders. It is important tonote that the rapid growth of the local garment industry has far eclipsed the Bangladeshi government’s capacity tomonitor or enforce worker safety conditions. Our experience in other emerging markets has shown us that achieving
meaningful progress will require a broad and robust level of engagement from the Bangladeshi government, as wellas with the factory owners, non-governmental organizations, labor and civil society.
Our intention since the beginning of this multi-year process has been driven by our commitment to improve theworking conditions at garment factories in Bangladesh. Our on-the-ground fire inspectors have already identified
many improvements, such as the installation of sprinklers and fire doors in buildings, which are already being made.
But, we know the power that can come when retailers take action together. As a company, we very much respect
the labor rights groups who are working primarily with European retailers through the framework of the Accord,and hope that our path forward will be one where we work together to advance a shared agenda of creating a safer
work environment in Bangladesh. It is our hope that all parties can commit to work together to ensure that efforts
to improve fire and building safety in Bangladesh are aligned, compatible, and seek to avoid duplication wherever
possible. The value of an initiative ultimately should ultimately be measured by the impact it achieves, and we willcontinue to report on the progress we make in the months and years ahead.

Bangladesh Timeline

Bangladesh Timeline

11
1

3

2010

2011
2

5

7

9

2012
4

13

2013
6

8

12

15
2014

2015-2018

14

16

10
1 1. December
1.
2010:
at Hameem,
Gap Inc.
employeessite stakeholders
and meet inwith
local
stakeholders
December 2010:
Fire atFire
Hameem,Gap Inc. employees
visit
site and meetvisit
with local
the days
immediately
following the firethe daysfollowing
firevisit Dhaka to meet with local stakeholders and industry partners
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4. andAugust2011: Gappartners
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industry

5. October 2011: Gap Inc. works with other brands and Hameem factory owner to deliver worker humanitarian fund (all 8 brands contribute)

3 June 2011: Gap Inc. is the sole brand that agrees to redraft the “Joint MOU on Fire Safety” with3.
6. September 2012: Gap Inc. negotiations with international NGOs and trade unions break down, primarily over the dispute
stakeholders
		 international
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and building
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4 7. August
4.
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brandsto Planexecutethefireworkerhumanitarianfund.
8. February 2013: Formal expert fire and building safety inspections of all Gap Inc. approved factories begin

5 October 2011: Gap Inc. works with other brands and Hameem factory owner to deliver worker
5.
humanitarian fund (all 8 brands contribute)44
6 September 2012: Gap Inc. negotiations with international NGOs and trade unions break down,
6.
primarily over the dispute resolution provisionHUMAN RIGHTS | BANGLADESH FIRE AND BUILDING SAFETY
9. May 2013: Gap Inc. begins direct negotiations with IndustriALL and UNI Global—negotiations break down over the dispute		 resolution provision
10. July 2013: North American brands and retailers announce the creation of the Alliance for Bangladesh Worker Safety
11. September 2013:		

- Develop a “hotline” process—Sect.3.1

		- Engage 3rd parties to develop training program—Sect. 4.2(a)(ii)		- Adopt training standards, curriculum—Sect. 4.2(a)(iii)		- Adopt a common fire and building safety standard—Sect. 5.2(a)		- Factory lists shared with FFC—Sect. 6.2(b)		- Factory inventories complete—Sect. 7.2(a)(ii)		- Available Alliance fire and building safety reports shared with FFC—Sect. 7.2(a)(iv)

12. October2013:		

- Fire and building safety trainings begin—Sect. 4.2(b)		- Identification of Worker Participation Committees—Sect. 4.2(b)(iv)

13. November 2013: Finalize protocols for reporting inspections—Sect. 7.s(b)14. July 2014:		

- Achieve 100% inspections of Alliance factories—Sect. 6.2( c)		- Train workers, management at 100% of Alliance factories—Sect. 4.1

15. July 2015: Achieve transition from individual company to Alliance Fire and Building Safety Training Program—Sect. 4.2(a)(vii)
16. ONGOING (through 5 years): Ongoing training, inspections, audits and verification, and public reporting*Section numbers correspond to details in the Alliance Members Agreement

Gap Inc.’s Fire and Building Safety Action Plan
One of our core initiatives now underway in Bangladesh is a commitment to shoring up safety conditions at the morethan 70 factories from which we source apparel. We were one of the first brands to launch a comprehensive fire andbuilding safety plan in October 2012. We engaged a Chief Fire Safety Inspector, Fire Safety Team, and Building Safety
Team to conduct fire and building safety inspections with formal remediation plans and accountability mechanisms.
The cornerstone of Gap Inc.’s plan centered on fire and building safety inspections conducted by qualified andindependent inspectors. We retained the services of Randolph W. Tucker, an internationally renowned expert on fire
safety, as our Chief Fire Safety Inspector, and starting in January 2013, he began overseeing fire and building safety
inspections of garment factories producing for our brands in Bangladesh. These fire safety inspections were based onnational laws, internationally recognized workplace safety standards, and existing best practices in Bangladesh. We
also retained the firm Walter P. Moore to help assess the structural integrity of the apparel factories from which wesource in Bangladesh. As a fulfillment of our responsibilities under the Alliance, both inspection firms will continue to
conduct these inspections on behalf of Gap Inc.
Other key aspects of Gap Inc.’s Fire and Safety Building Plan included providing vendors with accelerated accessto capital for safety improvements, to assist factory owners in Bangladesh in making necessary fire and building
safety upgrades. We also sought to implement a Worker Support Program to ensure that factory employees who
were displaced from work because of required remediation work identified by our inspections were able to receive
payment of up to one month’s wages for missed work days. We are also engaging with governments and theInternational Labour Organization (ILO) on various facets of our program.
Key aspects of Gap Inc.’s Fire and Building Safety Action Plan are now being executed through our participation in the
Alliance for Bangladesh Worker Safety. By partnering with so many other leading apparel brands and retailers on thiseffort, we believe we will have far greater impact than we could by working independently.
45

HUMAN RIGHTS | BANGLADESH FIRE AND BUILDING SAFETY

The Alliance for Bangladesh Worker Safety
In July 2013, Gap Inc. signed an agreement to form the Alliance for Bangladesh Worker Safety. The Alliance originallybrought together 17 founding brands that play a substantial role in Bangladesh’s garment industry. There are now
20 members and that number is expected to grow. As a founding member, Gap Inc. joined other members to provide
the funding necessary to support the specific programs of the Bangladesh Worker Safety Initiative. The agreement
was created under the guidance of former Senators George Mitchell and Olympia Snowe of the Bipartisan
Policy Center.
The Alliance was borne out of the belief that collaboration with safety experts, governments, multi-lateral
institutions, non-governmental organizations, and workers, among others, is essential for creating long-term
systemic change in the country. The Alliance has developed a measurable framework that will not only incentivize
the Bangladesh government to shoulder the responsibility of actively enforcing compliance with labor standards andbuilding and safety codes, but also provide technical and financial resources to bolster the nation’s trained safety
experts and civil engineers who can perform inspections and oversee required factory improvements.
This emphasis on capacity building goes hand-in-hand with a commitment from Alliance members to inspect
and train 100% of their sourcing factories within the first year, and as of August 2013, at least $45 million has beencommitted to the Worker Safety Fund (WSF). Further, some members are offering a combined total of over $100
million in access to capital to assist those factories that they work with that might require additional resources tomake safety upgrades. Further, as more brands and retailers join the Alliance, we anticipate the cumulative financial
contributions will increase.
Key elements of the Alliance include:• Empowering workers to take an active role in their own safety, and to be able to speak out about unsafe
		 conditions without any risk of retaliation.
• Providing safety inspection, and safety and empowerment training for 100% of factories in the Alliance		 members’ respective supply chains.
• Sharing information on training, current and future fire and building safety inspections and		 remediation actions.
• Establishing a common standard for safety inspections and safety and worker empowerment training.
• Independent monitoring and verification of the inspections and training.
• Inclusion of diverse stakeholders in decision making and collaboration in implementation.
• A Bangladeshi focus, with a framework that engages and builds capacity of key stakeholders, including the		 Government of Bangladesh and Bangladeshi industry.
• Commitment of substantial financial resources to accomplish these tasks, as well as encouraging and assisting		 in the establishment of sustainable mechanisms to meet these objectives.
• Commitments by some members to make low-cost capital available to factories in order to accelerate the		 pace of improvements. This program, to which some members have already pledged a total of over		 $100 million, was created in response to priority requests from the Bangladesh Garment Manufacturers
		 and Exporters
46

HUMAN RIGHTS | BANGLADESH FIRE AND BUILDING SAFETY
Association and the Bangladesh Knitwear Manufacturers and Exporters Association.
Key elements of our Fire and Building Safety Plan will help us fulfill our responsibilities as a part of the Alliance. Like
many other retailers, our efforts to address this issue predate the creation of the Alliance, and we feel we have a great
deal to share with and learn from others as we move forward. For additional and updated information on our efforts
to address fire and building safety in Bangladesh, please visit the following sites:• BangladeshWorkerSafety.org—The website for the Alliance for Bangladesh Worker Safety.
• WeAreCommitted.com—A Gap Inc. blog that shares key updates on Bangladesh fire and building safety, as well		 as information on additional efforts we undertake to improve working conditions in our supply chain.
• GapInc.com—Our corporate website, which includes a section dedicated to press releases and key updates on		 our efforts to improve fire and building safety in Bangladesh.

47

HUMAN RIGHTS | FREEDOM OF ASSOCIATION
Key Takeaways:• Our Code of Vendor Conduct explicitly supports freedom of association and the rights of workers to “lawfully
and peacefully associate, organize or bargain collectively.”• These rights allow workers to find a common voice and provide them with a framework for engaging withmanagement on fair wages, sufficient benefits, and the right to do their work in fair and decent conditions.
• We use a wide range of approaches to ensure that the rights of freedom of association are respected, fromsupporting open dialogue between factory workers and managers to partnering with workers’ rights groups
and trade unions when appropriate.
As stated in our Human Rights Policy, Gap Inc. supports the United Nation’s Universal Declaration of Human Rights,
which includes freedom of association and the right to collective bargaining. Our Code of Vendor Conduct (COVC)
explicitly states that:“Workers are free to join associations of their own choosing. Factories shall not interfere with workers who wish tolawfully and peacefully associate, organize, or bargain collectively. The decision whether or not to do so should bemade solely by the workers.”
The right to organize and bargain collectively allows those workers who so choose to find a common voice. It provides
workers with an important framework for engaging with management on their rights to receive fair wages, sufficient
benefits, and the ability to do their work in fair and decent conditions. While management in some factories may provide excellent workplaces and engage with their employees through a variety of channels, we believe that freedom of
association can serve as an important pathway to help workers achieve better working conditions.
The extent to which freedom of association rights are upheld and respected varies from country to country. In many
regions of the world, social protections, civil society, and governmental institutions remain underdeveloped, andsystemic inequities can lead to exploitative labor practices. What’s more, those who press for improvements can facedaunting challenges and even personal risk as they make a case for change and play a public role in negotiations.
Because workers around the world face such diverse challenges depending on their location and circumstances,
we use a wide range of approaches to help ensure that their rights are respected. We support open and productive
dialogue between factory workers and managers­—two groups with a history of mistrust and poor communicationin many developing countries. When appropriate, we seek to help bridge this divide while ensuring that freedom of
association is respected both in principle and in practice. In some cases, we also partner with workers’ rights groups
and trade unions. We find that dialogue among factory management, labor groups, and workers can help in addressing issues when challenges arise. It can also lead to improvements in other aspects of factory conditions.
While our approach may sound simple in theory, it is often difficult to initiate a constructive labor relations dialogue
among groups with conflicting points of view. In many cases, it is an achievement even to foster an environment inwhich a productive dialogue can take place.

Case Study: Fostering consensus and dialogue in Cambodia’s garment sector
It is reported that more than 1,800 trade unions represent garment workers in Cambodia, covering approximately
370 factories. Many factories have more than one union; some have more than ten unions in a single facility.
The high number of unions in the country increases the complexity of addressing freedom of association and48

HUMAN RIGHTS | FREEDOM OF ASSOCIATION
collective bargaining issues. The challenges are compounded by the government’s inconsistent enforcement of
the country’s labor laws.
In 2011 and 2012, a series of strikes occurred in Cambodia’s garment industry, mainly driven by workers demanding
increases in wages and benefits. Gap Inc. sourced from several of the factories affected by these strikes. Sometimes
management would negotiate an agreement with the most representative union, only to have another union initiate
a strike with slightly higher demands in an effort to win members.
As a result of the strikes, the Garment Manufacturers Association of Cambodia and the eight major union confederations and federations (representing a majority of the unions officially registered with the Cambodian government)
negotiated a Memorandum of Understanding. It went into effect on October 3, 2012, and is in effect for two years. In
coordination with other key buyers in Cambodia, Gap Inc. played an active role in helping foster the negotiations that
led to its creation.
The Memorandum of Understanding has several key consequences:• Encouraging the use of Collective Bargaining Agreements (CBA) to protect the rights of both workers and		 factory owners.
• Addressing the complexities of having so many unions in a single facility by mandating that the union		 representing the most workers in a given facility will lead in CBA negotiations with the employer, thus
		 representing all workers in a factory.
• Tasking an independent Arbitration Council to review and arbitrate labor disputes between workers and		 factory owners. The Arbitration Council was launched in 2003 with the initial assistance of the International 				 Labour Organization (ILO) and in collaboration with tripartite stakeholders: the Cambodian Ministry of Labor,
		 employers’ associations, and trade unions.
• Agreeing that in the absence of a CBA, and when mediation fails to resolve an issue, both parties will accept
		 the Arbitration Council’s ruling as final and binding for all rights-related disputes.
• Creating a working group of representatives from trade unions and the Garment Manufacturers Association
		 of Cambodia to address issues surrounding short-term contracts for workers.
• Initiating a national policy dialogue on productivity.
We are hopeful that this Memorandum of Understanding will help improve industrial relations and working conditions in Cambodia. Formalizing a dispute resolution process helps resolve urgent issues in a way that is transparent,
collaborative, efficient, and respected both by unions and employers. We believe it is a credible platform for peacefullabor dispute resolution in Cambodia that benefits both workers and suppliers. It also opens a broader conversation
about issues surrounding wages, productivity, benefits, and short-term contracts—all urgent issues that will help
define the future of Cambodia’s garment industry.

This experience helped reinforce several lessons we’ve learned over time, while leading to new insights:• It is important to create an open, enabling environment for sometimes adversarial parties to engage in		 constructive dialogue. Providing the appropriate context is crucial for meaningful and effective industrial
		 relations to occur.
49

HUMAN RIGHTS | FREEDOM OF ASSOCIATION• Using peaceful means of dispute resolution, by supporting credible and independent organizations such as the		 Arbitration Council, can help bring stability to the complex relationships between unions and employers in		 certain markets.
• Even in difficult circumstances, it is often possible to reach a common goal by engaging a broad set of		 stakeholders, including the local government, trade unions, brands, industry associations, multi-lateral		 agencies, and non-governmental organizations.
• Most importantly, it takes continuous effort to achieve sustainable improvement.

50

HUMAN RIGHTS | FORCED LABORKey Takeaways:• As we work to combat forced labor, we recognize that this human rights abuse can take many forms. Some are
deeply entrenched in local contexts and customs, requiring extensive stakeholder networks to identify andaddress them.
• Through partnership and collaboration, we have taken a number of steps to address the exploitative practiceknown as Sumangali, which affects young women who work in fabric mills and apparel factories inSouthern India.
The International Labour Organization (ILO) estimates that more than 20 million people around the world are forced
to work against their free will. This issue has received heightened attention over the past several years due to theinnovative and diligent work of non-governmental organizations, governments, multi-lateral organizations, media,
and companies.
At Gap Inc., we explicitly prohibit the use of forced labor in the making of our products through our Code of Vendor
Conduct (COVC) and our Vendor Compliance Agreements. For information on how we monitor the factories making
our branded apparel, please review the Monitoring and Remediation section of this report.
At the policy level, we are encouraged by the U.S. Department of State’s ongoing commitment to address thisissue through the Global Trafficking in Persons Report, which provides a meticulous analysis of the state of forcedlabor, human trafficking, and slavery worldwide. This important document serves as a baseline that helps dictate
programmatic collaboration across sectors and diplomatic actions between governments aimed at addressing these
exploitative practices.
In California, we welcome the California Transparency in Supply Chains Act (CATSCA), which requires companies of acertain size to publicly disclose how they are working to identify and eradicate forced labor in their supply chains.
At a more grassroots level, technologies such as the Free 2 Work application are helping consumers make informed
decisions about supporting companies that address the issue of forced labor.
While these innovative strategies bring promise, there is more work to be done.
Based on our long history of actively addressing various human rights issues in our supply chain, we know thatforced labor can take many forms. Some are deeply entrenched in local contexts and customs, and require extensive
stakeholder networks to identify and address. We have developed such stakeholder networks in key sourcing regions
around the world, and we partner with groups to address the issues we collectively seek to change.

Case Study: Forced labor in Southern India—the Sumangali scheme
One example of how we partner with and leverage our stakeholder network to address complex issues is the
Sumangali scheme in Southern India. Sumangali is a practice that brings young women to work in fabric mills andapparel factories on the promise of decent wages, accommodations, and payment of a lump-sum amount at the endof a three-year contract. In some cases, this lump-sum payment is used as a dowry for marriage. The problem exists
primarily in fabric mills in this region of India, where some mills are reported to pay below minimum wage, provide
unacceptable living conditions, and force these women to work overtime.
The Sumangali scheme is a violation of our COVC, and we do not approve apparel factories that use this practice.
Knowing that addressing systemic issues requires an industry-wide, locally inclusive approach, we took a leadership51

HUMAN RIGHTS | FORCED LABOR
role in establishing an industry working group through the Ethical Trading Initiative. We helped bring together
international brands and retailers, the local and national government, manufacturers and mills, non-governmentalorganizations, and trade unions to discuss the issue and identify a locally-driven way forward.
We also organized a meeting with Brands Ethical Working Group (BEWG) members and the Tirupur Exporters
Association (TEA), which resulted in the formation of the Tirupur Stakeholders Forum (TSF). The TSF has since agreed
on a set of guidelines for factories to help eliminate unacceptable employment practices. TSF members are now
engaged in a dialogue that will hopefully lead to tripartite oversight of these guidelines by representatives from local
non-governmental organizations, industry representatives, and trade unions.
Through these ongoing partnerships, we helped create an initial roadmap with the Tamil Nadu Working Group andthe Ethical Trading Initiative to address the Sumangali issue. The roadmap is built on a three-pronged strategy:
1.
		
		
		
		

Support leadership from within the local industry to accelerate change. Work with the Ethical Trading
Initiative, the International Labour Organization, non-governmental organizations, and local government todevelop locally based programs. The goals: to help suppliers develop better working conditions focusedon increasing awareness of workers’ rights, help develop worker-management dialogue, enable forms ofworker representation and collective bargaining, regulate recruitment agents, and conduct hostel inspections.

2. Support local NGOs to educate local communities to aid in prevention. Implement an outreach and		 awareness plan at the community level in Tamil Nadu to highlight the problems associated with Sumangali		 schemes and brands’ expectations toward their abolition. This includes setting up orientation and training for		 schools, teachers, parents, health workers, and factory managers to promote rights awareness for female		 garment workers in the region.
3.
		
		
		

Support government involvement to aid enforcement. Work with suppliers (both fabric mills and apparelfactories) and local government to create a supportive environment for female garment workers in
Tamil Nadu—leveraging existing social service and nonprofit initiatives to ensure effective protection
and support services.

This initiative will be implemented over the next three years. We advance it with cautious optimism, knowing that
addressing human rights issues in local contexts with longstanding customs is both difficult and complex. Throughpartnership and collaboration, we are confident that positive change will help lead to more just and equitable futures
for female garment workers in South India.

52

HUMAN RIGHTS | CHILD LABORKey Takeaways:• We have a zero-tolerance policy when it comes to child labor and maintain a thorough remediation process
in case of the rare instance when underage workers are identified in a factory producing apparel for one ofour brands.
• We recognize that child labor is one of the most difficult human rights issues to remedy because it is so often
driven by systemic issues related to poverty.
• The case studies below highlight some of these complexities and describe the steps we are taking to identify andaddress the root causes of child labor.
Gap Inc. has worked to combat child labor in the apparel industry for nearly 20 years. Our position has not changed:
Child labor is an unacceptable practice that violates our Code of Vendor Conduct and Human Rights Policy. However,taking a stand on child labor is the easier part of the equation. The more difficult part is creating solutions that not
only remediate occurrences, but also help address their underlying causes.
In order to effectively combat child labor, we believe it must be understood in the context in which it occurs. It is oneof the most difficult human rights issues to remedy because it is so often driven by systemic development issues
related to poverty. Studies show that adolescents who work excessive hours or in hazardous conditions are far lesslikely to complete their education, which severely curtails their ability to escape poverty. In a very real sense, childlabor is both a symptom and a cause of poverty.
Governments, multi-lateral institutions, and non-governmental organizations have all invested in efforts to address
this issue, yet the International Labour Organization estimates that there remain over 200 million child laborers in
the world today.

We value documents such as the U.S. Department of Labor’s List of Goods Produced by Child Labor or
Forced Labor. This expansive document was created by the Department’s Bureau of International Labor
Affairs (ILAB) to “develop and make available to the public a list of goods from countries that [ILAB] hasreason to believe are produced by forced labor or child labor in violation of international standards.” It
is updated annually, and provides consumers and companies alike with a thorough analysis of current
trends in child labor and forced labor.
Based on our understanding of the underlying complexities of child labor, our threefold strategy addresses the issue
at multiple levels:
1.
		
