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'To supplement our own staff, Gap Inc. works to build the capabilities of our suppliersby conducting worker training' this training addresses specific human rights issues - page 5

'providing additional detailed guidance on recruitment' - page 5

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Training

Gap Inc

.

continually strive

s

to become more effective at identifyi

ng 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. .4

 

Our COVC also has stringent requirements around

Foreign Cont

ract 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 o

ngoing training, our Assessment & Remediation team convene

s

regularly to discuss

program effectiveness

and improvements

. In April 2015, based on

a thorough

risk assessment, we

strengthened our

F

oreign

C

ontract

W

orker 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 re

gular assessments of employment agencies.

To supplement

our own staff,

Gap Inc. works to build

the

capabilit

ies of our suppliers

by conducting

worker trainings, participating in multi

-

stakeholder initiatives, and forging partnerships with expert

stakehol

ders and suppliers to address specific human rights issues. Gap Inc. has helped suppliers

improve their capabilities for more than a decade, and created field teams for social & labor capability

building that are dedicated to helping suppliers manage and i

mprove the sustainability of their own

operations. .5