Gap Inc. 2015 - 16 CSR Report

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Contents Strategy

About this Report__________________________________________ 01

About Gap Inc.__________________________________________________ 01

Letter from Our CEO_______________________________________ 02

Business Strategy_________________________________________ 05

Our Commitment to Sustainability___________________________________ 05

How We Support the Sustainable Development Goals_________________ 08

Advancing Progress Across Our Value Chain_________________________ 09

Assessing Materiality______________________________________________ 09

Our Management Approach_______________________________________ 12

Acting with Integrity_______________________________________________ 16

Sustainability Policies_____________________________________________ 18

Executive Q & A _________________________________________________ 20

Goals and Progress________________________________________ 23

People
Advancing People and Communities________________________ 26

Context and Approach____________________________________________ 27

Employees and Workforce_________________________________________ 28

Our Employee Experience_________________________________________ 35

Youth Opportunity: This Way Ahead_________________________________ 40

Community Investment and Volunteering_____________________________ 43

Empowering Women: P.A.C.E._____________________________________ 45

Improving Factory Working Conditions______________________ 49

Context and Approach____________________________________________ 50

Our Policies and Commitment to Human Rights_______________________ 52

Collaborating on Supply Chain Sustainability__________________________ 63

Assessment and Remediation______________________________________ 68

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment ii
Environment
Water Stewardship________________________________________ 71

Context and Approach____________________________________________ 72

Women + Water_________________________________________________ 74

Improving Manufacturing in Mills and Laundries _______________________ 76

Chemicals_______________________________________________________ 79

Product Sustainability______________________________________ 80

Context and Approach____________________________________________ 81

Mapping the Product Life Cycle____________________________________ 82

Sustainably Sourcing Raw Materials_________________________________ 85

Addressing Water Use with Design Choices__________________________ 86

Integrating Sustainability Into Our Brand Decisions_____________________ 87

Operational Eco-Efficiency_________________________________ 89

Context and Approach____________________________________________ 90

Climate and Energy_______________________________________________ 90

Waste__________________________________________________________ 92

Appendix

GRI Content Index________________________________________________ 94

UN Global Compact: Communication on Progress___________________ 101

Public Reporting Working Group Statement_________________________ 104

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment iii
Reporting Fiscal Years

2014 2015 2016 2017

About Gap Inc. About this Report


Gap Inc. is one of the world’s leading specialty retailers, based This report covers Gap Inc.’s global operations for the two fiscal
in San Francisco, California. As of January 28, 2017, we had years ending January 30, 2016 (fiscal 2015) and January 28,
approximately 135,000 employees and approximately 3,200 2017 (fiscal 2016). Our last report covered the fiscal years 2013
company-owned stores and 459 franchise store locations. and 2014.
We offer apparel, accessories and personal care products for
Previous reports can be accessed online.
men, women and children under the Gap, Banana Republic,
Old Navy, Athleta and Intermix brands. In December 2016, we We sought to prepare the report in accordance with the core
acquired Weddington Way. option of the Global Reporting Initiative’s (GRI) Standards.

Gap Inc. is an omni-channel retailer, with sales to customers The Public Reporting Working Group has reviewed and provided
both in stores and online, through company-operated and feedback on our sustainability report. The results of their
franchise stores, websites and third-party arrangements. Gap assessment can be found at the end of this report. We have
Inc. has company-operated stores in the United States, Canada, not conducted external assurance for this report. Gap Inc. is
the United Kingdom, France, Ireland, Japan, Italy, China, Hong committed to the United Nations Global Compact (UNGC) Ten
Kong, Taiwan and Mexico. We also have franchise agreements Principles and this report serves as our Communication on
with franchisees to operate Gap, Banana Republic and Old Navy Progress (COP).
stores throughout Asia, Australia, Europe, Latin America, the
Middle East and Africa. Please direct any questions to press@gap.com.

Most of the products sold under our brand names are


designed by us and manufactured by independent sources.
We also sell products that are designed and manufactured
by branded third parties, especially at our Intermix brand. We
purchase private-label and non-private-label merchandise
from suppliers with approximately 800 facilities in about 30
countries. Approximately 25% and 23% of our fiscal 2016
purchases, by dollar value, were from facilities in Vietnam
and China, respectively.

More information is available online in our annual filings.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 1
Letter from Our CEO
Good business can change the world.
When Doris and Don Fisher opened the first Gap store in San Francisco in 1969, they
didn’t expect to transform retail. They just couldn’t find a pair of good jeans that fit.
From that single store to today’s global business, Gap Inc. is synonymous with equality,
community and laid-back American style. Good business – the kind that puts people at
its center – has the potential to change the world, no matter how small it starts.

At Gap Inc., we still sell good jeans, and we still believe in good business. We’re also
part of a world that’s changed a lot since 1969. Today, customers expect more from a
product. They want to know the story behind it. Where did it come from? Who made
it? Was it created in a fair, safe and environmentally responsible way? What was the
impact on people and the planet?

We owe it to our customers to ask ourselves those same questions. Some of the
answers have brought us back to our core values, and some have compelled us to
find new solutions and build new partnerships. Gap Inc. is one of the world’s leading

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 2
global apparel retailers. Our global scale affords us the opportunity and responsibility
to make business more sustainable, not just within our own company, but across the
industry as well. Addressing the apparel industry’s systemic challenges is a big job, so
we’re collaborating with suppliers, governments, NGOs, multilateral organizations and
industry leaders to find solutions that work. Our success depends on our people: the
ones who design, make and sell our products, and the ones who buy them.

To see this progress in action, you can visit Gap and buy a pair of Gap for Good denim,
made with 20% less water than conventional manufacturing methods, saving nearly
65 million liters of water per year, or about as much water as the city of San Francisco
consumes every day. By 2021, 100% of the cotton you buy from Gap will be more
sustainably sourced.

Good business—the kind that puts


people at its center—has the potential
to change the world, no matter how
small it starts.
You can go to Athleta for clothing designed by and for women athletes, and activewear
made from organic cotton and recycled polyester. By 2020, 80% of Athleta’s materials
will be made with sustainable fibers.

You can go into one of our flagship Old Navy, Gap, or Banana Republic stores and
there’s a good chance you’ll meet a graduate of This Way Ahead, our job training and
paid internship program for 16-24 year olds from low income communities. By 2025,
5% of our entry-level sales associates will be hired through This Way Ahead – that’s
thousands of young people helping to shape the future of our company.

You can travel to one of the factories we partner with, and you’ll meet one of the
65,000 graduates of P.A.C.E., Gap Inc.’s life skills and education program. By 2020,
one million women from factories and communities around the world will have
completed the program. That’s one million women with greater confidence, new skills
and a brighter future.

If you can’t travel to one of these factories, you can go to www.gapincsustainability.


com and see a published list of all our suppliers. You can also learn about our
partnerships with organizations like ILO Better Work, Verité, and the Sustainable
Apparel Coalition. With them, we’re working to improve our supply chain and amplify
the voices of garment workers. Cooperative relationships between factory workers and
managers are good for business, plain and simple.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 3
We’ve made good progress. I’m proud of this work. But there’s so much more we
need to do. And it’s not just about the clothes we make, it’s about our impact on
the world we live in. The human and environmental threat of climate change is more
present than ever, and we need bold action from communities, companies and
customers to move towards a low-carbon economy.

By 2020, we’re reducing absolute greenhouse gas emissions from our global owned
and operated facilities by 50%, and we’re diverting 80% of our waste from landfill for
our U.S. facilities. To make that happen, we’re monitoring our energy use, pursuing
new approaches to increase efficiency, and looking for ways to reduce waste and save
money in the process.

We’re in a time of great transition, from a changing retail landscape to a changing


climate, but there’s one thing that hasn’t changed since 1969: good people make
good business. While much work lies ahead of us, our collective commitment to
action will not waver. Ultimately, our customers are the ones with the real power
to change the world, every time they purchase more sustainable, humane and
responsible products. Thanks to them, we’re facing the future with creativity, vision
and a clear sense of purpose.

Art Peck
CEO, Gap Inc.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 4
Business Strategy
As Doris and Don Fisher built Gap Inc., they imagined a company that
would also create opportunities for the people and communities touched
by their business. In the decades since, we have been on a journey to
realize this vision.

Our Commitment to Sustainability


We strive to ensure that the people who make our products work in safe, fair
conditions. We are committed to minimizing our environmental footprint. And we
are dedicated to supporting the communities where we operate. We do this by
collaborating throughout our value chain and across government, business and civil
society to address systemic challenges. We also seek to engage our employees and
customers across all our brands in our effort to build a more sustainable world.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 5
As one of the leading apparel retailers, we rely on a world where people and the
environment thrive. Like other global businesses, we recognize that we contribute to
and have the opportunity to address systemic social and environmental challenges.
The Short Story We are committed to augmenting business value, minimizing our environmental impact

Sustainability Strategy and working with all sectors to achieve progress on global goals. That’s why we have
aligned our sustainability strategy with the United Nations (UN) Global Sustainable
•• Our sustainability strategy aligns with the
global sustainable development agenda, Development Agenda. Frameworks such as the UN Guiding Principles on Business
including the United Nations (UN) Guiding and Human Rights, the UN Sustainable Development Goals (SDGs) and the Paris
Principles on Business and Human Rights,
Agreement on climate change have established a foundation that informs how business
the UN Sustainable Development Goals
(SDGs) and the Paris Agreement on can contribute value to the planet and society. Using the global agenda as our guide,
climate change. we have identified issues that are the most material to our business, and we apply our
•• We are integrating sustainability more deeply company’s core strengths, reach and skills development to maximize our impact.
into our business to create greater impact
across our value chain. One of the key frameworks we use is the UN Guiding Principles on Business and

•• We focus on issues where we have the Human Rights, which defines the private sector's responsibility to protect, respect and
greatest opportunities for influence and remedy human rights. The principles outline the rights and needs of vulnerable people
impact: advancing people and communities,
and emphasize how women and men may face different risks. Our Human Rights
improving working conditions and
water stewardship. Policy is based on the Guiding Principles to honor and protect the human rights of our
approximately 135,000 employees and the millions of people involved in our supply
chain. We want to ensure that all of our employees and the people in our partners’
facilities work in safe, fair conditions, and that they are treated with dignity and respect.

Using the global agenda


as our guide, we have
identified issues that are
the most material to our
business, and we apply
our company’s core
strengths, reach and skills
development to maximize
our impact.

Alongside hundreds of companies, we recognize the urgent need to address global


climate change caused by anthropogenic greenhouse gas emissions, as well as other
environmental impacts caused throughout our value chain. In addition to tracking
and reporting on goals aimed at ensuring a healthy planet, we have added our voice
to the We Mean Business coalition. As a company, we are committing to leadership
on climate action, which complements our ambitious work protecting and ensuring
access to the world's water resources.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 6
We are also proud to support the UN SDGs, which codify the global community’s
commitment to ending poverty, protecting the planet and ensuring prosperity for all.
To meet these goals, everyone—from business to government to civil society—must
do their part.

In 2015, after the SDGs were adopted, we assessed Gap Inc.’s opportunities to
advance progress on the SDGs. This assessment revealed that our company’s
sustainability efforts align most closely with eight of the goals. In particular, we have
a leadership opportunity to support SDG 8, Decent Work and Economic Growth,
through our Workplace Cooperation Program, and our youth-employment program
This Way Ahead. Some of our leading programs, such as our P.A.C.E. women's
empowerment program, support SDG 5, Gender Equality, as they’re focused on
achieving gender equality and empowering all women and girls.

This assessment also highlighted how we are advancing SDG 12, Responsible
Consumption and Production, for the apparel retail industry. We do this through efforts
such as our Mill Sustainability Program (see page 77), our goals to eliminate hazardous
chemicals (page 80), significantly reduce our carbon emissions (page 91), waste (page
92) and water consumption (page 71).

We are proud to support the UN SDGs, which codify the global community’s
commitment to ending poverty, protecting the planet and ensuring prosperity
for all. To meet these goals, everyone—from business to government to civil
society—must do their part.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 7
How We Support the Sustainable Development Goals
We aim to create opportunities for our employees, for women and girls around the world impacted by the apparel supply chain, and
for young adults seeking to begin their career, so they can reach their goals and fulfill their greatest potential.

1. End poverty in all its forms everywhere. 10. Reduce inequality within and among countries.

2. End hunger, achieve food security and improved 11. Make cities inclusive, safe, resilient
nutrition and promote sustainable agriculture. and sustainable.

3. Ensure healthy lives and promote well-being for 12. Ensure sustainable consumption and
all at all ages. production patterns.

4. Ensure inclusive and equitable quality 13. Take urgent action to combat climate change
education and promote lifelong learning. and its impacts.

5. Achieve gender equality and empower all 14. Conserve and sustainably use the oceans,
women and girls. seas and marine resources.

15. Sustainably manage forests, combat


6. Ensure access to water and sanitation for all. desertification, halt and reverse land degradation,
halt biodiversity loss.

7. Ensure access to affordable, reliable, 


16. Promote just, peaceful and inclusive societies.
sustainable and modern energy for all.

8. Promote inclusive and sustainable economic 17. Revitalize the global partnership for
growth, employment and decent work for all. sustainable development.

9. Build resilient infrastructure, promote


sustainable industrialization
and foster innovation.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 8
Sustainability Investments in Our Value Chain Programs in progress

Environmental Performance Management


Capability Building
Assessment and Remediation
Product Sustainability Empowering Women: P.A.C.E.
Water Stewardship Water Stewardship Climate and Waste

Design and D
 evelopment Manufacturing (Tier 2) Distribution End of Life

Raw Materials and Product and Finishing (Tier 1) Stores


Processing (Tier 3) Climate and Waste Climate and Waste
Water Stewardship Water Stewardship Youth Opportunity: This Way Ahead
Empowering Women: P.A.C.E. Empowering Women: P.A.C.E. Product Sustainability
Product Sustainability Assessment and Remediation
Capability Building
Environmental Performance Management

Assessing Materiality
Our reporting is built on transparency, impact and accountability. We conducted
a materiality analysis to ensure our strategy and reporting is focused on the most
important current and future economic, environmental and social impacts, as well as the
people and communities we touch. We use our materiality assessment in four ways:

1. to identify the most material sustainability issues for Gap Inc. in terms of
business value, risks and opportunities for long-term planning

2. to understand how sustainability and key business issues intersect

3. to inform future sustainability commitments and resource allocation

4. to support Gap Inc.’s engagement with external stakeholders

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 9
Some findings affirmed our current direction, particularly those related to the importance
of our employees and supply chain workers, as well as our role in water stewardship.
Other arising issues are driven by the trend toward increased transparency, which
is changing the business environment as consumers and stakeholders seek greater
openness about products and services. We are adapting to these important advances
and continuing to manage our most material topics.

Gap Inc. Material Issues


The garment industry is estimated to be the second highest polluting industry after oil.
It is also a massive global employer, with over 60 million jobs throughout the supply
chain, according to the International Labour Organization (ILO). Underscoring these
facts, the World Economic Forum’s 2015 Global Risk Outlook names climate change,
water and unemployment/underemployment as high global risks to both governments
and businesses with “significant negative impacts within in the next 10 years.”

These issues, among the others listed below, must be addressed to ensure the
sustainability, resilience and basic viability of Gap Inc.’s continued business.

Governance and Human Rights Resource Use,


Operating Context and Social Impacts Scarcity and Impacts

Corporate Governance Worker Right and Well-Being Water

Country/ Regional Legal Chemicals and


Income, Wages and Inequality
and Economic Conditions Toxic Management

Human Capital Energy and


Radical Transparency
and Development Climate Stewardship

Technology and
Diversity and Inclusion Waste and End of Life
Product Innovation

Reputation and
Resiliency Sustainable Materials Sourcing
Consumer Engagement

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 10
Core Sustainability Advancing People and Communities
We could not succeed as a company without the exceptional
Focus Areas people who support our business—from the employees
We recognize that we cannot lead on
in our retail stores, to the workers on the factory floors to
every issue; given our business operations
and strengths, we prioritize our greatest the communities near our operations. We aim to create
opportunities for leadership to maximize opportunities for our employees, for women and girls around
impact. Gap Inc.’s sustainability materiality
the world impacted by the apparel supply chain, and for young
assessment set our overarching sustainability
agenda and helped establish our five adults seeking to begin their career, so they can reach their
core focus areas: Advancing People and goals and fulfill their greatest potential.
Communities, Improving Factory Working
Conditions, Water Stewardship, Product
Sustainability and Operational Eco-Efficiency.
Improving Factory Working Conditions
We partner with all our suppliers to provide safe, fair and
healthy working conditions for the individuals who create our
clothes. Together, we’re building the capacity of our suppliers to
manage and improve their practices, designing industry-leading
programs to improve worker and manager relations, assessing
and improving working conditions to meet legal and international
standards and increasing transparency about our efforts.

Water Stewardship
Water is essential for our business and for the people and
communities where we operate. We look for ways to address
water impacts at all product life stages. Our programs aim to
reduce water use, eliminate discharge of hazardous chemicals
and work directly with women to improve access to clean,
safe water.

Product Sustainability
Our integrated commitment to sustainability begins with our
design teams and the development of products that look good,
have lower impact on the environment and bring confidence
to our customers. Since the materials in our clothes greatly
contribute to each garment’s environmental impact, our design
and production decisions have significant power to make our
products more sustainable.

Operational Eco-Efficiency
LED A dedication to reducing the impacts of our owned and
operated stores, distribution centers and offices means
reducing our operational greenhouse gas emissions and waste
production, and working with our logistics and procurement
partners to identify practices that are more efficient and have
lower environmental impact.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 11
Our Management Approach
Given our size, we feel a great responsibility to the planet and to the people who
make our clothes. Our global scale also provides an opportunity to make a real
difference. Our aim is to reimagine the way business can change the world. We are
doing this by supporting long-term business performance while creating greater
equality and opportunity, developing social and environmental innovations that allow
people to fulfill their potential, and scaling these innovations by integrating them into
our business and products.

In addition to aligning our goals with the global sustainable development


agenda, we follow an intentional approach. For all of our social and
environmental programs, we:

1
Integrate Sustainability into Our Business
By integrating sustainability into our business as a core driver, we create
wider accountability for sustainability goals. This allows us to leverage our
talent across all of Gap Inc. to achieve our ambitious sustainability goals.

2
Set Ambitious Goals
By setting ambitious goals, we establish focus on key indicators across
our company so that we can measure our progress on delivering real
benefits to the people and communities we serve.

3
Deliver on Our Commitments
By delivering on our commitments, we contribute in a meaningful way
to the people and places we rely on for our business—which also
helps our company succeed.

4
Form Partnerships with Civil Society, Governments and
Other Sectors to Increase Collective Impact
By partnering with organizations from the local to the global level, we
are able to can deliver impact on a bigger scale and create long-term,
sustainable progress.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 12
Partners and Stakeholders
Advancing progress on issues such as water access and climate change, women’s
empowerment and inclusive economies, and safe and fair working conditions demands
collaboration and jointly developed solutions. These issues are systemic, complex and
intertwined and cannot be solved by any one actor alone. By working together, we can
The Short Story
combine the right expertise and tools to develop holistic perspectives and help address
Stakeholders these challenges.
•• The scale of issues such as climate change
and worker safety demands that we join Engaging stakeholders and establishing partnerships is a critical part of our sustainability
with others to forge solutions. strategy. We work with diverse groups of experts and organizations to foster clearer
•• A range of perspectives enables us to understanding of complex issues, as well as local conditions in the countries where we
conceive initiatives that help bring about do business. As conditions and challenges evolve in our industry, these dialogues give
long-term, sustainable change.
us insights to improve our programs and refine our strategies. The dialogues also reveal
•• Our latest collaborations take an innovative unexplored issues and encourage us to expand our ambitions.
approach to challenges facing our industry
and the world.
We have many key stakeholders: the people who make our clothes, our customers,
•• One example is our new five-year suppliers and factories, employees, unions, governments, multilateral institutions,
partnership on Women + Water with the
NGOs, industry associations, investors, communities and others. We also belong to a
United States Agency for International
Development (USAID). number of organizations that enable us to more effectively collaborate with and learn
from stakeholders. Multi-stakeholder initiatives bring together organizations and people
from different sectors that play a key role in finding new approaches and creating
collective action.

