Code of Conduct for Vendors and Contractors

The following Code of Conduct establishes American Eagle’s policy of working with
only those vendors and contractors who share our commitment to ethical and
responsible business principles including protection for the rights of individuals,
promotion of equal opportunity and respect for the environment. This Code of
Conduct must be communicated to all workers and posted prominently in the
workplace in their language.
Child Labor
American Eagle vendors and contractors are prohibited from using child labor as defined
by local laws and regulations. Irrespective of local law, our vendors will not use workers
younger than the age of 15 or the compulsory age to be in school.
Forced or Involuntary Labor
American Eagle vendors are prohibited from using forced or involuntary labor, including
prisoners, bonded or indentured workers. We will not purchase or utilize products from
businesses utilizing forced or involuntary labor.
Disciplinary Actions and Harassment
Vendors and contractors must treat employees in a fair manner with dignity and respect.
Our vendors will not tolerate or use corporal punishment, threats of violence, or other
forms of physical, psychological, or sexual harassment or abuse.
Nondiscrimination
American Eagle respects cultural differences; however, our contractors and vendors are not
permitted to discriminate in hiring or employment practices on the basis of race, religion,
age, nationality, social or ethnic origin, sexual orientation, gender or political opinion.
Freedom of Association
Vendors and contractors must respect the rights of employees to associate freely, join
organizations of their choice and bargain collectively without unlawful interference.
Health and Safety
Contractors and vendors must provide workers with a safe and healthy work environment
that complies with all applicable laws and regulations. Employees must have access to
potable water and sanitary facilities, and all workplaces must have adequate fire safety,
lighting and ventilation facilities. Residential facilities, if provided to workers, must also
meet these requirements.
Environment
Contractors and vendors must comply with all applicable environmental laws and
regulations.
Inspection and Compliance
Contractors and vendors authorize American Eagle and its authorized agents to engage in
inspection activities to ensure compliance with this Code of Conduct. Such inspection
activities may be unannounced or without prior notice, and may consist of reviews of
applicable books and records as well as private interviews with workers. Contractors and
vendors must maintain on-site all documents and records required to confirm compliance
with this Code of Conduct. Inspections may take place at the workplace environment,
including the manufacturing facility, as well as employer provided housing and related
facilities.
Compensation
Contractors and vendors shall comply with all applicable compensation laws and
regulations including those relating to wages, overtime, hours, piece rates and benefits.
Overtime shall be paid at the rate not less than that required by local law. Except in
extraordinary circumstances, employees shall not be required to work more than 60 hours
per week, including overtime, and shall be entitled to at least one day off in every seven day
period.
Benefits
Contractors and vendors shall provide workers with all benefits required by law or
regulation including, if required, meals, transportation, health care, child care, and leave
for medical, family, or religious reasons. As required by law or regulation, contactors and
vendors shall make contributions towards workers social security and insurance programs.
Legal Requirements
Contractors and vendors must comply with all laws and regulations applicable to apparel
and related industries including local and national codes, treaties and industry standards
relating to employment, health, safety and the environment.
Contractors and vendors must also comply with applicable United States laws and
regulations relating to imported products including country of origin marking
requirements, labeling requirements, and product and fabric testing requirements