{"id":42147,"date":"2015-09-17T11:25:58","date_gmt":"2015-09-17T16:25:58","guid":{"rendered":"https:\/\/content.findlaw-admin.com\/ability-legal\/contracts\/uncategorized\/code-of-business-conduct-gap.html"},"modified":"2015-09-17T11:25:58","modified_gmt":"2015-09-17T16:25:58","slug":"code-of-business-conduct-gap","status":"publish","type":"corporate_contracts","link":"https:\/\/corporate.findlaw.com\/contracts\/operations\/code-of-business-conduct-gap.html","title":{"rendered":"Code of Business Conduct – Gap"},"content":{"rendered":"

How we do business is as important as what we do. <\/strong><\/p>\n

Do: what153s right <\/strong><\/p>\n<\/p>\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Our Code of Business Conduct<\/p>\n<\/td>\n

<\/td>\nGap Inc.<\/strong><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n
\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n3<\/strong><\/td>\n<\/td>\nDoing what153s right at Gap Inc.<\/strong><\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

What our Code is<\/p>\n

Why it153s important<\/p>\n

Your commitment to doing what153s right<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Contents<\/p>\n<\/td>\n

<\/td>\n4<\/strong><\/td>\n<\/td>\nSpeak up! Sharing your concerns<\/strong><\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

How to share your concerns<\/p>\n

Code Hotline<\/p>\n

You are empowered: Anti-Retaliation Policy<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n5<\/strong><\/td>\n<\/td>\nWorking with integrity<\/strong><\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Zero Means Zero Policy<\/p>\n

A safe and healthy environment<\/p>\n

Recording your time<\/p>\n

Other work standards<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n8<\/strong><\/td>\n<\/td>\nPutting ethics into practice<\/strong><\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Product integrity<\/p>\n

International trade regulations<\/p>\n

Anti-Boycott Policy<\/p>\n

Bribes and improper payments<\/p>\n

Competition laws (Anti-trust)<\/p>\n

Fair and honest business dealings<\/p>\n

Intellectual property rights<\/p>\n

Government agency complaints<\/p>\n

Government requests for information<\/p>\n

Protecting our environment<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n14<\/strong><\/td>\n<\/td>\nAvoiding conflicts of interest<\/strong><\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Giving or accepting gifts and entertainment<\/p>\n

Doing business with spouses, partners, relatives or friends<\/p>\n

Handling personal relationships at work<\/p>\n

Working outside of Gap Inc.<\/p>\n

Serving as a director or officer of another organization<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n19<\/strong><\/td>\n<\/td>\nProtecting our brand<\/strong><\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Confidential and personal information<\/p>\n

Material information and insider trading<\/p>\n

Media inquiries<\/p>\n

Financial integrity<\/p>\n

Cooperating with Audits<\/p>\n

Company property<\/p>\n

Trademarks and counterfeit merchandise<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n24<\/strong><\/td>\n<\/td>\nUnderstanding political guidelines<\/strong><\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Political activities<\/p>\n

Political contributions<\/p>\n

Lobbying<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n25<\/strong><\/td>\n<\/td>\nResources for doing what153s right<\/strong><\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Contact information<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n

Gap Inc. was founded in 1969 on the principle of doing business responsibly,
\nhonestly and ethically. Today, we remain just as committed to working with the
\nhighest standards of integrity. Nothing less will do.<\/p>\n<\/p>\n

\n

Our Code of Business Conduct166<\/p>\n

is a commitment we make to our shareholders, customers and each other not
\nonly out of a legal obligation, but because it153s the right thing to do. Our
\nsuccess is built on trust, along with a reputation for transparency and quality
\nin everything we do.<\/p>\n

We each make important contributions to protecting our company and its
\nreputation. Recognizing right from wrong, and understanding the ethical
\nimplications of our choices, is fundamental to doing what153s right at Gap Inc. We
\nare each responsible for applying the standards outlined in our Code of Business
\nConduct to our work, every day.<\/p>\n<\/p>\n

2 <\/strong><\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Doing what153s right at Gap Inc.<\/strong><\/p>\n

How we do business is as important as what we do.<\/strong><\/p>\n

Our Code of Business Conduct (Code) is your guide to working with integrity,
\nhelping you do what153s right in every situation, every day, no matter where you
\nwork.<\/p>\n

Our company has been built on integrity, quality and trust:with each other,
\nour customers and business partners. Our reputation starts and ends with each of
\nus.<\/p>\n

We153re each responsible for understanding and following our Code and other Gap
\nInc. policies, as well as the laws in each country where we do business. And
\nit153s just as important that we speak up if we see or suspect Code violations.\n<\/p>\n

Managers have an even more important role.<\/strong><\/p>\n

Lead and act with integrity;<\/p>\n

Understand the Code and periodically review it with your teams;<\/p>\n

Encourage employees to raise questions and concerns;<\/p>\n

Ensure your team completes all required compliance training;<\/p>\n

Openly support the Anti-Retaliation Policy;<\/p>\n

Take prompt and effective action where appropriate; and<\/p>\n

Seek help from Global Integrity and Compliance when needed.<\/p>\n

When in doubt, ask!<\/strong><\/p>\n

The Code can153t provide specific advice for every situation. But, most
\nproblems can be easily avoided by referring to the Code, using good judgment and
\nasking for help when in doubt.<\/p>\n

Ask yourself<\/strong><\/p>\n

If you153re not sure if something raises an ethical concern, ask yourself:<\/p>\n

Is this the right thing to do?<\/p>\n

Is this legal and am I authorized to do this?<\/p>\n

Is it consistent with our Code and other policies?<\/p>\n

Is this in line with Gap Inc.153s reputation or my personal reputation?\n<\/p>\n

Would I want to see this reported in the media?<\/p>\n

If the answer to any of these questions is NO, you should discuss the
\nsituation with your supervisor, the Human Resources department or the Global
\nIntegrity and Compliance department immediately.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

3 <\/strong><\/p>\n<\/p>\n

\n\n\n\n\n\n\n\n\n
<\/td>\n<\/tr>\n
\n

Speak up!<\/strong><\/p>\n

Share any concerns<\/strong><\/p>\n

We are each responsible for living up to our Code and acting with integrity.
\nWe have an equal responsibility to speak up and voice any questions and
\nconcerns.<\/p>\n

If you believe anyone is not living up to our Code or policies, have a
\nquestion or concern, or are unsure how to handle a situation, here153s what to do:\n<\/p>\n

Use our Open Door process and talk with your supervisor, manager, or
\n Human Resources representative.<\/p>\n

If you aren153t comfortable using the Open Door process, contact the
\n Global Integrity and Compliance Department at Global_Integrity@gap.com or
\ncall the Code Hotline.<\/p>\n

Check out the Resources section in the back of this booklet for more
\n information about who to contact with specific questions.<\/p>\n<\/td>\n<\/tr>\n

\n

Code Hotline<\/strong><\/p>\n<\/td>\n<\/tr>\n

\n

The Hotline is free, confidential and available 24 hours a day, seven days a
\nweek, to Gap Inc. employees around the world. Interpreters are available and
\ncalls may be made anonymously.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/tr>\n
\n

