Vendor Code of Conduct
AqNova Marketplace Policies & Disclosures
AQNOVA MARKETPLACE
AqNova Global Seller Center
VENDOR CODE OF CONDUCT
Ethical Operating Standards · Misrepresentation Prohibition · Greenwashing Enforcement
Supply Chain Integrity · Labour & Human Rights · Environmental Compliance · Business Integrity
Effective Date: April 7, 2026 | Version 1.0 | Must Be Signed at Onboarding
aqnova.co/selling-on-aqnova/code-of-conduct | Operated by Arivon Holding Corporation
| IMPORTANT LEGAL NOTICE THIS VENDOR CODE OF CONDUCT ('THE CODE') IS A LEGALLY BINDING DOCUMENT. COMPLETION OF THE AQNOVA VENDOR ONBOARDING PROCESS — INCLUDING CLICKING 'I ACCEPT' OR SIGNING THE ONBOARDING DECLARATION — CONSTITUTES YOUR AGREEMENT TO COMPLY WITH EVERY PROVISION OF THIS CODE. MATERIAL VIOLATIONS MAY RESULT IN IMMEDIATE LISTING SUSPENSION, ACCOUNT TERMINATION, PAYOUT FORFEITURE, REFERRAL TO REGULATORY AUTHORITIES, AND LEGAL PROCEEDINGS WHERE APPLICABLE. THIS CODE SUPPLEMENTS — AND MUST BE READ ALONGSIDE — YOUR SELLER AGREEMENT (SECTION 1.3) AND THE PLATFORM TERMS & CONDITIONS (SECTION 1.1). IN THE EVENT OF CONFLICT BETWEEN THIS CODE AND THE SELLER AGREEMENT ON CODE-SPECIFIC MATTERS, THIS CODE GOVERNS. |
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This Section 10.9 — Vendor Code of Conduct ('the Code' or 'this Code') establishes the minimum ethical, environmental, commercial integrity, and legal compliance standards that every AqNova Vendor must meet as a condition of selling on the AqNova Marketplace. The Code applies from the date of your onboarding acceptance and continues in force throughout the duration of your commercial relationship with Arivon Holding Corporation.
AqNova exists to connect the world's conscious consumers with genuinely sustainable, organic, ethically sourced, and purposefully made products. Every Vendor on AqNova represents an extension of that mission. Your conduct — in how you produce, source, describe, pack, ship, and stand behind your products — either reinforces that mission or undermines it. This Code is how AqNova ensures the former.
The Code is calibrated against internationally recognized standards including the ILO Core Conventions, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, the Ethical Trading Initiative (ETI) Base Code, the Responsible Business Alliance (RBA) Code v8.0, and applicable anti-greenwashing law across all AqNova operating jurisdictions.
| Section 10.9 — Contents 10.9.1 Scope, Applicability & Binding Effect 10.9.2 Ethical Operating Standards 10.9.3 Misrepresentation Prohibition — Product, Claims & Identity 10.9.4 Greenwashing Enforcement — What It Is, What Is Prohibited & Consequences 10.9.5 Labour & Human Rights — Vendor Workplace Obligations 10.9.6 Health, Safety & Worker Wellbeing 10.9.7 Environmental Standards — Production, Sourcing & Packaging 10.9.8 Supply Chain Integrity & Due Diligence 10.9.9 Business Integrity & Anti-Corruption 10.9.10 Data Protection & Information Security 10.9.11 Product Safety & Regulatory Compliance 10.9.12 Intellectual Property — Use & Protection 10.9.13 Legal Compliance — Global Regulatory Obligations 10.9.14 Grievance Mechanisms — Worker Voice & Reporting 10.9.15 Monitoring, Audit & Enforcement Framework 10.9.16 Anti-Greenwashing Law — Global Legal Reference 10.9.17 Annual Compliance Self-Assessment 10.9.18 Onboarding Acceptance & Binding Signature 10.9.19 Contact — Code of Conduct & Compliance |
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10.9.1 Scope, Applicability & Binding Effect
This Code applies to all individuals and business entities registered as Vendors on AqNova Marketplace — including sole traders, partnerships, limited liability companies, corporations, cooperatives, artisan collectives, and any other form of legal entity. It applies regardless of:
The Vendor's country of domicile, country of incorporation, or country of operation.
The Vendor's size — from a solo artisan selling handmade products to a multi-national enterprise operating across multiple jurisdictions.
The product category — all product categories listed on AqNova are subject to this Code.
The volume of sales or the duration of the commercial relationship — the Code applies from the first product listing.
The Code applies to the Vendor's own operations — including the people they employ, engage, or contract to make or fulfill their products — and, where specified, to their supply chains. Vendors are responsible for ensuring that their key suppliers and sub-contractors are aware of this Code's requirements and operate in a manner consistent with it.
| Three Categories of Vendor Obligation in This Code ABSOLUTE OBLIGATIONS: These apply to all Vendors in all circumstances. They cannot be modified by size, market, or operational context. Violations of absolute obligations trigger immediate enforcement action. Examples: no child labour; no forced labour; no counterfeit goods; no greenwashing. SCALED OBLIGATIONS: These apply to all Vendors but are calibrated to the Vendor's size, sector, and operational risk. A Tier 1 artisan producer is not expected to meet the same supply chain audit depth as a Tier 3 enterprise vendor. Examples: environmental management systems; supply chain mapping; GHG disclosure. ENCOURAGED PRACTICES: These are not currently mandatory but represent AqNova's direction of travel and may become mandatory in future Code revisions. Examples: living wage payment; Science Based Targets; 100% renewable energy. Vendors who meet encouraged practices receive recognition in AqNova's Sustainability Impact Programme. |
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10.9.2 Ethical Operating Standards
AqNova's Vendor community is defined by the shared commitment to purpose-driven commerce. The following ethical operating standards apply to every Vendor's conduct on the Platform and in the operation of their business. These standards are the foundation on which every other section of this Code rests.
A. Honesty & Accuracy — The Foundational Standard
Every statement a Vendor makes — in a product listing, in a marketing communication, in a certification submission, in a dispute response, in a support ticket, in a review — must be accurate, honest, and not designed to mislead. This is not simply a regulatory requirement: it is the first principle of ethical commercial conduct.
Product descriptions must accurately represent what the buyer will receive, including: materials, ingredients, dimensions, weight, origin, certifications, processing methods, and sustainability attributes.
Vendor storefronts and About sections must accurately represent the Vendor's business, its size, its production practices, and its sustainability credentials.
