Seller Verification & Credentialing Policy

AQNOVA MARKETPLACE

Global Legal Footer Framework

Comprehensive Compliance & Platform Governance Reference

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Global Vendor Identity Verification, Business Credentialing, Sustainability Certification Review & Ongoing Compliance Monitoring Framework

Effective Date: April 7, 2026 | Version 1.0 | Arivon Holding Corporation

AqNova's Seller Verification & Credentialing Policy establishes the comprehensive framework governing identity verification, business registration authentication, bank account validation, sustainability credentialing review, and ongoing compliance monitoring for all Vendors seeking to list and sell products on the AqNova Marketplace. This Policy applies to all Vendor applicants globally, from initial application through the full lifecycle of their Platform relationship.

AqNova operates as a curated marketplace for sustainable and eco-friendly products. The integrity of the Platform depends critically on AqNova knowing who its Vendors are — their legal identity, their business credentials, and the authenticity of the sustainability claims they make. This Policy is AqNova's primary tool for ensuring that every Vendor on the Platform meets the identity, compliance, and sustainability standards that make AqNova a trusted marketplace.

5.5.1 Why Vendor Verification Matters — AqNova's Verification Philosophy

Vendor verification is not a bureaucratic formality — it is the foundation of the trust that makes a curated marketplace function. When a Buyer purchases a certified organic food product on AqNova, they need to know that the Vendor behind that listing is a real, identifiable business with genuine certifications and accountability for what they sell. Without rigorous verification, AqNova is just another anonymous marketplace where fraudulent actors can exploit consumer trust.

5.5.2 Vendor Onboarding — Identity Verification (KYC)

All Vendor applicants must complete identity verification (KYC — Know Your Customer) as a condition of activating their account and listing products. KYC is conducted through AqNova's integrated identity verification provider (Jumio, Onfido, Persona, or equivalent, depending on region), which uses automated document verification, biometric liveness checks, and database cross-referencing.

A. KYC Requirements by Vendor Type

B. KYC Technology — Automated Verification

AqNova's KYC provider performs the following automated checks on submitted identity documents:

Document authenticity verification: machine-readable zone (MRZ) reading; security feature validation (holograms, watermarks, microprint); forgery detection; expired document rejection.

Biometric liveness detection: AI-powered analysis of the selfie or short video to confirm: (a) the person is physically present (anti-spoofing); (b) the face matches the document photo; (c) the session was not pre-recorded or manipulated.

Database cross-referencing: name and document number matched against: (a) global sanctions lists (OFAC, UN, EU, OFSI); (b) Politically Exposed Person (PEP) databases; (c) adverse media databases; (d) fraud risk indicators.

Address verification: utility bill or bank statement OCR-parsed and cross-referenced against address databases.

C. KYC Assurance Levels

AqNova uses a tiered KYC assurance framework based on ISO/IEC 29115:

Level 1 (Basic) — email verification and basic identity details: available only for Browse/Wishlist access. Not sufficient for listing activation or payout.

Level 2 (Standard) — document verification + liveness check: required for all Vendors to activate listings and receive payouts.

Level 3 (Enhanced) — Level 2 plus in-person verification or advanced biometric confirmation: required for Vendors in high-risk categories (see Section 5.5.8) or Vendors triggering enhanced due diligence (EDD) during AML screening.

5.5.3 Business Registration Verification

For Vendors operating as registered business entities, AqNova verifies the existence and current active status of the business through official registration documents and, where available, direct database cross-referencing with official business registries.

A. Required Business Registration Documents

Certificate of Incorporation or equivalent (for companies): government-issued certificate confirming the business's legal name, registration number, and jurisdiction of incorporation.

Business registration number / tax registration number: the unique identifier assigned by the jurisdiction's companies registry or tax authority.

Memorandum and Articles of Association (or equivalent constitutional document): for companies, to verify the business's authorized activities include the category of goods being sold on AqNova.

Proof of current trading status: where available, confirmation from the official registry that the business is in good standing, not dissolved or struck off (e.g., Companies House confirmation statement in the UK; Secretary of State good standing certificate in the US; printout from official e-registry where available).

Director/Authorized Signatory list: current list of directors or authorized signatories, confirming the individual who has completed KYC is authorized to bind the business.