U.S., Canada and Puerto Rico: Dial toll-free 1-866-GAP-CODE (1-866-427-2633).\n<\/p>\n

Outside of North America: Dial your country153s AT&T Direct Access Code,
\nthen 866-GAP-CODE (866-427-2633) (Find your country153s AT&T Direct Access
\nCode at www.usa.att.com\/traveler).<\/p>\n

If you are unable to place a call, contact the Global Integrity and
\nCompliance Department at Global_Integrity@gap.com.<\/p>\n

Anyone who reports a concern is protected from retaliation by strict
\nenforcement of our Anti-Retaliation Policy.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n
<\/td>\n<\/tr>\n
\n

Question:<\/strong> What happens when a call is placed to the Code
\nHotline?<\/p>\n

Answer:<\/strong> The Hotline is answered by a confidential, outside
\nservice. A live operator will ask you a series of questions to gather
\ninformation about your concerns. The information you provide will be forwarded
\nto the appropriate department (e.g., Global Employee Relations, Global Integrity
\nand Compliance or Loss Prevention) for review and action. Any information you
\nprovide is kept strictly confidential and only shared with people who must know
\nand can take action.<\/p>\n<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/tr>\n
<\/td>\n<\/tr>\n
\n

Question:<\/strong> May I call the Hotline if I don153t speak English?\n<\/p>\n

Answer: <\/strong>Yes, the Hotline can be accessed from anywhere in
\nthe world and interpreter services are available.<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

<\/p>\n

4 <\/strong><\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Working with integrity<\/strong><\/p>\n

At Gap Inc., we want to do more than just follow the law. Working with
\nintegrity and treating each other with respect is the foundation of an
\nenvironment that inspires creativity and delivers results.<\/p>\n

Zero Means Zero: no discrimination, harassment or
\nretaliation<\/strong><\/p>\n

We have zero tolerance for discrimination, harassment or retaliation. All
\nemployment decisions are to be made without regard to race, color, age, gender,
\ngender identity, sexual orientation, religion, marital status, pregnancy,
\nnational origin\/ancestry, citizenship, physical\/mental disability, military
\nstatus or any other basis prohibited by law. This policy applies to our
\ndirectors, employees, applicants, customers and business partners (including
\nindependent contractors, vendors and suppliers).<\/p>\n

Harassment is not tolerated, and can include slurs as well as any other
\noffensive remarks, jokes and other verbal, non-verbal, graphic, electronic or
\nphysical conduct that could create an intimidating, hostile or offensive work
\nenvironment.<\/p>\n

In addition to the above, “sexual harassment” can include:<\/p>\n

Unwanted sexual advances or propositions;<\/p>\n

Offering employment benefits in exchange for sexual favors;<\/p>\n

Making or threatening reprisals after a negative response to sexual
\nadvances;<\/p>\n

Visual conduct: Leering, making sexual gestures, displaying of
\nsexually suggestive objects or pictures, cartoons or posters, electronic
\ndisplay or dissemination of such material;<\/p>\n

Verbal conduct: Making or using derogatory comments, epithets, slurs
\nand jokes;<\/p>\n

Verbal abuse of a sexual nature, graphic verbal commentaries about a
\nperson153s body, sexually degrading words used to describe a person, suggestive
\nor obscene letters, notes or invitations; and<\/p>\n

Physical conduct: Touching, assault, impeding or blocking movements.\n<\/p>\n

How to Report a Concern:<\/strong> We can153t help resolve a
\ndiscrimination, harassment or retaliation problem unless we know about it. It153s
\neveryone153s responsibility to share their concerns so the appropriate steps can
\nbe taken to resolve the issue. If you feel you have been subject to
\ndiscrimination, harassment or retaliation, or you153ve seen it in the workplace,
\nplease report it promptly to your manager, Human Resources or the Code Hotline.
\nEvery complaint will be promptly and thoroughly investigated, and no action can
\nbe taken against you for raising a concern or cooperating in an investigation.\n<\/p>\n

You are expected to fully cooperate with investigations related to Zero Means
\nZero Policy violations. No action can be taken against you for raising a Zero
\nMeans Zero concern or cooperating in any such investigation. Failure to
\ncooperate may result in discipline,<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

5 <\/strong><\/p>\n<\/p>\n

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<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> One of my co-workers frequently makes off-color
\njokes during meetings that make me uncomfortable.<\/p>\n

What should I do?<\/p>\n

Answer: <\/strong>Offensive behavior, including inappropriate jokes,
\nis not tolerated. If you are not comfortable raising the issue directly with
\nyour co-worker, or this doesn153t work, you should speak to your manager or your
\nHuman Resources representative.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
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<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Question:<\/strong> I feel that I153m<\/p>\n

being discriminated<\/p>\n

against by my manager,<\/p>\n

what do I do?<\/p>\n

Answer: <\/strong>All Gap Inc. employees should have a work
\nenvironment that153s free from discrimination, harassment or retaliation from
\nanyone. If you feel you153re being discriminated against by your manager, you
\nshould use our Open Door process and speak with your next level manager or Human
\nResources representative. You can also call our Code Hotline.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
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<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> I have a concern about something my manager is
\ndoing that I believe is a violation of our Code. What do I do? I153m afraid
\nreporting my concern will affect my performance evaluation.<\/p>\n

Answer:<\/strong> With our Open Door process, your manager would
\ntypically be the first place to raise your concern. However, since your concern
\nis with your manager153s behavior, you should contact your next level manager,
\nyour Human Resources representative or call the Code Hotline. Please know that
\nretaliation for raising Code concerns is not tolerated.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n
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6<\/strong> Working with integrity<\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

including termination. If any employee is found to have violated the Zero
\nMeans Zero Policy, we will take appropriate corrective action, which may include
\ntermination. We will also let the individual who raised the complaint know that
\naction has been taken.<\/p>\n

A safe and healthy environment<\/strong><\/p>\n

We153re committed to providing a safe and healthy working environment for
\nemployees, customers, contractors and vendors.<\/p>\n

Zero tolerance for workplace violence:<\/strong> We will not tolerate
\nany act or threat of physical violence (including intimidation, harassment
\nand\/or coercion), or threat of violence, that affects our employees, property or
\ncompany. This includes severe, offensive or intimidating conduct that creates a
\nhostile, abusive, or intimidating work environment for anyone.<\/p>\n

Drugs and Alcohol Policy:<\/strong> You may not use, sell, possess,
\npurchase or transfer illegal drugs : or sell, transfer or distribute personal
\nprescription drugs : on Gap Inc. premises, in company vehicles or during work
\nhours. You also may not be under the influence of illegal drugs during work
\nhours, regardless of when they were consumed. You are not permitted to drink, or
\nbe under the influence of, alcohol during work hours or on Gap Inc. premises
\nwith one exception: If you153re of legal drinking age, you may drink alcohol at
\ncompany-sponsored functions that are approved by a Senior Vice President or
\nabove.<\/p>\n