See a list of member and partner organizations and initiatives.

Engaging stakeholders and


establishing partnerships
is a critical part of our
sustainability strategy.

Our latest collaborations take an innovative approach to our industry's challenges.


In 2016, we formed the five-year Women + Water Global Development Alliance with
the United States Agency for International Development (USAID). Through this alliance,
we will expand our P.A.C.E. programs to advance the health and well-being of women,
families and communities touched by the apparel industry—with an emphasis on
access to sustainable water, sanitation and hygiene services, as well as the effective

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 13
management of water resources. Alliance partners—including Water.org, CARE India,
Institute for Sustainable Communities and the International Center for Research on
Women (ICRW)—will apply a systemic, gender-sensitive and flexible approach to
maximize progress on our shared goals.

We are also collaborating on solutions that matter most to workers and our suppliers'
facilities. For example, with the ILO's Better Work program, we have developed Gap
Inc.’s Workplace Cooperation Program, which gives workers and management the
skills they need to resolve workplace issues, engage in respectful collaboration and
drive continuous improvement in the workplace. Through other partnerships, we
developed our Workforce Engagement Program to measure and improve the degree to
which garment workers feel valued and engaged at work.

Looking forward, we will continue to engage our stakeholders and partners in taking a
proactive, systemic approach that addresses root causes and accounts for more of the
people and organizations who may be affected by an issue.

To create the change we’re after, we can’t do this work alone. We partner
with organizations large and small to make this work happen. The United
Nations is one of them. For years, we’ve supported the UN Global Compact
and its guiding principles.
—Art Peck, CEO, Gap Inc.

Sustainability Governance
We implement a robust governance structure to ensure that our Global Sustainability
program both meets our company’s social and environmental goals and supports
our business. Gap Inc.’s Board of Directors, particularly the Board’s Governance and
Sustainability Committee, oversees our Global Sustainability program and receives
regular updates directly from David Hayer, Senior Vice President, Global Sustainability,
and President, Gap Foundation. Hayer also meets quarterly with Gap Inc. CEO Art
Peck, and he meets regularly with the Executive Vice President of Global Supply Chain.
Hayer reports to Brent Hyder, Executive Vice President, Global Talent and Sustainability,
who reports directly to our CEO.

Our organizational structure allows collaboration across key departments at Gap


Inc. Our Global Sustainability department works closely with our Supply Chain,
Government Affairs, Public Affairs, Legal and Gap Foundation teams, among others.
Gap Inc.'s Environmental Council—which is sponsored by Shawn Curran, Executive
Vice President, Global Supply Chain: Logistics and Product Operations, and includes
other functional leaders and subject matter experts across our business and brands—

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 14
is integral in building this alignment. The Council is responsible for evaluating new
initiatives and reviewing progress on our existing environmental goals and programs,
particularly those that relate to Gap Inc.'s overall climate change strategy and waste-
reduction efforts.

Gap Inc. has developed


systems and procedures
focused on identifying
and managing risks—
including those related
to sustainability.

Managing and Prioritizing Risks


Gap Inc. has developed systems and procedures focused on identifying and managing
risks—including those related to sustainability.

At the enterprise level, our Internal Audit team conducts annual risk-assessment
interviews with more than 60 of the company’s top executives and Board members.
The team interviews a subset of these executives every quarter to track changes in the
company’s risk profile. Our Internal Audit team uses these risk-assessment interviews,
as well as a consideration of external factors affecting our company and industry, to
develop heat maps that identify the most significant risks to the company. The team
prioritizes risks based on the likelihood and severity of their potential impact on meeting
the company’s strategic initiatives and maintaining business operations. We then
monitor these areas for trends. Our executive leadership team and the Board review
and sign off on these enterprise risk assessments.

In addition, our Global Sustainability team works with business partners and experts
to assess the importance of potential social and environmental risks and opportunities
to our business and external stakeholders, including suppliers and the people
who make our products. These include the risks that climate and environmental
impacts could pose to our business. The team uses tools to help prioritize risks and
opportunities, including a sustainability materiality assessment (described on page
11), life cycle assessment of representative products (page 84) and a stakeholder
engagement process. For these materiality and other risk assessments, we consider
such factors as the magnitude, likelihood and time horizon of potential impacts on our
business and stakeholders.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 15
Within our supply chain, tier 1 suppliers of branded products, and some tier 2
suppliers, use the Sustainable Apparel Coalition’s Higg Index to perform environmental
self-assessments. In 2016, our Internal Audit team conducted comprehensive risk
assessments of the management of social and environmental issues at both tier 1 and
tier 2 suppliers. Their goal was to identify risks impacting our business and evaluate
the response in place to mitigate those risks. These results have been integrated into
our programs and are detailed throughout this report.

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 US 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.

How we do
business is just
as important as
what we do.

Acting with Integrity


How we do business is just as important as what we do. Our Global Code of
Business Conduct (COBC) serves as our ethical compass for the commitment to high
standards that we make to our stakeholders, customers and one another.

Our Global Integrity team manages our COBC program. The program is led by
Gap Inc. Global General Counsel and Chief Compliance Officer Julie Gruber, who
reports directly to Gap Inc.’s CEO. In addition to the Global Integrity team, we have
a Global Integrity Committee, consisting of senior cross-functional leaders. This
committee meets quarterly to provide program guidance, offer insights into the
business that may impact the COBC and raise overall awareness of the COBC
within the company. The Global Integrity leader presents to the Audit and Finance

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 16
Committee of the Board of Directors at least semi-annually to provide program
updates. The Board of Directors also receives training on compliance and integrity-
related topics.

When issues arise, our employees are encouraged to use our open-door process for
discussing any concerns with their supervisor, next-level manager or human resources
representative. Employees may also contact our Global Integrity team, which oversees
our COBC program. We also provide a confidential COBC hotline, email box and web
portal for use 24 hours a day, seven days a week, to employees and anyone who
conducts business with Gap Inc. or is affected by our business. We have investigative
teams that log, process and address complaints received through any channel,
including our COBC hotlines.

Key Aspects of How We Implement Our COBC:

•• Within 30 days of their initial hire date, all employees globally are required to
take a COBC overview course.

•• In addition, we provide ongoing compliance training to various targeted


employee audiences on topics of nondiscrimination and harassment,
wage and hour compliance, workplace accommodations, anti-corruption,
competition law compliance and data privacy and security. Our Global Integrity
team also conducts general in-person training sessions through the year.

•• We provide a variety of online self-help tools for compliance education and


communication, including leader tools (which guide leaders on how to have
effective conversations with their teams), FAQs, policy links and contacts.

•• Each year, for various business units or offices, our Global Integrity team
conducts interviews with employees and selected suppliers. These interviews
allow us to gauge how well our employees understand our COBC, remind
our employees and suppliers of their responsibilities and our expectations as
to how we engage with each other, and ensure that employees know how to
report COBC violations.

•• Senior-level employees must certify their COBC compliance annually and are
briefed on relevant compliance or integrity topics to raise awareness.

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 Policy, which combines
elements from our COBC with anti-bribery requirements under the U.S. Foreign
Corrupt Practices Act (FCPA) and other similar laws around the world. The policy
and related training programs help employees recognize and avoid corrupt business
practices in all aspects of Gap Inc.’s business.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 17
Sustainability Policies
In order to clearly demonstrate our commitments, we have developed several policies
that address specific social, governance and environmental concerns. Here is a brief
summary of our policies, which are updated and available online.

Animal Welfare Policy

Our Athleta, Banana Republic, Gap and Old Navy brands are deeply committed to
the ethical sourcing of our products, which includes the humane treatment of animals.
We expect all suppliers to make our products in an ethical and responsible way.

Anti-Corruption Policy

Our Anti-Corruption Policy, which is incorporated by reference into our COBC,


prohibits bribery by an employee or agent of Gap Inc. The policy combines elements
from our COBC with anti-bribery requirements under the U.S. Foreign Corrupt
Practices Act (FCPA) and other similar laws around the world.

California Transparency in Supply Chains Act

On January 1, 2012, California enacted this law, requiring companies of a certain size
to publicly disclose the steps they are taking to identify and eradicate forced labor
in their supply chains. Gap Inc. supported this legislation, which we also view as an
important statutory policy lever to assist in the global fight against human trafficking.

Climate Policy

Gap Inc. is committed to reducing our impact on climate change. The consequences of
a changing climate are profound and wide-ranging, from biodiversity and water resource
impacts, to public health and agricultural impacts, to increased risk to our business in
the short and long term. Addressing climate change makes us more resilient and efficient
while enhancing our connection with consumers, employees and other stakeholders.

Code of Business Conduct (COBC)

Our global COBC serves as our ethical compass for the commitment we make to our
stakeholders, customers and one another. It is our guide to working with integrity and
doing what is right in every situation, every day, no matter where we work.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 18
Code of Vendor Conduct (COVC)

Our COVC sets forth the basic requirements that all factories must meet in order to do
business with Gap Inc. This code is based on internationally accepted labor standards,
including the ILO’s Declaration on Fundamental Principles and Rights at Work (ILO core
conventions) and the Universal Declaration of Human Rights.

Conflict Minerals Policy

Gap Inc. is committed to ensuring compliance with section 1502 of the United States
Dodd Frank Act relating to trade in conflict minerals.

Human Rights Policy

Gap Inc. is committed to respecting internationally recognized human rights and


eliminating human rights abuses. We support the principles contained within the
Universal Declaration of Human Rights, the UN Global Compact, the OECD Guidelines
for Multinational Enterprises and the ILO core conventions.

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.

UK Modern Slavery Act

Gap Inc. is committed to supporting and improving labor rights and working conditions
globally across the retail and apparel industries. As a business, we have a moral
responsibility to protect and care for those whose work goes into creating our products
and bringing them to our customers. Our commitment in this regard applies equally
to all of our brands. Wherever we operate, and whomever we are operating with, we
strive to do so in compliance with our overall Human Rights Policy.

Wood-Derived Fabric Policy

Gap Inc. is committed to the ethical sourcing of our products and the use of
sustainable raw materials. Gap Inc. is against the use of ancient and endangered high-
carbon-value forest areas to make cellulose-based textiles, including but not limited to
rayon, viscose, lyocell and modal.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 19
Executive Q & A
A Conversation with David Hayer, President, Gap Foundation,
and Senior Vice President, Global Sustainability, Gap Inc.

Why is sustainability so We were founded in 1969 by Don and Doris Fisher, a husband and wife team who
important to Gap Inc.? believed in giving back to the community, the people who make our products and
the environment. To them, success has always been about so much more than
selling clothes.

Sustainability is becoming mainstream. Gap Inc. is in a unique position to influence the


industry, government and our customers by leading the way with best practices.

What is the biggest change in Today, we know more about what works and what doesn’t. We are doubling down on
our sustainability work since models that truly show value, like the ILO’s Better Work program, which now covers
our last report was published a majority of the facilities we source from in Bangladesh. It’s less about testing an
covering 2013 through 2014? approach, and more about building programs that scale.

Our global portfolio of brands positions us well to accelerate impact worldwide. Some
of our brands, like Gap and Athleta, have set ambitious goals on sustainable cotton
and synthetic fibers. As our understanding grows, we are infusing better environmental
practices into every part of the business.

What do you see as the biggest There are five key levers that I feel need to be addressed to propel the apparel
challenges to our work? industry forward: building effective partnerships, reducing fragmentation, converging
on what works, integrating accountability, and recruiting and developing top talent.
Each of these components is important to improve working conditions and reduce
environmental impacts.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 20
How do you define effective As a company, we're estimated to represent a small but significant fraction of the
partnerships, and how do we apparel industry, which is humbling. We need help to continue to drive lasting
select our partners? impact. We need external collaborations and multi-stakeholder initiatives—it’s NGOs,
manufacturers, government, labor groups and consumers. Today, we vet partners
based on shared vision and work style, supplemental capability and a true commitment
to long-term impact.

Why is streamlining sourcing The high degree of fragmentation across the industry is a significant challenge to
relationships and efforts an improving sustainability. Over the past seven years, Gap Inc. has strategically reduced
important part of our strategy? its number of sourcing facilities by over 25%. Prioritizing resources and ensuring
that brands and suppliers collaborate more closely on social and environmental
performance has been critical to our evolution. We need tougher expectations across
the industry. As we raise our standards and source solely from higher-performing
vendors, we necessarily reduce the amount of relationships we maintain.

When it comes to sustainability, we’re focused on efficacy and efficiency. We’re


pursuing the most innovative work with like-minded apparel companies, multilateral
institutions, governments, labor organizations, environmental groups and other key
stakeholders. That collaboration stands to change the way we assess our facilities and
build capacity; it will help us save water and diminish chemical usage. Competition is
a healthy part of any business, but this is one place where we need to converge within
the industry.

You mentioned integrating Sustainability must continue to become a seamless part of how we run our company.
accountability as a key lever, The days of it being a small program off to the side of the core business are long
how is that going? over. We are evolving the work to increasingly be a part of what we do regularly.
We’ve made progress, but fully integrating sustainability across our business will unlock
the biggest opportunities.

Tactically, it’s about education, empowerment and accountability. We want to enable


the people who are making real decisions, asking real questions and having real
debates about our products to understand how to push forward what is right for
people, the planet and our company.

This work requires recruiting the best talent possible, from experienced and diverse
backgrounds. It requires the most qualified and creative professionals dedicated to
creating innovative supply chain solutions. We need to invest in them and support their
development. We’ve made good progress, but we still have room to grow.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 21
Where do you see the future of We have a responsibility, to be accountable and maintain high levels of transparency.
reporting for Gap Inc.? To do so, we will identify opportunities to publish our program impact in ways that are
more accessible and more frequent, including reporting on our sustainability metrics
and progress at least annually.

What keeps you fired up about I can’t believe I get to wake up and do this job every day.
your work?
I’ve met hundreds of mothers in our cut-and-sew facilities across the globe; I’ve
met dozens of young men and women beginning their first jobs in our stores in
urban centers across the US. We all want the same thing: to build a better future for
ourselves and our families. I’m fired up to help each one of them.

To me, leading sustainability at Gap Inc. is really about equality—equal treatment,


equal opportunity and the ability for everyone to enjoy a healthy environment.

We have a tremendous opportunity to connect the dots on our progress and our
challenges. We must translate the activity we’re seeing across the industry into better
results. As we continue to weave sustainability into all we do, I’m confident that Gap
Inc., is taking the right steps toward the future we all want to see.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 22
Goals and Progress
Holding ourselves accountable is fundamental to our approach to sustainability—below are key goals, our progress to date
and where we are heading in the future.

Existing Goals
Completion
Advancing People and Communities Details
Target*

Employees

Women make up 74% of our employees,


Ensure female representation at all
68% of our global store managers, 51% of
leadership levels is meaningfully above Ongoing
our leadership (VP and up) and serve equally
external norms
as our brand leaders

We’ve eliminated on-call scheduling and


Pilot and commit to expand programs that
provide store employees with at last 10 to 14
provide advance notice and stable, flexible 2017
days’ notice for their schedules, throughout
scheduling to store employees
our brands

Youth Opportunity: This Way Ahead

60% of This Way Ahead participants report


97% of youth report increase in soft skills and
increased on-the-job skills and confidence 2018
66% of youth report increase in confidence
as a result of their internships

65% of This Way Ahead interns receive


offers to continue as Gap Inc. sales
74% of interns received job offers 2020
associates upon the completion of
their internships

Community Investment

All teams have a Community Leader (CL),


62% of teams have a CL; 74% of CLs led at
and all CLs organize and lead at least 3 2018
least 3 volunteer projects
volunteer projects per year

All Community Leaders form a long-term


relationship with one nonprofit partner to 70% of have established relationships 2018
maximize volunteering impact 2018

*By end of year

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 23
Completion
Empowering Women: P.A.C.E. Details
Target*

Improve the lives of one million women and


girls in Gap Inc.’s supply chain and other 68,000 women have participated
2020
manufacturing and community settings through 2016
through the Gap Inc. P.A.C.E. program

Expanded program to bring new educational


Expand P.A.C.E. to a suite of learning
opportunities to girls ages 11 to 17. New
programs that provides multiple entry points
curriculum focuses on improving self- 2020
for addressing the needs of adolescent girls
confidence and helping girls develop future
and women leaders
goals and aspirations

Factory Working Conditions

100% of Gap Inc.’s suppliers producing branded 84% of facilities rated yellow or green
2020
apparel are rated yellow or green by 2020 through 2016

Partner with Verité and strategic suppliers


to measure workers’ sense of value and
Implemented Workforce Engagement
engagement at work, and launch projects
Program at 89 facilities representing
aimed at improving 20,000 workers’ 2018
220,000 workers with Verité and Good
engagement. Publicly report on findings and
World Solutions
impact, and share best practices with all Gap
Inc. suppliers

As part of the Social and Labor Convergence


100% of strategic suppliers of branded Project, we are helping to create a shared
apparel self-report their sustainability tool for footwear and apparel companies
2018
performance in Gap Inc.’s global sustainability to assess factories’ social and labor
data system performance. This represents a more unified
effort to self-report sustainability performance

Operational Eco-efficiency

50% absolute reduction of greenhouse


gas emissions in our owned and operated 7% reduction achieved through 2016 2020
facilities globally

Pilots underway; we are currently reassessing


80% waste diversion from landfill for our
our methodology to calculate waste production 2020
U.S. facilities
and diversion

Work towards zero discharge of hazardous We have communicated our Manufacturing


chemicals in our supply chain through Restricted Substances List to suppliers, 2020
membership in ZDHC 2020 Roadmap facilities and mills that make our clothing

*By end of year

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 24
New Goals
Completion
Advancing People and Communities
Target*

$15M per year in employee-driven community investment Ongoing

5% of new store hires are from This Way Ahead 2025

10,000 teens and young adults participate in This Way Ahead 2020

10,000 women empowered through P.A.C.E. and Fair Trade 2020

Water Stewardship

Save 1 billion liters of water in our manufacturing processes 2017

25% of product made using techniques that save water 2020

Product Sustainability

Eliminate the use of fibers derived from wood from ancient and endangered forests 2020

100% of cotton purchased from more sustainable sources 2021

80% of materials made with sustainable fibers 2020

*By end of year

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 25
Advancing People and Communities
In this section •• Employees •• Youth Opportunity:
This Way Ahead
•• Employee Impact:
Community Investment
•• Empowering
Women: P.A.C.E.

We could not succeed as a company without exceptional people


who support our business—from the employees in our retail stores, to the
workers on the factory floors, to the communities that surround our operations.
We aim to create opportunities for our employees, for women and girls around the
world impacted by the apparel supply chain, and for young adults seeking to begin their
career, so they can reach their goals and fulfill their greatest potential.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 26
Context and Approach
Seeking a better life for your family. Building the confidence to set bigger goals.
Finding time to mentor an intern. These acts inspire us every day—and they are carried
out by people touched by our business throughout the world, from a woman who sews
our clothes, to one of our 135,000 employees. These are the people who make our
company what it is today, and by helping them succeed, we all succeed.

As a company, we can make the biggest impact by focusing on areas that align
with our business and affect the people we work with. Our mission is to promote
advancement for people and communities. We set ambitious goals, and we integrate
our advancement programs into our core company operations to deliver social and
business returns. We focus on creating opportunities for our employees, young
people seeking their first jobs, the workers who make our clothes, and the women
and girls in the global communities where our company has influence and reach.

Our empowerment, employee and workforce programs support the rights and well-
being of the people who embody and drive our business, ensuring they have equal
opportunity and support to develop personally and professionally. Within our global
workforce, our teams are dedicated to giving back, both through their time and their
support, and Gap Inc. is there to match them every step of the way. Working with and
hiring great people, encouraging their development and supporting them for who they
are just makes sense.

One of the critical ingredients to the success of our advancement programs is our
focus on partnerships: We collaborate with local and international NGOs, local
community organizations and government agencies that expand our access to people,
resources and expertise. We know that collaboration allows us to engage with people
and contribute more to communities than we could alone.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 27
Employees and Workforce
Since our founding, we’ve embraced core company values that include celebrating
individuality and diversity and treating all people equally—with respect, dignity
and fairness.

At Gap Inc., we have developed a workplace culture that promotes these fundamental
values. Our innovative initiatives champion diversity, inclusion and equality to attract
and retain talent, and to support positive change across business and society.

