49 2021 ESG REPORT THE BIG PICTURE EMPOWERING WOMEN ENABLING OPPORTUNITY ENRICHING COMMUNITIES GOVERNANCE We have investigative teams that log, We support, and base our policies on, RESPONSIBLE process, and address complaints received, the principles outlined in the UDHR, and the Global Integrity and Internal UNGC, OECD Guidelines for Multinational BUSINESS Audit teams conduct broad investigations Enterprises, and the ILO’s Core Conventions. where required. The COVC also sets out our basic PRACTICES expectations for environmental standards ANTI-CORRUPTION AND to all Tier 1 vendors and suppliers with ANTI-BRIBERY whom Gap Inc. conducts business. We At Gap Inc., integrity is woven into every aspect of our expect all facilities to comply with relevant business. We hold ourselves to the highest standards of ethics, We are committed to maintaining a environmental laws and regulations, transparency, and compliance through a strong set of policies. compliance program that diligently manage their energy use and water addresses corruption risks throughout impacts, and complete the Higg Index our global operations. Facility Environmental Module annually. CODE OF BUSINESS ENABLING EMPLOYEES Our companywide system monitors and CONDUCT (COBC) TO SPEAK UP addresses anti-corruption risks and DATA PRIVACY enforces our internal Anti-Corruption We create a culture of integrity and trust We encourage our employees to report and Anti-Bribery Policies. We deliver As a global brand built on the foundation by Doing the Right Thing: doing business any suspected violations through our anti-corruption training (available to all of customer trust, we respect the privacy responsibly, ethically, and honestly. Our Open Door process. Employees can raise employees) to specific levels and high-risk rights of our customers. We follow global COBC, which is published in 10 concerns with their manager, next-level markets to help employees recognize and seven principles in our approach to data languages, sets out the policies, values, and manager, local human resources, our avoid corrupt practices. Our Legal team use, new technologies, and services: principles we expect all Gap Inc. employees Global Integrity team, or our confidential carries out a risk assessment exercise consent, control, fairness, minimization, to uphold and comply with. The Global COBC Hotline. The hotline is a telephone with corruption as a critical component. confidentiality, access, and accountability. Integrity team oversees our COBC program. and web-based reporting system available 24/7 to employees and anyone Learn more on our Policies website. Our Privacy Policy adheres to laws across who conducts business with Gap Inc. the jurisdictions where we do business. EMPLOYEE TRAINING or is affected by our business. While these rights may vary, we make CODE OF VENDOR CONDUCT (COVC) reasonable efforts to honor requests even if We provide all new employees with access a country or jurisdiction does not require us to the COBC when they join, and require To ensure that our partners act in line with to do so. Our privacy policies have received the completion of a COBC Overview our standards, we require that all facilities accolades for their clarity and simplicity. e-learning module within 30 days of hire. that produce goods for Gap Inc. meet our Additional training based on location, COVC requirements and Human Rights We also know that security is at the center level, and role is required. It includes Policy, which defines our approach and of any good privacy program. We use specific issues such as sexual harassment, activities to protect against human widely accepted security standards and non-discrimination and harassment, rights abuses. practices to guide our decisions around wage and hour compliance, workplace securing personal information. accommodations, anti-corruption, and data privacy and security. Our Global Learn more on our Privacy Policy website. Integrity team also conducts ad hoc periodic training sessions throughout the year.