Vendor communications with buyers — including pre-sale messages, post-sale communications, and dispute responses — must be honest and professionally conducted.
Any statement of fact that turns out to be materially inaccurate — even if originally made in good faith — must be corrected promptly when the inaccuracy comes to the Vendor's attention.
B. Fair & Respectful Conduct
Vendors must treat all buyers, fellow Vendors, AqNova staff, and third parties with professional respect and courtesy.
Vendors must not engage in aggressive, intimidating, or harassing communications with any buyer, regardless of the nature of a dispute.
Vendors must not make false, defamatory, or misleading statements about other Vendors, their products, or their businesses.
Vendors must not attempt to manipulate buyer reviews — including incentivizing positive reviews, requesting review removal, or submitting fake reviews.
Vendors must not use AqNova's platform to engage in predatory, deceptive, or manipulative pricing practices — including artificial price inflation and deflation, bait-and-switch pricing, and false 'was/now' promotions.
C. Platform Integrity
Vendors must use the AqNova Platform only for its intended purpose — the legitimate sale of sustainable, organic, and ethically sourced products to conscious consumers.
Vendors must not create multiple accounts to circumvent performance monitoring, account restrictions, or platform bans.
Vendors must not attempt to use AqNova's systems — including the search algorithm, review system, or promotional tools — in ways that are manipulative or inconsistent with the Platform's community purpose.
Vendors must not facilitate or participate in coordinated inauthentic behavior on the Platform, including review manipulation rings, listing keyword abuse, or artificial traffic generation.
Vendors must promptly comply with all reasonable requests from AqNova's compliance, trust, and support teams within the timeframes specified by those teams.
D. Duty to Update
The Vendor's duty of accuracy is ongoing — not only at the point of listing creation. Vendors must update their listings, certifications, and account information promptly whenever a material change occurs that affects the accuracy of information displayed on the Platform:
Change in product formulation, materials, or ingredients that affects any claim on the listing (including sustainability, organic, or allergen claims).
Change in supplier or supply chain that may affect a certified claim (e.g., change to a supplier not covered by a GOTS certification).
Change in certifications — whether renewal, expiry, suspension, or withdrawal of any certification displayed on the Platform.
Change in business entity, name, registration, or operational status.
Any product safety incident, regulatory enforcement action, or recall affecting a listed product.
10.9.3 Misrepresentation Prohibition — Product, Claims & Identity
Misrepresentation — making or implying a statement about a product, business, or certification that is false or misleading — is one of the most serious violations of this Code. It harms buyers, undermines AqNova's trust architecture, exposes AqNova and the Vendor to regulatory enforcement, and violates consumer protection law in every jurisdiction where AqNova operates.
A. Product Misrepresentation — Prohibited
| PRODUCT MISREPRESENTATION — ZERO TOLERANCE The following product misrepresentations result in IMMEDIATE listing removal. Repeated or systematic misrepresentation results in ACCOUNT TERMINATION. |
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| Type of Misrepresentation | Examples | Consequence |
|---|---|---|
| False material composition | Listing as '100% organic cotton' when the product contains synthetic blends; listing as 'solid teak' when the product is engineered wood with teak veneer; listing as 'pure essential oil' when the product is diluted. | Immediate listing suspension. Evidence request. Account warning. Repeat: termination. |
| False country of origin | Listing as 'Made in Italy' when the product is manufactured in a different country; falsely claiming 'Handmade in Kenya' for factory-produced goods; misrepresenting origin to benefit from origin-based consumer perception. | Immediate listing suspension. Customs authority referral where applicable. Account warning. Repeat: termination. |
| False certification claim | Claiming USDA Organic, GOTS, Fair Trade, Leaping Bunny, or any other certification without holding a current, valid certificate from the issuing body covering the specific product. Uploading fabricated or altered certificates. | Immediate account suspension. Permanent greenwashing enforcement log entry. Referral to certifying body and applicable regulatory authority. |
| False handmade or artisan claim | Describing factory-produced goods as 'handmade,' 'hand-poured,' 'artisan-crafted,' or equivalent without genuine hand-production involvement. | Listing suspension. Account warning. Listing description must be corrected before reinstatement. |
| Counterfeit or inauthentic goods | Selling goods that infringe a registered trademark, brand name, or design right — including products that replicate the appearance of a branded product without authorization. | Immediate account termination. No appeal. Legal referral. Payout forfeiture. |
| False weight, size, or quantity | Listing a product as '500g' when the product dispatched is materially less (outside industry tolerance); misrepresenting product dimensions; mislabeling pack quantity. | Immediate listing suspension. Buyer refund funded from Vendor payout. |
| False sustainability specification | Listing EV charging equipment with a false rated power output; listing solar panels with inflated wattage; claiming battery capacity that is not achieved in real-world testing. | Immediate listing suspension. IEC certificate review. Account warning. Repeat: termination. |
| Missing allergen disclosure — food products | Failing to disclose any of the 14 major allergens where present in a food product. Life-threatening allergen omissions constitute a food safety emergency. | Immediate listing suspension. Food safety authority referral. Full buyer refund. Potential recall. |
B. Business Identity Misrepresentation
Vendors must not misrepresent their legal entity — including operating under a name that is not their registered business name without proper DBA/trading-as disclosure.
Vendors must not impersonate another business, brand, artisan, or person in any aspect of their AqNova presence.
Vendors must not misrepresent their business size, manufacturing capacity, or operational scope in ways designed to deceive buyers about the nature of their business.
Vendors who describe themselves as a 'small family business,' 'independent artisan,' 'women-owned cooperative,' or similar identity claim must be able to verify that claim on request. Deliberate identity misrepresentation to attract preferential consumer sentiment is a Code violation.
C. Pricing Misrepresentation
'Was/Now' or strikethrough pricing: the 'was' price must reflect a genuine previous price at which the product was sold for a meaningful period (minimum 28 consecutive days in the preceding 90 days) — consistent with EU Omnibus Directive (2019/2161/EU) and equivalent consumer protection law globally.
'Limited time offer' pricing: time-limited discounts must have a genuine, observed end date. Perpetual 'limited time offers' are a deceptive trade practice prohibited under the FTC Act § 5, EU UCPD, UK CPRs, and equivalent national law.
'Bundle value' claims: the stated individual component values in bundle pricing must reflect genuine individual market prices for those products, not artificially inflated comparison values.
10.9.4 Greenwashing Enforcement — What It Is, What Is Prohibited & Consequences
Greenwashing is the act of making environmental or sustainability claims that are false, misleading, unsubstantiated, or more favorable than the facts justify. It is one of the most serious issues facing the sustainable commerce sector globally — and one that directly threatens AqNova's foundational purpose and legal position.