As one of the world’s leading apparel retailers, we see an opportunity to stand


alongside other leaders and work toward greater fairness for everyone. We feel it
is important to take public positions on issues that matter to our employees, our
customers and our business. In this way, we can champion the ideals of our founders
and contribute to broader cultural change.

We strive to create a workplace culture that embraces diversity and inclusion


and treats every individual with dignity and respect. By upholding these
values, we are able to attract and retain talented people, deliver the best
products and experiences to our customers, and support positive change
across business and society.
—Kisha Modica
Senior Director, Diversity and Inclusion

Diversity, Inclusion and Equality


At Gap Inc., a sense of belonging is always in style. Our goal is to attract, develop and
retain the best talent from all walks of life — people who will disrupt the way we do
business, now and in the future. We believe embracing diversity promotes creativity
and innovation.

To us, celebrating individuality goes hand in hand with having deep respect for all.
Our business can thrive only if everyone has the chance to do the same. For our
business to grow, our people also need to understand and embrace the wide variety
of cultures that we encounter across our brands and store locations.

Our commitment to equality and diversity is embedded in our Code of Business


Conduct (COBC), which includes a zero-tolerance policy for any form of discrimination,
harassment or retaliation. This policy applies to our directors, employees, applicants,
customers and business partners, including independent contractors and suppliers.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 28
We believe in standing up for all forms of equality—inside and outside our company.
In recent years, this has included raising our voice in opposition to proposed legislation
impacting members of the lesbian, gay, bisexual, transgender and queer (LGBTQ)
communities, many of whom are current and future employees and customers.

Our Global Talent team works with our Diversity and Inclusion team to design, develop,
deliver and evaluate programs and activities related to talent and inclusion. We use
internal and external benchmarks, and leaders across the organization identify
and prioritize a set of critical issues (e.g., sustainable development or leadership
opportunities) based on agreed-upon criteria. Our Communications and our Public
and Government Affairs teams support communication of these priorities internally
and externally.

To us, celebrating
individuality goes
hand in hand
with having deep
respect for all.

Creating a Community of Diversity and Inclusion


We believe diversity increases creativity and innovation, promotes high-quality decisions
and enhances economic growth. An inclusive culture helps employees feel comfortable
being authentic at work. We have internal teams dedicated to embracing and driving
diversity and inclusion efforts:

Diversity and Inclusion Council

This advisory group—comprising corporate and field executives and leaders from
throughout our organization—develops diversity and inclusion strategies and connects
these activities with business outcomes.

Enterprise Diversity and Inclusion Team

This team is responsible for the design and implementation of Gap Inc.'s Global
Diversity and Inclusion strategy.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 29
Diversity Ambassadors

These individuals across our organization champion diversity efforts, build awareness,
increase knowledge and share their skills and resources within their respective teams.

Business Resource Groups

Gap Inc. employees from diverse backgrounds have taken the initiative to develop
Business Resource Groups, which provide opportunities for cross-cultural learning,
mentoring and relationship building. These groups organize development, networking
and volunteering events. They gather employee input and support on internal
initiatives, as well as offer consumer perspectives and product feedback that help
Gap Inc. in the marketplace. Additionally, they contribute their language skills and
knowledge of various countries and cultures to support the global aspects of our
business. Engaged employees gain networking experience and visibility, and they
meet leaders across the company.

We support our employees in developing these Business Resource Groups,


which may grow and change in the future. Our current Business Resource
Groups include:

AANG African American Networking Group

ASIA Asians Supporting Inclusion and Awareness

GapWIL Women in Leadership

GEAR Gap Gay Employees, Allies and Resources

HOLA Honoring Our Latino/Hispanic Ancestry

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 30
In 2016, 52 percent of our full-time and part-time (non-seasonal) employees in the U.S. identified as ethnically diverse.

Gap Inc. Owned Facilities

US Ethnic Breakdown 2013 2014 2015 2016

White

All 53% 51% 50% 48%

Management 75% 74% 73% 72%

New Hires 51% 49% 46% 44%

Asian

All 6% 6% 7% 7%

Management 9% 9% 9% 10%

New Hires 6% 6% 6% 6%

Black

All 19% 19% 19% 19%

Management 6% 6% 7% 6%

New Hires 23% 24% 24% 24%

Hispanic

All 18% 20% 20% 21%

Management 9% 10% 10% 10%

New Hires 16% 17% 18% 19%

Other Minority

All 4% 4% 4% 5%

Management 1% 1% 1% 2%

New Hires 5% 5% 6% 6%

All Minorities

All 47% 49% 50% 52%

Management 25% 26% 27% 28%

New Hires 49% 51% 54% 56%

*United States full-time and part-time, non-seasonal employees. Data on ethnic diversity not available outside the U.S.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 31
ASCEND
Investing in the Next Generation of Leaders
We are devoted to developing an inclusive, diverse workforce and a pipeline of future
leaders. Our ASCEND program supports Gap Inc.’s ongoing vision and commitment to
developing talent, driving engagement and advancing diversity. ASCEND is designed to
help minority leaders realize their potential and achieve their career aspirations through
mentorship, building opportunity and individual capability building.

We also invest in the next generation through our support of and recruiting at minority
job fairs and through the Gap Foundation’s This Way Ahead youth internship and job-
skills program.

Read more on page 40.

Standing with the LGBTQ Community


We believe part of our role as a business is to bring people together and work toward
a brighter future where everyone has the opportunity to thrive as equals. Gap Inc.
and the UN Foundation built a partnership to raise awareness and funds in 2017 for
UN Free and Equal, a program of the Office of the UN High Commissioner for Human
Rights (OHCHR) to promote equal rights and fair treatment for lesbian, gay, bisexual,
transgender and intersex (LGBTI) people globally.

The partnership marked Pride Month and included two main components to engage
our customers:

•• As part of Gap Inc.’s #WearYourPride campaign, 30% of net sales from


Gap brand’s Pride T-shirts were donated to the UN Foundation to benefit
Free and Equal.

•• Gap Inc. brands also sold special, Pride-themed e-gift cards. We donated $2
from each card sold to support Free and Equal.

This campaign allowed us to publicly demonstrate our commitment to equality, while


giving our customers a way to support and celebrate Pride.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 32
Creating Opportunities for Women
Creating opportunities for women is deeply embedded in our culture. From store
managers to brand CEOs, women have long played an important role in running and
growing each of our brands. Women make up over 70% of our employees, serve as
a majority of our global store managers and serve equally as our brand leaders. We
strongly believe that our commitment to equality for women gives us a competitive
advantage, it helps us attract top talent, increase engagement and retention, and
connect with our customers, a majority of whom are women.

Our global Women and Opportunity initiative includes both internal and external
programs and activities that engage leaders and employees across our company.
Our broader women’s empowerment strategy includes ensuring alignment across
all efforts impacting women and leveraging gender inclusion. This commitment to
equality extends to all aspects of our business, from learning and development to
leadership training.

Inspiring Future Women Leaders


Our GapWIL—Gap Women in Leadership—group partnered with Girls Inc., a nonprofit
whose mission is to inspire all girls to be strong, smart and bold, to launch a summer
"menteeship" program at Gap Inc. During the three-week program, high school
juniors met with career coaches, visited stores and developed technical skills through
workshops in retail and inventory management. They also sat down with Gap Inc.
leaders to learn about the business and our company's values.

In addition to these efforts, we have integrated our P.A.C.E. program into our core
business practices to help the women who make our clothes and their communities
gain the skills and confidence they need to advance in work and life. In September
2015, we announced a major expansion of P.A.C.E., with the goal of reaching 1 million
women throughout the world by 2020. (Read more about P.A.C.E. on page 45.)

In 2014, we signed the Women’s Empowerment Principles, developed by UN Women


and the UN Global Compact to give business practical guidance on areas such as
women’s professional development and the need to publicly report on progress about
gender equality.

One of the ways we support women’s equality is by providing equal pay for equal work.
We are proud that in 2015 we became the first Fortune 500 company to report publicly
that we pay female and male employees the same for the same work around the
world, verified by a third party. By sharing our progress, we aim to engender broader
change, with other companies following our lead.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 33
We were honored to receive the 2016 Catalyst Award
recognizing Gap Inc.’s culture of equality, inclusion
and opportunity.
2016 Catalyst Award Winner
We were honored to receive the 2016 Catalyst Award recognize Gap Inc.’s culture of
equality, inclusion and opportunity. Catalyst selected Gap Inc. because of our leadership
on equal pay for women, strong representation of women at all levels, and our dedication
to advancing women, including our employees, customers and the people touched by
our business around the world.

The annual award from Catalyst recognizes organizations whose innovative approaches
result in proven, measurable results that advance the recruitment, development and
advancement of women in the workplace. For the first time since the inception of the
Catalyst Award, Gap Inc. is the sole company to be honored by the organization in a
given year and has become the first company from the fashion industry to be recognized.

Initiatives that are considered for the Catalyst Awards are evaluated in a rigorous,
yearlong process against criteria such as strategy and rationale, senior leadership
activities, accountability and transparency, communication, employee engagement,
innovation and measurable results.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 34
Our Employee Experience
Our business success depends on our people. That’s why we are dedicated to
attracting talented employees and giving them opportunities and reasons to achieve
The Short Story
their work and life goals at Gap Inc. Our workplace culture and benefits are designed
Careers and to meet the professional and personal needs of our employees and their families. For

Development retail employees in particular, we improved wages and scheduling practices so that
the people who work in our stores experience greater stability and flexibility.
•• We emphasize a growth mindset, which
we cultivate by promoting from within and
eliminating traditional performance reviews. Advancing Careers and Developing Talent
We strive to develop a diverse pipeline of talent and give our employees opportunities
•• Store employees can advance within
the field or into corporate positions; a to learn and develop, stay challenged, take on new roles and adopt greater responsibility.
number of our executives started out as We know our current and prospective employees expect a path to new opportunities
store associates.
that rewards them for their performance and value contribution. Offering our employees
•• Our Rotational Management Program challenging work that tests and builds their capabilities not only sets them up for
combines classroom learning with on-the-
success, it makes our business stronger and more innovative.
job training across multiple functions.

•• Instead of reviews, employees frequently As a retailer that values hands-on experience in our stores, we give store employees
meet with managers to receive feedback
opportunities to take on higher-level field and corporate positions. The best testaments
and guidance on opportunities to develop.
to the opportunities we provide are our employees who started out at stores and rose
through the ranks to senior management positions; approximately 18% of Gap Inc.
executives at the vice president level and above started their careers working with
product and customers in stores.

Global Share of Open Positions


2013 2014 2015 2016
Filled by Internal Hires

Vice President and Above 71% 57% 70% 71%

Director / Senior Director 67% 65% 65% 64%

Manager / Senior Manager 57% 60% 58% 59%

Store Management 53% 52% 53% 49%

Overall (including Store Associates) 15% 15% 14% 15%

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 35
Many people stay at the company or return because of the opportunities and range
of roles that our brands and business provide. It’s common for our employees to work
for multiple brands and functions during their careers. Employees at the manager
and higher levels average more than seven years with the company, and more than
16% of employees return for new challenges and opportunities. We recently launched
a revamped careers site and a new careers blog, as well as an alumni program to
connect past, current and future talent.

We also recognize the need to look outside our organization to make sure we find the
best people for each role. We aim to balance our internal promotions and external hires
to achieve the most productive mix of diverse talent, functional and subject matter
expertise and organizational fit.

Our Approach to Learning and Development


Our learning and development model is based on two core beliefs: Everyone has the
capacity to learn and grow, and the best opportunities for learning take place on the job.

In 2014, we did away with our traditional annual review process for employee
performance in favor of a new system called “GPS—Grow. Perform. Succeed.”
With a focus on continuous learning, GPS uses frequent performance conversations
and coaching sessions to give employees regular feedback and guidance on their
work and development opportunities.

Because we believe most growth happens on the job, we use a 70-20-10 model for
career development that emphasizes learning through real work experiences. 70%
of an employee’s learning and development takes place on the job and is built into
their goals, 20% occurs through mentorships and collaboration and 10% comes from
courses or formal training.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 36
We offer employees at all levels a variety of training opportunities, ranging from online
courses to in-person workshops and multiday programs. A few examples of programs
that improve our business by promoting employee learning and development include:

Retail Academy

This program combines classroom sessions, rotational training and business simulations
designed to develop the skills employees need to advance and navigate the increasingly
complex and technology-driven retail space. This includes a world-class Rotational
Management Program for high-potential entry-level talent being groomed to become
future leaders of the company.

Leadership Development

This six-month program provides tools and resources to new people managers and
helps them develop the long-term capabilities of others, create better ways to achieve
business success and empower their teams.

Employee Profile

Andres Dorronsoro and the Rotational Management Program


“RMP was an outstanding experience,” said Dorronsoro.
“The combination of classroom learning and on-the-job training
through multiple functions was the perfect way to learn what a
career in retail actually meant and how I could make an impact.”
Dorronsoro still remembers how the head of RMP, Leah Slater,
encouraged him to speak up and share ideas with anyone who
would listen to make our business better. “At 22, I was out in our
stores and shopping the competition, identifying problems and
recommending solutions. Her encouragement is what pushed
me to have this rigor in challenging the status quo.”
After working in our stores for many years and studying
business in college, Andres Dorronsoro knew he wanted to do After RMP, Dorronsoro chose to focus on merchandising—a

something with the consumer experience, but he didn’t really good decision seeing as he is now a senior vice president and

know what that meant. Following an internship at our corporate general manager for Old Navy Merchandising. Today, he credits

office, someone suggested that he go through our Rotational the people of RMP for putting him on the path to success: “It’s

Management Program (RMP) to learn about different roles in the the people along the way that made RMP amazing,” he said.

company. He started the program in 2004. “The mentors, the teachers and my fellow classmates are still a
part of my life.”

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 37
Benefits and Work-Life Integration
We offer financial incentives, work-life integration and benefits aimed at helping our
employees make the most of their professional and personal lives. This supports
employees and increases their engagement at work, which contributes value to
our business. In 2017, we received recognition from the Business of Fashion’s
Best Fashion Companies to Work For as a Top Performer in Rewards and Benefits,
highlighting our pay-for-performance philosophy.

A number of our departments offer flexible scheduling to shift the emphasis from where
and when work is conducted to the results delivered. This results-driven model lets
employees adjust their schedules and the way they work to suit their personal needs
and circumstances.

We also offer other programs designed to accommodate the different needs of our
employees and their families. These programs include:
The Short Story
•• Nationwide Family Support: US full- and part-time employees have online
Benefits and access to child-, elder- and pet-care resources. Full-time US employees

Work-Life Integration also benefit from back-up childcare and priority access to nationwide
childcare centers.
•• We support our employees in a range of
ways, from 401(k) matching to wellness
•• Leave: US employees can take extended time off from work to manage the
programs to family support.
demands of their family and personal lives.
•• Our rewards for strong performance and
benefits support employees in creating a •• Phase in/phase out: Eligible employees can temporarily reduce their work
thriving future. hours before, during or after maternity or family leaves of absence.
•• We have taken steps to raise our US
We also provide a number of additional benefits that make up a significant portion
hourly minimum wage and improve
scheduling practices, including eliminating of their overall compensation package and are intended to help our people and their
on-call scheduling and providing employees families lead healthier, more productive lives:
with at least 10 to 14 days’ notice for
their schedules. •• Health and wellness benefits: We offer full medical, dental and vision
coverage for full-time employees.

•• Financial benefits:

–– GapShare 401(k) plan matches employees’ contributions dollar for


dollar up to 4% of base pay, with 100% immediate vesting.

–– Employee Stock Purchase Plan (ESPP) allows full- and part-time


employees to purchase Gap Inc. stock at a 15% discount quarterly.

•• Work-life balance and lifestyle benefits:

–– We provide generous paid time off (PTO) that increases with promotion
and seniority.

–– Our Employee Merchandise Discount Program gives full- and part-time


US employees up to 50% off at Gap, Banana Republic and
Old Navy, as well as 25% off at Athleta.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 38
–– We also offer tuition reimbursement, wellness programs and
commuter benefits.

•• Community investment benefits: The Gap Foundation matches or


supplements employees’ contributions of money or time to eligible nonprofits.

Wages and Scheduling: Promoting Stability and Flexibility


for Retail Employees
Our store and other hourly employees are especially sensitive to wages and
scheduling—they greatly affect employees’ ability to make ends meet and fulfill
family obligations, undertake academic or other pursuits and plan their lives.
To promote stability and flexibility for retail employees, we have taken steps to raise
our US hourly minimum wage and improve scheduling practices, including eliminating
on-call scheduling and providing employees with at least 10 to 14 days’ notice for
their schedules.

We were one of the first US retailers to increase our US minimum hourly rate.
The increase took effect in two stages: In June 2014, we raised the minimum
hourly rate to $9, and in June 2015, we raised it again to $10.

Ensuring Worker Safety


When it comes to attracting and retaining employees, we are dedicated to
fundamental worker safety. We strive to prevent and promptly address any
employee work-related injuries.

We have a centralized online reporting system that tracks all incidents and injuries.
We analyze the information at least quarterly to assess risks and develop preventive
measures. Our internal claims team and safety department analyze recurring injuries
or issues to determine if current policies or practices need to be amended or if more
training is required to address risks. Our independent Internal Audit department audits
health and safety risks and processes. We incorporate results into the performance
evaluations and compensation of relevant personnel.

For data on workplace health and safety, please see our Data Tables.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 39
Youth Opportunity: This Way Ahead
In 2007, we launched This Way Ahead, our life skills and paid store internship program,
to help youth from low income communities between the ages of 16 and 24 land their
first job. Because our Old Navy, Gap and Banana Republic employees mentor the
program participants, This Way Ahead also builds our retail employees’ leadership and
management skills. We’ve also integrated the program into our recruitment strategy to
help Gap Inc. stores build a valuable talent pipeline of future employees.

How This Way Ahead Works

Nonprofits recruit youth This Way Ahead Participants apply for Mentorship by Graduates eligible
provides training internships at stores current employees for store jobs

Through This Way Ahead, we have re-envisioned our retail stores as a rich training
ground, where our employees can share what they have learned about career
The Short Story planning and help participants explore careers that will ignite their passion. Each This
Way Ahead participant receives two months of in-person and online job training and
This Way Ahead
coaching. During this time, they learn the skills they need to get and keep a job—from
•• This Way Ahead, our training and internship
program, helps teens and young adults
decision-making and goal-setting, to how to make presentations and resolve conflicts.
from underserved communities land their After the training program, youth are eligible to apply for paid internships at our stores.
first job. This Way Ahead is a collaborative
partnership between local nonprofits, Part of what makes our program successful is our emphasis on partnerships and the
Gap Inc. and three of our brands
power of human connections. We work closely with local nonprofit organizations that
(Old Navy, Gap and Banana Republic).
help recruit and train participants, and we rely on store employee volunteers to lead
•• Program participants and employee
workshops and mentor participants.
volunteers both receive real career and
personal benefits.
This Way Ahead has had a significant impact to date, and we have set our sights high
•• Since 2007, more than 2,800 young people for the future. Through early 2017, more than 2,800 young people have participated in
across 15 cities in the US, UK and Canada
have participated in This Way Ahead.
This Way Ahead across 15 cities in the US, UK and Canada. In 2015, we announced
a bold goal to hire 5% of our new entry-level store employees from This Way Ahead
•• As we expand to reach our goals, we are
looking at new ways to tailor the program
by 2025. To reach that goal, we expect 10,000 youth to participate in This Way Ahead
to different cities and markets. by 2020. Already, we are on our way to achieving this goal: In 2016, we doubled the
number of cities and tripled the number of interns who are part of This Way Ahead, and
in 2017 we added two additional cities and doubled the number of interns again.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 40
In the 11 years we have run This Way Ahead, we have measured
substantial social and business benefits:

Goals 97% 97% of This Way Ahead participants improve their work-ready and
soft skills, including job search and interviewing skills, as well as
•• By 2025, 5% of our entry-level store
communications, problem-solving, decision-making and relationship-
employees are hired through This Way Ahead.
building skills.
•• By 2020, 10,000 teens and young adults
participate in This Way Ahead.

