Gap Inc. COVC Final Formatted For Print PDF

Gap Inc.
Code of Vendor
Conduct Manual
Gap Inc. Code of Vendor Conduct Manual
Copyright Gap Inc. The information contained herein is confidential and proprietary to Gap Inc. Do not distribute.
Part 1: Introduction
11 Chapter 1: Overview
15 Chapter 2: Code of Vendor Conduct
Contents

2.1 Overview
2.2 Structure
21 Chapter 3: Assessment & Remediation

Program Overview
3.1 Overview
3.2 Types of Assessments
3.3 On-Site Assessment
3.4 Issue Classification and Performance
Measurement
3.5 Corrective Action Plan (CAP) Management
3.6 ILO Better Work Assessments
33 Chapter 4: Vendor Approval Process & Status

Changes Overview
4.1 Overview
4.2 Requesting New Facility Approval
4.3 Documentation
4.4 Initial Assessment
4.5 Cases Where Corrective Action is Needed
4.6 Consequences of Facility Approval
4.7 Consequences of Facility Rejection
4.8 Vendor or Facility Changes
4.9 Termination of Approved Status
37 Chapter 5: Management Systems
40 Chapter 6: Vendor Portal in Gap Inc.’s

Global Sustainability System (GSS)

Part 2: Provisions & Standards
44 I: Compliance with Laws
I.A Compliance with Laws
I.B Worker Interviews
I.C Bribery
I.D U.S. Foreign Corrupt Practices Act (FCPA)
I.E Transparency
I.F Unrestricted Access
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I.G Employment Contracts III.B.08 Control of Earnings
III.B.09 Recruitment Fee Chargeback
I.H Unauthorized Sub-contracting
III.B.10 Foreign Contract Worker
I.I Facility Expansion Transportation
I.J Subcontractor Monitoring (Handwork) III.B.11 Final Payment and Return Fee
III.B.12 New Facilities—Foreign Contract Labor
I.K Gap Inc. COVC Poster
Requirements
I.L Worker-Management Communication III.B.13 Control of Passports
I.M Child Care Facilities III.B.14 Foreign Contract Worker
Discrimination
I.N Apprentice and Vocational Programs
III.B.15 Documentation
54 II: Environment III.B.16 Foreign Contract Worker List
II.A Environmental Management System III.C Labor Standards: Discrimination
III.C.01 Discriminatory Employment Practices
II.B Environmental Emergency Plan
III.C.02 Discrimination: Recruitment process
II.C Wastewater Treatment Policy and Procedure III.C.03 Discriminatory Medical Examinations
II.D Water Quality Program III.C.04 Discrimination: Pregnancy and
Maternity
II.E Chemicals Inventory
III.C.05 Religious Observances
II.F Restricted Substances List
III.D Labor Standards: Forced Labor
II.G Chemicals Storage III.D.01 Forced Labor
II.H Chemical Handling Procedures III.D.02 Free Egress
III.D.03 Restrictions to Voluntarily Ending
II.I Chemical and Waste Disposal
Employment
II.J SAC Higg Index Facility Environment Module III.D.04 Restrictions on Worker Movement
III.D.05 Worker Time Off Due to Emergencies
64 III: Labor Standards
III.A Labor Standards: Child Labor III.E Labor Standards: Freedom of Association
III.A.01 Minimum Age Requirement III.E.01 FOA: Compliance with Applicable
III.A.02 Mandatory Schooling Age Laws
III.A.03 Age Verification Documents III.E.02 Threats to Freedom of Association
III.A.04 Age Verification Procedure III.E.03 Collective Bargaining
III.A.05 Children in Production Areas III.E.04 Deducting Union Membership Fees
III.A.06 Young Workers: Working Conditions III.E.05 Interference with Association Process
III.A.07 Young Workers: Wages III.E.06 Special Protection to Workers
III.A.08 Young Workers: Legal Approval III.E.07 Access to Facilities
III.A.09 Young Worker Monitoring III.E.08 Freedom to Choose Organizations
III.A.10 Young Worker Education III.F Labor Standards: Humane Treatment
III.B Labor Standards: Foreign Contract Labor and Disciplinary Practices
III.B.01 Employment Contracts III.F.01 Physical Abuse
III.B.02 Employment Terms III.F.02 Verbal/Sexual Abuse
III.B.03 Host Country Employment Contract III.F.03 Disciplinary Actions
III.B.04 Orientation Training III.F.04 Grievance Channels and Retaliation
III.B.05 Recruitment Agencies III.F.05 Security Personnel
III.B.06 Recruitment Agency Due Diligence III.F.06 Pat-downs
III.B.07 Host Country Fees III.F.07 Harassment and Abuse Policy
4 Gap Inc. Code of Vendor Conduct Manual

III.G Labor Standards: Wages, Benefits and Terms IV.A.04 Ventilation
of Employment IV.A.05 General Safety: Lighting
III.G.01 Minimum Wage Requirement IV.A.06 Floor Safety
III.G.02 Unreasonable Production Quotas IV.A.07 Sanitation and Housekeeping
III.G.03 Overtime and Incentive Rates IV.A.08 Stairways and Raised Platform
III.G.04 Unpaid OT Adjustments IV.A.09 Confined Spaces
III.G.05 OT Allowances IV.A.10 Seating and Ergonomic Mats
III.G.06 Display of Legal Minimum Wages IV.A.11 Smoking
and Wage Calculation IV.A.12 Pregnant and Breastfeeding Women
III.G.07 On-Time and Direct Payment IV.A.13 Workers with Disability
to Workers IV.A.14 Toilets
III.G.08 Monetize or Encash Benefits IV.A.15 Personal Protective Equipment (PPE)
III.G.09 Wage Statements IV.A.16 Machine/Equipment Safety
III.G.10 Right to Refuse Employer Services IV.A.17 First Aid and Medical Facility
III.G.11 Excess Charge for Goods and Services IV.A.18 Canteen and Eating Area
III.G.12 Short term/Temporary/Fixed Term IV.A.19 Drinking Water
Contracts IV.A.20 Fire Safety Certificates
III.G.13 Usage of Layoffs and Rehiring to Avoid IV.A.21 Exits/Exit Routes/Emergency Routes
Benefits IV.A.22 Emergency Lighting
III.G.14 Suspension/Termination of Contracts IV.A.23 Firefighting Equipment
III.G.15 Illegal Deduction from Worker Wages IV.A.24 Fire Detection and Alarm Systems
III.G.16 Leaves and Holidays IV.A.25 Emergency Procedures and
III.G.17 Leave Procedures Evacuation Drills
III.G.18 Leave/Holiday/Weekly Off Payments IV.A.26 Building Safety
III.G.19 Leave Records IV.A.27 Electrical Safety
III.G.20 Payment of Benefits
IV.B Dormitory
III.G.21 Legally Required Withholdings
IV.B.01 Health and Safety
III.G.22 Worker Tools Provided Free of Charge
IV.B.02 Exits, Emergency Lighting and
III.G.23 Taking Work Home
Fire Alarm
III.H Labor Standards: Working Hours IV.B.03 Clear Halls and Exits
III.H.01 Normal Work Schedule IV.B.04 Posted Evacuation Directions
III.H.02 Overtime Hours IV.B.05 Fire Extinguishers
III.H.03 Involuntary Overtime IV.B.06 Fire Fighting Equipment
III.H.04 Overtime as Condition of IV.B.07 Fire Drills and Evacuation Drill Log
Employment IV.B.08 Electrical Safety
III.H.05 Timekeeping System and Records IV.B.09 Yellow Box or Markings
III.H.06 Working Hours One Day off in 7 IV.B.10 First Aid Kit
III.H.07 Daily Rest Periods IV.B.11 Dormitory Location
III.H.08 Overtime Management System IV.B.12 Segregated Hazard and Combustible
Material
116 IV: Occupational Health & Safety
IV.B.13 Free Access
IV.A Occupational Health & Safety
IV.B.14 Separate Rooms by Gender
IV.A.01 Compliance with Laws
IV.B.15 Sanitation
IV.A.02 Health and Safety Committee
IV.B.16 Sufficient Space
IV.A.03 General Safety
IV.B.17 Laundry
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IV.B.18 Worker Storage Space 201 Appendix 12: Root Cause Analysis
IV.B.19 Bare Floors and Personal Mats Guidelines
IV.B.20 Sufficient Toilets and Showers 210 Appendix 13: Gap Inc. Facility Rating
IV.B.21 Toilet Sanitation Methodology Overview
IV.B.22 Privacy
213 Appendix 14: Gap Inc. Supplier
IV.B.23 Toilets by Gender
Sustainability Joint Assessment
IV.B.24 Kitchen Facilities
Program Overview
IV.B.25 Dormitory Conditions (Electricity,
Temperature and Ventilation) 218 Appendix 15.A: Risk Assessment Template
IV.B.26 Sufficient Lighting 220 Appendix 15.B: Risk Assessment
IV.B.27 Water Management
151 V: Management Systems 221 Appendix 15.C: Risk Assessment Hierarchy
V.A Company Statement and Management of Controls
Oversight
222 Appendix 15.D: Bow-Tie Analysis
V.B Management Responsibility and Worker
224 Appendix 15.E: Risk Assessment Rating
Feedback
Matrix
V.C Risk Assessment Process
226 Appendix 15.F: Risk Assessment Process
V.D Management and Worker Trainings
227 Appendix 16: Gap Inc. Water Quality
V.E Performance Objectives and Targets Program for Denim Laundries Guidelines
230 Appendix 17: Gap Inc. Restricted Substances
Part 3: Appendix List (RSL) and Zero Discharge of Hazardous
Substances—Manufacturers’ Restricted
159 Appendix 1: Glossary of Terms
Substances List (ZDHC MRSL)
173 Appendix 2: COVC Critical Issues List
232 Appendix 18: Gap Inc. Chemical Storage and
177 Appendix 3: Gap Inc. Unauthorized Handling Guidelines
Subcontracting Policy
234 Appendix 19: Sustainable Apparel Coalition
180 Appendix 4: Sandblasting Policy (SAC) Facility Module – Environment:
181 Appendix 5.A: Facility Expansions Policy Apparel and Footwear FAQ
183 Appendix 5.B: Facility Expansions Policy 241 Appendix 20: Energy & Greenhouse
Workflow Gas (GHG) Emissions Guidance
184 Appendix 6: Conditional Approval Policy 247 Appendix 21: Waste Management
Guidance
187 Appendix 7: Facility Status Change
252 Appendix 22: Water Consumption and
190 Appendix 8: Assessment Agenda Example
Wastewater Discharge Guidance
192 Appendix 9: Assessment Documentation
259 Appendix 23: Gap Inc. Code of Business
& Records to Review
Conduct
196 Appendix 10: Corrective Action Plan (CAP)
and Open Areas for Improvement (AFI)
Guidelines
200 Appendix 11: Corrective Action Plan (CAP)

Part 1:
Introduction
7
Our approach to improving
working conditions is based
on transparency, partnership,
and innovation. We believe that
by working together, we can
improve workers’ well-being,
reduce environmental impacts,
and unleash improved business
performance.

Part 1 Introduction Chapter 1: Introduction & Overview 9
Chapter 1:
Overview
Gap Inc. seeks to ensure that the people who work in our supply chain are treated with
fairness, dignity and respect – an aspiration that is born out of the belief that each life
is of equal value, despite the systemic inequities around the world. We also strive to be
responsible stewards of the environment, and seek to reduce the environmental impacts
in our supply chain. These values are intrinsic to Gap Inc., and are expected of us by our
employees and customers.
Achieving this requires innovation and closer partnership with the mills, suppliers, vendors
and facilities that manufacture our branded product. As Gap Inc. seeks to build deeper
partnerships with suppliers, we will be asking more of you in terms of how you invest in
your employees and reduce your environmental impacts. At the same time, more assistance,
better tools, and added capability building services will be provided to help your business
improve its sustainability performance. One of our responsibilities in a partnership model is
to clearly establish and communicate all of our expectations to our supply chain partners.
To that end, we have evolved our Code of Vendor Conduct to this Code of Vendor Conduct
Manual (COVC Manual) to provide our supply chain partners with more clarity on our
standards, goals, and expectations.
Our expectation is that our suppliers will share our

commitment to sustainability, and to respecting the rights
of their employees. We are committed to partnering with
you to make the right decisions for your employees, your
business, and the communities in which you operate.
Our main objective in creating and sharing this manual is to help ensure better
understanding of our sustainability standards, so proactive steps can be taken to comply
with them. Our expectation for our vendors and facilities is for you to take increased
ownership of the improvement process, make smart investments in your sustainability
efforts, and attain continual and sustainable progress against your own sustainability goals.
This effort is rooted in an ethic of continuous improvement, and a willingness to learn from
each other. We look forward to partnering with you on this shared effort.
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Our COVC Manual will be reviewed
on an annual basis to reflect best
practices and ensure that our
standards are leading the industry.
We will require your feedback and
partnership along the way, and
expect continuous improvement
from ourselves, and our supplier
partners.

CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 2: Code of Vendor Conduct 13
Chapter 2:
Code of Vendor Conduct

2.1 Overview
In 2015, Gap Inc. reviewed its Code of Vendor Conduct (COVC) and made several updates to
it. This will become an annual exercise, in which we will evaluate the content of our COVC
Manual and the performance of our suppliers to ensure that we are assessing sustainability
performance across the appropriate standards and metrics.
This COVC Manual is an evolution of our COVC and is reflective of lessons learned over the
past two decades, evolving standards and best practices in the industry. Gap Inc. strives
to be inclusive, therefore lessening redundancy wherever possible. One such example is
Gap Inc.’s adoption of the Sustainable Apparel Coalition’s Higg Index Facility Module –
Environment: Apparel/Footwear (FMEAF), which we now require our suppliers to participate
in. In updating this COVC, we also reviewed the standards and recommendations published
by industry groups, such as ILO Better Work, The Global Social Compliance Program (GSCP),
SA8000, The Fair Labor Association (FLA), ETI Base Code and SMETA Guidelines, and the
Alliance for Bangladesh Worker Safety’s fire and building safety standards. Additionally, this
COVC follows the International Labour Organization (ILO) Conventions, and requires legal
compliance with national law and local legislation as a baseline. Relevant ILO Conventions
include:
→→ 29 - Forced Labor
→→ 87 - Freedom of association and protection of the right to organize
→→ 98 - Right to organize and collective bargaining
→→ 100 - Equal remuneration
→→ 105 - Abolition of forced labor
→→ 138 - Minimum age
→→ 155 - Occupational Safety and Health Convention
→→ 158 - Termination of Employment Convention
→→ 182 - Worst forms of child labor
A key update made in 2015 is the inclusion of Provision V, which is focused on Management
Systems. In 2015-16, Provision V will not contribute to facilities’ ratings, as this is a pilot
project that will require feedback from all stakeholders involved (including vendors and
facilities) to ensure that the standards are clear, fair, and achievable. For more information
on Management Systems, please see Chapter 5 of this document.

Did you know that Gap Inc. also has a
Code of Business Conduct (COBC)? Our
COBC is a commitment we make to our
shareholders, customers and each other
not only out of a legal obligation, but
because it’s the right thing to do. Our
success is built on trust, along with a
reputation for transparency and quality
in everything we do. Just as our COVC
is aimed at helping us uphold ethical
standards in our supply chain, our COBC
helps us hold ourselves to working
with the highest standards of integrity
within our own business operations.
For more information on our COBC,
please see Appendix 24: Gap Inc. Code of
Business Conduct.

2.2 Structure
The structure of the COVC Provisions & Standards section of the COVC Manual is as
follows:
1. Provision: Each chapter begins with several introductory sentences that outline our
high-level goals and objectives.
2. Standard: These describe in more detail the specific expectations within each Provision.
3. Standard Detail: These provide further clarity on how facilities can comply with our
Standards, and are meant to help ensure that you understand the nuances of our
expectations.
4. Standard Sub-detail: These outline the exact evaluation metric that our Assessment &
Remediation Specialist will document while conducting assessment of your facility.
5. Guidance/Best Practices/Frequently Asked Questions: These provide additional
information, helpful tips, and general suggestions on how you can most effectively
improve your sustainability performance.
The requirements provided in this document are not exhaustive, and there may be
additional requirements raised during the assessment in line with the local and legal
practices.
Please see Part 2 of this document to review Gap Inc.’s COVC Provisions and Standards.

As Gap Inc. seeks to build deeper
relationships with selected suppliers,
we will also be asking more of you—
in terms of quality, on-time delivery, as
well as sustainability performance—
and our Supplier Sustainability team is
here to support your facility as we work
together to build a more sustainable
apparel industry. While assessing
facilities’ performance against our Code
of Vendor Conduct is a significant aspect
of our work, we are also consultative
partners that can help you problem-
solve and innovate to identify new
solutions.

Chapter 3:
Assessment & Remediation

Program Overview
3.1 Overview
Gap Inc. has a team of approximately 50 Assessment & Remediation Specialists involved
in regular facility assessments and remediation. Such assessments promote increased
awareness of labor conditions to Gap Inc., facilitate greater partnership with our suppliers,
drive improvements in sustainability performance and ultimately drive positive change.
The success of each assessment depends largely on the willingness of the facility
management to provide access to a facility’s grounds, records and workers. We believe that
transparency is crucial for the long-term health of our business relationships and ask that all
our vendors and facilities embrace this as a core aspect of our partnership. Our focus is on
assessing sustainability performance and helping to identify areas for improvement, which
can only be done if we understand the true working conditions and environmental impacts
in the facility.
3.2 Types of Assessments

Our assessments can be classified as one of the following types:
Initial Assessment The first full assessment carried out for a facility that has been
offered for assessment and approval.
Full Assessment Assessments that cover all sections of Gap Inc. COVC. At least one
Full Assessment is conducted for all active, approved facilities
each fiscal year (February 1st to January 31st), unless otherwise
specified for certain categories.
Follow-up Assessments carried out to assess the progress made by facilities

Assessment on the issues identified during the Initial Assessment or Full
Assessment. New issues may also be found during follow-up
assessments and those are also recorded and reported.
Joint Assessment Gap Inc. will conduct Joint Assessments with Verité (a leading
NGO focused on ensuring that people work under safe, fair, and
legal conditions) where the focus of Verité’s work will be to assess
workers’ sense of value and engagement. Facilities selected for
Joint Assessments will be pre-notified and briefed on the process,
its requirements, and our expectations. (Refer Appendix 14 for
details).
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Depending on a multitude of factors, including facilities’ previous assessment results (i.e.
their rating) and our understanding of facility management’s approach to sustainability,
notification of assessments will vary. For facilities that have been transparent, shown a
commitment to continuous improvement, and a proven ability to effectively and sustainably
remediate issues, our preference will be to conduct announced assessments. The categories
of assessment notifications are:
Announced Announced Assessments are defined as assessments for which

Assessment facilities are contacted prior to the assessment in order to 1) set a
mutually acceptable date and time to conduct the assessment, or
2) ensure they have been informed of when the assessment will
take place only as a courtesy.
Unannounced Unannounced Assessments are those assessments when the

Assessment facility is not given any advance notice about the time or date of
assessment.
Semi-Announced A Semi-Announced Assessment is defined as an assessment

Assessment for which the facility has been informed of a specific period of
time during which the assessment may take place (e.g., during a
particular month or within a two-week window). However, the
facility is not given the specific assessment date.
Gap Inc. has recently partnered with Verité to launch a

new type of assessment, which is focused on evaluating
workers’ sense of engagement at work. This type of
assessment will complement the assessments described
in this section. We are launching this program in 2015 in
Bangladesh, China, Guatemala, and India, and will scale it
to additional countries in 2016. For more information on
this unique partnership, please see Appendix 14: Verité Joint
Assessment Overview.

3.3 On-Site Assessment
During each assessment, information is gathered from management interviews,
confidential worker interviews, visual observation, and documents/records reviews based on
a minimum sampling. The size of Gap Inc.’s assessment team will depend on several factors.
The below chart outlines our guidance on the number of people and person-days that will
be spent on-site during an assessment.
Table 1: Assessment Team Size and Number of Days
Total Interviews
Individual (Individual & Time &
Person No. of Worker Group, Worker & Worker Wage
Days Workers Interviews Management) Files Records
Full 1 Up to 800 5-15 8-25 5-15 8

Assessment
2 801-3000 15-30 25-50 15-30 20
4 Above 3000 30-50 50-70 30-50 35
Follow-Up 1 0-1500 5 5 5 5
Assessment
2 1501+ 15 15 15 15
We recognize that every country and every facility is different and so our assessment team
is trained to assess facilities according to the local environment. Facility management
is expected to provide their full support and access for the assessors to carry out all
assessment activities. Facilities shall allow Gap Inc. representatives or agents unrestricted
access to its facilities for observation, workers for interview and relevant records for review,
whether or not notice is provided in advance. Any form of restriction during our assessments
will be considered a critical COVC violation and will negatively impact facility’s rating, and
may lead up to termination of our business relationship.
At the end of assessment, the assessor(s) will discuss all assessment findings with the
facility management. Gap Inc. assessors will also discuss the corrective actions required,
timelines and the next steps to be taken. Facility management is encouraged to seek details
and clarification if required.
Our facility ratings will evolve
to reflect updates we make to
our sustainability standards.
Our longer-term commitment is
to reward suppliers that embrace
sustainability and proactively seek
to improve conditions for their
employees, and reduce their
impacts on the environment.
For more information on our
facility ratings, please see
Appendix 13: Gap Inc. Facility
Rating Methodology Overview.

3.4 Issue Classification And Performance Measurement
Gap Inc. recognizes that compliance with sustainability standards is not always simply black
or white. To reflect this, we introduced a new facility rating system that offers gradients of
non-compliance that correspond to different severity levels. Issues will be scored according
to four severity levels: Non-compliance, key, severe and critical. (Refer to Appendix 2 for a list
of all critical issues.)
→→ Each of these categories of issues will impact the facility rating calculation on an
incremental basis. (Refer to Appendix 13 Gap Inc. COVC Ratings Methodology for
details.)
→→ Based on the new Ratings Methodology, after every full assessment, Gap Inc.’s Global
Sustainability Data System will calculate a performance rating and a corresponding
color rating for each facility.
→→ There are 3 performance grades defined as below:
Category Color Rating Point Range Description
Top Performer Green 86-100 Maintains a high level of social

and environmental performance.
Average Performer Yellow 65-85 Social and environmental

standards require improvement.
Bottom Performer Red 0-64 Social and environmental

standards require immediate
attention.
Note: A vendor rating is calculated as the average rating for all the facilities attached to that vendor.
3.5 Corrective Action Plan (CAP) Management
Efficient and expedient Corrective Action Plan (CAP)

Management is a critical component of managing
your facility’s risks, and improving your sustainability
performance. Our Supplier Sustainability team can partner
with you to make improvements in how you create and
implement corrective actions.
A written report of findings will be shared with the facility and vendor management within
7 days of completion of the assessment. Thereafter the facility is required to follow the
following procedure for CAP management and issue resolution.
Within 10 calendar days upon receiving the Assessment Report, the vendor or the facility
shall submit a CAP to the designated Gap Inc. Assessment & Remediation Specialist
(see Appendix 11 CAP Template). To ensure sustainable resolutions of issues, facilities are
encouraged to conduct root cause analysis (See Appendix 12 Root Cause Analysis Guidelines)
of issues and to present corrective actions that address the root causes. Some issues may
require multiple progressive corrective actions for resolution. In such case, each corrective
action shall have a target completion date.
For information on our expectations for CAP Management if

your facility is participating in the ILO Better Work program,
please contact a Gap Inc. Assessment & Remediation
Specialist in your region.

The CAP submitted by each facility must include the following information:
1. Area for improvement (AFI) identified and Facility Improvement Plan (FIP), which are
noted in the Assessment Report from Gap Inc.
2. Specific Corrective Actions (CA) to eliminate the cause of AFI. This could include
developing or updating written policies or procedures, capability building and any other
relevant actions.
3. If Root Cause Analysis has been conducted (as per Gap Inc.’s Root Cause Analysis
Guidelines), Corrective Actions should target the root cause(s) identified.
4. Information on who is accountable for each Corrective Action implementation at
your facility.
5. A deadline for completing each Corrective Action.
The Gap Inc. assessor will follow up with the facility on the Corrective Action Plan according
to the timeline set by the facility. The facility is responsible for sending to the Gap Inc.
Assessment & Remediation Specialist (A&RS) evidence of corrective actions taken as per
the timelines for each issue reported in the assessment report. The assessor will review the
evidence submitted and update the facility whether the issue can be resolved by offsite
review of evidences, or if an on-site verification is required.
If the facility can not accomplish the Corrective Action by the agreed upon deadline, the
facility shall notify the A&RS at least one week before the deadline, and must provide
information on:
1. Reason for delay.
2. Evidence of progress to date.
3. New Corrective Action deadline taking into consideration the consequence model for
past due FIPs included herein.
It will be up to the Assessment & Remediation Specialist to accept or reject the reasons
provided for delays. If the facility does not provide evidence of Corrective Action by the
agreed upon due date, or does not notify the Assessment & Remediation Specialist of
delays, the issue will be escalated according to the consequence model for past due Facility
Improvement Plans (see Appendix 10 Corrective Action Plan and Open AFI Guidelines).
Gap Inc. is a founding member of the
International Labour Organization’s
(ILO) Better Work program. Better
Work assists facilities in improving
practices based on core ILO labor
standards and national laws, and
does so with a strong emphasis on
improving worker-management
cooperation, working conditions,
and social dialogue. Gap Inc. strongly
encourages participation in the Better
Work program, which is operational
in Bangladesh, Cambodia, Haiti,
Indonesia, Jordan, Lesotho, Nicaragua,
and Vietnam. For more information
on how you can participate, please
contact our Supplier Sustainability
team, or visit www.betterwork.org.

3.6 ILO Better Work Assessments
Better Work is a partnership program managed by the International Labour Organization
and the International Finance Corporation.
Gap Inc. has been a strong supporter of Better Work since its inception, and we continue to
support its growth and evolution. In key markets, we have replaced our own assessments
with Better Work assessments, and have sought to increase the number of facilities
participating in Better Work each year. We are committed to not reducing or terminating
production orders based on Better Work assessment results, as long as participating
facilities continue to embrace an ethic of continuous improvement. We recognize that
Better Work’s assessment methodology has some differences from our own, and as a result
we have taken steps to ensure that our rating system does not unfairly penalize facilities
participating in the Better Work program.
We encourage you to learn more about Better Work at www.betterwork.org.
We are committed to partnering
with suppliers that can meet our
key business and sustainability
expectations, including those focused on
quality, timely delivery, sustainability,
and ethical business conduct. As such,
selecting who and where we source our
products requires a comprehensive due
diligence process, one that ensures that
the new facilities are willing and able
to meet our minimum expectations
and have the capacity to continuously
improve. In the spirit of transparency,
we also expect our approved vendors
and facilities to continue to disclose
changes in their operations that may
impact Gap Inc.’s business.

Chapter 4:
Vendor Approval
Process & Status Changes
Overview
4.1 Overview
Vendors must ensure that all facilities anticipated to produce goods for Gap Inc., including
subcontractors, are approved by the Global Sustainability department before any Gap Inc.
production begins. The approval process is outlined below.
4.2 Requesting New Facility Approval

Vendor/facility is required to raise the request for a new facility approval with Gap Inc.’s
Global Supply Chain department (Sourcing/Merchandising team), and not with the Global
Sustainability department. The Global Sustainability department will only accept new
facility approval requests from our counterparts in Global Supply Chain, and will not accept
any new facility approval requests directly from vendors.
Once the vendor/facility has submitted a request for the new facility approval to Global
Supply Chain, they will evaluate the need for the new facility. When the request is accepted
by Global Supply Chain, they will forward the request to Global Sustainability and the
documentation process will commence.
4.3 Documentation
Vendor and Vendor Affiliates (facilities) will be requested to sign and return the Vendor
Compliance Agreement (VCA) along with other agreements and forms.
→→ By signing the VCA, Vendor and Vendor Affiliates certify that they will comply with Gap
Inc.’s Code of Vendor Conduct (COVC) and allow Assessment & Remediation Specialists
(A&RS) or other designated parties to have unrestricted access to Vendor’s and Vendor
Affiliate’s facilities, dormitories, workers, and to all relevant records (see VCA sections
I.B, I.C and VII.A).
A copy of the VCA is included in the Vendor Compliance Agreement section of the Vendor
Handbook, and Chapter 1 is available in the Gap Source Library (gSL - https://gapweb.gap.
com/gw/content/vendorportal/en/gsl.html).
After the review and acceptance of all required documents submitted by a vendor/facility,
Global Sustainability will initiate the assessment process.
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4.4 Initial Assessment
Where appropriate, Global Sustainability may request that an Assessment & Remediation
Specialist or other designated party conduct an initial on-site assessment of the requested
facility.
Upon review of the facility assessment report, Global Sustainability will notify the Vendor
and Gap Inc. representative of one of the following decisions:
→→ Corrective Action Needed
→→ Approved
→→ Rejected
4.5 Cases Where Corrective Action is Needed

If Global Sustainability informs a Vendor that corrective action is needed before a facility
can be approved, the facility may be given the opportunity to take appropriate steps to gain
approval.
Global Sustainability must determine that corrective action has been satisfactorily
completed before a facility can be approved for production.
4.6 Consequences of Facility Approval

Only the Global Sustainability department is authorized to approve a facility. This approval
will be documented in writing. For more information on approval process, please see
Appendix 7: Facility Status Change.
An approved facility will be authorized to begin production only after a written approval
letter is issued by the Global Sustainability department upon successful completion of the
approval process which may include other processes such as technical approval or Gap Inc.
Water Quality Program (WQP) approval.
Vendors may initiate Gap Inc. production only after a Purchase Order (PO) is received from
the Company.
4.7 Consequences of Facility Rejection

Rejected facilities are not authorized to produce for Gap Inc., and the rejected facility cannot
re-apply with an approval request within 12 months from the date of rejection.
4.8 Vendor or Facility Changes

Vendor and Vendor Affiliates must promptly notify Global Sustainability’s Supplier
Sustainability team in advance by e-mail, fax or letter of changes in Vendor’s or Vendor
Affiliate’s name, address or ownership. Gap Inc. production cannot be moved to facility’s
new location without prior written authorization by Global Sustainability department.

Vendor and Vendor Affiliates must also promptly notify Gap Inc.’s Supplier Sustainability
team in advance by e-mail, fax or letter if the facility’s physical structure, capabilities or
composition of the workforce significantly changes, such as adding an additional building or
additional room to an existing structure. Please see Appendix 5: Facility Expansion Policy.
4.9 Termination of Approved Status

A facility’s approved status may be revoked by Global Sustainability for significant non-
compliance with the COVC.
Orders are not authorized to be placed at a facility with revoked status. In addition, existing
production may be pulled once a determination of revocation has been made.
Facilities that are not expected to receive future POs may be deactivated. Production in
deactivated facilities is not authorized.
Deactivated facilities may be re-approved for production only following the appropriate
review by Global Sustainability.

CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 4: Vendor Approval Process & Status Changes Overview 35
Chapter 5:
Management Systems
Beginning in 2015, Gap Inc. will be piloting an additional Provision focusing on Management
Systems (with five supporting Standards) in our COVC. Your facility’s performance against
these Standards, however, will not contribute to your facility ratings 2015-16.
Effective management systems help ensure that social and environmental sustainability
and continuous improvement are part of the day-to-day operations of the facility. A facility
with a strong internal management system will be alerted immediately to sustainability
risks, and will have preventative measures in place to help ensure an issue does not
recur. In this way, facilities can take increased ownership of their sustainability program
and ultimately may be able to continuously improve business operations with fewer
accidents, less employee turnover, less rework, higher productivity, and fewer impacts on
the environment. All of these improvements can lead to a stronger partnership between
Gap Inc. and your company. Gap Inc. expects that facilities will have effective management
systems to proactively identify and manage sustainability issues that may arise and not wait
for external assessments.
A facility that has effective management systems in place

A) Plans, in terms of policies that document goals and
objectives and procedures that will carry out these goals
B) Does, or implements those plans and has people
responsible for training employees on these processes
C) Checks that the plans are implemented and are in fact
effective and D) Adjusts the plan or processes where they are
not effective.
Thus, our assessors will not only be assessing the availability of written policies, but will also
be evaluating facilities’ effective implementation (and compliance), deployment, and level of
assessment of the written policies.
Below are questions you will want to consider as you further your implementation of
sustainability-related Management Systems.
CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 5: Management Systems 37

Plan
Your facility is expected to establish the objectives and processes necessary to deliver
results in accordance with the expected targets or goals.
Policy
→→ Write a policy that clearly states what your facility is trying to achieve.
→→ Ensure that your policy is clear enough to be tested and assessed.
→→ Ensure your policy covers all COVC and legal requirements.
Appoint
→→ Ensure you have assigned responsibility for the oversight, communication, deployment,
and assessment of the policy and related practices.
→→ Ensure the assigned individuals are held accountable for its implementation.
Objectives & Targets
→→ Set sustainability targets that are measurable, documented and associated with a
timeline.
Develop Written Procedures
→→ Develop written processes and procedures that are consistent with applicable laws.
→→ Develop written processes and procedures to support the implementation of this policy.
→→ Keep proper documentation to track compliance to this area.
Do
Your facility is expected to put your planning into practice.

Internal & External Communication
→→ Ensure your facility’s policy and procedure has been communicated to relevant
employees.
→→ Ensure relevant employees understand the policies and procedures, and put it into
practice.
Capability Building & Training
→→ Ensure there are records or documentation of relevant trainings.
→→ Ensure the trainings are held in the language employees easily understand.
→→ Try to provide trainings in various formats (e.g. verbal, written, pictorial).
→→ Develop systems to check for effectiveness of trainings.
→→ Ensure the frequency of trainings is appropriate to the number of staff, new staff, and

the related procedures.
→→ Ensure relevant employees understand the policies and procedures, and that they put it
into practice.
→→ Assess whether sufficient time has elapsed since adoption of the practice to
demonstrate consistent use.
Implementation
→→ Ensure your facility implements all the established policies/procedures established.
Check
Your facility is expected to assess its performance and the performance of the man-
agement system based on established indicators periodically.
→→ Review whether the facility has met its objectives and targets.
→→ Ensure that deviations from the practice (i.e. subject of the training or policy) are
identified, analysed, and investigated.
Adjust
Your facility should identify deficiencies and root causes, and generate solutions for
continuous improvement in reasonable timeframes, based on performance against
indicators.
→→ If not meeting its targets, your facility should identify root causes and/or deficiencies.
→→ Take action to improve performance, such as updating procedures or providing better
training.
→→ Ensure regular management reviews are conducted.
CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 5: Management Systems 39

Chapter 6:
Vendor Portal in Gap Inc.’s

Global Sustainability
System (GSS)
In 2015, Gap Inc.’s Global Sustainability department adopted a new data system to
support its sustainability programs. A critical feature of this new data system is a vendor
portal, through which our vendors can access information related to their sustainability
performance, assessment history, and helpful tools that will allow you to proactively
manage your sustainability risks and opportunities.
Gap Inc. is committed working with suppliers to provide

updated information about progress towards remediation
of issues. To aid this effort, Gap Inc. will develop an online
portal to facilitate information sharing and communication.
Key elements of this new vendor portal include:

→→ New vendor and new facility approval, in which the data system will collect
information and relevant documents that are required to approve a new or expanded
facility for Gap Inc. production. Such information includes detail on the production
facility and the working conditions within it, as well as information on workers, their
wages, and other related labor standards information that is critical for us to evaluate
if the facility is appropriate for Gap Inc. production. This streamlined approval process
will help Gap Inc. and our partner vendors avoid duplicative work, and will allow for
increased efficiency as we evaluate new facilities.
→→ Assessment results and Corrective Action Plan (CAP) management, including each
facility’s detailed assessment history, status of specific issues found and where
they are in the remediation process, a scoring summary, and the ability to upload
documentation of remediation efforts. Vendors will also have the ability to compare
and manage sustainability performance across their facilities.

→→ Facility and worker information updates that covers relevant workforce and operational
information related to your facility. At a minimum Gap Inc. will require that this information
be updated on an annual basis, but we will also be regularly encouraging our vendors to
review and update this information more frequently and on an as-needed basis.
→→ Communications and a resource library, which will house updates to our Code of
Vendor Conduct Manual, Gap Inc.’s Code of Business Conduct, and other policies
and procedures that are relevant to the work we do with you. A streamlined
communications functionality will allow us to be more efficient and consistent in
how we share information and ensure that relevant information on our Supplier
Sustainability programs are being shared with the right individuals. Over time, we will
also include best practices, guidance, tutorials, and e-learning capabilities that will help
our vendors learn about leading sustainability practices and opportunities.
The above functionalities are the key aspects of the vendor portal as we roll it out, but over time,
we will add more capabilities that will further support our shared objective of building a more
sustainable supply chain. In 2016, we will be piloting a social impact and business performance
dashboard, during which time we will ask you for additional information on your workforce,
working hours, wages, as well as information on absenteeism, turnover, and rework rates.
For more information on Gap Inc.’s vendor portal, please visit gap.cr360.com.
CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 6: Vendor Portal in Gap Inc.’s Global Sustainability System 41
42 42
Gap Inc.
GapCode
Inc. of
Code
Vendor
of Vendor
Conduct
Conduct
Manual
Manual
Part 2:
Provisions &
Standards
CONFIDENDIAL DO NOT DISTRIBUTE

44
I. Compliance with Laws
Facilities that produce goods for Gap Inc. shall operate in full compliance with the laws of their respective countries and with all other applicable laws, rules
and regulations. As a condition of doing business with Gap Inc., each and every vendor must comply with this Code of Vendor Conduct.
Gap Inc. will continue to develop assessment and remediation systems to evaluate and ensure compliance. Wherever there is a difference in the requirements
as per local law and that in the Gap Inc. COVC, the more stringent requirement shall apply. Vendor and Vendor Affiliates shall use only Gap Inc. approved facili-
ties for the production of goods. Vendors shall obtain written authorization from Gap Inc. to use these facilities prior to the start of production.

I.A Facility operates in full compliance with all applicable laws, rules and regulations including those relating to labor, worker health and safety, and
the environment.
Standard Standard
Detail ID Standard Detail Sub-Detail ID Standard Sub-Detail Guidance/FAQ/Best Practices
I.A.01 Facility operates in full compliance I.A.01.01 Facility operates in full compliance with all applicable Guidance
with all applicable laws, rules and laws, rules and regulations, including those relating to There are many types of laws related to
regulations including those relating labor, worker health and safety, and the environment. environment, discrimination, forced labor,
to labor, worker health and safety, Facility appoints adequate officials/personnel as per legal contract labor regulations, child labor,
I.A.01.02
and the environment. requirements (e.g. welfare/safety/liaison officer). wages & benefits, working hours, humane
treatment, and freedom of association.
I.A.01.03 Facility provides workers their legally required Additionally, there are frequently laws
certificates/forms/cards/permits. and regulations that cover: A) Internal
Regulations & Standing Orders: If required
I.A.01.04 Facility provides local legal departments with their by law, internal regulations/standing orders
required information/notices. should be available, up to date and posted
following local laws. B) Required Business
Insurances: If required by law, required
business insurances, e.g. fire, earthquake,
should be available, and up to date following
local laws.
I.A.02 Facility shall maintain copies I.A.02.01 Facility maintains copies of applicable local laws.
of local laws and post them in
prominent places if required by law.
I.A.02.02 Abstracts of local laws are posted in prominent locations
in the facility.
I.A Facility operates in full compliance with all applicable laws, rules and regulations including those relating to labor, worker health and safety, and
the environment.
Standard Standard
I.A.03 Facility management shall be able I.A.03.01 Facility management demonstrates adequate knowledge
to demonstrate adequate knowledge of local laws related to environment, discrimination,

local laws related to environment, forced labor, contract labor regulations, child labor, wages
discrimination, forced labor, contract & benefits, working hours, humane treatment, and
labor regulations, child labor, freedom of association.
wages & benefits, working hours,
humane treatment, and freedom of I.A.03.02 Facility management demonstrates adequate knowledge
association and knowledge of how of how to access information and track changes related to
to access information and track local laws (e.g., through the internet, law books or through
changes related to local laws, e.g., regular communication with local labor officials, etc.)
through the internet, law books or
through regular communication
with local labor officials, etc.
I.A.04 If required by law, facilities shall I.A.04.01 Required operating business license/registration is
have operating business license/ available.
registration available and up to date.
I.A.04.02 Required operating business license/registration is up to
date.
I.A.04.03 Facility meets all other requirements related to required

operating business license/registration.
I.A.05 If required by law, required business I.A.05.01 Required insurances are available.
insurances, e.g. fire, earthquake,
shall be available, and up to date I.A.05.02 Required insurances are up to date.
following local laws.
I.A.05.03 Facility meets all other requirements related to required
insurances.
I.A.06 Facility maintains updated internal I.A.06.01 Required internal regulations/standing orders are
regulations/standing orders/work available.
rules and posts them in prominent
areas if required by law. I.A.06.02 Required internal regulations/standing orders are up to
date.
I.A.06.03 Required internal regulations/standing orders are posted.
Part 2: Provisions & Standards Section I: Compliance with Laws

I.A.06.04 Required internal regulations/standing orders are in full
45
compliance with local labor law.
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I.B Worker Interviews
Management is prohibited from coaching or requiring workers to provide certain answers to assessors during confidential worker interviews.
Standard Standard
I.B.01 Management is prohibited from I.B.01.01 Facility management does not coach or require workers to
coaching or requiring workers to provide certain answers during interviews with Gap Inc.
provide certain answers during assessors.
interviews.
I.B.02 Management must provide I.B.02.01 Facility provides Gap Inc. assessors with adequate privacy/
assessors with adequate privacy as private area for conducting worker interviews.

required in order to conduct worker
interviews.
I.B.03 Under no circumstances shall I.B.03.01 Facility staff does not retaliate against workers who bring up
workers be penalized for speaking issues of compliance.
with assessors (including any form
of retribution or being denied wages
for the time spent in interviews
with the assessors).
I.C Bribery
Facilities do not tolerate, permit, or engage in bribery, corruption, fraud, or unethical business practices whether in dealings with business partners,
public officials or any Gap Inc. representatives.
Standard Standard
I.C.01 Facilities do not tolerate, permit, or I.C.01.01 Facility staff does not accept bribes from workers who want
engage in bribery, corruption; fraud to maintain their position or avoid disciplinary action, and/or
or unethical business practices facility staff does not attempt to bribe a Gap Inc. employee.
whether in dealings with business
partners, public officials or any Gap
Inc. representatives.
I.D U.S. Foreign Corrupt Practices Act (FCPA)
Facilities must comply with the U.S. Foreign Corrupt Practices Act (FCPA) and must not engage in corrupt or unethical practices, such as accepting or
offering bribes in exchange of preferential treatment or jobs.
Standard Standard
I.D.01 Facilities must not accept I.D.01.01 Facility operates in full compliance with
reimbursements, kickbacks or other U.S. Foreign Corrupt Practices Act (FCPA)
amounts from suppliers, government regarding corruption and unethical

agencies, employees, etc. practices, and does not attempt to make
payment to a government official for
the purpose of obtaining or retaining
business for or with, or directing
business to, any person.
I.E Transparency
Facilities are transparent with their policies, processes, and records applicable to their operations and compliance levels with the Gap Inc. COVC and
any Supplemental Requirements. All records and documents provided to Gap Inc. representatives not only limited to payroll and time-keeping records
shall be complete and accurate.
Standard Standard
I.E.01 Facilities shall present I.E.01.01 Facility records accurately reflect Best Practices
documentation that accurately facility conditions. It is well known that some facilities that produce for global brands
reflects the conditions of the facility and retailers at times struggle to pay legal wages or to control
or any subcontracted employees excessive working hours. In order to hide this, an alarming number
working on-site, such as payroll, of facilities employ dishonest means such as record manipulation,
health & safety, and personnel worker coaching, and bribery to pass assessments. This game of
records. ‘cat and mouse’ has promoted a warped understanding of supply
chain practices by many and undermines efforts to improve working
conditions. All supply chain partners have an important role to play in
breaking this manipulative cycle. From our experience we know that
brands and retailers that employ unrealistic “Comply or Die” pressure
tactics are least likely to see the truth, while those programs driven by
transparency and realistic continuous improvement are able to build
trust and demonstrate forward momentum more easily. Therefore, it
is the Gap Inc. program philosophy to better understand root causes
and supplier challenges in order to craft realistic improvement
expectations that put workers’ safety and livelihoods first and that
promote business with partners willing to work in a transparent and

honest manner.
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I.F Unrestricted Access
Facility allows Gap Inc. representatives or agents unrestricted access to its facilities for observation, workers for interview and relevant records for
review, whether or not notice is provided in advance.
Standard Standard
I.F.01 Facility allows Gap Inc. I.F.01.01 Facility staff allows full access to facility.
representatives or agents
unrestricted access to its facilities I.F.01.02 Facility staff allows full access to facility records.
for observation, workers for
interview and relevant records for I.F.01.03 Facility staff allows full access to workers.
review, whether or not notice is

I.F.01.04 Facility staff allows full access to any other part of their
provided in advance.
facility and its operations.
I.G Employment Contracts

All applicable records and documentation referenced in this standard are kept on-site and are available to Gap Inc. representatives for at least the past
12 months.
Standard Standard
I.G.01 Worker employment eligibility I.G.01.01 Worker employment eligibility requirements/forms/permits

requirements/forms/permits shall are available.
be available and up to date.
I.G.01.02 Worker employment eligibility requirements/forms/permits
are correctly completed.
I.G.01.03 Facility meets all other requirements related to worker

employment eligibility requirements/forms/permits.
I.G.02 If required by law, written I.G.02.01 Required written employment contracts are available.
employment contracts shall be
available, up to date and shall I.G.02.02 Required written employment contracts are up to date.
comply with local law.
I.G.02.03 Required written employment contracts have necessary
information on wages and other benefits.
I.G.02.04 Required written employment contracts comply with labor

law.
I.G.01.05 Facility meets all other requirements related to required

written employment contracts.
I.G Employment Contracts
All applicable records and documentation referenced in this standard are kept on-site and are available to Gap Inc. representatives for at least the past
12 months.
Standard Standard
I.G.03 Copies of written employment I.G.03.01 Required written employment contracts are provided to
contracts shall be provided to workers.
workers and terms and conditions

of employment shall be effectively I.G.03.02 Required written employment contracts are in the language
communicated prior to signing. of workers.
I.G.03.03 Terms and conditions of employment are effectively

communicated to workers.
I.G.04 All applicable records are I.G.04.01 All records are available on-site.
maintained well, complete and
accurate. I.G.04.02 All records are complete and have accurate information.
I.H Unauthorized Sub-contracting

Vendors shall only use Gap Inc. approved facilities for the production of goods. Facilities shall obtain written authorization from Gap Inc. to use these
facilities prior to the start of production.
Standard Standard
I.H.01 Facilities shall only use Gap Inc. I.H.01.01 Facility only places Gap Inc. production in approved facilities.
approved facilities for the production
of goods. Facilities shall obtain
written authorization from Gap Inc.
to use these facilities prior to the
start of production.

