pg. 3

"POLICIES

Our efforts to address human trafficking in the apparel industry are guided by our Human Rights Policy,

which is founded on the principles outlined in the United Nations Universal Declaration of Human Rights (UDHR) and the International 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 supply chain. This policy establishes key principles that guide how we run our business, as well as the core issues that we work to address.

Gap Inc. also has a Code of Vendor Conduct (COVC) that applies to all facilities that produce branded goods for Gap Inc. or any of its subsidiaries, divisions, affiliates or agents, which states that the company prohibits the use of “involuntary labor of any kind, including prison labor, debt bondage, slave labor or forced labor by governments."

Our Code of Business Conduct (COBC) requires our employees to act ethically and with integrity at all times. It also includes provisions on salient human rights issues. All employees are required to complete the Principles of Integrity: Code of Business Conduct Overview training course to ensure their understanding of our commitments."

pg. 5

"In signing Gap Inc.’s VCA, which incorporates our COVC, Gap Inc. suppliers agree to comply with the following:

“All applicable laws, rules and regulations … these laws include, but are not limited to, laws relating to the employment conditions of their respective employees 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.”

I have checked Code of conduct includes modern slavery provisions because the COVC prohibits modern slavery (See above p. 3)

I have changed Compliance with the law Beyond tier 1 to Tier 1 because there is no evidence of this applying to Tier 2.

I have changed contracts include clauses (beyond tier 1) to Tier 1 because there is no evidence of the COVC or the Vendor Compliance Agreement to apply to suppliers further down the chain.

I checked labour rights because the VCA includes suppliers to comply with labour or workers rights (see above and p. 5)

I changed prohibition of forced labour (beyond tier 1) to Tier 1 because there is no evidence of this applying to Tier 2.

I checked prohibits child labour because "the COVC contains provisions related to forced labor, child labor, foreign contract workers and identity document retention" (p. 4-5).

I also checked prohibits charging recruitment fees and protection of migrant workers Beyond Tier 1 because the "Foreign contract worker requirements are a sub-section of our COVC"(p.8) and the company signed the committment to responsible recruitment that includes the following: "We commit to work with our global supply chain partners to create conditions so that: No workers pay for their job; Workers retain control of their travel documents and have full freedom of movement; and All workers are informed of the basic terms of their employment before leaving home" (p.8) and the company specifies that "We have satisfied these requirements of the Commitment to Responsible Recruitment in our Tier 1 branded apparel supplier facilities" (p. 9). "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" (p. 10). "For more than a decade, we have had a “no fees” policy that applies to foreign contract workers" (p. 5)