		
		

Monitor the factories that produce our branded apparel—including sub-contractors. Our Social
Responsibility Specialists visit factories, review age-verifying documents, and interview workers. Whenrequired, they help improve verification and records-retention systems so that factories can build their own
capacity to identify and not hire underage workers.

2. Implement a comprehensive remediation plan if an underage worker is identified. On the rare occasion that		 an underage worker is found working in a facility that makes our branded apparel, that person must be		 immediately removed from the workplace, given access to schooling, paid an ongoing wage, and guaranteed		 a job at the factory upon reaching the appropriate age. The vendor responsible for this violation pays for the		 costs associated with this remediation, which provides further incentive for our suppliers to ensure that their		 age-verification systems are comprehensive and effective.
3. Work in partnership with stakeholders to identify locally relevant solutions. We work with local organizations
53

HUMAN RIGHTS | CHILD LABOR
		
		
		

and development experts to address the root causes of child labor. Our partnership with expert groups inIndia, such as Bachpan Bachao Andolan (BBA), Society for Promotion of Youth and Masses (SPYM), andNational Homeworkers’ Group (NHG), are recent examples.

The approach we take depends on the local context and specific nature of the problem. While monitoring andremediation are crucial aspects of our strategy to address the issue of child labor, they alone are not always sufficient.
The case studies below highlight the complexity and challenges of child labor and how we partner with others tocreate long-term sustainable change.

Case Study 1: The complexities of child labor in Cambodia’s garment sector
Many people assume that child labor at the cut-and-sew level is driven by exploitative or irresponsible factory
managers willfully hiring underage workers. Yet the reality can be much more complex. Underage workers
sometimes go to great lengths to secure counterfeit documents that misrepresent their age because, in many
developing countries, seeking employment before reaching a legal age can seem a more viable option thanattending school.
In Cambodia, we have even seen instances of local governments helping underage workers attain legal
documentation that misrepresents their age. The rationale is that, if these young people are able to migrate fromrural areas to urban centers for work, they will be able to help support their families back home, thus helping to spur
economic development in more isolated parts of the country.
This is a systemic problem—one that conveys the complexity underlying many human rights issues. In order toaddress it, we have worked to gain an in-depth understanding of the issues from multiple perspectives by consultingwith a range of stakeholders. Follow our outreach and analysis, we elected to communicate our position against childlabor to the government of Cambodia, and we continue to work with the International Labour Organization, local
stakeholders, and local and national government agencies in the country.

Case Study 2: Child labor in the cotton fields of Uzbekistan
Each autumn, more than a million children are forced to work in Uzbekistan’s cotton fields, picking the cotton forexport to international markets. One of the most troubling aspects of this exploitation is that the use of forced childlabor is directly orchestrated by the national government, a practice that has been in place for decades.
While our company does not purchase raw cotton directly, we believe that apparel retailers who rely on cotton in
their products have a role to play in addressing the issue.
Since we became aware of this crisis in 2007, we have been working to bring about a solution in partnership with anorganized network of concerned stakeholders that include human rights experts, non-governmental organizations,trade unions, industry associations, socially responsible investors, and other global apparel brands and retailers.
In addition to participating in the stakeholder network, we have made it clear to our vendors that we expect theirfactories and fabric mills to avoid knowingly purchasing Uzbek cotton. We have also participated in meetings with
the U.S. State Department and other government agencies to explore potential policy initiatives that would address
the problem. And we have supported multiple complaints filed with the International Labour Organization, citing the54

HUMAN RIGHTS | CHILD LABOR
Uzbek government’s continued violation of international labor norms.
Despite the steps taken, we have received reports that the use of child labor persists in Uzbekistan’s cotton fields.
We will continue to work with the multi-stakeholder network seeking to end this practice, lending our expertise andvoice where we can make an impact.

55

HUMAN RIGHTS | PURCHASING PRACTICESKey Takeaways:• We recognize that decisions made by production and sourcing teams at Gap Inc. can have significant impacts on
workers in our supply chain.
• We continue to deepen our understanding of these impacts and work to incorporate this knowledge into ourdecision-making.
The business decisions we make at our headquarters may seem far removed from working conditions inside supplierfactories, but in fact these two realms are intricately linked.
For example, if we make a last-minute change to an order of 500,000 T-shirts, such as an alteration to the type of
stitching used, the factories where we place our orders must ensure they have the right number of workers on handto complete the order. If such a change is poorly planned or projected, this type of decision can mean that workers
are pressed to work longer hours or lose their days off in order to meet shipping deadlines. Further complicating
this issue is the dynamic between suppliers and apparel brands: Most factories manufacture garments for several
companies at a given time, and some vendors are unwilling to disclose their full production capacity to companies
such as ours.
As we work with factories to address issues outlined in our Code of Vendor Conduct, we seek to build our own
knowledge of how our decisions affect theirs. This is one of our reasons for fostering a sense of partnership in
our strategic relationships with vendors—because it helps both of us to improve. We are emphasizing vendor
partnerships even more under Gap Inc.’s new sourcing strategy, which we began implementing in 2012. This strategy
calls for working with a smaller, consolidated vendor base to facilitate deeper relationships. As we create benefits fora range of stakeholders, from factory managers to our own business, we create incentives for positive change andhelp ensure that this work is sustainable and enhanced over time.
In 2011, we created a Brand Integration and Vendor Performance project team at Gap Inc. to help our company
better leverage vendor data to drive business decisions, including order placement. By assessing the drivers ofvendor performance and deploying our expansive data on factory performance, the team sought to improve ourown production management planning and identify where we can help improve management systems in our key
vendors’ factories.
To continue our progress in this area, we take a multi-faceted approach to improving our purchasing practices.
Our Social & Environmental Responsibility team continues to pursue several initiatives, which include:• Meeting regularly with strategic and low-performing vendors to assess their performance against our Code		 of Vendor Conduct and discuss how the timing and planning of our orders are affecting their workers.
• Meeting with leaders in the Gap Inc. Sourcing department to examine any issues related to working conditions
		 that may have stemmed from our decisions at headquarters.
• Developing a virtual training tool that can be used by our employees globally to understand our company’s		 social and environmental responsibility efforts, with a focus on how our purchasing decisions can impact local
		 communities around the world.
• Training all new hires in inventory management, merchandising, production, and sourcing on the importance		 of responsible purchasing practices; and highlighting case studies and tools to ensure that factory orders are		 made with a full understanding of their potential impact on workers.
We still see opportunities to make our purchasing practices a stronger driver of both human rights and business
56

HUMAN RIGHTS | PURCHASING PRACTICES
success. As we continue to consolidate our supplier base and build long-term relationships with key vendors, we
believe we will be able to innovate in ways that make our purchasing practices even more effective.

57

HUMAN RIGHTS | GOALS

Current human rights goals
Estimatedcompletion date
70% or more of our factories in ILO Better Work markets participate in the ILO Better Work program.

2014

All factories Gap Inc. sources from in Bangladesh will comprehensive fire and building safety inspections by July 2014,
and will have begun implementing remediation plans to ensure safety standards are met.

2014

Gap Inc. will build a team of dedicated vendor capacity building experts who will be fully trained and deployed by 2015.

2015

Completed human rights goals
Completed
date
Implement and evolve our Vendor Engagement Program with 20 of our key vendors globally.

2011

Assess our vendor Social Responsibility rating tool in terms of distribution, utilization and effectiveness.

2011

Enhance sustained working conditions by driving industry collaboration initiatives in our top 10 sourcing countries.

2011

58

GOALS AND PROGRESS | Supply chain | Overview

Human Rights
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iquametum venisse modit amcommo lobore vendre modolum vendre essequa

Gap Inc. 2011/2012 Social and Environmental Responsibility Report59

HUMAN RIGHTS | DATA
2009 - 2012 Factory ratings comparison
Rating factories’ performance against our Code of Vendor Conduct is one of the most important things we do toseek to ensure safe and fair working conditions. We continually review our rating approach to maximize our ability
to understand and improve factory performance. Ultimately, the changes to our factory ratings and our Vendor
Development Program support our broader goal: to shift away from simply “policing” factories to understanding andaddressing the root causes of problems. We believe we have the responsibility to monitor factories and hold themaccountable—while helping them improve through better systems and practices.

100%
90%

14.5%

16.0%

15.9%

16.1%

35.8%

36.5%

34.2%

36.1%

31.5%

30.8%

34.3%

34.7%

18.3%

16.7%

15.6%

13.1%

2009

2010

2011

2012

Fiscal year

Fiscal year

Fiscal year

Fiscal year80%

% of total

70%
60%
50%
40%
30%
20%
10%
0%

Green: excellent
Light green: good
Yellow: fair
Red: action required

Note:
Data represents fiscal year and includes factories producing Gap Inc. branded product that are part of our monitoring program and that wereactive during either the full year or partial year. Partial-year factories include those that began or stopped working with Gap Inc. at some point
during the fiscal year.

60

HUMAN RIGHTS | DATA
2012 Factory ratings by geographic region
Regionof factories

Actionrequired

Greater China

343

22.4%

32.4%

34.4%

10.8%

North Asia

64

6.3%

42.2%

48.4%

3.1%

Southeast Asia

295

12.9%

30.2%

42.4%

14.6%

South Asia

332

8.1%

47.9%

35.2%

8.7%

Persian Gulf

1

100.0%

0.0%

0.0%

0.0%

North Africa & the Middle East

29

31.0%

41.4%

13.8%

13.8%

Sub-Saharan Africa

3

66.7%

33.3%

0.0%

0.0%

Europe

29

3.4%

24.1%

24.1%

48.3%

United States and Canada

33

1.3%

12.8%

30.8%

55.1%

Mexico, Central America & the Caribbean

78

0.0%

9.1%

24.2%

66.7%

South America

13

0.0%

30.8%

53.8%

15.4%

1220

13.1%

34.7%

36.1%

16.1%

Total

NumberFair (%)

Good (%)

Excellent (%)

(%)

Note:
Data represents fiscal year and includes factories producing Gap Inc. branded product that are part of our monitoring program and that wereactive during either the full or partial year 2012. Partial-year factories include those that began or stopped working with Gap Inc. at some point
during the fiscal year.

61

HUMAN RIGHTS | DATA
2011 Factory ratings by geographic region

Regionof factories

Actionrequired

Greater China

326

19.3%

35.6%

31.0%

14.1%

North Asia

75

14.7%

37.3%

44.0%

4.0%

Southeast Asia

297

12.5%

30.3%

39.7%

17.5%

South Asia

361

18.6%

41.3%

31.6%

8.6%

Persian Gulf

1

100.0%

0.0%

0.0%

0.0%

North Africa & the Middle East

31

41.9%

45.2%

3.2%

9.7%

Sub-Saharan Africa

3

0.0%

100.0%

0.0%

0.0%

Europe

28

0.0%

32.1%

35.7%

32.1%

United States and Canada

36

0.0%

11.1%

30.6%

58.3%

Mexico, Central America & the Caribbean

81

2.5%

17.3%

38.3%

42.0%

South America

16

12.5%

25.0%

62.5%

0.0%

1255

15.6%

34.3%

34.2%

15.9%

Total

NumberFair (%)

Good (%)

Excellent (%)

(%)

Note:
Data represents fiscal year and includes factories producing Gap Inc. branded product that are part of our monitoring program and that wereactive during either the full or partial year 2011. Partial-year factories include those that began or stopped working with Gap Inc. at some point
during the fiscal year.

62

HUMAN RIGHTS | DATA
2012 Factory approval
RegionNumber of
new factories
evaluated

Approved(%)

Not Approved(%)

Pending(%)

Greater China

65

52.3

23.1

24.6

North Asia

4

50.0

25.0

25.0

Southeast Asia

41

73.2

7.3

19.5

South Asia

49

85.7

2.0

12.2

Persian Gulf

0

N/A

N/A

N/A

North Africa & the Middle East

0

N/A

N/A

N/A

Sub-Saharan Africa

0

N/A

N/A

N/A

Europe

4

75.0

25.0

0.0

United States and Canada

10

90.0

0.0

10.0

Mexico, Central America & the Caribbean

16

93.8

6.3

0.0

South America

1

100.0

0.0

0.0

190

71.4

11.5

17.2

Total

Note:
Data represents fiscal year and includes factories producing Gap Inc. branded product that are part of our monitoring program and that wereactive during either the full or partial year 2011. Partial-year factories include those that began or stopped working with Gap Inc. at some point
during the fiscal year.

63

HUMAN RIGHTS | DATA
2011 Factory approval
RegionNumber of
new factories
evaluated

Approved(%)

Not Approved(%)

Pending(%)

Greater China

71

78.9

19.7

1.4

North Asia

7

71.4

28.6

0.0

Southeast Asia

44

86.4

11.4

2.3

South Asia

50

82.0

18.0

0.0

Persian Gulf

0

0.0

0.0

0.0

North Africa & the Middle East

5

80.0

0.0

20.0

Sub-Saharan Africa

1

0.0

100.0

0.0

Europe

4

75.0

25.0

0.0

United States and Canada

8

100.0

0.0

0.0

Mexico, Central America & the Caribbean

22

95.5

4.5

0.0

South America

0

0.0

0.0

0.0

212

83.0

15.6

1.4

Total

Note:
Data represents apparel factory status as of 2/1/2012 for factories that went through our approval process in fiscal year 2011.

64

HUMAN RIGHTS | DATA
2012 Factory monitoring
RegionActivefull year(# of factories)

Activefull year visited(# of factories)

Percentage visited(%)

Greater China

262

262

100.0

North Asia

58

58

100.0

Southeast Asia

232

221

95.3

South Asia

265

265

100.0

Persian Gulf

1

1

100.0

North Africa & the Middle East

26

26

100.0

Sub-Saharan Africa

2

2

100.0

Europe

21

21

100.0

United States and Canada

20

20

100.0

Mexico, Central America & the Caribbean

60

37

61.7

South America

10

10

100.0

Total

957

923

96.4

Note:
Active full year denotes factories that Gap Inc. has approved and worked with for the full fiscal year 2012. Data includes factories producing
Gap Inc. branded product that are part of our monitoring program.

65

HUMAN RIGHTS | DATA
2011 Factory monitoringa
RegionActivefull year(# of factories)

Activefull year visited(# of factories)

Percentage visited(%)

Greater China

253

251

99.2

North Asia

68

66

97.1

Southeast Asia

230

226

98.3

South Asia

281

281

100.0

Persian Gulf

1

1

100.0

North Africa & the Middle East

27

26

96.3

Sub-Saharan Africa

3

3

100.0

Europe

24

22

91.7

United States and Canada

28

26

92.9

Mexico, Central America & the Caribbean

57

57

100.0

South America

14

14

100.0

986

973

98.7

Total

Note:
Active full year denotes factories that Gap Inc. has approved and worked with for the full fiscal year 2011. Data includes factories producing
Gap Inc. branded product that are part of our monitoring program.

66

HUMAN RIGHTS | DATA
Today, we assess more than 700 items—potential issues that can affect working conditions—related to our Code ofVendor Conduct (COVC) that could range from whether a factory has clean bathrooms to its adherence to local laws.
We organize all these items into four principles, rather than the eight we used to use. This approach helps simplify
the data for reporting and collecting purposes. The four principles are: management system, environment, labor andworking conditions. The below data highlights a representative group of items instead of all 700 in an effort to makeour reporting more accessible and useful. From each main category, we’ve selected items that stakeholders havebeen most interested in and that, together, create an overall picture of performance.
In addition to the below data, we have numerous articles on the site that detail our efforts to address existing andpotential future COVC violations. For example, you can read more about our efforts to remediate compliance issues,
promote a safe and fair hand work environment, address child labor and human trafficking.

67

HUMAN RIGHTS | DATA
2012 COVC violations by region (chart I)
Complianceprinciple

Management
systemEnvironmental

Principle
subsection

Compliance detail

Handworkmonitoring

Does not maintain hand work supply chain details

Legal &
customerrequirements

Does not allow unrestricted access

EMS

Does not have an EMS

Environmental
emergency
plan

Does not have a notification procedure in case of
accidental discharge or environmental emergency

Hazardous
substances

Does not store and dispose of hazardous
materials appropriately.

Greater
China

North
Asia

343 Factories

64 Factories

Factory has not established a contractor monitoring system

Does not comply with child labor laws, including
hiring, wages, hours & conditions regulations

Child labor

Contractlaborregulations
Discrimination
Labor

Working
conditions

Employs worker below the legal min. age or 15,
whichever is higher
Employee Contract in Home Country
Return fee
Discriminatory distribution of wages & benefits
Discriminatory hiring policy

Forced labor

Uses involuntary labor

Freedom of
associationand the rightto collective
bargaining

Does not permit workers to organize

Humanetreatment

Does not prohibit physical punishment or coercion

Wages &
benefits

Does not pay overtime & incentives as required

Working
hours

Does not allow workers to refuse overtime

Dormitory &canteen

Does not maintain clear exit routes

Machinesafeguarding

Does not equip machinery with operation
safety devices and inspect on a regular basis

OccupationalsafetyDoes not maintain sufficient, clearly marked exits & routes

Penalizes workers’ efforts to organize

Does not prohibit psychological abuse or coercion
Does not provide understandable wage statement.
Does not provide 1 day off in 7
Does not provide individual mats or beds

Does not provide sufficient lighting

Note:
The data set displays the percentage of factories by region that had a specific Code of Vendor Conduct violation outstanding (irrespective of whenthe violation was identified) within the fiscal year 2012. The data represents factories producing Gap Inc. branded product that are part of ourmonitoring program and that were active during either the full or partial year. Partial year factories include those that began or stopped working
with Gap Inc. at some point during the fiscal year 2012.
68

HUMAN RIGHTS | DATA
2012 COVC violations by region (chart II)
Complianceprinciple

Management
systemEnvironmental

Principle
subsection

Compliance detail

Handworkmonitoring

Does not maintain hand work supply chain details

Legal &
customerrequirements

Does not allow unrestricted access

EMS

Does not have an EMS

Environmental
emergency
plan

Does not have a notification procedure in case of
accidental discharge or environmental emergency

Hazardous
substances

Does not store and dispose of hazardous
materials appropriately.

South
Asia

Southeast
Asia

284 Factories

328 Factories

Factory has not established a contractor monitoring system

Does not comply with child labor laws, including
hiring, wages, hours & conditions regulations

Child labor

Contractlaborregulations
Discrimination
Labor

Working
conditions

Employs worker below the legal min. age or 15,
whichever is higher
Employee Contract in Home Country
Return fee
Discriminatory distribution of wages & benefits
Discriminatory hiring policy

Forced labor

Uses involuntary labor

Freedom of
associationand the rightto collective
bargaining

Does not permit workers to organize

Humanetreatment

Does not prohibit physical punishment or coercion

Wages &
benefits

Does not pay overtime & incentives as required

Working
hours

Does not allow workers to refuse overtime

Dormitory &canteen

Does not maintain clear exit routes

Machinesafeguarding

Does not equip machinery with operation
safety devices and inspect on a regular basis

OccupationalsafetyDoes not maintain sufficient, clearly marked exits & routes

Penalizes workers’ efforts to organize

Does not prohibit psychological abuse or coercion
Does not provide understandable wage statement.
Does not provide 1 day off in 7
Does not provide individual mats or beds

Does not provide sufficient lighting

Note:
The data set displays the percentage of factories by region that had a specific Code of Vendor Conduct violation outstanding (irrespective of whenthe violation was identified) within the fiscal year 2012. The data represents factories producing Gap Inc. branded product that are part of ourmonitoring program and that were active during either the full or partial year. Partial year factories include those that began or stopped working
with Gap Inc. at some point during the fiscal year 2012.

69

HUMAN RIGHTS | DATA
2012 COVC violations by region (chart III)
Complianceprinciple

Management
systemEnvironmental

Principle
subsection

Compliance detail

Handworkmonitoring

Does not maintain hand work supply chain details

Legal &
customerrequirements

Does not allow unrestricted access

EMS

Does not have an EMS

Environmental
emergency
plan

Does not have a notification procedure in case of
accidental discharge or environmental emergency

Hazardous
substances

Does not store and dispose of hazardous
materials appropriately.

North Africa/
Middle East

Sub-SaharanAfrica28 Factories

3 Factories

Factory has not established a contractor monitoring system

Does not comply with child labor laws, including
hiring, wages, hours & conditions regulations

Child labor

Contractlaborregulations
Discrimination
Labor

Working
conditions

Employs worker below the legal min. age or 15,
whichever is higher
Employee Contract in Home Country
Return fee
Discriminatory distribution of wages & benefits
Discriminatory hiring policy

Forced labor

Uses involuntary labor

Freedom of
associationand the rightto collective
bargaining

Does not permit workers to organize

Humanetreatment

Does not prohibit physical punishment or coercion

Wages &
benefits

Does not pay overtime & incentives as required

Working
hours

Does not allow workers to refuse overtime

Dormitory &canteen

Does not maintain clear exit routes

Machinesafeguarding

Does not equip machinery with operation
safety devices and inspect on a regular basis

OccupationalsafetyDoes not maintain sufficient, clearly marked exits & routes

Penalizes workers’ efforts to organize

Does not prohibit psychological abuse or coercion
Does not provide understandable wage statement.
Does not provide 1 day off in 7
Does not provide individual mats or beds

Does not provide sufficient lighting

Note:
The data set displays the percentage of factories by region that had a specific Code of Vendor Conduct violation outstanding (irrespective of whenthe violation was identified) within the fiscal year 2012. The data represents factories producing Gap Inc. branded product that are part of ourmonitoring program and that were active during either the full or partial year. Partial year factories include those that began or stopped working
with Gap Inc. at some point during the fiscal year 2012.