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I.I Facility Expansion
Whenever there is any expansion to the existing approved facility, facility/vendor shall inform Gap Inc.’s Supplier Sustainability team as soon as the
expansion is ready and shall not move any Gap Inc. production to the expanded area before receiving written approval from Gap Inc. (See Gap Inc.
Facility Expansion Policy in Appendix for more detail)
Standard Standard
I.I.01 Facility must notify Gap Inc. I.I.01.01 Facility notifies Gap Inc. Supplier Sustainability team of the
Supplier Sustainability team in case expansion to the approved facility.
of any expansion to the existing
approved facility. This includes

expanding to new buildings, floors,
etc. See Gap Inc. Facility Expansion
Policy in Appendix for more detail.
I.I.02 No Gap Inc. production shall be I.I.02.01 Facility shifts Gap Inc. production to expanded part of an
shifted to the expanded part approved building only after receiving written approval from
without receiving written approval Gap Inc. Supplier Sustainability team.
to do so by the Gap Inc. Supplier
Sustainability team.
I.J Subcontractor Monitoring (Handwork)

Facilities engage in monitoring and verification of their subcontractors to assess and address any risk associated with all sections of the COVC.
Standard Standard
I.J.01 If a facility uses any other Gap I.J.01.01 Facility monitors other facilities used for Gap Inc. production.
Inc. approved facility (owned or
subcontracted), for production of
Gap Inc. merchandise, they shall
have a system to monitor and verify
the status of their compliance to
the requirements listed in this
document.
I.J Subcontractor Monitoring (Handwork)
Facilities engage in monitoring and verification of their subcontractors to assess and address any risk associated with all sections of the COVC.
Standard Standard
I.J.02 Facility follows Gap Inc. Handwork/ I.J.02.01 Facility has provided Gap Inc. with a list of hand work
Homework Policy and Monitoring contractors being used for Gap Inc. branded product.
Procedures for monitoring of its

handwork supply chain, wherever I.J.02.02 Facility signed and submitted 'Letter of Assurance' to Gap Inc.
applicable.
I.J.02.03 Facility has obtained signed undertakings from its
sub-contractors.
I.J.02.04 Facility maintains details of its handwork supply chain

(contractors/sub-contractors/handworkers).
I.J.02.05 Facility monitors its handwork supply chain.
I.J.02.06 Facility maintains adequate records of monitoring visits of

the handwork supply chain.
I.K Gap Inc. COVC Poster

Gap Inc.’s COVC is posted in at least one conspicuous location in the facility that is regularly accessible to workers and in the predominant languages of
the workers.
Standard Standard
I.K.01 Gap Inc.’s COVC is posted in at least I.K.01.01 Gap Inc.'s COVC is posted.
one conspicuous location in the
facility that is regularly accessible I.K.01.02 Gap Inc.'s COVC is posted in the language of workers.
to workers and in the predominant
languages of the workers.

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I.L Worker-Management Communication
Facility constitutes and manages worker-management communication forums in compliance with law.
Standard Standard
I.L.01 Facility constitutes and I.L.01.01 Worker-management council is formed.

manages worker-management
communication forums in I.L.01.02 Worker-management council composition is in accordance
compliance with law. with law.
I.L.01.03 Representatives of worker council are elected in accordance

with law.
I.L.01.04 Worker council is functioning/carrying out its activities in

accordance with law.
I.L.01.05 Records of meetings/activities of worker council are

maintained and available.
I.M Child Care Facilities

Facility shall provide child care facilities wherever required by law.
Standard Standard
I.M.01 Facility shall provide child care I.M.01.01 Facility provides a childcare facility (creche).
facilities wherever required by law
I.M.02 Adequate infrastructure/ amenities I.M.02.01 Creche attendant is adequately trained in childcare.
shall be provided in childcare room
I.M.02.02 Creche room in the facility has sufficient space and is not
congested for the number of children in the creche.
I.M.02.03 Creche is provided with adequate facilities (food/washroom/

recreational items/feeding area etc.).
I.M.02.04 Creche is maintained properly (ventilation/cleanliness/

temperature etc.).
I.M.02.05 Proper records are maintained for children in creche (age/

weight/medical history/special requirements/attendance etc.).
I.N Apprentice and Vocational Programs
Any apprenticeship or vocational education programs at the facility are legal, documented and designed for the educational benefit of the workers.
Standard Standard
I.N.01 Obligations to employees under I.N.01.01 Facility does not use apprenticeship/training schemes to
labor or social security laws and avoid obligations to employees under labor or social security
regulations shall not be avoided laws and regulations.

through the use of apprenticeship/
training schemes where there is no I.N.01.02 Facility is imparting relevant skills to workers under
real intent to impart skills or provide apprenticeship/trainee contracts.
regular employment.
I.N.02 Facilities shall maintain accurate I.N.02.01 Accurate records of trainees, seasonal or occasional workers
records of trainees, seasonal or are maintained.
occasional workers.

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II. Environment
Facilities shall comply with all applicable environmental laws and regulations. Facilities must manage their impact on the environment, including energy & green-
house gas (GHG) emissions, air pollution (emissions to air), water consumption, water quality, wastewater, waste diversion and disposal, and chemical use and
handling.
II.A Environmental Management System

Facility has an Environmental Management System (EMS).
Standard Standard

II.A.01 An EMS shall be available, II.A.01.01 Facility has an EMS. Best Practices
implemented and well An EMS should be designed specifically for each
communicated. II.A.01.02 Facility's EMS is implemented and is effective. facility. Factors such as size, production processes,
level of management commitment, local or
II.A.01.03 Facility has an environment management policy.
national regulations or laws, and expectations
Facility conducts environmental awareness trainings for of NGOs, governments, and local communities
II.A.01.04
workers. should all be considered.
There are several internationally recognized and

II.A.01.05 Facility’s EMS operates in full compliance.
certifiable EMSs: ISO 14000, EMAS and BS 7750.
Although not required, facilities that are certified
II.A.02 Facility shall maintain an II.A.02.01 Facility has an Environmental Management Record.
in one of these standards meets this EMS Code
Environmental Management Record
requirement.
to document any environmental
emergencies e.g. accidental spills
or discharges, along with corrective
and preventative actions.
II.A.03 Facility operates in full compliance II.A.03.01 Required legal environmental permits (e.g. air/water/noise/
with all applicable environmental waste/central treatment plant etc.) are available.
laws, rules and regulations.
II.A.03.02 Required legal environmental permits (e.g. air/water/noise/
waste/central treatment plant etc.) are up to date.
II.A.03.03 Required legal environmental permits (e.g. air/water/noise/

waste/central treatment plant etc.) have no other problems.
II.A.03.04 Facility complies with other applicable environmental laws

and regulations.
II.A Environmental Management System
Facility has an Environmental Management System (EMS).
Standard Standard
II.A.04 All monitoring reports such as air, II.A.04.01 Required environmental monitoring reports are available.
water, noise etc. shall be maintained
as per local legal requirements. II.A.04.02 Required environmental monitoring reports are up to date.

II.A.04.03 Required environmental monitoring reports comply with
local laws.
II.B Environmental Emergency Plan

Facility has an environmental emergency plan (EEP) that includes procedures for notifying local community authorities in case of accidental discharge
or release of any other environmental emergency.
Standard Standard
II.B.01 Procedures to contact appropriate II.B.01.01 Facility has a process to contact appropriate government
government authorities or agencies authorities or agencies, in case of accidental discharge.
in case of accidental discharge, shall
be available.
II.B.02 Procedures to clean up accidental II.B.02.01 Facility has written procedures to clean up accidental
wastewater discharge or release, or wastewater discharge or release, or other environmental
other environmental emergencies emergencies that extend beyond the facility property.
that extend beyond the facility
property, shall be available.
II.B.03 Facility shall train personnel on how II.B.03.01 Facility trains personnel on how to properly respond in the
to properly respond in the event of event of a spill or environmental emergency.
a spill or environmental emergency
and maintain proper training II.B.03.02 Facility keeps records of accidental spills or discharges.
records.
II.B.04 Facility shall instruct workers on II.B.04.01 Facility instructs workers on first aid and emergency action
first aid procedures and emergency procedures in case of accidental exposure.
action to take in case of accidental
exposure by means of trainings and II.B.04.02 Facility posts first aid and emergency action procedures in
posters. case of accidental exposure in both the chemical storage and
Part 2: Provisions & Standards Section II: Environment

mixing areas.
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II.B.04.03 Facility has workers’ training records on how to properly
respond in the event of a spill or environmental emergency.
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II.C Wastewater Treatment Policy and Procedure
Facility maintains an up-to-date Wastewater Treatment Policy and Procedure. All industrial and domestic wastewater is treated to meet the discharge
requirements of local law. In addition, the facility shall comply with all applicable monitoring and reporting requirements. Treatment facility must be
appropriately sized to process effluent of all production processes, and may not be left idle during production times.
Standard Standard
II.C.01 Procedures for discharging II.C.01.01 Facility has procedures for discharging wastewater.
wastewater shall be available, to
include at least: II.C.01.02 Facility has a fully functional and well-maintained
wastewater treatment plant.

• Sources and components of
wastewater II.C.01.03 Capacity of facility wastewater treatment plant is sufficient
• Flow of wastewater/ wastewater to treat all effluent water.
treatment plant
II.C.01.04 Wastewater Treatment Plant has no other related problems.
• Treatment methods, e.g.
sedimentation, chemicals
• Frequency of wastewater
monitoring
• Authorized personnel
• Permit renewal
II.C.02 If facility discharges wastewater II.C.02.01 Discharge wastewater to Central Treatment Plant meets the
to a Central Treatment Plant (CTP), applicable water quality standards for CTP.
the facility will meet any applicable
standards for water quality before it
is discharged to the CTP. In addition,
facility will maintain a copy of
any applicable license or permit
authorizing discharge to the CTP.
II.D Water Quality Program
All denim laundry facilities shall comply with the requirements of the Gap Inc. Water Quality Program.
Standard Standard
II.D.01 All denim laundry facilities II.D.01.01 Wastewater discharge is in compliance with Gap Inc. Water
producing Gap Inc.’s denim product Quality Guidelines and local law requirements.
shall comply with the requirements

of the Gap Inc. Water Quality
Program.
II.E Chemicals Inventory

Facility maintains a current Chemical Inventory that lists all chemicals used in the facility and the supplier’s name.
Standard Standard
II.E.01 Facility shall maintain and make II.E.01.01 Facility maintains a Chemical Inventory and Usage Log with
available to workers, a list of all required details.
hazardous substances used in the
workplace. The list shall include, but II.E.01.02 Facility makes the Chemical Inventory and Usage Log
is not limited to: available to workers.
• Date
• Chemical name
• Supplier info. (Name, Address,
Contact # and Name)
• Usage / quantity used
• Storage location
• Availability of MSDS
• Authorized users’ signatures

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II.F Restricted Substances List
Facility adheres to chemicals restrictions, as described in the Gap Inc. Restricted Substances List (RSL), and also prohibits the use of banned chemicals
in manufacturing processes, as described in the Zero Discharge of Hazardous Chemicals - Manufacturing Restricted Substances List (ZDHC MRSL).
Standard Standard
II.F.01 Facility shall not be using any legally II.F.01.01 Facility does not use any legal banned or restricted chemicals
banned or restricted chemicals as per the Gap Inc. Restricted Substances List.
as per the Gap Inc. Restricted
Substances List (RSL); See ZDHC
MRSL Appendix.

II.G Chemicals Storage
Chemicals and hazardous substances storage areas are maintained in an organized and safe manner, with clear and proper labelling of chemicals
containers.
Standard Standard
II.G.01 Facility's Hazardous substances/ II.G.01.01 Facility has a separated, marked storage area for chemicals. Guidance
chemical storage area is suitably • Different chemicals should be appropriately
located and is properly maintained. II.G.01.02 Facility's chemical storage area is suitably located. separated within the storage area.

Different chemicals are separated within the storage area. • Chemicals should be stacked following
II.G.01.03
manufacturers’ guidelines.
II.G.01.04 Facility's chemical storage area is well maintained and • The storage area should be well ventilated
is provided with required fixtures if required (e.g. special and kept at the temperature specified by the
protective lights). manufacturers’ instructions.
• Chemical storage area should be segregated
II.G.01.05 Facility's chemical storage area is well ventilated.
from the product processing area. Chemical
wastes should not be stored in work areas or
II.G.01.06 Facility keeps their chemical storage area dry.
in garment/fabric-storage areas.
II.G.01.07 In the facility, chemicals are only kept in the designated • Chemicals should not be stored near
storage area. production lines, in stairwells, or in other
areas not designated for chemical storage.
II.G.01.08 Chemical stacking height does not present a hazard.
• Bulk chemical containers should be closed
when not in use.
II.G.01.09 Facility has "No Smoking" signs posted in areas where
chemicals are present. • Secondary or point-of-use containers should
be labelled with content identification and,
II.G.01.10 Facility's chemicals are appropriately covered when not in where appropriate, a hazard warning, or signs
use. are posted in storage and mixing areas with
this information.
II.G.01.11 Facility has a separated, marked storage area for hazardous
• Chemicals (bleaching agents such as chlorine,
waste like waste oil, sludge, empty containers, etc.
neutralizing agents such as hydrogen peroxide
[H2O2], acetic acid and soda ash, soaps and
II.G.02 Chemical containers shall be II.G.02.01 Chemical containers are labelled indicating the contents and
surfactants, softeners, dyestuffs and sulphuric
labelled indicating the contents any potential hazard.
acid) should be stored in an area walled off
(chemical or trade name) and
II.G.02.02 Facility reuses and/or disposes of empty chemical and from the laundry equipment.
potential hazard (e.g., flammability).
Empty chemical containers shall be hazardous substance containers in a safe manner. • Floors should be kept dry and free from
either disposed of or, if reused, are standing water or chemicals.
only used to hold the same chemical • Empty chemical and hazardous substance
as their original, labelled contents. containers should be removed from work
areas promptly, should be stored in a secure
designated area and should be removed from

the facility on a regular basis.
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II.G Chemicals Storage
Chemicals and hazardous substances storage areas are maintained in an organized and safe manner, with clear and proper labelling of chemicals
containers.
Standard Standard
II.G.03 Chemicals purchased, stored or used II.G.03.01 Facility has a MSDS for every chemical used.
shall have a Material Safety Data
Sheet (MSDS), chemical safety card
or other similar documentation
from the manufacturer that can be

understood by workers involved in
the use and handling of hazardous
chemicals.
II.G.04 MSDS or similar documentation II.G.04.01 Facility's MSDS is in the local language.
shall be in the predominant
language of the workers. MSDS shall II.G.04.02 Facility's MSDS contains all relevant information.
describe, at least:
• Chemical name and type

• Potential health or
environmental hazards of the
chemical
• PPE to be worn by chemical
handlers
• Safe storing and handling
requirements
• Clean up and exposure
procedures
II.G.05 Chemicals that may exhibit a II.G.05.01 Chemicals with hazardous characteristics are stored in
hazardous characteristic such secondary containment that can hold 100% of the chemical
as flammability, corrosivity or plus 10% more.
toxicity shall be stored in secondary
containment that can hold 100% of II.G.05.02 Facility's fuel tank is surrounded by a second containment
the chemical plus 10% more. unit (a wall, dyke or similar structure) that is constructed of
leak-proof, non-absorbing material.
II.G.06 Chemicals, hazardous or otherwise, II.G.06.01 Facility's chemicals are not stored with combustible
shall be stored separately from materials.
combustible materials, such as raw
materials, fabric, paper, or other fuel
sources.
II.H Chemical Handling Procedures
Facility shall have defined safe chemical handling procedures and shall train workers in these procedures and hazards of chemical exposure.
Standard Standard
II.H.01 Facility shall implement chemical II.H.01.01 Procedures for chemical handling and storage are available. Guidance
use and handling procedures that • A procedure should exist for reporting and
shall, at least: II.H.01.02 Facility's chemical use and handling program complies with responding to chemical spills inside the

applicable laws, regulations and internal requirements. production area.
• Include storage locations
• Indicate proper handling, II.H.01.03 Procedures for chemical handling and storage are effectively • Spills and/or leaks should be cleaned up
labelling, storage and segregation implemented and communicated. promptly.
of chemicals • Cement or glue bowls in the production
II.H.01.04 Facility's chemical use and handling program includes process should be covered completely when
• Require workers to wear Personal
outlines of work practices and procedures that define the not in use. When in use, only that portion of
Protective Equipment (PPE)
appropriate and safe use and storage of chemicals. the bowl necessary for efficient application
• Require workers to review
should be uncovered.
Material Safety Data Sheet II.H.01.05 Facility trains workers in MSDS of chemicals, safe work
(MSDS) • Only non-electric mixers should be used
practices and hazards particular to their job assignment.
because of the danger of fire or explosion; air
• Identify authorized personnel
II.H.01.06 Facility keeps workers’ training records on chemical use, pressure mixers are preferred.
• Include spill clean-up protocols
handling, disposal and spill clean-up. • Each chemical should have its own separate
• Training records shall be dispenser or dispensing tools.
maintained. II.H.01.07 Procedures for chemical handling and storage function in full
compliance.
II.H.02 Workers shall be given proper II.H.02.01 Facility has a separate dispenser or dispensing tool for each
equipment and follow procedures chemical.
that allow them to manually
dispense chemicals in a manner that II.H.02.02 Facility has procedures for reporting and responding to
reduces the possibility of spillage chemical spills inside the production area.
and unnecessary exposure and clear
II.H.02.03 Facility's procedures for reporting and responding to
spillage, if required.
chemical spills inside the production area are effectively
implemented and communicated.
II.H.02.04 Procedures for reporting and responding to chemical spills

inside the production area function in full compliance.
II.H.02.05 Spill kit is available.
II.H.02.06 Spill Kit is completely equipped.

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II.H Chemical Handling Procedures
Facility shall have defined safe chemical handling procedures and shall train workers in these procedures and hazards of chemical exposure.
Standard Standard
II.H.03 There shall be a designated, highly II.H.03.01 Facility has designated wash area(s) (for bathing eyes and
visible, emergency wash station washing skin) in or near work and chemical mixing/transfer
in or near the work and chemical areas.
mixing/transfer areas with facilities
for bathing eyes and washing skin. II.H.03.02 Wash area(s) (for bathing eyes and washing skin) provided in
Examples may include eye fountain facility are accessible and functional.

or bottles of saline eye solution.
Workers shall receive regular
training on their use.
II.I Chemical and Waste Disposal

Facility segregates hazardous from non-hazardous materials and disposes of both types of materials in a safe and legal manner.
Standard Standard
II.I.01 Hazardous and non-hazardous II.I.01.01 Facility has procedures for classification, collection and
wastes shall be disposed of regularly disposal of waste.
in a safe manner in accordance
with local and national laws. Where II.I.01.02 Facility's waste disposal procedures are complete and
applicable, permit or license for appropriate for the types of waste.
authorized waste hauler(s) must be
II.I.01.03 Facility’s procedures for classification, collection and disposal
valid and a copy made available for
of waste are implemented effectively.
review.
II.I.01.04 Facility has contracted/renewed the contract with authorised
agency for safe and legal disposal of waste.
II.I.01.05 Facility's waste disposal in compliance with legal

requirements.
II.I.01.06 Facility maintains waste disposal records.
II.I.01.07 Facility does not practice uncontained and open burning of

waste on facility property.
II.J SAC Higg Index Facility Environment Module
Facility annually completes and submits the Higg Index Facility Environment Module.
Standard Standard
II.J.01 Facility annually completes and II.J.01.01 Facility has completed the Higg Index Facility Frequently Asked Questions
submits the Higg Index Facility Environment Module. What is the Higg Index and why does Gap Inc. use it?
Environment Module. (See SAC Gap Inc. is committed to helping our facilities on our

Facility Module: Environment journey of continuous improvement. The Higg Index is a
Apparel and Footwear Appendix) tool to help establish a baseline of facilities’ environmental
performance and measure their improvement. It measures
environmental impacts including energy/greenhouse gas
emissions; water; wastewater/effluent; air emissions; waste;
and chemicals management. Specifically, the Higg Index is
an apparel and footwear industry self-assessment standard
for assessing environmental sustainability throughout the
supply chain. Launched in 2012, it was developed by the
Sustainable Apparel Coalition, a non-profit organization
founded by a group of fashion companies, the United States
government Environmental Protection Agency, and other
non-profit entities. The Higg Index is a self-assessment
tool aimed at creating a standard industry approach to
measuring and evaluating environmental impacts of all
apparel and footwear products for the industry, while
informing business-to-business decision-making that
identifies ways to improve products and processes.
Do these Environmental Protection guidelines relate to the

Higg Index Facility Environment Module?
Yes. The Environmental Protection requirements are meant
to complement the questions from the Higg Index Facility
Environment Module Level 1 questions, as the primary focus
of the Higg Index is with regards to Management Systems.
You may use the same documentation to demonstrate
compliance with Gap Inc. and to answer the Higg Index-
Environment Facility Module questionnaire. You may also
want to use the Higg Index questionnaire as a tool to help
you set up the Environmental Management System in your
facility.
Part 2: Provisions & Standards Section III: Labor Standards

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III. Labor Standards
III.A Labor Standards: Child Labor
Facilities shall employ only workers who meet the applicable minimum legal age requirements or are at least 15 years of age, whichever is greater. Facilities must
also comply with all other applicable child labor laws. Facilities are encouraged to develop lawful workplace apprenticeship programs for the educational benefit of
their workers, provided that all participants meet both Gap Inc.’s minimum age standard of 15 and the minimum legal age requirement.
III.A.01 Minimum Age Requirement

All workers meet the applicable legal minimum age requirements or are at least 15 years of age, whichever is greater. If the minimum legal age is
higher under local law, the higher age applies.
Standard Standard
III.A.01 Notwithstanding the minimum III.A.01.01 Workers are of or above the legal Frequently Asked Questions
age requirement of 15 years, if a minimum age. Are there any circumstances where Gap Inc. allows children
country’s minimum age has been to be in a supplier’s production facility? Gap Inc. does not
set at 14 in compliance with ILO III.A.01.02 Workers are of or above 15 years of age.
consider a production facility a suitable place for children. In no
Convention 138, that minimum age circumstances are children allowed in the production area. If a
III.A.01.03 Facility operates in full compliance with
shall apply. facility maintains child care facilities, they should be separate
regard to workers being of or above the
from work areas.
legal minimum age/15 years of age.
What should a facility do if child labor is discovered? If child
labor is found, Gap Inc.’s primary concern is for the welfare of
the child. The facility must take appropriate steps and actions to
ensure that the child, if removed from the facility, will not be in
a more compromised position than while she/he was employed
by the facility. Gap Inc.’s child labor remediation policy is aligned
with ILO BFC’s Child Labor Guidance.
In case child labor is found, the facility shall take the following
steps: Confirmed underage worker is removed from the
workplace, and is enrolled in education or vocational training
courses until he/she reaches legal working age.
Average wages are paid until the underage child reaches legal
working age (i.e., 15 years old), and as well as vocational school
fees. When the underage child turns 15 or the legal working age,
he/she is given an option of returning to work if he/she wishes.
Some countries have laws that dictate procedures to follow in

case child labor is detected. Make sure you/ the facility is aware of
these or following them, as appropriate, in case the need arises.
III.A.02 Mandatory Schooling Age
No worker shall be employed who is under the age for mandatory schooling.
Standard Standard
III.A.02 No worker shall be employed who III.A.02.01 Workers are above the age of mandatory schooling.
is under the age for mandatory
schooling.

III.A.03 Age Verification Documents
Facility has a rigorous age verification procedure which includes maintaining copies of official government-authenticated documentation for every
worker that verifies the worker’s date of birth. In countries where official proof-of-age documents, birth certificates or government-issued IDs are not
available, the facility employs independent & reliable means for determining workers’ age.
Standard Standard
III.A.03 Facility shall maintain appropriate III.A.03.01 Appropriate age verification documents are Frequently Asked Questions
age verification documents for available. In my country not all workers have formal identification
each worker. If required, such age cards that can prove their exact age. Is this considered a non-
verification document shall be in III.A.03.02 Appropriate age verification document is
compliance?
compliance with any applicable complete.
In all cases, you are responsible for ensuring that there are
legal requirement.
III.A.03.03 Appropriate age verification document no child workers employed) and that you have rigorous
Facility shall photocopy (where complies with legal requirements. and effective methods for ensuring this is the case (See
not restricted by law) the Supplemental Requirements 3 and 7). In countries where
original identification (ID) or III.A.03.04 Facility does not accept photocopies of no reliable birth documentation exists, you are expected to
other document and not accept a identification provided by worker without implement a recruitment system that appropriately assesses
photocopy provided by the worker. verifying authenticity. the age of potential workers based on local norms. Examples
of other documents might include:
III.A.03.05 Appropriate age verification document is in full
compliance. • Educational certificate
• Election identification card/voter registration card
• Family book
• Residence document indicating name and age of members
of a household
• School leaving certificate
• Medical assessment of development, or other means
considered reliable in the local context

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III.A.04 Age Verification Procedure
In countries where no reliable documentation exists, the facility shall implement a recruitment systems that appropriately assesses the age of
potential workers.
Standard Standard
III.A.04 In countries where no reliable III.A.04.01 Facility has a robust age verification process.
documentation exists, the facility
shall implement a recruitment III.A.04.02 Facility's age verification process is implemented effectively.
system that appropriately assesses
the age of potential workers. III.A.04.03 Facility's age verification process operates in full compliance.

III.A.05 Children in Production Areas
No children, as defined above, are allowed in the production area, even if they are not working.
Standard Standard
III.A.05 No children, as defined above, are III.A.05.01 Non-working children are not present in the workplace.
allowed in the production area, even
if they are not working.
III.A.06 Young Workers: Working Conditions

Facility takes all necessary precautions to ensure that young workers, under the age of 18, are protected from working conditions that could pose
danger to their health, safety or development. This includes restrictions on night work, any job function considered hazardous.
Standard Standard
III.A.06 Facility shall comply with any III.A.06.01 Legal limitations on the kinds of work young workers can
legal restriction on the working perform are followed.
conditions, hours of work, type of
work. for young workers (Such as III.A.06.02 Facility follows and enforces the special working conditions
no work at night, no jobs that are requirements for young workers. (e.g. special meal breaks).
considered particularly dangerous,
III.A.06.03 Facility enforces restrictions on working hours for young
such as handling chemicals or
workers.
operating heavy equipment, special
meal breaks, etc.). III.A.06.04 Young workers legal requirements are in full compliance.
III.A.07 Young Workers: Wages
Facility shall obtain necessary authorizations and pay the appropriate minimum wages, overtime and legally entitled bonuses. Facilities shall
follow legal exceptions to the minimum wage and any legally entitled bonuses and/or benefits of young workers.
Standard Standard
III.A.07 In some countries, there are special III.A.07.01 Wages and Benefits for young workers comply with local law.
exemptions to the minimum wage

for young workers. Facilities shall
obtain necessary authorizations
and pay the appropriate minimum
wages, overtime and legally entitled
bonuses. Facilities shall follow legal
exceptions to the minimum wage
and any legally entitled bonuses
and/or benefits of young workers.
III.A.08 Young Workers: Legal Approval

Facility shall obtain necessary legal approvals (permits/medical check-up records etc.) for all young workers.
Standard Standard
III.A.08 Facility shall obtain necessary III.A.08.01 Required legal approvals for young workers. Permits/medical
legal approvals (permits/ medical check-up records are available.
check-up records etc.) for all young
workers. III.A.08.02 Required legal approvals for young workers. Permits/medical
check-up records are in full compliance.

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III.A.09 Young Worker Monitoring
Facility shall have the required tracking system for all young/ juvenile workers (e.g. young worker register).
Standard Standard
III.A.09 In some countries, regulations III.A.09.01 Required register/list for young workers is available and
require a facility to maintain an complete.
updated list of juvenile workers and
register them with government III.A.09.02 Facility has submitted required register/list for young
authorities. Even if this isn’t workers to local labor authorities.
required in your country, a similar

III.A.09.03 Required register/list for young workers is in full compliance.
tracking system is useful for making
sure juvenile workers are always
employed in strict accordance with
laws governing their employment.
III.A.10 Young Worker Education

Facility shall comply with all education related Government programs.
Standard Standard
III.A.10 Facility encourages and allows III.A.10.01 Young workers are not prohibited or discouraged from
eligible workers, especially younger pursuing educational opportunities.
workers, to attend night classes and
participate in work-study programs
and other government-sponsored
educational programs.
III.B Labor Standards: Foreign Contract Labor
Facilities that recruit or employ foreign contract workers (FCW) 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 termi-
nate 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.
In addition to the requirements for all the other sections in this document, the following requirements apply to migrant and foreign contract workers.
III.B.01 Employment Contracts

Employment contract that is legally enforceable, clear, and written in the employee’s language, is executed with each worker in the worker’s home
country. Applicants have an opportunity to review or are guided through the provisions before signing and receiving a copy of the contract. Each appli-
cant receives a contract for employment (“Employment Contract”) and the terms and conditions of the contract do not contravene applicable laws or
the Foreign Contract Labor standards of this Code.
Standard Standard
III.B.01 Employment contracts signed III.B.01.01 Terms and conditions of the Frequently Asked Questions
in home country are legally employment contract are in Why are foreign contract workers more vulnerable to abuses of freely chosen
enforceable and meet the compliance with laws and/ employment and freedom of movement?
minimum requirements or FCW standards of Gap Inc.’s
Unlike domestic workers, the threat of deportation hangs over the heads of all foreign
of applicable laws and the COVC.
contract workers. Assessment of foreign contract labor issues should be handled with
requirements of this Code,
III.B.01.02 Employment contract or notices sensitivity to their special circumstances. Foreign contract workers tend to be less
and are written in a language
to workers are translated to vocal because of the high cost of losing their jobs.
that the foreign workers
understand. workers language. Are there any other requirements I need to follow for foreign contract workers?
Workers have been given the III.B.01.03 An employment contract is Yes. All requirements in this document are apply to foreign contract workers. Areas
opportunity to review or are signed in the worker’s home of particular attention include:
guided through the provisions country.
Discrimination
before signing and receiving a
copy of the Contract. III.B.01.04 FCW receive a copy of • Vendor must pay the same minimum wage to foreign contract workers in the
Employment Contract in his or same job category as local workers.
Each applicant receives the
her home country. • Vendor must provide the same terms and conditions to foreign contract workers
employment contract signed.
as local workers unless the local law requires differently.
• Females are not subject to pregnancy testing.
Freedom of Association
• Grievance systems must be accessible and responsive to foreign contract workers.
Employment contract in home Forced Labor

III.B.01.05
country is in full compliance. • Vendors may not withhold or deduct any “guarantee” money from workers’
wages.

• All wages must be paid directly to the workers
69
Housing
• Any vendor providing housing must comply with the dormitory requirements.
70
III.B.02 Employment Terms
Employment Contracts must be aligned with all requirements in this document and must specify: Worker’s name, passport details, detailed
address in home country and secondary contact (contact for emergencies); Type of work to be performed, job title, occupation category if appli-
cable, and location; Term (duration) of the contract; Minimum and overtime wage rates to be paid; bonuses, any indemnities or allowance to be
paid; Maximum allowable overtime hours consistent with the laws of the host country and Gap Inc. COVC; All benefits to be provided (including
medical coverage, sick leave, annual leave and holidays); All deductions to be taken (including charges for food and housing; Estimated minimum
net pay that the worker can expect per month; Summary of the living conditions; Detailed information on any Medical Testing that is required
by laws of workers’ home country or host country (Per Standard III.C.03, medical testing is prohibited except where required by law); Payments to
be received at the end of contract, including transportation (Per Standard III.B.10 & 11); and Terms of recourse for early contract termination with
and without reasonable notice by the employer or the employee with regards to payments due and travel expenses for repatriation.

Guidance/
Standard Standard FAQ/Best
Detail ID Standard Detail Sub-Detail ID Standard Sub-Detail Practices
III.B.02 Employment Contracts must be aligned with all requirements in this III.B.02.01 Employment contract specifies workers’ personal
document and must specify: information (name, passport details, address in
home country, and secondary emergency contact
• Worker’s name, passport details, detailed address in home country
information).
and secondary contact (contact for emergencies)
• Type of work to be performed, job title, occupation category if III.B.02.02 Employment contract specifies type of work to be
applicable, and location performed, job title, occupation category if applicable,
• Term (duration) of the contract and location.
• Minimum and overtime wage rates to be paid; bonuses, any
III.B.02.03 Employment contract specifies term (duration) of the
indemnities or allowance to be paid
contract.
• Maximum allowable overtime hours consistent with the laws of the
host country and Gap Inc. COVC III.B.02.04 Employment contract specifies minimum and
• All benefits to be provided (including medical coverage, sick leave, overtime wage rates to be paid.
annual leave and holidays)
III.B.02.05 Employment contract specifies maximum allowable
• All deductions to be taken (including charges for food and housing
overtime hours consistent with the laws of the host
• Estimated minimum net pay that the worker can expect per month country and Gap Inc. COVC (no more than 60 hours/
• Summary of the living conditions week on regularly scheduled basis).
• Detailed information on any Medical Testing that is required by
laws of workers’ home country or host country (Per Standard III.C.03, III.B.02.06 Employment contract specifies all benefits to be
medical testing is prohibited except where required by law) provided (including medical coverage, sick leave,
annual leave and holidays).
• Payments to be received at the end of contract, including
transportation (Per Standard III.B.10 & 11) Employment contract specifies all deductions to be
III.B.02.07
• Terms of recourse for early contract termination with and without taken (including charges for food and housing).
reasonable notice by the employer or the employee with regards to
payments due and travel expenses for repatriation. III.B.02.08 Employment contract specifies estimated minimum
net pay that the worker can expect to receive per
month.
III.B.02 Employment Terms
Employment Contracts must be aligned with all requirements in this document and must specify: Worker’s name, passport details, detailed
address in home country and secondary contact (contact for emergencies); Type of work to be performed, job title, occupation category if appli-
cable, and location; Term (duration) of the contract; Minimum and overtime wage rates to be paid; bonuses, any indemnities or allowance to be
paid; Maximum allowable overtime hours consistent with the laws of the host country and Gap Inc. COVC; All benefits to be provided (including
medical coverage, sick leave, annual leave and holidays); All deductions to be taken (including charges for food and housing; Estimated minimum
net pay that the worker can expect per month; Summary of the living conditions; Detailed information on any Medical Testing that is required
by laws of workers’ home country or host country (Per Standard III.C.03, medical testing is prohibited except where required by law); Payments to

be received at the end of contract, including transportation (Per Standard III.B.10 & 11); and Terms of recourse for early contract termination with
and without reasonable notice by the employer or the employee with regards to payments due and travel expenses for repatriation.
Guidance/
Standard Standard FAQ/Best
III.B.02 III.B.02.09 Employment contract specifies a summary of the

(CONT.) living conditions, including any curfews.
III.B.02.10 Employment contract specifies medical testing

required by laws of workers' home country or host
country.
III.B.02.11 Employment contract specifies means of

transportation for workers return to home country.
III.B.02.12 Return fee clause in employment contract is clear

and effectively reflect the full intent of Contract Labor
Requirements.
III.B.02.13 Employment contract specifies return fee to be

refunded.
III.B.02.14 Employment contract specifies terms of early

contract termination either by employer or the
employee, with and without reasonable notice,
including payments due, travel expenses for
repatriation.
III.B.02.15 Employment contract specifies recruitment fee

restrictions (if imposed by applicable host or home
country laws).
III.B.02.16 Employment contract is in compliance with all other

standards outlined in the Gap Inc. COVC.

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III.B.03 Host Country Employment Contract
Facility may not modify or impose any additional terms or requirements on the worker after the Employment Contract is signed unless expressly
required by law. Under no circumstances is contract substitution permitted. If receiving/host country law requires an additional contract be signed, it
must contain exactly the same content and provisions as that signed in the sending/home country.
Standard Standard
III.B.03 Where the law requires an III.B.03.01 Employment contract signed in home country is not
employment contract to be signed substituted with a contract signed in host country.
in the host country, no terms in the
contract shall be less favourable to III.B.03.02 Where it is not expressly required by law, facility does not

the FCW than those in the contract impose any additional terms or requirements on the worker
signed in the home country. after the Employment Contract is signed.
III.B.03.03 Where law requires an employment contract to be signed

in host country, the employment contract does not have
any new terms and condition that are less favourable to the
FCWs.
III.B.03.04 Where law requires an employment contract to be signed in

host country, the employment contract does not have any
new terms and condition that contravene applicable laws or
the standards of this Code.
III.B.04 Orientation Training
Orientation Training is provided for all foreign contract workers. Where possible, orientation training is provided in the home country prior to
departure. In all cases, Orientation Training must include the following and be in a language s/he understands: Employment terms and conditions;
Living conditions in the host country; Dormitory rules; Workplace conditions; Rights and responsibilities; Required job skills.
Standard Standard
III.B.04 Foreign workers are properly III.B.04.01 Where home country requires it, pre-departure training for

oriented on the working and FCWs is conducted.
living conditions. There are home
countries where pre-departure III.B.04.02 FCWs are oriented on the working and living conditions.
training is legally mandated. In
III.B.04.03 Orientation training for FCWs covers the following
such cases, FCWs at the facility
information:
have undergone such orientation
training. a) Employment terms and conditions
The pre-departure orientation shall b) Living conditions in the host country
be given in a language the foreign
c) Dormitory rules
workers understand.
d) Workplace condition
e) Rights and responsibilities
f) Required job skills.
III.B.04.04 Orientation trainings for FCWs is in a language workers

understand.

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III.B.05 Recruitment Agencies
Recruitment agencies are only used under the following conditions: A) The agency is licensed by the home country government, and where
applicable the host country government. B) A written contract exists between the facility and recruitment agency that clearly defines all hiring
practices. C) Recruitment agency discloses all the information regarding the use of any sub-contractors, sub-agents or any individual for recruiting
workers for the facility. D) 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.
Standard Standard
III.B.05 • Vendor must take all reasonable steps necessary to ensure that III.B.05.01 Facility employees or representatives do not Best Practice

it does business with reputable recruitment agencies which do accept reimbursements, kickbacks or other Wherever possible, the vendor
not charge workers fees in excess of what is legally permitted amounts from recruitment agency or other should avoid using recruitment
by any applicable law of the host or home country. person involved in the recruiting process. agencies altogether and
• Vendor must have a written agreement with the agency(ies) instead either transfer existing
III.B.05.02 The recruitment or employment agency
that clearly defines all hiring practices expressly requiring that workers from the vendors’
licensed by the home country government, and
total fees paid by the worker must not exceed any such legal home country facilities or hire
where applicable the host country government.
limits. workers directly.
• Vendors must put the terms and conditions stated in III.B.05.03 There is a written contract between the facility
employment contracts into practice and recruitment agency that clearly defines all
• Vendors must understand the legally allowable charges that hiring practices.
can be imposed by recruitment agents.
III.B.05.04 Facility's written agreement with the
• Vendors shall check with different recruitment agents to
agency(ies) expressly requires that total fees
compare their charges and only work with those in compliance
paid by the worker must not exceed legal limits
with law.
of the host or home country.
• Vendors shall clearly communicate to agents that over-charging
is strictly not allowed. III.B.05.05 The recruitment agency discloses all the
• Vendors shall cross check with workers to verify that information regarding the use of any sub-
recruitment agents do not over-charge under any contractors, sub-agents or any individual for
circumstances. recruiting workers for the facility.
• Vendors shall prepare a service agreement with the
recruitment agency to ensure all above conditions are included
and practiced.
III.B.06 Recruitment Agency Due Diligence
Facility has a mechanism to ensure that all third-party employment agencies (in sending and receiving countries, as applicable) recruit workers
ethically, and in compliance with relevant laws and the COVC.
Standard Standard Guidance/FAQ/Best

III.B.06 Upon starting a relationship with a new employment III.B.06.01 Facility conducts due diligence (prior to engaging the
agency, facilities shall conduct pre-selection due recruitment and employment agencies) on agencies'

diligence to ensure compliance with applicable laws compliance with applicable laws and with the Gap Inc. COVC.
and the COVC.
III.B.06.02 Facility conducts ongoing assessments (at least annually) of
Vendors/Facilities shall conduct ongoing assessment employment agencies on their compliance with applicable
(at least annually) of employment agencies to laws and Gap Inc. COVC requirements.
ensure compliance with applicable laws and COVC
requirements.
III.B.07 Host Country Fees

Facility pays 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 may not at any point deduct from wages, charge workers or otherwise accept
reimbursements to re-coup these fees. Facility or the recruitment agency does not collect from FCWs a deposit or bond or withhold part of FCWs’
earnings at any point of their employment. The facility prohibits recruitment agencies from charging FCWs illegal fees and fees payable to the host
government, such as levy, legal work document fees, and fees for renewing work documents.
Standard Standard Guidance/FAQ/

Detail ID Standard Detail Sub-Detail ID Standard Sub-Detail Best Practices
III.B.07 Facility pays all host country fees and III.B.07.01 Facility pays all host country fees and levies.
costs, including recruitment agency fees,
visa fees, and medical checks and any III.B.07.02 Facility pays all host country recruitment fees.
costs that are not the legal responsibility
of the worker. The facility may not III.B.07.03 Facility pays all host country renewal fees.
at any point deduct from wages,
III.B.07.04 Facility pays all other applicable host country fees and costs.
charge workers or otherwise accept
reimbursement to re-coup these fees. Facility reimburses host country fees paid by existing workers.
III.B.07.05
FCWs are not charged recruitment fees
payable to the home government which III.B.07.06 Agencies are not charging workers fees in excess of what is legally permitted by
the FCWs are not legally responsible for. applicable law of the host or home country.
III.B.07.07 Facility complies with any other rules applicable related to recruitment agency fees.