•• By 2018, 60% of This Way Ahead


66% 66% of participants report an increase in their self-confidence
and their ability to get a job in the future.
participants report increased on-the-job
skills and confidence as a result of
their internships.
77% 77% of This Way Ahead graduates receive job offers at our
stores after their internship.
•• By 2018, 65% of This Way
Ahead interns are hired on as Gap Inc.
sales associates upon the completion
of their internships. 89% 89% of mentors say they’ve increased their ability to develop
and coach their teams.

85% 85% of participants report improved communications skills.

Through This Way Ahead, we have re-envisioned our retail stores as a rich
training ground, where our employees can share what they have learned
about career planning and help participants explore careers that will ignite
their passion.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 41
We are continually refining This Way Ahead based on data we collect and feedback
we receive from nonprofit partners, participants and employee volunteers.
Given external trends, we have built a program that is responsive to the changing
landscape for young employees. As we expand the program to achieve our goals, we
are testing different models tailored to different geographic markets, where the number
of stores and interns vary. We are also applying the lessons we have learned over the
years, including the value of investing in long-term partnerships with local nonprofits,
which customize the training programs for young people in their area, and the value of
testing new ideas through pilots.

After a decade of running This Way Ahead, in 2017 we are launching a longitudinal
study to assess the program’s long-term impact on participants. This study will help
us understand how This Way Ahead gives low-income young people the skills to
succeed in the working world, and how the program benefits our business by building
a robust pipeline of talented, engaged employees. We look forward to continuing to
share our insights with other organizations and companies that are investing in youth-
employment programs.

Dashawn Hightower
This Way Ahead Graduate and Old Navy Employee

Before This Way Ahead, I thought a job was just about collecting
a paycheck. Now I know a job can change your life. I interned
at the Harlem Old Navy store on 125th Street. After being late
and being written up a few times, my manager, Yeera, pulled
me to the side and said, “Dashawn, what is it you want to do
with this opportunity?”

I thought I had joined the program to become a sales associate


and get a check. She made me realize that this was only the
beginning. If I worked hard enough, there was real opportunity to
Dashawn Hightower, 2013 This Way Ahead Graduate, speaking to an audience
of 1200+ at the 2017 Old Navy Field Leadership Conference
grow within the company. That’s what it took to turn me around.

Dashawn Hightower was a 2013 This Way Ahead graduate. After three years with Old Navy, today, I’m a Training and
Today, Hightower is an intern manager at his Old Navy store, Business Operations Specialist at our flagship store on 34th
helping do for others what the program did for him. Street in Manhattan. If you want to learn something new, I’m
the person you train with.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 42
Community Investment and Volunteering
Our work culture is imbued with a spirit of giving back: It’s what attracts many people
to work for Gap Inc. and it is a key part of what inspires our employees to stay.
That's why we created flexible programs that encourage our employees to give back
in the way that makes the most sense for them, through money or volunteer time.

The Short Story


We give our employees a chance to make a real difference in their communities

Community Investment through our Community Leaders program, which consists of approximately 3,000

•• To encourage employees to give back, people across seven countries. Our Community Leaders, the heart and soul of our
we provide time off for volunteering, grants volunteer efforts, are encouraged to identify a local nonprofit organization that can use
for community organizations, money for
the talents and skills of our employees. Leading by example, they inspire their teams
volunteer time and matching donations.
to volunteer—fueling a movement that rallies all of us to create positive change and
•• We delivered over $30 million in
embody our philosophy to Be What’s Possible.
employee-driven community investment
in 2015 and 2016.
We are dedicated to making a genuine impact through our efforts. To do this, our
•• Employees volunteered over 900,000 hours Community Leaders identify local organizations we can partner with to create long-
in 2015 and 2016.
term positive impact. This model gives our partners the confidence to invest in training
•• Nearly 3,000 of our employees in seven our employee volunteers, and it fosters a deeper connection between our volunteers
countries participate in our Community
and the local community. To further incentivize action, we have integrated volunteerism
Leaders program.
into our core business through our employee-driven community investment goals.
Just as for any other business activity, each team is responsible for setting and
delivering on their goals. In addition to our Community Leaders program, we offer
Goals benefits that encourage employees to give back in the way that is right for them:
•• Deliver at least $15 million per year in
employee-driven community investment.
Field Team Grants
•• Employees report at least 430,000
volunteer hours. For every 25 hours a store team volunteers to support youth development or women’s
advancement, they can request a $250 grant for the community organization. We
•• By 2018, 80% of teams have a Community
Leader, and 50% of teams organize incentivize efforts in youth development and women’s advancement because these are
and lead at least three volunteer projects two of Gap Inc.’s sustainability focus areas, where we can have the greatest impact.
per year.
Money for Time
•• By 2018, 70% of Community Leaders
form a long-term relationship with
We donate $150 to the partner nonprofit for every 15 hours an employee volunteers
one nonprofit partner to maximize
volunteering impact. after one year of work.

Financial Donation Match

We match employees’ financial donations to eligible community organizations after


one year of work.

Take Five

Eligible employees can take up to five hours per month to volunteer.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 43
In 2015 and 2016, Gap Inc. and employees contributed over $30 million in employee-
driven community investment, which represents the combined value of volunteer hours,
employee financial contributions and company matching dollars. This amount includes
more than 920,000 employee volunteer hours with organizations focused on a variety
of issues, from helping disadvantaged women thrive to enabling young people to
achieve a better future.

For Gap Inc., these programs deliver both social and business benefits: Our
communities benefit from the long-term impact of our employee volunteer efforts, and
our business is rewarded with more engaged employees who are passionate about
making a difference in the world. For example, we've found that volunteers have a
turnover rate nearly a third lower than individuals who are not similarly engaged, they
stay with our company for nearly twice as long and they are more frequently promoted.

Gap Inc. employees


who volunteer are
more engaged at work,
stay with our company
nearly twice as long
and are more
frequently promoted.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 44
Empowering Women: P.A.C.E.
Women have played an essential role at Gap Inc. from the moment Doris Fisher
The Short Story helped open our doors in 1969. Today, women comprise the majority of both our

P.A.C.E. employees and workers within the apparel industry; investments in women are a
business imperative. We also know that women are powerful catalysts for change,
•• P.A.C.E. unlocks opportunities for
the women and girls who work in the and when women thrive, their communities thrive. Our business supports women’s
global apparel value chain and live in skills development and encourages them to use their voices and dream bigger so
surrounding communities.
they can help themselves, their families and communities thrive for generations.
•• 68,000 women in 12 countries
participated in the program by end Launched in 2007, our unique P.A.C.E. (Personal Advancement and Career
of 2016. Enhancement) program is dedicated to supporting the women who work in the global
•• Participant evaluations document apparel industry, and within our global supply chain. Although women represent the
higher self-esteem and productivity. majority of the sector’s workforce, relatively few have the opportunity to advance to
•• We are expanding P.A.C.E. through management positions, and many lack access to the education and training they need
a partnership with USAID focused on to support their personal and professional growth. We developed P.A.C.E. to give these
women and water.
women the foundational life skills, technical training and support that will help them
advance in the workplace and in their personal lives.

Goals We began offering P.A.C.E. in factories, and as we have developed our approach,
we have expanded the program to unlock new possibilities for women and adolescent
•• By 2020, improve the lives of 1
million women and girls in Gap Inc.’s girls in surrounding communities. To date, more than 68,000 women in 12 countries
supply chain and other manufacturing have participated.
and community settings.

•• By 2020, expand P.A.C.E. to a suite Beyond strong partnerships with our suppliers, a key element of our successful program
of learning programs that address is collaboration with organizations that have a deep understanding of the needs of the
the needs of adolescent girls and
women we aim to serve. The International Center for Research on Women (ICRW), a
women leaders.
global institute dedicated to empowering women, as well as Swasti Health Resource
Centre, worked closely with our teams to design P.A.C.E., and CARE International has
served as a key implementing partner for the program over the years.

In 2016, on International Day of the Girl, we announced the expansion of


the program to bring new educational opportunities to girls ages 11 to 17.
Our new curriculum focuses on improving self-confidence and helping girls
develop future goals and aspirations.
Guided by firsthand stories and metrics-driven results, we are scaling P.A.C.E. beyond
its initial scope. In September 2015, we announced our goal to expand the program
to reach 1 million women and girls by the end of 2020. Always keeping real impact in
mind, we recognize that this rapid, ambitious expansion poses challenges. To address
this, we are working with our partners on innovative implementation approaches that

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 45
10 Years of P.A.C.E.
Program expanded P.A.C.E. launched in China, Commitment to reach
to Cambodia. Sri Lanka and Indonesia 1 million women

2008 2012 2015

2007 2011 2013 2017


P.A.C.E. program Transition from NGO Community Program Government and NGO
piloted in India implementation to a vendor launched in India, Bangladesh engagements begin
trainer model allows us to and Cambodia –
scale up program Girls program kicks off

will help us achieve the right mix of scale and impact. Today, P.A.C.E. programs for
women include up to 80 hours of classroom learning, interactive exercises and open
discussion covering areas such as communication; problem-solving and decision-
making; time and stress management; water, sanitation and hygiene; as well as
additional modules when appropriate. We are currently evaluating how to maintain the
program's impact, while respecting that one of the biggest challenges women face is
enough time to complete responsibilities at work and at home.

The P.A.C.E. for Girls Program is an innovative program that aims to build the skills and
efficacy of young (11- to 13-year-old) and adolescent (14- to 17-year-old) girls to be
confident, resourceful and able to plan for their future. The program aims to enable girls
to negotiate the physical, mental and social transitions during adolescence that have
important implications for outcomes in adulthood. It also aims to strengthen parent-
child communications.

Women who participate


in P.A.C.E. report
increased knowledge,
skills and productivity,
as well as higher self-
esteem and confidence.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 46
In addition to educating women and increasing their skills on these critical topics,
the most transformative lesson P.A.C.E. delivers is knowledge of how women can
advocate for themselves. We want to help women find and use their voices. As we
celebrate the 10-year anniversary of P.A.C.E. and work toward our goal of reaching
1 million women and girls, we have reflected on several key ingredients that make
this program a success: our strong partnerships both internally and externally, our
relationship with our key facility partners and our focus on the women of today. We also
have reflected on how the lives of women have changed over the 10 years P.A.C.E.
has been functioning. To ensure the greatest value to the women within the program,
we are in the process of evaluating our current curriculum to ensure that it remains
relevant in our rapidly changing world.

We have found that P.A.C.E. programs are most effective in communities where
we have a strong presence. By focusing on our supply chain, we are better able to
understand the specific needs and challenges in those areas, and by engaging with
our vendors, we can support their business and ours. To date, 42 suppliers in 10

At its core, P.A.C.E. is helping women use their voices, share their dreams
and own their futures. As a result, women are speaking up for themselves,
their families and their communities. It’s changing lives. This ripple effect is
the power of P.A.C.E.
- Kindley Walsh Lawlor, Vice President, P.A.C.E.

countries are planning on or are currently implementing P.A.C.E. These suppliers


report benefits in the form of improved workforce productivity and performance and
greater retention of workers. P.A.C.E. strengthens our relationship with our suppliers
and enhances their performance, and it also deepens the sense of meaning and
purpose among our employees.

Evaluations of participants have documented our impact: Women who participate in


P.A.C.E. report increased knowledge, skills and productivity, as well as higher self-
esteem and confidence. They describe becoming better at communicating, managing
their finances, taking care of their health and planning for the future. P.A.C.E. has also
helped enhance women’s relationships at work, at home and in their communities.

Gap Inc. and USAID Women + Water Global Development Alliance


In many garment-producing countries, some of women’s most significant challenges
relate to water. Women bear a disproportionate burden when it comes to household
responsibilities such as cooking and cleaning, which require water. According to
UNICEF, women and girls globally spend more than 200 million hours collecting water

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 47
each day—time that could be spent earning additional income, caring for their families
or getting an education. Moreover, women, along with their families, face serious health
risks due to inadequate access to safe drinking water and sanitation facilities, and poor
understanding of healthy hygiene practices.

In an additional effort to address these water challenges and strengthen women’s lives,
we have integrated a water, sanitation and hygiene (WASH) curriculum into our P.A.C.E.
program. The P.A.C.E. WASH curriculum is part of our core P.A.C.E. curriculum and
is key to our larger Women + Water strategy, which seeks to address water issues
through the lens of people and human rights (read more about this on page 75).

In 2017, we announced a partnership with the United States Agency for International
Development (USAID) that will expand this program even further. Gap Inc. and USAID’s
five-year Women + Water Global Development Alliance aims to advance the health and
well-being of women, families and communities touched by the apparel industry.
The alliance will focus on four key areas:

1. improving health and advancing development, including access to sustainable water,


sanitation, hygiene services and hard goods such as toilets and filters, and effectively
managing water resources

2. improving the quality of life and life skills of women touched by the apparel value chain

3. developing an effective model for a systemic partnership across the apparel industry
value chain to achieve development outcomes

4. disseminating lessons learned across and beyond the apparel industry sector

Alliance partners—including Water.org, CARE India, Institute for Sustainable


Communities and ICRW—will draw on their complementary strengths to improve
health and well-being in countries of shared interest, starting in India. To maximize
the impact of these efforts, the Alliance is applying a three-part approach based on:

Gender sensitivity

While we will engage both men and women, we recognize the pivotal role that
women play in society and their unique
needs and opportunities.

Systems thinking

We understand that a variety of interdependent factors can determine the behaviors of


individuals, and we recognize that changes at the individual, organizational, community
and systems levels are often needed to sustainably improve the lives of women, their
families and their communities.

Flexibility

The program will allow us to learn while doing, and we will adjust as the program evolves.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 48
Improving Factory Working Conditions
In this section •• Our Policies and
Commitment to
•• Collaborating on Supply
Chain Sustainability
•• Assessment
and Remediation
Human Rights

We partner with all of our suppliers to ensure safe, fair and healthy
working conditions for the individuals who create our clothes.
Together, we’re building the capacity of our suppliers to manage and
improve their practices, designing industry-leading programs to improve
worker and manager relations, assessing and improving working conditions
to meet legal and international standards and increasing transparency about
all of our efforts.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 49
Context and Approach
Consumer trends and expectations are placing greater demands on production
timelines and capabilities—which can ultimately affect the individuals working in the
garment industry.

To help manage these broad shifts in the industry, we continue to integrate policies and
programs into our core business and form partnerships across the apparel industry to
ensure that the people in our supply chain work in safe, fair conditions.
The Short Story
Since launching our Supplier Sustainability program in 1994, we have transformed our
Factory Working approach to improving facility working conditions by developing innovative programs

Conditions that go far beyond assessing and remediating issues in our approved facilities.

•• We work with governments, NGOs, trade


In recent years we have taken steps to:
unions and others to forge innovative
solutions to systemic issues. •• Revamp our policies and tools such as building out our Code of Vendor
Conduct (COVC) into a comprehensive manual to be more transparent to
•• We have consolidated our supplier base by
our suppliers, so that they understand and meet our expectations related to
25% so that we can work more closely with
fewer suppliers. working conditions and labor standards.

•• We have built a holistic sustainability team •• Consolidate our supplier base so that we are working more closely with fewer
so that all of our field staff can support suppliers. Today, we are working with 25% fewer suppliers than we were five
progress with suppliers.
years ago.

•• Deepen our partnerships with suppliers and NGOs to create a more advisory
and collaborative approach grounded in continuous improvement. With our
Goal suppliers, we are designing new approaches to worker engagement and are
By the end of 2020, we have set a goal for all
providing training to improve suppliers’ social and environmental capabilities.
strategic suppliers to elevate social and labor
performance ratings to earn a rating green or
Examples include our Workforce Engagement Program with Verité and our
yellow, thereby eliminating the most egregious ongoing work with the Arbitration Council Foundation in Cambodia.
noncompliant issues from our supplier base.
•• Build a holistic sustainability team, moving from a model with separate
employee functions by program to require all of our field staff to help deliver
each of our Supplier Sustainability programs. This allows us to evaluate and
improve our suppliers' sustainability performance in an efficient manner and
provide them with support that is best suited to their needs.

•• Pioneer new programs in collaboration with a broad set of industry-wide


initiatives. This includes supporting the Social and Labor Convergence Project
by co-chairing two of its working groups and helping develop the Better Work
Academy in partnership with the ILO's Better Work program.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 50
More than a million people work in the facilities that create our clothes, and
we want to ensure that they work in safe, fair conditions and are treated with
dignity and respect.
Our Supplier Sustainability efforts thus far have primarily focused on issues at cut-
and-sew facilities where we have direct relationships and greater influence to drive
improvements. We also monitor, assess, remediate and disclose their supporting
facilities, such as laundries, embroideries and screen printers. However, we are
evolving our strategy to address issues in other parts of our supply chain, including
areas where we have less direct influence but nonetheless see opportunities to improve
working conditions. For instance, we are working with our strategic mill suppliers to
assess their working conditions and build their capacity to proactively mitigate risks,
Top Sourcing Countries and we are seeking to improve conditions in the cotton sector through our partnership

Our brands sell products that are manufactured with the Better Cotton Initiative
in about 30 countries. All the items we design
and offer are produced in third-party facilities, Our Global Supply Chain and Supplier Sustainability teams work in about 30 countries
owned and operated by our suppliers. A and we often tailor our practices in these places based on a deep understanding of
majority of our purchases come from the six
countries listed below.
the local context. In addition to our Assessment and Remediation program, which we
maintain for every supplier and facility wherever we source branded apparel, we have
created unique programs and specific policies to address local economic, political,
Facilities
Country (As of Jan 28, 2017) business and cultural context where needed. These assessments include social, political
and environmental data, along with risk indices and expert analysis. They also draw on
China 234
the insights we have gathered through ongoing engagement with a variety of external

Vietnam 129 stakeholders and business partners.

When we assess a facility, they receive a rating that is calculated based on clear
India 120
criteria within five categories: Compliance with Laws, Environment, Labor Standards,
Cambodia 59 Occupational Health and Safety, and Management Systems. Violations are input into a
system that categorizes findings by their level of severity: “critical,” “severe,” “key” and
Sri Lanka 53
“non-compliant.”

Bangladesh 51
We use a color-coded system to rate facilities’ performance based on assessments.
High-performing facilities with no critical or few violations receive a green rating.
A list of all facilities we source from
Average performers are rated yellow, while facilities that need improvement on one or
is available here.
more serious issues are assigned a red rating. Critical, severe and key violations have a
greater negative impact on a facilities’ rating than “non-compliance” violations, such as
first-aid kits not being fully stocked.

All of these efforts support our goal to achieve a sustainability rating of green or yellow
for all suppliers by the end of 2020.

Detailed data from our COVC assessments are available online.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 51
Our Policies and Commitment to
Human Rights
The Short Story
We are proud to support the principles outlined in the Universal Declaration of Human

Human Rights Rights (UDHR), the UN Global Compact, the OECD Guidelines for Multinational

•• Garment industry jobs help many people Enterprises and the ILO’s core conventions. These principles form the foundation for
build a better life, but some regions suffer our Human Rights Policy, which defines our approach and activities to respect human
from a lack of infrastructure or rule of law.
rights and prohibit human rights abuses.
•• We support the principles in the Universal
Declaration of Human Rights (UDHR), the Additionally, our COVC—which lays out our standards for labor, working conditions,
UN Global Compact, the OECD Guidelines management systems and environmental management—forms the core of our
for Multinational Enterprises and the ILO’s
commitment to ensuring our vendors respect the human rights
core conventions, and we are signatories to
the UN Guiding Principles on Business and of the people who make our branded apparel.
Human Rights.
Read more about our COVC and our Assessment and Remediation
•• Our Human Rights Policy, Code of Vendor
Conduct (COVC) and other policies outline program on page 68.
our high expectations on social and human
rights issues in our industry. Our Supplier Sustainability team is composed of individuals from the regions in which
they work. We believe that local staff are more effective at understanding workers’
needs, take greater responsibility for enforcing our standards—particularly on issues
that can be difficult to detect—and help us ensure compliance with our COVC.

We believe that local staff


are more effective at
understanding workers’
needs, take greater
responsibility for enforcing
our standards—particularly on
issues that can be difficult to
detect—and help us ensure
compliance with our COVC.