70

HUMAN RIGHTS | DATA
2012 COVC violations by region (chart IV)
Complianceprinciple

Management
systemEnvironmental

Principle
subsection

Compliance detail

Handworkmonitoring

Does not maintain hand work supply chain details

Legal &
customerrequirements

Does not allow unrestricted access

EMS

Does not have an EMS

Environmental
emergency
plan

Does not have a notification procedure in case of
accidental discharge or environmental emergency

Hazardous
substances

Does not store and dispose of hazardous
materials appropriately.

United States
and Canada

Mexico, Central
America and the
Caribbean

33 Factories

54 Factories

Factory has not established a contractor monitoring system

Does not comply with child labor laws, including
hiring, wages, hours & conditions regulations

Child labor

Contractlaborregulations
Discrimination
Labor

Working
conditions

Employs worker below the legal min. age or 15,
whichever is higher
Employee Contract in Home Country
Return fee
Discriminatory distribution of wages & benefits
Discriminatory hiring policy

Forced labor

Uses involuntary labor

Freedom of
associationand the rightto collective
bargaining

Does not permit workers to organize

Humanetreatment

Does not prohibit physical punishment or coercion

Wages &
benefits

Does not pay overtime & incentives as required

Working
hours

Does not allow workers to refuse overtime

Dormitory &canteen

Does not maintain clear exit routes

Machinesafeguarding

Does not equip machinery with operation
safety devices and inspect on a regular basis

OccupationalsafetyDoes not maintain sufficient, clearly marked exits & routes

Penalizes workers’ efforts to organize

Does not prohibit psychological abuse or coercion
Does not provide understandable wage statement.
Does not provide 1 day off in 7
Does not provide individual mats or beds

Does not provide sufficient lighting

Note:
The data set displays the percentage of factories by region that had a specific Code of Vendor Conduct violation outstanding (irrespective of whenthe violation was identified) within the fiscal year 2012. The data represents factories producing Gap Inc. branded product that are part of ourmonitoring program and that were active during either the full or partial year. Partial year factories include those that began or stopped working
with Gap Inc. at some point during the fiscal year 2012.

71

HUMAN RIGHTS | DATA
2012 COVC violations by region (chart V)
Complianceprinciple

Principle
subsection

South America

Compliance detail

12 Factories

Management
systemEnvironmental

Handworkmonitoring

Does not maintain hand work supply chain details

Legal &
customerrequirements

Does not allow unrestricted access

EMS

Does not have an EMS

Environmental
emergency
plan

Does not have a notification procedure in case of
accidental discharge or environmental emergency

Hazardous
substances

Does not store and dispose of hazardous
materials appropriately.

Factory has not established a contractor monitoring system

Does not comply with child labor laws, including
hiring, wages, hours & conditions regulations

Child labor

Contractlaborregulations
Discrimination
Labor

Working
conditions

Employs worker below the legal min. age or 15,
whichever is higher
Employee Contract in Home Country
Return fee
Discriminatory distribution of wages & benefits
Discriminatory hiring policy

Forced labor

Uses involuntary labor

Freedom of
associationand the rightto collective
bargaining

Does not permit workers to organize

Humanetreatment

Does not prohibit physical punishment or coercion

Wages &
benefits

Does not pay overtime & incentives as required

Working
hours

Does not allow workers to refuse overtime

Dormitory &canteen

Does not maintain clear exit routes

Machinesafeguarding

Does not equip machinery with operation
safety devices and inspect on a regular basis

OccupationalsafetyDoes not maintain sufficient, clearly marked exits & routes

Penalizes workers’ efforts to organize

Does not prohibit psychological abuse or coercion
Does not provide understandable wage statement.
Does not provide 1 day off in 7
Does not provide individual mats or beds

Does not provide sufficient lighting

Note:
The data set displays the percentage of factories by region that had a specific Code of Vendor Conduct violation outstanding (irrespective of whenthe violation was identified) within the fiscal year 2012. The data represents factories producing Gap Inc. branded product that are part of ourmonitoring program and that were active during either the full or partial year. Partial year factories include those that began or stopped working
with Gap Inc. at some point during the fiscal year 2012.

72

HUMAN RIGHTS | DATA
2012 COVC violations by region (chart VI)
Complianceprinciple

Management
systemEnvironmental

Principle
subsection

Compliance detail

Handworkmonitoring

Does not maintain hand work supply chain details

Legal &
customerrequirements

Does not allow unrestricted access

EMS

Does not have an EMS

Environmental
emergency
plan

Does not have a notification procedure in case of
accidental discharge or environmental emergency

Hazardous
substances

Does not store and dispose of hazardous
materials appropriately.

EuropePersianGulf

28 Factories

1 Factory

Factory has not established a contractor monitoring system

Does not comply with child labor laws, including
hiring, wages, hours & conditions regulations

Child labor

Contractlaborregulations
Discrimination
Labor

Working
conditions

Employs worker below the legal min. age or 15,
whichever is higher
Employee Contract in Home Country
Return fee
Discriminatory distribution of wages & benefits
Discriminatory hiring policy

Forced labor

Uses involuntary labor

Freedom of
associationand the rightto collective
bargaining

Does not permit workers to organize

Humanetreatment

Does not prohibit physical punishment or coercion

Wages &
benefits

Does not pay overtime & incentives as required

Working
hours

Does not allow workers to refuse overtime

Dormitory &canteen

Does not maintain clear exit routes

Machinesafeguarding

Does not equip machinery with operation
safety devices and inspect on a regular basis

OccupationalsafetyDoes not maintain sufficient, clearly marked exits & routes

Penalizes workers’ efforts to organize

Does not prohibit psychological abuse or coercion
Does not provide understandable wage statement.
Does not provide 1 day off in 7
Does not provide individual mats or beds

Does not provide sufficient lighting

Note:
The data set displays the percentage of factories by region that had a specific Code of Vendor Conduct violation outstanding (irrespective of whenthe violation was identified) within the fiscal year 2012. The data represents factories producing Gap Inc. branded product that are part of ourmonitoring program and that were active during either the full or partial year. Partial year factories include those that began or stopped working
with Gap Inc. at some point during the fiscal year 2012.

73

GOALS AND PROGRESS | Supply chain | Overview

Environment
Full Section

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iquametum venisse modit amcommo lobore vendre modolum vendre essequa

Gap Inc. 2011/2012 Social and Environmental Responsibility Report74

ENVIRONMENT | OPERATING CONTEXT & STRATEGYKey Takeaways:• We believe the long-term viability of companies will depend on their ability to successfully operate in a world offinite natural resources.
• We are working to measure and reduce our environmental impacts to protect natural resources, lessen risk, spur
competitive advantage, and help drive innovation.
• We are strengthening our environmental strategy to focus more comprehensively on our supply chain to ensurethat our company thrives in a rapidly evolving business environment.

The landscape has changed
Our environmental initiatives are founded on the premise that we live in a world of constrained, finite natural
resources, and that the long-term viability of companies will depend on the ability to do more with less.
Climate change and water scarcity have become significant risks for many industries, and they are increasingly
affecting companies’ ability to operate. We recognize that in order to meet the environmental challenges of the 21st
century, innovations will be required across all sectors.
As we continue to expand into new and emerging markets, environmental issues are presenting both new risks andopportunities, making our focus on environmental impacts all the more critical. These issues are global in nature;climate change and water scarcity do not observe national borders. Nor do environmental issues exist in a vacuum—environmental sustainability and human rights are deeply intertwined. In order to meet these global and systemic
challenges, companies such as ours must enact programs that address the comprehensive and interconnectednature of sustainability issues.
Many trends are shaping the way companies mitigate risks and address opportunities:• Innovations in product development and operational efficiency.
• Changes in the availability of the resources needed for companies to make their products.
• Increased investor and consumer demand for sustainable practices and products.
• Measurement and awareness of environmental impacts that can help drive innovation and efficiency.
• Changes in the regulatory environment that require companies to mitigate their environmental impacts.
• Increasing transparency in the global marketplace, and the ability of technology to highlight impacts that were		 not previously clear.
At Gap Inc., our objective is to measure and reduce our impacts on the environment in order to protect natural
resources, lessen risk, spur competitive advantage, and help drive innovation. We seek to do so in a way that createsvalue for a wide range of stakeholders—from communities in the developing world to customers, employees,
shareholders, and others affected by our business. Over the last ten years, we have made companywide advances in
the following areas:• Supporting public policies that address the causes and effects of climate change.
• Measuring our environmental footprint in our owned and operated facilities, as well as our supply chain.

75

ENVIRONMENT | OPERATING CONTEXT & STRATEGY• Reducing our energy and water use, and working with our supplier partners to reduce their own.
• Reducing the waste we generate in our own operations, and diverting more of it from landfill.
• Advancing water quality and conservation initiatives in our supply chain.
• Collaborating with stakeholders and experts to make progress toward our goals.
While we are proud of the progress we have made through our portfolio of environmental initiatives, we feel a senseof urgency to do much more. Today’s environmental challenges demand collaboration and smart risk-taking, twocentral principles of our approach.
Our environmental strategy to date has stemmed from carefully analyzing our environmental challenges as a global
apparel retailer and taking action in the areas where we have the greatest opportunity and influence to createchange. For example, while we have more direct control over our store and facility construction and our product andpackaging design, we have less control over suppliers in our supply chain.
Our environmental strategy continues to be informed by the Gap Inc. Environmental Council, which is comprisedof senior executives across our company. Established in 2008, the Council acts as an internal think tank with themission to improve how our company uses resources and to reduce our environmental impacts. The Council meetsquarterly to:• Identify and prioritize opportunities with our brands to support our environmental initiatives.
• Engage and influence senior leadership to make decisions and execute on environmental priorities.
• Share best practices across our brands and functions, and inform and involve employees on priorities
		 and activities.
Our impact on the environment
Influence

Direct control

Weak/no control

InputsWater, pesticides,
fertilizers, dyes,
energyFuel, water,
chemicals

Fuel, corrugate,
plastic

Energy, wood,other contruction
materials

Energy, corrugate,
plastic

Energy, water,
dry cleaningmaterials

Process

Raw materials andtextile production

Garment production

Transportation of
goodsStore and facility
construction

Store operations(including packaging)Consumer use
and disposal

Outputs

Emissions, waste,
runoff (wastewater)

Emissions, waste,
wastewater

Emissions, waste,
wastewater

Emissions, waste

Emissions, waste

Emissions, waste

Now, with more advanced tools and experience to guide us, we are bolstering our environmental strategy to focus
more comprehensively on our supply chain and ensure that our company thrives in this evolving context.

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ENVIRONMENT | OPERATING CONTEXT & STRATEGY“Companies are now operating in a world where the climate is changing, the global population is
growing and the demands for energy, water and other natural resources are greater than ever before.
We need businesses to accelerate their actions to address these constraints. Gap Inc. is starting on thisjourney by acknowledging the interconnectedness of environmental, social and business sustainability,and how critical these issues are for its business success. The expectations are high for Gap Inc. todemonstrate results.” – Ceres
Our strategy starts with a new vision
Our evolving strategy is based on our new vision for social and environmental responsibility at Gap Inc. to “Raise
the bar by creating value for all.” This means we will seek to reduce our environmental impact and spur sustainable
innovation in a way that benefits a broad group of stakeholders, including workers, communities, consumers,
employees, and our company.
Our evolving environmental strategy leverages our strengths and requires partnership with stakeholders to address
the issues most important to our company and society. It allows us to more closely measure our environmental
impacts and the return on investment of our initiatives. We will continue to align our environmental initiatives withnew opportunities for our business, and to build on the steps we have taken so far.
We are also working to more deeply integrate our human rights programs and our environmental initiatives. For
example, we recognize that access to clean water is a fundamental human right as outlined in the United Nations’
Resolution 64/292, which recognizes “the human right to water and sanitation, and [acknowledges] that clean
drinking water and sanitation are essential to the realization of all human rights.” As we move forward, we will
be building on our longstanding commitment to human rights through our efforts to minimize and improve ourenvironmental impact.
As we evolve our environmental strategy, we continue to implement key initiatives to reduce our impacts on theenvironment. Please see the following sections of this report for more information on each:• Our Footprint: Learn how we measure and analyze our environmental footprint—both within our owned and		 operated facilities and across our supply chain.
• Energy and Climate: We have sought to reduce our GHG emissions since 2003, and are on our way to meeting		 our ambitious GHG reduction goal by 2015.
• Water: Water quality and usage are significant issues for Gap Inc., which is why we are partnering with expert
		 stakeholders such as Conservation International and the Natural Resource Defense Council to address them.
• Waste: Business units across Gap Inc. are working together to reduce waste in our headquarters offices, stores,		 and distribution centers.
• Product: We are a founding member of the Sustainable Apparel Coalition. Having piloted the Higg Index, we		 are now exploring how we can integrate sustainability standards, programs, and policies throughout the
		 design and production process.

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ENVIRONMENT | OUR FOOTPRINT
Key Takeaways:• Acting on our belief that what gets measured gets managed, we continue to create a detailed assessment of ourenvironmental footprint.
• We began our footprint assessment with our owned-and-operated facilities and are now expanding our analysis
to our supply chain, focusing on cut-and-sew vendors and fabric mills.
• The information we collect not only improves our own operations, but it also helps our strategic vendors identify
operational and technological improvements to increase efficiency, achieve cost savings, and develop moreenvironmentally responsible practices.
We firmly believe that what gets measured gets managed. Our overarching goal is to minimize environmental
impacts, which requires us to first understand them.
In 2009, we completed our first assessment to establish the baseline needed to set energy and waste reduction
targets for our owned and operated facilities. We began with facilities and stores in the U.S., which account for
approximately 70 percent of our company’s sales, and where we believed we could most quickly maximize our
impact. Based on this assessment of our energy and water use, and waste generated, we set an absolute goal toreduce greenhouse gas (GHG) emissions 20 percent in the U.S. by 2015 using a 2008 baseline.
Based on the more detailed footprint assessment we began in 2012, we are in the process of developing an overall
waste strategy and ambitious waste goal. This new goal will seek to improve our business practices and processes tominimize our waste production in our supply chain, our owned and operated facilities, and through the end of our
products’ lifecycle. For more information on our waste reduction efforts, please visit the Waste section of this report.
Gap Inc. Supply Chain

Environmental Footprint Scope

PHASE I
Retail Stores(sell clothes)Transportation(transport clothes)

PHASE II

Distribution Centers(send shipments to stores)

HQ and Studios(product planning/ design)

Factories(cut and sew fabric)

In 2011 and 2012, we went beyond assessing our owned and operated facilities to launch a project that establishes
a baseline measure within our supply chain. This pilot phase, which involved a group of key suppliers, sought toassess several key environmental categories at the cut-and-sew level of our supply chain, including energy use
and GHG emissions, water use and management, waste management, and environmental policies and reporting.
We examined the geographical location, size and operations of each facility together with the type and volume of
products each facility manufactures for our company.
We launched this pilot phase at the cut-and-sew level with two objectives: First, we sought to understand andquantify key environmental impacts along our supply chain so that we could help drive improvements. Second,
we wanted to gather information that would help our strategic vendors and factories identify operational andtechnological improvements they could implement to increase efficiency, achieve cost savings, and develop moreenvironmentally responsible operations and practices.
Overall, 234 factories in 21 countries participated in this environmental footprint assessment. We are now analyzing
the results and developing reduction and efficiency targets.

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ENVIRONMENT | OUR FOOTPRINT
Through our partnership with key stakeholders such as the Natural Resources Defense Council (NRDC), and throughour initial footprint assessments, we have also found cost-saving and innovation opportunities at the fabric milllevel of our supply chain. For more information on how we seek to improve the overall sustainability and efficiency ofstrategic fabric mills, dyehouses, and garment-finishing facilities in our supply chain, please visit the Water section ofthis report. We look forward to reporting on our progress in our next report.

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ENVIRONMENT | ENERGY AND CLIMATEKey Takeaways:• Climate change has the potential to negatively impact our business, and we believe that companies have an
ethical responsibility to address this societal challenge.
• We have been working to reduce our GHG emissions since 2003. Our current goal is to cut absolute emissions
20 percent by 2015 in the U.S., based on 2008 levels.
• Because a significant portion of the emissions related to our business come from operations throughout our
supply chain, we are committed to developing a reduction strategy that addresses this risk. In 2012, we held
Green Manufacturing Workshops for some of our key vendors.
We know that climate change has the potential to impact our business. In fact, we have likely already experienced it.
In 2010, cotton prices hit a nearly two-decade high, which put significant pressures on the apparel industry. Volatile
climate patterns in key cotton-producing regions played a role in these price increases, and these climate patterns
may have been caused, at least in part, by climate change. Droughts in some regions, combined with floods in others,
contributed to the instability in the cotton markets, and posed challenges for our supply chain.

In late 2012, we selected a new data provider to help us store, manage, and analyze our energy and GHGrelated data. This new enterprise data management system will help us systematically track all relevantenergy usage and emissions and allow us to better understand how we can continue to reduce our impact in this key area.
We believe that companies have an ethical responsibility to address climate change. For this reason, we have worked
to reduce our GHG emissions since 2003. Our first goal: to reduce emissions 11 percent per square foot between 2003
and 2008 in our U.S. operations. We exceeded that goal by achieving a 20 percent reduction per square foot duringthat time period. Following this achievement, we set a more aggressive goal to cut absolute emissions 20 percent
by 2015, based on a 2008 baseline. We continue to measure both our absolute and per-square-foot emissions (oremissions intensity) to gain the most accurate assessment of our impact. To ensure that we meet our goal, we havecreated a Sustainable Building and Operations Working Group to develop and execute our reduction plan. The groupis comprised of leaders from approximately 20 cross-functional departments at Gap Inc., including our Brands,
Construction, Real Estate, Operations, and Supply Chain.
Emissions source

Scope 1

Scope 2

Stationary
combustion

Mobilecombustion

Electricity

2010

24,661

722

495,078

2011

23,665439

2012

18,395502

Total scope
1&2

Scope 3

Total scope
1, 2 & 3

UpstreamTransportation*

Businesstravel**520,461

43,428

9,646

573,535

467,756

491,860

47,388

10,607549,855

429,865448,762

53,80814,195

516,765

We plan to report more comprehensively on our progress in 2015 (our target year) and are on track to achieve our goal
as a result of deep cooperation and collaboration with business partners throughout the company. For example,
working with our energy procurement and store design and operations teams, we have launched several pilot
projects to explore the potential for light-emitting diode (LED) technology to lessen our use of electricity in lighting
our stores—the single biggest users of electricity among our owned and operated facilities.
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ENVIRONMENT | ENERGY AND CLIMATE
In our distribution centers, we have also identified opportunities to reduce energy costs and emissions throughgreater energy efficiency. In 2012, we launched a partnership with one of our vendors, GE, to conduct energy andwaste “Treasure Hunts” in our distribution centers. We assembled a team of subject matter experts made up ofservice providers, engineers, energy consultants, motors, lighting and HVAC experts, and matched them with the
distribution center’s management, operations and maintenance staff. Over the course of two full days, the teamevaluated several opportunities to reduce energy usage and incorporate waste management best practices at our
distribution center in Fresno, California. Acting on our findings from this process, we have achieved an average
reduction in energy usage of 17 percent, and cost savings of close to 30 percent in the distribution center. Based on
this success, we recently completed an additional Treasure Hunt at our distribution center in Ohio and are expanding
this initiative to our distribution center in Gallatin, Tennessee.
In support of our broader environmental strategy, and our efforts to reduce GHG emissions as much as possible, we
are working with Ceres, one of our key stakeholders and an organization with which we have been engaged since2007. Ceres has been working to help us create and implement a Climate and Energy Policy to inform our company’s
energy procurement and our position with respect to climate change and its impact on our business. This policy isunder development, and we look forward to sharing more details in future reports.

Gap Inc. served on the City and County of San Francisco’s business committee to shape the city’s Climate
Action Plan. We supported the City and County of San Francisco’s greenhouse gas emissions reduction
strategy, working with a group of stakeholders to help reach San Francisco’s shared goals.
We also actively support efforts to pass smart, comprehensive climate and energy legislation. We are members of
Ceres’ Business for Innovative Climate and Energy Policy (BICEP) coalition, because we believe that diverse businessperspectives are vital to solving America’s climate and energy challenges. The coalition’s goal is to work directly withkey allies in the business community, and with members of Congress, to pass effective energy and climate change
legislation that is consistent with BICEP’s core principles. For more information on Ceres and BICEP, please visit www.
ceres.com/bicep.
Because a significant portion of our overall GHG emissions comes from operations throughout our supply chain,
we have a long-term commitment to develop a reduction strategy that addresses this risk. As we further reduce ourenergy footprint in our owned and operated facilities, we continue to look for ways to best extend those efforts to
our global operations and suppliers.
Since 2009, and as a part of our work with the Natural Resource Defense Council’s (NRDC) Responsible Sourcing
Initiative, we helped to identify and work with mills and dyehouses to implement several energy-saving measures.
In 2012, we began conducting Green Manufacturing Workshops for some of our key vendors. This training focusedon resource efficiency—primarily reducing our energy use and water consumption—and shared information on
environmental data management and environmental best practices. Workshops were conducted over the courseof 14 sessions held in Vietnam, Indonesia, India, Cambodia, and Sri Lanka. In total, 285 individuals were trained,
representing 139 vendors to date. We plan to continue rolling out these workshops in key sourcing countries, and arecommitted to enhancing and evolving the curriculum to ensure it covers the most important environmental issues toour suppliers, our stakeholders, and our company.

