Acting with Integrity
Acting with Integrity Living our values every day
How we do business is just as important as what we do. Our Global Code of Business Conduct (COBC) serves as our ethical compass for the commitment to high standards that we make to our stakeholders, customers and one another.
When issues arise, our employees are encouraged to use our open-door process for discussing any concerns with their supervisor, next-level manager or human resources representative. Employees may also contact our Global Integrity team, which oversees our COBC program. We also provide a confidential COBC hotline, email box and web portal for use 24 hours a day, seven days a week, to employees and anyone who conducts business with Gap Inc. or is affected by our business . We have investigative teams that log, process and address complaints received through any channel, including our COBC hotlines.
Our Code of Business Conduct serves as our ethical compass for the commitment we make to our stakeholders, customers and one another
to do what’s right.
How we do business is just as important as what we do.
Key aspects of how we implement our COBC:
- Within 30 days of their initial hire date, all employees globally are required to take a COBC overview course.
- In addition, we provide ongoing compliance training to various targeted employee audiences on topics of nondiscrimination and harassment, wage and hour compliance, workplace accommodations, anti-corruption, competition law compliance and data privacy and security. Our Global Integrity team also conducts general in-person training sessions through the year.
- We provide a variety of online self-help tools for compliance education and communication, including leader tools (which guide leaders on how to have effective conversations with their teams), FAQs, policy links and contacts.
- Each year, for various business units or offices, our Global Integrity team conducts interviews with employees and selected suppliers. These interviews allow us to gauge how well our employees understand our COBC, remind our employees and suppliers of their responsibilities and our expectations as to how we engage with each other, and ensure that employees know how to report COBC violations.
- Senior-level employees must certify their COBC compliance annually and are briefed on relevant compliance or integrity topics to raise awareness.
We are diligent about addressing corruption risks, particularly in developing countries with limited rule of law. We have a company-wide program for monitoring, enforcing and addressing any issues related to our Anti-Corruption Policy, which combines elements from our COBC with anti-bribery requirements under the U.S. Foreign Corrupt Practices Act (FCPA) and other similar laws around the world. The policy and related training programs help employees recognize and avoid corrupt business practices in all aspects of Gap Inc.’s business.