Health & safety laws and policies:<\/strong> To make sure our
\nworking environments are safe and healthy, it153s important that all of us
\nunderstand and follow the laws and policies that relate to our jobs. We also
\nneed to make sure our vendors follow applicable health and safety regulations.
\nMerchandise vendors should also follow the guidelines outlined in Gap Inc.153s
\nCode of Vendor Conduct.<\/p>\n

Recording your time<\/strong><\/p>\n

If you are a non-exempt (hourly) employee, you must accurately record your
\ntime worked as required by law or policy in your country : whether scheduled or
\nunscheduled, overtime or straight time, authorized or unauthorized. You should
\nlet your supervisor or manager know if you are having any problems recording
\nyour time.<\/p>\n

Recording time accurately<\/strong><\/p>\n

When recording your time, remember that non-exempt (hourly) employees should
\nnever:<\/p>\n

Work without pay, including not recording hours for work done at home\n<\/p>\n

Move hours from one day to another on a time record to avoid overtime\n<\/p>\n

Record time for a co-worker or ask a co-worker to record time for you\n<\/p>\n

Inaccurately record time worked<\/p>\n

Remove correctly recorded hours from a time record<\/p>\n

Other work standards<\/strong><\/p>\n

Gap Inc. employees are required to follow all applicable laws and regulations
\nregarding meal periods, rest breaks and employment of minors. If you see or
\nsuspect any violation of these standards, please talk with your manager or your
\nHuman Resources representative.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Working with integrity 7<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Putting ethics<\/strong><\/p>\n

into practice<\/strong><\/p>\n

Our Code reflects our commitment to deliver results with integrity and work
\nto the highest ethical standards. Putting our Code into practice means taking
\nresponsibility for our actions, thinking co-workers and customers first, and
\ncreating with quality, every time.<\/p>\n

Product integrity<\/strong><\/p>\n

We take pride in providing the highest quality products possible. In addition
\nto meeting our own internal quality standards, our products must be produced,
\ntested, packaged and labeled in full compliance with applicable laws and Gap
\nInc. policies.<\/p>\n

Local laws<\/strong><\/p>\n

If a local law conflicts with our Code, you should follow the law. If a local
\nbusiness practice conflicts with our Code, you should follow the Code. If you
\nhave a question about what153s the right thing to do, contact Global Integrity and
\nCompliance at Global_Integrity@gap.com or call the Code Hotline.<\/p>\n

International trade regulations<\/strong><\/p>\n

If you153re involved with importing or exporting goods among various countries,
\nyou153re required to understand and follow relevant legal requirements. If you
\nhave questions about import\/export requirements or other international trade
\nissues, please contact the Legal department to avoid potentially breaking the
\nlaw (see Resources section for contact information).<\/p>\n

Doing what153s right, wherever we work: applicable laws<\/strong><\/p>\n

We realize there are differences in local laws and practices in different
\ncountries. Sometimes our Code may go above and beyond what153s required by law.
\nBecause we153re committed to meeting the highest standards of business conduct
\nwherever we do business, we all must follow all aspects of the Code, even if
\nit153s not required by local laws. In other cases, there may be country-specific
\nlaws that aren153t addressed by our Code, but are included in other Gap Inc.
\npolicy manuals. Make sure you know and follow all laws and policies that relate
\nto your job.<\/p>\n

There153s never a question that we follow the laws of the countries where we do
\nbusiness. Not following the law may result in corrective action (including
\ntermination), recovery of damages and criminal charges.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

8 <\/strong><\/p>\n<\/p>\n

\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Anti-Boycott Policy<\/strong><\/p>\n

By law, Gap Inc. employees and agents may not support or cooperate with an
\nunsanctioned boycott of another country that is “friendly” to the United States.
\nThe company must report any information about, or request to support, a boycott
\nto the U.S. government. You could receive this type of request in a bid
\ninvitation, purchase contract, letter of credit or verbally. If you learn of a
\nboycott of another country that is “friendly” to the United States, contact the
\nLegal department (see Resources section for contact information).<\/p>\n

Bribes and improper payments<\/strong><\/p>\n

Giving bribes, kickbacks or other improper cash payments (or anything else of
\nvalue) to government officials, civil servants or anyone else to influence them
\nis prohibited and illegal under the U.S. Foreign Corrupt Practices Act (FCPA).
\nThis includes direct or indirect offers or promises of payment. Even if bribery
\nseems to be an accepted local practice in a country, Gap Inc. employees are not
\nallowed to engage in this practice. All employees must follow the company153s
\nAnti-Corruption Policy (see Resources section for the policy) and the FCPA, as
\nwell as local anti-bribery laws. The FCPA permits certain types of payments or
\nfees only under very specific circumstances; however, you must consult with the
\nGlobal Integrity and Compliance department at Global_Integrity@gap.com prior to
\nmaking or authorizing any payment of this type.<\/p>\n

Make sure to ask yourself<\/strong><\/p>\n

Are any of these red flags present?:<\/strong><\/p>\n

Doing business in a country that has a reputation for corruption<\/p>\n

Unreasonably high fees are being requested<\/p>\n

Unusual payment methods, such as requests for payments in cash<\/p>\n

Lack of transparency in expense or accounting records<\/p>\n

Deliverables that sound too good to be true<\/p>\n

Competition laws (Anti-trust laws)<\/strong><\/p>\n

Many of the countries where we do business have competition laws, or
\n“anti-trust” laws. These laws reinforce our own ethical standards : it isn153t
\nbusiness at any cost, and everyone needs to be able to compete fairly in a free
\nmarket. These laws generally prohibit business practices that interfere with
\ncompetition, including price fixing, allocation of markets, or allocation of
\nvendors.<\/p>\n

Gap Inc. employees and directors are required to comply with our Competition
\nLaw Policy.<\/p>\n

Any employee who violates this policy may be subject to disciplinary action,
\nincluding termination, significant monetary damages or fines, and even
\nimprisonment. Additionally, Gap Inc. can be prosecuted and fined millions of
\ndollars, may have to pay damages and attorneys153 fees, and could lose shareholder
\nconfidence and public trust as a result of competition law violations (see
\nResources section to find the policy on GapWeb).<\/p>\n

If you have any concern about a violation of competition laws by the company,
\nan employee or competitor, you should contact the Legal department as soon as
\npossible (see Resources section for contact information and to find the policy
\non GapWeb).<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n\n

Question: <\/strong>The customs agent has found that our shipment
\npaperwork is missing required information. May I give him a cash payment to
\nensure that our shipment departs on time?<\/p>\n

Answer: <\/strong>No. You may not make a direct or indirect payment to
\na government worker to avoid a requirement.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> I153ve arrived at the airport in a foreign country
\nand have been denied entry because my passport has been found deficient. May I
\nmake a small payment, equivalent to US$5.00, to the immigration officer in order
\nto be allowed into the country?<\/p>\n