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ENVIRONMENT | WATER
Key Takeaways:• Water issues significantly impact people and communities around the world; they also pose risks to ourbusiness, and can affect our global cotton supply chain.
• We are currently conducting a water risk assessment in partnership with Conservation International, withthe ultimate goal of developing supplier engagement strategies for freshwater conservation.
• We launched our Water Quality Program in 2004, establishing requirements for all denim laundries that do
business with Gap Inc. More recent water initiatives include our Mill Engagement Program, which brings ourefforts deeper into our supply chain.
The related issues of water scarcity and water quality affect people and communities around the world in acute ways.
They can also pose real risks to our business. For example, both droughts and floods have increasingly interrupted
the global cotton supply, causing volatility in commodity markets with serious implications for apparel supply chainsand our business. In addition, increasing water shortages and/or restrictions on water consumption could affect ourability to operate in certain regions.
In 2011, Gap Inc. contributed to the development of Ceres’ Aqua Gauge: A Framework for 21st Century Water Risk
Management. Ceres’ report provides a broad overview of how competing freshwater demands and limits to supply
are beginning to affect corporate financial performance in a range of industrial sectors. This impressive tool helps
companies develop management systems to deal with the risks associated with water, and our Environmental Affairs
team is using it as we build out and implement our own water strategy.

The sustainability challenges we face, and the economic opportunities in meeting them, require profound changes in the way business does business. Water is core to economic and community vitality andis an issue that we often take for granted. Gap Inc. recognizes that the global water crises will require
collective action and is demonstrating leadership through aggressive commitments like the zero discharge of hazardous chemicals by 2020.
Addressing its impacts on water quality and scarcity worldwide will require Gap to innovate, increasetransparency and partner with its suppliers to improve their own water practices. Ceres looks forward toworking with Gap Inc. in the years ahead to find and implement solutions to this critical issue—driving
change across the apparel industry and beyond. —­ Ceres
We are working to address the issues where we have the most direct influence, focusing our efforts on denim
laundries and fabric mills. In denim laundries, garments are finished using large amounts of chemicals and water.
In fabric mills, the dyeing and finishing processes also use significant amounts of dyes, chemicals, water and energy.
We launched our Water Quality Program in 2004 to monitor denim laundries’ wastewater discharge, requiring alllaundries producing for Gap Inc. brands to adhere to a set of industry-leading guidelines on water quality. In 2010,
we standardized these guidelines as a requirement for doing business with our brands. All denim laundries
producing Gap Inc. branded denim are required to meet our water quality guidelines. We continue to measureprogress against strict industry guidelines, which include standards for overall water temperature, color gradations,and chemical makeup.
We are also implementing a Mill Engagement Program to raise the bar for social and environmental practices infabric mills in ways that will benefit the environment, communities, workers, fabric mills, and Gap Inc. This stage of82

ENVIRONMENT | WATER
the apparel manufacturing life-cycle represents significant opportunity for reduction of our products’environmental footprint.
The goals of the Mill Engagement Program are to:• Build a better understanding of the fabric mills in our supply chain. Because we currently do business directly
		 with cut-and-sew vendors rather than procuring fabric from mills, our relationships with mill suppliers		 are indirect.
• Create policies and incentives to ensure that mills adhere to common social and environmental
		 performance standards.
• Fully integrate the Mill Engagement Program into our standard supply chain practices.
Our Mill Engagement Program emerged from our cross-brand collaboration with BSR through the Apparel Mills &Sundries working group, and from our partnership with the Natural Resources Defense Council (NRDC) over the past
several years. In tandem with the NRDC, we seek to establish standards to improve the environmental performanceof dyeing and finishing facilities through reductions in water, energy, and chemical use. This effort is an extension of
the NRDC’s Responsible Sourcing Initiative, which we helped create in 2009.
To date, we have partnered with five mills in our
supply chain through our collaboration with the NRDC
and BSR’s Mills and Sundries Working Group, and areplanning to extend this partnership to approximately
15 more mills over the next three years. Over time,
we also plan to establish a Preferred Mill Program.
This program will require the implementation of
measurement technologies at key mills and monitor
investments in cleaner production technologies.

Our best practices are focused on being basic, widely applicable,
low-cost, often ignored, and with short payback periods

1. Leak detection, maintenance, housekeeping
Cost: Small

2. Reuse cooling water
Cost: Small

3. Reuse condensate
Cost: Moderate

4. Reuse process water
Cost: Small to Moderate

5. Recover heat from hot water rinses
Cost: Moderate—Highest

6. Pre-screen coal

In addition to our partnerships with the NRDC, we
have launched a global water risk and opportunity
assessment of our supply chain. We intend to develop
supplier engagement strategies that will provide
incentives and guidance for freshwater conservation.
Our immediate focus is to engage fabric mills anddenim laundries. These facilities play a critical role
within our supply chain and create its most significant
water impacts and dependencies.

Cost: Moderate

7. Fix/maintain steam traps
Cost: Small

8. Recover heat from smokestacks
Cost: Moderate

9. Insulate pipes/valves/flanges
Cost: Small

10. Optimize compressed air system

Cost: Small*The payback periods for our best practices are all less than a year
This list courtesty of NRDC

In 2013, we are partnering with Conservation International to conduct national-level assessments of freshwaterrisk for key sourcing countries. Understanding our exposure to global water risks, and identifying both risks andopportunities related to water, are crucial first steps in prioritizing and focusing our water strategy. Based on thefindings of the mapping exercises and supplier assessments we are doing through our work with the NRDC, we willdevelop a broader roadmap for engaging fabric mills and denim laundries across our supply chain.

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ENVIRONMENT | WATER

Case Study: Zero Discharge of Hazardous Chemicals (ZDHC), a 2020 Roadmap
We are working toward further reducing the use of hazardous chemicals in the manufacture of our products, and arecommitted to working toward zero discharge1 by 2020.
We believe that collaboration is an important path forward in order to work toward the zero discharge of hazardous
chemicals by 2020. While we believe it is important that we work toward these goals as a company, we recognize
the inherent limitations of any single company seeking to effect lasting change in the global apparel sector.
Based on this belief, we joined the Zero Discharge of Hazardous Chemicals (ZDHC) Programme. We see the need forthe collective action of brands and the factories that comprise their respective supply chains to drive substantive
and sustainable improvements. Collaborating with other global brands and retailers allows us to advocate together
for enhanced chemical management and cleaner production, with unified environmental requirements to suppliers
around the world.
We are also working with a broad array of committed ZDHC stakeholders including chemical suppliers andassociations, environmental and social NGOs, textile industry associations, academics, policy makers andmanufacturers. Our hope is that the shared responsibility of all key stakeholders in this important effort will provide
greater transparency, expedited chemical management efforts and the eventual elimination of hazardous chemical
discharge within the apparel sector.
As part of our participation in the ZDHC Programme, we have made the following commitments:• Eliminating Hazardous Chemicals: We support the goal of eliminating the industrial releases of hazardous
		 chemicals into the environment, as reflected in the Joint Roadmap2. We acknowledge and understand the		 seriousness of the problem of hazardous chemicals and commit with other member companies toward the		 goal of zero discharge of hazardous chemicals for all products across all pathways of release (discharges,
		 emissions and losses) in our supply chains (with a full life-cycle perspective) by 2020.
• Actionable Timeline: We agree to the content, actions and timelines outlined in the Joint Roadmap. We will		 work collaboratively through an active engagement with identified stakeholders.
• Policy Changes: We commit to support policy and wider systemic change in order to achieve this 2020 goal.
		 This commitment includes investment in industry and government collaborations in order to evolve the		 current state of science and technology and develop systemic changes across the industry.
• Transparency: We will drive toward innovative solutions for transparency in chemical management disclosure.
		 We believe that the elimination of hazardous chemicals needs not only collaboration and partnership with our		 industry peers, but also a holistic and integrated approach. We will apply value-chain as well as life-cycle		 thinking and innovation towards the development of integrated chemicals management. In order to achieve
		 our goal toward zero discharge of hazardous chemicals by 2020, mechanisms for disclosure and transparency
		 about the hazardous chemicals used in our global supply chains are important and necessary.
• Role of Vendors: To make this commitment a reality, Gap Inc. will continue to work with our approved vendors
1 Zero discharge means the elimination of all releases, via all pathways of release (i.e. discharges, emissions and losses, from our supply chains andour products). In light of the increasing sophistication of analytical tools and methods, references to “elimination” or “zero” must be understoodas “not above background concentration” rather than “not detectable.” Our commitment is to work toward the elimination of hazardous chemical
releases that can be measured by modern scientific methodology and instruments.
2 Available at: http://www.roadmaptozero.com/joint-roadmap.php

84

ENVIRONMENT | WATER
		 in phasing out hazardous chemicals within their facilities. We will accelerate the phase out of the highest		 priority hazardous chemicals.
Achievement of this ambitious 2020 goal requires the collective action of the apparel industry and other stakeholders.
We understand that this is a global undertaking that will take the commitment of many, and will require the sharingof best practices and the implementation of practical solutions. We believe that together, we can makesignificant improvements.

85

ENVIRONMENT | WASTE
Key Takeaways:• With more than 3,000 stores around the world, in addition to our office buildings and distribution centers, we
see enormous opportunity to reduce our environmental impact while generating cost savings.
• We are creating a waste strategy that will minimize our waste production both upstream and downstream.
• We are partnering with other retailers to help scale waste-reduction efforts, in part by facilitating recycling inmall store environments and introducing lease templates that support our environmental goals.
Our 2010 footprint assessment highlighted a significant degree of influence on the amount of waste in our owned
and operated facilities—and a large opportunity to reduce our impact on the environment while generating costsavings. With more than 3,000 stores around the world, in addition to our office buildings and distribution centers,
minimizing waste output is not a simple task, and it requires more than a singular approach.

We are headquartered in San Francisco, which has committed to be a zero-waste city by 2020. We aredoing our part to help achieve this target by greening all of our office buildings in the city. Most recently,
we “greened” our largest San Francisco building through a series of adjustments to the way our employees sort and dispose of their waste—resulting in a 75 percent diversion rate.
While we have a high degree of control over reducing waste in our office buildings and distribution centers, reducing
waste at the store level is often more challenging. As tenants in shopping malls and other retail locations, we often
have less influence over the key infrastructure and processes required for comprehensive waste reduction programs.
Some of our stores are located in areas that lack a basic municipal recycling infrastructure.
Despite these challenges, we are in the process of forging a comprehensive waste strategy and accompanying goalthat will minimize our waste production both upstream and downstream.
Key elements of our waste strategy will include:• Determining data collection capabilities and best practices within the retail industry.
• Collaborating with cross-functional partners within Gap Inc. and across our family of brands to address waste		 generation and encourage diversion.
• Identifying metrics to track progress and create systems and processes to collect data in alignment with our		 business partners.
• Partnering with vendors and stakeholders to implement our waste diversion programs.
• Creating an enterprise-wide waste management policy.
• Reporting publically on our progress.
We are also partnering with other retailers through industry groups such as the Retail Industry Leaders Association(RILA) and the Professional Retail Store Maintenance Association (PRSM) to facilitate recycling in mall store
environments and establish lease templates that support our environmental objectives. Through our work with RILA,
we have created and are working to finalize a “green lease,” which will enable our Real Estate teams to include terms
in our lease agreements to establish recycling infrastructure and energy efficiency priorities in our stores. With PRSM,
we have implemented demonstration projects in partnership with Sears stores to recycle plastic shipping material.
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ENVIRONMENT | WASTE
For more information about how we are working to identify waste reduction and efficiency opportunities inour distribution centers, please see the “Energy and Climate” section related to the Treasure Hunts underway inpartnership with GE.

87

ENVIRONMENT | PRODUCTKey Takeaways:• We are a founding member of the Sustainable Apparel Coalition, a network of brands and stakeholders creating
common metrics and approaches to reduce the social and environmental impacts of apparel and footwear.
• Gap brand piloted the Higg Index, a tool that enables footwear and apparel companies to evaluate material
types, products, facilities, and processes based on a range of environmental and product design choices.
• We have created a Sustainable Fiber Toolkit for designers and merchants across our brands to highlight theenvironmental and social impacts of natural, manufactured, and alternative fibers.
As a retail apparel company, we are committed above all to producing great products for our customers. We believethat creating socially and environmentally responsible products is central to this commitment. Simply put, we wantto provide our customers with products they feel good about wearing.
Whether we are addressing fire and building safety in Bangladesh, freedom of association issues in Cambodia,
seeking to ensure water quality at denim laundries in Mexico, or reducing water use in fabric mills and dyehouses in
China, these initiatives are all part of a broader effort to provide a product portfolio that is socially and environmentally responsible.
What constitutes a responsible product? For the apparel sector, one of the most critical next steps will be developing
an agreed-upon standard. As a founding member of the Sustainable Apparel Coalition (SAC), we have an extraordinary opportunity to help drive such progress.
The SAC seeks to identify common metrics and approaches to reduce the social and environmental impacts of apparel and footwear products. Like the SAC, we recognize that the environmental and social challenges in apparel
supply chains affect the entire industry, reflecting systemic issues that no one company can solve on its own. Working with other brands and key stakeholders within SAC, we are committed to improving the environmental and social
performance of the industry as a whole.

The Higg Index 1.0 is an indicator-based tool for footwear and apparel that enables companies toevaluate material types, products, facilities, and processes based on a range of environmental andproduct design choices. The Index asks practice-based, qualitative questions to gauge environmental
sustainability performance and drive behavior for improvement. It is based on the Outdoor Industry
Association’s Eco Index and Nike’s Apparel Environmental Design Tool, and has been enhanced throughrigorous pilot testing.
In 2012, Gap brand piloted the Higg Index, testing four high-volume products that we produce each season.
Our Social and Environmental Responsibility department led the pilot in close partnership with our Sourcing,Marketing, Transportation, and Product Integrity teams.

Another avenue by which we are advancing product sustainability is throughGap brand’s Wise Wash denim. Wise Wash refers to a manufacturing processthat uses low-impact manufacturing techniques, consuming less energy andwater than conventional wet processing. On average, Wise Wash jeans use
25 percent less water, electricity, and chemicals. We launched this line of denim
in Fall 2012 with eight men’s and eight women’s washes, and are currently
evaluating how we can most effectively scale this program.
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ENVIRONMENT | PRODUCTUsing the three core modules of the Higg Index—Brand, Product, and Facility—this initiative helped us better understand where we should focus our efforts at the design, manufacturing, packaging, and end-of-life stages of our
supply chain. For example, we learned that initiatives such as Wise Wash, which promotes water and energy savings,
can significantly improve our score if they are scaled across all products in a given category. The Facility module of the
Higg Index helped us benchmark sustainability practices across facilities, though activities at this stage, we learned,
have little impact on a product’s score. And finally, optimizing modes of transportation away from air freight and toward less impactful methods of transport such as rail can also have a positive impact on our Higg score. While manyof the insights gained may seem like common sense, such a systematic analysis provides an essential method tomeasure, prioritize and assess a product’s environmental impact in a way that can be consistent across our industry.
As a result, we are exploring a number of next steps, including efforts to:• Integrate sustainability standards, programs, and policies throughout the design process.
• Partner more closely with suppliers in order to report more accurately on manufacturing processes.
• Engage in and communicate select initiatives to consumers over the long term.
We are also working with the SAC to help establish key performance indicators for measuring the social impacts ofclothing. Based on our experience in seeking to improve working conditions in our supply chain, we know how difficult—and essential—such measurement can be. We look forward to launching the social and labor indicators as partof the Higg Index in 2013.
As a result of our Higg Index pilot, we recognized the need for and have created a Sustainable Fiber Toolkit for designers and production teams across our family of brands. Because sustainable fiber selection and processing can be a
confusing process of navigation, interpretation and trade-offs, we have sought to analyze and understand the environmental and social impacts of each fiber that our brands use. The Sustainable Fiber Toolkit is designed to offer Gap
Inc. brands an objective overview of sustainable fiber and processing information and ideas while ultimately empowering them to define what designing for sustainability means to them and their customers.
Our Sustainable Fiber Toolkit provides:• An overview of the environmental and social impacts of natural, manufactured, and alternative fibers.
• An overview of the environmental and social impacts of different manufacturing stages, including dyeing,		 printing, bleaching, and garment washing.
• Information on sustainable fiber options and processes that our designers may have not yet explored.
• Suggestions on how to source fabrics to optimize the sustainability benefits of each fiber, while also providing
		 information on sustainability opportunities at each stage of an apparel product’s lifecycle.
• Innovative scenarios and ideas related to sustainable design and manufacturing that are intended to inspire		 individuals to develop ideas of their own.
We plan to leverage the Toolkit to help drive awareness and education throughout the organization as a useful way
to serve our company’s environmental goals, our brands’ design needs, and our customers’ preferences.

89

ENVIRONMENT | GOALS

Current environment goals
Estimatedcompletion dateComplete supply chain water mapping and create a supply chain water strategy.

2014

Reduce absolute GHG emissions 20% by 2015.

2015

Partner with 20 key fabric mill suppliers to establish social and environmental responsibility standards andimprove performance.

2015

Work towards zero discharge of hazardous chemicals in our supply chain by 2020, through our partnership in the
ZDHC 2020 Roadmap.

2020*Due to current changes in how we are collecting environmental data, and changes in the service providers we work with, our previous goals on
environmental data will be revised, with new, related goals being announced in our next report.

Completed environment goals
Completeddate
Continue to pilot waste management and recycling initiatives at the store level.

2012

Complete supply chain footprint assessment.

2012

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GOALS AND PROGRESS | Supply chain | Overview

Environment
Data

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acidui blaortio eu feu feuguero odoloreetue vulluptatem veliquisisl iurem digna faccum zzriurem velit vulla commy
nim quam dio od magna feu facing eu facil utpat. Ibh et, quatue minim vulla feuiscipit wisi.

La faccummolor augiam vel ut velit irit at, quametue moloreriurem dit autpate tuerciduis et, si ea augiat ullametnos doleniamet volorer iuscidunt nos autat lut ulluptate magniam, conse consed te feum qui eriusto del ent il illutet
volenim dunt alit nullamconsed min vendipsum niat.
It nulla faccum nummodo lorper sustrud magna conse tem quat. Ut alis num et nonsent nonsecte mod magniat,
quisi exer ing etueril dit del eugiam nosto commodo ero dipit nis digna adip ex exerosto estrud ea facil exercil
iquametum venisse modit amcommo lobore vendre modolum vendre essequa

Gap Inc. 2011/2012 Social and Environmental Responsibility Report91

ENVIRONMENT | DATA
2006 – 2012 U.S. Energy consumption50

KWH/SQFT

40

30

30.08

28.29

27.48

26.01

25.60

25.05
21.98

20

10

0

2006

2007

2009

2008

Calendar year

92

2010

2011

2012

ENVIRONMENT | DATA
U.S. Energy consumption by source

Indirect source(Electricity)
76.6%This graph refers to our energy consumption by sourcein 2008 – the base year by which we calculated ourEnvironmental Footprint. “Other Indirect (Mobile)”sources refer to transportation of products from ourdistribution centers to stores via an outsourced
network of poolers and haulers, as well as energy
consumed by the company’s jet (which represents
approximately 2% of this category, and 0.3% of ouroverall energy consumption)

Other indirect(Mobile)13.2%
Direct source(Stationary)
10.2%

93

ENVIRONMENT | DATA
2010 - 2012 U.S. Energy consumption by operation
5
4,252,329

4,077,099

4,048,480

2,990,825 (70%)

2,879,107 (70%)

2,746,277 (68%)

592,728 (14%)

639,854 (15%)

703,390 (17%)

499,912 (12%)

455,448(11%)

426,780(11%)

158,783 (4%)
10,081 (0.2%)

152,484 (4%)
6,009 (0.1%)

165,159 (4%)
6,874(0.2%)

2010

2011

2012

4

All values in MMBtu and %

3

2

1

0

Calendar year
Corporate jet

Outbound logistics

Headquarters

StoresDistribution centers

94

ENVIRONMENT | DATA
2010 - 2012 GHG emissions
Emissions source

Scope 1

Scope 2

Stationary
combustion

Mobilecombustion

Electricity

2010

24,661

722

495,078

2011

23,665439

2012

18,395502

Total scope
1&2

Scope 3

Total scope
1, 2 & 3

UpstreamTransportation*

Businesstravel**520,461

43,428

9,646

573,535

467,756

491,860

47,388

10,607549,855

429,865448,762

53,80814,195

516,765

95

ENVIRONMENT | DATA
2004 - 2012 Water Quality Program
Calendar year

# of Denim
laundries

Pass

Fail

Pilot (2004)

18

14

4

Phase I (2005)

41

22

19

Phase II (2006)

90

44

46

Phase III (2007)

110

69

41

Phase IV (2008)

90

71

19

2009

109

100

9

2010

104

94

10

2011

93

77

16

2012

72

65

7

96

GOALS AND PROGRESS | Supply chain | Overview

Employees
Full Section

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nim nostisi.

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Ustio dolor at vullutat, consed enit venit irit nullummy nos aut etum dui blaore exeros autet augiam, conulputat
praesed mincin er sit lum do consecte consequipsum dolendit volorper sissequ ismodipis ad tem ing eu feu facip
enisse minit praestrud tat.

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tincilit at, quat vendre te molorti sciduis acing ex elenibh er sum ipsum vullaortio core veliqui pisiscil utatum
doloreros adio elesse dolortisi erat. Ut elenisl ute tem nonsed ent velit vullam in ut wisse esto doloborer sustrud et
acidui blaortio eu feu feuguero odoloreetue vulluptatem veliquisisl iurem digna faccum zzriurem velit vulla commy
nim quam dio od magna feu facing eu facil utpat. Ibh et, quatue minim vulla feuiscipit wisi.