Trading Name / DBA registration (if applicable): where the Vendor trades under a name different from their registered legal name, the applicable Doing Business As (DBA) registration or trademark registration is required.

B. Global Business Registry Verification

Where official business registries are accessible online and permit automated or manual cross-referencing, AqNova's onboarding team verifies the submitted documents against the official registry. The following table sets out primary business registry references:

C. Sole Trader Business Verification

Sole traders (self-employed individuals operating under their own name or a trading name without a registered company) are verified through enhanced individual KYC (Section 5.5.2) plus:

Self-employment or business registration confirmation: applicable registration documents (e.g., UK self-employment HMRC registration; US Schedule C/DBA filing; Indian GST registration for individual traders; South African sole proprietor registration with CIPC where applicable).

Proof of business activity: recent business bank statements (last 3 months), tax returns referencing business income, or equivalent documentation demonstrating active trading activity.

5.5.4 Bank Account Validation

All Vendor payout accounts must be validated before any payout is processed. Bank account validation prevents payment diversion fraud, money mule activity, and unauthorized access to Vendor payouts. The following validation steps are applied:

A. Validation Steps

Account ownership verification: the payout account must be held in the name of the Vendor entity (or its sole trader/director/authorized signatory) as verified through KYC. Third-party bank accounts are not accepted as payout accounts without explicit documented authorization.

Micro-deposit verification: for bank transfer payouts (ACH/SEPA/SWIFT), AqNova initiates a micro-deposit test (two small deposits, typically USD $0.01–$0.99 or equivalent) to the provided account. The Vendor confirms the deposit amounts in the Vendor Dashboard within 72 hours, confirming they have access to the account. This micro-deposit is then reversed or credited to the Vendor's payout balance.

IBAN/routing number validation: bank account routing details (IBAN, SWIFT/BIC, ABA routing number, sort code, BSB, etc.) are validated against applicable banking databases for format correctness and bank identity.

AML account screening: the payout bank account details are screened against known fraud and money-laundering indicators, including: high-risk bank or financial institution lists; newly opened accounts (account age below 30 days flagged for enhanced review); account numbers associated with prior fraud incidents in AqNova's fraud intelligence network.

Re-validation on change: whenever a Vendor changes their payout bank account details, the new account undergoes full re-validation. The old account receives a payout hold notification and the Vendor receives an email security alert about the account change. A 48-hour cooling-off period applies before payouts are directed to a newly registered account.

B. Mobile Money Account Validation (Africa)

For Vendors using mobile money platforms (M-Pesa, MTN MoMo, Airtel Money, etc.) as payout accounts:

The mobile money account is validated through the applicable network's API to confirm: account exists, is active, and is registered in the name of the verified Vendor individual/entity.

Test transaction: a micro-transaction (equivalent to USD $0.01) may be initiated to confirm account receipt capability.

SIM registration verification: where the mobile money network permits, SIM registration data is cross-referenced against the Vendor's verified identity.

5.5.5 Tax Compliance Verification

AqNova collects and verifies tax identification information from all Vendors to enable its obligations as a marketplace facilitator (tax collection and reporting), as an electronic commerce operator (TCS deduction in India), and as a payer (1099-K reporting in the US). The following tax verification requirements apply:

5.5.6 Sustainability Credentialing Review — Three-Tier Framework

AqNova's sustainability credentialing review is the most distinctive element of the Vendor verification process and reflects the Platform's core value proposition as a curated sustainable marketplace. Every sustainability claim made in a product listing — from organic certification to B Corp status to Fair Trade approval — is subject to credentialing review before it can be displayed on the Platform. This is not a standard practice on generalist marketplaces; it is AqNova's competitive differentiator and the foundation of Buyer trust.

A. Tier 1 — Third-Party Certified Claims (Highest Standard)

Tier 1 certifications are claims backed by an accredited, independent certifying body that has conducted a rigorous assessment of the product's sustainability attributes against a defined standard. These are the highest-value sustainability claims and are displayed with AqNova's "Verified Certification" badge.

Verification process: AqNova cross-references the Vendor's claimed certification against the certifying body's publicly accessible certificate registry. Where the registry is not publicly accessible, AqNova contacts the certifying body directly to verify the certificate's validity, scope, and expiry date.

