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Responding department: Social & Environmental Responsibility

Stock exchange symbol: (GPS:US)

Does your company have a publicly available commitment to respect human rights?


Gap Inc. seeks to ensure that the people who work at our company and in our supply chain are treated with fairness, dignity and respect—an aspiration that is born out of the belief that each life is of equal value, despite the systemic inequities around the world. As part of upholding this belief, we have a stand-alone Human Rights Policy at Gap Inc. to help promote equality and respect the rights of our employees, and the workers in our supply chain. Our Human Rights Policy applies globally within our wholly-owned operations and across our branded apparel supply chain. It highlights our commitment to respect fundamental human rights throughout these operations, as well as our intent to promote human rights within our sphere of influence. Our policy recognizes and draws upon the United Nations Guiding Principles on Business and Human Rights, as well as other recognized international policy frameworks. One of the most powerful ways that we bring our Human Rights Policy to life is through the enforcement of our Code of Vendor Conduct (COVC). Our COVC seeks to safeguard workers’ rights in the factories where Gap Inc. products are made.

LINKS: [link] [link]

How are human rights governed in your company?

Our Social and Environmental Responsibility (S&ER) Department is directed by Bobbi Silten, Senior Vice President of Global Responsibility at Gap Inc. and President of Gap Foundation. Bobbi reports to Michelle Banks, Executive Vice President, Global Responsibility, General Counsel, Corporate Secretary & Chief Compliance Officer, who reports to directly to Gap Inc.’s Chairman and CEO. Gap Inc.’s Board of Directors oversees our company’s social and environmental responsibility efforts, receiving annual updates from Bobbi. Furthermore, Bobbi regularly meets with Michelle and our CEO to discuss current S&ER issues and progress. The Board of Directors has a Governance and

Sustainability Committee, which is tasked with assisting the Board in fulfilling its oversight responsibilities relating to the company’s corporate governance matters, including the development of corporate governance guidelines and oversight of the company’s programs, policies and practices relating to social and environmental issues and impacts.

How are human rights managed within your company?

The Gap Inc. Code of Business Conduct (COBC) sets forth the company’s expectation that our own employees embody our “Do: what’s right” value and is our foundation for promoting a responsible and ethical work environment. Human rights management beyond our owned and operated facilities is driven through our Vendor Engagement & Monitoring (VE&M) efforts. Through our VE&M program, we seek to build sustainable human rights practices in garment factories by investing in workers’ well-being and rights, vendor capacity building, and factory monitoring and remediation. In 2013, we monitored 97.4 percent of our supply chain in 32 countries. As part of our VE&M Program, we emphasize remediation and the implementation of corrective action plans to address any violations that are found. We work with factory management to agree on specific time-bound improvement plans when violations are identified. We monitor progress through follow-up visits and on-site meetings with unions if they are present in a factory. We collaborate with local stakeholders to help identify and address factory issues when they may have more direct access and influence. Beyond fixing the issues we identify, we also make efforts to conduct root cause analyses and review management systems to assess the underlying causes of ongoing violations. We believe that the most sustainable way to address problems over the long term is to help vendors understand the conditions that allow violations to recur.

What is the company’s approach to the engagement of stakeholders (including workers, and local communities impacted by the company’s activities), on human rights issues?

Collaborative engagement continues to be a guiding principle of both our business strategy and our social and environmental initiatives. Through various types of partnerships—with labor rights organizations, environmental groups, multi-stakeholder initiatives, community-based organizations, trade unions, industry associations, investors,academics, factory owners and managers, workers, shareholders, governments, and other companies—we are better able to make sense of the universe of issues we proactively seek to address. Working with such diverse groups and organizations not only helps us make a greater impact on key human rights issues, it also helps our business operate in a smarter, more informed manner. Through formal memberships in multi-stakeholder initiatives such as the Alliance for Bangladesh Worker Safety and the Ethical Trading Initiative, we are able to address systemic social and environmental issues that require a broad set of actors from many sectors. We are also a founding member of the International Labor Organization’s Better Work program to support vendor compliance with labor standards and laws.

On a less formal basis, we partner with key labor rights organizations to address singular issues that require remediation. The nature of our engagement depends on the demands of a given issue. We also contribute to collective efforts in a variety of ways. We believe that being an effective contributor to any multi-stakeholder effort requires knowing when to lead, and when to follow. We are at the forefront in several collective efforts, and we have also followed other companies and stakeholders when their expertise and assets are better suited to take the lead.

