pg. 4
"Wherever we employ people directly, we do so in accordance with our Human Rights Policy, Code of Business Conduct and in compliance with local labor laws. Members of our store management team visit our retail stores on a regular basis to ensure that our policies are put into practice, and our loss prevention and audit teams carry out annual assessments of our stores. Similar internal audit processes are carried out in respect to practices within our distribution centers."
pg. 7
"For our Licensing business that launched in 2020, we require all factories considered for producing licensed product to submit a recent third-party audit report from an approved auditing firm before they are approved to begin production. Our teams review these audits and will reject the factory for production if forced labor is found."
Audits (self-reporting):
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 (p. 6)
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. (p5)
Site visits (self-reporting):
We also monitor unauthorised subcontracting (UAS), which has high risk for forced labor.
We take extra precautions in countries with a high risk of UAS by offering specialized
awareness training for suppliers and facility management, and by conducting site visits to
ensure our product is being manufactured in the appropriate designated facility (p7)