La faccummolor augiam vel ut velit irit at, quametue moloreriurem dit autpate tuerciduis et, si ea augiat ullametnos doleniamet volorer iuscidunt nos autat lut ulluptate magniam, conse consed te feum qui eriusto del ent il illutet
volenim dunt alit nullamconsed min vendipsum niat.
It nulla faccum nummodo lorper sustrud magna conse tem quat. Ut alis num et nonsent nonsecte mod magniat,
quisi exer ing etueril dit del eugiam nosto commodo ero dipit nis digna adip ex exerosto estrud ea facil exercil
iquametum venisse modit amcommo lobore vendre modolum vendre essequa

Gap Inc. 2011/2012 Social and Environmental Responsibility Report
97

EMPLOYEES | OPERATING CONTEXT & STRATEGYKey Takeaways:• Achieving our company’s mission to be the world’s favorite for American style depends on our ability
to attract, develop, and retain the best talent in our sector.
• Many of our employees joined Gap Inc. and choose to stay here because of our company’s promise to“Do more than sell clothes.”
While our employees are united by a shared mission to be the world’s favorite for American style, what guides andinspires us is a promise to do more than sell clothes. Don and Doris Fisher founded the company on a commitment
to service and responsibility that remains core to attracting and retaining the best talent in our sector today. This
commitment permeates virtually all aspects of our company­—from our efforts to improve working conditions in ourapparel supply chain to supporting volunteerism, helping our employees make an impact in the communities where
they live and work.
Our company culture is a reflection of the values that Don and Doris have instilled in the company since its founding
in 1969.
Think: customers first. We consider the needs and value the diversity 		of thought, experience, and perspectives among our customers.
Inspire: creativity. We open ourselves to new ideas, tapping into our
broad set of perspectives.
Do: what’s right. We treat every customer, supplier, and employee withrespect and act with integrity.
Deliver: results. We strive to provide a dynamic and inclusive work
environment where employees thrive and generate top performance.

In addition to our values and company culture, our deep commitment to fostering a diverse and inclusive
environment, and developing and recognizing the accomplishments of our employees are what helps to keep our
employees engaged and motivated. Each of the following sections outlines the unique ways in which we seek todo so:• Diversity and Inclusion: To succeed in the global marketplace, we continue to develop a diverse employee base		 and an inclusive work environment.
• Career Development: We invest in our employees to help them realize their professional goals and lead		 successful lives.
• Recognition: Retaining the best talent in our sector comes from acknowledging our employees for their		 innovation, integrity, and responsibility.
• Benefits and Rewards: We provide our employees with a competitive combination of compensation, benefits,		 and rewards­—all important to attracting and retaining the best talent.

98

EMPLOYEES | DIVERSITY AND INCLUSION
Key Takeaways:• Our diverse and inclusive employee base helps foster a creative culture, drive innovation, and enable us to be
more effective everywhere we do business around the world.
• We support a number of innovative programs that help incorporate diversity at all levels of our company, andwe are always looking for new and better ways to build on our progress.
At Gap Inc., employee diversity is integral to achieving our company’s global growth objectives. Collectively, ourbrands have a presence in more than 90 countries, and our diverse employee base enables us to be more innovativeand effective in serving our customers around the world. Creating this environment requires everything from having
the right policies in place, to implementing company-wide programs, to supporting employee driven initiatives.
Embracing diversity requires us to provide an open, inclusive, and respectful work environment, which comes to life
through our Code of Business Conduct (COBC), including various employee policies
and initiatives.
Our Code of Business Conduct sets forth the company’s expectation that our employees do what’s
right, acting with integrity in all they do. It is our foundation for promoting a responsible andethical work environment, and helps ensure that our employees act in ways that reflect ourcompany’s culture of integrity and values.
Our comprehensive non-discrimination policy, known as “Zero means Zero,” helps ensure that ouremployees are able to do their best work in a productive, professional environment.
We also promote diversity at Gap Inc. through company-driven initiatives such as our ASCEND program, which
recognizes diverse store leaders who demonstrate the capability, desire, and potential for career advancement.
The program features a variety of Gap Inc.’s most successful leadership development trainings. Through ASCEND,
we also provide mentoring programs that help employees to succeed and the company to build a pipeline ofdiverse leadership.
Many of our employees want to take their own initiative to embrace diversity and inclusion, and we believe in giving
them the opportunity. Our Employee Resource Groups help foster a work environment where our employees andcustomers are treated with respect and cultural sensitivity. These groups are open to all employees and united by
a common philosophy that diversity brings value to Gap Inc. Our four groups include:• African American Networking Group (AANG): Established in 2000, AANG’s mission is to establish
		 and maintain a network of African American employees that fosters professional development at		 all levels. The group also focuses on raising cultural awareness at Gap Inc. and volunteering in		 the community.
• Asians Supporting Inclusion and Awareness (ASIA): Established in 2011, ASIA’s mission is to create		 awareness and make an impact on the Asian/Pacific Islander community at Gap Inc. by providing
		 an environment that gives our employees the opportunity for networking, professional development,
		 community outreach, and sharing different cultures.
• Gap Gay Employees, Allies & Resources (GEAR): Established in 2006, GEAR’s mission is to create an		 inclusive and supportive environment at Gap Inc. for Lesbian, Gay, Bisexual, Transgender, Queer,		 and Ally (LGBTQA) employees while embodying Gap Inc.’s values. Our aim is to help Gap Inc. become		 the employer and retailer of choice for the LGBTQA community.
99

EMPLOYEES | DIVERSITY AND INCLUSION• Honoring Our Latino/Hispanic Ancestry (HOLA): Established in 2010, HOLA’s mission is to empower
		 our Latino/Hispanic employees to drive business and make a positive impact in our community.
		 We support our members by creating meaningful networking opportunities and identifying creative		 ways to grow our business while celebrating our shared heritage.

For eight consecutive years, Gap Inc. has been recognized for supporting equality for LGBT employees,
receiving a 100 percent rating on the Human Rights Campaign’s Equality Index.

Our North American employees recently gave us promising feedback on our efforts to foster a diverse and inclusive
work environment. According to our August 2012 employee opinion survey, 82 percent of employees believe thateveryone has a fair chance to have a successful career at Gap Inc., regardless of their differences or background,compared to an industry average of 65 percent.
As we continue to expand globally, we will ensure that our diversity strategies address global issues and those specific to the countries where we operate. In some instances, this may mean expanding existing initiatives; in otherinstances, we will need to explore and address particular diversity and inclusion challenges that may differ fromthose we face in in North America.
We’re already taking steps to do so. For example, our Global Supply Chain team is committed to raising culturalawareness among our sourcing offices in Hong Kong, Seoul, and Delhi. These offices collaborate across geographies
to create product for our brands. The Global Supply Chain team has held workshops to increase awareness and understanding of different cultures and communication styles. Through these types of development opportunities, weseek to promote a global, diverse, inclusive, and effective workplace.

Case Study: Results Only Work Environment (ROWE)
In 2011–­12, several business units within Gap Inc. and at Gap brand adopted Results Only Work Environment (ROWE).
ROWE is a corporate culture initiative designed to improve employee productivity, accountability, and engagement.
It respects the value of our diverse employee base by empowering people to work in whatever way they are mostproductive. In a ROWE, the emphasis shifts from how work is done to the results delivered. Employees are held
accountable for their specific piece of the business.
Several departments have made a successful transition to ROWE, empowering their teams and helping employees
do their best work. We believe that ROWE will make teams more accountable for delivering results and empower employees to eliminate work that’s not productive. As a positive byproduct of a ROWE, employees have more flexibility
in their schedule, as long as their work gets done. We have had remarkable early success with this program and willcontinue to evaluate how we can expand it to help our employees thrive.

100

EMPLOYEES | CAREER DEVELOPMENT
Key Takeaways:• We attract and keep exceptional talent by helping our employees realize their professional goals while finding
personal fulfillment in their work.
• We use a 70–20–10 model of career development that offers our employees a diverse platform for growth.
Career development at Gap Inc. begins with ensuring that our employees feel connected to our shared purpose andvalues and that they understand the role they play in helping Gap Inc. succeed. We offer employees a variety of experiences to grow personally and professionally.
Our approach to career development is based on a 70–20–10 model: Employees gain 70 percent of their learningand development through on-the-job experience, 20 percent through mentorships and collaboration, and 10 percent
through courses and formal training.
The 70 percent on-the-job training may involve everything from daily activities to “stretch” assignments that place
employees in situations outside their current realm of expertise and responsibility. As we continue to expand globally, we are committed to giving our employees even more opportunities to take on new roles and international
assignments. The 20 percent portion may involve formal mentorships and coaching sessions, or collaborative projects
that involve in-depth feedback from team partners. We encourage all of our employees to seek out mentors and workwith them on a regular basis to pursue thoughtful career plans for their future with Gap Inc. Formal courses andtraining make up the other 10 percent of career development. For example, through our partnership with eCornell,
employees can take interactive online courses from Cornell University in the areas of Management, Leadership,
Financial Management, and Human Resources.
In addition to our 70–20–10 model, we offer a number of inspiring programs that help our employees achieve theirfull potential. Some examples of our training and career development initiatives include:• Mindspark is a three-day, multi-sensory experience wherein 30–40 of some of our best and brightest
		 employees work to develop innovative solutions for our most important business challenges. The creativity of		 participants is “sparked” by a variety of external stimuli such as thought leaders, industry experts, entertainers		 and designers who expand our spectrum of thinking. Mindspark builds innovation skills that can be used every
		 day, while yielding new ideas that are relevant to our business.
• QUEST is a 12-month leadership program that provides focused, accelerated development in the areas of		 leadership, change, innovation, global mindset, business performance, strategic thinking, decision making
		 and partnerships. Participants, with the full engagement of their leaders, apply lessons learned to their jobs
		 through structured individual projects and pay it forward activities.
• Adaptive Leadership is a four-day development experience for select employees at Gap Inc. designed to build
		 strategic capabilities needed individually and as an organization to help us achieve Gap’s vision to become the		 world’s favorite for American style, and develop strategies to win through our global brands structure.
• Our Field Apprentice Program brings field employees into our headquarters for five-week summer
		 assignments. We encourage participants to share their perspectives with corporate teams. The program is		 proof that increasing communication between field and headquarters makes us more effective in achieving
		 our business goals.
• Leading Leaders @Gap is a six-month development program that helps leaders of managers inspire people at		 all levels of the company to achieve exceptional results.

101

EMPLOYEES | CAREER DEVELOPMENT• Gap Inc.’s Retail Academy offers employees a variety of development and training options, including e-learning,		 self-studies, classroom sessions, rotational training, business simulations, and multi-media presentations.
		 All academy offerings are designed to help our employees grow, develop, and better understand how our retail		 business operates.
Gap Inc. employees are proud to be part of a company that places a high value on social and environmental responsibility; their words and actions tell us so. For many, these values enter into their choice to come and build a career
here. We inform and engage them on how those initiatives relate to what they do­—whether they work in Production,
Store Design, or Inventory Management. We provide an orientation for new hires that introduces them to the socialand environmental responsibility programs relevant to their roles and responsibilities.

102

EMPLOYEES | RECOGNITION
Key Takeaways:• We recognize our employees for their exceptional work, and seek to ensure that outstanding contributions
are recognized company-wide.
• The Fisher Awards, named in honor of Gap Inc.’s founders, recognize employees who exemplify Gap Inc.’smost important values.
It’s our job to make sure that our employees’ good work is highlighted and rewarded. Gratitude and support are
expressed openly and often­—through informal and formal programs and practices including monetary awards, gifts,
special recognition cards, emails, acknowledgement in large meetings, or just a few kind words in person.
We have several companywide recognition programs, including Applause and the Fisher Award:• Applause is our peer-based online recognition program. It allows employees to create and send personalized		 recognition cards to team members for amazing performance. In 2011–12, our employees shared over 255,000
		 cards, highlighting how team members have represented and upheld our company’s cultural pillars­—Inspire:		 creativity; Think: customers first; Do: what’s right; and Deliver: results.
• The annual Fisher Award recognizes employees who exemplify our company’s most important values. Named		 for Gap Inc. founders Don and Doris Fisher, the award honors employees around the world who best fulfill their		 inspiring legacy. Employees may nominate teammates or themselves for living our founding values in the		 realms of Innovation, Integrity, Community, and Store Excellence.

Case Study: Profiles of 2011 & 2012 Fisher Award Winners
Chris Nicklo: Fisher Award Winner for Innovation
Location: San Francisco
Gap Inc. has always thrived on innovation. Doris and Don Fisher made sure it was part of the business foundationfrom day one. And now employees like Chris carry that torch every day.
Chris, VP of Marketing for Banana Republic, and members of his team were honored as the 2012 Fisher Award Winners for Innovation for fostering the brand’s partnership with Virgin America. The winning team included Alejandro
Alvarez (Director of Marketing), Charlotte Murphy (Associate Marketing Manager), Amanda Garrett (Manager of
Public Relations), Jen Matic (Senior Director of Creative Marketing), Brent Kawahara (Senior Director of Product Management), Nicole Wiesmann (Senior Director of Design), Jennifer Lane (Designer), Josue Asselin (Senior Designer), andRozh Roux (Senior Director of Tech Design/Patterns).
Working collectively across the brand in San Francisco and New York via the Marketing, Public Relations, Design, andProduction functions, the team created a number of original successes, including the Holiday Gift Baggage giveaway
in 2011, the in-flight ‘Mad Men’ fashion show, and the full redesign of Virgin’s uniforms in 2012.

Fisher Award Winners for Store Excellence: Masaya Kurashima and Ai Fukaya
Location: Japan
Doris and Don’s focus on the customer experience has always been paramount­—which is why, every year, Gap Inc.
recognizes employees for store excellence.
103

EMPLOYEES | RECOGNITION
In 2012, Masaya, a district manager for Old Navy, and Ai, a general manager for Old Navy, received one of thoseawards for being instrumental in launching Old Navy’s first store outside North America in Odaiba, Japan. To introduce the new brand to Japan, they ran a pop-up store for three months, engaged in daily efforts to help customers
become familiar with the brand, and searched for staff that embodied the brand’s fun, family-friendly culture.
Through months of hard work and dedication, they helped the store deliver the best sales across all of Gap Inc. during its first six days of opening.

Fisher Award Winner for Community: Karen Barbarics
Location: Pennsylvania
Don and Doris Fisher have always made it a priority for Gap Inc. to be more than just a company. Their priority has
inspired and supported employees like Karen to make a difference in communities around the globe.
In 2012, Karen, a general manager for Gap, earned the Fisher Award for Community for raising awareness about autism. When her son was diagnosed with the disorder in 2005, she had no resources to help him. After a quick Internet search, she discovered the organization Autism Speaks and decided to get involved. She founded the Lehigh Valley
Walk in her community with an emphasis on educating others about autism. The success of the walk, which has
raised more than $3 million for Autism Speaks, has made it an annual event with about 10,000 participants each year.
Karen is also responsible for her in-store “Closing the GAP on Autism” campaign, which was held in 160 stores in thefall of 2011.

Fisher Award Winner for Integrity: Marla Debbaudt
Location: Michigan
Don and Doris Fisher grew a company on their belief that integrity shows­—and Marla embodies that belief throughher work as Director of Talent Management Operations. She earned the 2011 Fisher Award Winner for Integrity inrecognition for carrying on one of the company’s core values­—”Do: what’s right.”
Marla’s commitment to integrity came to light when she spoke up about a vendor conduct issue. Throughout her
career, she has been a champion of implementing the Principles of Integrity courses, online trainings designed tohelp employees meet legal requirements and do what’s right every day.

104

EMPLOYEES | BENEFITS AND REWARDS
Key Takeaways:• We take a holistic view of compensation, benefits, and rewards to help our employees lead thriving,
successful lives.
• We seek to offer qualifying employees a range of benefits including health insurance, life and accident
insurance, disability insurance, retirement savings plans, employee stock purchase plans, paid vacation andholidays, product discounts, and transportation allowances.
We believe in providing our employees with the resources they need to lead thriving, successful lives. That takes morethan a paycheck. It requires that we take a holistic view of compensation, benefits, and rewards to meet our employees where they are, based on their needs. Recognizing the full spectrum and evolving nature of those needs is morecrucial than ever to retaining the best talent in our sector.
Our global approach to benefits aligns employee needs with options available in each country to ensure that we areproviding a comprehensive benefits package. Specific benefits vary by employees and region, but we seek to offer
qualifying employees health insurance, life and accident insurance, disability insurance, retirement savings plans,
employee stock purchase plans, paid vacation and holidays, product discounts, and transportation allowances.
We also aim to provide our employees with the resources to make informed decisions about meeting their personalneeds and those of their family members. For example, in the United States, we work with a team of health careadvocates who help employees select the benefits that are best for them, ensure that claims are correctly processed,
and navigate care options.
We believe that providing access to affordable health care benefits is vital to recruiting and retaining a thriving
employee base. We offer competitive benefits including medical, dental, and vision to all employees classified as fulltime, and we extend those benefits to their spouses and dependents. In several countries, the benefits also apply toqualifying same-sex domestic partners. In 2012, comprehensive transgender benefits became part of our health planin the United States. We also provide wellness clinics, on-site flu shots and biometric screenings, flexible and affordable weight loss programs, and subsidized yoga, Tai Chi, boot camps, and negotiated rates for gym memberships insome U.S. locations.
In several countries, our health care benefits also apply to qualifying same-sex domestic partners, extending frompolicies we have had in place for a number of years to support LGBT employees. In 2013 we saw the Supreme Courtof the United States strike down the federal Defense of Marriage Act as unconstitutional. The Court’s ruling now allows our married LGBT employees to enjoy equal rights to benefits and obligations under federal law that are basedon one’s marital status. In 2012, we signed an amicus brief with the Ninth Circuit Court of Appeals, challenging thefederal defense of DOMA, alongside other leading companies such as eBay, Google, Microsoft, and Starbucks.
For part-time store employees in the U.S., we offer National Health Access (NHA), which provides a variety of healthcare options ranging from discounts on medical and health costs to major medical insurance. We also offer Retiree
Health Access to our retired employees in the U.S.

Our Gap Inc.-sponsored health plans in the United States met many requirements of the Patient
Protection and Affordable Care Act (PPACA) before it was passed in 2012. For many years, we haveoffered health care plans with no pre-existing condition limitations, no lifetime maximums, andfree preventive care.

105

EMPLOYEES | BENEFITS AND REWARDS
We provide competitive financial benefits, which play an essential role in attracting, rewarding, and retaining thetalented people who want to build long-term careers at Gap Inc. In the United States, our GapShare 401(k) Plan offers
dollar-for-dollar company match contributions of up to 4 percent of base pay, with 100 percent immediate vesting for
all employees who are over 21 and have worked at least 1,000 hours of service.
We also provide support to our employees in the United States when significant emergencies or natural disasters
strike. Through our Individual Disaster Relief Support Plan, we offer continued pay, allowances for severe homedamage, clothing, food, temporary housing, and/or cash to employees facing emergencies or crises.

Case Study: Gap Inc.’s Japan Disaster Relief Efforts
Our employees were deeply affected by the devastating earthquake and tsunami that occurred in Japan in
March 2011. Following the disaster, we moved quickly to identify how Gap Inc. could help:• Gap Foundation made a $200,000 grant to Global Giving to provide emergency and disaster support and		 services, including food, water, medical supplies, and other immediate needs.
• Gap Inc. collected and matched donations from our more than 135,000 employees worldwide through an		 online system.
• Gap Inc. donated $1.1 million (USD) of clothing in Iwate, Miyagi and Sendai.  
• Gap brand North America created exclusively designed T-shirts to sell online and in 12 U.S. flagship stores, with		 profits directed to relief efforts.
• In Japan, we provided each Gap store with a donation box at the register, and all customer donations were		 given to the Red Cross in Japan.

Case Study: Contributing to the rebuilding effort after Hurricane Sandy
In late October 2012, Hurricane Sandy ravaged the Caribbean, Mid-Atlantic, and Northeastern United States, leaving
widespread damage in its wake. The storm’s impact on everyday life was profound, and for many of us at Gap Inc., it
was deeply personal.
During the storm, our top priority was ensuring that our employees were safe and accounted for. Our company has
guidelines in place to provide relief and financial support to employees who have been affected by any disaster.
Depending on the severity of impact, our support ranges from cash for basic necessities to short-term hotel stays for
employees whose homes have been destroyed and/or are unlivable.
Our second priority was to identify how we could most effectively contribute to the rebuilding process. Immediately
after the storm passed, Gap Inc. committed to donating more than $1 million to help the victims of the storm. We
started by asking the American Red Cross (ARC) how we could support its efforts. ARC sent us a list of needed items,
and our first delivery of clothing reached New Jersey four days after Sandy hit. In total, we gave new clothing valued
at $315,000, which was distributed by the Salvation Army and the Red Cross in the communities hardest hit by thehurricane. We subsequently donated an additional $400,000 in cash to support the Red Cross recovery work.

106

EMPLOYEES | BENEFITS AND REWARDS
Our commitment to assisting in the rebuilding effort continues. Gap Foundation is leveraging its longstanding
partnership with Habitat for Humanity, whose affiliates in New York and New Jersey have identified families living
at or below the poverty level and whose homes were severely damaged. We have committed to providing Habitatfor Humanity with $350,000 to help develop and implement comprehensive neighborhood revitalization strategies,
prioritizing homeowners with the greatest vulnerability and need.
We are engaging our employees to help see this project through, and we are exploring opportunities for Gap Inc.
employees to assist with home construction as volunteers in the regions where our grant is focused.

107

EMPLOYEES | GOALS

Current employee goals
Estimatedcompletion dateContinue to build a globally effective, more agile organization by increasing the development of global leadershipskills, and the enhanced utilization of metrics to manage talent and evaluate HR programs and processes.

2014

Become a more globally effective organization by moving to a global brands structure and providing leaders theopportunity to develop and grow through an array of international assignments by 2014.

2014

Maintain and assess high levels of employee engagement through a more effective and frequent monitoringprocess to collect employee feedback by 2014.

2014

Completed employee goals
Completeddate
Continue to build a globally effective organization through succession planning and career growth, with a majorityof director and above positions filled by internal talent and an increase in international development assignments.

