The Gap, Inc. (GAP) — ESG & Values Scores

Environment story

GAP demonstrates moderate environmental commitment but faces significant transparency and greenwashing risks. The company discloses limited Scope 1, 2, and 3 emissions data, with no explicit net-zero target year disclosed in available filings. Supply chain emissions (Scope 3) represent a material footprint in apparel manufacturing and logistics. The 10-K acknowledges climate change risks to operations and supply chain but does not detail specific decarbonization infrastructure investments. No evidence of verified renewable electricity procurement targets or operational carbon reduction initiatives. Supply chain vulnerability in Vietnam (27%) and Indonesia (21%) exposure creates concentration risk. The company's acknowledgment of evolving sustainability reporting standards suggests disclosure gaps. Without clear net-zero targets, Scope 3 mitigation strategy, or verified renewable commitments, environmental credibility is constrained.

Criticisms on file

Undisclosed Scope 3 Emissions and Rising Supply Chain Carbon Risk
Source: GAP 10-K 2025: Risk Factors acknowledge climate change impact on supply chain operations and vendor facilities; no disclosed Scope 3 baseline or trend data.
No Disclosed Net-Zero Target or Climate Commitment Timeline
Source: GAP 10-K 2025: Management's Discussion and Analysis references sustainability integration but does not specify net-zero year or interim decarbonization milestones.
Supply Chain Concentration Risk in High-Emission Manufacturing Regions
Source: GAP 10-K 2025: Approximately 27% merchandise from Vietnam, 21% from Indonesia; both countries with significant manufacturing carbon footprints and limited disclosure of supplier decarbonization requirements.
Vulnerability to Climate Physical Risks Without Explicit Mitigation Strategy
Source: GAP 10-K 2025: Risk Factors state properties and operations vulnerable to hurricanes, floods, droughts, wildfires; no detailed business continuity or climate resilience plan disclosed.

Disclosed initiatives

Sustainability Integration into Business Practices

Company states commitment to integrating sustainability into business practices to support long-term growth as part of strategic priorities.

Direction unclear; no quantified targets or timelines provided.
Supply Chain and Inventory Management Optimization

Shared investments in supply chain and inventory management cited to optimize efficiency and responsiveness.

Potential operational emission reduction through logistics efficiency, but not explicitly framed as decarbonization.

Social story

GAP demonstrates moderate social commitment with documented DEI programs and union neutrality, but faces significant labor-relations risks and compensation equity gaps. No CEO-to-worker pay ratio disclosed, preventing precise penalty calculation; assumed ratio likely exceeds 200:1 based on retail industry norms and market cap. Union organizing activity is acknowledged as present but unresolved; no recent major strikes or documented NLRB violations disclosed in provided filings. Leadership diversity percentage not explicitly stated; typical retail/apparel sector leadership diversity under 40% suggests potential penalty. Supply chain labor audits via Code of Vendor Conduct exist but no detailed human-rights audit results disclosed. Turnover rate not reported. The company acknowledges labor shortage in field and distribution positions and notes increased union organizing activity post-NLRB rule changes, creating ongoing friction. Social initiatives exist but lack quantified targets and transparency.

Criticisms on file

Increased Union Organizing Activity and NLRB Facilitation
Source: GAP 10-K 2025: Risk Factors state 'increase in workers exercising their right to form or join a union, both generally and in the retail industry' and 'NLRB has issued decisions making it easier for employees to organize.' Company acknowledges union organizing activity 'from time to time.'
Labor Shortages and Wage Pressure in Field and Distribution Center Roles
Source: GAP 10-K 2025: Risk Factors note company has 'experienced a shortage of labor for field and distribution center positions' and faces 'competitive wage pressures, minimum wage legislation, and overtime and paid leave regulations.'
Undisclosed CEO-to-Worker Pay Ratio
Source: GAP 10-K 2025: MD&A and financial statements do not disclose CEO compensation ratio or median worker wage; prevents verification of pay equity.
Supply Chain Labor Compliance Gaps
Source: GAP 10-K 2025: Risk Factors acknowledge 'vendors and their suppliers may not be in compliance with [Code of Vendor Conduct] standards or applicable local laws' and note 'Significant or continuing noncompliance...could subject us to liability.'
No Disclosed Leadership Diversity Metrics
Source: GAP 10-K 2025: MD&A and audit do not provide executive or board diversity percentages; standard DEI reporting absent.

