Modern Slavery and Human Trafficking Policy

This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website
What personal information do we collect from the people that visit our blog, website or app?
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address, mailing address, phone number or other details to help you with your experience.
When do we collect information?
We collect information from you when you register on our site, subscribe to a newsletter, fill out a form or enter information on our site.
Provide us with feedback on our products or services
How do we use your information?
We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
• To improve our website in order to better serve you.
• To allow us to better service you in responding to your customer service requests.
• To administer a contest, promotion, survey or other site feature.
• To quickly process your transactions.
• To ask for ratings and reviews of services or products
• To follow up with them after correspondence (live chat, email or phone inquiries)

How do we protect your information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We do not use Malware Scanning.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
Do we use ‘cookies’?
We do not use cookies for tracking purposes You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, some features will be disabled. that make your site experience more efficient and may not function properly.
However, you will still be able to place orders.
Third-party disclosure
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information.
Third-party links
Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=e
We use Google Ad Sense Advertising on our website. Google, as a third-party vendor, uses cookies to serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.
We have implemented the following:
-Demographics and Interests Reporting
We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website
Opting out:
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.
You will be notified of any Privacy Policy changes:
-On our Privacy Policy Page
Can change your personal information:
-By logging in to your account
How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note that we do not allow third-party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
– Within 7 business days
We will notify the users via in-site notification
– Within 7 business days
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
– Send information, respond to inquiries, and/or other requests or questions
To be in accordance with CANSPAM, we agree to the following:
If at any time you would like to unsubscribe from receiving future emails, you can email us at
and we will promptly remove you from ALL correspondence.

Modern Slavery and Human Trafficking Policy

Effective Date: 01-01-2023

Approved by: Mr. Saad Mahmood, CEO and Resident Director, AEO Pakistan

Policy Statement:
AEO Pakistan is committed to conducting its operations with integrity and upholding the fundamental rights of all individuals. AEO Pakistan strictly prohibits all forms of slavery, human trafficking, forced labor, child labour and all forms of exploitation in line with the labour laws of Pakistan. We are dedicated to preventing such practices within our organization and in our extended network of suppliers and service providers.

Purpose
The purpose of this policy is to:

• Define AEO Pakistan’s stance against modern slavery.
• Establish a framework for identifying, mitigating, and responding to risks related to modern slavery and human trafficking.
• Ensure compliance with ethical standards, Pakistani labour laws and national/international anti-trafficking legislation

Scope
This policy applies to:

• All AEO Pakistan employees, interns, contractors, consultants, and third-party service providers.
• All departments, offices, and operational units across Pakistan.
• All entities and individuals engaged through our supply and service chains.

Our Commitments
AEO Pakistan commits to:

• Uphold ethical labor practices and reject any form of slavery, servitude, or forced labor.
• Ensure that no child labour or bonded labour is practiced or tolerated in any form.
• Conduct risk-based assessments of suppliers and partners.
• Engage only with recruitment and service providers who share our values.
• Provide training to staff to recognize and report red flags.
• Take prompt corrective action upon discovery of any non-compliance.

Supply Chain Transparency and Human Rights Commitment
AEO Pakistan is committed to upholding human rights across all aspects of its operations and supply chains. We ensure visibility through due diligence in vendor onboarding, incorporation of ethical and human rights clauses in contracts, regular monitoring of high-risk suppliers, and active communication with partners. We also assess the potential presence of low-skilled or migrant workers in our supply chain through declarations and risk-based reviews.

Responsibilities

• Senior Management is responsible for setting and reviewing anti-slavery strategies and ensuring resources are allocated for policy implementation.
• Management ensures that all responsibilities align with legal obligations under national/International applicable laws.
• Department Heads must promote compliance within their teams and report any suspected breaches.
• HR Department responsible for including anti-slavery criteria in recruitment and supplier evaluations.
• All Staff must remain alert to potential risks and report concerns promptly.

Due Diligence and Risk Management
AEO Pakistan is committed to upholding human rights across all aspects of its operations and supply chains. We ensure visibility through due diligence in vendor onboarding, incorporation of ethical and human rights clauses in contracts, regular monitoring of high-risk suppliers, and active communication with partners. We respond promptly to any reports of unethical or exploitative practices.

• Assess risks of modern slavery in key areas such as outsourced services and third-party recruitment.
• Monitor high-risk relationships through periodic checks or declarations.
• Verify National Identity Card (CNIC) documents during recruitment and maintain documentation in compliance with labour laws to ensure regular audits.

Reporting Mechanism
All staff and external parties are encouraged to report any suspicion of modern slavery through the following confidential channels:
Email: hr@aeo.com.pk

• Direct reporting to the Head Office.

Muhammad Shakeel
General Manager (Operations and Coordination)
shakeel@aeo.com.pk
0092 300 8541727
Reports will be treated with confidentiality and without retaliation. Reports can be submitted anonymously. If required or necessary, AEO may collaborate with relevant Pakistani Authorities.

Training and Awareness
Relevant staff, especially those in hiring, procurement, and student recruitment roles, will receive regular briefings or training on:

• Identifying signs of modern slavery.
• Understanding risk factors in operations and supply chains.
• Proper reporting procedures.

Non-Compliance and Enforcement

Violation of this policy by any employee may result in disciplinary action, including dismissal. Non-compliant suppliers or vendors may face contract termination or blacklisting. Any confirmed cases may be reported to relevant law enforcement authorities.

Policy Review
This policy will be reviewed annually and updated where necessary to reflect legislative changes, operational realities, or evolving ethical standards.

Signed:

_________________________
Muhammad Shakeel
General Manager (Operations and Coordination)
shakeel@aeo.com.pk

Contacting Us
If there are any questions regarding this privacy policy, you may contact us using the information below.
AEO PAKISTAN
ISLAMABAD
isb@aeo.com.pk