Our system of responsible business practices—including policies and procedures, tools and technologies, training programs, stakeholder engagement and more—protects our employees, customers, supply chain partners and workers, and our business.
We have several systems and procedures to identify and manage risks, including those related to human rights and labor, environmental impacts, and other sustainability issues. To prioritize risks and opportunities, we use tools such as our sustainability materiality assessment.
At the enterprise level, The Risk Committee, made up of leaders that represent the Senior Leadership team, provides oversight of the annual Enterprise Risk Assessment (ERA) process. The ERA begins with our Internal Audit team, who conducts an annual risk-assessment survey of more than 60 of the company’s top executives and Board members. The team also interviews a subset of these executives every quarter. The Risk Committee uses these interviews, as well as a review of external factors affecting our company and industry, to develop heat maps that prioritize risks based on the likelihood and severity of their potential impact on the company’s strategic initiatives and business operations. The CEO, Board of Directors and Senior Leadership team sign off and use the ERA to monitor and mitigate risks, as well as to update policies and include in Business Continuity Planning where required.
At the physical asset level, our Business Continuity Planning (BCP) team analyzes, prioritizes and helps mitigate risks to our owned and operated facilities and stores resulting from extreme weather, natural hazards and other external events. The BCP team uses predictive and actual models from the U.S. National Oceanic and Atmospheric Administration (NOAA) and other national and international agencies, which are overlaid against all of Gap Inc.’s facilities for tracking potential and actual impacts. The team uses a risk-assessment tool to determine the event and company risk and the residual risk remaining after preparedness plans are developed.
Our Inclusive, by Design mission informs our approach to stakeholder engagement: Advancing progress on systemic issues such as water resilience, climate change, women’s empowerment, and safe and fair working conditions demands collaboration and jointly developed solutions.
Having operated a variety of factory-focused programs for over two decades, we have established a comprehensive network of stakeholders that we rely on for insight, guidance and accountability. The frequency of our engagement with stakeholders is based on their connection to our business, our ability to impact them and the salience of the issue being addressed. For example, we engage with each stakeholder group at different cadences, depending on salient risks, priorities for our stakeholders, and our own priorities. In addition to our regular check-ins with stakeholders, we might also actively seek out stakeholder engagement when there are developing issues related to specific supply chains, countries, or materials. In these instances, we are typically hoping to learn more about a specific human rights issue or stakeholder need, to proactively mitigate potential risks. In other cases, when issues arise, including violations of our Human Rights Policy, COVC, or COBC, we seek to work with suppliers, unions, worker-representative organizations, and local and international NGOs that have expertise and connections in the that area.
When human rights issues arise, we work with suppliers, unions, worker-representative organizations, and local and international NGOs that have expertise and connections in that area. Our aim is to prioritize the impact of affected parties and come to a resolution that is fair and ethical. We use what we learn to improve how we respond to future issues, and we share insights with other buyers, governments and other stakeholders so these lessons can be applied more broadly.
Our stakeholders include:
Employees: We engage proactively with our employees quarterly to collect their feedback through surveys distributed by our HR team.
Customers: We also solicit feedback from a sample of customers through representative surveys conducted by our Consumer Insights team, including an annual survey that focuses on issues related to sustainability and our product offerings.
To see a list of organizations and initiatives that we belong to or partner with, click here.
Our Human Rights Policy defines our approach and activities to protect against abuses. To ensure that our partners act in line with our standards, we require that all facilities that produce goods for Gap Inc. meet our COVC requirements and Human Rights Policy.
We support and base our policies on the principles outlined in the Universal Declaration of Human Rights (UDHR), the UN Global Compact (UNGC), the OECD Guidelines for Multinational Enterprises and the International Labor Organization’s (ILO) Core Conventions.
Our COVC also sets out our basic expectations for environmental standards to all Tier 1 vendors and suppliers with whom Gap Inc. conducts business. We expect all facilities to comply with relevant environmental laws and regulations, manage their energy use and water impacts, and complete the Higg Index Facility Environment Module annually.
Our global COBC serves as our ethical compass for the commitment to high standards that we make to our stakeholders, customers and one another.
There are several key aspects of how we implement our COBC:
We are diligent about addressing corruption risks, particularly in developing countries with limited rule of law. We have a company-wide program for monitoring, enforcing and addressing any issues related to our Anti-Corruption / Anti-Bribery Policy (page 11 of our COBC), which combines elements from our COBC with anti-bribery requirements under the U.S. Foreign Corrupt Practices Act (FCPA) and other similar laws. The policy and related training programs help employees recognize and avoid corrupt business practices in all aspects of Gap Inc.’s business.
Protecting the privacy rights of our customers and employees is an integral part of building trust. Our comprehensive privacy program includes policies, standards and practices focused on keeping the data we collect secure and respecting privacy rights around the globe.
Our goal is to provide the highest quality experience to our customers while respecting their privacy. We have adopted seven principles that guide our choices as we adopt new products and services: consent, control, fairness, minimization, confidentiality, access and accountability. We also know that security is at the center of any good privacy program, and we use widely accepted security standards and practices to secure personal information.