Answer:<\/strong> No. You may not make a payment of cash, no matter
\nhow small, or provide anything else of value, to a government worker in order to
\nget around your deficient passport status. Before traveling overseas, make sure
\nall documentation is complete.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Putting ethics into practice 9<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Make sure to:<\/strong><\/p>\n

Review Gap Inc.153s Competition Law Policy for more details on these laws
\nand examples of prohibited activities.<\/p>\n

Consult with Gap Inc.153s Legal department before beginning any
\ndiscussions or attending any meetings with competitors.<\/p>\n

Use caution in all activities and discussions at trade associations,
\ntrade shows and similar joint endeavors that involve competitors.<\/p>\n

Contact Gap Inc.153s Legal department to report any activity by employees
\nor competitors that you believe may be inappropriate.<\/p>\n<\/td>\n

<\/td>\n\n

And do not:<\/strong><\/p>\n

Talk to a competitor about prices, marketing practices, other
\ncompetitors, vendors, market allocation, or geographic regions.<\/p>\n

Try to influence the prices at which franchisees or other third-parties
\nresell our products.<\/p>\n

Make any statements or written records, even in jest, that suggest that
\na proposed course of action will eliminate competition (e.g., “our plan will
\ncrush the competition” or “this acquisition would eliminate a competitor”).<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> Several people in my department need to use a
\nsoftware program, but we have only one copy. Is it okay to copy the program onto
\neach of our computers?<\/p>\n

Answer:<\/strong> No. Unless the<\/p>\n

license agreement for the software program specifies otherwise, a separate
\ncopy of the program must be purchased for each computer.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Fair and honest in our business dealings<\/strong><\/p>\n

Doing what153s right and acting with integrity has always been a fundamental
\npart of our culture. Our employees, customers, and business partners know they
\ncan trust Gap Inc. to be fair and honest. This trust is critical. You should
\nalways deal fairly with our customers, suppliers, vendors, competitors and
\nfellow employees. You should not take unfair advantage of anyone through
\nmanipulation, concealment, abuse of confidential information, falsification,
\nmisrepresentation of material facts or any other intentional unfair dealing
\npractice.<\/p>\n

Intellectual property rights<\/strong><\/p>\n

As we expect others to recognize the legal rights we have in our brands and
\ndesigns, we respect the legal rights of others. You should never make
\nunauthorized copies of material from books, magazines, newspapers, films,
\nvideotapes, music recordings, websites, products or computer programs. If you
\nhave questions about what materials you can or cannot use, email the Legal
\ndepartment at legal_clearance@gap.com.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n\n

Question: <\/strong>I found an image on a website that I153d like to use
\nin a design I153m creating. Is this okay?<\/p>\n

Answer:<\/strong> No. Images and other materials available on the
\nInternet are entitled to the same legal protection as other types of creative
\nmaterials. If you want to use “clip art” or stock photographs, you must review
\nthe applicable license agreement carefully to determine whether your intended
\nuse is permissible.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

10<\/strong> Putting ethics into practice<\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Government agency complaints<\/strong><\/p>\n

Occasionally, an applicant, customer, or current\/former employee may file :
\nor threaten to file : a complaint against Gap Inc. with the government. If you
\nare contacted about a government complaint, immediately call the Code Hotline.
\nNeither your supervisor nor the company are permitted to take any action against
\nyou for making or reporting a government complaint.<\/p>\n

Government requests for information<\/strong><\/p>\n

We will always cooperate appropriately with proper government requests or
\ninvestigations. If you are asked by a government official to provide company
\ninformation (either written or verbally) for a government investigation : or if
\na government representative visits your workplace asking for company records,
\ndocuments or other information : notify the Human Resources department or Legal
\ndepartment (see Resources section for contact information and to find the
\nGovernment Response Plan on GapWeb). You should always give truthful, accurate
\ninformation, and never try to obstruct, influence or impede the request for
\ninformation. You also should not alter, falsify, mutilate, cover up, dispose of
\nor destroy any documents or records related to a government request,
\ninvestigation or legal proceeding.<\/p>\n

Protecting our environment<\/strong><\/p>\n

Gap Inc. is committed to minimizing the negative impact of our business
\nactivities on the environment. All employees are responsible for complying with
\napplicable environmental laws and Company policies.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Putting ethics into practice 11<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Bringing our<\/strong><\/p>\n

Code to life<\/strong><\/p>\n

Gap Inc. was built on integrity : by employees who strive to do the right
\nthing. Understanding and abiding by our Code of Business Conduct helps us
\nprotect our reputation. When you regularly review the Code, you153ll better
\nunderstand how it affects the business decisions you make. And making the right
\ndecisions is how we move Gap Inc. forward.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Act with<\/strong><\/p>\n

integrity166<\/strong><\/p>\n

every day.<\/strong><\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Treat each other<\/strong><\/p>\n

with respect.<\/strong><\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

\n

Do: what153s right. <\/strong><\/p>\n

Our reputation starts and ends with you.<\/p>\n<\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Abiding<\/p>\n

by the<\/p>\n

Code:<\/p>\n

and the<\/p>\n

law:<\/p>\n

isn153t<\/p>\n

optional.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Speak up if<\/p>\n

something<\/p>\n

isn153t right.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Avoid even the<\/p>\n

perception of a<\/p>\n

conflict of interest.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Remember your actions reflect on all of us.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Keep business<\/p>\n

information<\/p>\n

confidential.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

When in<\/p>\n

doubt, ask!<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n
\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Avoiding conflicts<\/strong><\/p>\n

of interest<\/strong><\/p>\n

What is a conflict of interest? It153s when your personal interest or
\ninvolvement in a situation interferes with your ability to make decisions
\nobjectively and act in the best interest of Gap Inc. It153s important we avoid
\nactivities that create:or even appear to create:a conflict of interest with the
\ncompany. Even when nothing wrong is intended, the appearance of conflicting
\ninterests can hurt your reputation and the company153s image.<\/p>\n

If you see or suspect a conflict of interest, talk with your manager or your
\nHuman Resources representative. You also may contact Global_Integrity@gap.com
\nfor help.<\/p>\n

Situations you must avoid:<\/strong><\/p>\n

Giving, receiving or soliciting tips, gifts, entertainment, discounts
\nor other personal benefits outside of policy<\/p>\n

Directing business to third parties when you know they are owned or
\nmanaged by your family members or close personal friends<\/p>\n

Misusing company resources, your position or influence to promote or
\nassist an outside activity, including a second job<\/p>\n

Using business relationships to further a personal interest, including
\nsupport for charitable organizations<\/p>\n

Holding a significant financial interest in a supplier, competitor or
\nvendor of the company without prior authorization from the Chief Compliance
\nOfficer<\/p>\n

Make sure to ask yourself<\/strong><\/p>\n

If you aren153t sure if you face a conflict of interest situation, review this
\nchecklist:<\/p>\n

Will the activity influence my business decision?<\/p>\n

Will a family member or friend benefit personally from my involvement in
\nthis situation?<\/p>\n

If this situation becomes public knowledge, would the company be
\nembarrassed?<\/p>\n

Will my participation in this activity interfere with my ability to do my
\njob?<\/p>\n