Certificate currency: the certification must be current at the time of listing and must remain current throughout the listing period. AqNova monitors certificate expiry dates and notifies Vendors 90 days before expiry to renew.

Certificate scope: the certification must cover the specific product being listed (not just the Vendor's general business operations). AqNova verifies that the product's SKU or category is within the scope of the certificate.

B. Tier 2 — Substantiated Brand Claims (Verified Documentation)

Tier 2 claims are sustainability assertions made by the Vendor based on their own testing, life cycle assessments, supply chain audits, or internal environmental programs — without third-party certification. These claims are not displayed with the "Verified Certification" badge but may be displayed with a "Vendor Declared" label where AqNova has reviewed the supporting documentation.

Verification process: AqNova requires the Vendor to submit supporting documentation for Tier 2 claims at onboarding. Documentation may include: product test reports from accredited laboratories; life cycle assessment (LCA) reports by qualified LCA practitioners; supply chain audit reports; internal environmental management records; manufacturer declarations or certificates of analysis.

Documentation review: AqNova's sustainability review team assesses the documentation for: (a) relevance to the specific claim; (b) credibility of the testing/assessment source; (c) currency (dated within the last 24 months for most claims; 12 months for chemical/material composition claims).

Ongoing spot-checks: AqNova may conduct random post-listing documentation spot-checks to verify that Tier 2 claims continue to be substantiated. Vendors who cannot produce documentation on a spot-check request within 10 Business Days face listing suspension pending review.

C. Tier 3 — Aspirational / Directional Claims (Minimum Standard)

Tier 3 claims are general environmental or social aspiration statements that do not assert a specific, measurable, verifiable standard. Examples: "eco-friendly packaging," "sustainable practices," "crafted with care for the environment."

No pre-listing verification required: AqNova does not require documentation for Tier 3 claims before listing.

Post-listing monitoring: AqNova's automated listing monitoring system flags Tier 3 claims that appear potentially misleading given the product's other attributes.

Honesty requirement: Tier 3 claims must be truthful and not create a misleading impression of environmental benefit. A listing that uses Tier 3 language to imply certification-level credentials without holding such certification is treated as greenwashing and subject to enforcement under the Trust & Safety framework (Section 5.0, Section 5.6).

5.5.7 Product Category-Specific Verification Requirements

Beyond standard KYC, business registration, and sustainability credentialing, certain product categories require additional verification documentation specific to the regulatory requirements for those products. Vendors listing in the following categories must provide the applicable documentation before listing activation:

5.5.8 Verification for High-Risk Vendor Categories

Certain Vendor characteristics or business types are designated as high-risk and subject to Enhanced Due Diligence (EDD) during the verification process. EDD involves additional scrutiny, documentation requirements, and a longer review period.

A. High-Risk Vendor Designation Criteria

Vendors established in high-risk or non-cooperative jurisdictions as identified by the FATF (Financial Action Task Force) grey list or black list, including currently: Myanmar, Democratic Republic of Congo, Russia, Iran, North Korea (all applications from sanctioned jurisdictions are rejected).

Vendors whose beneficial ownership includes Politically Exposed Persons (PEPs) — current or former senior government officials, state-owned enterprise executives, or their immediate family members or close associates.

Vendors in product categories with elevated fraud or diversion risk: precious metals and gems; pharmaceutical-adjacent health products; high-value electronics; and international luxury goods.

Vendors applying to sell regulated food products (supplements, health foods, specialty foods) in markets with strict pre-market approval requirements (US, EU, India, Nigeria, Brazil, Australia).

Vendors with prior adverse regulatory or enforcement history, as identified through AML database checks or industry intelligence.

Vendors requesting payout methods that present elevated financial crime risk (certain cryptocurrency arrangements; wire transfers to high-risk financial institutions).

B. EDD Process

Enhanced Due Diligence for high-risk Vendors includes:

Senior review: EDD applications are reviewed by a senior member of AqNova's compliance team, not a standard onboarding analyst.

Source of goods documentation: Vendors must demonstrate the legitimate provenance of their products through supply chain documentation (supplier invoices; import records; COA; traceability documentation).

Enhanced business background screening: negative news search; regulatory history check; civil litigation check; industry body membership verification.