Disclosed initiatives

Code of Vendor Conduct Compliance Program

Company requires vendors in multiple countries to adhere to Code of Vendor Conduct covering anti-corruption, environmental, labor, health, and safety standards.

Establishes baseline labor compliance framework; compliance audit results not disclosed.
Talent Development and Retention Programs

Strategic priority to strengthen culture by developing talent and fostering high-performance environment; specific programs not detailed.

Direction stated but quantified outcomes and wage-competitiveness metrics not disclosed.
Omni-Channel Store Operations and Employee Experience

Investment in store operations and omni-channel capabilities; positions stated as supporting employee engagement.

Indirect labor benefit; no health, safety, or compensation data disclosed.

Governance story

GAP exhibits moderate governance structure with single-class share voting (positive), but board independence and lobbying disclosure gaps limit transparency. Board independence percentage not explicitly stated in filings; standard retail governance assumes 75–80% independence (within acceptable range, no penalty). No dual-class share structure disclosed. Lobbying expenditures not detailed; company does not appear to have public disclosure of targeted climate or consumer-protection lobbying. Active compliance risk exists: company disclosed NLRB labor-organizing facilitation, Microsoft cybersecurity outage impact (2025), and complex data privacy obligations (GDPR, state-level laws). No significant antitrust, financial-fraud, or consumer-safety consent decrees disclosed. Risk factors extensively detail cybersecurity, data privacy, and AI governance gaps rather than historical violations. Governance culture reflects reactive compliance rather than proactive board oversight of emerging risks (AI ethics, supply chain transparency).

Criticisms on file

Undisclosed Board Independence Percentage
Source: GAP 10-K 2025: Proxy statement and governance disclosures not provided in filings; board composition independence metrics not stated.
Undisclosed Annual Lobbying Expenditures
Source: GAP 10-K 2025: No disclosure of lobbying spend or climate/consumer-protection policy advocacy positions.
Significant Cybersecurity and Data Privacy Exposure
Source: GAP 10-K 2025: Risk Factors disclose company has 'been targeted by cyberattacks, which in some cases have been successful.' Retail industry noted as particular target. Company admits 'logging processes may not be sufficient to fully investigate a cyberattack.'
AI Integration Governance Gaps
Source: GAP 10-K 2025: Risk Factors acknowledge AI use 'could increase the risk of exposure of confidential or competitively sensitive information' and may generate 'offensive, illegal, inaccurate, or otherwise harmful content.' No independent ethics board or third-party audit disclosed.
Third-Party Cloud Infrastructure Single-Point-of-Failure Risk
Source: GAP 10-K 2025: MD&A discloses 'in 2025 we were affected by a global outage at Microsoft which impacted various Microsoft services.' Company acknowledges 'reliance on third-party systems means that any downtime or security issues they experience poses a greater risk of a single point of failure.'
Complex Legal Proceedings and Litigation Exposure
Source: GAP 10-K 2025: Risk Factors note company subject to 'various proceedings, lawsuits, disputes, and claims' including 'commercial, intellectual property, customer, employment, securities, and data privacy claims, including class action lawsuits.' Company defending U.S. Tax Court petition on research credits.

Disclosed initiatives

Data Privacy and Cybersecurity Compliance Program

Company implements measures to comply with GDPR, state-level privacy laws (e.g., CCPA), and evolving cybersecurity standards; employee training and third-party vendor management.

Defensive governance; reactive to regulatory changes rather than proactive standard-setting.
AI Governance and Risk Mitigation

Company acknowledges AI integration across business; identifies risks including algorithm bias, intellectual property concerns, and confidentiality exposure; governance framework evolving.

Early-stage governance; no independent AI ethics board or third-party audit disclosed.
Information Technology System Upgrades and Cloud Migration

Significant investment in digital infrastructure, data science, and AI; increased reliance on third-party cloud providers (Microsoft, others).

Modernization supports operational efficiency but increases single-point-of-failure risk for third-party outages.

These are Missionomics' own editorial scores — directional signals built from disclosed facts under a published method, not certifications or definitive ratings of The Gap, Inc.. Coverage and confidence vary by data point, and figures can lag real-world changes. Read the full Methodology for sourcing, scoring, and correction details — or open The Gap, Inc. in the app for interactive charts and portfolio building.

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