AqNova operates a zero-tolerance greenwashing policy. Every sustainability enforcement action is recorded in AqNova's public Greenwashing Enforcement Log at aqnova.co/sustainability/enforcement. The record is permanent and public. There is no private resolution of greenwashing violations.
A. What Constitutes Greenwashing on AqNova
| Greenwashing Category | Specific Prohibited Practices |
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| Unsubstantiated generic claims | Using terms such as 'eco-friendly,' 'green,' 'sustainable,' 'natural,' 'pure,' 'clean,' 'earth-friendly,' 'environmentally responsible,' or 'planet-friendly' without a specific, verifiable, and substantiated basis for the claim. These terms are prohibited as standalone product descriptors on AqNova unless accompanied by specific evidence in the certification registry or documented evidence uploaded to the Seller Portal. |
| False organic claims | Using the word 'organic' as a product descriptor without a current, verified organic certification from a recognized certifying body (USDA NOP; EU Organic 2018/848; Soil Association; ACO; NPOP; JAS; IBD; IFOAM-accredited equivalent) covering the specific product. Using 'organic' to describe a single ingredient while implying the whole product is certified organic. |
| False carbon neutrality claims | Claiming a product or business is 'carbon neutral,' 'net zero,' 'climate positive,' or 'carbon offset' without independent third-party verified evidence (PAS 2060:2014; Science Based Targets initiative; Carbon Trust Standard; equivalent certified standard). Purchasing cheap carbon offsets and claiming carbon neutrality without third-party verification is prohibited. |
| Misleading comparisons | Claiming a product is 'more sustainable' or 'greener' than a competitor product without specific documented evidence to support the comparison. Vague comparative claims ('our most eco-friendly collection yet') without measurable, verified evidence. |
| Hidden trade-offs | Highlighting one environmental attribute of a product while concealing a significant countervailing environmental impact. Example: promoting packaging as 'recycled cardboard' while the product itself contains banned synthetic chemicals. |
| False recyclability claims | Claiming packaging or products are 'recyclable' when they are not accepted by the recycling infrastructure available to buyers in their market. Example: labeling a composite multi-material packaging as 'recyclable' when no kerbside recycling stream accepts it. |
| False compostability claims | Claiming packaging is 'compostable' or 'biodegradable' without specifying whether it requires industrial composting conditions (EN 13432; ASTM D6400) or home composting conditions (OK Compost HOME; ASTM D6400 at ambient temperature). Failing to disclose conditions renders the claim misleading. |
| Scope misrepresentation of certifications | Applying a certification badge to a product that is not within the scope of that certificate. Example: applying a GOTS badge to a product from a factory not named in the certificate scope; applying COSMOS Organic to a product formulation not assessed by the certifying body; applying a company-level B Corp badge as a product-level certification. |
| False supply chain claims | Claiming 'ethically sourced,' 'fairly traded,' 'slave-labour-free,' 'conflict-free,' or 'responsibly sourced' without documented supply chain evidence sufficient to substantiate the claim. Claiming Fairtrade certification without a current FLOCERT or Fair Trade USA certificate covering the specific commodity. |
| Fabricated social impact claims | Claiming '10% of profits donated to environmental charities,' 'we plant a tree for every order,' or similar without a transparent, verifiable, documented program with independently confirmable impact. Social impact claims must be specific, accurate, and auditable. |
B. AqNova's Greenwashing Enforcement — Four Levels
| Level | Trigger | Enforcement Action | Greenwashing Log Entry? |
|---|---|---|---|
| LEVEL 1 — Listing Correction | Unverified sustainability descriptor (e.g., 'eco-friendly,' 'natural,' 'green') used without Registry-verified certification or documented evidence. Identified at listing review or by buyer report. | Listing returned for correction. Specific prohibited claim identified. Vendor has 5 Business Days to correct and resubmit. Listing remains inactive until corrected. | No — correction-only threshold. |
| LEVEL 2 — Listing Suspension + Formal Warning | Badge displayed on a product outside the certificate's certified scope; claim language exceeds certified scope (e.g., '100% organic' when certificate covers 70% organic content); expired certification continued to be displayed after expiry. | All affected listings suspended. Formal written warning issued. 5 Business Days to correct and resubmit with corrected evidence. AqNova may conduct certificate scope review. | YES — Greenwashing Enforcement Log entry created with Vendor name and claim. |
| LEVEL 3 — Account Suspension + Investigation | Second Level 2 violation within 12 months; fabricated or altered certificate discovered; systematic misrepresentation across multiple listings; false carbon neutrality claim; false Fair Trade claim. | All listings suspended. Account suspended pending investigation. AqNova legal team notified. Greenwashing Enforcement Log entry created. Regulatory referral to FTC (US), CMA (UK), ACCC (Australia), or national authority may be made. | YES — Public entry with detail of violation and investigation status. |
| LEVEL 4 — Permanent Termination + Regulatory Referral | Third violation; deliberate greenwashing scheme; organized misrepresentation; systematic falsification of sustainability credentials across multiple product categories. | Permanent account ban. All payouts held pending investigation and legal assessment. Permanent Greenwashing Enforcement Log entry. Mandatory referral to FTC, CMA, or applicable regulatory authority and/or certifying body. Legal proceedings initiated where evidence supports. | YES — Permanent public entry. Legal referral noted. |
10.9.5 Labour & Human Rights — Vendor Workplace Obligations
AqNova's mission — connecting the world's conscious consumers with genuinely ethical products — demands that the people who make those products are treated with dignity, respect, and fairness. The following labour and human rights standards apply to all Vendors who employ, engage, or contract workers in the production of their products.
A. No Forced Labour — Absolute Prohibition
| FORCED LABOUR — ABSOLUTE PROHIBITION — ALL VENDORS — ALL JURISDICTIONS Vendors MUST NOT use, facilitate, or benefit from any form of forced labour, including: — Forced or compulsory labour (ILO Convention C029) — Bonded labour, debt bondage, or servitude — Indentured labour, compulsory prison labour (outside ILO guidelines) — State-imposed forced labour programs — Human trafficking for labour exploitation — Deceptive recruitment (false promises of wages, conditions, or location) — Charging workers recruitment fees that create debt obligations — Confiscating or withholding workers' identity or travel documents — Restricting workers' physical freedom of movement — Work performed under threat of violence, punishment, or immigration reporting Workers must be free to leave employment with reasonable notice per applicable law. No worker may be required to make a deposit or surrender personal documents as a condition of employment. UFLPA (Uyghur Forced Labor Prevention Act — US): AqNova strictly prohibits products manufactured in whole or in part in Xinjiang, China, or by entities identified on the UFLPA Entity List, without clear and convincing evidence of forced-labour-free production per UFLPA § 2(d)(1). |
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B. No Child Labour
Vendors must not employ workers below the minimum legal working age in their jurisdiction, with an absolute minimum of 15 years of age (ILO Convention C138). For hazardous work: absolute minimum 18 years.
