Trading on inside information can have severe consequences. In addition, you must insist that vendors comply with applicable health and safety regulations, and that merchandise vendors follow the guidelines outlined in the Company's Code of Vendor Conduct. 14 GAP INC. CODE OF BUSINESS CONDUCT (Updated Feb. 1 2004). You should not use any personal data for personal benefit or in any other inappropriate way. Partnership If for any reason an entry must be changed, your supervisor must make the change, and you must initial it. Likewise, our customers have a right to wear Gap Inc. clothes and use our products with the knowledge that we are living up to their own high ethical standards. GOVERNMENT PROCEEDINGS AND REQUESTS FOR INFORMATION. You are prohibited from doing anything that involves fraud, theft, embezzlement or misappropriation of Company property. GAP INC. CODE OF BUSINESS CONDUCT (Updated Feb. 1, 2004) 9. By law, Gap Inc. employees and agents may not support or cooperate with an unsanctioned boycott of another country that is "friendly" to the United States. Admits Problems, Vows to Improve Working Conditions at Garment Factories. Please direct members of the media with inquiries to the Corporate Communications Media Hotline at (800) 333-7899, x75900 (within the U.S.) or (650) 952-4400, x75900 (outside the U.S.). Indemnification Gap Inc. Employees or agents of the Company should never directly or indirectly offer, promise to pay or authorize the payment of money, products, services or anything of value to any government official or agent in any country in order to influence acts or decisions of government officials, to receive special treatment for the Company or for personal gain. Direct Returns 100 Gap Inc. Gap Inc. respects and values its employees' and customers' privacy, and we expect our employees to do the same. The first social responsibility report issued by Gap Inc. found gaps in the occupational health and safety and human rights policies at some of the factories used by the retailing giant. In addition to meeting the Company's internal quality standards, our products must be produced, tested, packaged and labeled in full compliance with applicable laws and Company policies. Employees also must not be under the influence of illegal drugs or alcohol during work hours, regardless of when the drugs or alcohol were consumed. ACCURACY OF COMPANY RECORDS AND INTEGRITY IN REPORTS AND COMMUNICATIONS. Answer: No. The official return policy for Gap states that customers can return items purchased online or in … Employees must obtain approval from the Chief Executive Officer and Chief Compliance Officer before serving on the board of directors or as an officer of another for-profit company. Identity Theft Promissory Note Employee Stock Purchase Plan (ESPP) allows full- and part-time employees to purchase Gap Inc. stock at a 15% discount quarterly. The Company acknowledges that there are differences in local laws and practices between countries. Question: Can I make a personal contribution to a political party or candidate? + Coordinates and assists in providing human resource training to staff. Ive also seen 2 people that worked their 8 years each leave because they knew they wouldn't be able to move up. Most costs associated with your attendance at the conference must be paid for by your department. In that time I've seen 4 managers come and go. You may also accept holiday gift baskets or flowers within reason, as long as they are shared with the entire department. Favoritism, open displays of affection, and making business decisions based on emotions or friendships rather than on the best interests of the Company are examples of inappropriate conduct. It is also against Company policy to take any action against any employee or a director, vendor or agent of the Company for (1) lawfully providing information or assisting in an investigation of activities which he or she reasonably believes violates applicable law or (2) for providing truthful information to the government, a government agency or law enforcement officers relating to the commission of a legal offense. The Company will provide a reasonable accommodation to a qualified employee who has a physical and/or mental disability. Information relating to Gap Inc.'s business or strategy is strictly confidential. Non-Competition If you are asked to provide information (either written or verbally) for a government investigation, or if a government representative appears at your workplace, notify the Human Resources department or Legal department. Also report any stores operating under different names that copy the look and feel of our stores, or use labels or advertisements with our distinctive lettering or advertising styles. Full public disclosure generally means a widely distributed press release followed by publication in the print media and three or more days for distribution and interpretation of the information. Question: How can I be sure that documents I throw away stay confidential? Employees who find themselves in an intimate relationship or friendship should use tact, good judgment and sensitivity. Accepting a free trip from a vendor is a violation of Company policy. Franchise Reports to the Code Hotline may be made anonymously. If you see large volume sales of such merchandise in a location that would be difficult for someone to return to, buy a sample of each type of merchandise (for example, a shirt or a pair of jeans) and estimate the quantity being offered for sale. You may not accept the tickets if the total face value of the tickets received is U.S. $50 (or equivalent) or more, even if the vendor did not pay for them. The Company will provide a reasonable accommodation to a qualified employee who has a physical and/or mental disability. Examples include: information relating to sales, inventory, margins, earnings, significant proposed acquisitions, planned stock splits, proposed changes in dividends and other information that has the potential to affect the stock price of Gap Inc. or another company. In any event, you should advise the vendor about our policies regarding conflicts of interest. Question: One of my vendors offered me a free trip to a golf event it is sponsoring. You should understand your business unit's policies prior to accepting or giving any gifts or entertainment. We are committed to recruiting, hiring, training and promoting qualified people of all backgrounds, and make all employment decisions without regard to any protected status. You should understand your business unit's policies prior to accepting or giving any gifts. Addressing climate change benefits our business, making us more resilient and efficient, while enhancing our connection with