We use an integrated scorecard within our sourcing department to measure our


suppliers’ performance. We believe that further integrating sustainability into our
sourcing practices will play a key role in improving social and labor performance
and limiting any contribution our purchasing practices may have on issues such as
excessive overtime.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 52
In addition to our policies, we recognize that transparency has become a core
expectation of global companies. Twice a year, we publish our approved list of facilities
(see the list here), which includes cut-and-sew facilities, embroideries and laundries.
Our Supplier Sustainability team monitors each of the facilities disclosed on our list,
and publishes detailed data on our assessments, findings and resolution process here.

The sections that follow describe our policies and approaches to ensuring respect for
human rights.

Freedom of Association
Our COVC explicitly supports freedom of association and the rights of workers to
lawfully and peacefully associate, organize and bargain collectively. Many garment
workers have limited experience working at facilities or exercising these rights, and they
often have few other options for earning a steady income to support themselves and
their families. These rights can help workers find a common voice and provide them
with a framework for engaging with management on fair wages, sufficient benefits
and the right to do their work in fair and decent conditions. The limited rule of law in
many developing countries provides fewer protections for workers’ rights, which is why
freedom of association can be such an important enabler in certain countries. We use a
wide range of approaches in seeking to ensure that the rights of freedom of association
are respected, from supporting open dialogue between facility workers and managers,
to partnering with workers’ rights groups and trade unions when appropriate.

Human Trafficking and Forced Labor


The ILO estimates that more than 20 million people globally are forced to work against
their will. This issue has received heightened attention over the past several years due
to the innovative and diligent work of NGOs, governments, multilateral organizations,
media and companies.

Our COVC and Vendor Compliance Agreements explicitly prohibit the use of forced
labor in any stage of our products’ production, and we actively work to combat this
violation of fundamental human rights. While assessing facilities, our field teams
interview both workers and managers and review records to help ensure that workers:

•• have voluntarily agreed to all employment terms

•• are free to end their employment if and when they choose

•• can freely enter and exit their work spaces and living quarters

We believe legislation is an important lever in the global fight against human trafficking;
we welcomed the 2012 California Transparency in Supply Chains Act, which
requires companies of a certain size to publicly communicate their efforts to identify
and eliminate forced labor in their supply chains. We combine this disclosure with
our response to the UK Modern Slavery Act of 2015, which also requires eligible

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 53
businesses over a certain size to disclose annually the actions they have taken to
ensure there is no modern slavery in their business or supply chains.

Our response statement can be found here.

We also collaborate with stakeholder networks in key sourcing countries to monitor


and address forced labor risks. We were pleased that in 2016, KnowTheChain ranked
Gap Inc. second in its benchmark of 20 apparel and footwear companies based on
our efforts to eradicate forced labor from our global supply chain. While we recognize
that there is still much more to do, we are proud to help lead the industry in ensuring all
workers’ rights and freedoms are respected.

While we recognize that there is still much more to do, we are proud to help
lead the industry in ensuring all workers’ rights and freedoms are respected.

Foreign Contract Workers and Recruitment


Gap Inc. maintains that facilities that recruit or employ foreign contract workers (FCWs) shall
ensure that these workers are treated fairly and on an equal basis with its local workers.

Migrant workers shall not be subject to any form of forced, compulsory, bonded or
indentured labor. All work must be voluntary, and workers must be free to terminate
their employment at any time, without penalty. Migrant workers (or their family
members) shall not be threatened with denunciation to authorities to coerce them
into taking up employment or preventing them from voluntarily terminating their
employment, at any time, without penalty.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 54
Within our COVC, we have incorporated an extensive list of procedures and standards
in relation to the treatment and employment of foreign contract workers. Our COVC
states that facilities shall not discriminate, intimidate, control passports or misuse
contracts or recruiting fees and paperwork as they relate to migrant and foreign
workers. We also amended our requirements on employment of foreign contract
workers to ensure due diligence of recruitment agencies before contracts are made
with them, and we regularly assess their existing recruitment agencies on their legal
and ethical recruitment practices. Our Supplier Sustainability team tracks these
procedures to ensure that these workers are treated fairly and on an equal basis with
local workers.

As described in our COVC, facilities are expected to use recruitment agencies only
under the following conditions:

•• The agency is licensed by the home country government, and, where


applicable, the host country government.

•• A written contract exists between the facility and the recruitment agency
that clearly defines all hiring practices.

•• The recruitment agency discloses all the information regarding the use of
any sub-contractors, sub-agents or any individual for recruiting workers for
the facility.

•• The facility (including its employees and representatives) does not accept any
reimbursements, kickbacks or other amounts from the recruitment agency or
other person involved in the recruiting process.

The Supplier Sustainability team audits to determine whether our policies and
standards are followed. Gap Inc.’s Foreign Contract Workers policy states: “The facility
shall pay all fees and costs payable to the host government for the documentation of
FCW’s employment in the host country, including any levies, fees for work permit, fees
for renewing work documents. The facility shall not at any point deduct from wages,
charge workers or otherwise accept reimbursements to recoup these fees. The facility
or the recruitment agency shall not collect from FCWs a deposit or bond or withhold
part of FCWs’ earnings at any point of their employment.”

The FCW policy also prohibits recruitment agencies from charging FCWs any illegal
fees and/or fees payable to the host government, such as levy, legal work document
fees, and fees for renewing work documents.

In cases where it has been found that recruitment fees have been paid by workers,
we require and verify that the affected workers are reimbursed.

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Of all facilities active as of the end of fiscal year 2016, only a few employed foreign
contract workers, including in Jordan, where we partnered with Better Work and the
World Bank to help provide employment opportunities in the garment sector to
Syrian refugees.

Short-Term Contracts
According to our COVC, each facility shall not modify or terminate workers’ contracts
(including the signing of a series of short-term contracts in immediate succession), work
schedules or location for the sole purpose of avoiding wage requirements, including
overtime or other benefits. Temporary, short-term or fixed-term contracts for workers
should not be used for permanent jobs, and workers shall be shifted to permanent
status in accordance with local laws if they have exceeded the specified period.

Unauthorized Subcontracting
Subcontracting is common in the apparel industry, and it can pose risks because
suppliers may outsource production to facilities that have not been approved by
buyers and that do not uphold requirements for safe, fair labor practices and working
conditions. Our Global Supply Chain and Supplier Sustainability teams collaborate to
address unauthorized subcontracting (UAS).

We take extra precautions in countries with a high risk of UAS by offering specialized
training for suppliers and facility management, and by conducting site visits to ensure
our product is being manufactured in the appropriate designated facility. Our Supplier
Sustainability, Quality Assurance and Merchandising teams seek to detect UAS. If a
case is found, we may impose financial chargebacks, or, in severe or repeat cases,
we will terminate our business with a supplier. In the event that chargebacks are
imposed, those funds are reallocated either philanthropically or programmatically
toward projects that are focused on improving working conditions within our supply
chain or across the industry. High-Risk Incidents are immediately escalated and the
following steps are taken:

•• requires the unauthorized facility to immediately stop production of any


Gap Inc. branded apparel

•• ensures all goods (finished or unfinished) are returned to a facility approved by


Gap Inc., segregated and held until the issue is resolved

•• leads an investigation to look for and address any critical issues in the
unauthorized facility

•• requires the approved facility to register for management systems training


as a prevention measure, ensuring facilities invest in systems to prevent
future violation

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 56
Discrimination
We are committed to ensuring that the people who make our clothes are not subject
to any form of discrimination. Our COVC prohibits any form of discrimination during
hiring, compensation, access to training, promotion, termination or retirement based
on race, color, gender, nationality, religion, age, maternity status, marital status,
indigenous status, ethnicity, social origin, disability, sexual orientation, HIV/AIDS status
or membership in worker organizations, including unions or political affiliation.

We conduct
assessments of all
branded apparel
suppliers on a regular
basis to check for any
signs of discrimination.

We conduct assessments of all branded apparel suppliers on a regular basis to check


for any signs of discrimination in hiring or promotion decisions, contract terms, labor
practices, payroll records or tests or medical exams workers may be asked to take.
We know that enforcing our discrimination standards requires significant time and
attention, especially because the majority of garment workers are women, while the
vast majority of supervisors and managers are men.

Our team also identifies common risks and best practices for pregnant or nursing
women, including rearranging working hours, adjusting overtime hours and offering
greater flexibility for break times.

Child Labor
Gap Inc. does not tolerate the use of child labor under any circumstances.
We do recognize that it is a deeply complex issue that is inextricable from the broader
issues of poverty and economic development. Our Human Rights Policy and our
COVC explicitly prohibit the use of child labor. We require our supplier facilities to
establish robust age-verification processes to prevent employment of children or
underage workers. We also work to ensure that facilities respect local laws and
international standards related to employing younger workers who are not children.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 57
During facility visits, our Supplier Sustainability team interviews workers and managers
about recruitment and hiring, labor practices and working conditions for young workers.
They check for lawful, unaltered documents to verify workers’ ages, since workers can
go to great lengths to obtain counterfeit documents. Our teams also monitor whether
facilities are upholding labor laws and standards for legal young workers.

In the rare event that we encounter child labor at an approved facility, we take
immediate action to resolve the issue, including:

•• removing young workers from the facility

•• making sure workers have access to education or appropriate training,


receive an ongoing wage and are guaranteed a job if they choose to work at
the facility when they are older

•• requiring the offending supplier to pay for all remediation costs

Wages
We require suppliers to pay the legal minimum or industry wage, whichever is
higher. When violations are found, the facility must remedy the situation. If wage
violations are found and the supplier fails to properly remediate, we will implement
consequences up to and including termination of our relationship with that supplier.

We have conducted wage studies in our supply chain multiple times in order to assess
wages paid against various local and international frameworks. In data collected from
a selection of our suppliers, we found wages met minimum wage requirements and in
many cases exceeded local norms. To ensure the accuracy of this baseline study, we
engaged an independent third party to verify the process and findings.

We also collaborate on advocacy work to push for appropriate wage-setting


mechanisms in certain countries. Most recently, in response to the unrest in December
2016 in Bangladesh, we sent a letter to the prime minister of Bangladesh, seeking to
encourage the government to institute a regular wage review mechanism. We believe
that annual wage review mechanisms are an important legislative protocol, as they will
help ensure that minimum wage levels are adjusted on a regular basis to account for
inflation and cost of living adjustments.

Working Hours
Excessive working hours is one of the most common and persistent issues at the
facilities making our branded apparel. Several factors can contribute to this: Facility
managers may request overtime to meet tight deadlines or boost sales, workers may
choose to work more hours to increase their pay and buyers’ purchasing practices
such as rush orders can lead to more overtime. Recognizing our role in this, we
participated in a program to improve our understanding of how our purchasing choices
can lead to better outcomes. As part of Better Buying’s beta test, we enlisted suppliers

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 58
from South Korea, Sri Lanka and Hong Kong to evaluate our purchasing practices and
provide feedback on their impacts. Using the results of that project, we will seek to
incorporate insights into our core business operations, such as improved forecasting
and giving appropriate lead times.

The issue of capacity adds another layer of complexity to purchasing practices.


Apparel facilities typically work with five to 10 apparel brands at any given time. Despite
their efforts, facilities often miscalculate their capacity or buyers change orders at
the last minute, which means facilities may face too much or too little production
which directly affects working hours. To address this challenge, we have created
a team devoted solely to capacity planning. This allows us to build more balanced
purchase orders and ultimately help our suppliers improve how they manage their own
operations such that we can address the issue of working hours.

We impose several requirements that address working hours:

•• Workers must be allowed to refuse overtime without any threat or penalty


of punishment.

•• Workers must not be required to work more than six days in a row.

•• Facilities must take corrective actions to limit excessive overtime, which can
include analyzing the root causes of issues, adjusting production schedules
and improving management systems.

Based on each country’s laws, we set the total number of allowable working hours
per week, including overtime. Our facility ratings system identifies and implements
consequences for serious overtime violations.

Humane Treatment
The demands of garment manufacturing—including production targets and other
requirements—can place significant stress on workers and supervisors, which may
contribute to mistreatment in the workplace. We also recognize that supervisors may
not have enough training or experience to constructively communicate with workers,
or understand appropriate behavior in the work environment.

Read more about the Workplace Cooperation Program on 64.

We monitor for signs of verbal, psychological or physical mistreatment, including


coercion and threats to workers. Facilities are required to provide workers with
grievance channels and training on how to use these mechanisms, and we expect
facilities to have a disciplinary process and take action to address issues. We also
collaborate with select facilities through our Workplace Cooperation Program to
proactively improve worker-manager dialogue and relationships.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 59
Sexual Harassment in India
Women constitute 60–80% of India's apparel workforce. Recent build an environment where they clearly define and implement the
reports have highlighted that these women face widespread and national policy on Prevention of Sexual Harassment (as required
underreported sexual harassment, and this coverage has helped legally), and create an Internal Complaints Committee (also legally
create awareness within local communities and among various required). We also want to help them raise awareness among
stakeholders. Protection against sexual harassment and the right both male and female employees about the issue and about their
to work with dignity are universally recognized human rights by rights and responsibilities under the Sexual Harassment at the
international conventions. Workplace (Prevention, Prohibition and Redressal) Act of 2013.
We believe that implementing these mechanisms will help prevent
During regular facility assessments, we have found that there is
sexual harassment in the workplace.
a systemic failure to address this issue, despite stringent local
laws. There is also an opportunity for both local employers and We have conducted sensitization programs with all of our
employees to have a better understanding of this issue and the suppliers in India and have provided them with guidance on
legal requirements. legal requirements. We also have defined time-bound goals and
identified implementing organizations for this work.
To address this, our team is working with our suppliers in India,
covering around 100,000 workers. We aim to help our vendors

Grievance Mechanisms
We require facilities to provide a confidential and anonymous channel for workers
to express grievances without fear of retaliation. The grievance process must allow
for a timely response, with documentation, and an action plan to address the issue.
Our field team trains factory workers and managers on establishing and using
grievance mechanisms. If our team identifies any issues, we require facilities to
implement corrective action plans and evaluate their performance.

In 2015, we provided all of our suppliers with information on how to effectively operate
and manage grievance mechanisms. Key elements include:

•• information on how effective grievance mechanisms can play an important role


in identifying, preventing and remediating issues of concern on the facility floor

•• how facility-level grievance mechanisms can help support workers’ ability to


raise concerns and seek remedy in the workplace

•• how mechanisms can enable facility management to understand and address


issues before they escalate into bigger issues

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 60
We also train facility managers and workers on effectively using and managing
grievance mechanisms through our Workplace Cooperation Program (described on
page 64). Going forward, we will be focusing on improving facilities’ capabilities to
implement properly functioning grievance mechanisms and ensuring workers are able
to use them to advocate for their rights and well-being.

Fire and Building Safety


Levels of fire and building safety vary greatly across the global apparel industry,
and depend on a number of factors, including local laws and regulations, building
maintenance, the technical capabilities of local experts and the expectations and
actions of suppliers and brands.

To address this, our Supplier Sustainability team works to improve fire and building
safety by checking that all facilities:

•• maintain sufficient fire alarms, clearly marked exits and emergency lighting

•• conduct evacuation drills

•• keep all doors, aisles, exits and stairwells clear, accessible and unlocked
during working hours

•• maintain and charge fire extinguishers that are visible and accessible to
workers in all areas of the facility

We also continue to evaluate how our involvement in the Alliance for Bangladesh
Worker Safety can inform our approach to addressing fire and building safety across
all of our suppliers’ facilities. For example, we began conducting comprehensive fire,
building and electrical safety inspections in our approved facilities in Pakistan to identify
risks that may require immediate attention in that country.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 61
Bangladesh
Alliance for Bangladesh Worker Safety
Gap Inc. is a founding member of the Alliance for Bangladesh as well as the national garment industry, continually improve
Worker Safety. Now in its fifth year, the Alliance continues its working conditions. We have formed an expert team focused on
efforts to help ensure safer factories in Bangladesh. It has improving fire and building safety at the facilities producing our
released regular progress reports, including its third Annual branded apparel in Bangladesh. We also provide training to help
Report in 2016, as well as impact assessments and monthly drive worker and management behavior changes to improve fire
statements on completion of Corrective Action Plans and safety practices.
suspended operations. All reports may be found on the
Looking forward, we will continue to operate our program within
Alliance website.
Bangladesh, and strengthen our work with stakeholders to
In addition to our participation in the Alliance, we maintain achieve our collective vision of a multi-stakeholder, industry-wide
our commitment to ensuring that the facilities we work with, solution for improving the country’s working conditions.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 62
Collaborating on Supply Chain Sustainability
Addressing the systemic challenges of the apparel industry requires collaboration.
We embrace this approach by working closely with our suppliers to build their
capabilities, by joining industry-wide efforts to share best practices and improve
efficiency and by partnering with local and international NGOs on innovative programs
that benefit facility managers and workers.

Empowering our Strategic Suppliers


We partner with the facilities where our products are made to help them become
The Short Story
preferred employers in the communities where they operate. This supports workers
Collaboration and can benefit business by driving higher retention and improved productivity.
•• We work closely with our strategic suppliers To achieve this, we take a multipronged approach to building our suppliers’ capability.
to help build their capability to manage
social and environmental issues. To cultivate long-term, close relationships that allow us to create greater change

•• In partnership with organizations such as together, we are working with a smaller number of strategic suppliers. Over the past
Better Work and Verité, we are pioneering five years, we have streamlined our approved list of facilities from more than 1,200 to
programs that improve worker-manager
fewer than 900. With those suppliers, we develop shared sustainability goals and work
relationships and enhance worker
engagement and well-being. with them to measure and improve performance.

•• Together with the Social and Labor Our tier 1 suppliers are trained on our COVC on an ongoing basis. We also engage
Convergence Project, we are helping create
many suppliers more deeply through industry-leading programs such as P.A.C.E.
a shared tool for footwear and apparel
companies to assess facilities’ social and (described on page 45), our Workplace Cooperation Program (page 64) and our
labor performance. Workforce Engagement Program (page 66).
•• 164 of our facilities—20% of our strategic
suppliers—are enrolled in Better Work’s To help our suppliers make strategic investments in their employees and business
program to reduce the duplication of audits operations, we have increased their access to data and analysis from our Assessment
by brands.
and Remediation program (described on page 68). Over time, we will also disclose on
•• We have trained 31 facilities in nine countries each supplier’s involvement in various Gap Inc. programs and their areas of opportunity
through our Workplace Cooperation Program
for improving performance.
to improve dialogue and relations between
workers and management.
We believe that as suppliers take more ownership of their sustainability programs,
they will realize the business benefits and will require fewer external assessments
and incentives.

Social and Labor Convergence Project


The proliferation of duplicative assessments and their associated protocols consume
time and resources that suppliers could use to create real progress in their workers'
lives. We believe streamlined approaches to measuring social and environmental
performance can support systemic progress and make it easier for more businesses to
improve their social and environmental performance.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 63
That’s why, in 2015, Gap Inc. became a signatory to the Social and Labor
Convergence Project, a collaboration among apparel and footwear brands, retailers,
industry groups and civil society organizations. The project is building a shared data-
collection tool that can assess the social and labor performance of a manufacturing
facility. The initial tool was piloted in 2016, and it will be further tested in 2017.
The project aims to have the tool and verification methodology ready for adoption
in 2018. To help the project achieve its goals, Gap Inc. is chairing two key working
groups: the Tool Development Working Group and the Verification Working Group.

In 2015, Gap Inc. became a signatory to the Social and Labor Convergence
Project, a collaboration among apparel and footwear brands, retailers,
industry groups and civil society organizations.

ILO Better Work, Capability building and the


Workplace Cooperation Program
As part of our efforts to go above and beyond assessment and remediation and work
more collaboratively with our suppliers and other stakeholders, we have played a
leading role in multi-stakeholder collaborations such as the ILO’s Better Work program.
Better Work takes an advisory approach to monitoring facilities, with an emphasis
on protecting worker rights and well-being by helping companies and governments
uphold the ILO’s core labor standards and national labor laws. Better Work leads
facility assessments and helps address and remediate issues in Vietnam, Cambodia,
Indonesia, Bangladesh, Jordan, Haiti, Nicaragua and Lesotho.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 64
We have partnered with Better Work since its founding, and today we collaborate in a
variety of ways: We sit on the Better Work Advisory Board, we partner with them on
advisory services in eight of our sourcing countries and we advocate for other buyers
to adopt Better Work’s assessment reports instead of duplicating audits. Previously, we
set goals to have 70% or more of facilities in ILO Better Work markets participate in the
Better Work program. Our goal now is to enroll 100% of our eligible facilities in Better
Work countries in the program by the end of 2018.

