[W]e recommend Gap Inc. review whether [its] “severity” lens [of human rights risk to affected stakeholders] is consistently applied across its activities and business relationships: for example, in its approach to vendor capacity-building, and assessments of non-apparel suppliers...[W]e recommend that Gap Inc. review how and in what ways the results of...engagement [with workers & other affected stakeholders] are formally incorporated into existing systems for risk assessment, mitigation and remediation...From a Guiding Principles perspective, materiality assessments regarding human rights risks need to fully reflect the severity of impacts on affected stakeholders; it will be important to review this...We regret that...Gap Inc., felt it was necessary to form a separate Alliance for Worker Safety, rather than join the European-driven Accord...[in response to the Apr 2013 Bangladesh factory collapse]...We recognize Gap Inc.’s commitment to further aligning its approach with the Guiding Principles, and hope these comments can support its ongoing efforts to put respect for rights into practice...