Would anyone think it might affect how I do my job?<\/p>\n

If the answer is “yes” or even “maybe” to any of these questions, you may
\nhave a conflict of interest and should discuss the situation with your manager
\nor Human Resources representative. You can also contact Global_Integrity@gap.com
\nfor help.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

14<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> One of my vendors offered to send me to a
\nconference at no cost to Gap Inc. May I accept the invitation?<\/p>\n

Answer:<\/strong> With prior approval from Global Integrity and
\nCompliance, you may accept the vendor153s offer to pay for your registration fee
\nfor the conference. Travel, lodging and other expenses related to the conference
\nmust be covered by the business, unless you are participating as a speaker.<\/p>\n<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Question:<\/strong> What should I do if I am given a gift outside of
\npolicy?<\/p>\n

Answer:<\/strong> You should thank the giver for their generosity and
\npolitely refuse by letting them know that Gap Inc.153s policy prohibits you from
\naccepting the gift.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Question:<\/strong> A vendor offered tickets to a sporting event to me
\nand a co-worker. We plan to meet the vendor153s team at the event. May we accept
\nthem?<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Answer:<\/strong> You may accept the tickets if the retail value of
\nthe entertainment is less than $100 USD (or equivalent) per person and the
\nvendor will attend the event.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Question:<\/strong> A production vendor I work with offered to make
\nuniforms for my son153s baseball team. Is this okay?<\/p>\n

Answer:<\/strong> No. This would be considered using a business
\nrelationship to further <\/p>\n

a personal interest,<\/p>\n

which is a conflict<\/p>\n

of interest and<\/p>\n

prohibited.<\/p>\n<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> My manager asked me to review bids from several
\nphotographers and recommend one for an upcoming photo shoot. I noticed that one
\nof the lowest bids is from a friend of mine who I know does really good work.
\nWhat should I do?<\/p>\n

Answer:<\/strong> You should let your manager know about the
\nrelationship, give your manager your unbiased feedback and then remove yourself
\nfrom the decision-making process to avoid any actual or perceived conflict of
\ninterest.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> May my brother apply for <\/p>\n

a job opening in my department?<\/p>\n

Answer:<\/strong> Yes, as long as the position is not within your
\nchain of command, and you do not influence the hiring decision.<\/p>\n<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Avoiding conflicts of interest 15<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Giving or accepting gifts and entertainment<\/strong><\/p>\n

It153s important to avoid even the appearance of making business decisions
\nbased on in-appropriate or unethical influences. To prevent this situation, we
\ndiscourage you and your family members from giving, soliciting or receiving
\ngifts and entertainment from anyone doing business with (or wishing to do
\nbusiness with) Gap Inc. Gift examples include cash or cash equivalents (gift
\ncards), samples, discounts, event tickets, personal favors, recreation and
\ntransportation. Entertainment could include tickets to sporting events,
\nconcerts, golf and other events you attend or participate in with the outside
\nindividual.<\/p>\n

The following types of gifts and entertainment are absolutely prohibited:\n<\/p>\n

Gifts exceeding $50 USD (or equivalent)<\/p>\n

Entertainment exceeding $100 USD (or equivalent)<\/p>\n

Any solicited gift<\/p>\n

Gifts exchanged in the form of cash or cash equivalents (gift cards)\n<\/p>\n

Entertainment that would violate other provisions of the Code<\/p>\n

If business circumstances call for the exchange of gifts or entertainment,
\nuse good judgment to make sure the exchange doesn153t influence:or appear to
\ninfluence:your business decisions. Remember: If you give a gift or entertainment
\nto someone you work with outside the company, it needs to support a legitimate
\nGap Inc. business interest.<\/p>\n

Don153t forget that you are required to let the Global Integrity and Compliance
\nDepartment (Global_Integrity@gap.com) know about all gifts or entertainment
\nreceived in any one-year period<\/strong> if:<\/p>\n

The gifts and entertainment total more than $100 USD (or equivalent)
\nfrom a single source<\/p>\n

The gifts and entertainment total more than $250 USD (or equivalent)
\nfrom all sources combined<\/p>\n

Some business units at Gap Inc. have more restrictive rules about giving and
\nreceiving gifts, so make sure you understand your business unit153s policies
\nbefore accepting or giving any gifts.<\/p>\n

Ask yourself<\/strong><\/p>\n

Regardless of value, before giving or accepting any gift or entertainment,
\nalways consider:<\/p>\n

Is the exchange intended to influence business negotiations?<\/p>\n

Will the exchange appear to others to influence business
\nnegotiations?<\/p>\n

Will the exchange result in any special or favored treatment?<\/p>\n

Will my participation in the activity reflect poorly on Gap Inc.?\n<\/p>\n

If your answer is YES to any of the above, do not participate in the
\nexchange.<\/p>\n

A few exceptions when it comes to gifts:<\/em><\/p>\n

Business meals:<\/strong> As long as they are infrequent and not
\nextravagant, business meals are not considered gifts or entertainment, and may
\nbe accepted. However, it is critical that any business meal not create a sense
\nof obligation or result in favored treatment with a vendor or business partner.\n<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

16<\/strong> Avoiding conflicts of interest<\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Non-cash holiday gifts:<\/strong> As long as you share them with your
\ndepartment, you are allowed to accept holiday gift items such as gift baskets,
\ncookies, chocolates, flowers, moon cakes, Ochugen and Oseibo gifts, or other
\nsuch non-cash gifts, even if they exceed the $50 USD (or equivalent) gift limit.\n<\/p>\n

Third-party trainings:<\/strong> Some conferences or training by third
\nparties may also be accepted with prior approval from the Global Integrity and
\nCompliance department.<\/p>\n

Chinese communities:<\/strong> During Chinese New Year, you may accept
\na cash gift in the form of “Lai See,” but only for a nominal amount valued up to
\nHK$100 (or equivalent).<\/p>\n

Doing business with spouses, partners, relatives or friends<\/strong>\n<\/p>\n

Even if you are extremely careful, working directly with your spouse,
\npartner, relative or friend can create an actual or perceived conflict of
\ninterest. You must get the written approval of the Chief Compliance Officer and
\nyour Vice President or above before doing company business with relatives,
\nfriends, spouses or life partners. Of course, under no circumstance may you
\npressure others into hiring your relatives, friends, spouses or life partners as
\na company employee, supplier, vendor or landlord.<\/p>\n

Make sure to ask yourself<\/strong><\/p>\n

If working with a family member or friend, consider:<\/p>\n

Does one of you supervise or report to the other?<\/p>\n

Does either of you provide input on the other153s performance or career?\n<\/p>\n

If you answered YES to either of these questions, you should talk to your
\nmanager or Human Resources representative.<\/p>\n

Handling personal relationships at work<\/strong><\/p>\n

We recognize and respect your rights to socialize and pursue personal
\nrelationships with your co-workers. You should use good judgment to make sure
\nthese relationships don153t negatively impact your job performance, ability to
\nsupervise others or work environment.<\/p>\n