In 2015, we partnered with Better Work to create a new capability-building program


for the facilities we work with. This Workplace Cooperation Program gives workers and
managers the skills they need to resolve workplace issues, engage in collaboration
and drive continuous improvement in the workplace. Upon helping fund the expansion
of this program, we then asked Better Work to train our Supplier Sustainability team
on this curriculum, so we could deliver it to non-Better Work facilities. Through this
program, we help train committees of workers and managers to develop sustainable
solutions and share best practices for workplace challenges. The trainings cover
communications and problem-solving, how to handle grievances, negotiation skills
and more. Through this program, our Supplier Sustainability team also trains workers
and managers on how to run effective, collaborative discussions to promote improved
dialogue between workers and management.

We believe that improving dialogue and relations between workers and management
can help prevent labor disputes, resolve problems, give greater voice to workers and
improve productivity and competitiveness.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 65
In 2015-2016, we implemented training activities with 31 facilities in nine countries,
and we plan to expand into 69 facilities by 2017. In 2018, we will be adding a training
focus on supervisory skills to help define worker rights, supervisor responsibilities and
professionalism in the workplace. This program also teaches other valuable skills,
including communication and effective listening.

Facilities Assessment and Remediation in Better Work Markets (2016)


Facilities Assessment by Better Work or Gap Inc. during fiscal year

Country Facilities Assessed by Better Work Facilities Assessed by Gap Inc. Total

Bangladesh 18 34% 35 66% 53

Cambodia 40 67% 20 33% 60

Haiti 7 88% 1 13% 8

Indonesia 30 32% 65 68% 95

Jordan 3 75% 1 25% 4

Lesotho 2 100% 0 0% 2

Nicaragua 1 25% 3 75% 4

Vietnam 59 45% 71 55% 130

Total 160 45% 196 55% 356

*Not all assessed facilities are approved, or facilities may be newly approved or deactivated during year

Workforce Engagement Program


In addition to ensuring that the people who make our clothes work in safe, fair
conditions, it is crucial that they feel valued and engaged at work. Research has
shown that employee engagement enhances workers’ sense of well-being, and can
Goal also demonstrate positive business outcomes. According to Workplace Research
By 2018, partner with Verité and our
Foundation, highly engaged employees are 38% more likely to have above-average
strategic suppliers to measure workers’
engagement, and launch projects aimed at productivity, and suppliers that invest in workers receive a three-to-one return on
improving 20,000 workers’ sense of value their investment.
and engagement at work. Publicly report
on findings and impact, and share best In 2015, we launched our Workforce Engagement Program with Verité, a leading NGO
practices with all Gap Inc. suppliers.
with deep expertise in improving working conditions in the garment sector. The goal
of the program is to measure and improve the degree to which garment workers feel
valued and engaged at work, by giving workers an opportunity to provide anonymous
feedback on key topics such as supervisor relationships, grievance mechanisms, and
training and development opportunities.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 66
This information is collected through surveys, focus groups and one-on-one
interviews, which provide a cross-section of both quantitative and qualitative data
for our field team to derive insights from. Upon two years of implementation with
Verité, we began testing the delivery of this program through interactive voice
response (IVR) technology, smart phone applications (WeChat) and tablets. To do so,
we partnered with Good World Solutions, launching the technology-based survey in
three of our key sourcing countries.

Upon receipt of the data collected by Verité or Good World Solutions, we then
help our suppliers analyze the workforce-related insights to create tailored
recommendations they can use to make investments in their employees. This
analysis also informs training programs for facility managers, as it serves as the basis
for our Supplier Sustainability team to develop tools for facility managers to increase
workers’ satisfaction, knowledge and overall well-being. To achieve that end, in 2016
Gap Inc. created an Engagement and Well-Being Toolkit for suppliers, meant to
provide them with resources that can help them improve various workplace-related
issues. Examples of this include team-building activities, supervisory skills trainings
and investments in well-being infrastructure, such as building daycare centers on site
to help working mothers.

To date, we have worked with Verité to complete surveys in 81 facilities in


Bangladesh, China, Guatemala, India and Vietnam, and with Good World Solutions
we have delivered the tech-friendly survey to eight facilities in China (IVR and
WeChat), Sri Lanka (tablet) and Vietnam (IVR)—reaching a workforce of over 220,000
workers since 2015.

The goal of the Workforce Engagement Program is to measure and improve


the degree to which garment workers feel valued and engaged at work, by
giving workers an opportunity to provide anonymous feedback on key topics
such as supervisor relationships, grievance mechanisms and training and
development opportunities.
We have found that the program supports both social and business objectives: For
workers, it enhances well-being by helping facility managers listen to and act on their
concerns and ideas about improving the workplace. For management, giving workers
better benefits and resources at work can help increase productivity, improve retention
and lower absenteeism. The program also benefits our business by promoting an ethos
of continuous improvement among our suppliers. And by delivering best practices
and recommendations to our suppliers, the program is helping us meet our goal for all
strategic suppliers to achieve a sustainability rating of green or yellow by 2020.

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 67
A recent independent study completed by Verité highlights some of the positive
business benefits, making the case that when suppliers invest in their employees, their
business can benefit as well. Simultaneously, when facility management chooses not to
act upon the insights revealed in these assessments, or when coaching mechanisms
are deployed to provide “positive answers,” little improvement is observed by workers.

As we evolve the program, we will continue to find ways to incentivize supplier


ownership of this approach. We will continue to help facility managers understand that
this is not a compliance-related exercise, but is rather a program that complements
traditional assessments by focusing solely on the workforce as an asset. Further, we
will seek to deepen our partnership with other companies operating similar programs,
namely through the BSR Working Group on Worker Engagement, by sharing best
practices and seeking to align worker well-being and engagement tools.

Assessment and Remediation


Since beginning our Supplier Sustainability program in 1994, we have refined our
approach and introduced a range of innovative measures to more accurately assess
facility performance, focus our time on the most critical issues, better understand the
experience of the people who make our clothes and make sure their voices are heard.
We view our suppliers as critical partners in meeting our business and sustainability
The Short Story
goals, and we work with them to set shared goals and monitor and improve
Assessment and performance. Together, we share accountability for sustained improvement of working
Remediation conditions, which will help us reach our goal of ensuring all our supplying facilities meet

•• We aim to create industry-leading standards performance standards.


that go above and beyond local laws.
Today, our COVC, composed of industry-leading standards and legal requirements, is
•• We partner with our suppliers to set and
a living document that defines our standards for working conditions at the facilities that
deliver business and sustainability goals.
make our products. It is incorporated into our Vendor Compliance Agreement, which is
•• We updated our Code of Vendor
signed by all our branded-product manufacturers.
Conduct (COVC) and created new tools
to improve sustainability performance to
drive positive change. Our Supplier Sustainability Assessment Manual, which is based on industry best
practices, outlines the protocols our team uses to assess and remediate issues related
to labor or working conditions. Each fiscal year, our team conducts a full assessment
for all active manufacturers of our branded product to understand working and labor
Goal
conditions, facilitate greater partnership with our suppliers and improve sustainability
Achieve a sustainability rating of green or
performance. Each assessment includes interviews with managers, confidential
yellow for all suppliers by the end of 2020.
interviews with workers, visual observations and reviews of documents and records.

When we assess a facility, they receive a rating that is calculated based on clear
criteria within five categories: Compliance with Laws, Environment, Labor Standards,
Occupational Health and Safety, and Management Systems. Violations are input into
a system that categorizes findings by their level of severity: “critical,” “severe,” “key”
and “noncompliant.”

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 68
We use a color-coded system to rate facilities’ performance based on assessments.
High-performing facilities with no critical or few violations receive a green rating.
Average performers are rated yellow, while facilities that need improvement on one or
more serious issues are assigned a red rating. Critical, severe and key violations have a
greater negative impact on a facilities’ rating than “non-compliance” violations, such as
first-aid kits not being fully stocked.

A key tenet of
our approach to
partnering with
facilities is that
we work to fix
what we find.
A key tenet of our approach to partnering with facilities is that we work to fix what we
find. Together with facility management, we agree on specific, time-bound corrective
action plans to address findings, and we provide additional resources to fix the issues
that pose higher risks to workers’ rights and well-being, as well as to our business.
Based on the severity of issue, we outline a timeline within which we expect the
factory to fully remediate. We also collaborate with local stakeholders who have direct
access and influence to improve conditions. We monitor progress through follow-up
assessments. Should there be outstanding or overdue issues, our Supplier Sustainability
and Global Supply Chain teams escalate further intervention. However, if key or critical
issues remain unresolved, we may halt future order placement or discontinue the
supplier relationship.

In 2015, we introduced revisions to our COVC requirements, through the creation


of Gap Inc.’s COVC Manual and a revised Assessment Manual for our Supplier
Sustainability team. We have trained all our tier 1 suppliers on our COVC Manual,
which is the primary training resource that helps our suppliers understand how to
meet our sustainability requirements and proactively address issues related to labor
standards, working conditions, the environment and more.

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To help our suppliers take greater ownership of improving working conditions, we
added the Management Systems category in 2015. This category measures the
degree to which facility managers establish goals, implement plans, train employees,
conduct their own assessments and adjust their programs to ensure continuous
improvement. Also in 2015, we launched a new data system that includes a portal for
our suppliers to easily access information related to their sustainability performance
and find tools that can help them manage their risks and opportunities.

In 2017, we will be expanding our minimum requirements for suppliers, with additional
guidance on fire, electrical and structural safety based on our learnings in Bangladesh
and best practices in the industry.

Detailed data from our COVC assessments are available online.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 70
Water Stewardship
In this section •• Women + Water •• Improving Manufacturing in Mills
and Laundries
•• Chemicals

Water is essential for our business as well as the people and communities
where we operate. At each stage of our products' creation, we look for ways
to reduce water impacts. Through our programs, we reduce water use,
eliminate discharge of hazardous chemicals and work directly with women to
improve their access to clean, safe water.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 71
Context and Approach
Few resources are as essential to people’s health and well-being as water; we believe
clean, safe water is both an environmental issue and a basic human right. Water is also
critical to our business—it is used to cultivate raw materials like cotton, consumed in
the mills and laundries that manufacture our products and used by consumers when
they wash their clothes.

In recent years, decreasing availability of safe, clean water has become a significant
global challenge. Since 2015, the World Economic Forum has ranked the water crisis
as one of the top five global risks in terms of impact.1 It affects many people: One-third
of the world’s population lives in countries with poor water quality or where there is not
enough water. That ratio is expected to reach two-thirds by 2025.

By 2030, it is estimated that demand for clean water will exceed supply by 40%.
Climate change is exacerbating the water crisis, contributing to more frequent and
severe droughts, storms and floods, which affect livelihoods and increase the risk of
waterborne diseases. The issue of water is so important that the UN identified the
need to ensure the availability and sustainable management of water and sanitation as
Sustainable Development Goal (SDG) 6, Clean Water and Sanitation, which is one of
the 17 SDGs.

As a business that relies on water to create our products in communities where people
need access to water for their daily lives, water stewardship is a core pillar of the
Gap Inc. sustainability strategy. To help build the resilience of our company, our supply
chain and the people who make our clothes, we strategically address water use, water
contamination and education about water and sanitation.

Our Women + Water strategy is aimed at reducing impacts in three primary ways:

•• Building awareness and educating the women who make our clothes about
safe water-handling practices, and by increasing their access to safe water

•• Partnering with fabric mills and laundries to reduce manufacturing impacts

•• Adopting more water-efficient product design and sourcing practices

Apparel production requires water throughout its life cycle, and the manufacturing
process has significant water impacts. Cotton, an important raw material for Gap Inc.,
is one of the most water-intensive crops: About 1,500 gallons of water are needed to
produce the 1.5 pounds of cotton within a single pair of jeans. Additionally, harmful
chemicals used in dyeing and laundering can pollute as much as 200 tons of water per
ton of fabric. In a climate-challenged world where both too much and too little water

1
http://reports.weforum.org/global-risks-2017/the-matrix-of-top-5-risks-from-2007-to-2017/

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 72
can have a serious impact, cotton sourcing has become a risk, with repercussions
throughout our supply chain.

Beyond our supply chain, we are saving water through design choices and by
educating customers about water stewardship. We proudly communicate our efforts in
our product labeling, catalogs and online. Through this engagement, we hope to keep
customers informed about our progress and inspire them to consider water in their
daily lives and communicate the urgency of the work we’re doing.

For more on our efforts to reduce impact, specifically water-saving initiatives within
product design, see page 87.

Women and the Impact of Water


Of crucial importance is how water affects the people who make our clothes—roughly
80% of whom are women. These women need water to care for themselves, their
families and their communities. Unfortunately, access to clean, safe water is a major
challenge in many of our key sourcing countries, according to basin-level water risk
mapping through WRI’s Aqueduct tool, and issues such as population growth and
climate change exacerbate the crisis. In water-stressed areas, poor and marginalized
communities are affected the most. In India, groundwater pollution from agricultural and
industrial activities and poor sanitation represent a root cause of water-quality issues
that increase health and mortality risks. In China, 80% of water from underground wells
is unfit for drinking or bathing because of contamination from industry and farming.

Country China India Bangladesh Cambodia Indonesia

Mills • •
Denim
Laundries • • • • •
Wet
Processing • • • • •
Cut/Sew
Facilities • • • • •
P.A.C.E.
Program • • • • •
Water Medium/ Extremely Low/
High High
Risk* High High Medium

*Source: Conservation International research for Gap Inc.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 73
Women + Water
Our water strategy is focused on the intersection between our industry’s significant
use of water and the basic right people have to clean, safe water. In many parts of
the world, women are largely responsible for household duties such as cooking and
cleaning; they shoulder a disproportionate burden when it comes to water stress.
If women had better access to water, they could spend that time caring for their
families, getting an education or earning additional income. Women and children also
face serious health risks due to inadequate access to safe water and sanitation, which
is sometimes worsened by a limited understanding of healthy hygiene practices.

We recognize that water resource management is multifaceted, requiring diverse


solutions. To make holistic change at the individual, organizational, community and
systems levels, we need to coordinate efforts across business, government and civil
society. In addition to focusing on education and awareness, we also partner with
organizations to improve secure access to clean, safe water.

Our supply chain connects us to many of these women and their communities, giving
us an opportunity to help improve their access to water and help them manage water
issues. We support women and communities in two main ways: through our P.A.C.E.
program, which includes curriculum about health and safe water-handling practices,
and through partnerships with experts to address other systemic challenges, such as
access to clean, safe water.

Our water strategy is focused on the intersection between our industry’s


significant use of water and the basic right people have to clean, safe water.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 74
P.A.C.E. and the USAID Women + Water Global Development Alliance
In 2014, we introduced water, sanitation and hygiene (WASH) curriculum to our P.A.C.E.
program, which supports the women who make our clothes in gaining the skills and
confidence to advance in work and life (read more about P.A.C.E. on page 45). With our
expansion of P.A.C.E., and the goal to reach 1 million women and girls by the end of
2020, we are eager to reach even more women with effective strategies for managing
water issues.

With our expansion of


P.A.C.E., and the goal to
reach 1 million women and
girls by the end of 2020,
we are eager to reach even
more women with effective
strategies for managing
water issues.

In 2017, we announced a significant new partnership: a five-year collaboration with the


US Agency for International Development (USAID) to improve access to clean water and
sanitation services for the women touched by the apparel industry. We are expanding
our P.A.C.E. program in India to teach safe water-handling practices, alongside our
longstanding partners CARE and the International Center for Research on Women
(ICRW). We will also support access to clean water and sanitation with our partner
Water.org, and we will work to manage local water resources sustainably, in partnership
with the Institute for Sustainable Communities.

Read more about our USAID partnership on page 47.

Our partnership with USAID is designed to support women and communities as they
learn about WASH practices, while also developing leadership skills. This supports
women as they take initiative to incorporate improved water infrastructure in their
communities. Our partnerships take this program beyond education to provide the
essential hard goods, such as toilets and filters, needed in the home and to provide
neighborhoods with clean water access.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 75
Improving Manufacturing in Mills
and Laundries
The Short Story The processes behind making a piece of clothing affect both the environment and
people in the surrounding communities. Traditional fabric mills use a great deal of water
Mills and Laundries and chemicals during the dyeing and finishing process, and wastewater must be treated
•• Launched in 2013, our Mill Sustainability to ensure that both ecosystems and nearby communities are protected. Laundries,
Program expands our environmental efforts especially for denim, also require a great deal of water and pose pollution risks.
well beyond our own operations.

•• This program has reduced water and Gap Inc. is working with fabric mills and laundries to improve practices, and we are
electricity use, as well as wastewater pursuing partnerships across our supply chain to reduce water and chemicals use. We
discharge.
aim to save 1 billion liters of water in our manufacturing processes by the end of 2017.
•• We have strengthened our Mill Sustainability
Program and our Water Quality Program to We encourage and support our suppliers in conducting environmental footprint
reduce water impacts and fight pollution. assessments, including water use, using the Sustainable Apparel Coalition's (SAC)
•• We also partner with several industry Higg Index. Though our sustainability programs have traditionally focused on our tier
initiatives, including NRDC's Clean by 1 cut-and-sew facilities, we recognize the need to measure and address the impact
Design, Race to the Top and the Partnership
of the apparel supply chain more broadly. For this reason, we have expanded our
for Cleaner Textile program.
program beyond direct suppliers to reach deeper in our supply chain. Through our Mill
Sustainability Program, we have used the Higg Index to engage strategic mills in China,
India, Pakistan, Vietnam, Korea and Taiwan to conduct environmental assessments,
Goals including water consumption and wastewater treatment and disposal. We are also
•• Together with our suppliers, reduce
actively monitoring and helping improve wastewater quality at denim laundries through
water use in manufacturing by 1 billion
liters by 2017. our strengthened Water Quality Program (WQP).

•• Work toward zero discharge of hazardous In 2015 and 2016, we began working closely with our suppliers to share important
chemicals by 2020.
benchmarking data so our suppliers can see how their environmental performance
compares to competitors and peers. With a dashboard, we provide details—by country
and factory—water consumption, greenhouse gas (GHG) emissions and energy use—
and suggestions to help our suppliers identify opportunities for improvement.

Gap Inc. suppliers


have saved 668
million liters of
water since 2014.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 76
Mill Sustainability Program
Launched in 2013, our Mill Sustainability Program aims to improve the practices of
fabric mills, while delivering benefits to the people who live in surrounding communities.
Our program establishes clear environmental standards, and we are integrating those
standards into our sourcing decisions. We also aim to scale improvements across the
industry by working with our peers to identify and share best practices for improving
the use of water, chemicals and energy.

We started our program by working with strategic mills in China, India, Pakistan and
Taiwan to conduct environmental assessments, covering issues such as their energy
use, water consumption, wastewater treatment and disposal and handling of waste
and hazardous substances. Between 2015 and 2016, we expanded our program to
reach more mills, and we updated our mill policy to strengthen expectations. We have
invited 112 of our strategic mills—representing more than 70% of our fabric spend—to
participate in the Higg index.

Going forward, we will continue to work with our supply chain business partners to
engage with more tier 2 suppliers. We plan to establish an onboarding process for new
mill suppliers, with clear communication of our performance expectations. Additionally,
we communicated Minimum Expectations of Social and Labor and Environmental
Issues to our entire mill base in March 2017. By further integrating this program and
performance metrics across our business—and sharing innovative techniques and best
practices with our vendor partners and mills—we will broaden our impact.

The apparel sector is a thirsty industry, with significant water impacts—from water
consumption during production, to the use of harmful chemicals in dyeing and
laundering, to industrial water pollution. We have created internal programs working with
our strategic suppliers to reduce our company’s impact, and we participate in leading
industry initiatives to reduce the impacts of the sector more broadly.
–Sally Gilligan
Senior Vice President, Strategy and Product Operations, Global Supply Chain

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Mill and Laundry Partnerships
In addition to our Mill Sustainability Program, we are working to improve water impacts
by partnering with several industry collaborations.