III.B.07.08 Facility is not charging back or accepting reimbursement from foreign contract worker to
recover fees paid in the recruitment or hiring process.
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III.B.07.09 Facility complies with any other applicable rules related to vendor fees and deductions.
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III.B.08 Control of Earnings
Vendor must allow workers full and complete control over the monies they earn and must not withhold any “guarantee money” or recruitment fee
sums from pay otherwise due to foreign contract workers.

III.B.08 Vendor must allow workers full and III.B.08.01 Facility allows workers full and complete control over the monies they earn.
complete control over the monies they
earn (as required in Gap Inc.’s COVC) III.B.08.02 Facility does not withhold “guarantee money” or recruitment fee sums from pay due to
and must not withhold any “guarantee foreign contract workers.
money” or recruitment fee sums from

III.B.08.03 Facility complies with any other applicable rules related to control of earnings.
pay otherwise due to foreign contract
workers.
III.B.08.04 Facility is not involved in agency deductions for recruitments fees.
III.B.08.05 Agents do not collect recruitment fees by agents at facility premises/dormitory.
III.B.09 Recruitment Fee Chargeback

Facility pays all fees and costs payable to the FCWs’ home government for the documentation of their deployment to the host country, including re-
cruitment agency fees, visa fees, and medical checks and any costs, that are not the legal responsibility of the worker. The facility may not at any point
deduct from wages, charge workers or otherwise accept reimbursement to re-coup these fees. FCWs are not charged recruitment fees payable to the
home government which the FCWs are not legally responsible for.

III.B.09 Facility or the recruitment agency that III.B.09.01 Facility does not collect from and charge back to FCWs the fees payable to home
the facility works with for its FCWs government for the documentation of their deployment to and employment in the host
does not collect from or charges back country, including recruitment agency fees, visa fees, and medical checks and any costs,
to FCWs the fees payable to home that are not the legal responsibility of the worker.
government for the documentation of
their deployment to and employment in III.B.09.02 Recruitment agency that the facility works with for its FCWs does not collect from and
the host country, including recruitment charge back to FCWs the fees payable to home government for the documentation of
agency fees, visa fees, and medical their deployment to and employment in the host country, including recruitment agency
checks and any costs, that are not the fees, visa fees, and medical checks and any costs, that are not the legal responsibility of
legal responsibility of the worker. the worker.
III.B.10 Foreign Contract Worker Transportation
Facility arranges and pays for all of the worker’s airfare and/or other reasonable transportation costs back to the workers home country at the end
of the contract term or if the contract is terminated by the facility. In cases where the worker wishes to leave the facility prior to the end of contract
for any reason, the travel costs shall be paid on a pro-rata basis, as agreed in the contract. The facility may not at any point deduct from wages, charge
workers or otherwise accept reimbursement to re-coup these fees.
Standard Standard

III.B.10 Facility arranges and/or pays for III.B.10.01 Facility arranges and/or pays for the FCWs’ airfare and/or
the FCWs' airfare and/or other other reasonable transportation costs to return home, for
reasonable transportation costs to those who have completed their employment contract.
return home upon completion of
contract. III.B.10.02 Travel costs payable to FCWs who end their employment
prior to the end of the contract or who are terminated by
Travel costs payable to FCWs who facility are in accordance with the employment served by
ends employment prior to the end FCW and not lower.
of contract or who are terminated
by facility are proportionate to the
employment served by FCW.

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III.B.11 Final Payment and Return Fee
At the end of the worker contract, workers are paid and receive all settlement owed to them, including last-salary payments, return fee (if applicable),
end of service bonus, and any annual leave days owed to the worker.
Standard Standard
III.B.11 All last-wages worked for and III.B.11.01 Last-wages worked for and accrued Guidance
accrued convertible-to-cash benefits, convertible-to-cash benefits, including The return fee will equal the estimated average recruitment fees
including leave credits owed to the leave credits owed to the foreign incurred by workers in their home country (as determined from time to
foreign workers, are paid to the workers, are paid to the foreign time by Gap Inc. in consultation with workers, vendors, local NGOs and
foreign workers who complete the workers who complete the contract. government authorities as appropriate), less a pro rata portion based

contract. on the actual duration of stay vs. the contractual term. For example, if
III.B.11.02 Return fee policy is available.
Facilities shall have a written the estimated average recruitment fees incurred by any worker from
Return Fee policy. The policy shall Country A to secure employment in Country B are $2,000, such a worker
III.B.11.03 Return fee policy is effectively
be effectively implemented and who entered into a two year contract but decided to return home after
implemented.
communicated. 6 months would receive a Return Fee of $1,500 ($2,000 – 6/24).
III.B.11.04 Return fee policy is effectively Best Practice
Facility bears the applicable "Return
communicated.
Fee" at the end of the foreign To improve worker-management communication and ensure that an
workers' contract. Return fee policy functions in full effective grievance system is in place, facilities are encouraged to have
III.B.11.05
compliance. an onsite Foreign Contract Worker Coordinator or management team
that is fluent in the language of the workers and management.
III.B.11.06 Facility pays FCW "Return Fee".
III.B.11.07 Facility pays FCW "Return Fee"

contemporaneously with worker's
return to the home country.
III.B.12 New Facilities—Foreign Contract Labor Requirements
For all existing contract workers that paid home country fees, recruitment fees or host country fees prior to facility’s approval by Gap Inc., the facility
must: A) Pay to the worker a “Return Fee” in addition to any wages, benefits or other amounts due and owing to the worker at the time of his/her
return to the home country based on the completion of their contract. B) Reimburse any host country fees paid by existing workers. C) Provide written
communication to the worker with the amount of the Return Fee and conditions of payment.


III.B.12 For all existing contract workers that paid home III.B.12.01 Facility pays to the existing contract workers that paid home
country fees, recruitment fees or host country fees country fees, recruitment fees or host country fees prior to
prior to facility’s approval by Gap Inc., the facility facility’s approval by Gap Inc. a “Return Fee.”
must:
III.B.12.02 Facility pays to the existing contract workers that paid home
• Pay to the worker a “Return Fee” in addition to country fees, recruitment fees or host country fees prior to
any wages, benefits or other amounts due and facility’s approval by Gap Inc. any wages, benefits or other
owing to the worker at the time of his/her return amounts due and owing to the worker at the time of his/
to the home country based on the completion of her return to the home country upon the completion of their
their contract. contract.
• Reimburse any host country fees paid by existing
workers. III.B.12.03 FCWs who had paid home-country fees, recruitment fees, or
• Provide written communication to the worker host-country fees prior to Gap Inc.'s approval of the facility
with the amount of the Return Fee and conditions are provided written communication of the return fee and
of payment. conditions of payment.

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III.B.13 Control of Passports
Facility allows the worker full control over his or her identity papers, passports or similar documentation and provides the worker with a locked and
secure storage space in which to keep this documentation.
Standard Standard
III.B.13 Facility allows the worker III.B.13.01 Facility allows workers full control over his or Guidance
full control over his or her her passport and similar documentation. Many employers of foreign migrant labor argue that they need to hold
identity papers, passports or passports for local administrative practices. Since workers are often
similar documentation and III.B.13.02 Control of passport is not a condition of
issued visas under sponsorship of employers, they claim that it is the
provides the worker with a employment.
employers that are held responsible for the actions of the worker.

locked and secure storage
III.B.13.03 Foreign contract workers' travel and work They also argue that they need to hold passports to ensure that they
space in which to keep this
documents, such as passport and work are able to renew work and residence permits on time since, as they
documentation.
permit, are not held beyond the period claim, the government and workers will hold them responsible for
needed for processing those documents. any fines in this regard. Regardless of the validity of these claims, the
burden of risk for employing foreign workers rests with the employer
III.B.13.04 Facility provides workers with a locked and cannot be placed upon the workers themselves. For this reason,
and secure storage space in which to keep employers must not hold worker passports or working papers, beyond
passports or similar documentation. the minimum amount of time needed for processing, and must provide
a secure locker to each worker for the storage of these important
III.B.13.05 FCWs have individual lockers.
documents. Getting permission from the workers, even if written, to
III.B.13.06 Facility complies with any other requirement store documents for them is not a consistently credible mechanism to
related to control of passport. ensure freedom of movement and security of employee owned travel
and work documents.
III.B.14 Foreign Contract Worker Discrimination

Facility does not engage in discriminatory practices against foreign contract workers on the basis of their status as FCW. FCWs are given equal treat-
ment as the local workers, having equal access to opportunities to working conditions, such as wages and benefits, as legally permissible as possible.
Standard Standard
III.B.14 FCWs shall be entitled to the same working III.B.14.01 Facility pays the same minimum wage to FCWs in the same
conditions as the local workers in the same job job category as local workers.
class or skill level and as far as legally permissible.
III.B.14.02 Facility complies with any other requirement related to same
minimum wage.
III.B.14.03 FCWs do not receive less favorable working conditions

compared to the local workers.
III.B.14.04 Facility's policies are not discriminatory against FCWs.

III.B.15 Documentation
Recruitment and employment of foreign contract workers complies with applicable laws. FCWs have the proper legal documents as to their stay and
employment in the host country.
Standard Standard
III.B.15 FCWs have valid travel or work III.B.15.01 FCWs have up to date and valid travel or work documents,
documents, including work permit. including work permits.

III.B.15.02 Recruitment and employment of foreign contract workers
complies with other applicable laws.
III.B.16 Foreign Contract Worker List

Facility maintains and updates relevant documentation of its FCWs, including a register of FCWs/FCW roster with details on contract dates, validity of
work permit, passports, etc.
Standard Standard
III.B.16 Vendor must make available to III.B.16.01 Facility provides a current list of all foreign contract workers
Gap Inc. or its representatives upon employed by the facility.
request current lists of all foreign
contract workers employed at each III.B.16.02 Current list of all foreign contract workers employed includes
facility. date of arrival.
Workers’ list shall include the date III.B.16.03 Current list of all foreign contract workers employed includes
of arrival, contract term, anticipated contract term.
date of return, etc.
III.B.16.04 Current list of all foreign contract workers employed includes
anticipated date of return.
III.B.16.05 Current list of all foreign contract workers employed includes

validity period of work or travel documents.
III.B.16.06 Facility complies with any other requirement related to

provision of worker lists.
III.B.16.07 Facility complies with any other requirements applicable for

FCWs.

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III.C Labor Standards: Discrimination
Facilities shall employ workers on the basis of their ability to do the job, not on the basis of their personal characteristics or beliefs.
III.C.01 Discriminatory Employment Practices

Facility hires, promotes, pays wages and benefits, terminates and provides access to trainings without regard to race, color, gender, nationality,
religion, age, maternity, marital status, indigenous status or ethnicity, social origin, disability, sexual orientation, HIV/AIDS status, or membership in
workers organizations including unions or political affiliation. Hiring, promotion and other human resource decisions shall be made on the workers’
qualifications, skills, ability, productivity and overall job performance. Vendors shall comply with applicable wage and hour labor laws and regulations
governing worker compensation and working hours. Workers with the same qualifications, skills, experience and performance shall receive equal pay
for equal work in accordance with applicable labor laws.

Standard Standard
III.C.01 Facility hires, promotes, pays III.C.01.01 Facility does not engage in or support discrimination Frequently Asked Questions
wages and benefits, terminates during hiring, compensation, access to training, A supplier implemented a policy that requires job
and provides access to trainings promotion, termination or retirement based on race/ candidates and current workers to be tested for
without regard to race, color, gender, color/gender/nationality/religion/ age/maternity/ Hepatitis B. The supplier said they were doing this
nationality, religion, age, maternity, marital status/indigenous status or ethnicity/ social to protect other workers from catching the disease.
marital status, indigenous status origin/ disability/ sexual orientation/HIV/AIDS status or Is this acceptable?
or ethnicity, social origin, disability, membership in workers organizations including unions or
This is not acceptable. The use of medical
sexual orientation, HIV/AIDS political affiliation.
examinations to prevent a worker from being
status, or membership in workers
hired, or firing a worker who becomes ill, injured,
organizations including unions
or pregnant, is not allowed as per Gap Inc.’s COVC.
or political affiliation. Hiring,
However, an employer can conduct legal medical
promotion and other human
tests post-employment and take necessary
resource decisions shall be made on
precautions to protect other workers.
the workers’ qualifications, skills,
ability, productivity and overall job
performance.
III.C.02 Discrimination: Recruitment process
Hiring notices and job descriptions do not specify discriminatory factors, such as gender, age, or race.

III.C.02 Job advertisements and job descriptions shall not specify III.C.02.01 Facility does not have discriminatory job descriptions and/or
a particular race, color, gender, nationality, religion, age, job postings.
maternity, marital status, indigenous status, social origin,

disability, sexual orientation, HIV/AIDS status, membership in III.C.02.02 Facility's job application forms do not require information
workers’ organizations including unions, or political affiliation (e.g. caste, religion, union membership etc.) that may be used
for a particular job – except those limitations required by law. for discriminatory employment practices.
Job applicants shall not be asked about race, color, gender, III.C.02.03 During job interviews workers are not asked questions
nationality, religion, age, maternity, marital status, indigenous related to pregnancy status, union/political affiliations, HIV/
status, social origin, disability, sexual orientation, HIV/ AIDS AIDS status, etc., which may be used for discriminatory
status, membership in workers’ organizations including purposes.
unions, or political affiliation unless required by law (such as
screening for underage workers).
III.C.03 Discriminatory Medical Examinations

The use of medical examinations, such as pregnancy or HIV/AIDS tests, to prevent a worker from being hired is prohibited. Medical tests, if required
by law, shall comply with its requirements and shall not be used in a discriminatory manner.

III.C.03 The use of medical examinations, such as pregnancy or HIV/ III.C.03.01 Facility does not require workers to undergo medical
AIDS tests, to prevent a worker from being hired is prohibited. tests such as pregnancy or HIV/AIDS, which may be used
Medical tests, if required by law, shall comply with its for discriminatory purposes (decision of not hiring or
requirements and shall not be used in a discriminatory termination).
manner.
III.C.03.02 Only legally required tests are conducted and results are used
in compliance with laws.

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III.C.04 Discrimination: Pregnancy and Maternity
Pregnancy shall not be used as a basis for discriminatory practices like termination/demotion/pay cuts etc.
Standard Standard
III.C.04 Workers are not forced or pressured III.C.04.01 Facility does not force women workers to use contraception Frequently Asked Questions
to use contraception. during their employment period. What if pregnancy testing is legal under the local
Workers shall not be dismissed law?
III.C.04.02 Facility does not dismiss workers or force workers to resign
because of their pregnancy status, because of their pregnancy status. Gap Inc. prohibits discrimination and this practice
whether discovered through is a clear violation of our Code of Vendor Conduct.

pregnancy testing or other means. III.C.04.03 Facility does not demote or reduce pay for workers because Regardless of whether the law allows pregnancy
of their pregnancy status. testing or not, the purpose of our requirement is
Workers returning from maternity
shall not be demoted to a lower to ensure that results of such tests are not used to
III.C.04.04 Workers returning from maternity are assigned to jobs that prejudice an applicant’s employment in anyway.
grade
are of the same or a higher grade than the one they were in Pregnancy testing includes, but is not limited to,
before going on maternity leave. blood or urine tests or interviewing performed for
III.C.05 Religious Observances

Religious observance, prayer breaks and religious holidays are not prohibited.
Standard Standard
III.C.05 Religious observance, prayer breaks III.C.05.01 Religious observance, prayer breaks and religious holidays
and religious holidays shall not be are provided to workers.
prohibited.
III.D Labor Standards: Forced Labor

Facility shall not use involuntary labor of any kind, including prison labor, debt bondage, slave labor or forced labor by governments.
III.D.01 Forced Labor

Facility shall not use involuntary labor of any kind, including prison labor, debt bondage, slave labor or forced labor by governments.
Standard Standard
III.D.01 Facility shall not use involuntary III.D.01.01 Facility does not use any form of involuntary labor,
labor of any kind, including prison prison labor, debt bondage, slave labor, or forced labor by

labor, debt bondage, slave labor or governments.
forced labor by governments.
III.D.01.02 Workers' contracts do not contain provisions that place illegal
Terms of employment shall be those or unreasonable restrictions on the movement of workers or
to which the worker has voluntarily prevent workers from terminating their employment.
agreed.
III.D.02 Free Egress

If facility entrances are guarded for security reasons, workers shall have free egress at all times.
Standard Standard
III.D.02 If facility entrances are guarded for III.D.02.01 Facility provides free egress to workers at all times.
security reasons, workers shall have
free egress at all times
III.D.03 Restrictions to Voluntarily Ending Employment

Facilities do not employ tactics to prevent workers from leaving at will, such as withholding salary as a “year-end bonus” or charging a penalty when
workers terminate their contract, or by withholding any personal identification documents such as ID and passports
Standard Standard
III.D.03 Any restrictions for workers to III.D.03.01 Facility does not place restrictions for workers to voluntarily
voluntarily end their employment, end their employment, such as withholding salary as a “year-
such as, excessive notice periods, end bonus” or charging a penalty when workers terminate
with-holding original personal their contract, or by withholding any personal identification
identification documents or documents such as ID and passports.
substantial fines for terminating
their employment contracts, are

prohibited.
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III.D.04 Restrictions on Worker Movement
Beyond reasonable restrictions, workers can move freely within the facility to use the toilets, drink water, and take designated breaks. Workers
may leave the facility at the end of their shift or before the end of their shift under extenuating circumstances, such as personal leave or family
emergencies or illness, without fear of reprisal, disciplinary action, discrimination or termination.
Standard Standard
III.D.04 Facility shall not place unreasonable III.D.04.01 Facility does not place unreasonable restrictions on worker
restrictions on worker movement movement within facility (e.g. to use the toilets, drink water,
within facility (e.g. to use the toilets, and take designated breaks).
drink water, and take designated

breaks)
III.D.05 Worker Time Off Due to Emergencies

Workers shall be allowed to leave freely at the end of the shift or during shift under extenuating circumstances like illness or family emergencies.
Standard Standard
III.D.05 Workers shall be allowed to leave III.D.05.01 Workers are allowed to leave freely at the end of the shift or
freely at the end of the shift or during the shift under extenuating circumstances such as
during shift under extenuating illness or family emergencies.
circumstances like illness or family
emergencies
III.E Labor Standards: Freedom of Association
Workers are free to join associations of their own choosing. Facilities shall not interfere with workers who wish to lawfully and peacefully associate, organize or
bargain collectively. The decision whether or not to do so shall be made solely by the workers.
III.E.01 FOA: Compliance with Applicable Laws

Workers are free to choose whether or not to lawfully organize and join associations. If freedom of association and/or collective bargaining are re-
stricted by law, workers shall be free to develop parallel means for independent and free association and collective bargaining.

Standard Standard
III.E.01 Facility operates in full compliance with all III.E.01.01 Facility complies with all national laws and Frequently Asked Questions
applicable laws, rules and regulations concerning regulations concerning FOA and Collective Can foreign contract workers legally join unions?
freedom of association and the right of collective Bargaining.
It depends on the country. The ILO Convention
bargaining.
III.E.01.02 Facility allows workers to freely choose on Migrant Workers (ILO Convention 97) provides
Workers, without distinction whatsoever, shall whether or not to lawfully organize and join for this right. However, some countries have
have the right to establish and, subject only to associations. not ratified these conventions and/have not yet
the rules of the organization concerned, to join aligned their laws to convention. In such cases, we
organizations of their own choosing without III.E.01.03 Facility does not interfere with workers’ cannot force, pressure or incentivize our supply
previous authorization. organizations in any sense, including through chain partners to be out of compliance with local
acts which are designed to establish or law.
Employers shall refrain from any acts of
promote the domination, financing or control
interference with workers’ organizations, Independent Unions do not exist in my country;
of such organizations.
including acts which are designed to establish or therefore we may not be able to legally comply
promote the domination, financing or control of with workers choice of unions. Does this mean we
III.E.01.04 Workers are free to develop parallel means
workers’ organizations by employers. are not incompliance with the Gap Inc. COVC?
for independent and free association and
If freedom of association and the right to collective bargaining. No. Nothing in the COVC requires you to break the
collective bargaining is restricted by law, laws of your own country. However, in the event
workers are free to develop parallel means for that independent unions are not available, we
independent and free association and collective would encourage you to facilitate the formation
bargaining. of less formal worker committees in order to
build stronger worker relationship between
management and workers.

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III.E.02 Threats to Freedom of Association
Facility shall not threaten, penalize, restrict or interfere with workers lawful efforts to join associations of their choosing, carry out their union
activities including union meetings, demonstrations and lawful strikes.
Standard Standard
III.E.02 Workers shall be free from intimidation by III.E.02.01 Facility does not threaten, penalize, restrict
management to join an association and free from or interfere with workers’ efforts to organize,
management interference in the peaceful and join unions, bargain collectively or participate
lawful exercise of their right to organize and join in union's lawful activities like meetings,
associations. assembly, demonstrations, strikes etc. by

means of threat of transfer, dismissal, no
Employers shall not in any way use violence
opportunity to earn overtime/bonuses/
against, threaten, intimidate, harass or abuse
advancement etc.
workers seeking to form or join workers’
organizations or workers participating or Facility does not use violence against workers
III.E.02.02
intending to participate in union activities, seeking to form or join workers’ organizations
including strikes. or workers participating or intending to
Where local law or a collective bargaining participate in union activities, including
agreement allows attendance at association strikes.
meetings, workers shall not be restricted or
III.E.02.03 Facility does not threaten the use of police
penalized from attending such meetings.
or military personnel to prevent, disrupt or
The employer shall not in any way threaten the break up activities that constitute a peaceful
use of or use the presence of police or military, exercise of the right to freedom of association
to prevent, disrupt or break up any activities (including union meetings, assemblies and
that constitute a peaceful exercise of the right to strikes).
freedom of association, including union meetings,
assemblies and strikes. III.E.02.04 Facility does not use the presence of police
or military personnel to prevent, disrupt or
Workers shall not be terminated, transferred,
break up activities that constitute a peaceful
demoted, and denied advancement or
exercise of the right to freedom of association
opportunities to earn bonuses, or work overtime
(including union meetings, assemblies and
if they try to legally organize an association or
strikes).
bargain collectively.
Employers shall not threaten to, or shift III.E.02.05 Facility reinstates workers that were unjustly
production or close a facility in an attempt to dismissed due to their union activity, as
prevent the formation of a union, in reaction to required by local law.
the formation of a union, in reaction to any other
III.E.02.06 Facility is willing to restore workers' rights and
legitimate exercise of the right to freedom of
privileges lost due to their union activity, as
association and collective bargaining, including
required by local law.
the right to strike, or in an effort to break up a
union.
III.E.02 Threats to Freedom of Association
Facility shall not threaten, penalize, restrict or interfere with workers lawful efforts to join associations of their choosing, carry out their union
activities including union meetings, demonstrations and lawful strikes.
Standard Standard
III.E.02 (cont) III.E.02.07 Facility respects the laws, rules and procedures
(CONT) protecting the rights of workers to participate
Employers shall not offer or use severance pay in

in strikes consistent with ILO principles and
any form or under any other name as a means of
jurisprudence.
contravening the right to freedom of association,
including attempts to prevent or restrict union Facility does not threaten to shift production
III.E.02.08
formation or union activity, including strikes. or close the facility in an attempt to prevent
the formation of a union, in reaction to the
formation of a union, in reaction to any other
Workers who have been unjustly dismissed,
legitimate exercise of the right to freedom
demoted or otherwise suffered a loss of rights
of association and collective bargaining,
and privileges at work due to an act of union-
including the right to strike, or in an effort to
discrimination shall, subject to local laws, be
break up a union.
entitled to restoration of all the rights and
privileges lost, including reinstatement, if they so III.E.02.09 Facility does not offer severance pay as a
desire. means of contravening the right to freedom of
association, including attempting to prevent
or restrict union formation or union activity,
including strikes.
III.E.02.10 Facility does not impose sanctions on workers

organizing or having participated in a legal
strike.

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III.E.03 Collective Bargaining
Workers have the right to negotiate a collective bargaining agreement. If a collective bargaining agreement exists, facility complies with all contractual
provisions.

III.E.03 Employers shall bargain with any union that has III.E.03.01 Facility recognizes the rights of workers to free and voluntary collective
been recognized by law or by agreement between bargaining.
the employer and that union, provided such
agreement does not contravene local law, as a – or III.E.03.02 Facility honours the terms of the collective bargaining agreement they
the exclusive – bargaining agent for some or all of have agreed to and signed.

its workers
III.E.03.03 Facility bargains with the legally recognized union.
Employers, unions and workers shall honour, for the
term of the agreement, the terms of any collective III.E.03.04 Facility bargains with the union as per the agreement between facility
bargaining agreement they have agreed to and and union.
signed.
III.E.03.05 Collective bargaining agreement is negotiated freely, voluntarily and in
Collective bargaining agreements that have not good faith.
been negotiated freely, voluntarily and in good faith
shall be considered not applicable. III.E.03.06 Collective bargaining agreement does not contain provisions that
contradict national laws, rules and procedures.
Provisions in collective bargaining agreements that
contradict national laws, rules and procedures or III.E.03.07 Collective bargaining agreement offers protection to workers that are
offer less protection to workers than provisions equal to or greater than provisions in the Gap Inc. COVC.
of Gap Inc’s COVC shall also be considered not
applicable.
III.E.04 Deducting Union Membership Fees
Facility does not deduct union membership dues, fees, or fines from workers’ wages without the express and written consent of the individual, unless
otherwise specified in a freely negotiated and valid collective bargaining agreement or when required by law.
Standard Standard
III.E.04 Employers cannot deduct union III.E.04.01 Facility does not deduct union membership fees or any other
membership fees or any other union union fees from workers’ wages without the express and

fees from workers’ wages without written consent of individual workers.
the express and written consent of
individual workers, unless specified
otherwise in freely negotiated
and valid collective bargaining
agreements.
III.E.05 Interference with Association Process

Workers have the right to elect leaders and representatives of their unions without management interference.
Standard Standard
III.E.05 Employers shall not interfere with III.E.05.01 Facility does not interfere with the right of workers to draw
the right of workers to draw up their up their constitutions and rules, to elect their representatives
constitutions and rules, to elect their in full freedom, to organize their administration and
representatives in full freedom, to activities and to formulate their programs.
organize their administration and
activities and to formulate their
programs.

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III.E.06 Special Protection to Workers
Worker representatives are not discriminated against and have regular access to company management in order to address grievances and other
issues.
Standard Standard
III.E.06 Employers shall comply with all III.E.06.01 Facility complies with local laws that provide special
relevant provisions where local protection to workers or worker representatives engaged
laws provide special protection to in a particular union activity (such as union formation) or
workers or worker representatives to worker representatives with a particular status (such as
engaged in a particular union union founding members or current union office holders).

activity (such as union formation)
or to worker representatives with
a particular status (such as union
founding members or current union
office holders).
III.E.07 Access to Facilities

Facility shall not prohibit representatives of the trade union from interacting with workers so long as the terms of the engagement meet the conditions
established by the law or mutual agreement between the facility and the union.
Standard Standard
III.E.07 If required by law, workers’ III.E.07.01 Workers’ representatives have the facilities necessary for
representatives shall have the the proper exercise of their functions, including access to
facilities necessary for the proper workplaces as required by local law.
exercise of their functions, including
access to workplaces.
III.E.08 Freedom to Choose Organizations
Where more than one union exists within a facility, facility shall not interfere and shall not favor one union over another.
Standard Standard
III.E.08 Workers shall be free to choose III.E.08.01 Facility allows workers to freely choose which association to
which organizations to join and join.
shall not be forced to join one

particular organization rather than III.E.08.02 Trade unions not recognized as a bargaining agent of some
another unless required by law and or all of the workers in the facility, have the means for
that requirement is clearly stated defending the occupational interests of their members. (This
and explained to the worker prior to would include making representations on their behalf and
employment. representing them in cases of individual grievances, within
limits established by applicable law).
Employers shall not interfere with
the right to freedom of association III.E.08.03 Facility does not interfere with the right to freedom of
by favouring one workers’ association by favouring one workers’ organization over
organization over another. another.
Trade unions not recognized as a
bargaining agent of some or all
of the workers in a facility shall
have the means for defending
the occupational interests of
their members, including making
representations on their behalf
and representing them in cases of
individual grievances, within limits
established by applicable law.

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III.F Labor Standards: Humane Treatment and Disciplinary Practices
Facilities shall treat all workers with respect and dignity. Facilities shall not use corporal punishment or any other form of physical or psychological coercion.
III.F.01 Physical Abuse

Facility shall not use physical corporal punishment, force that causes bodily harm or pain, or other forms of physical contact to punish or coerce
workers.
Standard Standard
III.F.01 Facility must not engage in or III.F.01.01 Facility does not engage in or permit physical abuse to
permit physical abuse, use of force punish or coerce their workers.

that causes bodily harm or pain,
or other forms of physical contact, III.F.01.02 Facility does not permit or engage in coercive physical
including slaps, pushes, no matter contact, such as slaps, shoving, or throwing of objects at
how slight, to punish or coerce their workers.
workers.
III.F.01.03 Facility does not engage in any other form of physical abuse.
III.F.02 Verbal/Sexual Abuse
Facility shall not engage in or permit psychological coercion or any other form of non-physical abuse, including threats of violence, sexual harassment,
screaming or other verbal abuse. Discipline shall not subject workers to humiliating or degrading conditions.
Standard Standard
III.F.02 Facility must not engage in or III.F.02.01 Facility does not engage in or permit screaming or verbal Frequently Asked Questions
permit any form of verbal abuse. abuse when addressing productivity or disciplinary concerns As a general facility manager, how can I prevent

with employees. sexual harassment in the workplace?
Facility must not engage in or
permit unwelcome physical contact Facility does not engage in or permit threats of violence to First, it’s important to formally condemn and
III.F.02.02
or spoken words of sexual nature, punish or coerce their workers. prohibit sexual harassment by informing workers
unwelcome conduct that creates an that any form of sexual harassment and abuse by
intimidating or humiliating work III.F.02.03 Facility does not engage in or permit unwelcome anyone (including all management)is not accepted
environment. conduct that creates an intimidating or humiliating work in the workplace. Workers should be assured that
environment. such practices warrants strong disciplinary action,
Employers shall not offer
preferential work assignments or including possible legal action and that worker
III.F.02.04 Facility does not engage in or permit unwelcome physical safety and comfort is a top priority. In addition, it’s
other preferential treatment of any
contact of a sexual nature. important and helpful to create and communicate
kind in actual or implied exchange
for a sexual relationship, nor subject sexual abuse response procedures within the
III.F.02.05 Facility does not engage in or permit unwelcome spoken
employees to prejudicial treatment grievance system, using a trained female staff
words of a sexual nature.
of any kind in retaliation for refused member.
sexual advances. III.F.02.06 Preferential work assignments or other preferential Line/Production supervisor uses words like
treatment is not practiced or implied in exchange for a ‘donkey’, ‘idiot’, or ‘stupid’ to address and correct
sexual relationship or workers are not subject to prejudicial workers who make mistakes. The Supervisor insists
treatment in retaliation for refused sexual advances. this is not abuse, as this is accepted culturally, and
workers are used to being addressed with such
III.F.02.07 Facility does not engage in any other form of verbal or sexual
words.
abuse.
Even when common in a particular country, any
language that is abusive, demeaning or insulting
is a clear violation of Gap Inc.’s code standards.
Such behaviour should be immediately addressed
through trainings and/or disciplinary action to
ensure a more harmonious working environment
where workers are treated with respect and
dignity.

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III.F.03 Disciplinary Actions
Facility has a policy that clarifies and standardizes discipline. Disciplinary actions and processes consist of an escalating series of actions, starting with
warnings, followed by disciplinary actions (e.g. from verbal warning, written notice, to suspension and termination). The facility maintains written re-
cords of disciplinary actions taken. Discipline, either in policy or in practice, meets applicable laws and requirements of this Code. Workers are formally
communicated the rules and disciplinary processes at the time of hire.
Standard Standard
III.F.03 Facility shall have disciplinary policy III.F.03.01 Facility has a written and formal disciplinary policy and
and procedures within the confines procedures.
of the law and the requirements

of this code. The policy shall be III.F.03.02 Disciplinary policy or practices is aligned with relevant laws
formally communicated to workers and/or the requirements of Gap Inc.’s COVC.
at the time of hire.
III.F.03.03 Facility maintains records of disciplinary actions.
Disciplinary process leading up to
suspension or dismissal includes III.F.03.04 Workers who are subject to suspension or dismissal are
a series of verbal warnings and notified.
written notice to worker. Exception
to the escalating series of warnings III.F.03.05 Disciplinary practices follow facility's official policy on
may apply when the misconduct discipline.
is of serious nature, such as wilful
III.F.03.06 Disciplinary practices must not include monetary fines.
misconduct that causes harm to life
and property. Where it is legally III.F.03.07 Facility does not restrict or privilege workers’ access to food,
permissible or except when it is water, toilets, medical care, health clinics or other basic
unreasonable to do so, disciplinary necessities, as either punishment or reward, respectively.
action on conduct subject to
suspension or dismissal, in policy III.F.03.08 There is an escalating series of warnings given to workers
or in practice, provides for an prior to suspension or dismissal, in policy or in practice.
opportunity for worker to be heard.
III.F.03.09 Facility provides to a worker who is subject to suspension or
Disciplinary practices must be dismissal for an opportunity to be heard.
consistent and applied fairly among
all workers. III.F.03.10 Workers are formally communicated the rules and
Facility must not use the access disciplinary procedures at the time of hire and regularly
to food, water, toilets, medical thereafter.
care, health clinics or other basic
necessities, as either reward or
punishment.
Disciplinary practices must not
include monetary fines.
III.F.04 Grievance Channels and Retaliation
Workers have means to report grievances to management, including a channel that provides for confidentiality and anonymity. Workers can also bring
to management’s attention grievances through means other than their immediate supervisor. The grievance system includes addressing grievances in
a timely manner and documenting grievances and management action on grievances. Facility also provides for a system for addressing disputes in the
workplace, whether between co-workers or between workers and supervisor or manager. Such grievance channels and mechanisms for resolving dis-
putes and grievances provide for protection from retaliation.
Standard Standard

III.F.04 Confidentiality of information III.F.04.01 Facility has a grievance procedure or Best Practices
shared by workers through the system. The benefits of grievance systems:
grievance channels is such that
III.F.04.02 Facility grievance channel provides for • Effective grievance mechanisms can play an important role in
workers are protected from
confidentiality. identifying, preventing and remediating issues of concern on
retaliation and allows free flow
the facility floor. Facility-level grievance mechanisms can help
of information. Documenting
III.F.04.03 Grievance policy and procedures are support workers’ ability to raise concerns and seek remedy in
grievances and communicating
implemented. the workplace. Then can also enable facility management to
management response to those
understand and address those issues before they escalate into
grievances are also key to promote III.F.04.04 Grievance procedure/system provides something very disruptive.
effectiveness and build workers’ for resolving disputes in the workplace,
trust of the grievance system. How to ensure you are actually learning about workers’ grievances:
whether between co-workers or
Facility must not retaliate against between workers and supervisors. • Implement a Help Line as another method for workers to
workers who bring up grievances in confidentially voice concerns. Issues identified through the Help
III.F.04.05 Grievances or management's response Line should go before the grievance/communication committee
the form of threats, intimidation, or
to grievances are documented. as well.
other disciplinary action.
• Actively seek ideas for improvement through the communication
III.F.04.06 Grievance procedure/system provides
system/suggestion boxes, and exit interviews.
for means or channel to bring grievances
to management's attention other than • Conduct worker satisfaction surveys periodically to measure
to their direct supervisor. worker morale and help identify other opportunities for facility
and dormitory improvements.
III.F.04.07 Facility staff does not retaliate against • Hold regular worker feedback meetings to discuss issues and
workers who bring up workplace problems affecting workers in the day-to-day operations of the
grievances. supplier and to ask for their suggestions on how to address
problems or improve procedures. The meetings can be either
formal or informal.
Additional Practices:
• Use a formal worker performance management system as a basis

for promotions and pay increases.
• Specify and communicate to workers how long it will take for
management to respond to worker grievances. When responses

to grievance are delayed, the supervisor or manager handling the
complaint should communicate the reason for the delay.
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III.F.05 Security Personnel
On-site security personnel, including workers hired directly by the facility or workers hired by a third-party service provider, conduct routine and
emergency activities in a way that ensures the highest levels of safety and security, while also protecting the dignity of the worker. No force is used
except in self-defence and in situations where there is a clear and present danger to themselves or other workers. The use of force in these limited
circumstances is proportional to the situation and within the boundaries of law.
Standard Standard
III.F.05 Excessive force shall not be used III.F.05.01 Security is respectful of workers and does not intimidate
when security personnel exercises them.
force in situations where there

is no clear and present danger III.F.05.02 Security does not restrict the movement of workers.
to themselves or to workers, or
III.F.05.03 Security is not armed inside the facility.
is beyond the boundaries of the
law. Security personnel’s role and
III.F.05.04 Security personnel do not use excessive force.
responsibility, including interactions
with workers, are limited to
securing people’s safety and
property. Intimidation by security
personnel is not allowed.
III.F.06 Pat-downs
Should worker searches, such as “pat-downs,” or hand bag searches be necessary, all worker searches are conducted in the open and any physical
searches are performed by security personnel who are of the same gender as the worker and with respect for the worker, and the searches are applied
equally to all workers regardless of position.
Standard Standard
III.F.06 Facility must not conduct pat-downs III.F.06.01 Facility staff does not conduct strip searches.
in an abusive manner.
III.F.06.02 Pat-downs and/or hand bag searches are conducted by same
gender or in culturally appropriate manner.
III.F.06.03 Worker searches or pat-downs are conducted in the open.

III.F.07 Harassment and Abuse Policy
Facility has a policy that defines and prohibits all forms of harassment and abuse, and includes a list of penalties for violations.
Standard Standard
III.F.07 Facility’s policy on harassment III.F.07.01 Facility has a policy that defines and prohibits all forms of
and abuse defines harassment harassment and abuse.
and abuse and provides adequate

guidance as to its various forms that III.F.07.02 Facility's policy on prohibiting harassment and abuse
are subject to disciplinary action. includes penalties or disciplinary action on violations.
Management must discipline

anyone (including managers,
supervisors or fellow workers) who
engages in any physical, sexual,
physiological or verbal harassment
or abuse.

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III.G Labor Standards: Wages, Benefits and Terms of Employment
Facilities shall pay wages and overtime premiums in compliance with all applicable laws. Workers shall be paid at least the minimum legal wage or a wage that
meets local industry standards, whichever is greater. Facilities are encouraged to provide wages and benefits that are sufficient to cover workers basic needs and
some discretionary income.
III.G.01 Minimum Wage Requirement

Workers shall be paid at least the minimum legal wage that meets local industry standards, whichever is greater.
Standard Standard
III.G.01 Workers shall be paid at least the III.G.01.01 Minimum wages/local industry wages are Best Practice

minimum legal wage or a wage paid to workers. • Your facility should regularly survey your employees to evaluate if
that meets local industry standards, they have enough money for things like food and housing, and if
whichever is greater. III.G.01.02 Minimum wages/local industry wages are
they are able to save additional money after each pay period. This
paid to workers.
will help you better understand if you are covering basic needs and
Minimum wages/local industry wages are discretionary income.
III.G.01.03
calculated correctly. • When compensation does not meet the workers’ basic needs,
your company should develop, communicate and implement
III.G.01.04 Minimum wage payments are in full strategies progressively to improve wages. The following are
compliance. examples of actions facility can take to meet this objective while
minimizing the impact to operating costs: 1. Implement production
re-engineering and productivity improvement initiatives that
can enhance workers’ efficiencies. Efficiencies may help reduce
costs, overtime, and waste and improve quality. Apply the
savings toward wages, worker incentives, etc. 2. Provide training
to new workers on the wages, including calculation, deductions
and benefits they will receive, and ways they can increase their
earnings through efficiency gain.
III.G.02 Unreasonable Production Quotas
Facility shall not set production quotas or piecework rates at such a level that workers need to work beyond regular working hours (excluding overtime)
to earn the legal minimum wage or prevailing industry wage. Any quotas or rates must be reasonable for workers to meet within a regular shift.
Standard Standard
III.G.02 Facility shall not set production III.G.02.01 Production quotas are set at a reasonable rate for piece rate
quotas or piecework rates at such workers such that they are able to achieve it in regular shift,

a level that workers need to work and without having to work overtime to earn minimum
beyond regular working hours wages/ industry wages.
(excluding overtime) to earn the
legal minimum wage or prevailing
industry wage. Any quotas or rates
must be reasonable for workers to
meet within a regular shift.
III.G.03 Overtime and Incentive Rates

Facility pays overtime and any incentive (or piece) rates that meet all legal requirements or the local industry prevailing standard, whichever is greater.
Hourly wage rates for overtime must be higher than the rates for the regular work shift.
Standard Standard
III.G.03 Facility shall pay overtime and III.G.03.01 Facility pays overtime to workers at legal premium/industry
any incentive (or piece) rates that rates/agreed rates (if higher than legal rate).
meet all legal requirements or the
local industry prevailing standard, III.G.03.02 All overtime is appropriately paid.
whichever is greater.
III.G.03.03 Overtime calculation method is in compliance with the local
law.
III.G.03.04 Facility complies with any other requirement related to

overtime calculation.

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III.G.04 Unpaid OT Adjustments
Overtime hours shall not be adjusted against leaves/holidays/ absent days unless permitted by the local law.
Standard Standard
III.G.04 Overtime hours shall not be III.G.04.01 Overtime hours are not adjusted against leaves/ holidays/
adjusted against leaves/holidays/ absent days or in contravention to the local law.
absent days unless permitted by the
local law. III.G.04.02 Workers are not moved to other facilities to avoid payment of
overtime or other benefits.

