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"EVALUATING AND MANAGING RISKS

Gap Inc. works with governments, NGOs, and trade unions, and monitors resources – such as the U.S. Department of State’s Trafficking in Persons Annual Report and the Global Slavery Index – to identify high risk areas in our supply chain. We adopt a comprehensive view of the industry and areas of risk and focus our efforts where we do business and where our programs can have the greatest impact.

Further, we have built a map of our suppliers’ Tier 2 textile mill locations and have conducted due diligence in textile mills that are located in areas that are deemed high risk. We have communicated responsible recruitment requirements to Tier 2 mills in Taiwan and South Korea where there is elevated risk to foreign contract workers; we expect that suppliers in those countries to comply with our requirements by the end of 2020. We will be following-up with those facilities to assess progress when COVID-19 travel restrictions to these countries are lifted. Details on our efforts to protect the rights of foreign contract workers in Taiwan mills can be found online.

Subcontracting is a common practice in the apparel industry, used by suppliers to manage production capacity and fulfill large orders. However it can pose a risk. UAS is problematic because suppliers may outsource production to facilities that we have not approved and that do not uphold our requirements for safe, fair labor practices and working conditions. Smaller, unauthorized units may have labor practices that put workers at risk, and are beyond the view of our assessment and remediation team. Collaboration between our sustainability and sourcing teams, including knowledge sharing on how to spot subcontracting, can help us address UAS issues since incidents can be difficult to detect through the periodic facility assessments conducted by our sustainability field team. In countries with high risk of UAS, we take precautionary measures, such as specialized training for suppliers and facility management.

Our Supplier Sustainability, Quality Assurance and Merchandising teams seek to prevent and detect UAS. If a UAS case is found, we investigate, require remediation, and may impose financial chargebacks, or, in severe or repeat cases, we will terminate our business with the supplier.

We immediately escalate UAS incidents, and take the following steps:

Require the unauthorized facility to immediately stop production of any Gap Inc. branded apparel.

Require all goods (finished or unfinished) be returned to a facility approved by Gap Inc., segregated and held until the issue is resolved.

Lead an investigation to look for and address any critical issues in the unauthorized facility. Require the approved facility to register for management systems training as a preventative measure, and ensure that the facility invests in systems to prevent future violation.

In addition to helping us identify UAS and foreign contract workers, risk-mapping has identified the particular risks that refugee workers may face. We are committed to partnering with a broad set of stakeholders to confirm that our vendors have the appropriate capabilities and infrastructure to make opportunities for employment and fair, decent working conditions available to refugees.

Beyond our Tier 1 and 2 facilities, we have also engaged stakeholders to address the risk of forced labor deeper in the supply chain. When it comes to the raw materials used for our products, we recognize that forced and child labor is a risk, particularly within cotton cultivation. Cotton supply chains are often opaque, complex, and can involve traders and agents that facilitate the exchange of cotton and yarn between the different stages of production. Considering the evidence on forced labor in Uzbekistan’s cotton industry, we have signed the Cotton Pledge led by the Responsible Sourcing Network and have worked to educate and influence our suppliers and facilities on this issue. In 2018, based on evidence of forced child labor and/or forced labor within the cotton fields of Turkmenistan, we have expanded our policy to make it clear that we will not accept any clothing manufactured with fabrics that were knowingly made from Uzbek or Turkmen cotton.

We also recognize that a significant amount of the world’s cotton supply is grown and spun in the Xinjiang region of China and we have taken steps to better understand how our global supply chain may be indirectly impacted. Our efforts include working with our suppliers and actively engaging with industry trade groups, expert stakeholders, and other partners to learn more and advance our shared commitment to respecting human rights, in addition to increasing efforts to trace the cotton and other inputs used to manufacture our products back to their source. We can confirm that we do not source any garments from the Xinjiang region.

More broadly, we regularly explore new solutions that will give us meaningful insights into the origins of the raw materials in our products and how those who harvest them are impacted. We understand that there are human rights risks in our raw materials supply chain and are diligently working to manage these risks. We recognize that these risk assessments also require supporting enforcement processes, which can include country of origin declarations from suppliers, the use of fiber-tracing technologies, and the collection of documents that provide visibility into the flow of cotton and other materials that may enter our supply chain. We are using several technologies and partnerships to help us evolve and mature our approach to enforcing our standards on cotton.

As always, we will continue to actively collaborate with other brands and key stakeholders to explore and implement solutions.

More information on our commitment to transparency through disclosures such as Know The Chain and the Corporate Human Rights Benchmark is available online."

I have changed the answer from No to Yes as the evidence above does not answer this metric.