The Natural Resources Defense Council's (NRDC) Clean by Design program works
with global apparel companies to help textile mills reduce their use of water, energy and
chemicals. Since 2009, we have worked with Clean by Design to help mills conserve
resources, save money and improve their performance. During the reporting period,
we focused on helping three mills in Suzhou, China, improve their overall environmental
performance by reducing their use of water, energy and chemicals. This project, which
ended in 2017, resulted in a savings of 620 million liters of water per year.

In Vietnam, we work with Race to the Top, an initiative that includes global apparel
and footwear brands, government, local industry and civil society. Race to the Top
aims to scale up sustainable practices across the country’s garment-manufacturing
sector by focusing on four pillars: proving the benefits of a sustainable apparel sector,
demonstrating the business case for manufacturers and mills to invest in sustainability,
creating a supportive regulatory environment, and creating cost efficiencies and
opportunities for innovation in sustainability across Vietnam.

In Bangladesh, we are part of the Partnership for Cleaner Textile (PaCT), a program
focused on improving the environmental performance of the country’s textile wet-
processing sector. In Bangladesh, wet-processing facilities can use three times more
water than the global average. This not only wastes water, it consumes more energy
and costs more. Through PaCT, we are working with three denim laundries, where
we have the potential to save nearly 85 million liters of water. With four other laundries
nominated by other brands, there’s potential to save up to 114 million liters.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 78
In 2015, we built a training program focused on resource efficiency with three mills
in water-stressed regions in northern India. Building on this pilot, our India Water
Partnership with 10 mills provides technical expertise on water and energy efficiency,
as well as chemicals management.

Chemicals
Chemicals are used throughout the production cycle of most garments, from fabric
dyeing to creating unique finishes. According to some estimates, the global apparel
industry accounts for 25% of manufacturing chemical usage. The discharge of these
chemicals threatens local water sources; contamination could affect people living in
surrounding communities.

Because we know certain chemicals can be harmful to consumers, in 2008, we


developed a Restricted Substance List (RSL) that dictates which chemicals must not
be used to produce our clothing. We base this list on both existing and developing
legislation as well as toxicity risk assessments. As part of our ongoing monitoring
process, we have an independent, accredited, third-party lab test for restricted
chemicals in our finished products. If products do not meet applicable legal chemical
requirements and regulations, they will not be sold or must be remade to meet our
compliance standards. If a supplier’s product is shown to have elevated levels of these
chemicals, we provide test results and guidance to help the supplier remediate its
usage of these chemicals and educate the supplier on our chemical policy.

Looking beyond our initial chemicals management program, we are partnering to


address the impact of chemicals used in our supply chain through the Zero Discharge
of Hazardous Chemicals (ZDHC) program. In 2014, ZDHC established a strengthened
industry-wide standard for restricted substances with an expanded Material Restricted
Substance List (MRSL) that aims to reduce worker exposure to chemicals and reduce
chemical impacts on wastewater. We have communicated this list to the suppliers,
facilities and mills that make our clothing, and we have set an ambitious goal: to work
toward zero discharge of hazardous chemicals in our supply chain by 2020.

Three denim laundries that we source from in Bangladesh


are participating in the Partnership for Cleaner Textile
program, alongside other mills, which has identified nearly
114 million liters of water savings.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 79
Product Sustainability
In this section •• The Product
Life Cycle
•• Sustainably Sourcing
Raw Materials
•• Addressing Water
Use with Design
•• Integrating
Sustainability into
Choices Our Brand Decisions

Our integrated commitment to sustainability begins with our design teams


and the development of products that look good, have lower impact on the
environment and bring confidence to our customers. Since the materials
in our clothes greatly contribute to each garment’s environmental impact,
our design and production decisions have significant power to make our
products more sustainable.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 80
Context and Approach
We are committed to integrating environmental sustainability more deeply into every
aspect of our business, from the materials we source, to the suppliers we work with
and, ultimately, the clothes we sell.

We are committed to pursuing technology and product innovation, allowing us to


continually deliver great products that look good, delight our customers wear after
wear and reduce our impact on people and the planet. In recent years, we’ve begun
a new journey to build on our capabilities and empower our employees to make
sustainability part of their jobs. Our brands are tasked with developing strategies
to improve their sustainability performance, and in 2017, both our Athleta and Gap
brands released public goals to improve the materials they source.
The Short Story

Product Sustainability Given the size and complexity of the apparel supply chain, we work hard to identify and
measure our greatest environmental impacts so that we can invest resources in areas
•• We are committed to designing great
clothes that look good, delight our that will have the greatest impact.
customers and reduce our impact on
people and the planet. We have identified several critical ways to improve product sustainability:

•• By sourcing more sustainable raw


•• We partner with our most progressive and strategic suppliers to identify and
materials, we are protecting natural
scale best practices across our supply chain.
resources and reducing water, energy
and chemicals use.
•• We’ve identified ways to more sustainably source key raw materials.
•• We use life cycle analyses to find ways
to reduce impacts in manufacturing, •• Through our life cycle analyses, we are examining ways to reduce impacts
packaging and distribution, consumer in other stages of our products’ life, including manufacturing, packaging and
use and end of product life. distribution and in our retail operations.

•• Our brands work to develop solutions that are meaningful to their customers
and that can be scaled up across our business.

We are embarking on a long-term vision that builds on our strengths, addresses


our weaknesses, and ensures that our efforts are sustainable and scalable. We
also recognize that we cannot get there alone and we will continue to leverage our
relationships with peers, partners and stakeholder groups, such as the Sustainable
Apparel Coalition, Textile Exchange and the Better Cotton Initiative. Our partners each
bring something unique to the table in terms of access, expertise, common framework
or principles, funding and more. With these partnerships, we’re able to scale up
work through our global supply chain and support our brands in setting their own
sustainability goals.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 81
Mapping The Product Life Cycle
To understand environmental impacts for the entire process—from design, to
sourcing, to manufacturing, all the way to a customer’s closet—we perform life cycle
assessments (LCA). We use these to evaluate indicators such as product carbon
emissions, chemicals and water usage from cradle to grave. Our LCAs helped us
understand where we can engage our supply chain, internal teams and customers to
help reduce the environmental impacts of our products at all stages.

Given that denim plays such an important role in each of our brands’ assortments, we
measured the environmental impact of a pair of both men’s and women’s jeans, as well
as one of our T-shirts. Our findings revealed that, in terms of water, raw materials have
the greatest impact, primarily due to the water required in cotton cultivation. Consumer
use contributed the second-highest water impact due to laundering garments.
Consumer use also contributed the most significant carbon emissions due to the high
level of energy required to dry jeans and other clothes.

Using these results, we increased our efforts in areas where we have direct influence:
raw materials selection, fabric development, garment production and finishing. We also
affirmed that durable and well-loved garments, worn time after time, will have lower life-
cycle impacts, which has strengthened our commitment to classic, well-made designs
that our customers love and keep for years.

In 2016, Athleta's use of recycled raw materials diverted


the equivalent of 7 million plastic bottles from landfills.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 82
To understand our impacts and where we have the greatest leverage to address
issues, we use a tiered approach to mapping our supply chain.

The nature of our relationships with our product suppliers means we have the most
visibility and control over our tier 1 suppliers. Our tier 1 suppliers encompass cut-and-
sew facilities—where garments are embroidered, cut, assembled and finished—and
laundries, where finishes are applied and garments are washed before being packaged
and sent to our distribution centers. All of our tier 1 facilities are asked to respond
to the Sustainable Apparel Coalition’s Higg index, a self-reporting tool that evaluates
environmental performance and helps identify opportunities for improvement. Since
2016, we have published a complete list of our active facilities, which is available
online here.

Our tier 2 suppliers include textile mills, where fabric is woven or knit and dyed to the
perfect color or pattern. We have mapped the facilities of our strategic tier 2 suppliers
and are systematically mapping out all facilities for our tier 2 mills. Additionally, we
communicated Minimum Expectations of Social and Labor and Environmental Issues
to our entire mill base in March 2017, establishing standards for both social and
environmental monitoring and performance (for more on our engagement with mills
around water consumption and quality, see the section beginning on page XX.) So
far, we have engaged 30% of our strategic mill facilities in water and energy-efficiency
programs in China, India, Vietnam and Bangladesh, and we are planning to
engage more.

Our supply chain begins with what’s sourced from suppliers within tier 3, which
includes raw material cultivation and extraction, the first stages of production and the
preparation of those materials into fibers ready to become cloth.

In 2016, Gap Inc.


sourced more than
11.5 million pounds of
Better Cotton Initiative
cotton—enough
to make 7.4 million
pairs of jeans.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 83
Key Stages in the Apparel Life Cycle

Resource Extraction and Refining


This stage includes the sourcing of raw materials, including
cotton, polyester and man-made cellulosic fibers such as
viscose/rayon and modal. It can also include materials for trim,
such as zippers and embellishments, and turning them into a
form (such as spun thread) that is ready to be manufactured into
our products. Impacts can be reduced in this phase through
strategic sourcing of more sustainable materials.

Manufacturing
Manufacturing covers all processes involved in creating our
products, such as yarn spinning, knitting/weaving, dyeing,
embroidering, cut-and-sew processes, laundering and finishing.
In manufacturing, it’s possible to reduce the use of water, energy
and chemicals, especially with closed-loop or zero-discharge
manufacturing that reuses chemicals or water without releasing
them to the environment.

Packaging and Distribution


This includes all steps involved with labeling, packaging for
transport and storage, and freight to our distribution centers
and eventually to customers or stores.

Consumer Use
Consumer use of products—mostly from garment care including
washing, drying and dry-cleaning—contributes to a product’s
water and carbon footprint when in the customer’s possession.
Use may also include multiple “lives” if the garment is resold as
a second-hand product, which reduces the product’s life cycle
impacts compared to a new item.

End of Life
Finally, we consider the environmental impacts of when an item
is eventually discarded, usually into a landfill. This phase offers
opportunities for recycling, upcycling or helping create a circular
product life cycle.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 84
Sustainably Sourcing Raw Materials
We use many types of fibers in Gap Inc. products: natural fibers include plant-based
items such as cotton and linen, and animal-based materials such as wool, leather and
cashmere; synthetic fibers include polyester and spandex; and man-made cellulosics
include pulp-based materials such as rayon and modal. Each type of fiber has a social
and environmental impact, and we are empowering our designers with the knowledge
needed to make informed choices within the design process.

Recently, we published a policy, in line with Canopy Style, on sustainable procurement


of wood-derived fabrics, such as rayon, viscose, modal, lyocell and Tencel, to eliminate
the sourcing of woodpulp from ancient and endangered forests.

It can be challenging to trace tier 3 suppliers because most fibers are bought and
sold as commodities, and we do not have direct financial relationships with the
original suppliers. For some of these commodities, we have joined multi-stakeholder
partnerships, or certified initiatives such as organic, recycled, Fair Trade and others, that
help verify the origin of the fibers or ensure that these fibers are sustainably sourced.

Cotton
Cotton is essential to our business. As one of the leading apparel brands in the world,
we use a significant amount of the global cotton supply. Cotton cultivation requires
large amounts of land, human labor, machinery, pest- and weed control measures, and
it is also water-intensive. Cotton is also an important crop for the economy, supporting
the livelihoods of 250 million people, many of whom are women.

Given its importance in many of our products, we have announced ambitious goals
to source more sustainable cotton. Our commitment to sustainable cotton includes
sourcing recycled, organic, American-grown and cotton from the Better Cotton
Initiative (BCI).

These options enable us to purchase cotton that is grown in ways that reduce water
and pesticide usage, improve soil quality and work to make cotton production better
for the workers and farmers involved. For example, BCI provides training to millions of
farmers around the world to “produce cotton in a way that cares for the environment,
minimizing the negative effects of fertilizers and pesticides, and caring for water, soil
health and natural habitats.” BCI farmers also commit to decent work principles—
conditions that support workers’ safety and well-being.

This approach works: In a benchmark of BCI farmers in 2013, between 14% and
23% less water was used in cultivation than on farms that did not use BCI principles.
In 2016, we sourced 11.5 million pounds of BCI cotton—enough to make 7.4 million
pairs of jeans.

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Synthetic
We also use synthetic materials in our products, including polyester, spandex and nylon,
which provide essential performance properties. However, synthetics are often derived
from nonrenewable, petroleum-based sources. They also have fewer end-of-life solutions
than natural fibers because they may never biodegrade. To address these challenges,
we’re taking steps to ensure we’re sourcing more sustainable synthetic fibers.

As a brand that uses large amounts of synthetics in its active wear, Athleta is taking a
leading stance on addressing this issue with its goal of having 80% of materials made
with sustainable fibers by 2020. Athleta incorporates recycled polyester and nylon into
sourcing, which helps offset the impacts and waste streams of virgin materials and
preserves our nonrenewable resources. In 2016, Athleta diverted the equivalent of 7
million plastic water bottles from landfills by sourcing recycled polyester.

Addressing Water Use with Design Choices


The Short Story Since up to 80% of a product’s environmental impact is tied to decisions made in
design and development, we know that reducing water impacts begins with innovative
Water Use
product design. Our designers have embraced the opportunity to save water while
•• 80% of a product's environmental impact
is determined at the concept phase.
creating the style and quality our customers love. We are working with our designers to
evaluate a variety of factors that can reduce water impacts throughout a product's life
•• We find ways to reduce water and
chemicals use when designing and
cycle. These factors include: the type of raw materials and how much are used, how
selecting materials for our products. our products are manufactured and how long our clothes are designed to last.

In addition to improving the raw materials used in our products, we are working to
reduce water used to finish garments such as denim, while staying true to the look
and feel of the clothes that our customers love. For instance, Gap has pioneered a
smart denim wash technique called Washwell that incorporates water-savings as well
as plant-based fabric softeners that are certified by the US Department of Agriculture
as BioPreferred.® Not only did Washwell save more than 17.9 million liters of water in
2016, this process has helped to eliminate hazardous chemicals and protect the health
of workers and waterways.

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We are continuing to educate our brand designers, merchants,
product development and sourcing teams about how to design
using more sustainable fibers, fabrics and manufacturing
techniques that save water—and how to procure more
responsible materials.

Integrating Sustainability into Our


Brand Decisions
One of the most effective ways we’ve found to design and create more sustainable
products is to build awareness and education around sustainability, so as to improve
the impacts of our products on people and the planet. We continue to educate our
brand designers, merchants, product development and sourcing teams about how to
design using more sustainable fibers, fabrics and manufacturing techniques that save
water—and how to procure more responsible materials.

In partnership with sourcing product development teams, we’ve designed training


on raw materials and wet-processing impacts and alternatives. We trained product
development teams from Athleta and Gap and our sourcing teams to make informed
design decisions when creating more sustainable products. We are also engaging new
employees as they enter the company and start their careers. Product sustainability
curriculum is included in our existing Rotational Management Program training, and we
updated our new employee orientation to include key highlights and resources.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 87
We also publish a monthly Product Sustainability Report. This internal newsletter
provides updates on current events, industry innovations as well as company and
competitor initiatives. Informing our teams provides insight into the business value
and empowers them to integrate this information into their day-to-day work.

Brand Goals
From its start, Athleta has been grounded in the values of taking care of ourselves
and our environment. In 2015, the brand strengthened this commitment by integrating
sustainability more deeply into the way it does business. Athleta took its efforts to
the next level by building a passionate, knowledgeable, cross-functional team and
making training courses and tools available to them. This included the development of
ambitious sustainability targets and customer messaging.

From its start, Athleta has been grounded in the values of


taking care of ourselves and our environment.
Athleta has prioritized the conversion of raw materials to sustainable alternatives
and has set a goal to use sustainable fibers, including recycled polyester and
Lenzing Tencel, in 80% of materials by 2020. Athleta is also offering certified
Fair Trade products that provide additional worker funds to the factory certified
in Sri Lanka. These funds are used to address work needs such as health care,
childcare, transportation and community investment, based on nominations by a
worker committee.

Gap brand has established the ambitious goal to get 100% of its cotton from more
sustainable sources by 2021, including BCI, organic, recycled and American-grown.
Gap sourced 3.8 million pounds of BCI cotton in its Spring 2017 collection alone. The
brand is launching the Gap for Good platform, which serves to engage customers
through product tagging, in-store and online tagging and marketing material. We are
also working to educate our store employees on our sustainability efforts so they are
empowered to talk about this work with our customers.

We’ve also begun to examine our packaging, understanding that we need to work
holistically to ensure our products, and the items we use to protect and ship them,
have a smaller impact on the environment.

Looking forward, there are still many areas where we see impacts that must be
addressed, including sustainable chemistry and end-of-life solutions. We see
opportunity for industry-wide collaboration to find innovative solutions to many
outstanding issues. While we have much exciting work ahead of us in 2017 and
beyond, we are pleased that our brands are championing sustainability by setting
ambitious goals, integrating sustainability into their processes, designing with
sustainability in mind and communicating directly to customers.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 88
Operational Eco-Efficiency
In this section •• Climate and Energy •• Waste

A dedication to reducing the impacts of our owned and operated stores,


distribution centers and offices means reducing our operational greenhouse
gas (GHG) emissions and waste production, and working with our logistics
and procurement partners to identify practices that are more efficient and
have lower environmental impact.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 89
Context and Approach
A healthy environment is critical to healthy populations and our success as a business.
Alongside our supply chain work, we recognize we have the greatest power to reduce
our impact within our own operations. Our transportation team also works to achieve
emission reductions while streamlining our logistics. We view climate change as both
an environmental and a human rights issue. These efforts reduce environmental impact
and are cost-effective.

Climate and Energy


The Short Story
We focus primarily on energy and waste when it comes to the environmental impacts of our
Operational own operations. Taking action in one area, like waste, can also reduce GHG emissions.

Eco-Efficiency We believe it is vitally important that we address the urgent challenge of climate
•• We take steps every day to reduce the
change—and that integrating climate change into our business strategy contributes to
climate and waste impacts of our stores,
offices and distribution networks. a competitive advantage in several ways, as it:

•• We have installed LED lighting at 1,000 •• reduces our operating costs by increasing energy efficiency and
stores and we are pursuing new approaches
reducing consumption
to further increase our energy efficiency.
•• positions us well to adapt to a fast-changing regulatory environment affecting
•• We are partnering with industry leaders to
find ways to reduce major waste streams energy use, product marketing and labeling, and store construction
across the retail industry.
•• helps us improve our reputation and build support from a range of
stakeholders, including customers, employees, investors and
environmental organizations
Goals
Climate change affects us all, and we feel an urgency to act both individually and
•• Reduce absolute scope 1 and 2 greenhouse
gas emissions in our owned and operated alongside others. Since 2007, we have been actively engaged with Ceres, a leading
facilities globally by 50% by 2020. nonprofit organization dedicated to mobilizing the business community to build a
•• Divert 80% of waste from our U.S. facilities sustainable economy. As a member of Ceres’ Business for Innovative Climate and
by 2020. Energy Policy (BICEP) coalition, we advocate for progressive policy action on climate
and energy issues, and publicly affirmed our commitment to the Paris Agreement on
climate change.

Our climate goal—to achieve a 50% absolute reduction in the GHG emissions of our
owned and operated facilities globally between 2015 and the end of 2020—builds on
our previous goal to reduce our absolute U.S. GHG emissions 20% by 2015, based
on a 2008 baseline. We exceeded that goal by achieving a 37% reduction by the end
of fiscal 2015. As a result of our ambitious target, we were pleased to receive the U.S.
Environmental Protection Agency (EPA) Climate Leadership Award for "Excellence in
GHG Management – Goal Setting" in 2016, the second time we’ve received this award.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 90
Retail stores
Retail stores are the focus of Gap Inc.’s energy program since they generate
approximately 85% of our direct (scope 1 and 2) GHG emissions. We are taking
steps to adapt to climate change and regulatory changes by piloting and expanding
energy-management solutions for our retail operations, updating HVAC systems and
exploring renewable energy options. To work toward our 2020 emissions-reduction
goal, we used the EPA EnergyStar platform to analyze differences in store performance
and prioritize regions, brands and initiatives with the greatest opportunities for energy
improvements. We piloted a new energy-efficiency program at 100 stores across North
America to provide real-time monitoring and management of our energy use. We have
installed LED lighting—which use 80% less energy than conventional lights—at over
1,000 of our stores. Not only do these lights reduce our energy use, they last five to 10
times longer and they pay for themselves in just two to three years. In addition to this
work, renewable energy will likely be important for us to reach our goal, and we are
exploring options that achieve significant reductions while balancing business needs.

