pg. 5-6

"We recognize that policies and expectations alone are not a sufficient safeguard against forced labor within our supply chain. Our statements lay the foundation for our comprehensive approach to engaging and collaborating with our suppliers to monitor, remediate and continuously improve their performance with regard to responsible labor. Gap Inc.’s Supplier Sustainability team within our Global Sustainability department is responsible for the implementation of our supply chain policies and standards relevant to human trafficking and forced labor, which are reflected within our COVC. Our Supplier Sustainability team members – who are locally hired in the countries from which we source and who speak local languages – assess and validate that suppliers are meeting the expectations outlined in our COVC. We assess risks to especially vulnerable groups, including migrant labor and women in the workplace, and our COVC specifies our management approach towards ensuring free and voluntary labor for these groups. In 2020, COVID-19 limited our ability to conduct on-site audits in some sourcing countries, so we made adjustments to our approach, including the use of virtual assessments. In addition, we conduct desktop reviews of key supplier and worker documents to assess forced labor risks. We also conduct virtual worker interviews for validation of our findings and for further due diligence. When conditions allow, we will resume onsite assessments and supplier trainings in all sourcing countries.

Our COVC also has stringent requirements around foreign contract workers, who are at risk of exploitation through indentured servitude. We monitor how foreign contract labor is used at facilities producing Gap Inc. branded apparel to help ensure that people are free to work as they choose. For more than a decade, we have had a “no fees” policy that applies to foreign contract workers, which requires that any fees and costs payable to host governments for the documentation of foreign contract workers be covered by the facility. Our policy must be upheld throughout the entire employment cycle of foreign contract workers. To protect the rights of contract workers, Gap Inc. also requires suppliers to hold direct employment contracts and agreements with all contract workers. These requirements span recruitment, employment, up to termination of employment, and provide the lens through which our assessors look at policies, practices and conditions in the facility to find indications of forced labor. More information on our policies and procedures on foreign contract workers is available online. The section of our COVC detailing our Foreign Contract Worker Requirements is also available online.

Our COVC further states that facilities must allow “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.” Gap Inc. conducts both announced and unannounced audits in the facilities we monitor, and these are primarily conducted by Gap Inc. staff. Initial assessments for new facilities are generally coordinated with the requested vendor or facility.

Gap Inc. monitors for forced labor and human trafficking in all Tier 1 branded apparel supplier facilities from which we directly source. Facilities from Tier 1 suppliers include cutand-sew production, sub-contractors, and supporting units such as dyeing, embroidery, and wash units. 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. We paused the expansion of this program in 2020 due to a reevaluation of our Tier 2 supplier base and because of COVID19 restrictions. By 2025, we expect to enroll 100% of our strategic Tier 2 mill vendors into industry initiatives such as the Social Labor Convergence Program, which includes assessments on the risk of forced labor.

An increasing number of facilities producing our branded apparel participate in the Better Work program, a collaborative facility monitoring and capability building initiative led by the International Labour Organization (ILO). Facilities participating in Better Work are assessed by specialists employed by the ILO. These assessments are 100% unannounced and assessed against national labor laws and ILO Conventions, which includes instruments that directly cover forced labor."

The company mentions undertaking desktop reviews of key suppliers to assess risk of forced labour (see p. 5). Also, the company states using information on modern slavery prevalence (See below). Therefore, I have left the answer Conducting Desk Research checked.

"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" (p. 9-10)