2012

Continue progress on our diversity and inclusion efforts with a focus on workforce diversity through broad-based
training, targeted recruiting, mentorship programs and expanded Employee Resource Groups, as well as outreachto diverse customer segments.

2012

Sustain strong employee engagement through increased frequency and speed of obtaining and responding toemployee feedback.

2012

108

GOALS AND PROGRESS | Supply chain | Overview

Employees
Data

Put in hendrero consequatisi et aliquam, sum nis nonsequissit ulla con ut irilis acil eugait, sum doluptatummy nis
nim nostisi.

Igna at ea ad min voluptat wismodo luptat.
Ustio dolor at vullutat, consed enit venit irit nullummy nos aut etum dui blaore exeros autet augiam, conulputat
praesed mincin er sit lum do consecte consequipsum dolendit volorper sissequ ismodipis ad tem ing eu feu facip
enisse minit praestrud tat.

Wis nismodip ex eraesto enibh ese molore modionulla feugait, quat, conse molore magna autem doluptat. Dui
tincilit at, quat vendre te molorti sciduis acing ex elenibh er sum ipsum vullaortio core veliqui pisiscil utatum
doloreros adio elesse dolortisi erat. Ut elenisl ute tem nonsed ent velit vullam in ut wisse esto doloborer sustrud et
acidui blaortio eu feu feuguero odoloreetue vulluptatem veliquisisl iurem digna faccum zzriurem velit vulla commy
nim quam dio od magna feu facing eu facil utpat. Ibh et, quatue minim vulla feuiscipit wisi.

La faccummolor augiam vel ut velit irit at, quametue moloreriurem dit autpate tuerciduis et, si ea augiat ullametnos doleniamet volorer iuscidunt nos autat lut ulluptate magniam, conse consed te feum qui eriusto del ent il illutet
volenim dunt alit nullamconsed min vendipsum niat.
It nulla faccum nummodo lorper sustrud magna conse tem quat. Ut alis num et nonsent nonsecte mod magniat,
quisi exer ing etueril dit del eugiam nosto commodo ero dipit nis digna adip ex exerosto estrud ea facil exercil
iquametum venisse modit amcommo lobore vendre modolum vendre essequa

Gap Inc. 2011/2012 Social and Environmental Responsibility Report
109

EMPLOYEES | DATA
2012 North American gender demographics
Gap Inc.’s continued focus and strategic approach to diversity will enable us to better serve our global customers.

Male
29%

Male
30%

Male
26%

Female71%

Female70%

Female74%

Management
New hires
All employees

Note:
Includes U.S. and Canada Employees. Management data includes store and headquarter managers and above.

110

EMPLOYEES | DATA
2012 U.S. Ethnic demographics

Minority
33%

Minority
41%

Minority
46%

White
67%

White
59%

White
54%

Management
New hires
All employees

Note:
Minorities include all U.S. based employees who self-reported as non-white ethnicity (Black/African American, Asian, Hispanic/Latino, American
Indian/AK Native, Hawaiian/Pacific Islander or More than one Ethnicity). Management data includes store and headquarter managers and above.

111

EMPLOYEES | DATA
2012 Health & wellness benefits
The following chart provides an overview of Health & Wellness Benefits offered by Gap Inc. We want our health benefits
to do more than just take care of our employees when they’re sick. Our Health Reinbursment Account (HRA) plans are designed as a total health and wellness solution, with tools and resources to help employees improve their long-term healthand manage health care spending.
Program description
and coverage

Eligibility

Highlights

Health benefits

Available to all employees
classified as full-time, effective
on date of hire or change
status.

• Gap Inc oﬀers a Health Reimbursement Account with a medical
plan which includes first-dollar preventative care. The HRA isfunded by the company, and provide the ability to roll over dollars
to the next plan year.

• Medical• Dental• Vision• Health care and dependent care
Flexible Spending Accounts• 80% of Benefit eligible employees participate in Gap Inc.
medical plans.

• Life, disability, accidental
death and dismemberment,
medical benefits abroad
and business travel• Gap Inc. also oﬀers coverage to same- and opposite sex
domestic partners.
• In 2012, Gap Inc. paid approximately 78% of the costs of healthcare coverage for eligible U.S. employees and 71% of costs for
eligible U.S. employees' spouses and dependents.

Lifestyle benefit• 24/7 Nurseline service• Health risk assessments• Cancer care support• Onsite fitness programs (atsome corporate locations only,
full time/part time employees)• Employee Assistance Program(EAP) Life Resources (All U.S.
employees who are classified
as full-time, their dependents
and any other household
member are eligible)
National health access

Available to all employees andto same-sex spouses andopposite-sex domestic partners
and their dependents.

Gap Inc. is proud to oﬀer all employees access to a healthcare solution.

Note:
The benefits data in the chart applies to U.S. only, unless otherwise noted. Internationally, we align employee needs with the health care andwellness options available in each country to ensure we’re providing a comprehensive benefits package for our employees.
Employees who are classified as full-time are eligible for benefits.

112

EMPLOYEES | DATA
2012 Financial health benefits
The following chart provides an overview of Financial Health Benefits offered by Gap Inc. These benefits play animportant role in attracting, rewarding and retaining talented people who want to build long-term careers inour company.
Program description
and coverage

Eligibility

Highlights

GapShare 401(k) Plan:

Minimum age of 21, at least
1,000 hours of service.

• 90% of eligible employees participate in GapShare's 401(k) planin 2011• Gap Inc. oﬀers a 401(k) planfeaturing dollar-for-dollar
company matching contributions up to 4% of base pay,with 100% immediate vesting.

Employee Stock Purchase Plan
(ESPP):• 80% of eligible employees participate in GapShare's 401(k) planin 2012Full-time and part-time
employees are eligible.

• In 2011, 7264 employees participated in ESPP purchasing 1,301,166
shares of company stock.

• Employees can receive a 15%
discount oﬀ the fair market
value of Gap Inc. stock on the
day of the stock purchase.

• In 2012, 6926 employees participated in ESPP purchasing 960,930
shares of company stock.

Disability

Available to employees
classified as full-time.

• The STD Plan benefits are paid by Gap Inc. and replace 60% of
your base wages for up to 180 days. The STD Plus Plan pays 65%
of your base wages tax-free for a maximum of 180 calendar days
(six months). The LTD Plan pays 55% of your base wages (lessincome you receive from other sources) to a maximum benefitof $25,000 per month. The LTD Plus Plan pays 65% of your basewages tax-free.

Free financial
planning/counseling

Available to employees
classified as full-time.

• This free service helps employees take full advantage of Gap Inc.'s
benefit oﬀerings.

Access to home loans at
reduced rates

All full-time and part-time
employees are eligible

N/A

Note:
The benefits data in the chart applies to U.S. only, unless otherwise noted. Internationally, we align employee needs with the health care andwellness options available in each country to ensure we’re providing a comprehensive benefits package for our employees.
Employees who are classified as full-time are eligible for benefits.

113

EMPLOYEES | DATA
2012 Work-life balance & lifestyle programs
The following chart provides an overview of Work-life Balance & Lifestyle Programs offered by Gap Inc.
Our emphasis on wellness has garnered high interest and participation from our employees.
Program description
and coverage

Eligibility

Paid Time Off (PTO):

All employees classified as
full-time are eligible for holiday
pay and PTO on date of hire.

• Gap Inc. provides paid days to
use toward vacation, sickness
or personal time, in addition tocompany paid holidays.

Highlights

There are two main
PTO programs:
Plan Year Allowance PTO Planemployees have unused PTO
hours reset to zero each July.
Protected States PTO Plan employees roll over accrued
PTO each year.
Wellness programs:• Weight Watchers

Available to all employees
classified as full-time.

• 3,300 employees participated in these programs in 2012.
• 616 Employees participated in Weight Watchers. Total Reimbursement was approximately $51,000.

• Smoking cessation• 2,141 Employees participated in Healthcare Screenings and
Flu Shots.

• Onsite health assessments

Commuter benefits

Full-time and part-time
employees are eligible to use
benefit for parking expenses
or local mass transit services.

• 36,000 employees took advantage of this pre-tax benefit in 2012.
• 2012 Pre-Tax contributions: $3,905,640• 2012 Employee Savings: $1,562,256• 2012 Program Sponsor Savings: $298,791

Tuition reimbusement:• Gap Inc. employees can bereimbursed upto $5,000 per
year for approved job-related
academic courses.
Employee merchandise
discounts

Available to all employees
classified as full-time, with one
year of service.

• Approximately 1,160 employees take advantage of this benefit
each year.
• Total reimbursed for employees: $1,100,265.
• Average reimbursement per employee: $1,760

Full-time and part-time
employees are eligible.

• Employees received approximately $100.5 million in savings onmerchandise purchased in 2012.

Note:
The benefits data in the chart applies to U.S. only, unless otherwise noted. Internationally, we align employee needs with the health care andwellness options available in each country to ensure we’re providing a comprehensive benefits package for our employees.
Employees who are classified as full-time are eligible for benefits.

114

EMPLOYEES | DATA
2012 New parent support
The following chart provides an overview of New Parent Support benefits offered by Gap Inc. With a relatively young
and family-oriented employee population, we provide a wide range of support for new parents. This support helps
attract and keep great employees as they start and grow their families.
Program description
and coverage

Eligibility

Adoption assistance
reimbursement program

Available to employees
classified as full-time.

Weight Loss Subsidy

Available to employees atcertain locations.

Childcare support

Available to employees
classified as full-time in
New York and San Francisco
headquarter offices.

Healthy pregnancy program
pre-natal risk assessment
service

Available to employees
enrolled in UnitedHealthcare.

Parental Bonding Leave.
(baby bonding / paternity /adoption leave)

Available to all full-time
employees .

Phase out/phase back program
to assist new parents.

Available to all employees
classified as full-time.

Infertility benefits

Available to all employees classified
as full-time, enrolled in a UnitedHealthcare plan with one yearof service.

Transgender benefits

Available to employees enrolled
in UnitedHealthcare.

Note:
The benefits data in the chart applies to U.S. only, unless otherwise noted. Internationally, we align employee needs with the health care andwellness options available in each country to ensure we’re providing a comprehensive benefits package for our employees.
Employees who are classified as full-time are eligible for benefits

115

EMPLOYEES | DATA
2012 Community investment benefits
The following chart provides an overview of Community Investment benefits offered by Gap Inc. These benefits
encourage employees to play an active role in the causes that matter to them.
Program description
and coverage

Eligibility

Highlights

Gift Match:

All full- and part-time
employees.

• In 2011, Gap Inc. contributed $2.4 million to
thousands of nonprofits via Gift Match.

• Contributions to all eligible
nonprofits are matched,dollar for dollar.

• In 2012, Gap Inc. contributed $2.3 million to thousands ofnonprofits via Gift Match• In 2011, more than 4,600 employees participated in Gift Match.

• Donations can be made as
one-time gifts or via payroll
deduction.
Money for Time:• For every 15 hours an employee
volunteers in a calendar yearwith one nonprofit, Gap Inc.
will donate $150.
Board service match:• To support the leadershipoffered by our executives on
nonprofit boards of directors,
Gap Inc. will make a donation
to the nonprofit on whoseboards our leaders serve. This
is in addition to these
individuals’ annual gift match
allocations.
Field Team Grant:• When at least three store
employees spend 25 hours
volunteering with a nonprofit
that supports underserved
youth or women, Gap Inc.
provides a $250 grant tothat organization.

• In 2012, more than 4,300 employees participated in Gift Match

All full- and part-time
employees in North America
including Canada andPuerto Rico.

• In 2011, Gap Inc. contributed nearly $308,000 to organizations via
Money for Time.

Regional directors,
senior directors and above.

• In 2011, Gap Inc. contributed more than $240,000 in
Board Service grants.

• In 2012, Gap Inc. contributed nearly $291,000 to organizations via
Money for Time.

• In 2012, Gap Inc. contributed more than $275,000 in
Board Service grants.

All full-time and part-time
Field employees in North
America including Canada
and Puerto Rico.

• In 2011, Gap Inc. and Gap Foundation contributed nearly $855,000 in
Field Team Grants to organizations across the US and Canada.
• In 2011, Gap Inc. and Gap Foundation contributed $933,000 in Field
Team Grants to organizations around the world.

Note:
The benefits data in the chart is based on calendar year and applies to employees worldwide, unless otherwise noted.

116

EMPLOYEES | DATA
2012 Workplace health & safety data
This chart compares work-related employee injuries between U.S. Gap Inc. retail locations and all other U.S. Gap Inc.
locations. It measures frequency year-over-year since 2009. The data shows that the company’s number of work
related injuries has dropped since 2009.
Retail stores

All otherlocations

Total

2011

2012

2011

2012

2011

2012

Number of Gap Inc. employees

95,88886,3698,230

11,793

104,118

98,162Workers’ comp claims

1,688

1,474

147

180

1,885

1,654

Time loss claims

200

177

50

28

197

205

84,022,098

81,640,115

12,761,651

13,682,314

96,783,749

95,322,429

Rate of injury per 200,000 hours worked

4.02

3.61

2.30

2.63

3.90

3.47

Safety/injury incident reports

6,858

7,101

591

386

7,449

7,487

0

0

0

0

0

0

N/A

N/A

N/A

N/A

0.87

0.74

Hours of exposure

Occupational injury-related fatalities
Experience modification factor

Note:
Chart reflects U.S. data only, reported by calendar year.

117

GOALS AND PROGRESS | Supply chain | Overview

Community
Full Section

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iquametum venisse modit amcommo lobore vendre modolum vendre essequa

Gap Inc. 2011/2012 Social and Environmental Responsibility Report
118

COMMUNITY | OPERATING CONTEXT & STRATEGYKey Takeaways:• Communities around the world face a variety of pressing challenges and emerging opportunities. Gap Inc.’scommunity investment programs seek to apply outcome-driven, results-oriented thinking to confront thechallenges and maximize the opportunities.
• Since our founding, Gap Inc. has leveraged our company strengths to address critical community needs.
• We focus our community investment efforts on expanding opportunities for youth and women. We seek tocreate a virtuous cycle that produces long-term solutions for everyone involved.

Communities need investments that go deeper than grants alone
Communities across the United States and around the world are facing new and complex challenges. In the decade
between 2000 and 2010, the income and wealth of the average family fell for the first time since World War II. 1
Individuals and families are working harder than ever to stay afloat, and the nonprofit organizations addressing themost critical community challenges are serving more people than ever—only with fewer staff and resources.
Fueling sustainable community change requires more than grant-making. It calls for a new way of doing businessthat engages more deeply in community—with the innovative thinking to solve problems, fill local needs, andcreate opportunities for communities to reach their full potential.
Contributing to the strength of the communities in which we operate has been central to the way Gap Inc. hasdone business since we opened our first store in 1969. We know that when communities thrive, business thrives.
We believe that the best way to support the communities where we live and work—and ensure the long-term healthof our business—is to apply the same strategic business thinking we use in the boardroom to find solutions to social
challenges in communities around the world.
In 2006, Gap Inc. refocused our community investment strategy to build on two principles:• We develop community partnerships that leverage our company’s core strengths. As a global company, we look 				 at the full spectrum of our assets and abilities, and apply them to make the greatest possible impact in		 addressing local needs. This means we don’t just write checks. We enlist our globally recognized brands,		 marketing expertise, vendor relationships, and more than 135,000 talented employees to foster positive and		 sustained social change. This commitment and business-oriented approach are reflected in every step of		 Gap Inc.’s community investment strategy—from needs assessment to design to implementation.

mpany assets

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Employees

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• We seek to create a sustainable, virtuous cycle. When we invest in an
Community		 organization or a community, we strive to ensure that our programs go		 beyond a one-time benefit. We work to initiate a cycle that creates value		for everyone involved: the community, customers, employees, vendors,
Collective benefit
		 and shareholders. When everyone supports a shared purpose and derives a		 meaningful benefit, this cycle gains momentum and continues to benefit
		 all for the long term. Every local investment Gap Inc. makes—from helping
Cons
umers
		
to expand the capacity of our community partners to offering employee
		 expertise—aims to advance this broader long-term vision.
Virtuous cycle

The strength of a community rests in its ability to help residents reach their full potential. In 2012, Tufts University
and the National Conference on Citizenship published a report illustrating that regions where residents were

1 Pew Research Center: The Lost Decade of the Middle Class, August 2012.

119

COMMUNITY | OPERATING CONTEXT & STRATEGY
engaged and active in community affairs fared better during the recession. Moreover, the research showed that
communities with a higher density of nonprofit organizations filling local needs were better able to weather the
economic downturn than were regions with fewer social supports.
Given both the challenges and opportunities that families, communities, and the global economy currently face,Gap Inc. focuses our social investments on organizations that help residents achieve long-term successand independence.
Based on our company’s strengths and the ways that our business connects us to the community, we believe we canmake the greatest impact in two areas: helping young people in the developed world and women in the developingworld realize a healthy, productive future.
• Connecting youth. When our employees share their professional experiences with underserved youth, the		 impact outlives the program. As young people learn how real-world career skills can expand their options as
		 adults, they are encouraged to explore their own ambitions and envision a brighter future.
• Empowering women. When we partner with apparel vendors and organizations in the developing world to		 support personal advancement for female garment workers, the benefits extend beyond the individual.
		 As women become more skilled at their jobs and begin to elevate their status, their families are lifted by their		 confidence and improved business skills, and the factories where they work become more productive.
We recognize that the challenges we are working to address are deep and complex, and they require long-term
efforts to shift thinking and change behavior. Gap Inc. is committed to be an enduring partner that helps advance thesustained change that communities are seeking.

120

COMMUNITY | PARTNERSHIPSKey Takeaways:• Gap Inc. partners with community organizations that support underserved youth and help women advance by
creating opportunities for them to grow personally and professionally.
• We support our partners by applying company strengths and resources that bring strategic value and lead tolonger-term impact than grants alone.
• By working to understand our community partners’ needs and applying the company resources to help meetthem, we strive to fuel a virtuous cycle.
Gap Inc.’s community partners are at the heart of sustained social change. No one is better equipped to understandand address the pressing needs of a community than the nonprofit and civic organizations that serve its mostvulnerable residents. Yet as demand for social supports has grown, economic challenges have forced community
organizations to do more with less. In response, we invest in local partners and help them increase their skills,
capacity, and effectiveness.
In working with our community partners, we leverage company resources to make the greatest possible impact.
We see the community organizations we support as more than grantees; they are our partners in this critical work.
We collaborate with a diverse mix of organizations that have two things in common: a track record of strengthening
communities and an innovative approach to tackling social challenges. Given the complexity of the issues that community organizations face—and the daily challenges of addressing the increased, often urgent, demand for services—the needs of nonprofits are ever-changing. We therefore focus less on what we want to give, and more on what ourcommunity partners tell us is needed in order to better serve their clients.

A Virtuous Cycle: Leveraging resources to drive leadership capacity among our partners
The thinking behind our approach is grounded in the notion that Gap Inc. and our community partners have ashared purpose, and our partners are on the front line of delivering on that purpose. Over the past few years, thenonprofit leaders with whom we collaborate have told us that they need to stretch limited resources to address anincreased demand for services. Given their need to focus on immediate crises and the day-to-day operations of theirorganizations, they have little time to think about staff development, succession planning, or building the leadershipskills of their teams.
In 2009, we launched the Gap Inc. Leadership Initiative (GILI) as a way to invest in our nonprofit partners and theirneed to address these challenges. In addition to cultivating strong leaders, GILI encourages ongoing collaboration
between our partners so they can learn from each other, expand the skill base across the nonprofit sector, and help
nonprofits more effectively meet community needs long term.
GILI adapts leadership tools originally designed for Gap Inc. executives and deploys them in a training program thatreaches 50 leaders from 25 nonprofit organizations each year. The program includes an annual two-day conference aswell as ongoing mentoring and collaboration opportunities. Most important, the curriculum is customized to meetthe unique needs of the nonprofit sector.

121

COMMUNITY | VOLUNTEERING
Takeaways:• As communities grapple with a host of pressing challenges, a new volunteering model is needed to effectively
address the most pressing social and economic issues in the United States and abroad.
• At Gap Inc., some of the greatest strengths we can leverage to support communities are the skills and talents ofour more than 135,000 employees.
• Gap Inc. employees are concerned about the health of their communities and have a track record of taking
action. The volunteer programs that Gap Inc. has developed enable employees to contribute to theircommunities frequently and effectively.
Volunteering is more important now than it has been in a generation. Over the past several years, civic engagement
has taken on renewed meaning. In 2009, reflecting the increased need and enthusiasm for service, the Edward
M. Kennedy Serve America Act expanded opportunities for individuals and organizations to volunteer. Alongwith this renewed sense of urgency and purpose came a realization that a new model of volunteering—one thatapplies resources strategically—was needed to ensure that volunteers were bringing real value to the community
organizations where they serve.
Gap Inc. employees work to strengthen the communities in which we operate by volunteering their time and talent
to organizations in the United States and around the world. Our company has much more to offer communities thancash grants alone; our diverse, talented employee base is also a force for community change.
For many years, Gap Inc. has made it a central tenet of our business to create ways for our employees to volunteer
their time with nonprofit partners. We encourage employees to volunteer in whatever way best applies their unique
skills to meet long-term community needs – from offering legal support at a family services agency to providing
opportunities for underserved youth to develop career skills.