The worst forms of child labour (ILO Convention C182) are absolutely prohibited: trafficking; sexual exploitation; use in armed conflict; hazardous work including exposure to dangerous chemicals, heavy machinery, and excessive hours.
Young workers (15–17 years where legally permitted): restricted working hours; no hazardous tasks; no night work; protection of access to education.
Age verification: maintain documented age verification procedures (government-issued ID) for all workers. Records retained minimum 5 years.
Where child labour is discovered: prioritize the welfare of the child — including educational support and family welfare assistance — over immediate dismissal. Notify AqNova within 5 Business Days.
C. Freedom of Association & Collective Bargaining
Vendors must respect workers' rights to form or join trade unions or worker organizations of their choosing, without interference, harassment, or retaliation (ILO Convention C087, C098).
Where freedom of association is legally restricted (e.g., specific jurisdictions in Asia and the Middle East): Vendors must provide effective alternative mechanisms for worker collective representation (works councils; workplace committees).
Workers must be free to select their own representatives. No retaliation against workers who organize, bargain collectively, or participate in lawful industrial action.
D. Non-Discrimination & Equal Opportunity
Vendors must not discriminate in hiring, promotion, compensation, discipline, or termination based on: race, colour, sex, religion, political opinion, national extraction, social origin, disability, age, sexual orientation, gender identity, pregnancy, marital status, caste, or any other characteristic protected by applicable law (ILO Convention C100, C111).
Equal remuneration for work of equal value — ILO Convention C100 principle applied globally.
Migrant workers must receive the same employment conditions as comparable local workers. Recruitment fees must not be charged to workers — the employer bears all recruitment costs (Dhaka Principles for migrant worker recruitment).
E. Wages, Benefits & Working Hours
Workers must be paid at least the legally required minimum wage in their jurisdiction, paid in full, on time, and in legal tender. No deductions not permitted by applicable law.
Overtime must be voluntary and compensated at the premium rate required by applicable law.
Regular working hours must not exceed 48 hours per week. Total hours including overtime must not exceed 60 hours per week except in genuine time-limited exceptional circumstances.
Workers must receive at least one rest day per seven-day period. Daily rest between shifts: minimum 11 hours.
All legally required benefits (social insurance, health coverage, pension, maternity/paternity leave, paid annual leave) must be provided.
AqNova strongly encourages payment of a living wage — benchmarked against the Anker Living Wage Reference Values or equivalent national benchmark — and recognizes Vendors who demonstrate living wage payment in AqNova's Sustainability Impact Programme.
F. Humane Treatment — Zero Tolerance for Abuse
No worker may be subjected to corporal punishment, physical or psychological harassment, verbal abuse, coercion, intimidation, or any demeaning treatment.
Vendors must have documented policies prohibiting harassment and bullying, communicated to all workers and management in the languages they understand.
Disciplinary processes must be documented, fair, and consistent. Disciplinary deductions from wages must not exceed what is permitted by applicable law.
10.9.6 Health, Safety & Worker Wellbeing
Vendors must provide safe, healthy, and humane working conditions for all workers in their operations. AqNova's health and safety requirements are based on ILO Convention C155 (Occupational Safety and Health Convention) and applicable national health and safety law. Requirements are scaled to the Vendor's size and operational context.
| H&S Requirement | Minimum Standard | Scaled to Size |
|---|---|---|
| Emergency exits | Unobstructed at all times during working hours. Marked and illuminated. Evacuation routes posted. | All Vendors with physical premises. |
| Fire safety | Functioning fire detection systems (smoke alarms minimum); fire suppression equipment; evacuation drills minimum annually; emergency evacuation plan posted. | All Vendors with physical premises. |
| Chemical safety | Hazardous chemicals labelled per GHS/CLP standards; Safety Data Sheets (SDS) available in workers' language; appropriate PPE provided at no cost to workers. | Vendors using hazardous chemicals in production. |
| Machine safety | Dangerous machinery with appropriate guarding; lockout/tagout procedures; machine-specific safety training before workers operate machinery. | Vendors operating machinery. |
| PPE | Appropriate personal protective equipment provided free of charge to all workers required to use it. | All Vendors with workers in hazardous tasks. |
| Clean drinking water | Available at all times during working hours. | All Vendors with workers. |
| Sanitation | Adequate, clean, and segregated sanitation facilities. | All Vendors with workers. |
| First aid | First aid facilities and trained first aiders available during all working hours. | All Vendors with workers on-site. |
| Incident reporting | All workplace accidents, injuries, and near-misses recorded. Serious injuries and fatalities reported to AqNova within 72 hours. | All Vendors with workers. |
| H&S Committee | Joint management-worker H&S Committee for facilities with 10 or more workers. | Vendors with 10+ workers. |
| Pregnancy protection | Pregnant workers not assigned to chemical exposure, heavy lifting, or documented pregnancy-risk tasks without medical assessment and alternative assignment. | All Vendors with workers. |
10.9.7 Environmental Standards — Production, Sourcing & Packaging
AqNova is a sustainable marketplace. The environmental practices of AqNova's Vendors are not merely a compliance obligation — they are central to the platform's identity and the value proposition AqNova makes to its buyers. Vendors are expected to operate with genuine environmental responsibility, scaled to their size and sector.
A. Legal Environmental Compliance — Minimum Absolute Standard
All Vendors must comply with applicable environmental laws and regulations in every jurisdiction where they operate. Non-compliance resulting in criminal prosecution, significant regulatory enforcement, or material environmental harm is a material breach of this Code resulting in immediate account suspension.
Environmental permit compliance: hold and maintain all required environmental permits in your jurisdiction of operation.
Discharge and emission limits: operate within permitted discharge and emission limits for air, water, and soil.
Waste management: dispose of all waste — including hazardous waste — in compliance with applicable law. Hazardous waste must be handled by licensed contractors.
