Gap Inc.

Response for Business and Human Rights Resource Centre

Re: “Public Eye Award” Nomination
December 9, 2013

Gap Inc. has a long-standing commitment to respect the human rights of workers in our supply chain.
For more than 15 years, our internal Vendor Engagement and Monitoring team (“vendor team”) has
strived to ensure that our vendors’ factories comply with Gap Inc.’s Code of Vendor Conduct (“code”).
Our code is based on internationally accepted labor standards, including the International Labour
Organization’s (ILO) core conventions and the Universal Declaration of Human Rights.

We have been deeply saddened by the tragic events that have occurred in Bangladesh. We want to
clarify that Gap Inc. did not source any products from either Rana Plaza or Tazreen Fashions. Any
allegations that suggest otherwise are false and misleading. Nonetheless, we still strongly believe that all
apparel brands and retailers who source apparel from Bangladesh have a role to play in bringing about
real and lasting change for workers in the country’s ready-made garment sector.

Our efforts to protect workers in Bangladesh predate our role in founding the Alliance for Bangladesh
Worker Safety (“Alliance”) and the formation of the Accord on Fire and Building Safety in Bangladesh,
which many European retailers have endorsed. Gap Inc. launched our Fire and Building Safety Action
Plan (“Plan”) for factories we do business with in October 2012 and met with all of our key vendors in-
country. Under the Plan, Gap Inc. retained fire safety and engineering experts to inspect all approved
factories where we source product in Bangladesh. The inspections have been completed, and the
experts are now mapping out remediation plans to help factories address areas that do not meet
industry safety standards.

We also want and expect our impact to be broader than the factories where we source in Bangladesh.
That is why Gap Inc is a founding member of the Alliance for Bangladesh Worker Safety. The Alliance is
a serious and transparent, binding commitment on the part of its members to make urgent
improvements to worker safety in Bangladesh. It lays out a resource-driven action plan with a detailed
set of measurable, time-bound targets, and makes tens of millions of dollars available to achieve them.

Specifically, the Alliance has committed to:

 Establish common standards for Fire and Building Safety
 Inspect 100% of Alliance member factories
 Train 100% of member factories, including factory owners, management and workers
 Require transparent reporting
 Empower workers through education and the availability of anonymous helpline technology
As part of the Alliance, we have also established a worker support program, setting aside ten percent of
the Worker Safety Fund (approximately $50 million) to support workers temporarily displaced by factory
safety remediation activities. For factory owners, some Alliance Members (including Gap Inc.) have
offered up to a total of $100 million in accelerated access to capital to help support fire and building
safety upgrades.

The Alliance is dedicated to implementing solutions to the complex challenges surrounding worker and
fire safety, and has made tangible progress against its ambitious goals since founding in July 2013.
Milestones already achieved include:

 Established a Board of Directors and a governance model, which includes Bangladeshi

representatives (from BGMEA and BRAC)
 Engaged in ongoing dialogue with the ILO, U.S. Government, Bangladesh Government and
international development organizations
 Adopted and shared Fire and Building Safety Standards with the ILO, Accord, BUET and publicly
 Disclosed a list of member factories and overlap with Accord factories
 Formed a Committee of Experts to advise on technical issues such as factory inspections and
remediation
 Advanced safety inspections by member companies and an equivalency process
 Opened an operating office in Dhaka with local staff and technical experts
 Begun disbursing worker compensation from the Worker Safety Fund to workers displaced by
fire safety remediation/factory closure in association with BRAC Bank

Beyond the Alliance and Plan, our vendor team has a long history of working closely with suppliers to
help ensure their labor practices comply with Gap Inc.’s code. Our code requires all factories that
produce Gap Inc. branded apparel to comply with all applicable laws, avoid excessive overtime in
accordance with ILO standards and treat all workers with fairness, dignity and respect. Workers must be
able to refuse overtime without any threat of penalty, punishment or dismissal.

Our vendor engagement efforts seek to build sustainable human rights practices in garment factories by
demonstrating the value we can create for a broad set of stakeholders by investing in workers’ well-
being and rights, vendor capacity building, and factory monitoring and remediation. Last year, we
monitored more than 96 percent of our supply chain in 32 countries, including 585 announced and 563
unannounced audits. We are in the process of implementing a case management approach to vendor
engagement that is being rolled out to factories that are strategically important or have repeated
compliance issues. When we encounter issues, we attempt to engage factory management in
remediation and capacity-building programs because we believe this approach does more good for
workers and the industry than terminating relationships and allowing problems to persist.

We believe that cross-sector collaboration and multi-stakeholder initiatives are key to lasting, systemic
change. That is why for more than a decade, we have worked with other companies, governments,
trade unions, NGOs and international institutions to advance the quality and consistency of supply chain
monitoring. We helped found the Better Work program, a highly regarded partnership between the
International Labour Organization (ILO) and International Finance Corporation (IFC) that helps
governments, workers and companies comply with the ILO’s core labor standards and national labor
laws. A Gap Inc. executive currently sits on the Better Work Advisory Board and represents U.S. brands.

We are also working with the Global Social Compliance Programme (GSCP) and other leading apparel
retailers to create an industry-aligned approach to social and labor management systems that would
help vendors comply with working standards and engage in continuous improvement programs. A Gap
Inc. executive currently sits on the GSCP Advisory Board.

For more details about Gap Inc.’s ongoing efforts to promote fair labor practices and safe working
conditions across our global supply chain, please see our Social and Environmental Responsibility Report
and website.