A Virtuous Cycle: Reimagining the way volunteers and community organizations interact
The global economic challenges of the past several years have contributed to a renewed focus on volunteeringand service. Recognizing the need to serve more people with decreased financial resources, leaders from multiple
sectors have encouraged more people to get active and volunteer. During that same time period, a group of fiveorganizations, including Gap Inc., recognized that simply encouraging more people to volunteer wasn’t enough: If
nonprofits didn’t have the right systems in place to train and manage the surge of volunteers, the experience would
fail to benefit both those who wanted to volunteer and the nonprofit
organizations they wanted to support. In response, a new national coalition
was formed called Reimagining Service,which seeks to “convert goodintentions into greater impact.” Together with representatives from nonprofits,
government, faith-based organizations, private foundations and corporations,
we advocate for a strategic approach to volunteering designed to bringmaximum value to nonprofit organizations. And we are working with leadersacross all sectors to shift perceptions about the value of volunteerism.
We seek to build partnerships that strive for long-term impact, and our approach to volunteering is grounded in the
belief that long-term relationships between nonprofit partners and employee teams have the greatest potential to
do just that. Our Community Leader program encourages this sustained engagement by cultivating company
service leaders:122COMMUNITY | VOLUNTEERING• Each team identifies one employee to serve as a Community Leader. We equip these individuals with tools and		resources to lead their teams’ volunteer strategies.
• Community Leaders work with their teams to identify a local need and select a nonprofit partner organization
		 that addresses it. Employee teams work to develop ongoing relationships with their nonprofit partners. As the		 partner organization’s staff gets to know the skills and expertise of our employees, they can better leverage		 their time as volunteers. In turn, as our employees better understand the needs of the nonprofit, they can
		 identify team members with the skills and experience best suited to meet those needs.

We strive to design our volunteer programs to benefit everyone involved, from our communities and nonprofit
partners to our employees and shareholders:• Focused support meets organizational and community needs. Our nonprofit partners receive sustained support		 that seeks to meet their needs and capacity, so they can spend less time training and managing volunteers and		 more time pursuing their missions.
• Sustained commitment helps employees understand their impact. Because we believe in fostering long-term		 impact rather than one-time volunteer opportunities, our employees see the effects of their involvement grow		 over time.
• Volunteering boosts employee satisfaction and pride in our company. Gap Inc. benefits from the increased
		 employee morale and engagement, and from new skills that our employees develop through their volunteer
		 and leadership activities.

123

COMMUNITY | YOUTH
Key Takeaways:• Today, 6.7 million young people in the United States are disconnected from work and school, with few
opportunities to find and advance in a career.
• Given Gap Inc.’s experience hiring first-time workers and equipping them with the skills needed to succeed in
the workplace, Gap Inc. can play a role in helping to reconnect these youth.
• We want to unleash the potential inherent in all young people through the transformative power of work.
We do this by providing financial support, designing and running programs, and leveraging other corporate
resources on behalf of positive youth development.
Today, one in six young people in the United States is disconnected from school or work. Without a clear plan orpath for the future, these 6.7 million young people have few opportunities to find and advance in a career. This limits
their opportunities for a successful, stable adulthood, and costs the nation an estimated $93 billion annually in lost
revenue and additional social services per year. 2
We believe that work is a powerful force in a young person’s life, and we know what it takes for a young person to
get a job and succeed in a work environment. Beyond a paycheck, work experience has the power to provide young
people with critical perspective on their options for the future and new appreciation for the value of education. Job
training programs can help young people develop critical life skills and make an indelible impact on individuals, theirfamilies, and the community.
Helping youth advance in work and in life has been core to our business since our first store opened in 1969. Since
then, hundreds of thousands of young people have experienced the satisfaction that comes from landing their “firstjob” in our retail stores. By giving young people the knowledge and skills to actively shape the trajectory of their lives,
we are also contributing to the health of the community and protecting the long-term health of our business. Our
programs prepare young people for adulthood by exposing them to the transformative power of work.
In 2011-12, Gap Foundation President Bobbi Silten served on the White House Council for Community Solutions todevelop a plan for reconnecting youth, ages 16-24, with meaningful education and employment opportunities. As
part of this project, we collaborated with McKinsey & Company, Corporate Voices for Working Families, Opportunity
Nation, and the Taproot Foundation to develop a new resource: Connecting Youth & Business: A Toolkit for Employers.
The Toolkit guides employers through an assessment of their strengths to help them identify effective ways tosupport underserved youth and implement job training or mentoring programs that meet the organization’s needs
and capacity.

A Virtuous Cycle: Connecting underserved youth to career and life opportunities
Gap Inc.’s signature youth program This Way Ahead provides job readiness training and paid internships forunderserved youth in New York City, Boston, and San Francisco.
Working closely with three nonprofit partners (The Door, Enterprise for High School Students, and Cambridge
Housing Authority), Gap Inc. employees created a program that helps young people develop the hard and soft skills
that are critical for success in life and provides them with real-world work experience.
• Our employees share what they have learned about career planning and the importance of education.
		 They help participants explore a range of industries and become excited about finding a career they are		 passionate about.
2 White House Council for Community Solutions: Community Solutions for Opportunity Youth, Final Report, June 2012.

124

COMMUNITY | YOUTH• Store managers facilitate classes in career skills—from making tough decisions and giving presentations to		 setting goals and resolving conflict. Along the way, interns meet with mentors from the nonprofit partner who
		 help them navigate challenges and overcome potential barriers.
• To date, 75 percent of This Way Ahead interns have been hired as permanent store associates, and their average		 tenure is longer than that of their peers.
• The curriculum for This Way Ahead is available for other companies and organizations to use.
By the end of our 2012 fiscal year, more than 1,000 youth had participated in this life-changing program. Gap Inc.
employees at every level of the company contribute to the success of This Way Ahead by volunteering their time andtalent to develop the curriculum, teach classes, and coach interns.
Gap Inc. invests in nonprofit organizations that help young people explore their career options, develop career-related
skills, and experience on-the-job learning. We work alongside community organizations as strategic partners with ashared goal.
• Designed in partnership with the Pearson Foundation, Plan Ahead is a semester-long college and career		 awareness course for ninth graders in the San Francisco Unified School District (SFUSD). During 75 hours of		 coursework, students learn to develop a path to a career, college, and life after high school. In the 2011–2012
		 school year, nearly 4,000 SFUSD students completed the course. Of students surveyed after the first semester,		 nearly 80 percent reported increased knowledge of the classes they need to take to complete high school and		 go to college.
• At Camp Old Navy, underserved youth experience what it’s like to have a job in a retail setting. More than		 70,000 youth have participated in Camp Old Navy since it was launched in 1999.
While our programs were not designed to recruit or develop talent for the company, they have proven to be a sourceof qualified and motivated talent for Gap Inc. while helping young people discover their own career ambitions andchart a brighter future. In 2012, Gap Inc. served more than 89,678 young people in five countries by partnering withmore than 60 community organizations. Specifically, 8,425 youth benefited from soft-skills development, 80,129 fromwork-ready skills development, and 1,124 from learn-and-earn experiences.
Given the large number of youth who are isolated from school and work and the complex challenges that theseyoung people face, we know this is just a start. But we hope that Connecting Youth & Business will help other
employers join the national effort to re-engage young people around the world.

125

COMMUNITY | ADVANCING WOMENKey Takeaways:• Globally, 80 percent of garment workers are women. Through the Gap Inc. P.A.C.E. (Personal Advancement& Career Enhancement) program, we provide female garment workers with the foundational life skills andenhanced technical skills needed to advance in their personal lives and in the workplace.
• P.A.C.E. is a flexible, sustainable program that has profound benefits for garment workers, their families andcommunities, and manufacturers.
• By measuring the impact of P.A.C.E., we are showing that investing in female garment workers can advanceopportunities for women to become confident leaders at home, in the community, and in the workplace, while
improving productivity for Gap Inc. vendors.

“Research shows that when provided access to educational learning and technical support, women canbe real agents of change—for their families, their communities and, ultimately, for society as a whole.”­—Dotti Hatcher, Executive Director, Gap Inc. P.A.C.E. Global Initiatives

We know that women’s education and economic advancement are central to thriving communities. Women who
earn an income spend more on their families, and educated women are more informed about their rights and how
to exercise them. When women’s livelihoods improve, the impact extends far beyond the individual; it can determine
the overall health of communities in the developing world.
Gap Inc. is committed to creating opportunities for women to advance and lead – both within our company and in
the communities touched by our business. Since Doris Fisher co-founded Gap Inc. in 1969 with her husband Don,
women have shaped every part of the company’s management and culture. Today, women make up approximately
70 percent of our employees worldwide. When we refocused Gap Inc.’s community investment strategy in 2006 toleverage the company’s greatest strengths for maximum impact, investing in opportunities for women was a natural
fit for our company.
Globally, 80 percent of garment workers are women, yet few have opportunities to advance in the workplace.
By working to ensure that these women are supported by their workplace, confident in their skills and abilities, andrecognized as full and productive participants in society, we not only help strengthen communities, but we also
ensure the integrity of our products and our company. Our investments in female garment workers are focused on
creating a virtuous cycle where women are elevated by new opportunities, families and communities gain fromgreater inclusion of women, and garment manufacturers benefit from an engaged and motivated workforce.

A Virtuous Cycle: P.A.C.E. benefits female garment workers, their communities, and participating factories“Women hold enormous potential to make a difference… Gap Inc.’s P.A.C.E. program gives female garment workers the
skills and confidence to fulfill this potential—in their personal lives, with their families, and in their communities.”– Shiv Kumar, Managing Director, Swasti-Health Resource Centre

Launched in 2007, the Gap Inc. P.A.C.E. program provides a sustainable pathway for women garment workers toadvance in their personal and professional lives. P.A.C.E. is a comprehensive learning experience focused on helping
female garment workers (FGWs) develop life skills and enhanced technical skills. It also creates a supportive environment where participants can put these new skills to use at work, at home, and in their communities.
• P.A.C.E. is founded on global partnerships. Working closely with Swasti-Health Resource Centre and the		 International Center for Research on Women (ICRW), we developed a curriculum that draws on Gap Inc.’s wide
126

COMMUNITY | ADVANCING WOMEN
		 and unique range of resources, including our global employee base, relationships with garment manufacturers,
		 and partnerships with nonprofit organizations that understand the social and cultural barriers faced by female		 garment workers.
• The program is designed for flexibility and sustainability. P.A.C.E. is completely voluntary for both factories
		 and workers, so participation is a clear commitment to advancing the roles and lives of women. Our partners
		 train factory staff to implement the curriculum and integrate it into the ongoing operations of each		 manufacturer to ensure sustainability. While the foundational learning components are consistent, P.A.C.E.
		 is adaptable to the culture, workplace, and needs of female garment workers in each setting where it
		 is implemented.
• Women gain foundational skills that improve their confidence and positively impact their families. P.A.C.E.
		 teaches foundational life skills such as communication, problem solving and decision making at work and at
		 home, and financial and legal literacy. The program also includes orientation and training for human resources		 staff and other employees at the factory to ensure a supportive work environment.
• Gap Inc. is guided by evaluation every step of the way. Our vendors and partners collect data before and		 after each learning module so we can measure changes in the participants’ knowledge and the program’s		 impact in making garment factories more supportive and productive places to work. In a recent end-line		 evaluation of the program’s first year at a facility in Bangladesh, the proportion of female garment workers
		 that held leadership roles on committees or groups in the previous six months increased by more than four		 times—from 6 percent to 25 percent. In 2012, ICRW aggregated findings from five program evaluations in India,
		 Vietnam, and Cambodia. The chart below indicates their findings:

Five sites aggregate indicators
India pilot, India scale-up, Cambodia, India vendor owned, and Vietnam

Have money which they can
decide on their own how to use
Rating for quality

74.4
81.3
71.3
86.9

Rating for quantity

63.8
84.5

Can talk about home stress withpeers at work

49.9
68.2

Female garment workers are able toorganize travel or can travel alone to a
far city/village

38.1
57.9

64.4
Female garment workers feel theiropinion is respected in family discussions 79.4
Baseline %Endline %*The baseline data was collected prior to the implementation of P.A.C.E. at a given factory.
The above data is aggregated based on studies conducted over one or two year timeframes.

127

COMMUNITY | ADVANCING WOMEN
P.A.C.E. is currently operational with 22 vendors in more than 60 factories in seven countries (Bangladesh, Cambodia,
China, India, Indonesia, Sri Lanka, and Vietnam). To date, more than 20,000 women have participated in the program.
Our vision is for P.A.C.E. to be widely recognized as a model for advancing women in the developing world and in
emerging markets. The Gap Inc. P.A.C.E. program has been recognized for making a difference in the lives of womenand their communities globally. Honors for the program include the 2010 Financial Times/Justmeans Social
Innovation Award, the 2011 International Center for Research on Women’s Champion of Change Innovation Award,
and recognition from President Clinton and the Clinton Global Initiative. Gap Inc. is focused on continued expansion
with our manufacturing vendors, and we plan to double the number of participating vendors by 2015. We are also
developing a strategy to expand the program into community settings, and we look forward to sharing our progressin our next report.

128

COMMUNITY | GOALS

Current community goals
Women

Estimatedcompletion date

Increase vendor participation in the P.A.C.E. program by expanding program to 40 key vendors by the year 2015.

2015

An additional 10,000 female garment workers will complete P.A.C.E. program by the year 2015.

2015

Expand P.A.C.E. program into community settings by partnering with select NGOs to develop and implement modified
P.A.C.E. community program—Target 3 community programs in 2013 and 10 community programs by the year 2015.

2015

Volunteering

Estimatedcompletion date

Increase the impact of employee volunteering by encouraging each employee team to identify a Community Leader,
and then form a long-term partnership with one community organization. By Q4 2013, 1200 Community Leaders will
have identified their long-term community partners.

2013

Set a target of creating $16 million in employee-driven value to the community in 2014. This includes employees’
donations of time and money, and Gap Inc.’s financial match of both.

2014

Youth

Estimatedcompletion date

Provide 95% of our key youth-serving community partners with support beyond cash grants.

Ongoing

Through Gap Foundation’s community partners, serve at least 70,000 underserved youth and young adults per year.

Ongoing

Completed community goals
Completion
date
Create new opportunities for underserved youth and women by expanding our programs.

2012

Deliver at least 75 percent of grants in target causes and invest our company assets to build nonprofit capacity.

2012

Continue to connect our employees to our nonprofit partners so they can increase our impact beyond a cash grant.

2012

Provide at least 95 percent of youth-serving nonprofit partners with support beyond cash grants.

2012

Strive to increase the annual value of employee-driven contributions of time, money and talent to the community.

2012

Contribute our knowledge of volunteerism to the national service movement; begin to shift our own company
volunteerism from a hands-on to a skills-based approach.

2012

129

GOALS AND PROGRESS | Supply chain | Overview

Community
Data

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nim nostisi.

Igna at ea ad min voluptat wismodo luptat.
Ustio dolor at vullutat, consed enit venit irit nullummy nos aut etum dui blaore exeros autet augiam, conulputat
praesed mincin er sit lum do consecte consequipsum dolendit volorper sissequ ismodipis ad tem ing eu feu facip
enisse minit praestrud tat.

Wis nismodip ex eraesto enibh ese molore modionulla feugait, quat, conse molore magna autem doluptat. Dui
tincilit at, quat vendre te molorti sciduis acing ex elenibh er sum ipsum vullaortio core veliqui pisiscil utatum
doloreros adio elesse dolortisi erat. Ut elenisl ute tem nonsed ent velit vullam in ut wisse esto doloborer sustrud et
acidui blaortio eu feu feuguero odoloreetue vulluptatem veliquisisl iurem digna faccum zzriurem velit vulla commy
nim quam dio od magna feu facing eu facil utpat. Ibh et, quatue minim vulla feuiscipit wisi.

La faccummolor augiam vel ut velit irit at, quametue moloreriurem dit autpate tuerciduis et, si ea augiat ullametnos doleniamet volorer iuscidunt nos autat lut ulluptate magniam, conse consed te feum qui eriusto del ent il illutet
volenim dunt alit nullamconsed min vendipsum niat.
It nulla faccum nummodo lorper sustrud magna conse tem quat. Ut alis num et nonsent nonsecte mod magniat,
quisi exer ing etueril dit del eugiam nosto commodo ero dipit nis digna adip ex exerosto estrud ea facil exercil
iquametum venisse modit amcommo lobore vendre modolum vendre essequa

Gap Inc. 2011/2012 Social and Environmental Responsibility Report
130

COMMUNITY | DATA
2008-2012 Volunteerism: Total employee contribution
84

74.3
72

60

59.7
50.8

Number of employees (in thousands)

48

39.2
36

33.49

24

12

0

2008

2009

2010
Calendar year

Note:
This data is based on a calendar year.

131

2011

2012

COMMUNITY | DATA
2008-2012 Volunteerism: Total employee contribution
459.6
450

428.8

433.2

2010

2011

375

318.2
Hours volunteered (in thousands)

300

269.2

225

150

75

0

2008

2009

Calendar year

Note:
This data is based on a calendar year.

132

2012

COMMUNITY | DATA
2008-2012 Financial donations: Employee participation

Number of employees (in thousands)

10

8

6

5.48

5.37

5.01

4.62

4.33

4

2

0

2008

2009

2010
Calendar year

Note:
This data is based on a calendar year

133

2011

2012

COMMUNITY | DATA
2008-2012 Financial donations and volunteerism: Total employee contribution

50

39.7 M

Dollars (in millions)40

31.9 M30

32.3 M

30.7 M

27.3 M

20

10

0

2008

2009

2010

2011

2012

Calendar year

Note:
This data is based on calendar year. Data represents the total value of the money and the volunteer time that Gap Inc. and its employees invested
in the community.

134

GOALS AND PROGRESS | Supply chain | Overview

Appendix

Put in hendrero consequatisi et aliquam, sum nis nonsequissit ulla con ut irilis acil eugait, sum doluptatummy nis
nim nostisi.

Igna at ea ad min voluptat wismodo luptat.
Ustio dolor at vullutat, consed enit venit irit nullummy nos aut etum dui blaore exeros autet augiam, conulputat
praesed mincin er sit lum do consecte consequipsum dolendit volorper sissequ ismodipis ad tem ing eu feu facip
enisse minit praestrud tat.

Wis nismodip ex eraesto enibh ese molore modionulla feugait, quat, conse molore magna autem doluptat. Dui
tincilit at, quat vendre te molorti sciduis acing ex elenibh er sum ipsum vullaortio core veliqui pisiscil utatum
doloreros adio elesse dolortisi erat. Ut elenisl ute tem nonsed ent velit vullam in ut wisse esto doloborer sustrud et
acidui blaortio eu feu feuguero odoloreetue vulluptatem veliquisisl iurem digna faccum zzriurem velit vulla commy
nim quam dio od magna feu facing eu facil utpat. Ibh et, quatue minim vulla feuiscipit wisi.

La faccummolor augiam vel ut velit irit at, quametue moloreriurem dit autpate tuerciduis et, si ea augiat ullametnos doleniamet volorer iuscidunt nos autat lut ulluptate magniam, conse consed te feum qui eriusto del ent il illutet
volenim dunt alit nullamconsed min vendipsum niat.
It nulla faccum nummodo lorper sustrud magna conse tem quat. Ut alis num et nonsent nonsecte mod magniat,
quisi exer ing etueril dit del eugiam nosto commodo ero dipit nis digna adip ex exerosto estrud ea facil exercil
iquametum venisse modit amcommo lobore vendre modolum vendre essequa

Gap Inc. 2011/2012 Social and Environmental Responsibility Report135PUBLIC REPORTING WORKING GROUP STATEMENT
Reporting serves several purposes. For those looking to compare companies, both quantitative and qualitative data
provide useful comparison points. For those working to change problems related to human rights, labor rights andthe environment, both types of data provide information that allow for documenting progress. In addition, reporting
helps us to understand what works and what has not worked to bring about positive change.
Gap Inc. has been a leader in many aspects of corporate responsibility and reporting. For example, Gap Inc.’s report
indicates executive-level accountability for sustainability and provides stakeholders with a clear understanding of thecompany’s overall governance structure. The company has a long history of robust reports. While Gap Inc.’s two-year
reporting cycle has produced comprehensive and useful information over the past decade, we encourage Gap Inc. tomove toward a more frequent reporting cycle, such as an annual comprehensive report or quarterly data updates
on its website. We believe that more frequent data and analysis reporting would anchor Gap Inc.’s leadership in amore comprehensive way. It is also important to note that the state of reporting is rapidly evolving and there is a
growing emphasis and pressure on companies to articulate processes for identifying material sustainability issues.
We support Gap Inc.’s conclusions that the issues presented in this report are material to the business, impacted
communities and investors.
In the Human Rights section of the report, Gap Inc. recognizes that the landscape has changed dramatically since
its social responsibility program began in the mid-1990s. The company points to an increased fragmentation of
supply chains, intensified competition in the apparel industry and the rise in demand for lower-cost, faster fashion.
It is a significant challenge to put in place a human rights strategy to address systemic issues that improve thelives of workers and have a positive impact on their communities. To meet this challenge, Gap Inc. has evolved andis still evolving its approach containing these and other elements: utilizing root cause analysis rather than relying
exclusively on factory audits; developing suppliers instead of policing them; putting social and labor compliancesystems in place; building the capacity of managers and workers to address issues as they emerge and working witha range of stakeholders—NGOs, trade unions, community leaders, governments—to leverage positive change.
Gap Inc. has been a leader in forging collaborative approaches to supply chain responsibility. Yet, more needs to bedone by the company and the entire apparel industry.
The entire apparel industry needs to take concrete steps to create humane working conditions by a) fully integratingsocial and environmental responsibility requirements into the sourcing and buying function; b) eliminatingpurchasing practices that have negative impacts on workers; c) including human rights criteria into pricing decisions;d) creating systems that guarantee workers are paid a sustainable living wage; e) requiring suppliers to foster anenvironment where workers can organize and join trade unions without fear of retaliation; f) collaborating to bringcollective leverage to improve working conditions throughout the entire supply chain down to the commodities
level; g) utilizing the full force of their commercial power to press for strong governmental labor and environmental
policies and enforcement and g) reporting on outcomes and impacts of supply chain social responsibility programs
so that stakeholders, including consumers and investors, are better informed about performance changes over time.
This is not philanthropy, meaning that it should not be considered optional. We view this work as necessary, andcentral to any global company’s value proposition, although relatively few companies fully grasp these obligations
and opportunities.
This year, the world’s attention has turned to grave concerns and critical issues that remain unaddressed in
Bangladesh. Gap Inc. has long played a constructive and solutions-oriented role in addressing these problems,
dating back to the 2010 fire at the Hameen Group’s factory in Dhaka. Following that tragedy, and in spirit withGap Inc.’s history and willingness to work with different stakeholders, the company initiated engagement with laborrights groups to identify sustainable solutions. However, these problems­—which are not unique to Gap Inc.—have