B. Prohibited Substances — Absolute Prohibitions
| PROHIBITED SUBSTANCES — NEVER USE IN PRODUCTION OR PRODUCTS The following substances are absolutely prohibited from use in Vendor operations or products listed on AqNova, regardless of jurisdiction or regulatory status: — All substances banned under the Stockholm Convention on Persistent Organic Pollutants (POPs) — including DDT, aldrin, PCBs, and listed PFAS — All substances restricted under the Montreal Protocol on Ozone Depleting Substances (ODS) — including CFCs, HCFCs, halons, and methyl bromide — Hazardous wastes prohibited from export under the Basel Convention — EU REACH Regulation (1907/2006/EC) Annex XVII Restricted Substances (applies globally as AqNova's baseline for all products) — RoHS restricted substances (lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs) in applicable electronics and electrical products — CPSIA restricted substances: lead in substrate (>100ppm), lead in paint (>90ppm), phthalates in children's products — Formaldehyde above applicable thresholds for textiles and furniture products — Any substance on applicable national restricted lists for products intended for destination markets |
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C. Environmental Management — Scaled Standards
| Vendor Scale | Environmental Standard Required | Encouraged / Future Direction |
|---|---|---|
| Small/Micro — Solo artisan; less than 10 employees | Legal environmental compliance (mandatory). Basic waste reduction practices. Sustainable packaging (Section 10.5.14 compliance from applicable Phase date). | Document your environmental footprint. Begin tracking energy and water use. |
| Medium — 10–100 employees | All above + documented environmental policy communicated to all staff. Identification of material environmental aspects (emissions, water, waste, chemicals). Targets for material impacts. | ISO 14001 or equivalent EMS implementation. Scope 1 + 2 GHG measurement. |
| Large — 100+ employees; or high-environmental-impact sector | All above + ISO 14001:2015-aligned Environmental Management System (EMS) or equivalent. Scope 1 and 2 GHG emissions measured and disclosed to AqNova on request. Water use tracked in water-stressed regions (WRI Aqueduct). | Science Based Targets (SBTi-validated). Scope 3 measurement. 100% renewable electricity by 2030. Net-zero target. |
D. Deforestation-Free Sourcing
Vendors sourcing high-risk commodities must demonstrate deforestation-free sourcing consistent with the EU Deforestation Regulation (2023/1115/EU) — AqNova's global baseline — and applicable national environmental law:
High-risk commodities requiring deforestation-free evidence: palm oil; cocoa; coffee; soya; timber; rubber; beef and beef-derived products.
Accepted evidence: FSC or PEFC certification (timber and paper); RSPO certification (palm oil); Rainforest Alliance or UTZ certification (cocoa, coffee); SAN/RA certification (soya); credible supply chain mapping to source with deforestation-free documentation.
EU Deforestation Regulation (EUDR): products in scope supplied into or from the EU from December 30, 2024 onwards must be accompanied by due diligence statements confirming deforestation-free sourcing and legal production.
E. Packaging — AqNova Sustainability Standards
AqNova's packaging sustainability standards are detailed in Section 10.5.14 of the Shipping, Fulfillment & Logistics Standards. Key requirements for vendors in this Code context:
Phase 1 (current): no polystyrene loose fill; no single-use PVC plastic film; no packaging falsely labeled as recyclable, biodegradable, or compostable without third-party certification.
Phase 2 (Q3 2026): eliminate single-use plastic outer mailers; right-size all packaging (≤20% void space); FSC/PEFC certified outer cartons for shipments above 500g.
Phase 3 (Founding Vendors — immediate; all Vendors — 2027): 100% plastic-free inner packaging; AqNova Eco Packaging Badge eligibility.
10.9.8 Supply Chain Integrity & Due Diligence
The sustainability of an AqNova product is only as genuine as the supply chain that produced it. AqNova's supply chain due diligence requirements recognize that many of the most serious risks — forced labour, deforestation, conflict minerals, chemical contamination — occur in the earlier tiers of the supply chain, not in the Vendor's own operations.
A. Tier 1 Supplier Transparency — Minimum Standard
All Vendors must be able to identify their direct (Tier 1) suppliers — the entities who provide them with the primary materials, ingredients, components, or finished goods they sell on AqNova — on request from AqNova's compliance team.
Tier 1 supplier information: name; country; facility name and address (or region where facility-level detail is not available); primary product/material supplied.
Vendors who publicly disclose their Tier 1 supplier list (e.g., through Open Supply Hub — opensupplyhub.org; Sedex; or their own published supplier disclosure) receive recognition in AqNova's Sustainability Impact Programme.
B. Cascading Code Requirements to Suppliers
Vendors must communicate the requirements of this Code — or equivalent minimum standards consistent with it — to their direct suppliers in high-risk categories.
High-risk categories requiring active supplier Code communication: apparel and textiles; electronics and electrical products; food and agricultural products including fresh produce; cosmetics and personal care ingredients; minerals, metals, and gemstones.
Vendors in high-risk categories should require key direct suppliers to confirm their compliance with the Code's labour, environmental, and business integrity standards, and to keep that confirmation current.
C. Conflict Minerals — Mandatory Obligation
Products containing tin, tantalum, tungsten, or gold (3TG minerals) must comply with applicable conflict minerals due diligence requirements:
US Dodd-Frank Act Section 1502 and SEC conflict minerals disclosure rules (for products with US nexus or publicly listed suppliers).
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRA).
EU Conflict Minerals Regulation (2017/821/EU): importers of 3TG minerals into the EU must conduct OECD-aligned due diligence.
AqNova prohibits products containing 3TG minerals that cannot demonstrate a clean supply chain (Conflict-Free Sourcing Initiative (CFSI) validated smelter/refiner; equivalent third-party audit).