consumers, employees and other stakeholders. Material information is any information that could be considered important by a person in deciding whether to trade in a company's stock. The Gap, Inc., commonly known as Gap Inc. or Gap, (stylized as GAP) is an American worldwide clothing and accessories retailer. If known by you, your friends or others when buying or selling Gap Inc. stock before public disclosure of the information, that would be in violation of U.S. laws. Answer: To cooperate fully with our external auditors, you should tell them that you are only 80% sure of the answer and perform the additional research if required. If you are unsure of the value, return it. Gap Inc.'s success depends on a reputation for integrity and quality in everything we do. Close the achievement gap by reducing the attendance gap. Management It is also a violation of this policy to sell, transfer or distribute personal prescription drugs on Company premises, in Company vehicles or during work hours. For callers from the U.S., Canada and Puerto Rico: 1-770-582-5221 (operator–assisted free call), The Code Hotline is staffed by a live operator from an outside company, 24 hours a day, seven days a week. In addition, certain vendor-paid trainings may be appropriate, but only with the written approval of the Chief Compliance Officer. In short, the Company is required by law to disclose lobbying-related information in great detail. Gap Inc. is an equal-opportunity employer and is committed to providing a workplace free from harassment and discrimination. Can I accept the trip as long as it doesn’t affect my purchasing decisions? Gap Inc. supported this legislation, which we also view as a policy lever to assist in the global fight against human trafficking. Is this permitted under our Code of Business Conduct? Taking prompt and effective action where appropriate. We plan to meet the vendor's team at the event. While certain minor payments to certain non-U.S. government officials made to expedite or secure the performance of certain routine governmental actions may not violate the law, you must consult with the Legal department prior to making or authorizing any payment of this type. You must obtain the written approval of your Vice President or above, and the Chief Compliance Officer, before doing Company business with parties such as relatives, friends, spouses or life partners You must always keep the Company's interests top priority in those interactions. All employment decisions are to be made without regard to race, color, age, gender, sexual orientation, religion, marital status, pregnancy, national origin/ancestry, citizenship, physical/mental disability, military status or any other basis prohibited by law, including but not limited to family status in Canada. Position Objective: Provide services as a Policy Analyst in support of the Scientific, Operations and Administrative Resources (SOAR) program at various Institutes and Centers within the National Institutes of Health (NIH). Unwanted sexual advances or propositions; Offering employment benefits in exchange for sexual favors; Making or threatening reprisals after a negative response to sexual advances; Visual conduct: leering, making sexual gestures, displaying of sexually suggestive objects or pictures, cartoons or posters, electronic display or dissemination of such material; Verbal conduct: making or using derogatory comments, epithets, slurs and jokes; Verbal abuse of a sexual nature, graphic verbal commentaries about a person's body, sexually degrading words used to describe a person, suggestive or obscene letters, notes or invitations; and. Keep in mind that business records and communications may become subject to public disclosure through government investigations, litigation or the media. Gap Inc. was founded in 1969 on the principle of conducting business in a responsible, honest and ethical manner. For purposes of this policy, harassment includes slurs and any other offensive remarks, jokes and other verbal, graphic, or physical conduct that could create an intimidating, hostile or offensive work environment. Stock Purchase, Divorce We cannot help resolve a discrimination, harassment or retaliation problem unless we know about it. Answer: No. It is Gap Inc. policy to regard all people, with or without disabilities, as individuals – to look at each person’s skills and abilities. Gap Inc. is an equal-opportunity employer and is committed to providing a workplace free from harassment and discrimination. LLC In doing your job, you are responsible for abiding by Gap Inc. policies and all local and national laws in all countries in which the Company does business. However, management respects and understands the Chinese tradition of giving "Lai See" during Chinese New Year as a friendly gesture. We take pride in providing high quality products. The information you overheard is considered "material." Accepting a gift valued at U.S. $50 (or equivalent) or more from a vendor is a violation of Company policy. The United States Securities and Exchange Commission and similar agencies are authorized to bring a civil lawsuit against anyone who trades on inside information (or who provides another person with inside information) and also against the Company. If I give them this answer without qualifying it I think they will be satisfied and move on, allowing me to get back to my work. The Company does not encourage the acceptance of "Lai See," and employees should not under any circumstance solicit for it. You are expected to cooperate fully with our internal and external auditors. You can find other examples in the confidentiality acknowledgement all employees are required to sign upon hire. Encouraging employees to raise questions and concerns; Providing education and counseling to employees; Initiating periodic compliance reviews with employees; and. You should never make unauthorized copies of material from copyrighted books, magazines, newspapers, videotapes or computer programs. Our Code of Vendor Conduct (COVC) sets forth the basic requirements that all factories must meet in order to do business with Gap Inc. Can I share this news with my friends? Employees should not alter, falsify, mutilate, cover up, dispose of, or destroy any documents or records related to a government request or investigation or legal proceeding. Don’t forget to put your packing slip in the box with your order. The consequences of a changing climate are profound and wide-ranging, from biodiversity and water resources, to public health and agricultural impacts, to increased risk to our business in the short and long term. Neither your supervisor nor the Company will take any action against you for reporting suspected misconduct in good faith.