III.G.05 OT Allowances
Workers shall be paid all legally applicable overtime allowances.
Standard Standard
III.G.05 In addition, workers who work III.G.05.01 Overtime related allowances are paid.
past a stipulated time in the
evening may be due a meal and/
or transportation allowance, if
specified by local law.
III.G.06 Display of Legal Minimum Wages and Wage Calculation

Legal Minimum wage rates, overtime rates, wage calculation shall be displayed at prominent places throughout the facility in the local language of
workers.
Standard Standard
III.G.06 Legal Minimum wage rates, III.G.06.01 Legal Minimum wage rates, overtime rates, wage calculation
overtime rates, wage calculation method is displayed at prominent places throughout the
shall be displayed at prominent facility in the local language of workers.
places throughout the facility in the
local language of workers.
III.G.07 On-Time and Direct Payment to Workers
Workers are paid directly and at least once per month within no more than 30 days, after the end of the previous month or within legally mandated peri-
od, whichever is earlier. Payments must be made in cash, and “in-kind” payments are prohibited.
Standard Standard
III.G.07 Worker payments (wages/ benefits/ III.G.07.01 Worker payments (wages/overtime/benefits/ allowances)
overtime/allowances) shall be paid are delivered as scheduled and not delayed.

on-time, in monetary form and
directly to workers III.G.07.02 Facility does not make in-kind wage payments.
III.G.08 Monetize or Encash Benefits

If not permitted under local law, facility shall not monetize/encash any benefit/allowance.
Standard Standard
III.G.08 If not permitted under local law, III.G.08.01 Facility does not pay money/encashment for certain benefits
facility shall not monetise/encash which are not permitted by law (e.g. meals during overtime,
any benefit/allowance. leaves).
III.G.09 Wage Statements

For each pay period, facility shall provide workers an understandable wage statement written in a language they understand which includes all relevant
details
Standard Standard
III.G.09 For each pay period, facility shall III.G.09.01 Wage statements are available to workers.
provide workers an understandable
wage statement written in a III.G.09.02 Wage statements are complete.
language they understand which
includes all relevant details. III.G.09.03 Wage statements are in workers’ local language.
III.G.09.04 Wage statements are in full compliance.

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III.G.10 Right to Refuse Employer Services
Workers shall have the right to use or not to use employer provided services, such as housing or meals.
Standard Standard
III.G.10 Workers shall have the right to use III.G.10.01 Facility does not make it mandatory to use employer
or not to use employer provided provided services such as housing, meals, transportation.
services, such as housing or meals.
III.G.11 Excess Charge for Goods and Services

Deductions for services/goods to employees (housing, meals, and supplies) provided by the employer shall not exceed the actual cost.
Standard Standard
III.G.11 Deductions for services/goods to III.G.11.01 Facility does not charge employees for services/goods
employees (housing, meals, and (housing, meals, transportation and supplies) at higher than
supplies) provided by the employer actual cost to facility.
shall not exceed the actual cost.
III.G.12 Short term/Temporary/Fixed Term Contracts
Where training wages are legally allowed, they are for a limited time frame and the 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.
Standard Standard
III.G.12 Workers shall not be moved III.G.12.01 Facility does not excessively use short term/temporary/fixed
between facilities or issued term employment contracts.

successive short-term contracts to
avoid payment of overtime or other III.G.12.02 Short-term/temporary/fixed-term workers are shifted to
benefits. permanent status in accordance with local laws once the
specified period has ended.
III.G.12.03 Short-term/temporary/fixed-term contracts are not being

used for permanent jobs.
III.G.12.04 Short-term/temporary/fixed-term workers’ employment

contracts are in accordance with local laws.
III.G.12.05 Facility does not use labor-only contracting to avoid

provision of benefits to workers.

short-term/temporary/fixed-term workers’ employment
contracts.
III.G.13 Usage of Layoffs and Rehiring to Avoid Benefits

Facility shall not modify or terminate worker contracts, work schedule or location for the purpose of avoiding wage requirements.
Standard Standard
III.G.13 Workers shall not be laid off and III.G.13.01 Facility does not terminate workers’ employment after their
then rehired shortly thereafter probationary period, and hire new workers thereafter, with
for the sole purpose of avoiding the intention of also not keeping them past the probationary
classifying those employees as period.
permanent and paying required
benefits. III.G.13.02 Workers’ contracts are not terminated and then re-
established to avoid payment of worker benefits.
III.G.13.03 Probationary period must be in accordance with local laws.

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probationary workers.
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III.G.14 Suspension/Termination of Contracts
Contract suspension/ terminations shall be in accordance with law and with full payment of legal termination benefits.
Standard Standard
III.G.14 Contract suspension/terminations III.G.14.01 Suspension of workers' contracts must be in accordance with
shall be in accordance with law local law.
and with full payment of legal
termination benefits. III.G.14.02 Facility meets all other requirements related to suspension of
workers' contracts.
III.G.14.03 Termination of workers' contracts must be in accordance

with local law.
III.G.14.04 Facility meets all other requirements related to termination

of workers' contracts.
III.G.15 Illegal Deduction from Worker Wages

Deductions from wages as a disciplinary measure are not permitted, including wage deductions for tardiness that exceed the wage equivalent of actual
time missed.
Standard Standard
III.G.15 Facility shall not make any illegal III.G.15.01 Deductions from wages are made in accordance with local
deductions from worker wages. law.
III.G.15.02 Tardiness is deducted in accordance with local law.
III.G.15.03 Tardiness is deducted on a pro-rate basis.

III.G.16 Leaves and Holidays
Facility provides paid leaves and holidays as required by law or which meet the local industry standard, whichever is greater.
Standard Standard
III.G.16 Facility must provide workers with III.G.16.01 Legally required leaves are provided.
a reasonable emergency leave
period (i.e. to care for a sick relative, III.G.16.02 Legally required leaves are properly calculated.

a death in the family, etc.) that is in
accordance with local laws, local III.G.16.03 Workers are not restricted from taking leaves.
customs or industry standard.
III.G.16.04 Legally required holidays are provided.
III.G.16.05 Workers are not forced to take leaves when there is less
work/production in the facility.
III.G.16.06 Leave and holiday policies and practices operate in full

compliance.
III.G.17 Leave procedures

Facilities must have clearly written leave procedures and these must be made accessible and communicated to workers.
Standard Standard
III.G.17 Facility must have clearly written III.G.17.01 Facility has clearly written procedures regarding sick leave,
procedures regarding sick leave, annual leave, maternity leave, emergency family leave and
annual leave, maternity leave, other leave as required by local law including the procedures
emergency family leave and other to avail such leaves.
leave as required by local law.
III.G.17.02 Facility's leave procedures are in accordance with local law.
Procedures must be made accessible
and communicated to workers. III.G.17.03 Facility's leave policies and procedures are communicated
effectively to workers.

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III.G.18 Leave/Holiday/Weekly Off Payments
Workers shall be paid for the leave not taken in addition to the leave days/holidays/weekly off days worked, as required by local law.
Standard Standard
III.G.18 If permitted by law, workers may III.G.18.01 Workers are paid for unclaimed leaves in accordance with
voluntarily agree to work through law.
their annual leave and they shall
be paid for the leave not taken in III.G.18.02 Workers are paid correctly for work done on leave/holidays.
addition to the days worked, as
III.G.18.03 Workers are paid correctly for work done on weekly off days.
required by local law.

III.G.19 Leave Records
Facility shall maintain all documentation related to worker eligibility for leaves and leaves availed accurately and up to date.
Standard Standard
III.G.19 Facility shall maintain all III.G.19.01 Facility maintains records of leaves (entitlement, availed and
documentation related to worker encashed).
eligibility for leaves and leaves
availed accurately and up to date. III.G.19.02 Leave records are both complete and accurate.
III.G.20 Payment of Benefits
Benefits, such as social insurance, retirement benefits, severance, maternity benefits, etc., are paid on time and in accordance with local laws. Deductions
or withholdings for these benefits must be remitted to the proper authority in the time period required by law.
Standard Standard
III.G.20 Benefits, such as social insurance, III.G.20.01 Maternity benefits are in accordance with local law.
retirement benefits, severance,

maternity benefits, etc., are paid on III.G.20.02 Maternity benefits are paid in accordance with local law.
time and in accordance with local
laws. III.G.20.03 Maternity benefits required documentation is in accordance
with local law.
III.G.20.04 Social security/medical insurance benefits are provided in

accordance with local law.
III.G.20.05 Social security/medical insurance benefits are paid in

accordance with local law.
III.G.20.06 Social security/medical insurance benefits required

documentation is in accordance with local law.
III.G.20.07 Legally required/agreed bonuses and allowances are paid.
III.G.20.08 Severance is paid.
III.G.20.09 Severance pay is paid correctly and accurately.
III.G.20.10 All other required benefits are provided in accordance with

local law.
III.G.21 Legally Required Withholdings

Deductions or withholdings for the benefits must be remitted to the proper authority in the time period required by law.
Standard Standard
III.G.21 Deductions or withholdings for the III.G.21.01 Legally required withholdings are made (e.g. social security,
benefits must be remitted to the pensions or healthcare.)
proper authority in the time period
required by law. III.G.21.02 Legally required withholdings are accurately calculated.

III.G.21.03 Legally required withholdings are forwarded to the
appropriate government authority.
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III.G.22 Worker Tools Provided Free of Charge
Work tools shall be provided free of charge at the time of employment.
Standard Standard
III.G.22 Workers may decide to bring their III.G.22.01 Essential work tools are provided free of charge at the time of Best Practice
own work tools, however, the facility employment. It is a best practice that procedures are outlined
shall offer free of charge any tool to acknowledge receipt of the tool and provide
that is required for the satisfactory direction on what happens when a tool is lost,
performance of the position. No stolen or no longer sufficient. Some countries may
deductions shall be made for work require that deductions for work tools not bring

tools unless the worker loses the the worker’s wages below the minimum wage.
tool and it needs to be replaced.
III.G.23 Taking Work Home

Workers shall not take work home, even if this work is voluntary.
Standard Standard
III.G.23 Workers shall not take work home, III.G.23.01 Facility does not allow workers to take work home.
even if this work is voluntary.
III.H Labor Standards: Working Hours
Facilities shall set working hours in compliance with all applicable laws. While it is understood that overtime is often required in garment production, facilities shall
carry out operations in ways that limit overtime to a level that ensures humane and productive working conditions.
III.H.01 Normal Work Schedule

Facility complies with all applicable laws, regulations and industry standard on working hours. Except in extraordinary business circumstances, the
maximum allowable working hours in any week shall be the lesser of a) what is permitted by national law or b) or a total of 60 hours of work in any
consecutive 7-day period.

Standard Standard
III.H.01 Facility's work schedules/shift III.H.01.01 The maximum allowable normal/fixed Best Practice
timings are not in accordance with working hours in any week is the lesser • To help reduce working hours, focus on streamlining and
legal requirements of a) what is permitted by national law, optimizing the workforce, thus easing production schedules.
or b) a regular workweek of 48 hours. Suppliers can reduce excessive overtime by becoming more
efficient through the adoption of lean manufacturing principles
and capacity building. Although style proliferation is one of the
primary drivers of overtime, there are many other contributors
including capacity miscalculations in sourcing, long approval
processes in merchandising, poor forecasting, as well as changes
in buying patterns in operations. Addressing these types of issues
can result in significant workforce efficiencies and, consequently,
decreased working hours.
• Facilities have successfully decreased the amount of overtime
needed by: Improving workers’ skills through training, mentoring
or coaching so that mistakes and rework does not contribute
to overtime. Improving production flow and processes so that
delays do not result in overtime. Improving capacity planning so
that enough workers are available to manage demands. Hiring
additional workers or adding another shift.
• Suppliers usually make decisions based on cost benefit analysis.
However, you shall make sure that all costs are factored into your
overtime analysis. For example: the cost of medical expenses, time
lost due to illness, injuries, and accidents, and rework could all be
caused by worker fatigue due to long working hours.

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III.H.02 Overtime Hours
Overtime hours shall not exceed legal limits or 12 hours in a week, whichever is lesser.
Standard Standard
III.H.02 Overtime hours shall not exceed III.H.02.01- Total weekly working hours (including normal working Frequently Asked Questions
legal limits or 12 hours in a week, III.H.02.04 hours and overtime hours) is less than 60 hours or the local I know the law says that we should not have that
whichever is lesser legal requirement whichever is lower. much overtime, but I am one of the best facilities
in my region. I cannot supply your products, at the
III.H.02.05 Facility complies with all other requirements related to
prices you need and still be competitive. What am I
excess overtime hours.
supposed to do?

III.H.02.06 Facility complies with special working hours and restrictions Gap Inc. understands that the industry norm in
for some groups of workers (e.g. women workers/pregnant some countries is to work consistent overtime
workers etc.) hours and that enforcement of laws is sometimes
weak. Further, while we know that limiting
overtime is a challenge in many supply chains, it is
also clear that there are varying levels of severity.
For that reason, we have built levels of severity
into our scoring system which will lead to varying
number of points deducted in each facility’s
assessment score. However, we need our facilities
to be committed to the protection of their workers’
health and safety, which is the purpose of limiting
worker hours.
Guidance
Extraordinary business circumstances would
include, natural disasters, legal strikes, black-
outs, lack or delay in raw materials (that is out of
Vendor’s control) or industry’s peak season and
it should never be more than 72 hours for up to 3
weeks in a 3 month period.
III.H.03 Involuntary Overtime
Workers may refuse overtime work without any threat of penalty, punishment or dismissal. Under no circumstances shall a facility impose punitive
measures such as salary deductions, apply coercion of any kind, deny future opportunities for overtime, or take disciplinary action against workers for
refusing overtime.
Standard Standard
III.H.03 All overtime shall be voluntary. III.H.03.01 Overtime is voluntary.

III.H.03.02 Facility does not retaliate against workers who refuse to
work overtime (by means such as threatening dismissal,
demotion, not allowing any overtime, pay cuts etc.).
III.H.03.03 Facility meets all other requirements related to workers’ right

to refuse overtime.
III.H.04 Overtime as Condition of Employment

Workers must not sign a document agreeing to work overtime on demand as a condition of employment.
Standard Standard
III.H.04 Workers must not sign a document III.H.04.01 Workers are not asked to sign a document agreeing to work
agreeing to work overtime overtime on demand as a condition of employment.
on demand as a condition of
employment.

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III.H.05 Timekeeping System and Records
Facilities shall have a functioning, reliable and accurate timekeeping system that allows workers to record their regular and overtime hours.
Timekeeping records shall be maintained and workers shall have access to their attendance records upon request.
Standard Standard
III.H.05 Facility shall have a functioning, III.H.05.01 Timekeeping system is available.
reliable and accurate timekeeping
system that allows workers to III.H.05.02 Timekeeping system is reliable and accurate.
record their regular and overtime
hours and have access to the time III.H.05.03 Timekeeping system is functioning.

records
III.H.05.04 Timekeeping records are available.
III.H.05.05 Timekeeping records are reliable and accurate.
III.H.05.06 Timekeeping records are in full compliance.
III.H.05.07 Workers record/punch their own working time (in and out
time).
III.H.05.08 Facility allows workers to access to their attendance/time

records upon request.
III.H.06 Working Hours One Day off in 7

Facility shall allow workers at least one day off in seven, or the local legal standard if more stringent. A day off must be at least 24 hours of
continuous rest.
Standard Standard
III.H.06 Facility shall allow workers at least III.H.06.01 Facility provides 1 day off in 7.
one day off in 7 or the local legal
standard if more stringent. III.H.06.02 If workers are required to work on a weekly off day,
compensatory off days are provided in accordance with law.
III.H.06.03 Facility’s 1 day off in 7 policies and practices are in full

compliance.
III.H.06.04 Facility's weekly off day is at least 24 hours of continuous

rest.
III.H.07 Daily Rest Periods
All legally required daily rest periods must be provided to all workers.
Standard Standard
III.H.07 All legally required daily rest periods III.H.07.01 Facility provides workers with all legally mandated rest
must be provided to all workers. periods.

III.H.08 Overtime Management System
Facility shall have a system that demonstrates that all overtime hours are voluntary.
Standard Standard
III.H.08 Facility shall have a system that III.H.08.01 Facility has a system to demonstrate that all overtime hours
demonstrates that all overtime are voluntary.
hours are voluntary.

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IV. Occupational Health and Safety
Facilities shall comply with all applicable laws and regulations regarding working conditions and shall provide workers with a safe and healthy environment.
IV.A Occupational Health and Safety

IV.A.01 Compliance with Laws
Facility complies with all applicable laws and/or manufacturer instructions regarding working conditions, including personal protective equipment,
machine safety, chemical handling and safety, first aid, medical care, food service, emergency preparedness, fire safety, structural and electrical safety.
Standard Standard

IV.A.01 Facility complies with all applicable IV.A.01.01 Facility complies with the country's health and safety laws.
laws regarding worker health and
safety.
IV.A.02 Health and Safety Committee

If required by law, health and safety committee shall be available in accordance with local law and meetings logs shall be maintained.
Standard Standard
IV.A.02 If required by law, health and IV.A.02.01 Required health and safety committee records are available.
safety committee shall be available
in accordance with local law and IV.A.02.02 Required health and safety committee operates in
meetings logs shall be maintained compliance with local laws.
IV.A.02.03 Facility meets all other requirements related to health and

safety committees.
IV.A.02.04 Required health and safety committee's meeting logs are

available.
IV.A.02.05 Required health and safety committee's meeting logs are in

accordance with local laws.
IV.A.02.06 Facility meets all other requirements related to health and

safety committee's meeting logs.
IV.A.03 General Safety
Facility complies with all applicable laws regarding risk protection.
Standard Standard
IV.A.03 Facility complies with all applicable IV.A.03.01 Facility complies with the country's risk protection laws. Guidance
laws regarding risk protection. Grates are acceptable for covering openings in
IV.A.03.02 Facility's floor openings are appropriately covered. the floor as long as any fumes and/or odours
Openings in the floor shall be

covered, flat and level with the are non-toxic and not offensive to workers.
IV.A.03.03 Floor opening covers sufficiently cover the risk of fumes/
floor, so that they do not create any The rungs of the grate should be close enough
odours/tripping/falling hazards.
hazard. together that the worker’s foot cannot get
caught in the space.
Part 2: Provisions & Standards Section IV: Occupational Health And Safety
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118
IV.A.04 Ventilation
Adequate and effective ventilation exist to ensure comfort of workers and proper circulation of air, especially in areas of frequent or heavy use of
chemicals and paints, or in areas with significant dust and material particles.

IV.A.04 Facility is well ventilated. There are windows, fans, air IV.A.04.01 Ventilation is sufficient.
conditioners or heaters in all work areas for adequate
circulation, ventilation and temperature control. IV.A.04.02 Facility's ventilation system is functioning.
Adequate Ventilation: IV.A.04.03 Working areas are at a comfortable temperature.

Facility shall have natural ventilation, operational exhaust
IV.A.04.04 Humidity in working areas is not high.
systems or temperature control devices to remove heat and
humidity.
IV.A.04.05 Facility's fans are cleaned on a regular basis.
Fans:
IV.A.04.06 Facility's fans have fan guards.
• Fans, if used, shall be cleaned on a regular basis
• Fans shall have a fan guard, if a worker can come into IV.A.04.07 Facility's chemical mixing and transfer areas are well ventilated.
contact with the blades in normal work practices.
• Fans shall not be used near chemicals, as this will IV.A.04.08 Facility's fans located near chemical areas do not blow
potentially expose the chemicals to a greater area. chemicals to the greater part of the facility.
Spot Cleaning: IV.A.04.09 Facility has vacuum systems in solvent areas.

• Solvent operations (e.g. spot cleaning) shall have vacuum
IV.A.04.10 Spot cleaning areas are segregated from main production area
systems that remove solvent vapours to the outside of the
and exhausts from spot cleaning stations are directed to the
facility.
outside of the facility.
Sandblasting:
• Sandblasting shall not be used in the facility IV.A.04.11 Facility does not use any sandblasting techniques.
IV.A.04.12 Facility meets all other requirements related to ventilation.
IV.A.05 General Safety: Lighting

Appropriate and sufficient lighting is installed to ensure workers are aware of their surroundings, are able to perform their duty in safety, and are able
to see any potential barriers or obstacles on their way to the nearest exits.

IV.A.05 Work surface lighting in production areas—such as sewing, IV.A.05.01 Work surface lighting is sufficient for the safe performance of
knitting, pressing and cutting—is sufficient for the safe production activities.
performance of production activities
IV.A.05.02 Facility's lighting system is functioning properly.
IV.A.05.03 Facility meets all other requirements related to lighting.

IV.A.06 Floor Safety
Floors shall have proper construction, drainage and maintenance.
Standard Standard
IV.A.06 Floors shall have proper IV.A.06.01 Facility's floors are well-constructed.
construction, drainage and
maintenance to prevent workers IV.A.06.02 Flooring is well maintained.

from slipping.
IV.A.06.03 Facility's drainage system is working and is well maintained.
Floors shall not have large
accumulation of standing water as IV.A.06.04 Facility's floor has adequate drainage (i.e. there is no standing
workers shall not be standing in or water.)
wading through water
IV.A.07 Sanitation and Housekeeping

Facility shall maintain good housekeeping and sanitation in all areas including outside stairs/exit paths and corridors.
Standard Standard
IV.A.07 Facility complies with all applicable IV.A.07.01 Facility complies with the country's sanitation laws.
laws regarding sanitation.
IV.A.07.02 Accumulated trash and/or empty containers are disposed of
Trash
regularly.
• Trash, debris or empty containers
shall not be allowed to IV.A.07.03 Facility has good housekeeping practices.
accumulate to the point where
IV.A.07.04 Facility's outside stairs and exit paths are well maintained.
it poses a fire safety hazard or
obstructs exits.
• Trash shall be collected and
removed from the site regularly
and properly.
Outside stairs and exit paths
• Outside stairs and exit paths

shall be well-maintained, i.e. not
covered by debris, trash or not
falling down.
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120
IV.A.08 Stairways and Raised Platform
Stairs, Platforms and elevated floors shall be well protected to eliminate safety hazards.
Standard Standard
IV.A.08 Stairways and raised work IV.A.08.01 Facility's stairways and/or raised platforms have railings.
platforms (not including loading
docks) shall have railings or visible IV.A.08.02 Facility's stairways and/or raised platforms have visible
markings to identify the potential markings to identify potential hazards.
hazard so that workers are protected
from falling.

IV.A.09 Confined Spaces
Facility’s confined spaces shall not pose danger to worker safety.
Standard Standard
IV.A.09 Facility shall have well defined IV.A.09.01 Confined space procedures are available.
confined space procedures and shall
train workers on these procedures IV.A.09.02 Confined space procedures are implemented.
IV.A.09.03 Confined space procedures are complete.
IV.A.09.04 Workers are trained in facility's confined space procedures.
IV.A.10 Seating and Ergonomic Mats

Facility shall take adequate measures to prevent fatigue and long term health problems to workers.
Standard Standard
IV.A.10 Proper ergonomic mats are IV.A.10.01 Proper ergonomic mats are provided to limit fatigue in cases
provided to limit fatigue in cases where workers are standing for an extended period of time.
where workers are standing for an
extended period of time. Proper IV.A.10.02 Seating provided to workers is comfortable.
seating is also provided to workers.
IV.A.11 Smoking
Smoking shall not be permitted in the areas where it may pose health risk for other workers and/or a fire hazard.
Standard Standard
IV.A.11 Smoking shall not be permitted in IV.A.11.01 Facility does not allow smoking in production/generator/
the areas where it may pose health boiler/chemical areas.
risk for other workers/fire hazard.

IV.A.11.02 "No-Smoking" signs are posted at the generator/boiler room/
chemical/fuel storage areas in the facility.
IV.A.12 Pregnant and Breastfeeding Women

Facility shall take all required measures to ensure health and safety of groups of workers with special requirements.
Standard Standard
IV.A.12 Pregnant and breastfeeding workers IV.A.12.01 Facility conducts a risk assessment to determine and address
shall not be placed in functions and any specific risks to pregnant, post-partum and nursing
areas (i.e. spot cleaning or chemical women.
handling) that are not healthy for
the duration of their pregnancy and IV.A.12.02 Facility complies with legal requirements on working
breastfeeding period. environment for pregnant, post-partum and breastfeeding
women.
IV.A.12.03 Facility makes reasonable accommodations in working

conditions for pregnant, post-partum and breastfeeding
women (such as job reassignments to non-hazardous or
lighter work, provision of seating, extended breaks, etc.).
IV.A.12.04 Facility meets all other requirements related to protections

for pregnant and breastfeeding workers.
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122
IV.A.13 Workers with Disability
Facility shall take all required measures to ensure health and safety of groups of workers with special requirements.
Standard Standard
IV.A.13 Facility takes adequate steps to ensure health IV.A.13.01 Facility takes adequate steps to ensure health and safety of
and safety of workers with disabilities. workers with disabilities.
IV.A.14 Toilets
There is appropriate number of clean, functional, and sanitary toilet areas and there is no unreasonable restriction on their use.

IV.A.14 Sufficient Toilets IV.A.14.01 Facility provides a sufficient number of toilets.
• The number of toilet facilities shall be adequate for the worker populace
IV.A.14.02 Facility has adequate special toilet facilities for
(male and female).
special groups of workers (pregnant women, workers
Clean Toilet Areas with disabilities, etc.)
• Toilets shall be functional, clean and sanitary.
IV.A.14.03 Facility's toilet areas are cleaned on a regular basis.
• Facilities shall have designated cleaners or some established procedures
for keeping the toilets clean throughout the day. IV.A.14.04 Facility's toilets are functioning.
Ongoing Maintenance
IV.A.14.05 Toilet areas are well maintained.
• Facilities shall maintain functioning toilets.
Free Access IV.A.14.06 Facility's toilet facilities are stocked with necessary,
locally accepted supplies, such as buckets of water,
• Workers shall be allowed to go freely to the toilet.
toilet paper, hand soap, covered trash bins, etc.
• Facilities may institute procedures to avoid workers congregating at
the entrance to the toilet area. However, facilities shall not restrict the IV.A.14.07 Facility's toilet facilities are stocked with necessary,
number of times a person may go to the toilet or have other procedures locally accepted supplies, such as buckets of water
that inhibit use or demean the worker. toilet paper, hand soap, covered trash bin throughout
Locally Accepted Supplies the day.
• Toilets shall be stocked with necessary, locally accepted supplies, such as IV.A.14.08 Facility meets all other requirements related to
toilet paper and/or buckets of water. supplies in toilets.
• Covered trash shall be provided in toilets.
• Proper hand wash facility with soap shall be provided near toilets. IV.A.14.09 Facility provides private toilet facilities.
Privacy Facility's toilets are marked by gender.

IV.A.14.10
• In larger facilities where there are multiple toilets in one bathroom, the
bathrooms shall be segregated by gender and marked. IV.A.14.11 Facility meets all other requirements related to toilet
facility.
• In facilities that may have only one toilet per bathroom, men and women
may share the room one person at a time.
IV.A.15 Personal Protective Equipment (PPE)
Appropriate personal protective equipment (PPE)—such as masks, gloves, goggles, ear plugs and rubber boots—is made available at no cost to all
workers and instruction in its use is provided.
Standard Standard
IV.A.15 Equipment IV.A.15.01 Facility provides appropriate PPE to workers.
• PPE appropriate to the work performed shall be

IV.A.15.02 Workers do not use each other’s PPE where sharing it may
made available to workers at no cost.
pose risk of infection transmission (e.g. face masks and
• Workers shall not use each other’s’ PPE where it may respirators).
pose risk of infection transmission (e.g. face masks
and respirators). IV.A.15.03 Workers do not have to pay for their own PPE.
• Appropriate and marked storage facility and
IV.A.15.04 PPE provided to workers is in line with the recommendations
cleaning facility shall be provided for PPE.
of MSDS.
• Workers must be required to wear the provided PPE
when necessary. IV.A.15.05 PPE provided is properly functioning.
Training
IV.A.15.06 PPE is in good condition.
• Workers shall be trained in the hazards and health
risks of their jobs. Training shall include methods to IV.A.15.07 PPE provided to workers is appropriately sized.
minimize these risks, including use of appropriate
PPE. IV.A.15.08 Facility provides facilities for cleaning and storing PPE.
• Workers shall be trained to fit, maintain and use
their PPE. IV.A.15.09 Workers use their PPE.
• PPE training records shall be maintained. Facility workers are trained to use their PPE.
IV.A.15.10
IV.A.15.11 Facility workers are trained on the health and safety risks of
not wearing their PPE.
IV.A.15.12 Facility workers are trained on how to maintain their PPE.
IV.A.15.13 PPE training records are available.
IV.A.15.14 PPE training records are accurate and up to date.
IV.A.15.15 PPE training records are in full compliance.
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IV.A.16 Machine/Equipment Safety
Facility shall comply with all laws regarding machine safety and take all steps to ensure machine safety.

IV.A.16 Machinery IV.A.16.01 Facility complies with the country's mechanical safety laws.
• Facility complies with all applicable laws regarding

IV.A.16.02 Machinery/equipment has functioning safety guards.
mechanical safety.
• Machinery is equipped with operational safety devices IV.A.16.03 Pulley guards or cages are provided on machine moving
and the safety devices are maintained in operational parts.
condition.

IV.A.16.04 Sewing machines have needle guards.
• Machinery/ equipment shall be inspected and
serviced in accordance with the manufacturer’s
IV.A.16.05 Sewing machines have eye shields.
recommendations and legal requirements (including
certification by the local government or an appropriate IV.A.16.06 Cutting machines have knife guards.
third-party).
• Individual operators are certified or licensed to operate IV.A.16.07 Machines have hands-free devices where required.
equipment where specialized equipment is utilized; and
a system is in place to verify and renew certifications / IV.A.16.08 Machines have finger guards where required.
licenses on a timely basis.
IV.A.16.09 Facility's hydro-extractors have adequate safety provisions
• Each piece of machinery or equipment has its own
like working brakes, secure covers, emergency stop button,
electrical, pneumatic, or hydraulic disconnect or power-
bolting to ground etc.
off switch or valve so that the individual machine or
piece of equipment can be isolated from the others. IV.A.16.10 Machinery/equipment safety guards have not been
• Facility shall prohibit the wearing of loose clothing tampered with, and are being used.
where it may pose a hazard to the worker
IV.A.16.11 Machinery/equipment's temperature gauges are operational.
IV.A.16.12 Facility's boiler room located in an area separated from the

production floor and office space.
IV.A.16.13 Facility's compressor is located in an area separated from the

production floor and office space.
IV.A.16.14 Facility's boiler has drip pans.
IV.A.16.15 Facility has an oil spill kit in the boiler room.
IV.A.16.16 Shut-off switches/valves are within workers reach for in and

out steam lines and for individual irons.
IV.A.16 Machine/Equipment Safety
Facility shall comply with all laws regarding machine safety and take all steps to ensure machine safety.

IV.A.16 IV.A.16.17 Facility does not store flammable materials in the boiler
(CONT) rooms.

IV.A.16.18 Facility does not store flammable materials on production
floors.
IV.A.16.19 Machinery Inspection and maintenance procedures are

available, up to date, and complete.
IV.A.16.20 Machinery Inspection and maintenance procedures are

appropriately implemented.
IV.A.16.21 Machinery is inspected and serviced on a regular basis.
IV.A.16.22 Machinery is inspected and certified by competent external

authorities where required by law.
IV.A.16.23 Machinery/equipment inspection/certification is up to date.
IV.A.16.24 Facility maintains equipment/machinery's inspection logs

and service records.
IV.A.16.25 Licence of the operators of specialised machines/boiler/

compressor etc., where required by law is available.
IV.A.16.26 Licence of the operators of specialised machines/ boiler/

compressor etc., where required by law is up to date.
IV.A.16.27 Each piece of machinery or equipment has its own electrical,

pneumatic, or hydraulic disconnect or power-off switch or
valve.
IV.A.16.28 Facility workers do not wear loose fitting clothes in area

where this type of clothing can pose a hazard.
IV.A.16.29 Machinery or equipment has On and Off capabilities.
IV.A.16.30 Facility's equipment has proper covers and guardrails to

protect workers from potential hazards.
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IV.A.17 First Aid and Medical Facility
Adequate arrangement for first aid and medical care shall be made by the facility.

IV.A.17 • A sufficient number of first-aid kits are IV.A.17.01 Facility provides a sufficient number of first aid kits on each floor/each
maintained on work floors and include section.
appropriate supplies based on risk. At
minimum, basic supplies such as bandages, IV.A.17.02 Facility provides easily accessible keys to the first aid kit (if locked).
scissors, gloves, gauze, eyewash solution,
IV.A.17.03 Facility's first aid kits are sufficiently stocked.
antiseptic ointment, and an emergency log are

included.
IV.A.17.04 Facility's first aid kits are easily accessible.
• Facility shall have sufficient number of certified
first aid trained people. IV.A.17.05 Facility provides first aid training to workers in every shift.
• A system to address severe injuries is also
in place. A medical clinic is available on-site IV.A.17.06 Facility has enough people trained on first aid.
or in close proximity, to address basic health
IV.A.17.07 First aid training records are available.
and injury needs. A system to address severe
injuries is also in place.
IV.A.17.08 First aid training records are complete and up to date.
• There is a medical room with adequate
personnel and facilities, where required by law. IV.A.17.09 First aid training records are in full compliance.
• Where applicable, medical records for all staff
are kept confidential and stored in a secure area. IV.A.17.10 Facility's procedures for dealing with serious injuries are available and
complete.
• Injury and incident records are properly
maintained and all significant incidents are IV.A.17.11 Facility's procedures for dealing with serious injuries are properly
investigated, reported and corrective action implemented and communicated to staff and workers.
performed to minimize re-occurrence. Records
shall cover minor incidents and near misses. IV.A.17.12 There is a medical room in the facility as required by law.
Records are maintained for a minimum of one
year or applicable law, whichever is greater. IV.A.17.13 Adequate facilities are provided in the medical room.
IV.A.17.14 There an appointed doctor/nurse in the facility as required by local law.
IV.A.17.15 Facility keeps medical records of workers as required by law.
IV.A.17.16 Medical records of workers are complete.
IV.A.17.17 Facility maintains injury and accidents records.
IV.A.17.18 Injury and accident records are complete.
IV.A.17.19 Facility uses injury and accident records to take corrective actions and
prevent re-occurrences.
IV.A.17.20 First aid and medical facility are in full compliance.

IV.A.18 Canteen and Eating Area
Facility makes adequate arrangements for provision of food and eating area for workers.
Standard Standard
IV.A.18 Food preparation, storage and eating IV.A.18.01 Facility has obtained applicable licence/certificate for Guidance
areas are clean, safe and hygienic. operating the canteen. The following guidelines help Gap Inc. determine
Appropriate precautions are taken whether the food service area is “safe, clean and

to avoid food contamination. IV.A.18.02 Facility's food preparation area is well maintained, clean and
hygienic:”
hygienic.
Food preparation is separate from • Food is stored in a refrigerator as appropriate
the work, chemical storage and IV.A.18.03 Facility maintains medical check-up records/ fitness • Food is protected from rodents and/or insects
sleeping areas. certificates for canteen workers who handle food. or flies
IV.A.18.04 Facility's food preparation area is located appropriately • Serving items such as plates and tumblers are
(away from chemical areas, toilets, sleeping areas, etc.) cleaned after each use and preferably sterilized
Eating facilities are protected from
the elements and adequate seating, • Canteen and storage is clean and tidy
tables and lighting is provided. IV.A.18.05 Eating area is appropriately covered and protected from • Dining hall and servicing areas are ventilated
elements (rain/heat/cold, etc.) with fans and/or open windows
IV.A.18.06 Eating area has adequate infrastructure including tables, • Accessible portable water in dining area
chairs, etc. • Sufficient hand washing stations
• Safety measures are in place as appropriate, for
IV.A.18.07 Adequate facilities including utensils/drinking water/hand example near gas cylinders.
wash/dust bins are provided in the eating area.
• Canteen staff takes appropriate precautions to
avoid food contamination (e.g. wearing hair net,
gloves etc.)
In some countries, additional precautions, such as
regular medical check-ups for kitchen personnel,
may be required by law.
Best Practices
• Food waste is minimized and managed
appropriately.
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128
IV.A.19 Drinking Water
Adequate arrangements for provision of sufficient and safe drinking/potable water shall be made for all workers.
Standard Standard
IV.A.19 Adequate arrangements for IV.A.19.01 Facility provides access to potable water.
provision of sufficient and safe
drinking/potable water shall be IV.A.19.02 Facility has good quality potable water.
made for all workers
IV.A.19.03 Drinking water test report is available.
Sufficient number of drinking water
storage containers/dispensers shall IV.A.19.04 Drinking water test report is up to date.

be provided and maintained
IV.A.19.05 Drinking water test report is in full compliance.
IV.A.19.06 Water containers/dispensers are provided in sufficient

number on all floors.
IV.A.19.07 Water containers are well-maintained.
IV.A.19.08 Water containers are cleaned regularly.
IV.A.19.09 Facility meets all other requirements related to water

containers.
IV.A.19.10 Facility meets all other requirements related to drinking

water.
IV.A.20 Fire Safety Certificates

Facility complies with all applicable laws regarding fire safety.
Standard Standard
IV.A.20 Facility shall obtain all applicable IV.A.20.01 Facility complies with the country's fire safety laws.
legal fire safety certificates/
licenses/inspection reports IV.A.20.02 Fire safety licenses/certificates are available.
IV.A.20.03 Fire safety licenses/certificates are up to date.
IV.A.20.04 Fire safety licenses/certificates are in full compliance.

IV.A.21 Exits/Exit Routes/Emergency Routes
There shall be sufficient, marked exits and clear routes from all areas of the facility to ensure safe and smooth evacuation from the facility.
Standard Standard
IV.A.21 • There are sufficient, clearly marked emergency IV.A.21.01 Facility has at least two exits on each floor.
routes and exits in all sections of the facility
• Routes marked as exits shall lead directly to a IV.A.21.02 Facility has a sufficient number of exits on larger floors

safe location outside of the building. where more exits are required as per law.
• Doors and other exits are kept accessible and IV.A.21.03 Exit doors are kept unlocked at all times during working
unlocked during all working hours in case of hours.
fire or other emergencies.
• All main exit doors open to the outward in the IV.A.21.04 Facility's exits are at ground level.
direction of planned egress.
IV.A.21.05 Facility's exits are clearly marked.
• Aisles, exit doors and stairwells are of sufficient
width and height (in absence of legal guidance, Facility's exit signs are visible from the workspaces.
IV.A.21.06
refer to OSHA standards) and are kept clear at
all times of work in process IV.A.21.07 Facility maintains clear access to exits.
• The areas in front of exits, fire-fighting
equipment, control panels and potential fire IV.A.21.08 Facility's exit doors are functioning and easily opened.
sources are kept clear and indicated with a
IV.A.21.09 Facility's electronic locks open manually in the event of a
yellow box or other marking.
power failure.
• There are fire protected stairwells and certified
fire doors where required by law. IV.A.21.10 Facility's doors/exits/stairs are of sufficient width.
• All aisles and exit routes shall be kept clear and
unobstructed at all times IV.A.21.11 Facility's exit or directional signs are visible.
IV.A.21.12 Facility's exit routes do not go through high hazard areas.
IV.A.21.13 Facility maintains clear access to exit routes.
IV.A.21.14 Yellow lines or other markings are available to indicate areas

to be kept free of obstructions.
IV.A.21.15 Yellow lines and/or other markings in the facility are clear.
IV.A.21.16 Facility designates outdoor assembly areas to be used in case

of emergency.
IV.A.21.17 Facility's outdoor assembly areas are located at a safe

distance from the building and/or away from emergency
vehicle traffic and activities.
129
IV.A.21.18 Facility provides sufficient access between workspaces.
130
IV.A.21 Exits/Exit Routes/Emergency Routes
There shall be sufficient, marked exits and clear routes from all areas of the facility to ensure safe and smooth evacuation from the facility.
Standard Standard
IV.A.21 IV.A.21.19 Facility keeps screened-in stairs unlocked during working

(CONT) hours.
IV.A.21.20 All main exit doors open to the outward/in the direction of
planned egress.
IV.A.21.21 Fire protected stairwells and certified fire doors exist

wherever required by law.
IV.A.21.22 Facility's exit signs/markings are in local language(s).
IV.A.21.23 Facility's exit signs/markings are functioning and are well-

maintained.
IV.A.21.24 Exit routes and emergency exits are in full compliance.
IV.A.22 Emergency Lighting

Sufficient, power backed up Emergency lights shall be provided throughout the facility.
Standard Standard
IV.A.22 Emergency lighting in stairways IV.A.22.01 Facility has emergency lights in all areas of each floor.
and exit routes is self-powered and
sufficient for an orderly evacuation. IV.A.22.02 Facility has emergency lights installed above stairwells.
Emergency lighting in stairways and
exit routes is periodically inspected IV.A.22.03 Facility's emergency lights are inspected and maintained
and equipped with heat insulation regularly.
where required by law.
IV.A.22.04 All emergency lights are properly functioning.
IV.A.22.05 Facility's emergency lights are self-powered and have

sufficient battery back-up.
IV.A.22.06 Facility meets all other requirements related to emergency

lights.
IV.A.23 Firefighting Equipment
Facility shall provide appropriate firefighting equipment in sufficient number throughout the facility. These shall be maintained in functional condition
at all times
Standard Standard
IV.A.23 • Sufficient firefighting equipment, IV.A.23.01 Facility has a sufficient number of fire extinguishers. Guidance
including but not limited to, • While the standard does not specify a ratio of

fire extinguishers, fire hoses, IV.A.23.02 Fire extinguishers are appropriate to the types of possible fire extinguishers to floor space, there should be
hydrants, and sprinkler systems, fires in the various areas of the facility. enough fire extinguishers placed on walls and
is installed and inspected by columns so that workers in each work area can
IV.A.23.03 Fire extinguishers or signs indicating the location of the
internal staff every month and see and have access to them.
nearest fire extinguisher are visible from every worker
by a professional at least every
workspace. • Fire extinguishers should not be so close to a
six months. potential source of fire, such as a boiler, that
• Fire extinguishers are regularly IV.A.23.04 Fire extinguishers are fully stocked where signs indicate they they could not be reached safely.
maintained and charged, are of should be available. Facility has other firefighting equipment • Fire extinguishers should not be grouped
the appropriate type for the fire like sand buckets/fire hose, fire hydrants, sprinkler systems together in one work section.
risk in the location in which they as required by law.
• Pressure gauges should be reviewed regularly
are placed, display the date of
to assess whether extinguishers have sufficient
their latest inspection, and are IV.A.23.05 Facility has other firefighting equipment like such as sand
pressure. The pressure gauge indicator should
mounted on walls and columns buckets, fire hoses, fire hydrants, and sprinkler systems as
be in the fully charged zone.
throughout the facility so that required by law.
they are clearly visible and • There should not be missing extinguishers
accessible to workers in all areas. IV.A.23.06 Facility meets all other requirements related to firefighting where signs indicate they should be available.
equipment.
• Operating instructions are posted
beside fire extinguishers. IV.A.23.07 Facility's fire extinguishers are regularly charged.
IV.A.23.08 Facility's fire extinguishers/other firefighting equipment are

regularly checked and maintained.
IV.A.23.09 Firefighting equipment displays the date of their last

inspection.
IV.A.23.10 Facility maintains clear access to firefighting equipment.
IV.A.23.11 Facility trains workers regularly in the use of firefighting

equipment.
IV.A.23.12 Firefighting equipment training records are available.
IV.A.23.13 Firefighting equipment training records are complete and up

to date.
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132
IV.A.23 Firefighting Equipment
Facility shall provide appropriate firefighting equipment in sufficient number throughout the facility. These shall be maintained in functional condition
at all times
Standard Standard
IV.A.23 IV.A.23.14 Facility meets all other requirements related to firefighting

(CONT) training records.
IV.A.23.15 Instruction to operate firefighting equipment is posted in

local language, next to the equipment.

