'Gap Inc.’s Supplier Sustainability team is trained to recognize situations where a facility may be using forced or involuntary labor, and is also trained to assess compliance with our company’s Foreign Contract Worker requirements. We publicly report aggregate findings of assessment results at the factories that make our branded apparel on our company website.'

Gap Inc. continually strives to become more effective at identifying and correcting issues in our supply chain, which can be hard to detect, even for a well-trained and experienced eye. Gap Inc.’s Supplier Sustainability team works directly with factory management and workers in the factories we monitor. Our COVC also has stringent requirements around Foreign Contract Workers, who are at risk of exploitation by indentured servitude. For over a decade, we have had a “no fees” policy that applies to Foreign Contract Workers, and also have requirements that cover the entire employment cycle of Foreign Contract Workers. Our 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 factory to find indications of or risks to forced labor.

In addition to ongoing training, our Assessment & Remediation team convenes regularly to discuss program effectiveness and improvements. In April 2015, based on a thorough risk assessment, we strengthened our Foreign Contract Worker requirements and updated them by providing additional detailed guidance on recruitment, fees, employment contracts, and onsite policies and practices, including equal treatment and non-discrimination. Additionally, we added a requirement for our vendors to conduct due diligence and regular assessments of employment agencies.