Code of Conduct

The Aeropostale Manufacturing Policies and Procedures (the “Policies and Procedures”) apply to all vendors and factories that manufacture products (each a “Manufacturer”) for Aeropostale, including its affiliates and subsidiaries. Aeropostale recognizes that the Policies and Procedures are not all inclusive, but Aeropostale will only do business with vendors and manufacturers that certify to us that their business practices are lawful, ethical and in compliance with the principles set forth in this Policies and Procedures. Furthermore, Aeropostale will only do business with vendors and manufactures that obey the laws of the country in which they operate and the principles expressed in this Policies and Procedures. Moreover, these Policies and Procedures will serve as the basis of Aeropostale’s inspection and evaluation of vendors and manufacturers.

1. Manufacturer’s Code of Conduct.

(a) Manufacturer will not use forced labor, prison labor, indentured labor or exploited bonded labor, or permit their suppliers to do so.

(b) Manufacture will not use child labor in the manufacturing of any products, including their components. Child labor means any person younger than 15 years of age or younger than the age of completing compulsory education in the country of manufacture where such age is higher than 15.

(c) Manufacturer will treat its employees with respect and dignity. No employee shall be subject to physical, sexual or psychological harassment or abuse.

(d) Manufacturer will not discriminate against any person in employment, including hiring, salary, benefits, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin.

(e) Manufacturer will provide a safe and healthy working environment for its employees to prevent accidents and injury to health arising out of, linked with, or occurring in the course of work or as a result of the operation of employer facilities. Manufacturer will fully comply with all applicable workplace conditions, safety and environmental laws.

(f) Manufacturer will recognize and respect the right of employees to freely associate in accordance with the laws of the countries in which they are employed.

(g) Manufacturer will pay its employees at least the minimum wage required by local law regardless of whether they pay by the piece or by the hour and shall provide legally mandated benefits.

(h) Manufacturer will not require their employees to work more than the limits on regular and overtime hours allowed by the law of the country of manufacture. Employees shall be entitled to one day off in every seven day period. Manufacturer will inform their employees at the time of their hiring if mandatory overtime is a condition of their employment. Manufacturer will not compel their workers to work excessive overtime hours.

(i) Manufacturer will compensate its employees for overtime hours at such premium rate as is legally required in the country of manufacture or, in countries where such laws do not exist, at a rate at least equal to their regular hourly compensation rate.

(j) Manufacturer will not use workers obligated under contracts which exploit them, which deny them the basic legal rights available to people and to workers within the countries in which they work or which are inconsistent with the principles set forth in these Policies and Procedures.