IV.A.23.16 Facility meets all other requirements related to firefighting
equipment instructions.
IV.A.24 Fire Detection and Alarm Systems
Facility shall have a functional and well maintained alarm system for early emergency warning.
Standard Standard
IV.A.24 • There are sufficient fire detection IV.A.24.01 Fire alarms are installed in the facility Guidance
and alarm systems throughout • Addressable smoke detectors refer to detectors
all areas of the facility (including IV.A.24.02 Facility's fire alarm is sufficiently audible. that are connected to a panel which is in the

canteen, dining areas, etc.) that control room, and indicates the location where
can be heard by all workers and IV.A.24.03 Facility's fire alarm has its own unique sound.
the smoke has been detected. It also triggers off
are visible in noisy areas a fire alarm
IV.A.24.04 Facility does not use the public address (PA) system as a fire
• There is a proper smoke & heat alarm. • Even when not required by law, addressable
detection system that covers the smoke detectors are considered a best practice.
entire facility where required IV.A.24.05 Facility's fire alarms are regularly inspected and maintained.
by law.
• Addressable smoke detectors are IV.A.24.06 Facility's notification system or button to sound the alarm is
connected to fire alarm, where clearly marked.
required by law
IV.A.24.07 Facility has visible fire alarm in areas where workers are
• There is a PA (Public Address) required to wear hearing protection.
system covering the entire
facility premises where required IV.A.24.08 Facility's fire alarms have a back-up electrical system.
by law.
IV.A.24.09 Facility has installed a public address system where required
by law.
IV.A.24.10 Facility has installed an addressable smoke detector system

where required by law.
IV.A.24.11 Facility meets all other requirements related to smoke

detectors and public address systems.
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134
IV.A.25 Emergency Procedures and Evacuation Drills
Facility shall have an Emergency response system and team with defined responsibilities. Emergency evacuation drills shall be conducted and recorded.

IV.A.25 • Facility shall have an Emergency response system and team IV.A.25.01 Facility has a designated emergency response team with
with identifiable trained first aid and fire-fighting personnel. assigned roles in case of any emergency.
The team shall be adequately trained on emergency response,
responsible for alerting workers, fire-fighting, and assisting in IV.A.25.02 Facility provides identification badges/bands/dress to the
evacuation. emergency response team personnel (firefighting trained
people/first aid trained people).
• There are exit route diagrams/ evacuation plans for each work

area and the diagrams are kept updated. Facility has an emergency telephone number(s) posted near
IV.A.25.03
• Evacuation drills are conducted at least twice per year per the or on telephones.
evacuation plan and cover all shifts. Drills are conducted more
frequently if required by law or where worker turnover is high, IV.A.25.04 Machinery/equipment has an automatic power-off button to
or if there are significant seasonal fluctuations in the size of the immediately shut off electrical power in case of emergency.
workforce.
IV.A.25.05 Facility's exit route diagrams/evacuation plans are posted.
• Emergency systems, such as the alarm and PA, are regularly
monitored and are tested in conjunction with evacuation drills. Facility's exit route diagrams/evacuation plans are up to date
IV.A.25.06
• There are records of drills which include, at a minimum, the and reflect the actual floor layout.
number of workers evacuated, length of time workers were
evacuated, issues encountered, and corrective action plan for IV.A.25.07 Facility's exit route diagrams/evacuation plan is complete.
those issues encountered, or any other information as required
by law. IV.A.25.08 Facility meets all other requirements related to exit route
diagrams/evacuation plans.
IV.A.25.09 Facility conducts evacuation drills at least twice per year or

more frequently if required by law or if there is high worker
turnover.
IV.A.25.10 Facility's evacuation drill covers all shifts.
IV.A.25.11 Facility meets all other requirements related to evacuation

drills.
IV.A.25.12 Facility keeps an evacuation/emergency drill log.
IV.A.25.13 Facility’s evacuation drill log is complete.

IV.A.26 Building Safety
Facility complies with all applicable laws regarding structural safety. Facility takes all steps to ensure that building housing the facility is structurally safe
and well maintained.

IV.A.26 • Facility has all legally applicable approvals required, including: IV.A.26.01 Facility complies with the country's structural safety laws.
– Generator installation permission

IV.A.26.02 Facility has generator installation permission if required by
– Occupancy certificate
law.
– Storage permit for petroleum storage inside facility
– Building approval documents for structural safety IV.A.26.03 Facility has a building occupancy certificate if required by
law.
– Floor layout plan
IV.A.26.04 Facility has a permit for petroleum storage inside facility if
• Floor load plan shall be maintained and made available on
required by law.
request
• All carrying pipes (i.e. gas, hot/cold water, steam etc.) have IV.A.26.05 Facility has building approval documents for structural
appropriate warning markings. Appropriate markings may safety if required by law.
include color-coded pipes or labels in the local language.
• Vertical or horizontal bracing is in place to safeguard against IV.A.26.06 Facility has floor layout plan approval if required by law.
earthquakes or other natural disasters, where required by law.
IV.A.26.07 Facility meets all other requirements related to required
• All non-structural elements, such as racks, are anchored to
approvals/certificates/licenses.
safeguard against earthquakes, where appropriate, where
required by law. IV.A.26.08 Floor load plan is available on request.
IV.A.26.09 Facility posts warning signs on exposed hot water and steam
pipes.
IV.A.26.10 Facility's accessible hot water pipes/steam pipes are

insulated.
IV.A.26.11 Vertical or horizontal bracing is in place to safeguard against

earthquakes or other natural disasters, where required by
law.
IV.A.26.12 Non-structural elements, such as racks, are anchored to

safeguard against earthquakes, where appropriate, where
required by law.
135
136
IV.A.27 Electrical Safety
Facility shall comply with all applicable laws regarding electrical safety. Electrical boards, panels, wiring, circuit breakers etc. shall be ade-
quately marked and protected.

IV.A.27 • Facility shall comply with all applicable laws IV.A.27.01 Facility complies with the country's electrical safety laws.
regarding electrical safety.
• Electrical switches and circuit breakers (e.g. IV.A.27.02 Facility has warning labels on electrical equipment.
SDB, DB) are labelled.
IV.A.27.03 Facility's electrical panel doors are securely closed.
• High voltage electrical equipment, electrical

circuit panels and cut-off switches shall be IV.A.27.04 Facility's electrical wiring/boards and panels are insulated in
clearly marked with warning labels. non-flammable material.
• Electrical boards and panels are insulated in
non-flammable material, and there are no loose IV.A.27.05 Conduit, junction boxes, outlets and switches are covered
or hanging wires. Electrical panels shall be kept with cover plates (electrical guards).
securely closed and accessible at all times.
IV.A.27.06 Facility's electrical wirings are intact.
• Wiring may not cross walkways.
• Electrical circuits are not overloaded and do IV.A.27.07 Facility maintains clear access to control panels.
not show indication of overheating or signs of
burning. IV.A.27.08 Facility meets all other requirements related to control
panels.
• Electrical equipment is periodically inspected
by trained personnel and by an external
IV.A.27.09 Facility's electrical wiring does not put workers in an unsafe
authority where required by law.
working condition.
• The electrical substation room is separated by
required fire rated construction. IV.A.27.10 Electrical circuits show no indication of overheating and
• There is a lightning protection/ arrestor system burning due to overloading.
installed on the building, if required by law.
IV.A.27.11 Electrical equipment is inspected and maintained
periodically.
IV.A.27.12 Electrical equipment inspection and maintenance is carried

out by competent/authorised people.
IV.A.27.13 Facility does not conduct maintenance on live electrical

equipment.
IV.A.27.14 The electrical sub-station construction is in compliance with

legal requirements of fire-rated construction.
IV.A.27.15 Lightning protection/arrestor system is installed on the

building as required by law.
IV.A.27.16 Facility meets all other requirements related to electrical

guards.
IV.B Dormitory
Facilities that provide housing for workers shall keep these facilities clean and safe.
IV.B.01 Health and Safety

Dormitory facilities meet all applicable laws and regulations related to health and safety, including fire safety, sanitation, risk protection, and electrical
mechanical and structural safety.
Standard Standard

IV.B.01 Dormitory facilities shall meet all IV.B.01.01 Facility complies with country's dormitory health & safety
applicable laws and regulations laws.
related to health and safety
including fire safety, sanitation, IV.B.01.02 Facility complies with country's dormitory sanitation laws.
risk protection, and electrical
IV.B.01.03 Facility complies with country's dormitory fire safety laws.
mechanical and structural safety.
IV.B.01.04 Facility complies with country's dormitory risk protection

laws.
IV.B.01.05 Facility complies with country's dormitory electrical safety

laws.
IV.B.01.06 Facility complies with country's dormitory mechanical safety

laws.
IV.B.01.07 Facility complies with country's dormitory structural safety

laws.
137
138
IV.B.02 Exits, Emergency Lighting and Fire Alarm
There are at least two clearly marked exits on each floor and emergency lighting is installed in halls, stairwells and above each exit.
Standard Standard
IV.B.02 There are at least two clearly IV.B.02.01 Facility's sleeping quarters have two well-lit exits on each
marked exits on each floor and floor.
emergency lighting is installed in
halls, stairwells and above each exit. IV.B.02.02 Facility's sleeping quarters have a sufficient number of exits.
IV.B.02.03 Facility's sleeping quarters' exit doors are clearly marked.

IV.B.02.04 Facility's outdoor assembly areas are located at a safe
distance from the building and/or away from emergency
vehicle traffic and activities.
IV.B.02.05 Facility's sleeping quarters' emergency lights are well-

maintained.
IV.B.02.06 Facility's sleeping quarters have enough emergency lights on

each floor.
IV.B.02.07 Facility's sleeping quarters have enough emergency lights in

stairwells.
IV.B.02.08 Facility's sleeping quarters have fire alarms installed on each

floor.
IV.B.02.09 Fire alarms in facility's sleeping quarters are regularly

maintained.
IV.B.02.10 Facility has electrical guards for electrical panel in facility's

dormitory.
IV.B.02.11 Facility meets all other requirements related to exits,

emergency lights and fire alarms.
IV.B.03 Clear Halls and Exits
Hall and exits are kept clear of obstruction for safe and rapid evacuation in case of fire or other emergencies.
Standard Standard
IV.B.03 Hall and exits are kept clear of IV.B.03.01 Facility maintains clear exit routes in sleeping quarters.
obstruction for safe and rapid
evacuation in case of fire or other IV.B.03.02 Facility's sleeping quarters have unobstructed exits.

emergencies.
IV.B.03.03 Facility's sleeping quarters' outside stairs and exit paths are
well-maintained.
IV.B.03.04 Facility meets all other requirements related to dormitory

exits and exit paths.
IV.B.04 Posted Evacuation Directions

Directions for evacuation in case of fire or other emergencies are posted in all sleeping quarters.
Standard Standard
IV.B.04 Directions for evacuation in case of IV.B.04.01 Facility posts evacuation directions in sleeping quarters.
fire or other emergencies’ are posted
in all sleeping quarters IV.B.04.02 Facility's sleeping quarters' evacuation diagrams are clear.
IV.B.04.03 Facility's sleeping quarters' evacuation diagrams are in the

local language.

emergency evacuations.
139
140
IV.B.05 Fire Extinguishers
Dormitory facilities shall ensure adequate and accessible fire extinguishers are installed.
Standard Standard
IV.B.05 Dormitory facilities shall ensure IV.B.05.01 Facility provides sufficient fire extinguishers in their sleeping
adequate and accessible fire quarters.
extinguishers are installed.
IV.B.05.02 Fire extinguishers in the sleeping quarters are readily
accessible.
IV.B.05.03 Facility regularly checks fire extinguishers in their sleeping

quarters.
IV.B.05.04 Facility's fire extinguishers in their sleeping quarters are fully

charged.
IV.B.05.05 Facility has a sufficient number of workers trained in the

usage of fire extinguishers in their sleeping quarters.

fire extinguishers.
IV.B.06 Fire Fighting Equipment

Fire hydrant and other fire fighting equipment, if required by law, shall be installed and properly maintained.
Standard Standard
IV.B.06 Fire hydrant and other firefighting IV.B.06.01 Fire hydrant/other firefighting equipment are available at
equipment, if required by law, each floor of dormitory if required by law.
shall be installed and properly
maintained. IV.B.06.02 Fire hydrant/other firefighting equipment are well-
maintained.

fire hydrants/other firefighting equipment.
IV.B.07 Fire Drills and Evacuation Drill Log
Fire drills shall be conducted at least once every six months. With appropriate documents maintained.
Standard Standard
IV.B.07 • Fire drills shall be conducted at IV.B.07.01 Facility conducts evacuation drills in the dormitories every Guidance
least every six months. six months. Dormitory fires may occur at night when the
• Facility shall keep an Evacuation workers are asleep. In the smoke and darkness, it

IV.B.07.02 Facility keeps an evacuation drill log for their dormitory.
Drill Log to record (e.g. photos, may be harder to leave the building quickly, and
date of evacuation drill, length workers may be disoriented from being woken up.
IV.B.07.03 Facility dormitory's evacuation drill log is complete.
of time it took to complete the For these reasons, it is especially important to have
evacuation, number of workers’ IV.B.07.04 Facility dormitory has emergency telephone numbers posted. fire drills, so workers will know how to exit quickly
participate and areas for and safely.
improvement etc.) IV.B.07.05 Facility meets all other requirements related to dormitory
• Emergency telephone numbers evacuation drills.
- fire, police, ambulance
service and hospitals - shall be
posted prominently near or on
telephone in the dormitory.
IV.B.08 Electrical Safety

Electrical Safety
Standard Standard
IV.B.08 • Electrical switches and circuit IV.B.08.01 Dormitory has warning labels on electrical equipment.
breakers (e.g. SDB, DB) are
labelled. IV.B.08.02 Dormitory's electrical wirings are intact.
• Electrical boards and panels are
IV.B.08.03 Dormitory’s electrical panel doors are securely closed.
insulated in non-flammable
material, and there are no loose Dormitory's electrical wiring is insulated.
IV.B.08.04
or hanging wires. Electrical
panels shall be kept securely IV.B.08.05 Conduit, junction boxes, outlets and switches are covered
closed at all times. with cover plates (electrical guards),
• Wiring may not cross walkways.
electrical equipment.
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142
IV.B.09 Yellow Box or Markings
Yellow box shall be painted at all areas of fire extinguishers or control panel to indicate the areas shall be kept free and without obstruction.
Standard Standard
IV.B.09 Yellow box shall be painted at all IV.B.09.01 Yellow boxes are painted at the areas of fire extinguishers or
areas of fire extinguishers or control control panels to indicate the areas should be kept free and
panel to indicate the areas shall be without obstruction.
kept free and without obstruction
IV.B.09.02 Yellow boxes painted in the dormitory are clearly marked.
Facility meets all other requirements related to dormitory

IV.B.09.03
electrical safety.
IV.B.10 First Aid Kit

Well-stocked first aid kit shall be provided in dormitory.
Standard Standard
IV.B.10 Well-stocked first aid kits shall be IV.B.10.01 First aid kit is available in the dormitory.
provided in dormitory
IV.B.10.02 First aid kit in the dormitory is well-stocked.
IV.B.10.03 Sufficient first aid trained people are available in the

dormitory.
IV.B.11 Dormitory Location

Dormitories are separate from any production or warehouse facility.
Standard Standard
IV.B.11 Workers dormitory is required to IV.B.11.01 Dormitories are segregated from production and warehouse
be segregated from production or areas.
warehouse to meet all applicable
rule and regulation related to fire
safety requirements.
IV.B.12 Segregated Hazard and Combustible Material
Hazardous and combustible materials used in the production process are not stored in the dormitory.
Standard Standard
IV.B.12 Segregated Hazardous and IV.B.12.01 Facility's fuel tank is located at a safe distance from the
Combustible Material from dormitory.
Dormitory

IV.B.12.02 Facility's production boilers are located at a safe distance
• Facility’s fuel tank is not located from the dormitory.
inside the dormitory.
• Facility’s production boilers are IV.B.12.03 Facility does not store unfinished work/packing material in
not located inside the dormitory. the dormitories.
• Facility shall not store their
IV.B.12.04 Facility meets all other requirements related to hazardous
unfinished work in the
and combustible materials.
dormitories.
• Facility shall not store packing
materials in the dormitories.
IV.B.13 Free Access

Dormitory residents are free to come and go during their off-hours under reasonable limitations imposed for their safety and comfort. Such limitations
may not prohibit workers from entering or exiting the dormitory at any time.
Standard Standard
IV.B.13 For dormitories on facility grounds, IV.B.13.01 Facility gives workers the freedom to leave or return to Frequently Asked Question
workers are free to come and dormitory grounds during off-hours. How do we establish a “reasonable curfew”?
go during their off hours up to a
IV.B.13.02 Facility’s dormitory curfew is reasonable. Most facilities impose certain limitations on hours
reasonable time at night, unless
and visitors. The issue is not whether there are
prohibited by law.
IV.B.13.03 Facility meets all other requirements related to free access to limitations, but whether such limitations are
dormitory. reasonable. Their aim should be the legitimate
safety of the residents as opposed to physical or
psychological coercion to make the workers work
longer or harder.
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144
IV.B.14 Separate Rooms by Gender
Sleeping quarters are segregated by gender.
Standard Standard
IV.B.14 Separate rooms shall be provided for IV.B.14.01 Facility separates their sleeping quarters by gender.
men and women
IV.B.14.02 Sleeping quarters provide sufficient privacy to workers
IV.B.14.03 Facility meets all other requirements related to separate

sleeping quarters.

IV.B.15 Sanitation
All areas in the dormitory shall be clean and well maintained.
Standard Standard
IV.B.15 All areas in the dormitory shall be IV.B.15.01 Good housekeeping is maintained in all areas of the
clean and well maintained. dormitory.
IV.B.15.02 Pest control is performed regularly in the dormitory.
IV.B.16 Sufficient Space

There is sufficient living space per worker in the sleeping quarters, which at a minimum, meets both the minimum legal requirement and the local
industry standard.
Standard Standard
IV.B.16 • There shall be enough space for IV.B.16.01 Facility provides the legal minimum and industrial standard
workers to exit safely in case living space in the sleeping quarters.
of an emergency and to move
between the mats or beds. IV.B.16.02 Facility provides sufficient exit space in the sleeping quarters.
• Living space per worker in the
IV.B.16.03 Facility meets all other requirements related to sufficient
sleeping quarters meets both the
space in dormitories.
minimum legal requirement and
the local industry standard.
IV.B.17 Laundry
There is sufficient space provided to dry clothes and belongings in the open air.
Standard Standard
IV.B.17 Facility shall provide facilities for IV.B.17.01 Facility provides easy and safe access to facilities for washing
washing and drying clothes, or if and drying clothes.
such facilities are outside of the

facility grounds shall be easily and IV.B.17.02 Facility meets all other requirements related to laundry
safely accessible. facilities in dormitories.
IV.B.18 Worker Storage Space

Workers are provided a private and secure storage space, such as a locker, for valuable personal belongings.
Standard Standard
IV.B.18 There shall be space for workers to IV.B.18.01 Facility provides personal storage areas.
safely store or hang their clothes,
passports and other personal IV.B.18.02 Facility's personal storage areas are secure.
possessions. Facilities shall provide
locked and secure storage space IV.B.18.03 Facility meets all other requirements related to personal
for workers’ possessions if workers storage space.
request it.
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IV.B.19 Bare Floors and Personal Mats
Workers are provided their own individual mats or beds, which are exclusively theirs for the time period that they are employed by the facility.
Standard Standard
IV.B.19 In some countries, people may IV.B.19.01 Facility provides individual mats or beds in the sleeping
prefer to sleep on mats or quarters.
mattresses on the floor rather
than in beds. Although this is in IV.B.19.02 Facility's workers are not sleeping on bare floors in the
compliance with Gap Inc.’s COVC, sleeping quarters.
workers shall not sleep on the bare
IV.B.19.03 Facility meets all other requirements related to personal

floor, and there shall be a sleeping
mats.
mat between their bodies and the
floor.
Workers shall not be required to

share their mats, mattresses or beds
with other workers.
IV.B.20 Sufficient Toilets and Showers

Sufficient toilets and shower are segregated by gender and provided in safe, sanitary, accessible and private areas.
Standard Standard
IV.B.20 The number of toilets and showers IV.B.20.01 Facility dormitory maintains sufficient and private toilet and
shall be adequate for the worker bathing facilities.
populace.
IV.B.21 Toilet Sanitation
Toilets shall be clean, sanitary, functioning and well maintained.
Standard Standard
IV.B.21 Toilets shall be clean, sanitary, IV.B.21.01 Facility dormitory's toilet facilities are cleaned on a regular
functioning and well maintained. basis.

IV.B.21.02 Facility dormitory's toilets are functioning.
IV.B.21.03 Dormitory toilets have locally acceptable supplies (buckets of

water/toilet paper/covered trash bin/soap etc.).
IV.B.21.04 Dormitory toilets are easily accessible and not kept locked.
IV.B.21.05 Facility's bathing facilities are clean.
IV.B.21.06 Facility's bathing facilities are functioning.
IV.B.21.07 Both hot and cold water are provided.
IV.B.21.08 Toilet/shower areas are well maintained.
IV.B.22 Privacy
Toilets and showers shall be in covered areas and shielded from view by those outside these areas.
Standard Standard
IV.B.22 Toilets and showers shall be in IV.B.22.01 Toilets and showers located outside the dormitory are
covered areas and shielded from covered and shielded.
view by those outside these areas.
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IV.B.23 Toilets by Gender
In larger dormitories where there are multiple toilets in one bathroom, the bathrooms shall be segregated by gender and clearly marked.
Standard Standard
IV.B.23 • In larger dormitories where IV.B.23.01 Facility dormitory's toilets are segregated and marked.
there are multiple toilets in one
bathroom, the bathrooms shall IV.B.23.02 Facility's bathing facilities are segregated by gender and
be segregated by gender and marked.
clearly marked
• In smaller dormitories that
toilets and bathing facilities.

may have only one toilet per
bathroom, both men and women
may share the room, one at a
time.
IV.B.24 Kitchen Facilities

Kitchen facilities or facilities used for food preparation, such as sinks, shall be separate from the toilet and shower area.
Standard Standard
IV.B.24 Kitchen facilities or facilities used IV.B.24.01 Facility's kitchen facilities or facilities used for food
for food preparation, such as sinks, preparation are separated from the toilet and bathing
shall be separate from the toilet and facilities.
shower area.
IV.B.24.02 Facility maintains updated medical check-up records/fitness
certificate for canteen workers who handle food.
IV.B.24.03 Eating area is appropriately covered and protected from

elements (rain/ heat/ cold etc.).
IV.B.24.04 Eating area has adequate infrastructure like table, chairs.
IV.B.24.05 Adequate facilities such as utensils/drinking water/hand

wash/ dust bins are provided in the eating area.
IV.B.25 Dormitory Conditions (Electricity, Temperature and Ventilation)
Dormitory facilities are well ventilated. There are windows to the outside or fans and/or air conditioners and/or heaters in all sleeping areas for ade-
quate circulation, ventilation and temperature control.

IV.B.25 Electricity IV.B.25.01 Facility's sleeping quarters have sufficient ventilation.
• Electricity shall be available in case ill workers remain

IV.B.25.02 Residents in the sleeping quarters have the ability to adjust
in the dormitory.
the temperature in living area or have sufficient resources to
• Facilities shall not turn off electricity to prevent workers be comfortable.
from returning to their rooms.
Temperature IV.B.25.03 Electricity is never suspended to prevent workers from
returning to their rooms.
• The temperature of the rooms and common areas shall
generally be of a comfortable level to the residents. IV.B.25.04 Facility meets all other requirements related to dormitory
• Residents shall have the ability to adjust the ventilation, electricity and temperature control.
temperature or receive sufficient resources to be
comfortable.
Ventilation
• Dormitory facilities are well ventilated.

• If sleeping quarters do not have a window to the
outside (not to the hall or other internal space), then
they shall have fans or air conditioners for circulation
and ventilation.
IV.B.26 Sufficient Lighting

Dormitory facilities have adequate lighting.
Standard Standard
IV.B.26 There shall be adequate lighting in IV.B.26.01 Facility dormitory provides sufficient lighting.
the sleeping rooms as well as in the
common areas, such as corridors, IV.B.26.02 Facility dormitory's lighting is functioning.
stairwells, bathrooms, kitchens, etc.
IV.B.26.03 Facility meets all other requirements related to facility
dormitory's lighting.
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IV.B.27 Water
Potable water or facilities to boil water are available to dormitory residents.
Standard Standard
IV.B.27 Potable Water IV.B.27.01 Facility provides potable water in the dormitories on all
floors in sufficient quantity.
• Potable water shall be available

throughout the day and night in Facility dormitory's water containers are cleaned on a regular
IV.B.27.02
the dormitory. basis and kept free from contamination.
• Water shall be cooled or heated
as required to make it suitable IV.B.27.03 Facility meets all other requirements related to potable water

for drinking. and water containers.
Water Containers
• Water containers shall be cleaned

regularly and kept free from
contamination.
V. Management Systems
Facilities shall establish sustainability management systems designed with appropriate operational controls to ensure compliance with applicable laws, regulations,
and the COVC. Management systems shall identify and control sustainability risks, and facilitate continuous improvement.
V.A Company Statement and Management Oversight

Facility has a written statement confirming its commitment to sustainability and to continuous improvement (as embodied in relevant laws and the
COVC). There is a senior manager or management team with designated responsibility for overseeing implementation of effective labor management

systems, and for ensuring that the facility meets COVC and legal requirements.
Standard Standard
V.A.01 • The company statement shall originate from the V.A.01.01 The facility has a written statement Frequently Asked Questions
highest level of management at the facility (or from from top management outlining its Does my facility need a separate management
the corporate or parent company level). commitment to sustainability. system for sustainability?
• The statement shall commit to meeting sustainability
V.A.01.02 The statement is communicated No. An efficient way to apply a management
and ethical conduct requirements as described by
to workers through an appropriate systems approach to meeting sustainability
relevant laws and the COVC.
mechanism. standards is to use your current business
• The statement shall include a commitment to management system. For example, every facility
continuous improvement. needs to hire workers. In order to avoid child labor,
• The statement shall be communicated to the discrimination, forced labor and other issues in
workforce using at least one of the following hiring, you should evaluate your current processes
mechanisms: posting the statement in a prominent for recruitment, selection and hiring of workers
location written in a language(s) workers to make sure you have the right controls in place.
understand, inclusion in the employee handbook, or Once you have put the necessary controls in place
communication during worker orientation training. you will need to do regular checking (monitoring)
to be sure they are effective.
V.A.02 A senior manager or management team shall be V.A.02.01 The company has a senior manager/
assigned the role for implementation of management management representative assigned
systems to meet legal and sustainability requirements. to implementing management systems
related to sustainability.
Part 2: Provisions & Standards Section V: Management Systems

151
152
V.B Management Responsibility and Worker Feedback
Responsibilities for meeting sustainability requirements (as described by laws and the COVC) are defined for management and supervisory personnel.
Roles for workers are also defined, and workers must have access to mechanisms to provide feedback on practices related to the COVC and to facilitate
continuous improvement.
Standard Standard
V.B.01 Management & Worker V.B.01.01 Roles for sustainability management systems Frequently Asked Question
Responsibility implementation are defined for management and Won’t a management system require a lot of
supervisory personnel. documentation and other complexity?
• Roles for sustainability
management systems

V.B.01.02 Workers roles for sustainability management systems are This is a very common concern, but a labor
implementation shall be defined. management system does not need to be any more
defined for all management and formal or complex than the system you use to
supervisory personnel. manage your business. For example, a procedure
• Workers’ roles within the can be as simple as a short list of what is to be
management systems shall be done, by whom, and how often. As for records,
defined. you only need to maintain items that are needed
to verify that you are meeting standards, such as
V.B.02 Worker Feedback V.B.02.01 Facility has a mechanism to obtain feedback from workers proof of age documents, training materials and
on sustainability management systems. attendance records, working hours and payroll
• Workers must have access to
documentation, and management meeting
mechanisms to provide feedback
on their roles in management minutes. You’re probably already maintaining
systems implementation much of this documentation.
to facilitate the continuous
improvement process.
Mechanisms may include, but
are not limited to, suggestion
boxes, worker surveys, focus
group meetings, discussions with
worker or union representatives,
or worker-management dialogue
sessions.
V.C Risk Assessment Process
There is a risk assessment process in place that identifies legal and COVC risks associated with facility operations. The process covers significant risks,
and results in implementation of appropriate procedural controls to ensure mitigation of identified risks.
Standard Standard
V.C.01 Risk Assessment V.C.01.01 Facility has a risk assessment process for legal and Frequently Asked Questions
sustainability risks. Why do management systems fail?
• Facilities shall have an annual

risk assessment process that Facility's risk assessment process is functional, implemented, There can be many reasons, but are usually related
V.C.01.02
regularly identifies and reviews and updated regularly. to a lack of senior management commitment;
legal and sustainability risks that failure to assign a senior manager with
are relevant to facility operations. responsibility and accountability for implementing
• The process shall review risk the systems; a facility tries to create a system
areas and determine the facility’s that is more complicated than their current
compliance level or vulnerability business management systems; management
to these risks. believes that the social compliance objectives of
• The process shall result in the systems will conflict with business objectives;
controls to mitigate identified the systems create extra or duplicate work that
risks. management believes does not add any value and
is not integrated into day-to-day operation of the
business; or senior management fails to regularly
measure and review the effectiveness of the
systems and make necessary improvements.
Where can I get more information on risk

assessment tools and protocols?
Please see Appendix 15 sections A-F for more

information.

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154
V.D Management and Worker Trainings
Facility has management and worker training programs that support effective implementation of sustainability management systems and meeting of
legal and COVC requirements.
Standard Standard
V.D.01 Training V.D.01.01 Facility has a mechanism to assess training needs.
• There are defined mechanisms

V.D.01.02 Facility's training materials are available and up to date.
to assess training needs, define
who receives it and how often, V.D.01.03 Facility's training process is functional, implemented, and
and to ensure that management, updated regularly.

staff, and workers are equipped
with the knowledge and skills V.D.01.04 Facility's training records are available and up to date.
necessary to carry out their work
effectively in a socially compliant
manner.
• Through orientation, ongoing
trainings, and other means of
communication, the facility
clearly communicates its policies
and procedures to appropriate
workers and staff.
• Training content shall cover all
aspects of the COVC.
• Training records, including
attendance and training
materials, shall be documented.
• Refresher training shall be
provided in the event there is
a significant chance in policies,
objectives, and procedures.
V.E Performance Objectives and Targets
There are performance objectives, targets, and implementation plans for sustainability management systems. These must be complimented by a man-
agement and internal review process to assess and monitor performance against sustainability requirements, and to effectively correct issues when
they arise and adjust objectives and targets when these are off track.

V.E.01 Objectives and Targets V.E.01.01 Facility has sufficient objectives and targets related to

sustainability management systems.
• Facilities shall set measurable sustainability objectives,
and targets shall align with identified high risk areas.
• Targets shall always have associated implementation
plans.
• Objectives and targets shall be reviewed at least
annually.
V.E.02 Self-Assessments V.E.02.01 Facility performs internal assessment against COVC

requirements.
• Internal self-assessments shall be performed at least
annually. Facility has sufficient records of its internal assessments.
V.E.02.02
• The assessments shall be conducted by the manager or
team with the defined role for sustainability.
• The criteria for the assessments shall cover the
requirements of local law and COVC requirements.
• Assessment results shall be maintained, with corrective
actions documented where needed.
V.E.03 Management Review V.E.03.01 Facility has a sufficient management review process of
sustainability objectives and targets.
• The management review should be led by the manager
or team with the defined overall role for sustainability.
• Management review must occur at least annually.
• Management review shall include reviewing
performance against objectives, measuring success, and
setting new targets for the next year, with a view to
continuous improvement.

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Part 3:
Appendix
CONFIDENDIAL DO NOT DISTRIBUTE 157

Appendix 1:
Glossary of Terms
Allowances An amount provided by a facility, usually in addition to
remuneration, such as money, given at regular intervals or for a
specific purpose. Some allowances are required by law, others are
voluntary provided by facilities. Some examples of allowances
include: transportation and meals.
Apprentice See Trainee.
Announced An assessment for which facilities are contacted prior to the

Assessments assessment in order to:
1) Set a mutually acceptable date and time to conduct the
assessment;
2) Ensure they have been informed of when the assessment will
take place only as a courtesy. Facilities are aware of what they will
be assessed against during announced assessments.
Benefits Compensation paid to employees in addition to remuneration

(wage/salary). Benefits can be classified as legal when stipulated
by laws such as overtime, holiday or vacation pay. Companies can
also provide voluntary benefits, which are not required by law,
such as loans or food baskets.
Bonded Labor (Or An illegal practice in which workers work at low wages to pay off
Bondage) the debt provided by employers, incurred either individually or as
an entire family.
Brushing Finishing activity by which a garment is brushed either manually

of by a machine to obtain a “used” look.
Bulk Chemicals Chemicals that are stored in quantities over 50 gallons/190 litres
(either in one drum or a combined total).
Business Insurances Protection against loss for which a company pays a certain sum
periodically in exchange for a guarantee that the company will be
compensated under stipulated conditions for any specified loss by
fire, accident, death, etc. Legally required business insurances vary
by country.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 1: Glossary of Terms 159

Business License A legal document that grants the requestor the right to operate
a business in the respective city. Depending on the country and
the business, there are other licenses that may also be required.
Synonyms: Business registration
Business Permits A legal document that offers proof of compliance with certain city
or state laws regulating structural appearances and safety as well
as the sale of products, like fire department permits, wastewater
discharge permits, etc.
Centrifugal Machines used in laundries to extract water from garments by

Extractors spinning at tremendously high G forces (G = the pull of gravity).
Change Analysis Anytime something new is brought into the workplace, whether
it is a piece of equipment, different materials, a new process, or
an entirely new building, new hazards may unintentionally be
introduced. Before considering a change for a worksite, it should
be analysed thoroughly beforehand. Change analysis helps in
heading off a problem before it develops.
Chemicals “Chemicals” is a common term that describes many different

solids, liquids and gases that are used to produce specific
effects on other substances. For the purposes of a Gap’s COVC,
“chemicals” include substances that may be present in facilities
such as paint, oil, degreasers, spot removers and solvents. It
also includes specialist laundry and dying chemicals used in
wet finishing facilities and mills, such as detergents, softeners,
surfactants, oxidizers and bleaching agents. Gap Inc.’s COVC
requires that all chemicals at a facility site have Material Safety
Data Sheets.
Child Labor Refers to any work by a child or young person, younger than the
age of 15 or below the minimum work age required by law, if such
age is above 15, which does not comply with the provisions of the
relevant ILO standards, or is likely to be hazardous or to interfere
with the child's or young person's education, or to be harmful to
the child's or young person's health or physical, mental, spiritual,
moral or social development.
Child Any person less than 15 years of age unless local minimum age
law stipulates a higher age for work or mandatory schooling, in
which case the higher age shall apply. If however, local minimum
age law is set at 14 years of age in accordance with developing
country exceptions under ILO Convention No. 138, the lower will
apply.

Closed Shop A provision in a collective agreement whereby all employees in a
bargaining unit must be union members in good standing before
being hired, and new employees must be hired through the union.
Coercion Is the practice of compelling a person to involuntarily behave

in a certain way (whether through action or inaction) by use of
threats, intimidation or some other form of pressure or force.
Coercion may typically involve the actual infliction of physical or
psychological harm in order to enhance the credibility of a threat.
The threat of further harm may then lead to the cooperation or
obedience of the person being coerced.
Collective An agreement negotiated between a group of employees (often

(Bargaining) a trade union) and an employer that sets forth the terms of
Agreement employment for the employees who are members of that group
of employees. This type of agreement may include provisions
regarding wages, vacation time, working hours, working
conditions, and health insurance benefits.
Collective Negotiations between an employer and a group of employees

Bargaining that determine the conditions of employment. The result
of collective bargaining procedure is called the collective
(bargaining) agreement. Often employees are represented in the
bargaining by a trade union or other labor organization.
Confined Spaces Confined spaces are enclosed or semi-enclosed areas in which a

worker could become locked or where there is not significant air
flow. This may include fuel tanks, dye machines, belly washers,
dryers, hoppers, or pits that an employee might enter during
maintenance or repair activities.
Deductions An amount or percentage deducted from worker’s pay. These

deductions vary widely by facility but could include housing,
loans, etc.
Development Instructional programs and/or experiences designed to help

employees become more efficient, professional workers, or to
equip them with the knowledge and skills that improve career
advancement opportunities.
Discharge Release of liquid effluent from a facility to chemical emissions

into the air through designated venting mechanisms.
Disciplinary Actions used by managers or supervisors to change the behavior

Practice of employees.

Discrimination Treatment or consideration based on class or category rather
than individual merit; partiality or prejudice. For the purposes of
Gap Inc.’s COVC discrimination includes practices that use race,
color, gender, nationality, religion, age, maternity, marital status,
indigenous status, social origin, disability, sexual orientation, and/
or membership in workers’ organizations including unions, or
political affiliation, as a basis for employing and paying and not a
person’s ability to perform a job.
Employee A document that includes information that employees may need

Handbook to refer to frequently in order to meet the terms and conditions of
their employment.
Employment An agreement entered into between an employer and an

Contracts employee at the time the employee is hired that outlines the
exact nature of their business relationship, specifically what
compensation the employee will receive in exchange for specific
work performed.
Employment Facilities should only hire individuals who are defined, by law,
Eligibility as eligible for employment, thus all individuals are required to
provide documentary evidence of employment eligibility (it would
vary by country) at the time of hire.
Environmental A situation created by an accidental release or spill of hazardous

Emergency substances (wastewater, chemicals, etc.) that poses a threat to
the safety of workers, residents, the environment, or property.
Environmental A management system is a set of interrelated elements used to

Management establish policy and objectives and to achieve those objectives. An
System (EMS) environmental management system must consist of:
→→ Environmental policy
→→ Planning: environmental risk assessment, setting objectives
and targets
→→ Implementation and operation: operational procedures;
adequate training; documentation and its control
→→ Checking: monitoring and measurement, assessment and
inspections
→→ Management review
Environmental The policy describes the facility’s activities, products, and

Policy services including a commitment to continual improvement
and prevention of pollution, as well as a commitment to comply
with legal and other requirements that relate to the significant
environmental aspects identified for the facility. The policy should
set out the framework for setting and reviewing environmental
objectives and targets.

Exhaust System A device that captures and removes fumes, vapors, dusts, etc.
from an enclosed area (room or building), and eventually takes
it outside to protect the workers therein. Other features such as
exhausters with overspray hoods provide additional coverage.
Exit Interview The formal conversation that takes place between an employee
and an HR or other manager to determine the reason(s) the
employee is leaving.
Exit Route Diagrams Maps detailing exit pathways. Also called: Exit or evacuation plan,
evacuation diagram.
Fine A sum of money required to be paid as a penalty for an offense.
Forced Labor The ILO’s definition of forced labor comprises two basic elements:
the work or service is undertaken involuntarily and it is executed
under the menace of a penalty.
Foreign Contract Is an arrangement by which workers arrive in a foreign country

Labor (FCL) “under contract”, usually with a third –party labor broker to
work at a particular workplace for a specified timeframe. FCL is a
widespread and growing phenomenon worldwide.
Foreign Contract Workers who sign an employment contract to work at a facility

Workers (FCW) outside their home country (used interchangeably with the term
Foreign Contract Labor).
Free Egress Unrestricted right to leave or go out.
Freedom Of The freedom of individuals to associate as an end in itself or

Association with a view to pursuing common projects, e.g. through churches,
trade unions, political parties, and sporting clubs. Freedom of
association (FOA) is a right identified under different international
labor standards including the Universal Declaration of Human
Rights and International Labour Organization Convention C87 and
Convention C98.
Full COVC Initial or Annual assessment that cover all applicable sections of
Assessment Gap Inc. COVC. It follows the Full COVC assessment methodology
and has a greater emphasis on management systems.
General Liability Comprehensive general liability coverage insures a business

against accidents and injury that might happen on its premises
as well as exposures related to its products. (Refer to the Vendor
Compliance Agreement, Insurance section, for specific Gap Inc.
requirements)

Grievance A grievance procedure refers to the steps to be followed in
Procedures resolving complaints from workers arising at work or out of their
work situation concerning both their existing rights, based on the
interpretation and application of existing rules, as well as matters
not currently included in any rules or procedures. The procedure
may be relatively informal, in which case it is purely voluntary and
places no legal obligation on workers or employer. If the parties
agree, however, they could formalize the procedure and make
it binding on both parties by including it as part of a collective
bargaining agreement.
Hazardous Material Any material that poses a threat to human health and/or the
environment. Typical hazardous substances are toxic, corrosive,
ignitable, explosive, or chemically reactive. Synonym: Hazardous
Substance.
Hazardous Work Any work which is likely to jeopardize children’s physical, mental
or moral health, safety or morals. Hazardous work should not be
done by anyone under the age of 18.
Hiring Process The practice of finding, evaluating, and establishing a working

relationship with future employees, interns, contractors or
consultants.
Housekeeping Cleanliness and order necessary for workers to be able to work

(Good) in a safe and healthy environment. It’s understood however
that during the work day there’s going to be some clutter and
disorganization, however exit pathways should always be kept
clear.
Human Resources The department or support systems responsible for personnel

sourcing and hiring, applicant tracking, skills development and
tracking, benefits administration and compliance with associated
government regulations.
Indentured Labor Work, performed by an individual contractually bound to an

employer for a specific time period, which is usually in return for
payment of travel and living expenses. Indentured laborers may
work on behalf of another person’s debt. For example, a child who
works as an indentured laborer to pay off a parent’s debt.
Industry Standard A voluntary, industry-developed or accepted practice established

and defined by authority, custom, or common consent to serve as
a reference, model, or rule.

Internal Compilation of rules set forth by an employer to define work
Regulations guidelines and policies that help employees understand how
the company operates, what is expected of them and in some
instances, what employees can expect from their employer. Also
known as Standing Orders.
Involuntary Labor See Forced Labor
Labeling Systems Methods that establish common and consistent approaches

to chemical hazard classification for the purposes of hazard
communication. It usually includes criteria for classifying
chemical substances and mixtures according to their health,
environmental and physical hazards. Some known systems are
the NFPA diamond system and the HMIS color bar system.
Labor-Only Labor-only contracting is defined as arrangement where the

Contracting contractor or subcontractor merely recruits, supplies or places
workers to perform a job, work or service for a principal, and (a)
contractor or subcontractor does not have substantial capital or
investment relating to job to be performed; or (b) contractor does
not exercise right to control work performance of employee. See
also Subcontracted Employees and Temporary Worker.
Leave Official permission to be absent from work. Leaves could be paid

or unpaid depending on local law and facility voluntary practices.
Some examples of leaves are vacation, sick leave, medical leave,
maternity leave, etc.
Levies Immigration fees.
Lux Unit of illumination, equal to one lumen per square meter or to

the illumination of a surface uniformly one meter distant from a
point of source of one candle.
Material Safety A compilation of information on the identity of hazardous

Data Sheet (MSDS) chemicals, health, and physical hazards, exposure limits, and
recommendations for appropriate human protective measures.
Migrant Worker Is "a person, who is to be engaged, is engaged or has been

engaged in a remunerated activity in a State of which he or she is
not a national".
New And Expectant Is defined as someone who is pregnant, has given birth (including
Mother stillbirth) within the last six months or is breastfeeding.

