Under Supply Chain Due Diligence and Verification, it states 'Gap Inc.’s Supplier Sustainability team is responsible for the implementation of our supply chain policies and standards relevant to human trafficking and forced labor. These policies and standards are reflected within the COVC. Assessment & Remediation Specialists – who are locally hired in the countries from which we source, and speak local languages – assess and validate that suppliers are meeting the expectations outlined in our COVC. We have additional requirements designed to protect foreign contract workers employed by vendors. We monitor how foreign contract labor is used at factories producing Gap Inc. branded apparel to help ensure that people are free to work as they choose. Our Foreign Contract Worker (FCW) Requirements specify that workers will not be charged fees, a policy we have had in place for over a decade, and that any fees and costs payable to host governments for the documentation of foreign contract workers will be covered by the facility.

Gap Inc. monitors all first tier branded apparel supplier facilities (including sub-contractors and supporting units) for forced labor and human trafficking, and is in the process of establishing social criteria which will enable us to evaluate working conditions at the mill level.

Our COVC further states that factories 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 factories we monitor, that are primarily conducted by Gap Inc. staff. Initial inspections for new factories are generally coordinated with the requested vendor or factory, and with subsequent full evaluations we aim for more than 50% to be unannounced or semi-announced.'