Acting with Integrity

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 / Anti-Bribery 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.

Data Privacy

We believe that trust is a cornerstone of a great brand and respecting the privacy rights of our customers and employees is an integral part of building that trust. Our comprehensive privacy program includes policies, standards and practices focused on keeping the data we collect secure and respecting privacy rights around the globe.   

As a global company, our Privacy Policy adheres to laws across the jurisdictions where we do business. While these rights may vary, we make reasonable efforts to honor requests even if a country or jurisdiction does not require us to do so. Our privacy policies have received accolades for their clarity and simplicity, and we continue to put privacy at the center of our customer experience.    

Maintaining brand trust is paramount as we continue to embrace technology. Our goal is to provide the highest quality experience to our customers while respecting their privacy. We have adopted seven principles that guide our choices as we adopt new products and services.  These principles include consent, control, fairness, minimization, confidentiality, access and accountability. We also know that security is at the center of any good privacy program. We use widely-accepted security standards and practices to guide our decisions around securing personal information.