Non-Governmental An organization that is neither a private or public business, nor
Organization (NGO) a government entity. These organizations take many forms and
have a variety of missions. Often, NGOs must meet certain legal
requirements and be registered with the government to be
officially recognized as an NGO. Sometimes, but not always, the
NGO is also a “not for profit” organization.
Notice Periods The time period that an employer or employee must give,
whatever the reason for the employee leaving. The notice period
will be determined either by law or by the terms of the contract
with the employee.
Overtime Premium Wage paid above the normal daily or hourly wage to compensate
for time worked beyond the normal working schedule. This
premium should be described in a country’s labor laws. Payment
for additional work done outside of regular working hours.
Pat-Downs A practice by which a worker is searched, by passing the hands

quickly over clothes or through pockets.
Personal Protective Safety equipment worn by employees to protect against physical

Equipment (PPE) hazards. Examples of PPE: eyewear, face shields, ear plugs, hard
hats, gloves, foot protection.
Physical Abuse Any act resulting in a non-accidental physical injury, including

not only intentional assault but also the result of unreasonable
punishment.
Piece-Rate A direct performance payment based on production by an

individual worker. A payment is made for each piece or other
quantity unit of work produced by an employee.
Potable Water Water fit for drinking. Potable water may come from many
different sources and may vary by facility. In some facilities,
potable water may come from the faucet; in other facilities,
potable water may come only from bottled water. They key is
whether the water is fit for drinking.
Powered Industrial Any mobile power-propelled truck used to carry, push, pull, lift,
Truck stack or tier materials. Powered industrial trucks can be ridden or
controlled by a walking operator. Commonly known as forklifts,
pallet trucks, tractors, platform lift trucks, motorized hand trucks,
rider trucks, fork trucks and lift trucks.

Prison Labor Refers to arrangements in which prisoners are used as part of the
work force. Under prison labor arrangements, prisoners may be
brought to the facility, or the production may occur in the prison
facilities. Although prisoners may be paid, because they often
have no choice to refuse the work, this is often a kind of forced
labor.
Probation Periods Probation is defined as “the action or process of testing or putting

to the proof”. For probationers, the probation period provides an
opportunity to demonstrate that they are able to do the job to
which they have been appointed. The period is usually defined by
local law. Synonym: Trial periods
Probationary New employee being considered for permanent status. A

Worker probationary employee has no seniority privileges or status and
usually may be discharged without cause.
Psychological In psychological coercion, the threatened injury regards the

Coercion victim’s relationships with other people.
Regular Work Shift This term means both a period of work that has a predetermined
starting and ending time and the regularly scheduled
configuration or pattern of work periods and days off. This
configuration may repeat itself on a weekly, biweekly, or longer-
term basis.
Regular Work Hours The Maximum number of hours set by local law that the workers
can work in a day or week to receive at least the legal basic wage.
Remuneration Payment or compensation received for services or employment.

This includes the base salary and any bonuses or other economic
benefits that an employee received during employment.
Synonym: Salary, wages, compensation.
Requirements Provide specific detail of what should be assessed under each

Code standard.
Return Fee The Return Fee will equal the estimated average recruitment
fees incurred by workers in their home country (as determined
from time to time by Gap Inc. in consultation with workers,
vendors, local NGOs and government authorities as appropriate),
less a pro rata portion based on the actual duration of stay vs.
the contractual term. . For example, if the estimated average
recruitment fees incurred by any worker from Country A to secure
employment in Country B are $2,000, such a worker who entered
into a two year contract but decided to return home after 6
months would receive a Return Fee of $1,500 ($2,000 – 6/24).

Safety Devices Piece of equipment which protect employees from hazards such
as those created by point of operation, nip points, rotating parts,
flying chips and parts and sparks.
Sandblasting Abrasive blasting involves forcefully projecting a stream of

abrasive particles onto a surface, usually with compressed air or
steam. Workers who perform abrasive blasting are often known
as sandblasters.
Secondary Also known as point-of-use containers, these are used when

Containers a material is transferred from an original container to other
containers, such as for making a solution of a chemical or
repackaging into smaller bottles for redistribution within the
production floor. All such secondary containers need to be
properly labeled with the full name of the materials in the
container and where appropriate, a hazard warning.
Secondary Apparatus installed around storage devices, such as tanks or

Containment containers, to prevent wastes or accumulated liquids from leaking
into the soil, groundwater or surface water by capturing any
leaks. Secondary containment devices include double-walls, liners,
vaults, spill baths, bund(ing), or berms. Sometimes secondary
containment is an area that is sloped to drain into a sump or
holding area where materials are collected.
Semi-Announced An assessment for which facilities are contacted prior to the

Assessments assessment but a specific date is not communicated and agreed
to. Instead, the facility receives a window (e.g. two weeks or one
month) during which the assessment will take place.
Sexual Harassment Any unwelcome sexual advance, request for sexual favors,
or verbal, written or physical conduct of a sexual nature by a
manager, supervisor, co-workers or non-employee (third party).
→→ Quid pro quo – A form of sexual harassment when a
manager/supervisor or a person of authority gives or
withholds a work-related benefit in exchange for sexual
favors. Typically, the harasser requires sexual favors from the
victim, either rewarding or punishing the victim in some way.
→→ Hostile environment – A form of sexual harassment when
a victim is subjected to unwelcome and severe or pervasive
repeated sexual comments, innuendoes, touching, or other
conduct of a sexual nature which creates an intimidating or
offensive place for employees to work.
Sludge Term used to describe solids that are removed from wastewater
after treatment. Sludge is slurry of solids and liquid and may be
thought of as one of three types: raw, biological or chemical.

Spill Kits Neutralizing agents, inert absorbents such as kitty litter or sand,
personal protective equipment (gloves, goggles, aprons, etc.)
for the person(s) collecting the spilled material, a high-density
polyethylene bucket and small shovel for collection of spill clean-
up materials prior to disposal, among other items.
Spill When a chemical product, waste or material is released from its

proper container into an area where it was not intended to be.
Spot Cleaning Process by which spots are removed from fabric or garment. Spot
cleaning usually entails a spot-cleaning gun, chemical solvents
and an exhaust-cleaning system.
Standards Of Positive expectations for work performance and workplace

Conduct behavior.
Standing Orders See Internal regulations.
Strip Search Is the stripping (removal of clothing, search of person and/or

personal effects) of a person to check for concealed items. This
practice in facilities, even if legally accepted, is against Gap Inc.’s
COVC.
Subcontracted Workers who are employed through a contractor which becomes

Employees their official employer. The employment responsibilities are
typically shared between the labor contractor or provider and
the business owner. The employer retains essential management
control over the work performed by the employees. The labor
provider, meanwhile, assumes responsibility for such tasks as
reporting wages and employment taxes. The employer’s main
responsibility is to write a check to the labor provider to cover
the payroll, taxes, benefits and administrative fees. The labor
provider does the rest. Synonyms: Leased employees, contracted
employees
Sufficient Lighting Lighting that fulfills the lux level requirements for the workplace
or specific task at hand. Workers should not have to strain their
eyes when conducting their activities.
Temperature Mechanisms use to regulate temperature as air conditioners,

Control Devices fans, heater, etc.

Temporary Worker (a) One bound by a short term legal agreement to work for
a specific period of time. (b) An employee, hired through a
specialized employment agency, who generally works less than
a year on one assignment, regardless of the number of hours
worked per week. Temporary workers (also called “contingency
staffing” or “temps”) are utilized to accommodate fluctuations
in labor requirements. While these workers may have full-time
positions with companies, they are paid by private employment
agencies. Synonym: Short term
Terms And Requisites that would define the employment relationship

Conditions Of between employee and employer. These are usually defined
Employment during the hiring process and may include compensation
arrangements, notice periods in the event of dismissal, holiday
pay rights, the place and hours of work, benefits and pension
schemes. Many countries require these factors to be set out in a
written contract.
Timekeeping A record of how a person's time has been spent. It is used to

Records calculate pay, assess the efficient use of time, or charge for work
done. This could include manual or electronic time sheets and
time cards.
Timekeeping Method used to record the amount of time an employee works.

System This could be manual or electronic as with the use of time clocks
and swipe cards. If the system is manual then workers must
personally record their hours.
Timekeeping The activity of recording the amount of time an employee works.
Trainee One bound by legal agreement to work for another for a specific
period of time in return for instruction in a trade, art, or business.
Synonym: Apprentice.
Training Instruction provided to stimulate change. Its focus is short-

term and directed solely at furnishing knowledge or skills that
employees need to carry out their present work duties efficiently
and effectively.
Unannounced An assessment where the facility is not given prior notice of the
Assessments assessment.
Unauthorized Assigning, subcontracting or otherwise transferring Gap Inc.

Subcontracting goods or obligations without such prior written authorization in
an unapproved facility.

Vacuum Systems System that removes air from a small area - generally this is used
for a single workstation and employee where the opening of the
system is right where the work is being performed. Most vacuum
systems include a hose that sucks the chemicals out of the air,
sending them outside and away from employees. Usually used in
facilities to remove solvents from spot cleaning stations.
Verbal Abuse It is hostile language that hurts the listener and is not accidental.
This includes yelling unnecessarily or swearing at workers.
Wages See Remuneration
Wash Stations Are used to counteract a reaction by providing large amounts of

continually flowing water to flush a chemical in case of exposure.
Some examples are showers and bottles of saline eye solution.
Waste, Hazardous By-products of society that can pose a substantial or potential

hazard to human health or the environment when improperly
treated, stored, transported or disposed. Possesses at least one of
four characteristics (ignitability, corrosivity, reactivity, or toxicity).
Waste, Solid Non-liquid, non-soluble materials ranging from municipal

garbage to industrial wastes that contain complex and
sometimes hazardous substances. Solid wastes also include
garbage, construction debris, commercial refuse, sludge from
water supply or treatment plants, and other discarded materials.
Technically, solid waste also refers to liquids and gases in
containers.
Wastewater Wastewater may be generated from:

→→ Process (or “trade”) effluents arising from various stages of an
industrial, agricultural, or commercial process;
→→ Cooling wastewater or other non-contact wastewater;
→→ Blow-down (e.g., from compressors, boilers);
→→ Stormwater run-off (sometimes referred to as surface water
run-off) from roofs, hardstanding areas, yards, car parks,
vegetated areas, etc.);
→→ Firewater;
→→ Sanitary/domestic wastewater (e.g., from toilets, sinks etc.).
This would include all manufacturing and/or commercial
activities within the facility site’s footprint, such as industrial
processing, lubrication, cooling, maintenance, cleaning, and
domestic use, as well as wastewater/effluent from dormitories
(e.g., bathrooms, showers, kitchens).

Withholdings A portion of an employee's wages or salary withheld by the
facility as partial payment of the employee's income tax, social
security or other legally required payments. Withholdings must
be forwarded to the appropriate government authority.
Workplace Any unwelcome verbal, written or physical conduct that either

Harassment denigrates or shows hostility or aversion towards a person
on the basis of race, sex, color, national origin, religion, sexual
orientation, age, veteran status, political affiliation, or disability,
that: (1) has the purpose or effect of creating an intimidating,
hostile or offensive work environment; (2) has the purpose
or effect of unreasonably interfering with an employee's
work performance; or (3) affects an employee's employment
opportunities or compensation.
Workplace Violence Any physical assault, threatening behavior or verbal abuse

occurring in the workplace by employees or third parties. It
includes, but is not limited to, beating, psychological trauma such
as threats, obscene phone calls, an intimidating presence, and
harassment of any nature such as stalking, shouting or swearing.
Young workers Any worker over the age of a child as defined herein and under
the age of 18.

Appendix 2:
COVC Critical Issues List

Issue severity
Provision Standard Standard detail Standard sub-detail level
Compliance with Coaching Coaching Answers Facility management does not coach or require workers to provide certain Critical

Laws Answers answers during interviews with Gap Inc. assessors.
Compliance with Bribery Bribery Facility operates in full compliance with U.S. Foreign Corrupt Practices Act (FCPA) Critical
Laws regarding corruption and unethical practices, and does not attempt to make
payment to a government official for the purpose of obtaining or retaining
business for or with, or directing business to, any person.
Compliance with Transparency Documentation Facility records accurately reflect facility conditions. Critical
Laws Transparency
Compliance with Unrestricted Access to Facility, Facility staff allows full access to the facility. Critical
Laws Access Workers, and
Records
Compliance with Unrestricted Access to Facility, Facility staff allows full access to facility records. Critical
Records
Compliance with Unrestricted Access to Facility, Facility staff allows full access to workers. Critical
Records
Compliance with Unauthorized Unauthorized Facility only places Gap Inc. production in approved facilities. Critical
Laws Subcontracting Subcontracting
Labor Child Labor Minimum Age Workers are of or above the legal minimum age. Critical
Requirement
Labor Child Labor Minimum Age Workers are of or above 15 years of age. Critical
Requirement
Labor Child Labor Mandatory Workers are above the age of mandatory schooling. Critical
Schooling Age
173
Issue severity
Labor Foreign Contract Recruitment Facility employees or representatives do not accept reimbursements, kickbacks Critical
Labor Agencies or other amounts from recruitment agency or other person involved in the
recruiting process.
Labor Foreign Contract Recruitment Fee Facility allows workers full and complete control over the monies they earn. Critical
Labor Withholding
Labor Foreign Contract Passport Facility allows workers full control over his or her passport and similar Critical
Labor documentation.
Labor Foreign Contract Passport Control of passport is not a condition of employment. Critical
Labor
Labor Discrimination Forced Facility does not force women workers to use contraception during their Critical
Contraception employment period.
Labor Forced Labor Forced Labor Facility does not use any form of involuntary labor, prison labor, debt bondage, Critical
slave labor, or forced labor by governments.
Labor Humane Physical Abuse Facility does not engage in or permit physical abuse to punish or coerce their Critical
Treatment and workers.
Disciplinary
Practices
Labor Humane Physical Abuse Facility does not permit or engage in coercive physical contact, such as slaps, Critical
Treatment and shoving, or throwing of objects at workers.
Disciplinary

Practices
Labor Humane Verbal Abuse Facility does not engage in or permit screaming or verbal abuse when Critical
Treatment and addressing productivity or disciplinary concerns with employees.
Disciplinary
Practices
Labor Humane Verbal Abuse Facility does not engage in or permit threats of violence to punish or coerce their Critical
Treatment and workers.
Disciplinary
Practices
174
Issue severity
Labor Humane Verbal Abuse Facility does not engage in or permit unwelcome conduct that creates an Critical
Treatment and intimidating or humiliating work environment.
Disciplinary
Practices

Labor Humane Verbal Abuse Facility does not engage in or permit unwelcome physical contact of a sexual Critical
Treatment and nature.
Disciplinary
Practices
Labor Humane Verbal Abuse Facility does not engage in or permit unwelcome spoken words of a sexual Critical
Treatment and nature.
Disciplinary
Practices
Labor Humane Verbal Abuse Preferential work assignments or other preferential treatment is not practiced Critical
Treatment and or implied in exchange for a sexual relationship or workers are not subject to
Disciplinary prejudicial treatment in retaliation for refused sexual advances.
Practices
Labor Humane Security Personnel Security is respectful of workers and does not intimidate them. Critical
Treatment and
Disciplinary
Practices
Labor Humane Pat-downs Facility staff does not conduct strip searches. Critical
Treatment and
Disciplinary
Practices
Labor Working Hours Overtime Hours Total weekly working hours (including normal working hours and overtime Critical
hours) does not exceed 80 hours.
Labor Working Hours Involuntary Facility does not retaliate against workers who refuse to work overtime (by Critical
Overtime means such as threatening dismissal, demotion, not allowing any overtime, pay
cuts etc.).
Part 3 Appendix Appendix 2: COVC Critical Issues List 175

Issue severity
Working Conditions Occupational Ventilation Facility does not use any sandblasting techniques. Critical
Health and Safety
Working Conditions Occupational Exit Routes / Facility has at least two exits on each floor. Critical
Health and Safety Emergency Routes
Working Conditions Occupational Exit Routes / Exit doors are kept unlocked at all times during working hours. Critical
Health and Safety Emergency Routes
Working Conditions Dormitory Exits, Emergency Facility's sleeping quarters have two well-lit exits on each floor. Critical
Lighting, and Fire
Alarm

176
Appendix 3:
Gap Inc. Unauthorized

Subcontracting Policy
Policy
→→ Vendor and facilities shall use only Gap Inc. approved facilities for the production of
Gap Inc. goods.
→→ Vendor shall obtain written authorization from Gap Inc.’s Global Sustainability
department to use these facilities prior to the start of production.
→→ Assigning, subcontracting or otherwise transferring Gap Inc. goods or obligations without
such prior written authorization in an unapproved facility is considered unauthorized
subcontracting and a material breach of the Vendor Compliance Agreement.
Purpose
→→ To define what constitutes unauthorized subcontracting (UAS) and the requirements
that apply in unauthorized subcontracting cases.
Scope
→→ This policy applies to all vendors and their facilities (owned or affiliated), producing/
handling Gap Inc. branded product.
→→ Gap Inc.’s Supplier Sustainability, and Global Supply Chain Category teams.
Requirements
The following requirements apply in the case of unauthorized subcontracting:
→→ Vendor will stop UAS immediately and move goods (finished or unfinished) to an
approved Gap Inc. facility.
→→ Gap Inc.’s Supplier Sustainability (SS) and Sourcing teams and Vendor will conduct
investigation and root cause analysis to determine reasons behind UAS.
→→ Gap Inc.’s Supplier Sustainability team will place facility and/or vendor “Under
Investigation” status to stop ongoing placement of orders after receiving notification
from SS Director.
→→ Gap Inc.’s Supplier Sustainability and Sourcing teams will align on the disciplinary action
plan for the vendor and facility involved and the UAS notification letter will be sent.
→→ Vendor will submit within 72 hours (of receipt of UAS notification letter) a commitment
to compliance and a corrective action plan (CAP) following Gap. Inc.’s CAP Guidelines.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 3: Gap Inc. Unauthorized Subcontracting Policy 177
→→ Once vendor’s commitment to compliance and satisfactory CAP is received:
• Vendor/facility’s status will revert to “Active” (if applicable).
• Goods can ship with Supplier Sustainability Regional Director’s approval.
→→ SS will follow up progress until vendor/facility has demonstrated successful
implementation of CAP.
Consequences of Violation
1. Consequences for not remediating pending requirements by dates agreed range from
warnings and suspension of new orders up to facility revocation.
2. Consequences are outlined on the Corrective Action Plan (CAP) and Open Areas for
Improvements (AFIs) Guidelines.

Vendor’s Business Volume <$1M1 Vendor’s Business Volume >$1M
Facility Vendor Facility Vendor
1st UAS Monetary investment Chargeback Monetary investment Chargeback

Occurrence In training at the US$10,000 In training at the US$50,000
facility/vendor’s facility/vendor’s
expense expense
2nd UAS Termination Chargeback Termination Chargeback

Occurrence Facility is terminated US$15,000 Facility is terminated as US$100,000
as Gap Inc. supplier Impact to orders Gap Inc. supplier Impact to orders
Reduction of current Reduction of current
orders by 20% orders by 20%
3rd UAS N/A Chargeback N/A Chargeback -

Occurrence US$20,000 US$150,000
Impact to orders Impact to orders
Temporary suspension Temporary suspension
of orders Or of orders Or
Termination Termination
Vendor is terminated as Vendor is terminated as
Gap Inc. supplier Gap Inc. supplier
1
Vendor’s business volume will be based on First Cost (total dollar amount) for past 12 months, from the date the UAS is found.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 3: Gap Inc. Unauthorized Subcontracting Policy 179
Appendix 4:
Sandblasting Policy
Gap Inc. is committed to the responsible sourcing of our products, which includes the
safety of workers producing our branded apparel. In support of this commitment, Gap Inc.
brands will no longer utilize the practice of sand blasting as a finishing technique for any of
our global branded apparel production, effective May 2011. This policy includes all types of
abrasives, not just sand, but also aluminum oxide, aluminum silicate, silicon carbide, copper
slag and garnet for abrasive blasting.

Appendix 5.A:
Facility Expansions Policy

Policy
→→ Vendors and facilities must notify Supplier Sustainability before expansions are
completed to ensure Supplier Sustainability conducts an assessment and approves the
expansion area (as applicable), before Gap Inc. production is moved to expanded area.
Purpose
→→ To define the different types of facility expansions, the notification and assessment
requirements applicable to each type and when in the process Gap Inc. production can
be moved to newly expanded areas.
Scope
→→ This policy applies to all vendors and their facilities (owned or affiliated), approved to
produce/handle Gap Inc. branded product.
Requirements
Can Existing Consequences of Violation
Gap Inc.
Production Not Moving Gap Inc.
Type of be moved to notifying production to
Expansion Type of Assessment Required/ Timing expansion? expansion expansion
1. Adding New and existing facility areas will undergo Yes. Production N/A N/A
shift(s), more a full assessment during Gap Inc.’s regular can be moved
employees, more schedule to newly added
sewing lines, areas before FA is
new capability, conducted
dormitory or
warehouse to an
approved facility
2. Expanding to Based on facility Red: FA within 15 days No. Production Warning Training at the
new building rating, full cannot be Letter facility/vendor’s
(s) , new floors, assessment (FA) moved to new expense
at the same (of new and building(s) until FA Violation
address - same existing facility is conducted and documented in
legal entity areas) is required: A&RS confirms no GSS
as the one critical issues were
originally found at newly Vendor and
approved expanded area facility lose
ratings points
Yellow: FA within Yes. Production Warning N/A

6 months or as per can be moved to Letter
regular schedule, newly expanded
whichever is earlier areas before FA is
conducted
Green: FA as per
regular schedule
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 5.A: Facility Expansions Policy 181
Can Existing Consequences of Violation
Gap Inc.
Production Not Moving Gap Inc.
Type of be moved to notifying production to
Expansion Type of Assessment Required/ Timing expansion? expansion expansion
3. Expanding to Initial assessment No. Production Warning Training at the

new building of the new cannot be moved Letter facility/vendor’s
(s), new building as soon to new building(s) expense
floors, at the as expansion until it has been Violation
same address approved in documented in
(different legal writing by GS GSS
entity from the
one originally Vendor and
approved)i facility lose
ratings points.
4. Expanding to Initial assessment No. Production N/A Violation is

new or existing of the new cannot be moved considered UAS.
building(s) at building as soon to new building(s) All UAS policy
new address as expansion is until it has been disciplinary
ready approved in actions will
writing by GS apply including
chargeback
i
Facilities approved under Gap Inc.’s All or Nothing Policy: Expansions to new building (s), new floors, at the same address (different legal en-
tity from the one originally approved) at facilities approved under Gap Inc.’s All or Nothing Policy, must meet requirements set forth under
type of expansion #2.
1. Facilities that fail to notify expansions to Supplier Sustainability will be issued Warning
Letter (WL).
1.1. Accumulating 3 WL ( within 3 years of the last WL) will lead to:
1.1.1. Training (selected by Supplier Sustainability) at the vendor/facility’s expense.
1.1.2. Violation documented in GSS. Vendor and facility loose ratings points.
2. Facilities that move Gap Inc. production to expansion without prior approval of Global
Sustainability (as applicable) will be subject to disciplinary actions for both vendor and
facility, including but not limited to training (based on GS Training Curriculum) at the
facility/vendor’s expense, chargeback, order reduction and termination, as defined under
the requirements table of this policy summary.

Appendix 5.B:
Facility Expansions Policy Workflow

FACILITY EXPANSIONS POLICY

Adding Gap Inc.
shift(s), more production can be Full assessment
GS receives employees, sewing moved to newly (FA) during Gap
notification of lines, new capability, Yes
expanded Inc.’s regular
facility expansion dormitory, at
approved areas before FA is schedule
facility? conducted
No
No
Expanding into
new building or floor, Is the facility Is the facility Is the facility
Yes No No
same address and rating red? rating yellow? rating green?
legal entity?
Yes Yes Yes
Gap Inc. Production Gap Inc. Gap Inc.

cannot be moved production can be production can be
until FA is conducted moved to newly moved to newly
and no critical issues expanded areas expanded areas
found at newly before FA is before FA is
expanded area conducted conducted
No No
FA conducted within
FA FA FA
6 months or as per
conducted within conducted as per process is
regular schedule,
15 days regular schedule followed
whichever is earlier
Expanding into new

building or floor, same
Yes
address and new legal
entity?
Gap Inc. production
Vendor
cannot be moved to
Expansion Approval
newly expanded
No requires a new process for End
areas until it has
assessment new facilities is
been approved in
followed
writing by GS
Expanding into new

building, different Yes
address?
REVISED
Part 3 Appendix Appendix 5.B: Facility Expansions Workflow 183

4/13/2015
Appendix 6:
Conditional Approval Policy

Policy
Under some special circumstances, a new facility offered for approval to manufacture Gap
Inc. products may be granted a ‘Conditional Approval’ even when there are some Code of
Vendor Conduct (COVC) issues pending for complete remediation, provided that all the
conditions explained in this policy are met.
Purpose
To allow further flexibility to the vendor approval process in case of urgent business needs.
Scope
1. This policy applies to all new facilities intending to produce/manufacture Gap Inc.
branded apparel product.
2. Gap Inc.’s Supplier Sustainability (SS), Supplier Sustainability Operations team (SSO) and
Global Supply Chain (GSC) teams.
Requirements
Due to some urgent business needs, at times GSC may request for conditional approval of a
newly assessed facility where some issues found during initial assessment are still pending.
Such requests can be submitted to the Regional SS Director. Such requests will be reviewed
thoroughly and appropriate actions will be taken in accordance to the following procedures:
1.
1.1. GSC provides business justification including the following:
1.1.1. Description of urgent business need: a. cost savings opportunity, b.
quality improvement in product, c. capacity constraints, d. capability
constraints, and/or, e. delivery or lead time concerns.
1.1.2. Product type, number of units, production start date, ship cancel date
and in DC dates.
1.1.3. Confirmation from respective Category Lead that conditional approval is
required.
1.2. Assessment & Remediation Specialist (A&RS) confirms:
1.2.1. No critical and/or severe issues were found during Initial assessment or
if found, have been remediated.
1.2.2. Valid corrective action plan (CAP) has been received following Global
Sustainability CAP and Open Areas for Improvements (AFIs) Guidelines,
for all other key and non-compliance issues.

1.3. Regional SS Director assesses type of remaining open key and non-compliance
issues, potential risks and CAP submitted.
1.4. Gap Inc.’s Quality Assurance team provides technical evaluation approval letter.
1.5. If Regional SS Director approves the conditional approval request, SSO will issue
the conditional approval.
1.6. If Regional SS Director rejects the conditional approval request, no conditional
approval will be issued. Under such circumstances, facility will need to complete
the suggested actions before the conditional/full approval requested can be
considered again.
2. After granting of conditional approval status, facility must remediate all pending
requirements by dates agreed or face consequences up to revocation.
3. SSO will issue Full Approval after all pending requirements have been remediated and
entered in Gap Inc.’s Global Sustainability System.
1. Consequences for not remediating pending requirements by dates agreed range from
warnings and suspension of new orders up to facility revocation.
2. Consequences are outlined on the Corrective Action Plan (CAP) and Open Areas for
Improvements (AFIs) Guidelines.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 6: Conditional Approval Policy 185
Conditional Approval Policy
Facility provides
GSC provides valid Regional SS Director
valid Corrective
Assessment & justification¹ with assesses type of
Global Supply Chain Action Plan (CAP) Regional SS
Remediation Category Lead’s ARS confirms valid remaining open key
Are there critial, (GSC) requests following GS CAP Director grants
Specialist (ARS) No confirmation to CAP has been and non-compliance
severe issues? Conditional and Open AFIs⁴ Conditional
conducts initial Regional SS³ received issues, potential
Approval (CA) Guidelines for all Approval?
assessment Director for risks and CAP
other key and non-
consideration submitted
compliance issues
Yes
If not, required for re-submission
Facility Facility re-submits
corrects ALL critical & CAP and/or other
severe issues before necessary
CA is requested? document(s) as per
No
SS Director’s
feedback for
consideration until
ARS confirms zero acceptable
non-compliances
Yes
with critical/severe
Yes
issue left
No
Conditional approval is Gap Inc.’s Quality
not granted Assurance team Is facility a
provides technical No supporting
evaluation approval facility²?
letter
Yes

Implement
consequences
Are pending issues Facility is
following No remediated by dates conditionally
Consequence
agreed? approved
Model by AFI
Severity Level
Yes
Notes:
1 . Business justification including the following:
- Description of urgent business need such as cost savings, quality improvement, capacity
constraints, capability constraints, delivery and/or lead time concerns Facility is fully
- Product type, no. of units, production start date, ship cancel date and in DC dates approved
2. Supporting facility includes Free-Standing laundry, embroidery and screenprinting
3. SS – GAP Inc.’s Supplier Sustainability Team under Global Sustainability REVISED 09/22/2015
186
4. AFIs – Areas for Improvements
Appendix 7:
Facility Status Change

Prospect
1. This is the status when sourcing submits a new facility approval request to Global
Sustainability team to begin Vendor Approval Process.
2. Supplier Sustainability Operations team will send email to the vendor requesting to
submit required documents.
Pending
1. Documentation process is completed and Supplier Sustainability team will schedule
initial assessment at the facility. Vendor/facility shall not start Gap Inc. production at
the facility yet.
Active
1. Upon a successful completion of the Vendor Approval Process, facility has been granted
final approval by the Global Sustainability team (and by QA team based on technical
evaluation where applicable). Supplier Sustainability Operations team will issue
“Approval Confirmation” letter to the vendor, copying Regional Supplier Sustainability
team, sourcing, QA and the facility. Facility may start Gap Inc. production at this stage.
Withdrawal
1. During the Vendor Approval Process (VAP), vendor/facility may decide to withdraw
from the VAP or decide not to remediate the Areas for Improvement (AFI) for business
reasons.
2. When Supplier Sustainability Operations Department receives a withdrawal request
before an initial assessment is conducted at the facility, Supplier Sustainability
Operations team will issue “Withdrawal Confirmation” letter to the vendor after
communicating with sourcing. Regional Supplier Sustainability team, Global Supply
Chain, QA and facility will be all copied in the mail.
3. When Supplier Sustainability Operations team receives a withdrawal request after
the initial assessment is conducted and there are no critical or severe issues found,
Supplier Sustainability Operations team will issue “Withdrawal Confirmation” letter to
the vendor after communicating with sourcing. Regional Supplier Sustainability team,
sourcing, QA and facility will be all copied in the mail.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 7: Facility Status Change 187
Rejection
1. During the Vendor Approval Process (VAP), after initial assessment is conducted, if the
facility (or vendor) refuses to remediate Areas for Improvement (AFI), or the facility is
believed to be unwilling to remediate their Areas for Improvement (AFI), Assessment
and Remediation team or Regional director may reject the facility.
2. Once the Supplier Sustainability Operations team receives rejection notification
from Assessment and Remediation team or Regional director, Supplier Sustainability
Operations team will communicate with sourcing and vendor and will issue facility’s
“Rejection Confirmation” letter to the vendor. Regional Supplier Sustainability team,
sourcing, QA and facility will be all copied in the mail.
3. If there were key issues found from the initial assessment, and vendor/facility decided
to withdraw the VAP, then the facility will be rejected and Supplier Sustainability
Operations team will issue “Rejection Confirmation” letter to the vendor, copying
Regional Supplier Sustainability team, sourcing, QA and facility.
4. Rejected facility (or vendor) may not be considered for re-assessment for at least
12 months. Authorization from Global Sustainability Regional Director is needed if
rejected facility (or vendor) would like to re-apply VAP before 12 months.
Deactivation
1. If a facility will no longer be used for Gap Inc. production, vendor/facility shall inform
sourcing and Supplier Sustainability team by e-mail that a facility has no plans for
future production.
2. Closure of a facility should also be disclosed to Supplier Sustainability team and
sourcing.
3. This request may also come from QA/sourcing/ARM/A&RS when it is known that the
facility has had no Gap Inc. production for the last six months and has no production
plan for next six months.
4. After the Supplier Sustainability Operations team communicates with Global Supply
Chain and the vendor, a “Deactivation Confirmation” letter will be issued to the vendor.
Regional Supplier Sustainability team, Global Supply Chain, QA and facility will be all
copied in the mail.
Re-activation
1. When there is a reactivation request for a facility that has been deactivated within the
past 12 months, the facility may be reactivated immediately after communicating with
the Supplier Sustainability Operations team. Reactivated status will be shared with
Regional Supplier Sustainability team, sourcing, QA and vendor and facility.
2. When there is a reactivation request for a facility that has been deactivated more than
12 months from the deactivation date, the facility will need to go through the regular
Vendor Approval Process again.

Under Investigation
1. Facility is placed under investigation when the facility has seriously violated Code
of Vendor Conduct or legal requirements (e.g., use of unauthorized subcontracting
facility) and Supplier Sustainability team is under process of investigating the facility.
This status should only be temporary but may be reversed to “active” with Regional
Director’s approval if the facility demonstrated that the situation has been resolved and
after Supplier Sustainability team verified that this has been done. During this status,
existing orders may continue, but no new order may be placed at this facility.
Revocation
1. If the facility under investigation fails to demonstrate that the situation with serious
non-compliance issue is resolved, then the facility will be “revoked”.
2. Revocation is the termination of a facility’s approved status due to serious non-
compliance issue with Gap’s Code of Vendor Conduct or other business agreement.
The Supplier Sustainability Regional Director will request to revoke a facility if the
facility is found with serious violation of the Code of Vendor Conduct or other business
agreement.
3. Once Supplier Sustainability Operations team receives Global Sustainability Vice
President’s and/or the Regional Director’s request to revoke the facility, Supplier
Sustainability Operations team will communicate with sourcing/vendor/QA and
will issue facility’s “Revocation Confirmation” letter to the vendor. Regional Supplier
Sustainability team, sourcing, QA and facility will be all copied in the mail.
4. Revoked facility (or vendor) may not be considered for re-assessment except with
Regional Director’s approval.
5. Existing orders may not continue to process unless advised by Regional Director, but
new orders may not be placed.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 7: Facility Status Change 189
Appendix 8:
Assessment Agenda
Example
The purpose of assessment agenda serves an initial plan to ensure all key elements of COVC
are properly covered in the on-site assessment. The timeline and sequence of assessment
can be modified as needed at the discretion of lead assessor with consideration of the
practical situation in facility.
Below is an example of 2-person day assessment to be used as a starting point.
Date (mm/dd/yy): Type of Assessment:
Vendor Name:
Facility Name:
Part 1. List of participants

Assessment Team:
Name Role
2.
3.
4.
5.
Facility/Vendor Representatives
Name Role
2.
3.
4.
5.

Part 2. Tentative Agenda
Day One - Date (mm/dd/yyyy):
Time Agenda Item
Opening Meeting (Attendees: Facility Management/Vendor and Assessment

0900 - 0930 team)
0930 - 1000 Site Introduction and Tour
Interviews with key Labor/Human Resources, H&S and Environment

1000 - 1030 management representatives
Interview with management and

workers where applicable on labor & Detailed facility tour & review of
1030 - 1200 ethics policies and procedures employees EHS
1200 - 1300 Lunch
Continuation of interviews with

management and workers as
necessary on labor & ethics policies Interview with management, health
1300 - 1715 and procedures. & safety programs and procedures
1715 - 1730 Team discussion and summarized the key findings in day one
1730 - 1800 Daily wrap up meeting with the representatives of facility management/vendor.
Day Two - Date (mm/dd/yyyy):
Time Agenda Item
Daily Opening Meeting (Attendees: Facility Management/Vendor and

0900 - 0915 Assessment team)
Interview with management, labor

& ethics and related management Detailed facility tour & review of
0915 - 1200 system programs and procedures employees’ EHS
1200-1300 Lunch
Interview with management, labor Interview with management,

& ethics and related management Environmental programs and
1300 -1530 system programs and procedures procedures
Finalize gathering evidence for the Finalize gathering evidence for the
1530 -1630 labor and ethics elements H&S and Environment elements
Assessment team review and

1630-1700 preparation for closing meeting
1700-1800 Closing meeting with the representatives of facility /vendor
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 8: Assessment Agenda Example 191
Appendix 9:
Assessment Documentation
& Records to Review
Facility Name: Date:
Documents Yes No N/A Remarks
Compliance with Laws
1 Business Licenses/Registration/Tax ID
2 Other legal licenses/permits to operate the Facility
3 Local Minimum Legal Wage document
4 Facility Layout (floor plan)
5 Employment Contracts
6 Internal Regulations/Standing Orders
7 Sub-contracting records
8 Fire Safety Certificate
Environment
9 Environmental Policy
10 Environmental Management Plan
11 Procedures for Chemical Handling & Storage
Chemical Inventory List/Material Safety Data Sheet

12
(MSDS) for all chemicals used
Consent for storage & transportation of hazardous

13
wastes/Hazardous wastes inventory
14 Procedure for Inspection & Maintenance

Procedure for Disposing Waste (including hazardous

15
wastes)
16 Procedure for Notifying Local Community
Procedures for reporting and responding to

17
environmental emergencies
18 Discharge permits (air, wastewater, etc.)
19 Effluent treatment plant log book
20 Monitoring report for Waste Gas, Wastewater, Noise
Labor
29 Master List for all employees
Employee Personnel Files (employment letter, age

30 documentation and other legally required forms) for all
types of employees
Master List for young workers/health check certificate

31
and registration
32 Employee Handbook
Policy, Procedure and Records for Hiring, Discipline,

33
Grievance , Leave, Resignation, Termination etc.
34 Minutes of workers’ committee or union
35 Collective Bargaining Agreement
Updated master list/receipts for social security & injury

36
insurance
37 Attendance records
38 Time records (regular and Overtime)
39 Wages records (time based/piece based)
40 Pay slip
41 Leave records (annual/sick/emergency)
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 9: Assessment Agenda Example 193
42 Maternity benefits records
43 Other benefits records (e.g. bonuses)
44 Severance pay and benefits records
Working Conditions
45 Evacuation Drill Log for Facility & dormitory
46 H&S committee meeting logs
47 Fire Fighting training records
48 Fire alarm/emergency lights testing records
49 First Aid training records
Personal Protective Equipment (PPE) distribution records

50
& training records
51 Accident records
52 Machine maintenance procedures & records
Operating Certificate for special equipment (lift, boiler,

53
compressor etc.)
Boiler inspection report & boiler operator’s competency

54
certificate.
Kitchen Hygiene Permission Certificate & Kitchen staff’s

55
health check certificate
56 Check records for temperature at production area
57 Drinking water test report
Foreign Contract Workers (FCW)
58 Master list of all FCW
59 Contract with labor supply agent
60 Migrant workers registration to government record

61 FCW policy and procedures
62 Policy for passport keeping, return fee, leave, etc.
Records for medical check-up, passport renewal, payment

63
of ticket, wage deduction
64 Dormitory Policy, curfew
Production Records
65 Material in/out records
66 Output records for each production process
67 Inspection records for QA
68 Broken needle records
Management System Records
69 Organization chart/structure
70 CSR policy
71 Departmental functions and responsibilities
72 Risk assessment records
73 Management system improvement plan
74 Internal controlled procedures
75 Training needs assessment
76 Development and training plans
77 Training material/evaluation and records
78 Internal monitoring schedule/assessment records
79 Management system review and action plan
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 9: Assessment Documentation and Records to Review 195
Appendix 10:
Corrective Action Plan (CAP)

and Open Areas for
Improvement (AFI) Guidelines
Policy
→→ To provide guidance to vendors and facilities on Gap Inc.’s expectations when corrective
action is needed as a result of violations to our Code of Vendor Conduct (COVC)
requirements.
Scope
→→ These guidelines apply to areas for improvement found during assessments conducted
by Gap Inc. Supplier Sustainability team.
Guidelines
Vendor/facility should, within 10 calendar days of receiving Gap Inc.’s initial or full assess-
ment report:
1. Submit CAP using Gap Inc.’s CAP template (see page 190).
2. CAP should include at least:
2.1 Area for improvement (AFI) identified and Facility Improvement Plan (FIP).
2.2 Specific Corrective Actions (CA) to eliminate the cause of AFI. This could include
developing or updating written policies or procedures, training, capability
building and any other relevant actions.
2.2.1 If Root Cause Analysis (RCA) has been conducted (as per Gap Inc.’s RCA
Guidelines), CA should target the root cause(s) identified.
2.3 Who is accountable for each CA and its implementation?
2.4 Deadline for completing each CA. Note that the deadline for completing last
action cannot be beyond the FIP date mentioned in assessment date.
2.5 Progressive Corrective Action Plan (pCAP)
Sustainable resolution of some issues may only be achieved gradually, such as
with excessive overtime and not providing one day off in seven. In those cases:
2.5.1 List all actions necessary to achieve complete FIP resolution, each with
its respective deadline.
2.5.2 Defined timelines and consequences apply to each CA within the
progressive plan; as such progress will be measured by completion of
each deadline.

