GPS » Topics » Japanese Communities:

This excerpt taken from the GPS 10-K filed Mar 28, 2005.

Japanese Communities:

 

The Company does not encourage the acceptance of “Ochugen” (Summer Gift) or “Oseibo”(Winter Gift), and employees should not under any circumstance solicit for it. However, management respects and understands the Japanese tradition of giving these gifts as a courtesy gesture. Therefore, only on this occasion may employees accept a non-cash gift in the form of either “Ochugen” or “Oseibo” valued up to 10,000 yen (or equivalent).

 

4

   GAP INC. CODE OF BUSINESS CONDUCT (Updated Jan. 4, 2005)


Question: One of my vendors offered me a free trip to a golf event it is sponsoring. Can I accept the trip as long as it doesn’t affect my purchasing decisions?

 

Answer: No. Accepting a free trip from a vendor is a violation of Company policy.

 

Question: One of my vendors offered to send me to a conference at no cost to Gap Inc. Can I accept the invitation?

 

Answer: No. Accepting a free trip from a vendor is a violation of Company policy. If you are interested in attending the conference speak to your manager. Most costs associated with your attendance at the conference must be paid for by your department.

 

Question: A vendor sent me a U.S. $90 (or equivalent) gold pen as a gift. Can I keep it?

 

Answer: No. Accepting a gift valued at U.S. $50 (or equivalent) or more from a vendor is a violation of Company policy. You should either return the pen or give the vendor a personal check for the value. If you are unsure of the value, return it. In any event, you should advise the vendor about our policies regarding conflicts of interest.

 

Question: A vendor offered me two tickets to a professional sporting event that the vendor will not be able to attend. Can I accept them? The vendor did not pay for them.

 

Answer: Accepting a gift valued at U.S. $50 (or equivalent) or more from a vendor is a violation of Company policy. 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. In that case, you should either decline the tickets or give the vendor a personal check for the face value of the tickets.

 

Question: A vendor offered tickets to a concert to myself and a co-worker, each valued at U.S. $55 (or equivalent). We plan to meet the vendor’s team at the event. Can we accept them?

 

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