Employees who find themselves in an intimate relationship or friendship
\nshould use tact and sensitivity to make sure they aren153t creating an
\nuncomfortable work environment for others. Favoritism, open displays of
\naffection, and business decisions based on emotions or friendships : rather than
\non the best interests of the company : are examples of inappropriate conduct.\n<\/p>\n

Personnel decisions can become difficult if you supervise someone you are
\nromantically involved with, living with or related to : leading to a possible
\nreal or perceived conflict of interest. If this is the case, you should talk
\nwith your manager or Human Resources representative, who will work with you and
\nthe other individual involved to separate your responsibilities from your
\npersonal relationship.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Avoiding conflicts of interest 17<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Working outside of Gap Inc.<\/strong><\/p>\n

You are required to get the approval of your supervisor and Human Resources
\nbefore accepting another job or working outside of Gap Inc. You also need
\nwritten approval from the Chief Compliance Officer before working for any Gap
\nInc. supplier, vendor, competitor or landlord.<\/p>\n

Exception:<\/em> If you work in a store or distribution center and don153t
\nsupervise other employees, you are pre-approved to work for other employers
\n(including retailers) as long as the work doesn153t interfere with your Gap Inc.
\nresponsibilities or schedule.<\/p>\n

Always remember that you may not use any company resources (time, equipment,
\nstaff, facilities, etc.) to support any outside work.<\/p>\n

Serving as a director or officer of another organization<\/strong>\n<\/p>\n

For-profit organizations:<\/strong> You need approval from the Chief
\nExecutive Officer and Chief Compliance Officer before serving as a director or
\nofficer of another for-profit company. You may not serve as a director or
\nofficer of a Gap Inc. competitor, potential competitor or a company with a
\nsignificant line of products that compete with those offered by Gap Inc.<\/p>\n

Non-profit organizations:<\/strong> We encourage you to serve as a
\ndirector, trustee or officer of a non-profit organization on your own time.
\nHowever, if you are representing Gap Inc., you must inform the Chief Compliance
\nOfficer. If you serve as a director or officer of a non-profit organization on
\nyour own time, always remember that you may not use company resources to support
\nany activity of the non-profit organization.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

18<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Protecting<\/strong><\/p>\n

our brands<\/strong><\/p>\n

Part of working with integrity is protecting Gap Inc.153s physical assets (such
\nas merchandise, equipment, and computers) as well as our intangible assets,
\nwhich includes our brand, reputation and confidential company information.<\/p>\n

Confidential and personal information<\/strong><\/p>\n

From time to time, you may have access to confidential information that
\npeople outside our company never see, such as unannounced product information or
\ndesigns, business or strategic plans, financial information and organizational
\ncharts, and other materials.<\/p>\n

Similarly, you may see personal information about co-workers, customers,
\nconsultants or other individuals. This could include names, addresses, e-mail
\naddresses, telephone numbers, government identification numbers (such as Social
\nSecurity numbers), employee ID numbers, and credit card or bank account
\ninformation. Personal information also may include race, gender, age, sexual
\norientation, religion, medical condition or similar information.<\/p>\n

We are each responsible for protecting Gap Inc.153s confidential and personal
\ninformation both while we are employees of the company and after our employment
\nends. Unauthorized use or disclosure of confidential or personal information may
\nlead to disciplinary action, including termination. Please report any suspected
\ninappropriate use or disclosure of confidential or personal information through
\nthe Open Door process or the Code Hotline. The company investigates reported
\nincidents where a breach of confidential or personal information may have
\noccurred.<\/p>\n

How to handle confidential and personal information<\/strong><\/p>\n

Only use confidential or personal information for company purposes\n<\/p>\n

Never use confidential or personal information for your own benefit
\nor the benefit of anyone else<\/p>\n

Don153t share this information with anyone outside the company unless
\nthere is a non-disclosure agreement or contract approved by the Legal department\n<\/p>\n

Only share confidential or personal information with co-workers who
\ntruly need to know to do their jobs<\/p>\n

Return all materials containing confidential or personal information
\non or before your last day with Gap Inc.<\/p>\n

It153s important to follow our standards of conduct around confidential
\ninformation with respect to the information of other companies as well. For
\nexample, you should never take or use confidential information or materials from
\na previous employer. You also shouldn153t ask for confidential information from
\nanother company153s employees or suppliers.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Protecting our brands 19<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> I received a call from a local charity asking for
\na list of the names and addresses of employees at my store in which I work. May
\nI share this information?<\/p>\n

Answer:<\/strong> No. Sharing Gap Inc. employee data violates company
\npolicy.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Question:<\/strong> How should I dispose of documents that contain
\nconfidential or personal information?<\/p>\n

Answer:<\/strong> Use a locked disposal bin or shredder. Do not use
\nregular recycling bins for these materials.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Question:<\/strong> I am really excited about my brand153s upcoming
\nadvertising campaign. May I give my friends and family members details about the
\ncampaign?<\/p>\n

Answer:<\/strong> No. Unannounced advertising campaigns are
\nconfidential information and may not be disclosed outside of the company.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n\n

Question:<\/strong> My laptop was stolen, but I153m not sure if there
\nwas any confidential or personal information on it : what should I do?<\/p>\n

Answer:<\/strong> All missing laptops must be reported to Corporate
\nSecurity.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> Where should I store electronic confidential or
\npersonal information?<\/p>\n

Answer:<\/strong> Confidential or personal information should always
\nbe kept on a network drive, never on your hard drive or a portable device. If
\nyour job requires that you keep this type of information on your laptop, you
\nmust have the company provided encryption software installed on your laptop. You
\nmay obtain encryption software through the Request Center on GapWeb.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<\/p>\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> What do I do if I don153t know if information I have
\naccess to is confidential or personal information?<\/p>\n

Answer:<\/strong> Talk to your manager.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

20<\/strong> Protecting our brands<\/p>\n<\/p>\n

\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Material information and insider trading<\/strong><\/p>\n

You may become aware of important company information before it153s been made
\navailable to the public. This information is called “material information” when
\nit could influence a decision to buy or sell a company153s stock. Material
\ninformation can include sales or inventory figures, financial information
\n(margins, earnings, and dividends), significant proposed acquisitions or
\nmanagement changes, planned stock splits or anything else that could affect the
\nstock price of Gap Inc. or another company.<\/p>\n

Ask yourself<\/strong><\/p>\n

In deciding whether something is material information, consider if the
\ninformation makes you think of buying or selling the stock of Gap Inc. or
\nanother company. If the answer is YES, it would likely have the same effect on
\nothers and is probably material information.<\/p>\n

If you153re unsure whether information is material or has been released to the
\npublic, call the Global Equity Administration department before trading (see
\nResources section for contact information).<\/p>\n

You153re not allowed to buy or sell the stock (or other securities) of Gap Inc.
\nor another company when you are aware of material information that has not been
\nmade public. You also are not allowed to share that information with others
\n(other than as required to do your job), or advise them to buy or sell the
\ncompany153s stock until the information has been made public.<\/p>\n