D. Supply Chain Due Diligence Legislation — Mandatory Compliance
| Legislation | Applies To | Key Obligation |
|---|---|---|
| UK Modern Slavery Act 2015 | UK-based Vendors or Vendors supplying into the UK with annual turnover above GBP £36 million | Publish an annual Modern Slavery Statement. Share publication URL with AqNova on request. Smaller Vendors: take reasonable steps to identify and address modern slavery risk in supply chain. |
| Australia Modern Slavery Act 2018 | Australian-based entities with annual consolidated revenue above AUD $100 million | Annual Modern Slavery Statement published to Australian government register. Smaller Vendors: encouraged to conduct modern slavery due diligence. |
| California Transparency in Supply Chains Act (SB 657) | Retailers and manufacturers doing business in California with global revenues above USD $100 million | Disclose supply chain due diligence efforts on California slavery and human trafficking on company website. |
| Canada — Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211, 2024) | Canadian government institutions and private sector entities meeting size thresholds | Annual report to Canadian government on forced labour and child labour risk and due diligence measures. |
| US Uyghur Forced Labor Prevention Act (UFLPA, 2021) | All importers of goods into the United States | Rebuttable presumption that goods produced wholly or in part in Xinjiang, or by UFLPA-listed entities, involve forced labour. Importers must provide clear and convincing evidence to US CBP to rebut presumption. |
| Germany LkSG (2023) | German-based companies with 1,000+ employees | Risk-based human rights and environmental due diligence in supply chains. Annual report. BAFA enforcement. |
| France Loi de Vigilance (Law 2017-399) | Large French companies (5,000+ employees in France; 10,000+ globally) | Published vigilance plan addressing human rights and environmental risks in supply chain. |
| EU Corporate Sustainability Due Diligence Directive (CSDDD, 2024/1760/EU) | Large EU and non-EU companies meeting size thresholds — phased implementation 2027-2029 | Mandatory human rights and environmental due diligence in own operations and supply chains. Civil liability. Director duty of care. |
| Norway Åpenhetsloven (2022) | Larger enterprises in Norway | Conduct UNGPs-based human rights due diligence. Publish annual reports. Respond to information requests from public. |
A. Anti-Bribery & Anti-Corruption — Zero Tolerance
| ANTI-CORRUPTION — ZERO TOLERANCE — ALL VENDORS — ALL JURISDICTIONS Vendors MUST NOT, and must not authorize any person on their behalf to: OFFER, PROMISE, GIVE, OR AUTHORIZE: any financial or other advantage to any person (public official, private individual, corporate employee, or political party) with the intent to obtain or retain business, or to secure any improper advantage, in connection with AqNova or any other commercial relationship. SOLICIT OR ACCEPT: any financial or other advantage in exchange for preferential treatment of any person or entity in their dealings with AqNova. MAKE FACILITATING PAYMENTS: even where local custom may suggest payments to expedite routine government actions, AqNova prohibits facilitating payments by Vendors in connection with AqNova's business. USE INTERMEDIARIES to make payments that AqNova could not make directly. APPLICABLE LAWS: US FCPA; UK Bribery Act 2010 (including s.7 — failure to prevent bribery); Brazil Lei Anticorrupção 12,846/2013; France Loi Sapin II; OECD Anti-Bribery Convention; and applicable national anti-corruption law in all Vendor operating jurisdictions. |
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B. Conflicts of Interest
Vendors must disclose to AqNova any actual or potential conflict of interest in their commercial relationship with AqNova — including personal relationships between Vendor personnel and AqNova employees, or competing financial interests.
Gifts and entertainment to AqNova employees: must be reasonable, proportionate, and consistent with applicable law. Maximum value: USD $75 per occasion per individual. No cash gifts.
C. Fair Competition & Antitrust
Vendors must comply with applicable competition law: US Sherman Act; Clayton Act; EU TFEU Arts. 101–102; UK Competition Act 1998; and equivalent national competition law.
Vendors must not collude with other Vendors on pricing, market allocation, bid-rigging, or other anticompetitive conduct through or outside the AqNova Platform.
Vendors must not exchange competitively sensitive information (pricing; customer lists; commercial strategies) with competitors.
D. Financial Integrity
Vendors must maintain accurate, complete, and transparent financial records relevant to their commercial relationship with AqNova — including payout records, tax registration, and transaction documentation.
Vendors must not engage in money laundering, financial fraud, or tax evasion in connection with their AqNova commercial relationship.
Vendors must comply with applicable AML/CTF requirements in their jurisdiction and cooperate with AqNova's payment processor AML screening as required by law.
VAT/GST/digital services tax: Vendors are responsible for their own tax compliance in all jurisdictions where they operate. AqNova collects and remits marketplace facilitator tax in jurisdictions where it is legally required to do so — Vendors must accurately disclose their own tax status in their account settings.
A. Personal Data Obligations
Vendors who handle personal data of AqNova buyers, Vendors, or employees in connection with their AqNova commercial relationship are subject to the following data protection requirements:
Vendors who process personal data on AqNova's behalf are data processors under GDPR (2016/679/EU), UK GDPR, and equivalent legislation, and must enter into a Data Processing Agreement (DPA) with Arivon Holding Corporation consistent with GDPR Article 28. Contact: privacy@aqnova.co to initiate a DPA.
Buyer personal data obtained through the AqNova Platform (including order information, delivery addresses, and communication history) must be used only for the fulfillment of the specific order. It must not be used to contact buyers directly outside AqNova's messaging system, to build marketing lists, or for any purpose other than order fulfillment.
Personal data of AqNova buyers must not be transferred to any third party without AqNova's written consent, except to the extent strictly necessary for carrier and logistics purposes in connection with the order.
Vendors must notify AqNova within 24 hours of becoming aware of any personal data breach affecting AqNova buyer or Platform data.
B. Applicable Data Protection Law — Global Reference
| Jurisdiction / Law | Vendor Obligation |
|---|---|
| EU — GDPR (2016/679/EU) | Buyer data from EU orders: lawful basis for processing required; data minimization; purpose limitation; storage limitation; subject rights compliance. DPA with AqNova required if processing EU buyer data. International transfer safeguards required. |
| UK — UK GDPR | Same as EU GDPR post-Brexit. ICO registration may be required for UK-established Vendors. |
| United States — CCPA/CPRA (California) | California buyers: right to know, delete, opt-out of sale. If Vendor qualifies as a 'business' under CCPA: privacy notice required. Vendor must not 'sell' buyer personal data received via AqNova. |
| Brazil — LGPD (Lei Geral de Proteção de Dados) | LGPD applies to processing of data of individuals in Brazil. Legal basis required. ANPD registration and compliance for Brazilian operations. |
| India — DPDPA 2023 (Digital Personal Data Protection Act) | Processing of Indian citizens' data requires consent or legitimate use basis. Data Principal rights. Cross-border transfer restrictions. |
| China — PIPL (Personal Information Protection Law, 2021) | Processing of Chinese citizens' personal information requires consent or statutory basis. Cross-border transfer of personal data from China requires security assessment or standard contract measures. |
| Singapore — PDPA (Personal Data Protection Act) | Processing personal data of Singapore individuals: consent or legitimate interest; notification; access and correction rights; data portability. |
| Nigeria — NDPR (Nigeria Data Protection Regulation, 2019) | Data controllers processing Nigerian citizens' data must comply with NDPR. NITDA reporting for data controllers processing data of over 1,000 subjects. |
| South Africa — POPIA | Processing of South African data subjects' personal information requires a lawful basis under POPIA. POPIA information officer appointment for South African entities. |
| All other jurisdictions | AqNova applies GDPR as global baseline. Vendors must comply with applicable national data protection law in all jurisdictions where they operate. |
A. Product Safety Baseline
All products listed on AqNova must comply with the EU General Product Safety Regulation (GPSR, 2023/988/EU) as AqNova's global product safety baseline — applied in addition to, not instead of, mandatory safety standards in destination markets. Vendors are responsible for product safety compliance in all markets they ship to.
