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"New employees within Gap Inc’s sourcing organization receive training on

our COVC, as they are another important touchpoint for our relationships with our sourcing

facilities."

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Gap Inc. has a Code of Vend

or Conduct (COVC) that applies to all facilities that produce

branded goods for Gap Inc. or any of its subsidiaries, divisions, affiliates or agents, which states

that the company prohibits the use of “involuntary labor of any kind, including prison labor,

debt

bondage, slave labor or forced labor by governments.".2

 

Ne

w employees within Gap Inc’s sourcing organization receive training on

our COVC, as they are another important touchpoint for our relationships with our sourcing

facilities.5

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We also monitor Unauthorised Subcontracting (UAS), which has high risk for forced labor.5

 

To supplement our own staff, Gap Inc. works to build the capabilities of our suppliers by

conducting worker trainings, participating in multi

-

stakeholder initiatives and forging

partnerships with expert stakeholders and suppliers to address specific huma

n rights issues.6

 

As part of our Global Sustainability long

-

range strategic plan, we have committed to further invest in both internal and external labor

standards trainings for our business partners, of which forced labor will be one component.6

 

We take

extra precautionary measures in countries with high risk of UAS, such as specialized training for

suppliers and facility management.7