Gap (GPS)

NO IMPROPER INFLUENCE ON AUDITS

You are expected to cooperate fully with our internal and external auditors. You must not directly or indirectly take any action to coerce, manipulate, mislead or fraudulently influence any public accountant engaged in the performance of an audit or review of Gap Inc.’s financial statements.

Question:

A senior director mentioned in a meeting (inadvertently or intentionally) that Gap Inc. is expected to post a loss for the quarter. Can I share this news with my friends? Can I trade in Gap Inc. stock?

Answer:

No. The information you overheard is considered “material.” The senior director should not have shared this information with you unless you needed the information to do your job. 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.

Question:

One of our external auditors has asked me a question at a time when I am very busy. I am 80% sure of the answer but to be completely sure will take some additional research. 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. Can I just tell them what I think the answer is, or should I tell them what I think the answer is but let them know I am only 80% sure?

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. In other words, you should give thorough and complete answers to all questions.