3. Complete resolution section of the submitted CAP and attach evidence of resolution, on
or before the CA deadline.
3.1 Email or fax evidence if it cannot be attached to CAP form.
4. Notify A&RS if CA cannot be met by deadline, before deadline is due and provide:
4.1. Reason for delay.
4.2. Evidence of progress up to date.
4.3. New corrective action deadline taking into consideration the consequence
model for past due FIPs included herein.
Assessment & Remediation Specialist (ARS) should, within 5 calendar days of receiving CAP:
5. Review CAP
6. Request CAP update if the above mentioned guidelines have not been followed, until
CAP submitted is valid.
7. Enter progressive CAs (if applicable) in GS System ensuring deadlines follow guidelines
provided herein.
Evidence of Corrective Action

Within 5 calendar days of receiving valid evidence of CA, A&RS should:
1. Document resolution and close open AFIs if AFI can be closed using “alternative method”.
2. Document progress if AFI:
2.1. Has not been completely resolved or,
2.2. Has been resolved but AFI cannot be closed using “alternative method”.
2.2.1. Flag the assessment for “physical follow up” when all AFIs have been
resolved or within 90 days from date of full assessment, whichever is earlier.
2.2.2. Add upcoming physical follow up date (date should be within 30 days of
receiving last evidence).
3. Conduct physical follow up assessment.
4. If facility does not provide evidence of corrective action by deadline or does not notify
A&RS of delays, A&RS should:
4.1. Follow up with facility via email or call within 15 calendar days of the deadline
and update GS System with progress based on the information provided.
4.2. Escalate following consequence model for past due FIPs included herein.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 10: Corrective Action Plan (CAP) and Open Areas for Improvement (AFI) Guidelines 197
Corrective Action Timelines & Consequence Model by AFI Severity Level
FIP/ Corrective action Timeline Consequences Model
Mid Term Remedial Long Term Preventive Actions
Examples Immediate Corrective
Actions
Action (e.g. remove (e.g. review and refine age
These examples serve as an children from work (e.g. provide employment verification process/ arrange
illustration only and do not area/ bring back Gap Inc. to relative of the child/ for child’s education/ 3rd
AFI Severity include the complete list of production to approved Conduct training for party intervention for system 30 days after respective 60 days after
Level COVC AFI’s by severity levels. unit) facility teams on UAS) improvement to prevent UAS) deadline respective deadline
Critical →→Child Labor 1-3 days 30-60 days 120-270 days Escalate to Manager and Director to escalate
Director to Sourcing
→→Unauthorized
subcontracting (Manager/ Director to (Work with Sourcing
engage with Facility/ to take appropriate
→→Physical abuseRestricted
vendor top management actions)
access to facility
and push for actions)
Examples
For illustration only. Not the
AFI Severity complete list of COVC AFI’s by 60 days after respective 90 days after
Level severity levels. Short-Midterm Corrective action Long term Preventive action deadline respective deadline
Severe Up to 60 days 60-120 days

→→Discrimination Escalate to Manager and Director to escalate
Director to Sourcing
→→Involuntary
overtimeTerminating (Manager/Director to (Work with Sourcing
workers for attempting engage with Facility/ to take appropriate
to organize vendor top management actions)
and push for actions)
198
Examples
AFI Severity For illustration only. Not the complete list of 60 days after respective 90 days after
Level COVC AFI’s by severity levels. Short-Midterm Corrective action 60 days after CA deadline deadline respective deadline
→→Required written employment contracts do Escalate to Manager Escalate to Director Escalate to Sourcing

Key Up to 60 days
not comply with labor law
→→Monthly wages not paid by stipulated time
→→Wage statements are not available to
workers
Consequences Model
Examples
AFI Severity For illustration only. Not the complete list of FIP/ Corrective action 180 days after CA 270 days after CA
Level COVC AFI’s by severity levels. Timeline 90 days after CA deadline deadline deadline
Non- →→Chemical containers not labeled Up to 30 days Escalate to Manager Escalate to Director Escalate to Sourcing
compliance →→Facility’s exit route diagrams are not posted
→→Machinery/equipment without safety guards
Part 3 Appendix Appendix 10: Corrective Action Plan (CAP) and Open Areas for Improvement (AFI) Guidelines 199
Appendix 11:
Corrective Action Planning- To be completed by Facility
Issue Detail—Copy from Assessment Report (Within 10 days of assessment Report receipt) Follow up and Status Update
Supporting
Standard Facility Root Expected Evidence of Gap Inc.
Sub Detail Area For Improvement FIP causes Corrective/ Preventive Completion Responsible Date of completed A&RS
ID Improvement (AFI) Plan (FIP) Date Identified actions Date person update Updated Status action Comments
III.G.16.02 Facility provides Facility has 9/10/15 If there are employees 8/12/15 HR 8/12/15 Completed Leave extension
married leaves 2 agreed to currently on leave or Manager notice sent to 3
days only instead provide have applied for leave employees
of 3 days in married leave in near future, extend
accordance to the of 3 days in their leave by 1 day
Local Labor Law accordance to
the Local Law Make changes in the 8/20/15 GM- HR 8/25/15 Completed Scan of revised
leave policy and get policy with top
sign off from the top management
management signature
Create awareness 8/30/15 HR 8/25/15 In progress- pictures of

among workers about Manager Notices and notice/ displays
the revised policy posters have
been displayed.
Working on
including it in the
worker orientation
program
Conduct training 9/5/15 HR 8/25/15 In progress- 2 Signed list of
for relevant HR and Manager batches of participants
Production staff for trainings for 2 batches
implementation of completed. 3 more and training
policy batches to be notification sent
conducted next for remaining 3
200
week batches
Appendix 12:
Root Cause Analysis

Guidelines
Introduction
Background
When people discover problems, the most frequent response is to rush to find a solution.
Finding an immediate fix for the problem is very satisfying no matter how many times this
process occurs. Unfortunately, it is not the best way to solve a problem, as this approach
leads to reoccurrence versus sustainable improvement. A better approach is to eliminate the
root cause by conducting an effective root cause analysis, and identifying and implementing
the best possible solution.
Overview
A Root Cause Analysis (RCA) is a structured step-by-step technique that focuses on finding
the real cause of a problem, and identifying, evaluating and implementing the best possible
solution. This technique helps assessors describe what happened, to determine how it
happened and to understand why it happened.
Only when we are able to determine why an event or failure occurred, we’ll be able to
generate practical recommendations for preventing incident recurrences.
There are several methods/tools available for conducting RCA and designing Corrective
Action Plans (CAP). The method explained here is similar to 5-Why analysis method. This is
for guidance only and vendors/facilities are free to use other methods as long as they prove
to be effective for sustainable resolution of issues.
Root Cause Analysis Procedure

1.2.1 Stage 1 – Issue Identification
Refer to the assessment report from Gap Inc. to identify the important/recurring issue that
needs to be taken up for RCA.
1.2.2 Stage 2 – Issue Analysis

1. Conduct a preliminary analysis of the issue at hand, to determine which areas/
departments are involved/impacted. Conduct a meeting with all the necessary
departments involved with the specific area for improvement. Remember that an issue
may occur because of problem with any or all of the following parameters so ensure to
include all relevant representatives in the meeting so that the issue and root causes can
be discussed from all points of view.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 12: Root Cause Analysis Guidelines 201
→→ Materials
• Defective raw material
• Wrong type for job
• Lack of raw material
→→ Employees
• Inadequate capability
• Lack of Knowledge
• Lack of skill
• Stress
• Improper motivation
→→ Machine/Equipment
• Incorrect tool selection
• Poor maintenance or design
• Poor equipment or tool placement
• Defective equipment or tool
→→ Environment
• Disorder workplace
• Poor job design and/or layout of work
• Surfaces poorly maintained
• Inability to meet physical demands of the task
• Forces of nature
→→ Management
• Lack of management involvement
• Inattention to task
• Task hazards not dealt with properly
• Other (horseplay, inattention....)
• Stress demands
• Lack of Process
• Lack of Communication
→→ Methods
• No or poor procedures
• Practices are not the same as written procedures
• Poor communication

2. Initiate a brainstorming process -- brainstorming should aide in determining the root
cause of the problem (refer to Root Cause Analysis Format designed to identify and
address areas for improvement.) to determine as many possible causes that could have
created the issue. “Ask as many times as possible, WHY”.
a. As tracing back the “whys?” to the root cause, issues that affect not only the
original symptom but also the entire organization will be identified. Through
this process many different symptoms will be uncovered that will help traced
back to two or three systemic sources.
b. When conducting this analysis it is important to focus on the process of
conducting the root cause of the problem and not the person(s) involved.
1.2.3 Stage 3 - Solution Analysis

1. Once the root cause of the problem has been identified, the next step is to identify
potential solutions. There may be various solutions, which should be noted.
2. After the solutions have been identified, they will need to be evaluated for potential
risks, impacts and benefits. It is important to select the most effective, efficient and
economical option that will work best. The sustainable improvement plans/corrective
actions (refer to Developing Effective Improvement Plans), should be endorsed by
management, and these may include but are not limited to, enhancements/creation of
administrative/management systems, procedures, that would sustainably address the
areas of non-compliance.
1.2.4 Stage 4 - Implementation

1. Once the best option has been selected it will need to be implemented, assessed and
possibly modified for effective impact. This process of self examination should be
continuous.
1.2.5 Stage 5 - Communication

1. Finally, there should be commitment by all departments involved to implement agreed
corrective actions. Plans must be communicated to those affected by or responsible for
any part of the corrective actions.
a. Communications should be recorded and signed by management.
b. Action plans/corrective actions should have a set timeline and specific owner
(refer to Root Cause Analysis Format)
Root Cause Analysis Tools
2.1 Root Cause Analysis Flow Chart
Review Prior Assessment Reports

Issue
Identification
Identify Issue(s)
Analysis of Issue(s) Identified
Meeting with Departments

Issue Invovled
Analysis
Conduct “Brainstorming” —
Ask “WHY”
Identified Root Cause
Identify &
Evaluate Potential
Solution
Solutions
Analysis
Select Solution
Implementation Communicate, Implement,

Re-assess Solution
& Re-assessment

2.2 Root Cause Analysis Format
Below Root Cause Analysis Format is a sample for root cause analysis meeting. Potential solutions are to be identified, evaluated and then the most appropriate
solution is to be selected through the brainstorming sessions and subsequent root causes identification and action plan development. Vendors/ facility may use any
other format that they deem suitable (e.g. 5-why analysis/ fishbone diagram etc.)

Root Cause Analysis Format
Areas for improvement
Departments involved:
Conduct Root Cause

Brainstorming Process Evaluate Solutions/ Actions Plans/Corrective Date
“WHY” Potential Solutions Select Actions Owner Due Date Completed
Part 3 Appendix Appendix 12: Root Cause Analysis Guidelines 205

2.3 Developing Effective Corrective Action Plan
Implementing effective improvement plans/corrective actions for each cause reduces the
probability that an issue will recur.
Corrective Actions (CA) should directly address the root causes identified providing specific
action for their elimination. Vague IPs such as, “Improve sexual harassment policy” do
not address the real issue at hand. Using cause classifications such as supervisor error or
equipment failure should be avoided.
There could be two kinds of Improvement Plans:
→→ Immediate. What should be done today to resolve the area for improvement (AFI)?
Action is taken as soon as AFI is identified.
→→ Long Term. What should be done to prevent recurrence? Long Term CA’s results in
changes to process and procedures.
When developing CAs, the following questions should be asked to ensure these are viable:
→→ Will the CA prevent recurrence?
→→ Is the CA feasible?
→→ Does the CA address all the causes?
→→ Will the CA cause detrimental effects?
→→ Will training be required as part of the implementation?
→→ In what time frame can the CA reasonably be implemented?
→→ What resources are required for successful development of CAs?
→→ What resources are required for successful implementation and sustainability of CAs?
At the end narrow down to the most effective, efficient and economical option: what will
work best.
It’s important to understand that, effective problem solving through Root Cause Analysis
techniques, represent for some organizations, a significant change on their way of thinking
and a significant cultural shift. Therefore the importance of management involvement and
buy in to have a successful sustainable outcome.
A successful CAP requires management that is involved at the proper level and is willing to
take responsibility to allocate adequate resources for CAP implementation. In addition, those
affected by or responsible for any part of the CA should be involved in the process.

2.4 Root Cause Analysis Scenarios
The following are examples of Root Cause Analysis Scenarios taken from real situations in
facilities.
SCENARIO #1:
AREA FOR IMPROVEMENT: Emergency Lights are not functioning.
→→ Meeting with departments involved: Maintenance Manager, Shipping Supervisor,
Human Resources Manager and Compliance contact.
→→ Brainstorming: Management started the brainstorming session asking: why?
• Why is the life period of emergency lights only a couple of months?
• Why are emergency light batteries out of power every day?
• Why is the quality of the emergency lights so poor?
→→ Root Cause Identified: No independent power line to emergency lights.
Facility turns off the power after working hours thus emergency lights are turned on
automatically. Therefore batteries loose all their power during the night.
→→ Corrective Action(s):
1. Install an independent power line to emergency lights to avoid batteries loosing
power every night.
2. Maintenance procedure will include:
a. Checking lights every day
b. Reporting when an emergency light is not functioning in order to be
changed immediately
c. Communicating maintenance changes to procurement department
so new emergency lights could be purchased and maintained in stock
before replacements are due.
d. Maintaining maintenance records
3. Include changes in the procedure to training conducted within the department,
including new maintenance personnel.
→→ Awareness/Communication:
• Conduct meetings with the maintenance department to explain the actions that
were going to be taken if they had an emergency light not functioning to avoid this
problem from recurring.
• Conduct meeting with maintenance department to review updates to maintenance
procedure. Procedures were posted in department’s bulletin board.
• Meeting records were kept as part of the recordkeeping policy.
→→ RC Analysis Outcome:
The facility installed an independent power line to emergency lights and saved money
by not having to buy new lights so frequently.
New procedures were put into place.
SCENARIO #2:
→→ AREA FOR IMPROVEMENT: Workers not using filter masks at spot cleaning station.
→→ Meeting with departments involved: Production Manager, supervisors, Maintenance
Manager, Controller, Compliance contact, HR contact, and some workers.
→→ Brainstorming:
1. Why are workers at the spot cleaning station using dust masks instead of filter
masks when using chemicals?
2. Why haven’t health risks been reviewed with workers?
3. Why hasn’t proper PPE been selected?
4. Why don’t workers understand the need of using filter respirators?
5. Why hasn’t management taken any disciplinary actions for this specific
problem?
6. Why aren’t there any records of training in the proper mask usage at the spot
cleaning station and on the consequences of not using them?
7. Why are some spot cleaning stations located in the middle of the production
area without any ventilation?
→→ Root Cause Identified:
1. Health/Risk assessment not performed
2. No training
Facility and workers are not aware of the health risks derived from not using the
appropriate masks (filter) at spot cleaning stations; moreover, facility has not
provided workers any training on this matter.
→→ Corrective Actions(s):
1. Implement an H&S program that among other things will include a health and
risk assessment of all functions. Program will also include an incentives program
and awareness campaign.
2. Once health risks are identified, training will be developed and provided to
workers in the spot cleaning area:
a. Training will include review of MSDS, PPE usage and consequences of not
using PPE.
b. A training scheduled will be developed and implemented targeting all
new hires.
c. Facility will keep records of these trainings.
1. Create and implement PPE policy and procedures that would include among
other things:

a. Implementation of a respiratory protection program with an external
supplier, which will include, regular monitoring in order to among
others, provide the best PPE for this area.
b. Periodical checks on the masks provided to workers to assess quality,
condition, adjustment, maintenance, cleaning etc.
c. Establishment of “mandatory PPE usage” areas
→→ Awareness/Communications:
1. Implemented an awareness campaign as part of the H&S program that include:
• Meetings with workers in the spot cleaning area to review new policies,
procedures, incentive program and training details.
• Training
• Posting of policies and procedures in bulleting board
• Posting H&S signs through out the facility
2. Keep meeting records as part of the recordkeeping policy.
→→ RC Analysis Outcome:
The proper respirators were provided to workers who were trained on the usage and
consequences of not using this equipment. The training helped workers understand
the importance of using respirators in their daily work activities.
As a result of the health/risk assessment facility identified some very hazardous

chemicals in use and was able to substitute them for chemicals with lesser health risks
for workers.
Appendix 13:
Gap Inc. Facility Ratings

Methodology Overview
In 2015, Gap Inc. introduced a new facility ratings methodology to evaluate the social and
environmental performance of its suppliers. These updates are based on feedback received
by Gap Inc.’s Global Sustainability team, Global Supply Chain team, vendors, and external
stakeholders.
What is the difference with this new approach?
Dimensions Old rating system New rating system Highlights

Structure 100% COVC based 100% COVC based • Move towards simplicity
with easy to understand
Scale Starting point at 75 Starting point at 100 scale
Color Scale Green 75 - 98 Green 86 - 100 • Rating will only be

Light Green 65 - 74 Yellow 65 - 85 produced at the time of a
Yellow 51 - 64 Red 0 - 64 full assessment
Red 0 - 50 • New severity scale
developed after review
History 4 Full Assessments + 1 Full Assessment issues
Follow-ups • Incentivizing improvement
and reducing issue
Issue severity multiplier Key x5 Critical x15
recurrance is key objective
Non-Compliance x1 Severe x5
Key x3 • Penalty box category to
Non-Compliance x1 reflect most egregious issues
Severity level within None Distinguish within some issues

issues
Issue Recurrence Double penalty if within 4 Double penalty if within 2
assessments assessments
Egregious Violation None Penalty box category for select

Process critical violations*

Desired impact to vendors
Simple →→ Calculation is straightforward

→→ Fewer color categories
→→ Scoring scale is intuitive
Reactive →→ Based on current autid and represents current state

→→ Issue reccurance for past 2 assessments
Accurate →→ Different levels of severity

→→ Severity levels within issues capture subtlety
Transparent Directly link issue resolution to score improvement

Issue Levels prioritize what is most important
Facility Ratings Frequently Asked Questions

Q: What is the definition of a recurring issue?
A: An issue that was found, resolved, but was found again in the next assessment. Ex: A
blocked exit was found in the previous assessment. The violation was addressed and the
issue was closed. However another exit was found to be blocked in current assessment.
Q: When will a new rating be generated?

A: A new rating will be generated at the time of a Full Assessment. Facilities are currently
inspected roughly every 12 months. In certain circumstances, we may perform full
assessments at a facility more frequently.
Q: What are examples of issues with different levels of severity?

A: We are currently addressing working hour violations. Other areas to build in different
levels of severity are under consideration.
Q: Can a facility earn “bonus points”?

A: Under the new methodology, we will no longer award bonus points. Bonus point activities
(such as certifications and program participation) will be tracked in a facility scorecard and
full report.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 13: Gap Inc. Facility Ratings Methodology Overview 211
Q: I have a suggestion on how to improve the ratings system – what should I do?
A: We plan to revisit the facility ratings periodically to improve and evolve the methodology.
A governance committee, comprised of GS and GSC leaders, will make final decisions. Please
provide your suggestions to the Assessment & Remediation Manager overseeing your facility.
Q: How are vendor ratings calculated?

A: Vendor ratings are calculated as an average of all facilities (including cut & sew, laundries, etc.)
that roll-up to the Vendor.
Q: Which facilities fall under a vendor?

A: Vendor scoring is based on facility mappings as defined by the Vendor Profile system.
Q: What issues are considered to be “egregious”?

A: Full list TBD.
Q: Where can I find out more about a particular facility’s issues?

A: We are in the process of building a new system that will include facility scorecards detailing
open violations at each facility. We expect the system will be in place by July 2015.
Q: How is issue recurrence handled for issues with different levels of severity?
A: If the issue shows no improvement, then issue recurrence rules apply.
Q: How is facility expansion accounted for?

A: If the facility expansion triggers a full assessment, a new rating will be generated.

Appendix 14:
Gap Inc. Supplier

Sustainability Joint
Assessment Program
Overview
Introduction
Gap Inc. has a long history of partnering with its vendors to advance our shared business
and sustainability goals. In 2015, we are launching a new chapter in this partnership, as we
seek to work with some of our most important vendors in making further progress on our
shared goal of growing our businesses in a responsible and sustainable way.
To this end, Gap Inc. has recently partnered with Verité, a leading NGO focused on ensuring
that people work under safe, fair, and legal conditions, to conduct “Joint Assessments” in
a subset of our approved facilities each year. These assessments are focused on engaging
workers, to help both Gap Inc. and your company better understand workers’ needs, so our
efforts to improve working conditions can be more targeted and have a higher return on
investment.
The goals of this program are as follows:

→→ To measure and subsequently improve workers’ sense of value and their engagement
at work
→→ To improve compliance with local and international labor standards as well Gap Inc.’s
Code of Vendor Conduct
→→ To identify opportunities for improved business performance
Gap Inc. has taken an approach similar to this in how we manage and work with our own
employees. We have found that having engaged employees has a great number of benefits.
An engaged employee:
→→ Is more productive and reliable, and works actively to improve the business
→→ Proactively seeks opportunities to improve his or her self, as well as organizational and
business performance
→→ Is positive about her/his job and the employer, and believes in the business
→→ Treats others with respect, and helps colleagues perform more effectively
→→ Goes above and beyond the requirements of the job
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 14: Gap Inc. Supplier Sustainability Joint Assessment Program Overview 213
This initiative is being piloted in 2015, and will be scaled in 2016 and beyond. Our goal is to
develop a new approach to improving working conditions that increasingly focuses on the
needs of workers, and does so in a way that provides benefit to your business.
These assessments will be done in partnership with Gap Inc.’s Assessment & Remediation
team, and the outcomes and findings of these assessments will not directly contribute to
your facility ratings. However, if severe or critical non-compliance issues are identified the
assessment process, these findings will be shared with the Gap Inc. team, which may impact
your facility rating.
Joint Assessment Objectives & Overview

Our intention is to establish baseline scores for workers’ sense of value and engagement
at work, and then measure those scores over time to see how our efforts are leading to
improvements in workers lives.
We believe that this approach will help us identify key opportunities for you, for your
employees, and for Gap Inc. By collecting data on what matters most to your employees,
we will be able to better partner with you to identify potential areas for improvement and
investment in ways that will lead to an increasingly engaged workforce. We will analyze the
data to identify actionable insights that you can use to better engage your workers, which
will in turn, we believe, lead to more engaged, productive, reliable, and positive-minded
employees.
This program is comprised of three main components:

1. Self-Assessment Questionnaire (SAQ): Participating facilities will be sent an SAQ at
least one month prior to the Joint Assessment. This SAQ captures workforce profile
information (such as number of workers; categories of workers) business performance
and social compliance indicators (such as absenteeism rates; defect rates; grievance
types), which will allow us to be more targeted and helpful when we are visiting your
facility. See Appendix 1 for a snapshot of the SAQ.
2. Worker Sense of Value Survey (SOV): When Gap Inc. and Verité are on-site conducting
an assessment, Verité and Gap Inc. will conduct interviews and surveys with workers
in both one-on-one and group settings. These findings will be anonymous and will be
aggregated, and will be oriented towards understanding how workers feel about their
roles in your organization, what they appreciate about working there, and what they
would like to see improve. Workers that are selected for interviews will come from
all levels of your organization, with interviews and surveys lasting no longer than 45
minutes, and the sample size will not be higher than 15% of your facility’s workforce.
3. Data Analysis and Insights: Following the assessment, Gap Inc. and Verité will partner
to review the SAQ, SOV, and will identify the key factors that lead to workers sense
of value and engagement. The important output for you, and for Gap Inc., will be
the identification of areas of opportunity to improve your employees’ sense of value
at work. The output for Gap Inc. will be the identification of opportunities for our
Capability Building and Assessment & Remediation programs.

Logistics & Scheduling
We recognize that this type of assessment brings with it logistical challenges, and one of
our top priorities is partnering with you to minimize and avoid any interruptions to your
business operations. Our Supplier Sustainability team is here to help you in planning and
executing this assessment, and we encourage you to reach out to us should you have any
questions or concerns. Depending on the number of workers in your facility, the assessment
will be for either one or two full days.
Joint Assessment Workflow for Gap Inc. & Verité:

1. Gap Inc. Pre-Assessment Activities:
• Gather facility information from Gap Inc. Global Sustainability Data System
• Contact supplier and schedule assessment
• Coordinate with facility for times and locations for interviews
• Distribute SAQ
• Agree on SAQ response date
• Review SAQ
2. Assessment Activities:
• Conduct opening meeting with facility management
• Gap Inc. Assessment & Remediation Specialist conducts COVC assessment
• Verité representative(s) conduct SOV
• Review preliminary findings with facility management during closing meeting
3. Post-Assessment Activities:
• Gap Inc. and Verité to analyze SAQ and SOV findings and draft a facility-specific
report
• Follow-up plan is shared with designated contacts at the facility, which will include
a report that includes recommendations on steps that may be taken to improve
employee engagement at your facility
• Gap Inc. and facility management partner on implementing relevant findings
Joint Assessment Workflow for Participating Facilities:

As indicated above, one important purpose of the program is to help you better engage
the workers for a more productive workforce, therefore for better business and social
performances. To achieve these intended outcomes of the program, your collaboration and
active participation is crucial. Below are things that we will need from you in the process:
Prior to the assessment:
1. Fill the Self-Assessment Questionnaire (SAQ) and return to Gap Inc. no later than
two weeks after receiving it. The SAQ consists of two parts. The first is Company and
Workforce Profile and business performance KPIs, which must be filled out as accurately
as possible. If you do not have certain information at your disposal, please work with
your Gap Inc. counterpart to identify ways in which this information can reasonably be
collected. The second aspect of the questionnaire is a self-checklist of employee “Sense
of Value” driver factors. If you do not have the information or do not know the answer,
please check the “No” or “Don’t have” answers. There is no right or wrong answers to
these questions, there would be no consequences for any answer, as the purpose of
these questions is simply for background and to help our team be more thorough when
they are on-site.
2. An e-copy of employee rosters to be sent to Gap Inc. at least three days prior to the
on-site date. In order to reduce the interruption of our work to your production, we will
do our best to limit our on-site time to the minimum, so pre on-site preparation is a key
priority for all of those involved in this endeavor. Employee rosters will help us sample
the workers for the on-site survey. Should you have concerns about privacy of employee
information, you can use employee identification number to replace real names of the
employees in the rosters.
3. To reduce the level of interruption of our work to your production, we will provide you
with an On-site Work Plan two weeks prior to our arrival.
4. To ensure the on-site process is as efficient as possible, you will need to orient your
entire management team on the engagement, make work/production plans according
to the on-site work plan agreed and prepare your production and coordinate with us
accordingly during our on-site time.
During the Assessment:

1. At least senior management representative must attend the opening and closing
meetings.
2. Management staff will be needed at all the times during our on-site time for helping
with the work process, including setting up of the survey and coordinating the process
(an HR representative will be ideal).
3. Provide suitable venues for worker survey and interview. Suitable venues include worker
training rooms or the cafeteria, or worker rest stations that can host 30 to 50 workers
at one time (please note that management offices, or other areas that workers are not
accustomed to being in are not appropriate venues). The venues need to be equipped
with chairs so workers can sit and write.

4. Organize workers for either survey or interviews based on the work plan agreed.
5. Pay workers for the time that they spend on survey and interviews. Each sampled
worker will take no longer than 45 minutes to participate in the survey or interviews.
6. Help answer questions that the Gap Inc. and Verité team may have on the SAQ.
Following the Assessment:

1. Clarify questions that are remaining from on-site visit in timely manner.
2. Provide any supplementary materials that may be needed.
3. Review the final assessment report and provide any feedback as needed.
Joint Assessment Output

Following the assessment, you will receive a full report from Gap Inc. on potential
opportunities for you and your management staff to increase employee engagement.
Gap Inc.’s Assessment & Remediation and Capability Building teams will also be using this
information to help improve our own programs, with our ultimate objective being that
we find new, innovative ways to partner, to help improve your employee engagement,
your employees’ sense of value, and eventually help you improve productivity, reduce
absenteeism, and diminish employee turnover.
For more information, please contact your Gap Inc. Supplier Sustainability point of contact.
Appendix 15.A:
Risk Assessment Template
Risk Assessment Team Leader: Team Members:
Implementation
No. Hazard Risk Level (H/M/L) Preventive actions Person in Charge (Yes/No/In progress)
Warehouse
1 Ex: one of the exit doors is locked regularly M All exit doors need to be Mr. A Y
opened always during
working hours.
2 Ex: workers carry goods in inproper L Effective training need to be Mr. B In progress
ergonomics. provided.
3
4
5
6
Cutting Section

1
2
3
4
Finishing Section
1
2
3
218
4
This template was created by ILO Better Work and is shared here with their permission.
Implementation
No. Hazard Risk Level (H/M/L) Preventive actions Person in Charge (Yes/No/In progress)
Shipping Area

4
Office
Surrounding Area
Part 3 Appendix Appendix 15.A: Risk Assessment Template 219

Appendix 15.B:
Risk Assessment Management

Establish the Context
→→ Strategic business context
→→ Country specific context
→→ Develop criteria and structure
Identify Risks
→→ What could happen?
→→ How could it happen?
M ANAGEMENT MON ITORI NG AN D REVI EW
Analyse Risks
CONSU LT AN D ENGAGE WORKERS

Determine Existing Controls
Determine Determine
likelihood impact
Estimate level of risk
Evaluate Risks
→→ Compare against criteria
→→ Set risk priorities
Risk Assessment
YES
ACCEPT
RISK?
NO
Treat Risks
→→ Identify and evaluate controls
→→ Select and prepare controls
→→ Implement controls

Appendix 15.C:
Risk Assessment: Hierarchy

of Controls
ELIMINATE →→ Can we stop performing spot cleaning?
if that is not feasible then

→→ Can we replace chemicals used for spot
SUBSTITUTE cleaning with a less harmful alternative?
and/or
→→ Can we move spot cleaning to a separate room

ENGINEER with proper ventilation and fume captors?
and/or
→→ Can we write a procedure for how to
ADMINISTRATIVE store, use and dispose of the chemical?
and/or
BEHAVIOR →→ Can we perform training of workers on

how to safely perform sport cleaning?
and/or
PPE →→ Can we give workers masks and gloves

to lower exposure to the chemical?
Control Effectiveness Description Effort
ELIMINATION 100% Hazard removed Remove or redesign the process or plant so hazard does LOW
not exist
SUBSTITUTION 75% Hazard reduced Hazard substituted by something of a lesser risk e.g. MODERATE
chemical replaced with less harmful chemical
ENGINEERING 50% Hazard reduced or Hazard controlled through isolation using engineered MODERATE
controlled measures e.g. machine guarding
ADMINISTRATIVE 25% Soft controls that rely Hazard controlled by safety procedures HIGH
on people
BEHAVIOUR 25% Soft controls that rely Hazard controlled by influencing people e.g. signs and HIGH
on people training
PPE 5% Damage only limited Hazard controlled by the use of personal protective MAJOR
equipment e.g. masks, hearing protection
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 15.C: Risk Assessment: Hierarchy of Controls 221
Causes Impact
1. P RE RY 1.
VE VE
N TIO Risk Event CO
2
N RE 2
3. 3.
Liklihood Consequence
4. 4.
Controls Controls
5. (Pre-event) (Post-event) 5.
6. 6.
7. 7.
8. 8.
Existing Liklihood Affecting Controls Owner Existing Liklihood Affecting Controls Owner
1. 1.
2 2
3. 3.
Bow-Tie Analyis
4. 4.
5. 5.
Tasks (future controls) Owner Date Tasks (future controls) Owner Date

1. 1.
2 2
3. 3.
Appendix 15.D:
Overall Risk Control Effectiveness Consequence Factor Liklihood Factor Liklihood Factor Risk Owner
□ Fully effective □ Minor □ Rare □ Low risk Name
□ Partially effective □ Major □ Possible □ Medium risk Date
□ Largely ineffective □ Catastrophic □ Almost certain □ High risk Signature
222
2 3
What could cause this to happen? What could the impact be if it
happened?
1.
1 1.
2
Risk Event
2
3.
3.
4.
4.

5.
5.
4 5
What can we do now to limit these What can we do now to limit these
causes? impacts?
1. 1.
2 2
3. 3.
4. 4.
5. 5.
Tips for Success

Involve workers. You need the right mix of operational and risk management experience.
Correct level of detail. Too high and the activity becomes meaningless. Too low and it becomes overly labour intensive.
Keep it practical. Avoid tick-box mentality and ask: “practically, what controls can we add?”
Use this method to its full potential. Bow-tie is only part of the picture. Focus on critical controls, procedures and responsible people.
Part 3 Appendix Appendix 15.D: Bow-Tie Analysis 223

EFFECT / CONSEQUENCE
Risk Assessment
Harm to people First aid case/ Medical Lost time injury/ Single fatality/ Multiple
exposure to treatment case/ reversible impact quality of life/ fatalities/
minor health risk exposure to on health irreversible ultimately fatal
Ratings Matrix
major health risk health impact impact on health

Environmental Minimal Material Serious Major Extreme
impact environmental environmental environmental environmental environmental
impact impact impact impact impact
Business Minimal impact Some impact/ Reduced Breakdown of No business.
interruption on non-core delays. dealt performance / key activities/ Survival of
operations with at ops level targets not met revenue loss/ company is
Appendix 15.E:
threatened
Property Minor damage Minor damage Damage or loss Extensive Destruction or
or vandalism to or loss of <5% of of <20% of total damage or complete loss of
asset total assets assets loss of <50% of >50% of assets
assets
Economic 1% of annual 2-5% of annual 5-10% of annual >10% of annual >30% of annual
budget budget budget budget budget
1 2 3 4 5
Chance Probability Frequency Insignificant Minor Moderate Major Catastrophic
Is expected to >95% Event has occurred A Almost certain 11 16 20 24 25
occur in most frequently. Likely
circumstances within 1 year.
Will probably >65% Event has occurred B Likely 7 12 17 23 24
occur in most infrequently. Likely

circumstances within 5 years.
LIKELIHOOD
Might occur at >35% Event has happened in C Possible 4 8 15 18 22

some time the past. Could happen
within 10 years.
Could occur at <35% Event has happened in D Unlikely 2 5 9 14 19
some time the past. Could happen
within 20 years.
May occur only <5% Event has not E Rare 1 2 6 10 15
in exceptional happened in the past.
circumstances Unlikely to happen
within 20 years.
224
Catastrophic
MEDIUM
HIGH
HIGH
CONSEQUENCE
Major
MEDIUM
HIGH
LOW
Minor
MEDIUM
LOW
LOW
LIKELIHOOD
Catastrophic Major Minor
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 15.E: Risk Ratings Matrix 225
Identify Risks
→→ What could happen?
→→ How could it happen?
M ANAGEMENT MON ITORI NG AN D REVI EW
Analyse Risks
Risk Assessment Process
Determine Existing Controls
CONSU LT AN D ENGAGE WORKERS

Determine Determine Organize a Hazard Hunt
likelihood impact in the facility
Estimate level of risk
Make it fun with a
Risk Quiz
YES
ACCEPT
RISK?

NO
Appendix 15.F:
Perform a Butterfly
Analysis
Treat Risks
→→ Identify and evaluate controls
→→ Select and prepare controls
→→ Implementation The Tiger in the Zoo
226
Appendix 16:
Gap Inc. Water Quality

Program for Denim
Laundries Guidelines
Policy
Compliance with Gap Inc.’s Water Quality Guidelines (WQG) and Program is mandatory for
vendors and facilities washing Gap Inc. branded denim.
Purpose
To provide detailed instructions on how to implement Gap Inc.’s WQP.
Scope
→→ All new, reactivated and active laundries (free-standing or facility with in-house
laundry) washing Gap Inc. branded denim
→→ All active laundries shifting their production type to Gap Inc. branded denim
→→ Global Sustainability’s Environmental Capability Building (ECB), Assessment &
Remediation (A&R), and Supplier Sustainability Operations teams.
→→ Gap Inc.’s Global Supply Chain Denim Category teams and 3rd party provider H2O Insight.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 16: Gap Inc. Water Quality Program for Denim Laundries Guidelines 227
Requirements
Type of Discharging Directly Discharging To Central
Laundry To The Environment Treatment Systems Deadline
New Denim 1. Test laundry’s wastewater 1. Test laundry’s wastewater Within 45 days
Laundry 2. Login to www.h2oinsight.com and 2. Login to www.h2oinsight.com and upload from receiving
upload original testing report, issued original testing report, issued by certi- WQP package
by certified laboratory, for the 17 WQG fied laboratory, for parameters in central
parameters 1 treatment system’s wastewater discharge
3. Upload copy of wastewater discharge regulations
permit 3. Upload copy of central treatment system’s
4. Upload copy of local wastewater dis- wastewater discharge quality data (if pos-
charge regulations sible) and discharge regulations
5. Complete laundry’s profile/information 4. Upload copy of wastewater discharge

permit
If testing results do not meet Gap Inc.’s water
quality guidelines, or local wastewater 5. Complete laundry’s facility profile/informa-
discharge regulations, whichever is stricter: tion
6. Make necessary operational or equip- If testing results do not meet central treatment
ment modifications in wastewater system’s wastewater discharge regulations:
treatment system 6. Make necessary operational or equipment
7. Re-test laundry’s wastewater modifications in wastewater treatment
system
8. Upload new testing report by specified
date 7. Re-test laundry’s wastewater
date
Active Denim 1. Test laundry’s wastewater 1. Test laundry’s wastewater Within 60 days
Laundry 2. Login to www.h2oinsight.com and 2. Login to www.h2oinsight.com and upload from receiving
upload original testing report, issued by original testing report, issued by certi- WQP package
certified laboratory, for the 6 key WQG fied laboratory, for parameters in central
parameters 2 treatment system’s wastewater discharge
3. Upload copy of wastewater discharge regulations
permit 3. Upload copy of central treatment system’s
4. Upload copy of local wastewater dis- wastewater discharge quality data (if pos-
charge regulations sible) and discharge regulations
5. Complete laundry’s profile/information 4. Upload copy of wastewater discharge

permit
If testing results do not meet Gap Inc.’s
water quality guidelines, or local wastewater 5. Complete laundry’s facility profile/informa-
discharge regulations, whichever is stricter: tion
6. Make necessary operational or equip- If testing results do not meet central treatment
ment modifications in wastewater system’s wastewater discharge regulations:
treatment system 6. Make necessary operational or equipment
7. Re-test laundry’s wastewater modifications in wastewater treatment
system
date 7. Re-test laundry’s wastewater
1
17 WQP parameters - Temperature, pH, Total Suspended Solids (TSS), Biochemical Oxygen Demand, Chemical Oxygen Demand, Color, Anti-
mony, Arsenic, Cadmium, Chromium, Cobalt, Copper, Cyanide, Lead, Mercury, Nickel, Zinc
2
Six WQP key parameters - Temperature, pH, Total Suspended Solids (TSS), Biological Oxygen Demand (BOD), Chemical Oxygen Demand
(COD) and Color

Type of Discharging Directly Discharging To Central
Laundry To The Environment Treatment Systems Deadline
Reactivated 1. Reactivation within 12 months – Laundry • Reactivation within 12 months – Laundry is Within 60 days
Denim Laundry is required to participate or complete WQP required to participate or complete WQP after from receiving
after reactivation following active denim reactivation following active denim laundry WQP package
laundry WQP requirements WQP requirements
• If laundry has already completed the • Reactivation after 12 months – Laundry is
WQP the year it is reactivated, no required to participate in WQP after reacti-
further action is required vation following active denim laundry WQP
requirements
2. Reactivation after 12 months – Laundry is
required to participate in WQP after reacti-
vation following active denim laundry WQP
requirements
Active Denim Same as Active Denim Laundry Same as Active Denim Laundry Within 60 days
Laundry where from receiving
production type WQP package
shifted from Non-
Gap Inc. denim to
Gap Inc. denim
Failure to comply with WQP and Guidelines carries the following consequences:
New Denim Laundry/Reactivated Withdrawal from vendor approval process provided no key issues are
Denim Laundry opened at time of withdrawal. Laundry 3 is not authorized to wash
Gap Inc. branded denim
Active Denim Laundry Revocation – Laundry loses authorization to wash Gap Inc. branded
denim for 12 months
Active Denim Laundry which Laundry is not authorized to wash Gap Inc. branded denim
production type shifted from Non-
Gap Inc. denim to Gap Inc. denim
3
If the laundry is in-house, the facility is also not authorized to manufacture/handle Gap Inc. branded product after withdrawal.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 16: Gap Inc. Water Quality Program for Denim Laundries Guidelines 229
Appendix 17:
Gap Inc. Restricted Sub-

stances List (RSL) and Zero
Discharge of Hazardous
Chemical–Manufacturers’
Restricted Substances List
(ZDHC MRSL)
Policy
→→ Compliance with Gap Inc.’s Restricted Substance List (RSL) and the Zero Discharge
of Hazardous Chemicals’ (ZDHC1) Manufacturing Restricted Substance List (MRSL) is
mandatory for vendors, mills, and trim suppliers for Gap, Banana Republic, Old Navy,
Athleta, and Outlet brands.
→→ RSL sets limits for substances in components of finished products.
→→ MRSL bans intentional use of hazardous substances by setting concentration limits for
substances in chemical formulations used for manufacturing (input chemistry).
Purpose
→→ To ensure Gap Inc.’s compliance with global product legislation restricting hazardous
substances in apparel, footwear and accessories.
→→ To prevent an industry-aligned list of banned substances from entering the supply
chain where they have the potential to contaminate products or be discharged into the
environment.
Scope
→→ All branded product sourced for Gap, Banana Republic, Outlet, Old Navy, and Athleta
destined for any market.2
→→ Gap Inc. sourcing channels, production and merchandising departments.
1
ZDHC is an apparel and footwear industry consortium with the goal of leading the industry towards zero
discharge of hazardous chemicals by 2020.
2
The Gap Inc. RSL and ZDHC MRSL do not apply to personal care products. The ZDHC MRSL does not apply to
leather goods at this time.

Requirements
→→ New and existing vendors, mills and trim suppliers must:
• Meet Gap Inc.’s RSL & & MRSL concentration limits in each product component.
• Use MRSL-compliant chemical formulations for manufacturing and related processes.
• Obtain and maintain a copy of the most current RSL and MRSL.
• Sign the RSL Acknowledgement form (new vendors, mills and trim suppliers
only) and return it to Gap Inc.’s Vendor Management, VAS or Product Safety &
Regulations (PSR) teams.
→→ The RSL, MRSL and accompanying documents are available on Gap Source Library.
• Participate in Gap Inc.’s RSL & MRSL testing program.
→→ Gap Inc.’s RSL & MRSL testing program standard operating procedure (SOP) and
manuals are available on Gap Source Library.
• Distribute the MRSL to their chemical suppliers to ensure purchased formulations
are MRSL-compliant.
→→ If product containing restricted substances above RSL limits or in violation of MRSL
requirements is found, penalties vary from order correction or cancellation to payment
of subsequent RSL testing of their products, among others.
→→ A complete list of penalties can be found in Gap Inc.’s RSL and MRSL testing program
SOP available on Gap Source Library.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 17: Gap Inc. Restricted Substances List (RSL) and Zero Discharge of Hazardous 231
Substances—Manufacturers’ Restricted Substances List (ZDHC MRSL)
Appendix 18:
Gap Inc. Chemical Storage

and Handling Guidelines
Example Chemical Storage Area Plan
The following shows one way to separate different chemical types in a storage area. This is
only a sample. The chemical types in this diagram (acids, oxidizers, flammables and alkali) do
not need to be in the corner or section of the storage area as indicated by the diagram; the
key point is to separate different types of chemicals.
(Top View)
Acids Oxidizers
Flammables Alkali
Separate different types of chemicals. See the Chemical Incompatibility Guide in this section
for further background.

Chemical Handling Guidelines
As it relates to Hazardous Substances standard, the following information describes storage
and handling guidelines that help promote safer practices. These are recommended guidelines a
facility can use to segregate their chemicals, but are not specific requirements. Other storage and
handling guidelines may also be used to meet the standard. This information is provided to A&RS
as background on what compliance with Hazardous Substances standard might look like.
Caution and common sense should be used when storing chemicals, so that incompatible
materials are not mixed together. Chemicals should be handled with caution and one
should understand their chemical, physical and toxic properties prior to working with them.
The following chemical handling guidelines are recommended to avoid dangerous reactions
between chemicals:
→→ Store similar materials together: acids with acids, bases with bases.
→→ Acids should not be mixed with:
• Bases (alkali chemicals) [Example: sodium hydroxide, “Caustic Soda”, “Lye”, “Sodium
Hydrate”]
• Oxidizers [Example: Sodium Hypochlorite “bleach”]
→→ Hydrogen peroxide may explode when heated. Keep it cool and away from acids, bases,
and fabric or clothing.
→→ Do not store ammonia and ammonia-containing compounds (for example Ammonium
Hydrogen Fluoride “Laundry Sour”) with acids, bases or flammable liquids.
→→ Many chemicals have more than one hazard. Example: Acetic Acid, Oxalic Acid, Sulfuric
Acid are both Corrosive and Acids.
→→ It is recommended that the minimum separation distance between containers is 3
meters (9 feet).
→→ It is recommended that the distance between liquid containers is 2 times the height
of the container. Example: Container is 1.5 meters tall. Distance between containers
should be a minimum of 3.0 meters.
→→ Store bags of dry powder chemicals on pallets, lying flat, and away from water.
→→ Keep a clear pathway between chemical storage containers.
→→ Do not block exit aisles with drums, barrels, bags etc.
→→ Keep non-flammable absorbent material available for spill clean-up, such as bags of sand.
→→ Follow proper spill cleanup procedures using absorbent material to collect the chemical
and dispose of it according to waste disposal regulations.
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 18: Gap Inc. Chemical Storage and Handling Guidelines 233
Appendix 19:
Sustainable Apparel
Coalition (SAC) Facility
Module – Environment:
Apparel and Footwear FAQ
Higg Index Question Appendix
The Higg Index is a suite of sustainability self-assessment tools for use by brands and
manufacturers within the apparel and footwear industry. Developed by the Sustainable
Apparel Coalition (SAC), the Higg Index aims to simplify and standardize the collection of
environmental and social impact data across the apparel and footwear supply chain.
The Higg Index Environmental Facility Module includes three levels of questions across
seven different impact categories. While most questions require a binary yes/no answer,
depending on the answer given, facilities must provide additional information to support
their response.
In general, the points available for each question increase as the questions go up in level. As
a result, facilities can work to improve their score by 1) having baseline practices in place that
allow them to respond positively to all Level 1 questions and 2) developing methodologies
and processes that allow them to respond positively to Level 2 and Level 3 questions as well.
Section 1: Environmental Management System (EMS) Questions
Level 1: Baseline Performance
FAC 1.1.1 Do you know what your site’s environmental impacts are?
FAC 1.1.2 Are one or more members of management specifically responsible for
coordinating your site’s environmental management activities?
FAC 1.1.3 Does your site have a program or system for monitoring environmental
regulations and permits required for operation?
FAC 1.1.4 Has your site facility been in compliance with all legal requirements/permits
during the past 12 months?