We were selected as a
2016 SmartWay High
Performer for our efforts
to use cleaner modes
of transportation and
encouraging the use of
fuel-saving strategies.

Distribution
In 2011, we joined a voluntary government and industry collaboration known as the
SmartWay Shipper Program, which brings together carriers, freight shippers and
logistics companies to improve fuel efficiency. In addition to being a certified EPA
SmartWay shipping partner, we became a Canadian SmartWay partner in 2013. We
were also selected as a 2016 SmartWay High Performer. We have committed to
increasing the amount of freight we ship by SmartWay carriers by 5% each year. We
also have committed to using cleaner modes of transportation and encouraging the
use of fuel-saving strategies and technologies. Moving forward, we are working to
integrate more of our business operations into the SmartWay program and improve our
data collection to better measure results.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 91
Supply Chain

Gap Inc. Global Greenhouse


Metric Tonnes CO2e
Gas Emissions

Type / Location 2014 2015 2016

Total GHG Emissions


499,859 481,122 447,687
(Scope 1 and 2)

Reduction rate N/A Baseline -6.95%

Scope 1 GHG emissions 31,275 28,465 23,811

Headquarters 1,780 1,466 1,559

Distribution Centers 6,118 6,885 5,556

Retail Stores 23,378 20,144 16,696

Scope 2 GHG emissions 468,584 452,628 423,878

Headquarters 23,116 18,916 15,894

Distribution Centers 41,178 41,054 39,598

Retail Stores 404,290 392,658 368,386

We recognize that our supply chain represents an even larger carbon footprint than
our direct operations. To address this, we are working closely with our product
suppliers to measure the environmental footprint of our supply chain. Gap Inc. was
one of the first members of the Sustainable Apparel Coalition to execute a large-
scale rollout of the environmental performance management tool, the Higg Index, to
our entire cut-and-sew and fabric mill suppliers. Our goal is to reduce the emissions
intensity of Gap Inc.’s products and manufacturing processes and, therefore, reduce
climate risk from potential sourcing impacts.

Waste
Our biggest waste streams from our owned-and-operated facilities are polyethylene
bags and plastic hangers. As many of our facilities are within larger mall complexes,
we are looking for solutions that address the diverse needs of our stores and
distribution centers. By addressing these two significant areas of waste, we’ll be able
to achieve our goal of diverting 80% of waste from U.S. facilities by 2020.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 92
We are engaged with our brands, suppliers and the greater apparel industry to achieve
our goal. For example, we are working with the Retail Industry Leaders Association
(RILA), which has convened retailers and major landlords to explore ways to collect
and recycle these major waste streams. In 2014, we diverted 29% of our waste from
our U.S. stores. We are currently reassessing our methodology to calculate waste
production and diversion and look forward to reporting our progress in the future.

We are particularly focused on:

•• Packaging sustainably: Boxes, hangers and plastic wrapping are used to


transport and to protect our clothes as they move from distribution centers
to stores. We are looking at ways to reduce packaging weight or change
the packaging materials to decrease the overall waste volume or allow for
greater recycling.

•• Recycling in malls: Reusing or recycling packaging pose challenges because


we don’t own the buildings where our stores are located. To address this, we
are working with our stores’ landlords on recycling options and also looking at
recycling stations where bags can be baled, picked up and recycled.

•• Creating opportunities via partnerships: Our teams are partnering with


RILA to discuss ways the industry can reduce the impacts of polybags. We
are also part of the Landlord Tenant Energy Partnership, which is exploring
how to incentivize energy efficiency and finance clean energy projects in
shared spaces.

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 93
GRI Content Index
We sought to prepare the report in accordance with the core option of the Global Reporting Initiative’s (GRI) Standards.
(GS Report and GS Website refer to Gap Inc.'s Global Sustainability Report, 2015–2016 and Global Sustainability website;
Annual Report refers to Gap Inc.'s Annual Report for the fiscal year ended January 31, 2016)

GRI Disclosure
Description Section(s) Page(s)
Indicator Source

General Standard Disclosure

1. Organization Profile

102-1 Name of the organization GS Report About Gap Inc. 1 

102-2 Description of the organization’s GS Report About Gap Inc. 1 


activities; primary brands, products,
and services, including an
explanation of any products
or services that are banned in
certain markets

102-3 Location of organization’s GS Report About Gap Inc.  1


headquarters

102-4 Location of operations: Number of GS Report About Gap Inc. 1


countries where the organization
operates, and the names of
countries where it has significant
operations and/ or that are relevant
to the topics covered in the report

102-5 Nature of ownership and legal form Annual Report Part I, Item 1. Business (page 1)   

102-6 Markets served, including GS Report About Gap Inc.  1 


geographic breakdown, sectors
served, and types of customers/
beneficiaries

102-7 Scale of the reporting organization Annual Report Part I, Item 1. Business (page  
3), and Item 7. Management’s
Discussion and Analysis of
Financial Condition and Results of
Operations (page 19)

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 94
102-8 Total number of employees by GS Report, About Gap Inc.; 1 
employment contract and gender; GS Website Measuring Our Progress/
Employees
Total number of employees by
employment contract (permanent
and temporary) by region;

Total number of employees by


employment type (full-time and
part-time) by gender;

Whether a significant portion of


the organization’s activities are
performed by workers who are
not employees;

Any significant variations in the


numbers reported above (such as
seasonal variations)

102-9 Describe the organization´s GS Report Advancing Progress Across 8 


supply chain Our Value Chain

102-10 Significant changes to the Annual Report Part I, Item 1. Business. (page 2)   
organization’s size, structure,
ownership, or supply chain

102-11 Whether and how the organization GS Report Managing and Prioritizing Risks 14-15 
applies the Precautionary Principle
or approach

102-12 List externally-developed economic, GS Report Sustainability Policies  17-18 


environmental, and social charters,
principles, or other initiatives to
which the organization subscribes
or endorses

102-13 Memberships in industry or GS Report Partners and Stakeholders  12 


other associations, and national
or international advocacy
organizations

2. Strategy

102-14 Statement from the most senior GS Report Letter From Our CEO  2-3 
decision-maker of the organization

102-15 Description of key impacts, risks, GS Report Assessing Materiality 9-10


and opportunities

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 95
3. Ethics & Integrity

102-16 Describe the organization´s GS Report Acting with Integrity, 15-18


values, principles, standards Sustainability Policies
and norms of behavior

4. Governance

102-18 Governance structure of the GS Report Sustainability Governance 13-14  


organization, including committees
of the highest governance body
and committees responsible for
decision-making on economic,
environmental and social impacts.

5. Stakeholder Engagement

102-40 List of stakeholder groups engaged GS Report Partners and Stakeholders  12 
by the organization

102-42 Basis for identifying and selecting 2013-2014 Gap Inc. 2013-2014 Sustainability   
stakeholders with whom to engage GS Report Report (pages 14, 15, 16)

102-43 Approach to stakeholder 2013-2014 Gap Inc. 2013-2014 Sustainability  


engagement, including frequency GS Report Report (pages 14, 15, 16)
of engagement by type and by
stakeholder group

102-44 Key topics and concerns that have GS Report Gap Inc. Material Issues; topics 9  
been raised through stakeholder addressed throughout the report
engagement; how the organization
has responded to those key topics
and concerns, including through its
reporting; the stakeholder groups
that raised each of the key topics
and concerns

6. Reporting Practice

102-45 List all entities included in the Annual Report Part I, Item 1. Business   
organization´s consolidated financial (pages 1 - 2)
statement; report whether any entity
is not covered in the report

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 96
102-46 Process for defining report 2013-2014 Gap Inc. 2013-2014 Sustainability  
content and the topic Boundaries; GS Report Report (pages 14, 15, 16)
explain how the organization
has implemented the Reporting
Principles for defining report content

102-47 List the material topics GS Report Gap Inc. Material Issues 9  
identified in the process for
defining report content

102-48 The effect of any restatements There are no restatements from the  
of information given in previous previous report data.
reports, and the reasons for such
restatements

102-49 Significant changes from The material topics and Boundaries   


previous reporting periods in remained the same
the list of material topics and
topic Boundaries

102-50 Reporting period for the GS Report About This Report 1 


information provided

102-51 Date of the most recent GS Report About This Report 1 


previous report

102-52 Reporting cycle GS Report About This Report 1 


(annual, biennial, etc.)

102-53 Contact point for questions GS Report About This Report 1 


regarding the report or its contents

102-54 Report the “in accordance” option GS Report About This Report 1 

102-55 The GRI content index GS Report GRI Content Index & UNGC 97
Communication on Progress

Specific Standard Disclosure

Economic

Aspect: Economic Performance

201-1 Direct economic value generated Annual Report Part II. Item 6. Selected   
and distributed Financial Data

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 97
201-2 Financial implications and other GS Report, Business Strategy; Sustainability 4-13, 17,
risks and opportunities due to GS Website Policies; Climate and Energy; Doing 88-89 
climate change Our Part on Climate, Collaborating
for Change

Aspect: Market Presence

201-1 Ratios of standard entry level GS Report, Creating Opportunities for Women, 31, 37, 56 
wage by gender compared to GS Website Wages and Scheduling: Promoting
local minimum wage at significant Stability and Flexibility for Retail
locations of operation Employees; Wages

Working for Greater Equality


and Opportunity

Aspect: Indirect Economic Impacts

203-2 Significant indirect economic GS Report Youth Opportunity: This Way 38-68 
impacts, including the extent Ahead; Community Investment and
of impacts Volunteering; Empowering Women:
P.A.C.E.; Improving Factory
Working Conditions

Environmental

Aspect: Energy

302-1 Energy consumption within GS Website Measuring Our Progress/


the organization Environment

302-3 Energy intensity GS Website Measuring Our Progress/  


Environment

302-4 Reduction of energy consumption GS Website Measuring Our Progress/


Environment

Aspect: Water

303-2 Water sources significantly affected GS Website Measuring Our Progress/  


by withdrawal of water Environment

Aspect: Emissions

305-1 Direct (Scope 1) GHG emissions GS Report, Climate and Energy 90


GS Website
Measuring Our Progress/
Environment

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 98
305-2 Energy indirect (Scope 2) GS Report, Climate and Energy 90
GHG emissions GS Website
Measuring Our Progress/
Environment

305-3 Other indirect (Scope 3) GS Website Measuring Our Progress/   


GHG emissions Environment

305-4 GHG emissions intensity GS Website Measuring Our Progress/  


Environment

305-5 Reduction of GHG emissions GS Report, Climate and Energy 90


GS Website
Measuring Our Progress/
Environment

Aspect: Supplier Environmental Assessment

308-1 New suppliers that were screened GS Report, Assessment and Remediation 66-68
using environmental criteria GS Website
Measuring Our Progress/
Working Conditions

308-2 Negative environmental impacts in GS Report, Assessment and Remediation 66-68 


the supply chain and actions taken GS Website
Measuring Our Progress/
Working Conditions

Social

Aspect: Employment

401-2 Benefits provided to full-time GS Report, Benefits and Work-Life Integration 36


employees that are not provided to GS Website
Measuring Our
temporary or part-time employees
Progress/Employees

Aspect: Occupational Health & Safety

403-2 Types of injury and rates of injury, GS Report, Ensuring Worker Safety 37
occupational diseases, lost days GS Website
Measuring Our
and absenteeism, and
Progress/Employees
work-related fatalities

Aspect: Training & Education

404-3 Percentage of employees receiving GS Report Our Employee Experience 33-34


regular performance and career
development reviews

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 99
Aspect: Diversity & Equal Opportunity

405-1 Diversity of governance bodies GS Report, Employees and Workforce 29


and employees GS Website
http://www.gapincsustainability.
com/strategy/our-sustainability-
strategy/ensuring-strong-
governance

Measuring Our
Progress/Employees

Aspect: Non-discrimination

406-1 Total number of incidents of GS Report, Discrimination 55


discrimination and corrective GS Website
actions taken Measuring Our Progress/
Working Conditions

Aspect: Freedom of Association and Collective Bargaining

407-1 Operations and suppliers in Freedom of Association 51


which workers’ rights to exercise
freedom of association or collective Measuring Our Progress/
bargaining may be violated or at Working Conditions
significant risk

Aspect: Child Labor

408-1 Operations and suppliers at GS Report, Our Policies and Commitment to 55-56
significant risk for incidents of GS Website Human Rights: Child Labor
child labor
Measuring Our Progress/
Working Conditions

Aspect: Forced or Compulsory Labor

409-1 Operations and suppliers at GS Report, Our Policies and Commitment to 51-52
significant risk for incidents of GS Website Human Rights: Human Trafficking
forced or compulsory labor and Forced Labor

Measuring Our Progress/


Working Conditions

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 100
Aspect: Human Rights Assessment

412-3 Significant investment agreements GS Report, Our Policies and Commitment to 47-60
and contracts that include human GS Website Human Rights
rights clauses or that underwent
human rights screening Measuring Our Progress/
Working Conditions

Aspect: Local Communities

413-1 Percentage of operations with GS Report Community Investment 41-42


implemented local community and Volunteering
engagement, impact assessments,
and/or development programs

Aspect: Supplier Social Assessment

414-1 New suppliers that were screened GS Website Assessment and Remediation; 66-68
using labor practices criteria Measuring Our Progress/
Working Conditions

414-2 Negative social impacts in the GS Report, Assessment and Remediation; 66-68
supply chain and actions taken GS Website Measuring Our Progress/
Working Conditions

United Nations Global Compact: Communication on Progress

Principle Principle Description Location

1 Businesses should support and respect Policies


the protection of internationally proclaimed California Transparency in Supply Chains Act
human rights Code of Vendor Conduct
Human Rights Policy
UK Modern Slavery Act

Implementation
Assessing Materiality
Advancing People and Communities
Improving Factory Working Conditions

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 101
2 Businesses should make sure they are not Policies
complicit in human rights abuses Human Rights Policy
Code of Vendor Conduct
Conflict Minerals Policy

Implementation
Advancing People and Communities
Improving Factory Working Conditions

3 Businesses should uphold the freedom of Policies


association and the effective recognition of Code of Vendor Conduct
the right to collective bargaining
Implementation
Freedom of Association

4 Businesses should uphold the elimination of all Policies


forms of forced and compulsory labor Human Rights Policy
Code of Vendor Conduct
California Transparency in Supply Chains Act
UK Modern Slavery Act

Implementation
Forced Labor
Human Trafficking and Forced Labor

5 Businesses should uphold the effective Policies


abolition of child labor Human Rights Policy
Code of Vendor Conduct

Implementation
Child Labor and Young Workers
Child Labor

6 Businesses should uphold the elimination Policies


of discrimination in respect of employment Human Rights Policy
and occupation Code of Vendor Conduct

Implementation
Discrimination
Advancing People and Communities
Improving Factory Working Conditions

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 102
7 Businesses should support a precautionary Policies
approach to environmental challenges Climate Policy
Wood-Derived Fabric Policy

Implementation
Letter From Our CEO
Assessing Materiality
Water Stewardship
Product Sustainability
Operational Eco-Efficiency

8 Businesses should undertake initiatives to Policies


promote greater environmental responsibility Animal Welfare Policy
Climate Policy
Wood-Derived Fabric Policy

Implementation
Water Stewardship
Product Sustainability
Operational Eco-Efficiency

9 Businesses should encourage the Policies


development and diffusion of Climate Policy
environmentally friendly technologies
Implementation
Product Sustainability

10 Businesses should work against corruption in all Policies


its forms, including extortion and bribery Code of Business Conduct
Code of Vendor Conduct
Human Rights Policy

Implementation
Acting with Integrity

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Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 103
Public Reporting Working Group Statement
Any report is a snapshot of that company at a particular moment in time that describes
where a particular company is. Much can be written to describe where a company is
at a particular moment, using data, measurements, photos, etc. However what is really
important is how the company, or any organization reporting, looks at where they are
at that moment in time, how they got there and where they need to go as they plan
their work for the future.

Gap’s 2017 report provides a comprehensive picture of where the company is at the
present moment. It supports and fills out that picture with data, descriptive writing and
photos to give a broader picture of the goals of the reporting company and progress in
achieving these goals. Good reports include challenges, such as negative findings in
factory audits, and how they are being addressed. It is about process and content, not
just one or the other.

The 2017 Gap report is such a report. For the PRWG, some members of which have
worked with Gap since their first report published in 2004, this report continues to
describe the process and content of the on-going work at Gap that we have seen.
In the diverse areas of the environment, ecology, worker rights and improving the
workplace, product development, etc. as well as reporting against industry accepted
standards such as the GRI Reporting Guidelines, Gap continues to describe its work
and its in-going challenges in detail.

The 2015 Gap CEO letter published on the Gap sustainability website describes the
work most accurately when he writes “Every Gap product is part of a bigger story”. He
goes on: “What that story is, however, can be tough to know at first glance. Was a shirt
or jacket sewn by someone who works in safe and fair conditions? Was care taken to
mitigate any potential environmental harm caused by the manufacturing process? Were
the people whose lives were touched by the creation of a piece of clothing affected in a
positive way?” Of course there are additional questions to ask…but it is the openness
to asking, and answering the questions that is important.

In working on this report, Gap shared its decisions: to move towards more frequent
reporting of data related various aspects of the work and urge Gap to make available
updated key performance data annually through its website. We realize the tremendous
amount of work that goes into reporting well and commend Gap for accepting this
work as part of the on-going process for positive change.

Gap’s continued support for the P.A.C.E. program (Personal Advancement and Career
Enhancement) as reflected in the expansion of the program to 16 countries with more
than 65,000 women participants needs to be highlighted as a sustainability program
that moves beyond mere data and numbers to the actual lives of women and their

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 104
families. The Gap goal of 1,000,000 participants in P.A.C.E. by 2020 reflects the broader
reality of true sustainability. The reporting by ICRW, (International Center for Research on
Women) documents and verifies the effects of the program, one that other companies
would do well to support.

We look forward to seeing the outcomes from the various collaborative projects in which
Gap is engaged. Learnings from each project as well as what is transferable to other
geographic locations will strengthen the work.

Other strong points in the report include the provision of county specific data, as well
as the reference to the Sustainable Development Goals (SDGs). Gap’s Restricted
Substances List (RSL), following AFIRM Group’s RSL would be stronger with a link from
the report to the RSL list online.

The next report would be strengthened by the expansion of information and data
regarding findings related to various types of unethical recruiting practices, where
they are found, how they are addressed and what measures are taken to change the
recruitment paradigm from ‘worker-paid fees’ to ‘employer-paid fees’. In particular, we
would recommend that Gap disclose the dollar amount that has been reimbursed to
workers, and set goals – and discuss challenges – for ensuring that workers are directly
employed by Gap suppliers. When migrant workers are employed by their recruitment
firm, it makes them particularly vulnerable to exploitation.

We also commend Gap for its work to ensure the sustainability of its raw materials and,
in particular, its cotton purchases. We would encourage Gap to provide greater specificity
around its sustainable cotton sourcing goals, supported by data to allow investors to
assess progress. We would also welcome a discussion of how Gap is addressing the
human rights of workers at these Tier 3 suppliers.

Gap did the right thing by voluntarily raising the minimum wage for its workers. We
encourage Gap to go a step further by publicly supporting an increase in the federal
minimum wage, with future adjustments indexed to inflation.

We strongly urge Gap to create links to its webpages as progress is made on any and
all of the issues described in the report. In that way, the on-going reality of the many
aspects of the work will be easier for readers to comprehend.

We commend Gap for its work and progress and look forward to the next Gap report.

Mr. Adam Kanzer, Managing Director of Corporate Engagement, Domini Impact Investments, LLC
Mr. Mike Lombardo, Vice President, Research, Calvert Research and Management
Dr. Ruth Rosenbaum, Executive Director, Center for Reflection, Education and Action (CREA)
Rev. David Schilling, Senior Program Director, Interfaith Center on Corporate Responsibility

Gap Inc.
Global Sustainability Report 2015–2016 Table of Contents Strategy People Environment 105

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