PEP management: Vendor accounts with PEP beneficial owners are approved only at senior compliance officer level, with enhanced monitoring applied throughout the relationship.

Longer review timeline: EDD applications receive a 10–20 Business Day review timeline (vs. 3–5 Business Days for standard applications).

5.5.9 International Vendor Verification — Jurisdiction-Specific Requirements

The following table maps jurisdiction-specific primary identity documents and business registration requirements for Vendors in each of AqNova's principal operating markets:

5.5.10 INFORM Consumers Act Compliance — US Federal (Effective June 27, 2023)

The INFORM Consumers Act (Integrity, Notification, and Fairness in Online Retail Marketplaces for Consumers Act), signed into law as part of the Consolidated Appropriations Act 2023, imposes specific seller identity verification and disclosure obligations on "high-volume third-party sellers" on online marketplaces. AqNova complies with the INFORM Consumers Act as follows:

A. INFORM Act Definitions — Applicable to AqNova

High-Volume Third-Party Seller: Any third-party seller who has made 200 or more discrete sales of new or unused consumer products on the marketplace in any 12-month period with an aggregate total value of USD $5,000 or more within the same 12-month period.

Online Marketplace: A consumer-directed, electronically-based place or system through which third-party sellers may engage in the sale, purchase, payment, storage, shipment, or delivery of a consumer product — applicable to AqNova.

B. AqNova's INFORM Act Compliance Program

Identity verification of high-volume sellers: AqNova collects and verifies the following information from all high-volume third-party sellers, or from all Vendors at onboarding (since AqNova cannot predict which Vendors will become high-volume): (a) bank account number or, if the Vendor does not have a bank account, payment processor account details; (b) contact telephone number; (c) email address; (d) a copy of a government-issued identification or, for an entity, a copy of the entity's tax identification document; (e) business address.

Annual certification: high-volume sellers must annually certify that the collected information remains accurate and complete.

Supply chain disclosure: upon reasonable request, AqNova may require high-volume sellers to provide information about the supply chain for their products to enable AqNova to comply with the Act.

Disclosure to consumers: for high-volume sellers, AqNova displays the seller's business address (name and country for business entities; name, country, and registration number for legal entities). AqNova also provides a mechanism for Buyers to report suspected anonymized or fictitious seller information.

Suspension for non-compliance: AqNova suspends high-volume sellers who fail to verify their information within 10 days of request and terminates accounts that fail to verify within 10 days after the initial suspension.

FTC enforcement: the FTC enforces the INFORM Act through the Federal Trade Commission Act. Violations are treated as unfair or deceptive acts. AqNova's compliance program is reviewed by legal counsel for INFORM Act requirements.

5.5.11 EU DSA Article 30 — Traceability of Traders

EU Digital Services Act Article 30 requires online platforms that allow consumers to conclude contracts with traders to obtain, store, and verify certain information about traders before allowing them to offer products or services. AqNova's compliance with DSA Article 30 is one of the most significant regulatory obligations shaping this Seller Verification & Credentialing Policy.

A. DSA Article 30 — Required Information

AqNova collects and verifies the following information from Vendors before allowing them to list products accessible to EU/EEA users:

Name: the full legal name of the individual Vendor or company, confirmed through identity verification.

Address: the registered address or principal place of business of the Vendor.

Contact details: telephone number and email address.

Bank account details: the details of the payment account to which the Vendor's earnings are remitted, verified through AqNova's bank account validation process (Section 5.5.4).

Identification number: National identification number (for individual traders) or Trade and Company Register number (for business entities), as applicable to the Vendor's country of establishment.

Self-certification: a self-certification by the Vendor that they only offer products or services that comply with applicable EU law.

B. DSA Article 30 — "Best Efforts" Verification

AqNova assesses whether the information collected is reliable and makes best efforts to verify it through: the identity verification process (Section 5.5.2); business registry cross-referencing (Section 5.5.3); and bank account validation (Section 5.5.4). Where verification reveals that the information is incorrect, inaccurate, incomplete, or outdated, AqNova requests corrected information and suspends the Vendor's listings pending the update.

C. DSA Article 30 — Consumer Disclosure

AqNova makes the verified trader information accessible to consumers:

The Vendor's name, country of establishment, and registered business address are displayed on the Vendor's profile page.