| Destination Market | Key Product Safety Standard | Critical for Vendor Action |
|---|---|---|
| United States | CPSC/CPSIA (Consumer Product Safety Improvement Act). ASTM standards by category. FCC certification for electronics. FDA FSMA for food. CARB standards for California. | CPSIA lead (<100ppm) and phthalate (<1000ppm) limits for children's products are absolute. Violation = immediate recall obligation. |
| European Union | EU GPSR (2023/988/EU — effective July 13, 2024); CE Marking for applicable categories; REACH compliance; RoHS for electronics; EN toy safety standards. | EU GPSR creates direct platform operator obligations. AqNova is required to cooperate with EU safety authorities. Non-compliant products: mandatory removal. |
| United Kingdom | UKCA Mark (replaces CE for UK market post-Brexit); UK GPSR equivalent; UK REACH; UK RoHS; UK Toy Safety Regulations 2011. | UKCA marking required for applicable product categories sold to UK buyers. |
| Canada | Canada Consumer Product Safety Act (CCPSA); Canada Consumer Chemicals and Containers Regulations; Health Canada regulated products. | CCPSA Section 7: suppliers must report product safety incidents to Health Canada. |
| Australia | Australian Consumer Law (ACL) consumer guarantees; ACCC Product Safety Standards; TGA for therapeutic goods. | TGA registration required for therapeutic goods. ACCC mandatory recall powers. |
| Brazil | INMETRO compulsory certification for regulated categories; ANVISA for food, drugs, cosmetics; ANATEL for electronics. | INMETRO certification mandatory for regulated categories. ANVISA registration for food/cosmetics. |
| Nigeria | NAFDAC mandatory registration for food, drugs, cosmetics, medical devices. SON certification for regulated products. | No NAFDAC registration: immediate listing removal. Non-negotiable. |
| India | BIS certification (mandatory for electronics, many household products); FSSAI for food; CDSCO for drugs/cosmetics; Legal Metrology compliance. | BIS mandatory for covered electronics categories. FSSAI license number mandatory on all food listings. |
| China | CCC certification (China Compulsory Certification) for regulated categories; SAMR/GACC registration for food imports; NMPA for drugs/cosmetics. | CCC mandatory for covered categories including electronics. GACC registration for food facility registration. |
| Saudi Arabia / GCC | SFDA registration for applicable food/health products; GCC G-Mark (SASO/GSO certification); SASO standards compliance. | Halal certification mandatory for food/cosmetics. SFDA registration for regulated categories. |
B. Vendor Product Safety Obligations
Maintain and make available to AqNova on request: applicable conformity certificates; test reports from accredited laboratories; Declarations of Conformity; Safety Data Sheets; and any other documentation required by applicable law.
Traceability: maintain supply chain traceability sufficient to identify and isolate affected batches in the event of a product safety incident. Minimum: one-step-forward, one-step-back traceability.
Notify AqNova within 24 hours of becoming aware of any product safety incident, recall, regulatory enforcement action, or consumer complaint involving a significant safety risk for products listed on AqNova. Contact: compliance@aqnova.co — Subject: 'PRODUCT SAFETY — URGENT — [Product Name] — [Vendor Name].'
Cooperate fully with any product recall investigation, corrective action, or regulatory authority inquiry affecting listed products.
A. IP Respect — Third-Party Rights
Vendors must not infringe the intellectual property rights — copyright, trademark, patent, design rights, or trade secrets — of AqNova, its buyers, other Vendors, or any third party.
Vendors must not list products that infringe the intellectual property rights of third parties. This includes: counterfeit branded goods; products bearing unauthorized reproductions of registered trademarks or designs; products that copy protected artistic or literary works.
Counterfeit goods: selling counterfeit products is an absolute prohibited practice under Section 10.9.3 and this Code. Detection results in immediate permanent account termination, payout forfeiture, and legal referral. There is no right of appeal for confirmed counterfeit violations.
Where a Vendor receives an IP infringement notice from a third-party rights holder through AqNova's Notice & Takedown process (Section 5.8 of the AUP), the Vendor must: (a) respond within 5 Business Days; (b) provide evidence of their right to sell the product; or (c) remove the listing. Failure to respond is treated as acceptance of the infringement claim.
B. AqNova Intellectual Property
Vendors may not use AqNova's brand name, logos, trademarks, or marketing materials without prior written consent from AqNova's marketing team.
AqNova's brand assets licensed to Vendors for VRPP (referral program) promotional content must be used strictly in accordance with the VRPP brand usage license in Section 8.7.
Vendors may not register domain names, social media handles, or business names that incorporate 'AqNova,' 'Arivon,' 'aqnova.co,' or any confusingly similar variation without prior written consent.
C. Confidentiality
Vendors must protect AqNova's confidential information — including platform data, buyer information, pricing structures, and operational strategies — with at least the same level of care they would apply to their own most sensitive information.
Confidential information may only be used for performing Vendor obligations and fulfilling orders on the Platform. It may not be disclosed to third parties without AqNova's written consent, except where required by applicable law.
Confidentiality obligations survive termination of the Vendor relationship for a minimum of 5 years.
A. Export Controls & Sanctions
Vendors must comply with applicable export control laws including US Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR); EU Dual-Use Regulation (2021/821/EU); UK Export Control Order 2008; and applicable national export control law.
Vendors must not conduct transactions with parties on applicable sanctions lists: OFAC SDN List; UN Security Council Consolidated List; EU restrictive measures; UK OFSI Consolidated List. Vendors must screen their own customers and sub-suppliers against applicable lists.
Vendors must not provide to buyers via AqNova any goods, technology, or services subject to export license requirements without first obtaining the applicable license.
B. Customs & Trade Compliance
All product shipments must be accurately described in customs documentation — under-valuation, misclassification, or falsification of customs documentation is prohibited and constitutes a material breach of this Code and applicable criminal law.