Once material information has been fully disclosed to the public, you may
\ntrade in the company153s stock. Full public disclosure generally means a widely
\ndistributed press release followed by publication in print media plus three or
\nmore days for distribution and interpretation of the information.<\/p>\n

Trading on material information before it153s been made public, also called
\n“insider trading,” is illegal and unethical, and can have severe consequences.
\nThe U.S. Securities and Exchange Commission and similar agencies are authorized
\nto bring a civil lawsuit against anyone who trades on inside information (or who
\nprovides another person with inside information) and also against the company.
\nInsider trading is also a crime subject to criminal penalties, including jail
\nterms.<\/p>\n

Media inquiries<\/strong><\/p>\n

Our Corporate Communications department handles all media inquiries for Gap
\nInc. If you talk directly to reporters without going through Corporate
\nCommunications, you run the risk of providing incorrect information, revealing
\nproprietary strategies or damaging our company153s reputation. You may not speak
\nto reporters on behalf of the company unless authorized. Instead, direct media
\ninquiries to the Corporate Communications Media Hotline (see Resources section
\nfor contact information).<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> A senior director mentioned in a meeting that Gap
\nInc. is expected to post a loss for the quarter. May I share this news with my
\nfriends and family? May I trade in Gap Inc. stock?<\/p>\n

Answer:<\/strong> No. The information you overheard is considered
\n“material.” The senior director should not have shared this information with you
\nunless you needed the information to do your job. Trading Gap Inc. stock by you,
\nyour friends or your family based on this information before it is publicly
\ndisclosed would be a violation of the law.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Protecting our brands 21<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Financial integrity<\/strong><\/p>\n

Accurate business records are essential to managing a successful company.
\nEvery employee is responsible for making sure all company records, information
\nand accounts are clear, truthful and accurate. For example, your expense
\nreports, time records, payments and other transactions must be correctly
\nrecorded, accounted for and approved.<\/p>\n

Keep in mind that business records and communications are company assets and
\nmay become public through government investigations, litigation or the media.
\nYou should follow the schedules in our Records Management Policy when deciding
\nwhether to keep or destroy business records (physical and electronic) (see
\nResources section to find the policy on GapWeb.) Also, keep in mind that some
\nrecords may need to be kept or preserved in the event of litigation or a
\ngovernment investigation. Check with the Legal department if you have questions
\nabout managing our records (see Resources section for contact information).<\/p>\n

As a public company, it153s critical that we disclose and report company
\ninformation, including our financial results and financial condition, in a full,
\nfair, accurate, timely and understandable way. All employees must comply with
\ncompany policies, procedures and controls. Accounting and financial reporting of
\ntransactions and forecasts must follow Gap Inc.153s accounting policies as well as
\nall generally accepted accounting principles and laws.<\/p>\n

If you have any concerns about the company153s financial controls, accounting,
\nfinancial reporting or auditing, contact Global_Integrity@gap.com or call the
\nCode Hotline.<\/p>\n

Cooperating with Audits<\/strong><\/p>\n

We all must cooperate fully with our internal and external auditors. You must
\nnot take any action to coerce, manipulate, mislead or fraudulently influence any
\npublic accountant engaged in an audit or review of Gap Inc.153s financial
\nstatements.<\/p>\n

Company property<\/strong><\/p>\n

Gap Inc. property (for example, merchandise, samples, supplies and equipment)
\nshould be used only for business purposes and not for personal use. Taking or
\nusing company property, such as samples of any value for personal purposes
\nwithout appropriate permission is stealing (for information on handling samples,
\nsee Resources section to find the Samples Management Policy on GapWeb). Gap Inc.
\nproperty may never be used for illegal purposes. You are prohibited from doing
\nanything that involves fraud, theft, embezzlement or misappropriation of company
\nproperty. If you suspect that activities in a store, distribution center, or
\nother facility are resulting in financial losses to the company (for example,
\nstealing), talk with your manager or call the Code Hotline.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> Is it okay to take home samples or defective
\nmerchandise?<\/p>\n

Answer:<\/strong> No. Taking any company property, including samples
\nor defective merchandise for personal use (even if you153re using it while in the
\noffice), is prohibited.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> May I send a personal fax from work or use my work
\nemail to communicate with a friend?<\/p>\n

Answer:<\/strong> Yes. Limited personal use of the company153s
\nelectronic communication resources is permitted as long as it complies with our
\nElectronic Communication Policy and does not interfere with your ability to do
\nyour job.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

22<\/strong> Protecting our brands<\/p>\n<\/p>\n

\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Trademarks and counterfeit merchandise<\/strong><\/p>\n

We all share a responsibility to protect company assets. This includes cash,
\ninventory, computers, equipment and supplies as well as intangible assets, such
\nas our brands, trademarks and reputation.<\/p>\n

Our trademarks (for example, Gap, GapKids, BabyGap, Banana Republic, Old
\nNavy, Piperlime, or Athleta) are among our company153s most valuable assets, and
\nall employees and business partners should help protect them. As our company
\nbecomes better known worldwide, we encounter increasing problems with
\ncounterfeit merchandise and “pirates” who sell merchandise under our trademarks.
\nOur vendors are also prohibited from selling or improperly distributing any
\nmerchandise bearing our trademarks, called “sell-off” merchandise, to anyone.
\nYou should promptly report instances of sell-off or counterfeit merchandise as
\nwell as other unauthorized uses of our trademarks.<\/p>\n

The Gap, Banana Republic, Old Navy, Piperlime, and Athleta trademarks are
\nowned by Gap Inc. and its subsidiaries, Gap (Apparel) LLC, Banana Republic
\n(Apparel) LLC, Old Navy (Apparel) LLC, Athleta Inc., Gap (ITM) Inc., Banana
\nRepublic (ITM) Inc., Old Navy (ITM) Inc., and Athleta (ITM) Inc.<\/p>\n

What to do if you see or suspect counterfeit merchandise?<\/strong>\n<\/p>\n

If you find sell-off or counterfeit merchandise : with any part of our
\ntrademarks on labels, hang tags, price tags, pocket flashers, other packaging,
\nor screened or embroidered onto the merchandise:in a location other than one of
\nour company-owned, franchise or wholesale locations, please:<\/p>\n

Note the name of the store, its location and size<\/p>\n

Try to estimate the volume of sell-off or counterfeit merchandise
\nbeing sold<\/p>\n

Email the Legal department at trademarks@gap.com<\/p>\n

If you see large volume sales of sell-off or counterfeit merchandise in a
\nlocation that would be difficult for someone to return to:<\/p>\n

Buy a sample of each type of merchandise (for example, a shirt or a
\npair of jeans). You may be reimbursed for these purchases<\/p>\n

Estimate the quantity being offered for sale<\/p>\n

Take photographs of signs or advertisements, if possible<\/p>\n

Collect business cards or promotional material<\/p>\n

Email the Legal department at trademarks@gap.com<\/p>\n

Also report stores operating under different names that copy the look and
\nfeel of our stores, or use labels or advertisements with our distinctive
\nlettering or advertising styles to the Legal department at trademarks@gap.com.\n<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Protecting our brands 23<\/strong><\/p>\n<\/p>\n