Priority human rights issues: What are some of the priority human rights issues for your company?

The company selected the following from a check list:

  • Health (including environmental health, workplace health & safety)
  • Workplace diversity / non-discrimination
  • Forced labour and human trafficking (including in supply chains)
  • Access to water
  • Women
  • Children (including child labour)

Actions on health

Alliance for Bangladesh Worker Safety, Vendor Engagement & Monitoring program

Actions on workplace diversity / non-discrimination

Gender equity and equal pay program

Actions on forced labour and human trafficking

Vendor Engagement & Monitoring program, Code of Vendor Conduct Policy

Actions on access to water

Mill Engagement program, Women & Water program

Actions on women

P.A.C.E. program, Gender equity and equal pay program, Women & Water program

Actions on children (including child labour)

Vendor Engagement & Monitoring program, Code of Vendor Conduct Policy

How are human rights commitments and information about how the company addresses its human rights impacts communicated, internally and externally?

Since our inaugural Social & Environmental Responsibility (S&ER) Report in 2003, we have continued to build our reporting on the principles of transparency, accountability, and honesty. We believe that the value of reporting can only be fully captured when it frankly discusses successes and failures, challenges and opportunities. We publish a new S&ER Report every two years, while updating our data annually. The scope of our report covers our companywide and global efforts across all brands. In our view, biennial reporting is an appropriate timeframe given the systemic and global nature of the issues our company seeks to proactively address. It also allows us to allocate our time and resources more effectively between programmatic work and communications. In addition to our public report, we provide regular, separate reports on our social and environmental progress to the Dow Jones Sustainability Index, the Ethical Trading Initiative, Social Accountability International, Carbon Disclosure Project, the United Nations Global Compact (UNGC), and Clinton Global Initiative. Providing these issue-specific reports to key stakeholders helps focus and advance our work with them to continually improve our social and environmental responsibility efforts. Link to our S&ER Report website: [link]

What provisions does your company have in place to ensure that grievances from workers and affected communities or individuals are heard, and can you provide examples of remedies provided?

We recognize the importance of maintaining grievance mechanisms, as a means for affected stakeholders to raise concerns about a company’s impacts. For our own employees, the Code of Business Conduct encourages employees to voice their concerns via Gap Inc.’s Code Hotline. At the operations level, our monitoring teams are flagged to workers as the main path to convey grievances. Gap Inc. has several initiatives that further demonstrate our support of expressing grievances, notably the Alliance Worker Helpline in Bangladesh, recent measures taken in Myanmar, and our policy on freedom of association. The Alliance For Bangladesh Worker Safety is committed to providing factory workers with the opportunity to voice safety concerns so that they can be heard and acted upon in a timely manner. The Alliance Worker Helpline provides workers with a reliable 3rd-party reporting channel that will allow them to raise safety concerns anonymously.

In Myanmar, where Gap Inc. recently began sourcing, audit results at two factories led to the following concrete measures that can help workers express and resolve grievances:

  • Development of formal policies, procedures and documentation for grievance mechanisms;
  • Inclusion of “no retaliation” and confidentiality provisions into policy and procedures for addressing grievances;
  • Provision of training to supervisors and workers on workplace etiquette, code of conduct and grievance channels; and
  • Creation of an investigation process and dedicated committee for addressing grievances. Lastly, Gap Inc. supports workers’ freedom of association.

The right to organize and bargain collectively allows those workers who so choose to find a common voice. It provides workers with an important framework for engaging with management on their rights to receive fair wages, sufficient benefits, and the ability to do their work in fair and decent conditions. Our Code of Vendor Conduct (COVC) explicitly states “workers are free to join associations of their own choosing. Factories shall not interfere with workers who wish to lawfully and peacefully associate, organize, or bargain collectively. The decision whether or not to do so should be made solely by the workers.”

Which external and collaborative human rights initiatives does your company participate in, and what is the nature of your involvement?

As mentioned above in our response to Question #4, we are involved in many forms of engagement and partnership. Furthermore, we work with CARE International and the International Center for Research on Women (ICRW) to help female garment workers succeed in work and in life through the Gap Inc. P.A.C.E. program. We are also active members of the Ethical Trading Initiative and the International Labor Organization’s Better Work program. We maintain formal memberships in multi-stakeholder initiatives such as Ceres, the Ethical Trading Initiative and others, through which we are able to address systemic social and environmental issues that require a broad set of actors from many sectors. Gap Inc. partners more informally with key labor rights organizations to address singular issues that require remediation.

