EMPTY STATE
COMPARISON TOOL

Gap 77/100

(NYSE:GPS) 2 of 20 (2016)

Gap Inc. (Gap) ranks second on the benchmark, demonstrating higher transparency on its approach to managing forced labor and human trafficking risks in its supply chain relative to its peers. The company has above-average disclosure across all thematic areas. Notably, Gap achieves the second-highest score on the recruitment and worker voice themes. In addition, it is one of only a few companies which discloses having programs to ensure worker empowerment, auditing recruitment agencies, and examples of remedy. Gap has leading practices with regards to assessing forced labor risks and purchasing practices, in particular with regards to addressing risks related to subcontracting. The company can improve its performance and disclosure in the areas of traceability, worker voice, and remedy.

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77 /100

2016 Ranking: 2 of 20

HOW DO THEY COMPARE?

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77

Gap was evaluated both in 2016, when it ranked second out of 20 companies, and in 2018, when it ranked third out of 43 companies. Since 2016, the company has improved by disclosing a supplier list, potential actions undertaken if suppliers do not implement corrective action plans, and supplier training on recruitment. The company also continued to build on its involvement with the ILO's Better Work program with regards to freedom of association and worker engagement.

METHODOLOGY

75

The average score for the sector was 37/100 compared to 49/100 in 2016. The number of companies assessed in 2018 increased from 20 to 43. Since 2016, the methodology has been strengthened, making it more difficult for companies to achieve the same score. The 19 companies benchmarked in both 2016 and 2018 saw their average score increase from 49/100 to 56/100, which is significant given the changes to the methodology.

2018 BENCHMARK

2016

77

Gap was evaluated both in 2016, when it ranked second out of 20 companies, and in 2018, when it ranked third out of 43 companies. Since 2016, the company has improved by disclosing a supplier list, potential actions undertaken if suppliers do not implement corrective action plans, and supplier training on recruitment. The company also continued to build on its involvement with the ILO's Better Work program with regards to freedom of association and worker engagement.

METHODOLOGY

2018

75

The average score for the sector was 37/100 compared to 49/100 in 2016. The number of companies assessed in 2018 increased from 20 to 43. Since 2016, the methodology has been strengthened, making it more difficult for companies to achieve the same score. The 19 companies benchmarked in both 2016 and 2018 saw their average score increase from 49/100 to 56/100, which is significant given the changes to the methodology.

2018BENCHMARK

THEME AND INDICATOR SCORE

The benchmark methodology has seven themes, selected to capture the key areas where companies need to take action to eradicate forced labor from their supply chains. There are a total of 22 indicators across the seven themes. For each theme, a company can score a total of 100 points.

Commitment and Governance

The company's top-level commitments on forced labor, supply chain standards, management processes, training programs and stakeholder engagement

OVERALL 92
INDICATORS
Awareness and Commitment
100
Supply Chain Standards
60
Management and Accountability
100
Training
100
Stakeholder Engagement
100

Traceability and Risk Assessment

The extent to which the company traces its supply chain and conducts forced labor risk assessments, and discloses information about these processes.

OVERALL 75
Traceability
50
Risk Assessment
100

Purchasing Practices

The company's awareness and action on purchasing practices that can exacerbate forced labor risks, and its process for selecting suppliers, integrating standards into contracts and cascading them down the supply chain.

OVERALL 75
Purchasing Practices
100
Supplier Selection
100
Integration into Supplier Contracts
0
Cascading Standards through the Supply Chain
100

Recruitment

The company's approach to reducing exploitation by recruitment agencies and eliminating workers' payment of fees for their jobs.

OVERALL 67
Recruitment Approach
50
Recruitment Fees
100
Recruitment Audits
50

Worker Voice

The extent to which the company proactively communicates with workers through the supply chain, enables freedom of association and ensures access to effective and trusted grievance mechanisms.

OVERALL 75
INDICATORS
Communication of Policies
100
Worker Voice
50
Worker Empowerment
50
Grievance Mechanism
100

Monitoring

The company's process for auditing (including whether it includes non-scheduled visits, document review, worker interviews) and disclosure about the audit process and findings.

OVERALL 90
Auditing Process
100
Audit Disclosure
80

Remedy

The extent to which the company has corrective action plans for non-compliant factories, as well as processes for remedying workers who are victims of forced labor, and reports on remedies provided.

OVERALL 63
Corrective Action Plans
75
Remedy Programs
50

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