\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Understanding<\/strong><\/p>\n

political guidelines<\/strong><\/p>\n

We encourage employees and Directors to get involved with issues that are
\nimportant to our business and community. However, political activity is
\ncarefully regulated by law, and there are strict guidelines and prohibitions
\nagainst employees participating in political activity on behalf of Gap Inc. For
\nthat reason, all political activity on behalf of the company must be initiated
\nor approved in advance by the Government Affairs and Public Policy team (see
\nResources section for contact information).<\/p>\n

Political activities<\/strong><\/p>\n

Your personal political activities must be done on your own time, with your
\nown resources. Out of respect for others, you must not promote any personal
\npolitical views or beliefs (including by posting or distributing notices or
\nother materials) on Gap Inc. premises. You also should not suggest that you
\nspeak for the company or that Gap Inc. supports your personal views.<\/p>\n

Political contributions<\/strong><\/p>\n

Gap Inc. provides eligible employees who are U.S. citizens with the
\nopportunity to contribute to the Gap Inc. Political Action Committee (GPAC). The
\nGPAC is a separate legal entity funded solely by voluntary contributions from
\neligible employees and Directors. All GPAC contributions are made in accordance
\nwith U.S. laws and regulations governing political action committees. You are
\nnot permitted to make direct financial contributions to any political candidate
\non behalf of Gap Inc.<\/p>\n

Lobbying<\/strong><\/p>\n

Lobbying is generally defined as contact with elected officials regarding
\nlegislative or regulatory issues impacting Gap Inc. Because we are required to
\nfollow strict reporting requirements around lobbying, the Government Affairs and
\nPublic Policy team must approve any lobbying activities on behalf of the
\ncompany, including retaining an external lobbyist or lobbying firm.<\/p>\n

You should know166<\/strong><\/p>\n

Over time, new policies will need to be written and old ones revised. While
\nwe reserve the right to make these changes without notice, we will try to let
\nyou know about any changes affecting your employment as soon as possible.<\/p>\n

The provisions of this Code may only be waived by Gap Inc.153s Chief Compliance
\nOfficer, and, in the case of executive officers, directors and our Controller,
\nby our Board of Directors or a Board Committee. Any waiver of this Code for an
\nexecutive officer, director or our Controller will be promptly disclosed as
\nrequired by law or stock exchange regulation.<\/p>\n<\/td>\n

<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> If I make a personal contribution to a political
\nparty or candidate, using my own money and resources, will I still be compliant
\nwith the Code?<\/p>\n

Answer:<\/strong> Yes, within the limits of the law. Gap Inc.153s policy
\nonly restricts political contributions made on behalf of the company.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
<\/td>\n<\/td>\n<\/td>\n\n

Question:<\/strong> What is the purpose of the Gap Inc. Political
\nAction Committee (GPAC)?<\/p>\n

Answer:<\/strong> The purpose of the GPAC is to support Federal
\ncandidates and committees that best support our corporate goals and business
\nstrategy in line with our company culture and values.<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

24<\/strong><\/p>\n<\/p>\n

\n

Resources <\/strong><\/p>\n

Here are more resources for questions about Gap Inc.153s Code of Business
\nConduct and other policies:<\/p>\n<\/p>\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n\n
<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Question about:<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Please contact:<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Phone<\/strong><\/p>\n<\/td>\n

<\/td>\n\n

Email<\/strong><\/p>\n<\/td>\n<\/tr>\n

\n

Boycotts<\/p>\n<\/td>\n

<\/td>\n\n

Legal Department<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n

<\/td>\n\n

legal@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Bribes or improper payments<\/p>\n<\/td>\n

<\/td>\n\n

Global Integrity and Compliance<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n

<\/td>\n\n

global_integrity@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Competition laws<\/p>\n<\/td>\n

<\/td>\n\n

Legal Department<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n

<\/td>\n\n

legal@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Conflicts of interest<\/p>\n<\/td>\n

<\/td>\n\n

Global Integrity and Compliance<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n

<\/td>\n\n

global_integrity@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Discrimination, harassment or retaliation<\/p>\n<\/td>\n

<\/td>\n\n

Your Manager, Human Resources, or the Code Hotline<\/p>\n<\/td>\n

<\/td>\n\n

1-866-GAP-CODE<\/p>\n

1-866-427-2633<\/p>\n<\/td>\n

<\/td>\n\n

employee_relations_Department @gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Government requests for information<\/p>\n<\/td>\n

<\/td>\n\n

Your Manager, Human Resources or Legal Department<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n

<\/td>\n\n

legal@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Insider trading or material information<\/p>\n<\/td>\n

<\/td>\n\n

Global Equity Administration Department<\/p>\n<\/td>\n

<\/td>\n\n

415-427-9200<\/p>\n<\/td>\n

<\/td>\n\n

insider_trading_ compliance@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

International trade regulations<\/p>\n<\/td>\n

<\/td>\n\n

Legal Department<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n

<\/td>\n\n

legal@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Media inquiries<\/p>\n<\/td>\n

<\/td>\n\n

Media Hotline<\/p>\n<\/td>\n

<\/td>\n\n

(800) 333-7899, x75900<\/p>\n

(within the U.S.)<\/p>\n

(650) 952-4400, x75900<\/p>\n

(outside the U.S.)<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Political activities<\/p>\n<\/td>\n

<\/td>\n\n

Government Affairs and Public Policy Team<\/p>\n<\/td>\n

<\/td>\n\n

415-427-5542<\/p>\n<\/td>\n

<\/td>\n\n

legal@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Trademark violations<\/p>\n<\/td>\n

<\/td>\n\n

Legal Department<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n

<\/td>\n\n

trademarks@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Use of third-party materials<\/p>\n<\/td>\n

<\/td>\n\n

Legal Department<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n

<\/td>\n\n

legal_clearance@gap.com<\/p>\n<\/td>\n<\/tr>\n

<\/td>\n<\/td>\n<\/td>\n<\/td>\n<\/tr>\n
\n

Vendor conduct<\/p>\n<\/td>\n

<\/td>\n\n

Social Responsibility<\/p>\n<\/td>\n

<\/td>\n\n

:<\/p>\n<\/td>\n

<\/td>\n\n

social_responsibility@gap.com<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Our policies on GapWeb <\/strong><\/p>\n

Learn more about our policies by going to GapWeb > Company Sites >
\nCorporate Departments ><\/p>\n

Legal > Our Teams > Global Integrity and Compliance<\/p>\n<\/p>\n\n\n\n
<\/td>\n\n<\/td>\n<\/td>\n\n

Anti-Corruption Policy<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
<\/td>\n\n<\/td>\n<\/td>\n\n

Competition Law Policy<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
<\/td>\n\n<\/td>\n<\/td>\n\n

Records Management Policy<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n\n\n\n
<\/td>\n\n<\/td>\n<\/td>\n\n

Samples Management Policy<\/p>\n<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

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