Gap Inc CODE OF BUSINESS CONDUCT Doing the Right Thing TABLE OF CONTENTS About the Code of Business Conduct Purpose Your Responsibilities Applicable Laws Obtaining Additional Information Reporting Code Violations No Retaliation Policy Changes Waivers Company Information and Assets 4 4 4 5 5 5 5 5 Conflicts of Interest General Gifts Entertainment Doing Business with Spouses Relatives or Friends Fraternization Outside Employment Outside Service as a Director or Officer Confidentiality Confidentiality of Personal Data Insider Trading Media Inquiries Accuracy of Company Records and Integrity in Reports Communications No Improper Influence on Audits Commercial Transactions Protecting the Brand Company Property 13 13 14 14 14 6 Political Contributions and Activities 6 7 Company Contributions 8 Personal Contributions 8 Lobbying 8 Legal Compliance Zero Means Zero No Discrimination or Harassment Complaint Procedures Accommodations for Disabilities Workplace Violence Labor Laws and Record Keeping Alcohol Drugs Complaints to Government Agencies Government Proceedings Requests for Information International Trade Regulations Antiboycott Policy Bribes and Improper Payments Antitrust Laws Selling Practices 12 12 12 13 8 CODE HOTLINE 9 9 9 9 10 10 10 10 10 11 11 To Report Suspected Violations of the Code For callers from the U S Canada and Puerto Rico 1 866 GAP CODE toll free For international callers 1 770 582 5221 operator assisted free call 15 15 15 Fair Dealing Product Integrity Respecting Intellectual Property Rights The Environment Health Safety 11 11 11 The Code Hotline is staffed by a live operator from an outside company 24 hours a day seven days a week Calls may be made anonymously You may also 11 11 CODE OF BUSINESS CONDUCT DOING THE RIGHT THING Gap Inc was founded in 1969 on the principle of conducting business in a responsible honest and ethical manner Today Gap Inc remains committed to meeting the highest standards of business conduct Nothing less will do We make this commitment to our shareholders customers neighbors and each other not only out of legal obligation but because it s the right thing to do Gap Inc s success depends on a reputation for integrity and quality in everything we do We all make an important contribution to the Company s reputation As we look to the future each of us is responsible for helping ensure that we continue to meet the standards that have made Gap Inc a leader s Paul S Pressler s Anne B Gust Paul S Pressler President and Chief Executive Officer Gap Inc Anne B Gust Chief Compliance Officer and Executive Vice President Gap Inc GAP INC CODE OF BUSINESS CONDUCT Updated Feb 1 2004 3 ABOUT THE CODE OF BUSINESS CONDUCT PURPOSE The Code of Business Conduct Code is designed to promote a responsible and ethical work environment for all Gap Inc employees and directors The Code contains guidelines on proper behavior in the workplace and whom you should contact if you have specific questions or concerns The Code applies to all Gap Inc employees and directors References in the Code to Gap Inc or the Company are generally intended to mean Gap Inc and its subsidiaries as a group YOUR RESPONSIBILITIES 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 You are responsible for knowing and following the laws and policies that relate to your job including the policies in the Code and all other Company policies including but not limited to Policy and Procedure manuals Employee Handbooks Human Resource manuals etc Violating these policies may result in corrective action up to and including termination of employment recovery of damages and filing of criminal charges However most problems can be easily avoided by simply using good judgment and seeking guidance when questions arise It is your responsibility to raise questions make appropriate disclosures and bring potential problems to the Company s attention Questions to Ask Ourselves Is this the right thing to do Is this legal Is this permitted under our Code of Business Conduct Would I want to see this reported in the media If the answer to any of these questions is NO you should discuss the situation with your supervisor the Human Resources department or the Corporate Compliance Governance department immediately Supervisors at the manager level and above are responsible for reviewing the Code with their employees and preventing detecting and responding to compliance problems by Leading with integrity Encouraging employees to raise questions and concerns Providing education and counseling to employees Initiating periodic compliance reviews with employees and Taking prompt and effective action where appropriate APPLICABLE LAWS If the Code or the Company requires you to take an action or prohibits you from taking action that you believe is in violation of a law or if you believe there is a conflict between the applicable laws of two or more jurisdictions please call the Code Hotline The Company acknowledges that there are differences in local laws and practices between countries In some instances the Code establishes policies and or requirements that would not otherwise be required in some countries In keeping with the Company s commitment to meet the highest standards of business conduct wherever we do business all employees must comply with all aspects of the Code even if it is not required by local laws Conversely there may be laws in certain countries which may not specifically apply outside of those countries and therefore are not specifically addressed in the Code Such laws would be addressed in Company documents such as but not limited to Employee Handbooks Policy and Procedure manuals and Human Resource manuals You are responsible for knowing and following all such laws and policies that relate to your job Throughout this Code references to applicable laws includes any law rule or regulation applicable to the Company or its employees or directors 4 GAP INC CODE OF BUSINESS CONDUCT Updated Feb 1 2004 OBTAINING ADDITIONAL INFORMATION If you have questions about the policies outlined in the Code or would like additional information talk to your supervisor or refer to Gap s Open Door Policy You can also contact the Human Resources department or the Corporate Compliance Governance department REPORTING CODE VIOLATIONS It is important to report all violations or suspected violations of the Code Gap Inc maintains a Code
View Full Document
Unlocking...