The product listing page displays the Vendor's name and country.

Full contact details (including email and phone number for business inquiries) are available to Buyers who have made a purchase from the Vendor (accessible through My Orders > Vendor Contact).

AqNova does not display individual traders' home addresses on public-facing pages — only business addresses. Individual traders may use a registered agent or business address for this disclosure.

5.5.12 Ongoing Compliance Monitoring & Re-Verification

Seller verification is not a one-time event at onboarding. AqNova monitors Vendor compliance throughout the relationship and re-verifies where defined triggers occur. The ongoing monitoring framework includes:

A. Continuous Automated Monitoring

Sanctions screening: all Vendors and their beneficial owners are re-screened against applicable sanctions lists on a daily automated basis. Any potential match is escalated immediately for manual review and payout hold if required.

PEP status monitoring: Vendors with identified PEP beneficial owners are monitored for changes in PEP status (e.g., new political appointment) through automated PEP database updates.

Adverse media monitoring: AqNova's compliance system performs automated adverse media monitoring for Vendor entity names against news databases on a weekly basis for high-risk Vendors.

Business status monitoring: where official business registries provide real-time APIs (Companies House UK; ACRA Singapore; SAMR China), AqNova monitors for business dissolution, strike-off, or insolvency filings.

Certification expiry monitoring: AqNova's sustainability credentialing system tracks certification expiry dates for all Tier 1 certifications and sends renewal reminders 90, 60, and 30 days before expiry.

B. Triggered Re-Verification Events

C. Annual Vendor Compliance Self-Certification

All Vendors are required to complete an annual compliance self-certification through the Vendor Dashboard. The annual certification requires the Vendor to confirm: (a) that their identity and business registration information remains accurate; (b) that their bank account details are current; (c) that their product listings continue to comply with Platform policies; (d) that their sustainability certifications (where applicable) are current; and (e) that they have not been subject to any adverse regulatory action in the preceding year. Vendors who fail to complete the annual certification within 30 days of the anniversary of their account activation date will have their listings suspended pending certification.

A. Verification Failure Outcomes

B. Verification Appeal Process

Vendors who wish to appeal a verification decision (rejection or suspension based on verification failure) may submit an appeal to compliance@aqnova.co [Subject: Verification Appeal — [Account Name]] within 30 calendar days of the decision notification. The appeal must include: (a) a statement of the grounds for appeal; (b) any additional documents or evidence not previously submitted; and (c) any explanation of discrepancies identified in the verification process. Appeals are reviewed by a senior compliance team member not involved in the original decision. Appeal decisions are issued within 10 Business Days.

5.5.14 Data Protection & Privacy in the Verification Process

The identity and business documentation collected during the verification process contains highly sensitive personal and financial data. AqNova processes this data under the following framework:

Legal basis for processing: KYC data is processed on the legal bases of: (a) legal obligation (AML/KYC law compliance, INFORM Act compliance, DSA Art. 30); (b) contractual necessity (processing necessary to perform the Vendor Agreement); and (c) legitimate interests (fraud prevention; platform integrity).

Data minimization: AqNova collects only the information necessary to meet its verification obligations. Excessive document collection beyond the required verification scope is prohibited.

Retention: KYC and business verification documents are retained for: (a) 5 years from the end of the Vendor relationship (AML record-keeping requirements under BSA/FinCEN, EU 6AMLD, UK MLR 2017, and equivalent national laws); OR (b) the period required by applicable national law where it is longer.

Third-party verification providers: AqNova's KYC providers (Jumio, Onfido, Persona) act as data processors under GDPR Article 28 (and equivalent) data processing agreements. They process personal data only for the purposes of identity verification and are prohibited from using the data for any other purpose.

No sharing for marketing: KYC data is not shared with Vendors' competitors, used for marketing profiling, or disclosed to third parties for commercial purposes.

Data subject rights: Vendor individuals whose personal data is processed in the KYC process have the data subject rights described in the Privacy Policy (Section 3.1) and applicable regional addendums (Section 3.8).

5.5.15 Contact Information — Vendor Verification

AqNova Marketplace | Global Legal Footer Framework | Section 5.5: Seller Verification & Credentialing Policy

© 2026 Arivon Holding Corporation. All rights reserved. Effective April 7, 2026. Version 1.0.