57 2021 ESG REPORT THE BIG PICTURE EMPOWERING WOMEN ENABLING OPPORTUNITY ENRICHING COMMUNITIES GOVERNANCE GRI Indicator Description Disclosure Source Section(s) Page(s) 203-2 Significant indirect economic impacts, including the extent of ESG Report Empowering Women: Gap Inc. P.A.C.E. 16 impacts Enabling Opportunity: This Way ONward 27 Procurement Practices 103-1 Management and approach Sustainability Materiality 103-2 Webpages Purchasing Practices 103-3 Anti-Corruption 103-1 Management and approach Sustainability Responsible Business Practices 103-2 Webpages 103-3 ESG Report Governance: Responsible Business Practices 49 To evaluate the effectiveness of Gap Inc.’s anti-corruption program, questions related to anti-corruption/anti-bribery are featured in Gap Inc.’s Code of Business Conduct (COBC) Assessments. COBC Assessments are conducted each year, with different markets/ functions identified to assess. The objective of the COBC Assessments is to gain an understanding of the impact of the COBC program. 205-1 Operations assessed for risks related to corruption We conduct Anti-Corruption Due Diligence (ACDD) in high-risk markets. Within these markets, our policy requires that any third party that interacts with government officials on behalf of Gap Inc., and/or third-party distributors, have an ACDD report. 205-2 Communication and training about anti-corruption policies Sustainability Responsible Business Practices and procedures Webpages ESG Report Governance: Responsible Business Practices 49 Gap Inc. has two internal-facing anti-corruption policies: 1) a global policy, and 2) a China Retail policy (high-risk market). Gap Inc. also has an anti-corruption training program, delivered to global directors and above, managers and above in high-risk functions, and all levels of HQ in high-risk markets (China, Mexico, and Italy). There is a separate course for the China employees, with content specific to the risks in China. This course is delivered at hire or promotion into role, and is required annually in high-risk markets and every two years globally. At times, Gap Inc. also delivers ad hoc anti-corruption training when there is opportunity (e.g. when we are traveling in market). Anti-corruption training is available to 100 percent of employees at Gap Inc.