136

PUBLIC REPORTING WORKING GROUP STATEMENT
continued to progress and most recently resulted in the tragedy at the Rana Plaza factory complex.
We believe a truly multi-stakeholder approach, including representatives of global and local labor unions, the NGO
community, the Bangladesh Garment Manufacturing and Exporters Association (BGMEA), government, industry andfactory management, will be necessary to bring about the systemic changes that are required in Bangladesh. We aredisappointed in Gap Inc.’s decision not to participate in the Accord on Fire and Safety in Bangladesh, which includes
the participation of all key stakeholders, and to help organize a parallel effort which has weaker accountability
mechanisms and no trade union participation—the Alliance for Bangladesh Worker Safety. In the coming months, wewill look to Gap Inc. to bring to bear its resources, extensive experience of engagement with stakeholders—especiallyworkers—and significant expertise to set high standards and work collaboratively with the Accord to bring about
needed change.
Roughly two hundred years into the industrial revolution, we are still grappling with unsafe working conditions, childand forced labor, starvation wages, gender inequality and environmental degradation in many places around theworld. One commodity alone—cotton—raises all of these issues. These problems are systemic and cannot be solved
by one or even a handful of companies working independently. It is also clear to us that market forces will not solve
them. The collapse of Rana Plaza has catalyzed an important and long-overdue development – competitors working
together to pursue common safety standards for workers. We strongly encourage all participants to seize thisopportunity to go beyond the critical fire and safety work and to tackle these broader interconnected sustainability
problems, none of which are inevitable or acceptable.
Mr. Adam Kanzer, Managing Director & General Counsel, Domini Social Investments
Mr. Mike Lombardo, Senior Sustainability Analyst and Manager, Calvert Social Index, Calvert Investment
Management, Inc.
Dr. Ruth Rosenbaum, Executive Director, Center for Reflection, Education and Action
Rev. David Schilling, Senior Program Director, Interfaith Center on Corporate Responsibility137

INDEPENDENT COMMENT FROM SHIFT“Respecting Human Rights in Gap Inc.’s Global Supply Chain”
The UN Guiding Principles on Business and Human Rights provide companies with a blueprint for how to know
and show that they respect human rights throughout their operations—in their own activities and business
relationships. Shift is a non-profit organization whose team helped shape and write the Guiding Principles; we now
work with governments, business and other stakeholders to put them into practice. We were asked by Gap Inc. tooffer reflections on the implications of the Guiding Principles for Gap Inc.’s efforts to respect human rights in its
global supply chain, as described in this section of their Social & Environmental Responsibility (S&ER) report.
Our comments were informed by reviewing documents and interviewing key staff; they are not an assessment of
the effectiveness of Gap Inc.’s policies and processes on the ground.
Gap Inc. has a Human Rights Policy that applies to its wholly-owned operations and apparel supply chain, as well as
a long-standing Code of Vendor Conduct that sets clear expectations for factories that produce goods for Gap Inc.
The Policy importantly identifies impacts on workers’ human rights as the company’s leading human rights risks.
The Guiding Principles focus attention on impact as the basis for a company’s responsibility to respect human rights,
rather than influence (or leverage). Influence is critical in preventing and addressing identified human rights impacts,
but is not a filter on a company’s responsibility—regardless of where those impacts occur in the supply chain.
Gap Inc.’s human rights commitments should apply equally to its non-apparel and non-merchandising supply chain,even if Gap Inc.’s leverage in these business relationships may be less—or less obvious—than its leverage with firsttier apparel vendors. This will be important as Gap Inc. expands its franchise business.
The S&ER and Sourcing teams work closely to embed Gap Inc.’s policy commitments in its relationships with vendors—and to help those vendors meet their own human rights commitments. The S&ER team provides input into key risk
assessment processes, including sourcing decisions and vendor relationships, and seeks to support category leadersin identifying and mitigating human rights risks in core business operations. This cross-functional engagement will
be central to achieving Gap Inc.’s goal of jointly advancing human rights and strategic business objectives.
The Guiding Principles focus companies’ human rights risk management processes on risk to affected stakeholders,rather than risk to the business. Risks of severe human rights impacts are the first priority. Gap Inc. implicitly
recognizes this in key programs (i.e., addressing Uzbek cotton) and in its responses to specific incidents (such as
instances of child labor), and seeks to use its leverage to address them. However, we recommend Gap Inc. review
whether this “severity” lens is consistently applied across its activities and business relationships: for example, in its
approach to vendor capacity-building, and assessments of non-apparel suppliers.
To fully assess the severity of potential impacts, a company needs to understand the perspectives of affectedstakeholders. Gap Inc. seeks to integrate worker perspectives into its robust vendor monitoring and capacity-building
program, and relies on local staff who are attuned to language, cultural and other sensitivities to do so. The valuethat Gap Inc. places on broader stakeholder engagement is evident in multiple places in the report. However, werecommend that Gap Inc. review how and in what ways the results of such engagement are formally incorporated
into existing systems for risk assessment, mitigation and remediation.
Notably, root cause analysis is an integral part of Gap Inc.’s processes. This helps Gap Inc. understand the underlying
causes of failures to respect workers’ human rights and helps Gap Inc. see where its own actions might contribute tonegative human rights impacts. Gap Inc.’s transparency in recognizing the relevance of purchasing practices for its
vendors’ ability to respect human rights is commendable, and provides a powerful example to other companies.

138

INDEPENDENT COMMENT FROM SHIFTWe were not asked to review supply chain metrics or performance data included in the report. With regard to
the processes for gathering such information, Gap Inc. has several initiatives underway to improve internal datacollection and sharing. Importantly, factory audit results are increasingly incorporated into Gap Inc.’s standard
operating procedures and reports, as well as into vendor capacity evaluations. Gap Inc. also plans to develop
outcome-oriented performance indicators to integrate human rights information into business decisions. We
welcome Gap Inc.’s acknowledgement that these efforts are essential to more meaningfully track its performance.
The Guiding Principles expect companies that may be involved with severe human rights impacts to report formallyon their efforts to address them. Gap Inc.’s description of the challenges of stemming forced labor by female garment
workers under the Sumangali scheme in Southern India is one of several compelling examples of this. We are also
pleased to see Gap Inc. explain its approach to materiality in reporting on its human rights performance. From a
Guiding Principles perspective, materiality assessments regarding human rights risks need to fully reflect the severityof impacts on affected stakeholders; it will be important to review this aspect as Gap Inc.’s approach evolves.
Operational-level grievance mechanisms are a formalized means for affected stakeholders to raise concerns aboutcompany impacts in order to seek remedy. Where workers are represented by trade unions, industrial relations
processes are themselves an important grievance mechanism. Gap Inc.’s efforts to support workers’ freedom of
association (for example, in Cambodia) are important in this regard. Gap Inc. can also build on lessons it has learned
from engaging credible third parties to help establish and operate effective grievance mechanisms.
The Guiding Principles recognize that there are many ways in which companies can seek to build leverage to address
endemic human rights challenges, including through collaborative efforts. Systemic weaknesses in building andfire safety in Bangladesh represent a particular priority in this regard. Collaboration—with other brands, retailers,
trade unions, civil society, suppliers, and the Bangladeshi Government—is essential to tackle this acute challenge.
We regret that many North American brands, including Gap Inc., felt it was necessary to form a separate Alliance forWorker Safety, rather than join the European-driven Accord, which has broad stakeholder and institutional support.
It is imperative to avoid duplication, inconsistency or confusion between the two initiatives. Observers of both
initiatives will ultimately look for what results are delivered for workers. Experience from Gap Inc.’s own fire andbuilding safety program, with its emphasis on worker empowerment, safety, and Freedom of Association, should
contribute towards advancing tangible improvements on the ground. Gap Inc. also has an important role to play indriving transparency and accountability to demonstrate the achievement of collective commitments and sustainable,
tangible improvements for workers.
Experience shows that companies that are willing to acknowledge challenges and seek shared solutions in meeting
their responsibility to respect human rights are best placed to build stakeholder understanding and trust. Gap Inc.
has come a long way from its first S&ER report in 2003, and we encourage Gap Inc. to continue to be transparent andreceptive to stakeholder concerns. We recognize Gap Inc.’s commitment to further aligning its approach with the
Guiding Principles, and hope these comments can support its ongoing efforts to put respect for rights into practice.

139

GRI-G4 CONTENT INDEXGENERAL STANDARD DISCLOSURES
GRI
Indicator

ReportSectionCoverage

UNGC
Principle

Full

8

CDP
Indicator

Supporting Documentation

STRATEGY AND ANALYSIS
G4-1

CEO message

ORGANIZATIONAL PROFILE
G4-3

Our Company

Full

G4-4

Our Company

Full

G4-5

Our Company

Full

G4-6

Our Company

Full

G4-7

Our Company

Full

Certificate of Incorporation

G4-8

Our Company

Full

Gap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report

G4-9

Our Company

Full

Gap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report

G4-10

Company: Our Company

Partial6

AF32

Employees: Diversity and Inclusion Data

G4-11

Employees

Partial3G4-12Found within each sectionof the report

Full

G4-13

Company: Our Company

Full

8.1

Gap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report

Human Rights: Operating Context andStrategy
Environment: Operating Context andStrategy
G4-14Company: Our Company

PartialGap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report

Human Rights: Operating Context andStrategy
Environment: Operating Context andStrategy
G4-15

Company: CEO Letter; Stakeholder
Engagement; Human Rights Policy and
Code of Vendor Conduct; California
Transparency in Supply Chains Act

Full

8

Gap Inc. Code of Vendor Conduct
Gap Inc. Human Rights Policy

Human Rights: UN Guiding Principles;Working with Factories; Capacity Building; Bangladesh Fire and Building Safety
Environment: Energy and Climate,
Water, Waste, ProductCommunity: Volunteering; Youth;
Advancing Women
G4-16

Company: Stakeholder Engagement

Full

Human Rights: Monitoring and Remediation; Bangladesh Fire and Building
SafetyIDENTIFIED MATERIAL ASPECTS AND BOUNDARIES
G4-17

Company: Reporting and Materiality;
Political Engagement and Public Policy

Full

G4-18

Found within each section of the report

Full

140

GRI-G4 CONTENT INDEXGENERAL STANDARD DISCLOSURES
GRI
Indicator

ReportSectionCoverage

UNGC
Principle

CDP
Indicator

Supporting Documentation

IDENTIFIED MATERIAL ASPECTS AND BOUNDARIES (continued)
G4-19

Company: Reporting and Materiality

Full

G4-20

Human Rights: UN Guiding Principles
on Business and Human Rights

G4-21

Environment: Operating Context
and Strategy

Full

G4-22

Company: Reporting and Materiality

Full

G4-23

Environment: Our Footprint; Waste
Community: Connecting YouthFull

Gap Inc. Human Rights Policy

STAKEHOLDER ENGAGEMENT
G4-24

Company: Stakeholder Engagement;
Reporting and Materiality

Full

G4-25

Human Rights: Stakeholder
Engagement

Full

G4-26

Environment: Reporting and Materiality

Full

G4-27

Company: Reporting and Materiality

Full

REPORT PROFILE
G4-28

This report covers Gap Inc.’s 2011 and2012 fiscal years.
Company: Reporting and Materiality

G4-29

Our last report covered Gap Inc.’s 2009
and 2010 fiscal years.

G4-30

We publish our Social and Environmental Responsibility Report biennially.
Company: Reporting and Materiality

G4-31

social_responsibility@gap.com

G4-32

This is a GRI referenced report, using the
GRI G4 Guidelines

G4-33

No external assurance received forthis report.

Full

0.2

2009 – 2010 Social Responsibility ReportFull

Gap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report

8.6, 8.6a,
8.6b,8.6c,
8.7,8.71,8.7b

GOVERNANCE (G4-35 to G4-38 are found in gray text as they are fully disclosed though not required for this reporting level)
G4-34

Company: Our Leadership

Full

Gap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report

Human Rights: Our Leadership

Full

Environment: Our Leadership

Full

Company: Our Leadership

Full

10

Gap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report

Environment: Our Leadership

Full

10

Gap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report

AF5
G4-35
AF5
G4-36
AF5
G4-37
AF5
G4-38

141

GRI-G4 CONTENT INDEXGENERAL STANDARD DISCLOSURES
GRI
Indicator

ReportSectionCoverage

UNGC
Principle

CDP
Indicator

Supporting Documentation

ETHICS AND INTEGIRTY
G4-56
AF1

Company: Human Rights Policy and
Code of Vendor Conduct; California
Transparency in Supply Chains Act;
Code of Business Conduct

Full

Gap Inc. Code of Business Conduct
Gap Inc. Code of Vendor Conduct

GRI-G4 CONTENT INDEXSPECIFIC STANDARD DISCLOSURES
GRI
Indicator

ReportSectionCoverage

UNGC
Principle

CDP
Indicator

Supporting Documentation

Full

7,8,9

12.2, 12.3

2012 CDP Investor Report

CATEGORY: ENVIRONMENTALASPECT: ENERGY | Environment: Energy and Climate.

G4-EN3

Environment: 2012 Environmental
Data Charts: 1) 2006-2012 US Energy
Consumption, 2) 2012 US Energy
Consumption by Source, and
3) 2010–2012 Energy Consumption
by Operation

ASPECT: EMISSIONS | Environment: Energy and Climate; Data.

G4-EN15

Energy and Climate

Full

7,8,9

7.2, 7.3, 7.4,
8.2 ,8.5, 8.8,
9.1, 9.2

2012 CDP Investor Report

G4-EN16

Energy and Climate

Full

7,8,9

7.2, 7.3, 7.4, 8.3,
8.5, 8.8, 10.1,
10.2

2012 CDP Investor Report

G4-EN17

Energy and Climate

Full

7,8,9

3.3, 3.3a, 3.3b,
3.3c2012 CDP Investor Report

G4-EN19

Energy and Climate

Full

7,8,9

2012 CDP Investor Report

ASPECT: PRODUCTS AND SERVICES | Environment: Water; Waste; Product.

G4-EN27

Energy and Climate;
Water; Waste; ProductPartial

7,8,9

3.2

Gap Inc. Code of Vendor Conduct

AF17
ASPECT: SUPPLIER ENVIRONMENTAL ASSESSMENT | Human Rights: Data. Environment: Operating Context and Strategy; Our Footprint; Water; Waste; Product.

G4-EN33
AF3

Human Rights: Data
Environment: Operating Context andStrategy; Water; Waste; Product

Full

7,8,9

Gap Inc. Code of Vendor Conduct

CATEGORY: SOCIALLABOR PRACTICES AND DECENT WORKASPECT: EMPLOYMENT | Employees: Operating Context and Strategy

G4-LA1

Employees:
2012 Diversity and Inclusion data: 1) Ethnic Demographics, 2) North American
Gender Demographics

Full

6

G4-LA2

Employees: Benefits and Rewards; Data

Full

6

142

GRI-G4 CONTENT INDEXSPECIFIC STANDARD DISCLOSURES
GRI
Indicator

ReportSectionCoverage

UNGC
Principle

CDP
Indicator

Supporting Documentation

CATEGORY: SOCIALLABOR PRACTICES AND DECENT WORKASPECT: OCCUPATIONAL HEALTH AND SAFETY | Employees: Data

G4-LA6

Employees:
2012 Workplace Health and Safety Data

Full

6

ASPECT: TRAINING AND EDUCATION | Employees: Career Development

G4-LA9

Employees: Career Development

Partial

1, 6G4-LA10

Employees: Career Development

Full

1, 6

Gap Inc. Retail Academy

ASPECT: DIVERSITY AND EQUAL OPPORTUNITY | Employees: Diversity and Inclusion

G4-LA12

Employees: Diversity and Inclusion

Full

1, 6

Gap Inc. Code of Business Conduct

HUMAN RIGHTSASPECT: HUMAN RIGHTS GRIEVANCE MECHANISMS | Human Rights: Operating Context and Strategy; UN Guiding Principles on Business and Human Rights

G4-HR12

Human Rights:
UN Guiding Principles on Business andHuman Rights

Full

1,2

Gap Inc. Code of Vendor Conduct

ASPECT: HUMAN RIGHTS ASSESSMENT | Human Rights: Working with Factories; Monitoring and Remediation

G4-HR9Human Rights:
Monitoring and Remediation

Full

1,2

Gap Inc. Code of Vendor Conduct

ASPECT: FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING | Human Rights: Operating Context and Strategy; Freedom of Association

G4-HR4

Human Rights:
Working with Factories; Freedom of
Association

Full

1,2,3

Gap Inc. Code of Vendor Conduct

ASPECT: SUPPLIER HUMAN RIGHTS ASSESSMENT | Human Rights: Working with Factories; Monitoring and Remediation; UN Guiding Principles on Business and Human Rights; Data

G4-HR11
AF3

Human Rights:
Monitoring and Remediation; Data

Full

1,2

Gap Inc. Code of Vendor Conduct
Gap Inc. Human Rights Policy

ASPECT: FORCED COMPULSORY LABOR | Human Rights: Working with Factories; Forced Labor

G4-HR6

Human Rights: Forced Labor

Full

1,2,4

Gap Inc. Code of Vendor Conduct
Gap Inc. Human Rights Policy

Full

1,2,5

Gap Inc. Code of Vendor Conduct
Gap Inc. Human Rights Policy

ASPECT: CHILD LABOR | Human Rights: Child Labor

G4-HR5

Human Rights:
Monitoring and Remediation

SOCIETYASPECT: LOCAL COMMUNITIES | Human Rights: Operating Context and Strategy; Working with Factories; Monitoring and Remediation

G4-SO2
AF3

Human Rights:
Monitoring and Remediation
Environment: Operating Context andStrategy; Our Footprint

Full

1, 2, 7, 8, 9

Gap Inc. Human Rights Policy

1, 7

Gap Inc. Human Rights Policy

PRODUCT RESPONSIBILITYASPECT: CUSTOMER HEALTH AND SAFETY | Company Overview: Product Safety

G4-PR1Company Overview: Product Safety

Full

143

GRI-G4 CONTENT INDEXSPECIFIC STANDARD DISCLOSURES
GRI
Indicator

ReportSectionCoverage

UNGC
Principle

CDP
Indicator

Supporting Documentation

CATEGORY: ECONOMICASPECT: ECONOMIC PERFORMANCE

G4-EC1
AF33

Company: Our Company
Employees: Benefits and Rewards
Community: Data

Full

Gap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report
Gap Foundation 2011 Year in Review
Gap Foundation 2012 Year in Review
Be What’s Possible

Employees: Benefits and Rewards
Community: Volunteering; Youth;
Advancing Women

Full

Gap Inc. 2012 Annual Report
Gap Inc. 2011 Annual Report
Gap Foundation 2011 Year in Review
Gap Foundation 2012 Year in Review
Be What’s Possible
Wearecommitted.com

Community: Youth; Advancing Women

Full

Gap Foundation 2011 Year in Review
Gap Foundation 2012 Year in Review
Be What’s Possible
Wearecommitted.com

ASPECT: INDIRECT ECONOMIC IMPACTS

G4- EC7
AF32
and 33G4- EC8
AF32

In performing our Materiality Assessment, GRI’s Apparel and Footwear Sector Supplement released in 2008 was referred to. Due to our biennial reporting cycle, we havechosen to utilize the recently released G4 Guidelines. While in transition to the new Guidelines, we have aligned key Sector Supplement Performance Indicators addedin light blue text, though the Supplement itself has not yet been updated to the G4.

144

RECOGNITION
2011-2012
Gap Inc. was named Yahoo! Finance’s first-ever Company of the YearFor the sixth straight year, Gap Inc. has been named to the Dow Jones Sustainability North American Index (DJSI),
based on an analysis of economic, environmental and social criteria.
Gap Inc. was awarded the 2012 Business Volunteer Program of the Year by CaliforniaVolunteers, as part of the
California Governor’s Volunteering and Service Awards.
For the fourth straight year, Gap Inc. is noted as a top company and retailer in Maclean’s “50 Most Socially
Responsible Corporations” list.
For the sixth straight year, Gap Inc. was chosen as one of the World’s Most Ethical Companies in recognition of ourcommitment to ethical leadership and corporate social responsibility.
For the seventh straight year, Gap Inc. made Corporate Responsibility Magazine’s “100 Best Corporate Citizens” list.
The company’s rankings included: human rights (tied for 1st overall, and 1st in retail/apparel); corporate governance(tied for 1st overall, and 1st in retail/apparel); philanthropy (1st in retail/apparel); and employee relations (2nd in retailand apparel, 4th overall)
Gap Inc. received an Excellence in Greenhouse Gas Management Goal Setting Certificate from the U.S. Environmental
Protection Agency, The Climate Registry, the Center for Climate and Energy Solutions and the Association of Climate
Change Officers for publicly reporting and verifying GHG inventories and setting an aggressive absolute GHG
emissions reduction goal.
For the seventh year in a row, Gap Inc. achieved 100 percent on The Human Rights Campaign’s Corporate Equality
Index—a tool to rate major corporations on their treatment of gay, lesbian, bisexual and transgender employees,
consumers and investors.

145