"Our efforts to address human trafficking in the apparel industry are guided by our Human Rights Policy" p. 3. They provide a link to this in their statement.

AND

"Gap Inc. also has a Code of Vendor Conduct (COVC) that applies to all facilities and third-party licensees 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'" p.3.

My comment: They do not provide a link to this in statement but can be found within their Human Rights Policy. It includes policies prohibiting child labour and forced labour, policies on recruitment fee chargeback, policies protecting migrant workers and policies protecting wages and freedom of association. Assumed all Tier 1.

On 'suppliers comply with laws and company policies':

"Prior to accepting any order for a Gap Inc. branded product, our suppliers are required to sign our Vendor Compliance

Agreement (VCA), a legally binding document that is a condition of doing business with Gap Inc" p.4.

My comment: This incorporates the COVC above. See p. 4 of statement.

My comment: The statement does mention Tier 2 provisions on forced and child labour, but these are not clear and the statement does not explicitly define how they tackle and prevent modern slavery.

"In 2017, we defined and communicated social criteria to Tier 2 fabric vendors, including production facilities and subcontractors. These social criteria include provisions involving forced and child labor. We have expanded an augmented version of our Assessment and Remediation program into our Tier 2 strategic textile mills, enabling us to directly evaluate working conditions at the mill level. In 2021, we ... ended the year with 75% of Tier 1 and 40% of strategic Tier 2 strategic mills participating in SLCP and/or ILO Better Work." p.6

Further comment: This metric also does not measure supplier engagement.

Pg. 4

“The COVC that is used for the assessments contains provisions related to forced labor, child labor, foreign contract workers and identity document retention.”

pg. 8

“In 2018, we joined the American Apparel & Footwear Association’s and Fair Labor Association’s Commitment to Responsible Recruitment, a proactive industry effort to address potential forced labor risks for migrant workers in the global supply chain. Per the commitment: “As an industry and as individual companies, we are committed to the fair treatment of workers in the apparel, footwear, and travel goods supply chains. One important part of this ongoing effort is working together to eliminate conditions that can lead to forced labor in the countries from which we source products. 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.

Therefore, companies who sign the Commitment to Responsible Recruitment agree to do the following:

• Incorporate the Commitment to Responsible Recruitment into their company social compliance standards, such as their code of conduct, before December 31, 2019.

• Periodically report on their actions to imbed elements of the Commitment to Responsible Recruitment in company’s policies and processes through their sustainability reporting and/or modern slavery legal disclosures.””