Level 2: Managing & Setting Goals
FAC 1.2.1 Do you have a formal Environmental Management System or program aimed
at continuously improving your site’s environmental impacts?
FAC 1.2.2 Does your site have an overarching environmental strategy that prioritizes
impact reduction areas and sets long-term targets (3-5 years) to achieve
significant environmental performance improvements?
Level 3: Leading Practice
FAC 1.3.1 Does your site assess and work with its production suppliers and sub-
contractors to improve their environmental performance across any relevant
impact area (e.g. energy/GHG emissions, water, waste)?
FAC 1.3.2 Are your site’s environmental management systems certified and/or audited
by an independent third-party assessor or an accredited internal assessor?
FAC 1.3.3 Does your site make information on its air emissions, greenhouse gas
emissions, water discharges, and waste generation available to the public?
FAC 1.3.4 Does your site make information on its resource consumption (energy and
water use) available to the public?
Section 2: Energy & Greenhouse Gas (GHG) Emissions Questions
FAC 2.1.1 Does your site track and measure, at least annually, energy use from all
sources, including energy generated on-site (direct) and purchased energy
(indirect)?
FAC 2.1.2 How much electricity does your site use each year?
FAC 2.1.3 How much steam does your site use each year?
FAC 2.1.4 Does your site calculate and track, at least annually, its greenhouse gas
emissions?
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Environment: Apparel and Footwear FAQ
FAC 2.2.1 Do you set and review at least annually improvement targets for reducing
energy use (including fuel use for on-site transportation if applicable)?
FAC 2.2.2 Do you set and review at least annually improvement targets for reducing
greenhouse gas (GHG) emissions?
FAC 2.2.3 Has your site had an energy audit conducted in the last three years by a
certified professional to identify potential energy and cost savings?
Level 3: Leading Practices
FAC 2.3.1 Has your site implemented any energy conservation or efficiency measures?
FAC 2.3.2 Do you have demonstrated evidence of reducing the amount of energy used
for your site?
FAC 2.3.3 Do you have demonstrated evidence of reducing the amount of greenhouse
(GHG) emitted for your site beyond the reductions directly linked from
reducing energy use?
FAC 2.3.4 Please list and describe any practices, programs, technology, or methods you
utilize at your site that you consider to be a “leading practice” for managing
and significantly reducing energy use and/or greenhouse gas emissions?
Section 3: Water Use Questions
FAC 3.1.0 Does this facility site only use Domestic Water? Note: This question is not scored.
FAC 3.1.1 Do you measure and track total water consumption for your site (including
domestic and process water)?
FAC 3.1.2 How much water do you use each year at your site?

FAC 3.2.1 Do you set, and review at least annually, formal targets for reducing water use
at your site?
FAC 3.2.2 Has your site had a water audit conducted to identify potential water and cost
savings?
FAC 3.3.1 Do you have demonstrated evidence of reducing the quantity of water used for
your site, such as by reusing rinse water or capturing condensate or cooling water?
and significantly reducing water use?
Section 4: Wastewater (Effluent) Questions
FAC 4.1.0 Please answer the following questions to help understand what the facility’s
domestic and industrial wastewater sources may be (e.g. types of facilities &
processes at facility).
FAC 4.1.1 Is all wastewater that is produced at your site being treated with primary and
secondary treatment?
FAC 4.1.2 Do you monitor the quantity and quality of wastewater produced at your site?
FAC 4.1.3 What is the daily wastewater production at your site?
FAC 4.2.1 Do you set and review at least annually formal targets for improving
wastewater quality for your site?
FAC 4.3.1 Do you have demonstrated evidence of improving the wastewater quality for
your site?
and significantly improving wastewater quality.
Section 5: Emissions to Air Questions
FAC 5.1.1 Do you maintain a current list (“inventory”) of emissions to air and their
sources at your site?
FAC 5.1.2 Are air emissions at your site regularly tested and monitored by a certified
professional or laboratory?
FAC 5.2.1 Do you set, and review at least annually, formal targets for reducing emissions
to air at your site?
FAC 5.3.1 Do you have demonstrated evidence of reducing the quantity of emissions to
air for your site beyond reductions resulting from reducing energy use?
and significantly reducing air emissions?

Section 6: Waste Management Questions
FAC 6.1.1 Do you measure and record, at least annually, waste generated from all waste
streams at your site?
FAC 6.1.2 How much solid waste is generated at your site each year?
FAC 6.1.3 How much hazardous waste is generated at your site each year?
FAC 6.1.4 How much of the waste generated is recycled instead of being disposed of
each year?
FAC 6.1.5 Does your site segregate hazardous and non-hazardous waste AND provide
training to personnel on handling and segregating waste?
FAC 6.1.6 Do you ban all on-site waste disposal (including landfill, incineration, waste to
energy)?
FAC 6.2.1 Do you set, and review at least annually, improvement targets to reduce the
quantity of waste generated for your site?
FAC 6.3.1 Do you have demonstrated evidence of reducing the quantity of waste
generated for your site?
and significantly reducing waste?
Section 7: Chemicals Management Questions
FAC 7.1.1 Has this facility assessed its chemicals management performance using the
Chemicals Management Module “Supplier” indicators?
FAC 7.1.2 Does this facility systematically monitor applicable chemical use regulations
on a regular basis to ensure compliance and to identify new or changing
compliance requirements?
FAC 7.1.3 Does this facility have a business process to ensure compliance with all
Restricted Substance Lists (RSLs) for brands it does business with?
FAC 7.1.4 Does this facility have a documented inventory of chemicals used to make
your products, and the respective supplier for each chemical?
FAC 7.2.1 Does this facility have an action plan to improve chemicals management
performance that is reviewed and updated at least annually?
FAC 7.2.2 Does this facility restrict chemicals used in manufacturing processes and/or
residing in final product that goes beyond a list of regulated chemicals and
RSLs?
FAC 7.3.1 Can this facility demonstrate evidence of chemicals management

performance improvement on an annual basis through Chemicals
Management Module assessment results and/or other documentation?
FAC 7.3.2 Does this facility collaborate with brands and chemical suppliers to prioritize
and select chemicals for alternatives assessment from substances of concern
and/or restricted substances lists?
FAC 7.3.3 Has this facility reduced the use of chemicals by the substitution of biological
enzymes in any of your processes? | What is the temperature used in the
enzyme processes and how many rinses have been reduced from this
substitution?
FAC 7.3.4 Has this facility reduced the use of any chemicals by recovering and reusing
them (for example, with caustic soda)?
More information on completing the Higg Index, including how to respond positively to questions, can be
found in the Sustainable Apparel Coalition’s How to Higg guide, published April 2014.

Appendix 20:
Energy & Greenhouse Gas

(GHG) Emissions Guidance
Energy consumption is one of the largest and most unpredictable expenses, and it leads
to some of the most significant environmental impacts associated with any business’
operations. Energy—in the form of operational fuels, purchased electricity, and steam/
cooling—is consumed and expended at every stage of a products’ lifecycle. By reducing
energy consumption and implementing leading energy practices, facilities have the
potential to reduce their fuel and electricity expenses while simultaneously decreasing their
carbon footprint.
Energy consumption directly impacts the earth’s climate. Climate change poses risks for
humans and natural systems, and contributes to business disruption. Anthropogenic
(human-caused) climate change results from the burning of carbon-based fuels such
as wood, coal, and petroleum1. This is causing the overall global temperature to steadily
increase, a phenomenon known as the greenhouse effect, accelerating weather events such
as droughts, typhoons, and hurricanes, and resulting in soil erosion, flooding, crop loss,
forest fires, sea level rise, and ocean acidification.
Figure 4: The Greenhouse Effect
Source: Climate Change (2007) The Physical Science Basis, a report accepted by
Working Group I of the Intergovernmental Panel on Climate Change
1
http://www.ipcc.ch/
Side effects of climate change like super storms and droughts have the potential to disrupt
businesses by creating suboptimal operating conditions, increasing the need for energy for
heating and cooling, or destroying valuable natural resources and raw materials needed to
supply products.
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Sixty percent of Gap Inc.’s vendors report that energy is one of their most significant
environmental impacts. Reducing energy consumption through improved efficiency,
technology, operational changes, and/or fuel switching are potential opportunities that lead
to a reduction in emissions, improvement in the stability of energy availability and price, and
achievement of bottom line savings.
Facilities must ensure that, in accordance with the Gap Inc. COVC, they are managing their
energy and GHG emissions to prescribed regulations and leading practices, including, but
not limited to:
→→ Developing a current and complete energy use (e.g., energy consumption data from
energy bills and meter readings, fuel bills, gas bills) and GHG emissions inventory
(direct and indirect)
→→ Identifying all areas within the facility where energy is being wasted
→→ Developing and implementing energy management, conservation, and efficiency
procedures for the facility, including all processes, lighting, compressed air systems,
equipment, heating, ventilation, and air conditioning systems, as well as fuel usage in
combustion equipment
→→ Monitoring and reviewing energy usage, setting goals and plans for improving energy
efficiency, and including provisions for comparing actual performance against the goals
Leading Practices to Reduce Energy Consumption & GHG

Emissions
Sample Cost Sample Savings (Energy
Practice (USD$) Reduction or USD$)
Recover heat from boiler smokestack and $22,000-$95,000 Savings range from 1-12% of energy
finishing operations such as hot water with payback period of 2-8 months,
rinse via economizer2 depending on project
Complete lighting retrofit by converting $10,000-30,000 50% reduction in lighting energy

lights to T-8 or T-5 fixtures and using consumption
compact fluorescent (CFL) or light-emitting
diode (LED) bulbs3
Install variable-frequency air compressor $19,000 4% overall electricity reduction

and optimize system4
Convert sewing machines from clutch $65,000 90% reduction in electricity;

motors to servo motors5 $22,000 annual savings
2
https://www.nrdc.org/international/cleanbydesign/files/rsifullguide.pdf
3
http://www.energystar.gov/sites/default/files/buildings/tools/EE_Guidebook_for_Textile_industry.pdf

Sample Cost Sample Savings (Energy
Maintain steam traps6 Insignificant 1-5% energy savings (72-128 kg coal
savings per ton of fabric); payback
period < 1 month
Insulate pipes, valves, and flangesii $4,500 0.01-0.5% energy savings (0.2-38 kg
coal savings per ton of fabric);
payback period < 1 month
Energy savings from leak detection, Insignificant 1.5-5% energy savings (47-340 kg
preventative maintenance, and improved coal savings per ton of fabric); 2-5%
cleaningii water savings; payback period < 1
month
Energy savings from reuse of cooling $1,500 1.6-1.8% energy savings (67-92 kg
waterii coal savings per ton of fabric);
Energy savings from reuse of condensateii Variable 0.8-3.2% energy savings (55-86 kg
coal savings per ton of fabric); 2-3%
water savings; payback period of 1
month – 1 year
4
http://www.nrdc.org/international/cleanbydesign/files/responsible-sourcing-guide.pdf
5
http://www.psesbd.org/index.php/publications/item/download/93_43af2224a3ec19c6827d826b26f512b9
6
Note: Energy savings calculated based on the use of coal as a fuel would also save energy at mills using
natural gas, wood, or other fuels to generate heat and steam.
Energy use and emissions can be further reduced by:

→→ Switching off and/or unplugging all equipment, machinery, electronics, and lighting
when not in use. Shifting to energy efficient equipment whenever possible.
→→ Installing motion sensor lights for low use areas.
→→ Increasing insulation to reduce use of heating and air conditioning. Setting air
conditioning and heating equipment to minimum/maximum levels recommended by
local governments.
→→ Educating employees on behavior changes to conserve energy, e.g. switching off lights.
→→ Installing onsite renewable energy (e.g. solar photovoltaic panels).
Facilities must ensure that its energy and GHG emissions are measured and recorded
annually for all operations. Gap Inc. encourages facilities to establish energy and emissions
reduction targets annually, and to maintain and disclose this information via the Higg Index.
Methodology for Conducting a GHG Inventory
A GHG inventory is a type of self-assessment that accounts for all sources of energy used by
a business and quantifies the volume (in metric tons) of GHGs released as carbon dioxide
equivalent (expressed as MTCO2e).
Improving energy & GHG emissions performance requires the following steps:
1. Conduct an initial inventory to obtain the organization’s baseline impact.
2. Set a reduction target to decrease the energy/emissions footprint.
3. Implement efficiency measures and leading practices to improve energy & GHG
emissions performance.
4. Measure impacts annually to compare current performance to baseline.
5. Report results via the Higg Index.
Conducting a GHG Inventory

6. Use an accounting methodology such as the WRI and WBCSD GHG Getting Started with
Protocol7 to ensure that there is a basic framework for completing the Data Collection
inventory.
Completing an environmental
7. Define the organizational and operational boundaries. This step inventory can be a daunting
is essential for determining which parts of a business to include process. The How to Higg document
and which inputs and outputs are material to the inventory. The created by the Sustainable Apparel
organizational boundary can be defined by financial control, Coalition (SAC) provides an excellent
operational control, or equity share. At a minimum, the operational checklist for the recommended
boundary should be drawn to include all assets that fall within the documents required to complete a
organizational boundary. Higg Index response. These same
8. Define the base year and data collection methodology. GHG documents can form the basis for
accounting is an iterative process, and the first inventory conducted is inventory data collection.
known as the base year. The base year is used as a point of reference
to track changes in the inventory over time as well as progress
towards reduction goals. Once the base year has been selected, determine how data
will be collected, tracked, and managed across the organization and who will be
responsible for maintaining this data and completing the inventories year after year.
9. Compile a comprehensive list of energy and emission sources that fall within the
organizational and operational boundaries. To thoroughly account for all energy
consumption and expenditures and GHG emissions, it will be necessary to engage a
team of individuals from across the organization. Including employees from as many
different departments as possible will help avoid missed energy or emissions sources
and set the stage for efficient data collection down the road.
7
World Resources Institute (WRI) and World Business Council for Sustainable Development (WBCSD). The
Greenhouse Gas Protocol: A Corporate Accounting and Reporting Standard, Revised Edition. 2007.

10. Collect data and calculate results for each energy and emission source identified.
Organizations completing an inventory for the first time will rarely have all of the data
necessary to follow the optimal calculation method and will need to use alternative
estimation methods. To increase the accuracy of the inventory year-over-year, work
to implement record-keeping changes that facilitate the use of optimal calculation
methods. Often simple changes such as tracking the volume of energy consumed along
with financial data can increase the accuracy of inventories dramatically.
11. Document findings and methodology. The inventory report should include all raw
data and sources, calculation methodology, assumptions, and boundaries. Thorough
documentation of a transparent and repeatable process will ensure inventories
conducted in subsequent years always use the same standards.
Setting Reduction Targets

A reduction target is a
Once a baseline GHG inventory has been completed, set and report on
numeric performance reduction targets. By creating and managing reduction targets, and by
objective related to using these targets as an opportunity to adopt leading practices, vendors
can save money, mitigate business risks, reduce environmental impacts,
energy or emissions
and improve their Higg Index score.
mitigation.
A reduction target is a numeric performance objective related to energy or
emissions mitigation. At a minimum, an effective target must quantify a reduction, specify
a baseline or starting point, and include a timeframe. An example of an appropriate target
would be: “By 2017, our organization will reduce GHG emissions by 15% relative to a baseline
year of 2013.”
Targets may be expressed as either absolute reductions or intensity reductions. An absolute
reduction target requires a specific reduction in a company’s overall impact in the targeted
environmental category, such as a 10% emissions reduction over a baseline year. An intensity
target reduction is normalized against a business metric, such as a reduction in emissions
per volume of product produced.
Absolute Target Example Intensity Target Example
By 2017, our organization will reduce GHG emissions by By 2017, our organization will reduce GHG
10% relative to our 2014 baseline. emissions by .025 MTCO2e per unit of product
produced for Gap Inc. relative to our 2014
baseline.
Many external and internal conditions can influence the target-setting process, and
these may change over time. External factors may include legal regulations affecting the
baseline year or mandated reduction targets. Internal factors may include natural growth,
acquisitions and divestitures, or uncontrollable factors related to energy use. When setting
targets, facilities must consider these factors relative to their overall business goals and
buyer demands.
Tracking Progress against Targets

Facilities can realize the greatest benefit, and improvement, by tracking progress towards
their goals at least on an annual basis. To do so, facilities must measure and record energy
consumption and GHG impacts, compare those measurements to their goals, maintain
records to corroborate their responses, and disclose this information using the Higg Index.
In general, at a minimum, facilities should track the following energy and emission metrics
on an annual basis:
→→ Types & sources of energy and emissions at each facility, how often energy and
emissions are measured, and the method of measurement. This may include:
• Stationary combustion sources (e.g., natural gas)
• Mobile emission sources (e.g., fuel consumption by owned or leased vehicles)
• Physical and chemical process (other than fuel combustion)
• Fugitive emission sources (e.g., refrigerant emissions)
• On-site landfills and wastewater treatment
→→ Total amount of electricity, steam, and hot/chilled water used for the last full calendar
year.
→→ Tool/Protocol used to perform energy and GHG calculations.
→→ Annual energy expenditures.
Utility bills, energy meters, and/or government reports can be used to begin tracking
consumption of electricity, diesel fuel, liquid petroleum gas, and other sources of energy and
emissions.

Appendix 21:
Waste Management
Guidance
Introduction
Waste impacts the communities in which businesses operate. It can leach toxins, take up
landfills, emit greenhouse gases that contribute to global warming, and pose a threat to
human health and the environment1. It can also be expensive to haul and dispose of waste;
waste reductions through efficiency and diversion can result in immediate cost savings.
Diverting waste through reuse, recycling, composting, and incineration conserves
energy, saves costs, and reduces the impact of business on local communities. Recycling,
composting, and incineration also have the potential to become revenue sources if products
are sold to an appropriate vendor partner2.
Per the Gap Inc. COVC, facilities must ensure that all solid and hazardous waste is
appropriately disposed of in accordance with local and national regulations. This includes,
but may not be limited to: obtaining appropriate permits, providing workers with
appropriate and properly labeled waste disposal containers, ensuring that solid waste is free
from hazardous contamination, handling and storing hazardous waste properly to ensure
the safety of workers and the environment, securing and protecting solid waste collection
areas, ensuring the safe & timely removal of solid waste from the premises by licensed
waste management contractors, disposing of waste in a responsible and controlled manner,
and documenting waste inventory and tracking records, including the final destination of all
solid waste.
Wastes may only be shipped to permitted, authorized facilities for treatment, disposal,
incineration, or other processing. Facilities must maintain detailed records on the
destination of all wastes and ensure that transporters and treatment and disposal providers
are properly documented.
Facilities must ensure that all hazardous waste handling, storage, transportation, and
disposal is appropriately managed in accordance with local and national regulations,
including: obtaining appropriate permits, providing workers with appropriate and properly
labeled waste disposal containers, handling and storing hazardous waste properly to ensure
the safety of workers and the environment, maintaining Material Safety Data Sheets (MSDS)
for chemicals, and documenting waste inventory and tracking records, including the final
destination of all hazardous waste.
1
http://www.epa.gov/osw/nonhaz/municipal/pubs/ghg/f02026.pdf
2
http://www.environmentalleader.com/2014/05/07/zero-waste-strategies-create-new-revenue-streams/
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Facilities must have in place effective spill response procedures and equipment and provide
training to employees in the event of a spill or other emergency situation.
Hazardous waste may only be shipped to permitted, authorized facilities for handling and
disposal. Facilities must maintain detailed records on the destination of all wastes and
ensure that transporters and handling and disposal providers are properly documented.
Facilities must ensure that its hazardous waste is kept separate from other solid waste, and
that it is measured and recorded annually for all operations. Gap Inc. encourages facilities to
maintain and disclose hazardous waste information via the Higg Index.
Facilities must ensure that its solid waste is measured and recorded annually for all
operations. Gap Inc. encourages facilities to establish waste reduction targets annually, and
to maintain and disclose this information via the Higg Index.
Leading Practices for Waste Reduction
Practice Sample Cost (USD$) Sample Savings (USD$)
Recycle and sell packaging materials None $3,000-$30,000 in potential revenue

such as corrugated cardboard, cartons,
tubes, spools, and thread cones to
reduce disposal costs3
Train employees and invest in basic None Up to $4,000 in purchasing costs

tools and equipment to reduce waste
fabric in the cut-and-sew process4
Recommended Waste Guidance

Waste can be reduced by:
→→ Modifying production processes to reduce or reuse waste
→→ Making a materials substitution when a less wasteful or environmentally-damaging
material is available
→→ Conserving material resources when possible without sacrificing safety or quality
→→ Diverting recyclable, compostable, burnable, and reusable materials from the solid
waste stream whenever possible
3
http://infohouse.p2ric.org/ref/01/0056604.pdf
4
http://www.epa.gov/region2/p2/textile.pdf

Methodology for Conducting a Waste Inventory
A waste inventory examines the volume of solid and/or hazardous waste generated by
a facility and the amount of that waste that was sent to landfill, incinerated, recycled or
composted, or reused.
Improving waste management performance requires the following steps:
2. Set a reduction target to decrease the waste footprint.
3. Implement efficiency measures and leading practices to improve waste performance.
Conducting a Waste Inventory

1. Use an accounting methodology such as
Getting Started with
the U.S. EPA’s WasteWise tool or Waste Data Collection
Reduction Model (WARM) to ensure that Completing an environmental
there is a basic framework for completing inventory can be a daunting
the inventory. process. The How to Higg document
2. Define the organizational and operational created by the Sustainable Apparel
boundaries. This step is essential for Coalition (SAC) provides an excellent
determining which parts of a business checklist for the recommended
to include and which inputs and outputs documents required to complete a
are material to the inventory. The Higg Index response. These same
organizational boundary can be defined documents can form the basis for
by financial control, operational control, inventory data collection.
or equity share. At a minimum, the
operational boundary should be drawn to
include all assets that fall within the organizational boundary.
3. Define the base year and data collection methodology. Waste accounting is an iterative
process, and the first inventory conducted is known as the base year. The base year
is used as a point of reference to track changes in the inventory over time as well as
progress towards reduction goals. Once the base year has been selected, determine
how data will be collected, tracked, and managed across the organization and who will
be responsible for maintaining this data and completing the inventories year after year.
4. Compile a comprehensive list of waste generation and disposal streams that fall
within the organizational and operational boundaries. To thoroughly account for all
waste generation, disposal, and expenditures, it will be necessary to engage a team of
individuals from across the organization. Including employees from as many different
departments as possible will help avoid missed waste sources and set the stage for
efficient data collection down the road.
5. Collect data and calculate results for each waste source and disposal stream identified.
Organizations completing an inventory for the first time will rarely have all of the data
necessary to follow the optimal calculation method and will need to use alternative
estimation methods. To increase the accuracy of the inventory year-over-year, work
to implement record-keeping changes that facilitate the use of optimal calculation
methods. Often simple changes such as tracking the volume of waste generated and
disposed along with financial data can increase the accuracy of inventories dramatically.
6. Document findings and methodology. The inventory report should include all raw
data and sources, calculation methodology, assumptions, and boundaries. Thorough
documentation of a transparent and repeatable process will ensure inventories
conducted in subsequent years always use the same standards.

Once a baseline waste inventory has been completed, set and report on reduction targets.
By creating and managing reduction targets, and by using these targets as an opportunity
to adopt leading practices, vendors can save money, mitigate business risks, reduce
environmental impacts, and improve their Higg Index score.
A reduction target is a numeric performance objective related to waste generation or
diversion rate improvements. At a minimum, an effective target must quantify a reduction
or improvement, specify a baseline or starting point, and include a timeframe. An example
of an appropriate target would be: “By 2017, our organization will reduce waste generation
by 15% relative to a baseline year of 2013.”
environmental category, such as a 10% waste generation reduction over a baseline year. An
intensity target reduction is normalized against a business metric, such as an increase in
recycling per unit of product produced.
By 2017, our organization will reduce waste By 2017, our organization will reduce waste
generation by 10% relative to our 2014 baseline. generation by .25 pounds per unit of product
produced for Gap Inc. relative to our 2014 baseline.
acquisitions and divestitures, or uncontrollable factors related to waste generation and
disposal. When setting targets, facilities must consider these factors relative to their overall
business goals and buyer demands.

their goals at least on an annual basis. To do so, facilities must measure and record waste
generation, disposal, and diversion, compare those measurements to their goals, maintain
records to corroborate their responses, and disclose this information using the Higg Index.
In general, facilities should track the following waste generation and disposal metrics on an
annual basis:
→→ Details of the facility’s most significant waste streams for the last full calendar year,
including:
• Volume of solid waste generated
• Volume of hazardous waste generated
• Volume of waste diverted from landfill via reuse, recycling, composting, and/or
incineration
→→ Information about waste segregation and processes for waste handling
→→ Annual waste management expenditures
Reports or bills from solid waste management providers can be used to begin tracking
the volume of a facility’s waste generation, disposal, and diversion. If disposal volume is
unknown, it can be estimated based on the number of containers, container size, percent
full, and number of waste management services per week.
Appendix 22:
Water Consumption and Waste-

Water Discharge Guidance
Water Consumption
Water is critical to the apparel industry. For example, it takes nearly 500 gallons of water
to produce a single pair of jeans.1 However, although water is in finite supply, it is under
significant stress. Global trends such as an increasing world population and climate-related
events such as drought or flooding may disrupt operations and increase the price of doing
business. Facilities with high water needs, such as laundries, are at particular risk.
Facilities without ready access to water must pay for water to be delivered to their
businesses. Depending on water scarcity in the region, water delivery can be extremely
costly and negatively affect both businesses and neighboring communities.
Reducing consumption of water by increasing operational efficiency, implementing new
technologies, and redesigning products and processes can simultaneously lower a business’
exposure to risk and its water impacts.
Leading Practices to Reduce Water Consumption
Sample Cost Sample Savings (Water

Install pipes and lines to capture and $12,000-$30,000 2-3% overall water reduction;
return condensate from steam operations
$8,000-$78,000 annual savings
to boiler steam system2
Purchase and install a cooling water reuse $1,500-$3,000 1-5% overall water reduction;
system that includes pipes, valves, a pump,
$2,000-$18,000 annual savings
holding tanks, and a control system3, 4
Routinely inspect and maintain steam <$5,000 2-5% overall water reduction and
traps, leaks, and equipment to reduce 1.5-5% energy savings
water and energy costs5
Reuse of process water from bleaching or $3,000 - $30,000 Bleaching: 4% water savings (6.47
mercerizing6 tons of water saved per ton of fabric);
Mercerizing: 3% water savings (4.54
tons of water saved per ton of fabric);
1
http://www.levistrauss.com/wp-content/uploads/2014/01/A-Product-Lifecyle-Approach-to-Sustainability.pdf
2
3
4

Recommended Guidance
Facilities must ensure that they are managing their water consumption in accordance with
prescribed regulations and leading practices, including, but not limited to:
→→ Obtaining appropriate permits for water use/extraction
→→ Recording and regularly maintaining data regarding water consumption (e.g. water
withdrawal and discharge data from water bills and meter readings)
→→ Labeling drinking water and service water
Water consumption can be further reduced by:
→→ Educating employees on behavioral changes related to water conservation such as
turning off faucets when not in use
→→ Regulating water pressure and routinely checking for leaks
→→ Installing low-flow faucets and outlets when possible, and investigating/implementing
other water reducing technologies
→→ Reuse and recycle water when possible, including rain water collection and greywater
use for landscaping
Facilities must ensure that water consumption is measured and recorded annually for all
operations. Gap Inc. encourages facilities to establish water reduction targets annually, and
to maintain and disclose this information via the Higg Index.
Wastewater Discharge (Effluent)

When not properly managed and treated, wastewater can pollute both surface and
groundwater, posing a threat to human health and the natural environment.7 In some
regions, it is costly to treat wastewater, placing a financial burden on suppliers who must
pay to treat the water offsite.
Wastewater discharge can be improved in several ways, including the quality and quantity
of the discharge, as well as how it is treated and used once it leaves a facility. By reducing
the volume of wastewater discharge, improving its cleanliness, or treating the water onsite
so that it can be reused, facilities can improve both their environmental impact and their
bottom line. Process and product redesign, operational efficiencies, and operator-owned
water treatment facilities are a few of the ways that facilities can reduce effluent impact and
expense.
In accordance with the Gap Inc. COVC, facilities must ensure that they are managing their
wastewater discharges in accordance with prescribed regulations, leading practices, and
Gap Inc.’s Effluent Guidelines, including, but not limited to:
5
6
https://www.nrdc.org/international/cleanbydesign/files/rsifullguide.pdf2 https://www.nrdc.org/internation-
al/cleanbydesign/files/rsifullguide.pdf
7
http://www.scirp.org/journal/PaperDownload.aspx?paperID=17027
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 22: Water Consumption and Waste-Water Discharge Guidance 253
→→ Obtaining appropriate permits for wastewater/effluent treatment and discharge
→→ Strictly complying with wastewater/effluent discharge limits
→→ Monitoring wastewater discharges, including sampling from the point of discharge (or
as instructed by permit requirements)
→→ Demonstrating that results of wastewater monitoring confirm that discharge meets
permit/authorization parameters
→→ Appropriately treating sanitary wastewater either onsite or via discharge to an offsite
treatment center (Publicly Owned Treatment Works, local municipality, etc.)
Additionally, facilities may wish to observe the following best practices:
→→ Enacting appropriate procedures to take immediate corrective actions in the event that
discharge limits are exceeded
→→ Keeping wastewater monitoring records on-site for review by outside personnel upon
request
→→ If applicable, maintaining a drainage system to convey wastewater to treatment and/or
discharge points
→→ If applicable, maintaining the onsite wastewater treatment plant under safe operating
conditions to avoid any risks to human health and/or the environment
→→ Regularly cleaning and maintaining drains
→→ Making drainage layouts available upon request
→→ Ensuring that wastewater personnel understand the processes, equipment and testing
required to operate the onsite treatment plant correctly
→→ Discharging rainwater to a location other than the treatment plant or adding it at a
time during the process that does not negatively interfere with the treatment process
Sample Cost Sample Savings (Wasstewater

Reverse osmosis wastewater treatment for $580,000 6% overall wastewater reduction;
process reuse8 $387,000 annual savings;
18 month payback period
→→ Identifying opportunities to reduce toxic chemical and pollutant use and discharge via
other best practices such as recycling, reuse, ingredient selection, product substitution,
and modifications to design and manufacturing processes.
Facilities must ensure that its wastewater impacts are measured and recorded annually for
all operations. Gap Inc. encourages facilities to establish wastewater reduction or quality
improvement targets annually, and to maintain and disclose this information via the Higg Index.
8
http://cdn.intechopen.com/pdfs-wm/22395.pdf

Methodology for Conducting a Water Inventory
A water inventory measures all water withdrawals (by source and river basin), discharges
(by treatment method and receiving body), consumption, and recycling/reuse by a business,
expressed in volumetric units such as megaliters (1 ML = 1 million liters = 1,000 m3). Water
quality of discharged effluents or process water may also be measured using standard effluent
parameters such as Biological Oxygen Demand (BOD), Total Suspended Solids (TSS), etc.
Improving water performance requires the following steps:
2. Set a reduction target to decrease water impacts.
3. Implement efficiency measures and leading practices to improve water performance.
Conducting a Water Inventory

6. Use an accounting methodology such as the Global Reporting Initiative’s environmental
guidelines pertaining to water, or a water footprinting methodology such as the Water
Footprint Network’s blue/green/grey methodology to ensure that there is a basic
framework for completing the inventory.
7. Define the organizational and operational boundaries. This step is essential for
determining which parts of a business to include and which inputs and outputs are
material to the inventory. The organizational boundary can be defined by financial
control, operational control, or equity share. At a minimum, the operational boundary
should be drawn to include all assets that fall within the organizational boundary.
8. Define the base year and data collection methodology. Water accounting is an iterative
process, and the first inventory conducted is known as the base year. The base year
is used as a point of reference to track changes in the inventory over time as well as
progress towards reduction goals. Once the base year has been selected, determine
how data will be collected, tracked, and managed across the organization and who will
be responsible for maintaining this data and completing the inventories year after year.
9. Compile a comprehensive list of water-related parameters that fall within the
organizational and operational boundaries. To thoroughly account for all water-related
impacts and expenditures, it will be necessary to engage a team of individuals from
across the organization. Including employees from as many different departments
as possible will help avoid missed water sources and set the stage for efficient data
collection down the road.
10. Collect data and calculate results for all water-related parameters
identified. Organizations completing an inventory for the first Getting Started with
time will rarely have all of the data necessary to follow the optimal Data Collection
calculation method and will need to use alternative estimation
Completing an environmental
methods. To increase the accuracy of the inventory year-over-year,
inventory can be a daunting
work to implement record-keeping changes that facilitate the use of
process. The How to Higg document
optimal calculation methods. Often simple changes such as tracking
created by the Sustainable Apparel
the volume of water withdrawals and discharges along with financial
Coalition (SAC) provides an excellent
data can increase the accuracy of inventories dramatically.
checklist for the recommended
11. Document findings and methodology. The inventory report documents required to complete a
should include all raw data and sources, calculation methodology, Higg Index response. These same
assumptions, and boundaries. Thorough documentation of a documents can form the basis for
transparent and repeatable process will ensure inventories conducted inventory data collection.
in subsequent years always use the same standards.

Once a baseline water inventory has been completed, set and report on reduction targets.
By creating and managing reduction targets, and by using these targets as an opportunity
to adopt leading practices, vendors can save money, mitigate business risks, reduce
environmental impacts, and improve their Higg Index score.
A reduction target is a numeric performance objective related to water quantity or
quality improvements. At a minimum, an effective target must quantify a reduction or
improvement, specify a baseline or starting point, and include a timeframe. An example of
an appropriate target would be: “By 2017, our organization will reduce water consumption by
15% relative to a baseline year of 2013.”
environmental category, such as a 10% reduction in water consumption over a baseline year.
An intensity target reduction is normalized against a business metric, such as a reduction in
wastewater generated per volume of product produced.
By 2017, our organization will reduce water By 2017, our organization will reduce water
consumption by 10% relative to our 2014 baseline. consumption by .25 liters per unit of product
produced for Gap Inc. relative to our 2014 baseline.
acquisitions, and divestitures, or uncontrollable factors related to water use. When setting
targets, facilities must consider these factors relative to their overall business goals and
buyer demands.

their goals at least on an annual basis. To do so, facilities must measure and record
water-related impacts, compare those measurements to their goals, maintain records to
corroborate their responses, and disclose this information using the Higg Index.
In general, facilities should track the following water metrics and expenditures on an annual basis:
Water Withdrawls
→→ Sources of water used at each facility, major end uses for water, how often water
withdrawals are measured, and the method for measurement.
→→ Total volume of water withdrawn by the facility (by source and river basin) during the
last full calendar year:
• Freshwater sources include surface water, groundwater (renewable or non-
renewable), municipal supply (including water purchased from non-municipal
entities), and external wastewater
• Non-freshwater sources include the ocean, brackish or saline surface water (other
than the ocean), brackish or saline groundwater, and untreated/partially treated
wastewater from municipal/other external sources
• Rainwater/Precipitation collected onsite for any use over the course of the reporting period
Water Discharges (Effluent)
→→ Types of water discharges located at each facility (e.g. canteen, dormitories, washrooms,
landscape irrigation, storm water runoff, etc.).
→→ Types of water-based operations located at each facility (e.g. dying/tanning, laundry,
wet finishing, steam/cooling waters, screen printing, degreasing, etc.).
→→ The volume of wastewater produced by the facility (and its treatment method and
receiving body) during the last full calendar year:
• Water may be discharged to subsurface waters, surface waters, sewers that lead to
rivers, oceans, lakes, wetlands, treatment facilities, and groundwater through:
• A defined discharge point (e.g., point source discharge, including sales of water
externally)
• Over land in a dispersed or undefined manner (e.g., non-point source discharge)
• Wastewater removed from the reporting organization via truck
• Discharge of collected rainwater and domestic sewage
• Specify freshwater or non-freshwater discharge by receiving body – ocean,
surface, subsurface/well, offsite water treatment
→→ Location and details of wastewater treatment. See Gap Inc. Effluent Guidelines for
more information on wastewater treatment.
• Water quality of discharged effluents or process water may be reported using
standard effluent parameters such as Biological Oxygen Demand (BOD), Total
Suspended Solids (TSS), etc.
→→ Wastewater contaminants measured, including quality of wastewater and quantity of
contaminants, and frequency of measurement.
Water Consumption
→→ Water consumed is the difference between water withdrawals and water discharges
(i.e., Consumption = Withdrawals – Discharges).
→→ Consumption removes water from a system and makes it unavailable for further
use (i.e., volume of water that does not return to the watershed from which it was
withdrawn).
→→ Water consumed includes the quantity of water:
• Evaporated for cooling purposes
• Evaporated from water storage facilities
• Lost via transmission
• Used directly in the organization’s products
• Onsite uses, including irrigation and road maintenance
Water Recycled/Reused
→→ Recycled water is the amount of used water / wastewater employed through another
cycle back in the same process or in a higher use in the process cycle before discharge
for final treatment and/or discharge to the environment.
→→ Reused water is the amount of used water / wastewater employed in another function
in a lower use in the process cycle before discharge for final treatment and/or discharge
to the environment.
• Reuse includes wastewater used for irrigation within a facility boundary, and also
harvesting of rainwater within a facility boundary.
Utility bills, water meters, and/or government reports can be used to begin tracking water
metrics, and reports from a facility’s wastewater treatment provider can be used to gather
data on effluent.
Additional guidance on best practices for water within the textile industry can be found at:

Appendix 23:
Gap Inc. Code of

Business Conduct
Our Code of Business Conduct (COBC) has been the foundation of our corporate compliance
program since 1998. Some highlights:
→→ Each employee and director of the company is responsible for complying with the Code
of Business Conduct.
→→ All of our employees around the world receive a copy of the COBC when they join the
company and agree in writing to comply with it.
→→ Each employee worldwide is required to complete the Principles of Integrity: Code
of Business Conduct Overview training course, which reinforces the company’s
commitment to the COBC.
→→ On an annual basis, senior employees must certify their compliance with the COBC.
→→ All employees are regularly reminded of the COBC and are encouraged to report any
suspected violations through the company’s Open Door process, the
Global_Integrity@gap.com mailbox or the COBC Hotline at speakup.gapinc.com.
→→ Reflecting the global reach of our company and diversity of our employees, the COBC is
published in nine languages.
Download the Code of Business Conduct

→→ English
→→ Chinese (Simplified)
→→ Chinese (Traditional)
→→ French
→→ French (Canadian)
→→ Italian
→→ Japanese
→→ Korean
→→ Spanish
CONFIDENDIAL DO NOT DISTRIBUTE Part 3 Appendix Appendix 23: Gap Inc. Code of Business Conduct 259

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Gap Inc.

15 Chapter 2: Code of Vendor Conduct

21 Chapter 3: Assessment & Remediation

33 Chapter 4: Vendor Approval Process & Status

37 Chapter 5: Management Systems

40 Chapter 6: Vendor Portal in Gap Inc.’s

CONFIDENDIAL DO NOT DISTRIBUTE Table of Contents 3

4 Gap Inc. Code of Vendor Conduct Manual

CONFIDENDIAL DO NOT DISTRIBUTE Table of Contents 5

6 Gap Inc. Code of Vendor Conduct Manual

8 Gap Inc. Code of Vendor Conduct Manual

Our expectation is that our suppliers will share our

CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 1: Introduction & Overview 11

12 Gap Inc. Code of Vendor Conduct Manual

Code of Vendor Conduct

CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 2: Code of Vendor Conduct 15

16 Gap Inc. Code of Vendor Conduct Manual

CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 2: Code of Vendor Conduct 17

18 Gap Inc. Code of Vendor Conduct Manual

Assessment & Remediation

3.2 Types of Assessments

Follow-up Assessments carried out to assess the progress made by facilities

Announced Announced Assessments are defined as assessments for which

Unannounced Unannounced Assessments are those assessments when the

Semi-Announced A Semi-Announced Assessment is defined as an assessment

Gap Inc. has recently partnered with Verité to launch a

22 Gap Inc. Code of Vendor Conduct Manual

Table 1: Assessment Team Size and Number of Days

Full 1 Up to 800 5-15 8-25 5-15 8

4 Above 3000 30-50 50-70 30-50 35

224 Gap Inc. Code of Vendor Conduct Manual

Category Color Rating Point Range Description

Top Performer Green 86-100 Maintains a high level of social

Average Performer Yellow 65-85 Social and environmental

Bottom Performer Red 0-64 Social and environmental

Efficient and expedient Corrective Action Plan (CAP)

For information on our expectations for CAP Management if

26 Gap Inc. Code of Vendor Conduct Manual

228 Gap Inc. Code of Vendor Conduct Manual

230 Gap Inc. Code of Vendor Conduct Manual

4.2 Requesting New Facility Approval

4.5 Cases Where Corrective Action is Needed

4.6 Consequences of Facility Approval

4.7 Consequences of Facility Rejection

4.8 Vendor or Facility Changes

34 Gap Inc. Code of Vendor Conduct Manual

4.9 Termination of Approved Status

A facility that has effective management systems in place

CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 5: Management Systems 37

Your facility is expected to put your planning into practice.

38 Gap Inc. Code of Vendor Conduct Manual

CONFIDENDIAL DO NOT DISTRIBUTE Part 1 Introduction Chapter 5: Management Systems 39

Vendor Portal in Gap Inc.’s

Gap Inc. is committed working with suppliers to provide

Key elements of this new vendor portal include:

40 Gap Inc. Code of Vendor Conduct Manual

CONFIDENDIAL DO NOT DISTRIBUTE

I.A Compliance with Laws

Gap Inc. Code of Vendor Conduct Manual

CONFIDENDIAL DO NOT DISTRIBUTE

I.A.04.03 Facility meets all other requirements related to required

I.A.06.03 Required internal regulations/standing orders are posted.

Part 2: Provisions & Standards Section I: Compliance with Laws