Lastly, in 2012 we began implementing our own Fire and Building Safety Action Plan in Bangladesh. Since that time, we have joined with other leading apparel brands and retailers, fire and building safety experts, the Bangladeshi government, policy makers, and leading non-governmental organizations to address fire and building safety in Bangladesh through the creation of the Alliance for Bangladesh Worker Safety. The Alliance’s collective work has resulted in completed inspections at all of the 587 factories in Bangladesh from which its members source apparel products. In its first year, the Alliance also provided basic fire safety training to more than one million workers and managers across factories that manufacture apparel for its members.

Which are the key one, two or three elements of your approach to human rights that been developed or amended since June 2011? Please indicate if these actions were in response to the UN Guiding Principles.

As a part of our effort to better understand how we can integrate the UN Guiding Principles into our policies and programs, Gap Inc. asked Shift to review our Social & Environmental Responsibility report and broader human rights management program, and offer reflections on the implications of the UN Guiding Principles for our efforts to respect human rights in our global supply chain. As a result of this partnership, we have moved to develop targeted and tailored country approaches, to best respond to and address unique circumstances in countries such as Myanmar and Bangladesh.

Responsible sourcing in Myanmar

As the first U.S. retailer sourcing apparel in Myanmar, we understood the need to evaluate and address risks as well as help develop responsible sourcing practices in the country’s garment industry. Considering Myanmar’s long period of isolation and early stage of development, we knew that there would be a number of challenges to address that affect the apparel industry and pose risks to garment workers and our business. As such, we engaged and continue to engage in extensive, ongoing consultations with key stakeholders across sectors to understand how human rights issues and the local operating environment in Myanmar impact and may be affected by our business. These consultations have involved in-person meetings and sustained dialogue with civil society and worker organizations in Myanmar, U.S. government agencies, the ILO and international NGOs with specialized expertise in Myanmar. Our due diligence, risk assessment and mitigation efforts in Myanmar have been informed by the UN Guiding Principles and the core principles that guide our business, which are described in such documents as our Human Rights Policy, Code of Business Conduct, Anti-Corruption Policy and Code of Vendor Conduct (COVC). These policies are grounded in internationally recognized standards, including the Universal Declaration of Human Rights, the International Labor Organization’s (ILO) Core Conventions and the OECD Guidelines for Multinational Enterprises. Consistent with these standards and the Guiding Principles in particular, our approach in Myanmar has involved ensuring appropriate policies are in place, assessing risks to workers, taking action to mitigate and prevent risks and publically reporting on our progress. Worker safety in Bangladesh As noted in question 8, following the tragic events of Rana Plaza in April 2013, Gap Inc. decided to expand efforts from its Fire and Building Safety Action Plan by partnering with leading North American apparel companies, retailers and brands in the summer of 2013 to launch the Alliance for Bangladesh Worker Safety. The core mission of the Alliance is to improve the safety of the women and men who make their living in Bangladesh’s ready-made garment sector. It represents a 5-year, $50 million effort to improve the fire safety and structural integrity of factory buildings through a rigorous inspection and training regime, which is already well underway.


What are some of the obstacles and challenges that your company encounters in implementing its human rights commitments?

Gap Inc. has been implementing various vendor capacity building programs for nearly ten years. Our approach is based on the idea that when social responsibility systems are run internally within a factory or vendor’s operations, they will become more sustainable. Over the years, we have found that our existing “one size fits all” approach to capacity building has limitations as we seek to create a lasting impact. The challenges and opportunities for improvement within a factory can vary greatly, which is why we are in the process of evolving our capacity building efforts toward a case management approach. We will be implementing tailored programs in factories that are either of strategic importance to our business or that have persistent compliance issues against our Code of Vendor Conduct (COVC). Our new sourcing strategy, which calls for working with fewer vendors in a deeper way, will help facilitate this work by supporting closer relationships that better meet the needs of individual factories. With a case management approach in mind, we are in the process of designing and implementing a needs-based assessment to identify our vendors’ capacity building needs. We are in the early stages of this new approach, and will continue to partner with the Global Social Compliance Programme to help ensure that our efforts complement other industry initiatives.