Gap Inc/The – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Gap Inc. has established a defined governance framework for its political and regulatory engagement, centered on its Government Affairs department and senior leadership, yet it does not disclose a dedicated review process for ensuring climate-specific lobbying alignment. Under the “GAP INC. POLITICAL ENGAGEMENT POLICY,” the company notes that “All corporate political contributions are reviewed and approved in advance by both the (i) Vice President of Government Affairs and (ii) the Chief Supply Chain, Strategy, and Transformation Officer (who oversees our environmental sustainability and climate efforts),” and that “Our corporate contributions are reviewed annually by the Board,” which “receives periodic updates regarding our political activities.” The company further affirms “Yes” to conducting its engagement activities “in line with the goals of the Paris Agreement” and highlights that it “partners on advocacy for climate policy in key sourcing markets,” exemplified by signing “a call to the government of Vietnam to simplify and expand access to renewable energy.” While these elements demonstrate clear sign-off procedures and named accountability, Gap Inc. does not disclose any specific mechanism—such as a climate-lobbying audit, trade-association review, or management process—to monitor and align its direct and indirect lobbying activities with its climate commitments. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Gap Inc. has established a defined governance framework for its political and regulatory engagement, centered on its Government Affairs department and senior leadership, yet it does not disclose a dedicated review process for ensuring climate-specific lobbying alignment. Under the “GAP INC. POLITICAL ENGAGEMENT POLICY,” the company notes that “All corporate political contributions are reviewed and approved in advance by both the (i) Vice President of Government Affairs and (ii) the Chief Supply Chain, Strategy, and Transformation Officer (who oversees our environmental sustainability and climate efforts),” and that “Our corporate contributions are reviewed annually by the Board,” which “receives periodic updates regarding our political activities.” The company further affirms “Yes” to conducting its engagement activities “in line with the goals of the Paris Agreement” and highlights that it “partners on advocacy for climate policy in key sourcing markets,” exemplified by signing “a call to the government of Vietnam to simplify and expand access to renewable energy.” While these elements demonstrate clear sign-off procedures and named accountability, Gap Inc. does not disclose any specific mechanism—such as a climate-lobbying audit, trade-association review, or management process—to monitor and align its direct and indirect lobbying activities with its climate commitments.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Moderate	Gap Inc. provides a moderate level of transparency around its climate-policy advocacy. It explicitly identifies two pieces of California legislation it engaged on – the “Climate Corporate Data Accountability Act (SB 253 Wiener)” and the “Climate-Related Financial Risk Disclosure Act (SB 261 Stern)” – and also references a public call for the government of Vietnam to “simplify and expand access to renewable energy,” demonstrating that it names identifiable policies and jurisdictions. The company describes several avenues of engagement, including working with the non-profit Ceres where it “served as educators about the developing bills through webinars and convened impacted companies,” and signing collective letters to national governments; these disclosures reveal both the methods used (webinars, convenings, sign-on letters) and the policymaking targets (California legislators, the Government of Vietnam). However, while Gap Inc. states that it is “aligned with the Paris Agreement” and wishes to encourage policymakers to “raise their ambition,” it does not spell out concrete policy changes, measurable targets, or specific legislative outcomes it is pursuing, leaving the precise objectives of its lobbying largely undefined. This combination of clear policy identification and mechanism detail, offset by vague desired outcomes, places the company in the mid-range of disclosure completeness.	C