Country of origin declarations must be accurate. Vendors must not misrepresent the country of origin of goods to circumvent tariffs, quotas, or trade restrictions.
HS code accuracy: the Harmonized System tariff classification declared on customs documents must accurately reflect the product. Deliberate misclassification to reduce import duty is customs fraud.
C. Tax Compliance
Vendors must comply with applicable tax law in all jurisdictions where they operate — including accurate tax filings, timely payment, VAT/GST registration and compliance where required, and transfer pricing compliance for inter-company transactions.
AqNova functions as a marketplace facilitator for VAT/GST/digital services tax in jurisdictions where applicable law requires this — including EU VAT (IOSS), UK VAT, Australia GST, Canada GST/HST, and others. Vendors must accurately disclose their own tax registration status in their account settings.
AqNova does not facilitate tax evasion. Vendors who structure transactions to avoid tax obligations may have their accounts suspended and be referred to applicable tax authorities.
D. Consumer Protection Law Compliance
Vendors must comply with applicable consumer protection law in every market they sell to — including distance selling regulations, right of withdrawal, refund obligations, and advertising standards. Key consumer protection laws are detailed in Section 10.8 (Returns, Refunds & Dispute Resolution).
Advertising of products: all marketing and promotional content created by Vendors must comply with the FTC Act § 5 (US), UCPD (EU), UK ASA/CAP Code, and equivalent national advertising standards laws. See Section 8.7 for referral marketing disclosure requirements.
A. Vendor Obligation — Worker Grievance Mechanisms
All Vendors with 10 or more direct workers must have a documented worker grievance mechanism through which workers can raise concerns about working conditions, labour rights violations, or Code violations without fear of retaliation.
The grievance mechanism must be accessible to all workers — including migrant workers, informal workers, and young workers — and available in the languages spoken by workers at the facility.
Workers who raise grievances must not be subjected to retaliation, punishment, dismissal, demotion, or any adverse treatment. Anti-retaliation is an absolute obligation.
Vendors should consider third-party-managed anonymous reporting channels for workers in higher-risk contexts — including production in countries with restricted freedom of association.
Grievance records must be maintained for a minimum of 3 years and made available to AqNova's compliance team on request.
B. Reporting Concerns to AqNova — Speak-Up
Vendors, their workers, supply chain workers, buyers, and any person with knowledge of a potential Code violation are encouraged to report concerns to AqNova:
Code of Conduct violations (general): compliance@aqnova.co — Subject: 'Code of Conduct Concern — [Company Name]'
Forced labour or child labour concerns in supply chains: compliance@aqnova.co — Subject: 'Supply Chain Worker Report — [Company Name]'
Anti-bribery and corruption concerns (including concerns about AqNova employees): ethics@aqnova.co — Subject: 'CONFIDENTIAL — [Topic]'
Greenwashing or sustainability misrepresentation: compliance@aqnova.co — Subject: 'Greenwashing Concern — [Product/Vendor Name]'
Product safety emergencies: safety@aqnova.co — Subject: 'PRODUCT SAFETY URGENT — [Product]'
All reports may be made anonymously. AqNova does not tolerate retaliation against good-faith reporters. The identity of reporters who request confidentiality is protected to the maximum extent permitted by applicable law.
A. Self-Assessment & Annual Certification
All Vendors are required to complete AqNova's Vendor Code of Conduct Annual Self-Assessment (Section 10.9.17) within 30 days of the anniversary of their onboarding acceptance date, and on each annual renewal. The Self-Assessment is the Vendor's annual certification of compliance with this Code.
B. Third-Party Audit Requirements
| Vendor Category | Audit Requirement | Timeline |
|---|---|---|
| High-risk product category Vendors (apparel, textiles, electronics, food/agricultural, cosmetics, minerals/metals) | Third-party social audit of Tier 1 manufacturing facilities: SMETA 4-pillar; SA8000; BSCI; or equivalent. Audit reports must be shared with AqNova. Corrective Action Plans for findings agreed and implemented. | Within 24 months of listing activation for existing Vendors. At activation for new Vendors from Phase 2. |
| Vendors shipping into the United States with goods potentially subject to UFLPA | Supply chain due diligence documentation demonstrating UFLPA compliance for any goods with Xinjiang supply chain exposure. | Before listing goods with applicable supply chain exposure. |
| Vendors with access to AqNova buyer data at scale (above threshold defined in DPA) | SOC 2 Type II report or equivalent information security assessment. | Annual. |
| Food Vendors in regulated categories (Nigeria, India, Brazil, Saudi Arabia, etc.) | Regulatory registration documentation: NAFDAC (Nigeria); FSSAI (India); ANVISA (Brazil); SFDA (Saudi Arabia) — as applicable by listing destination. | Before listing food products in applicable markets. |
C. AqNova's Right to Audit
AqNova reserves the right to conduct announced or unannounced audits of Vendor operations and facilities — directly or through third-party auditors — with reasonable prior notice except in cases of urgent concern about worker safety, material fraud, or product safety risk. Vendors agree to: provide full and open access to facilities, documentation, records, and workers; ensure workers can speak freely with auditors in private; and not take retaliatory action against workers who participate in audits.
D. Enforcement — Consequences of Code Violations
| Violation Severity | Examples | Enforcement Response |
|---|---|---|
| CRITICAL — Immediate Termination | Forced labour confirmed; child labour worst forms; human trafficking; UFLPA violation; counterfeit goods; deliberate greenwashing fraud; fabricated certification; deliberate misrepresentation of food allergens causing harm. | Immediate suspension and investigation. If confirmed: permanent account termination with written notice of cause. Payout forfeiture. Referral to law enforcement and regulatory authority where appropriate. Permanent Greenwashing Enforcement Log entry where applicable. |
| MAJOR — Suspension + Corrective Action Plan | Systematic wage theft; restriction of freedom of association; significant health & safety failure; data breach; significant environmental violation; repeated or systematic SNAD misrepresentation; expired certification continued to be displayed. | Formal notice with 30-day Corrective Action Plan (CAP) requirement. All listings suspended or restricted during CAP period. Follow-up assessment within 90 days. Failure to remediate: termination. |
| MODERATE — Warning + Remediation Window | Single-facility Code non-conformance; minor documentation gap; isolated claim language violation; processing time accuracy issues; packaging non-compliance with applicable Phase standard. | Formal written warning. 60-day remediation window. Follow-up assessment. Repeat violation: elevated to Major category. |
| MINOR — Advisory | Technical documentation gaps; delayed self-assessment completion; minor training shortfall; missing sustainability narrative in listing. | Written advisory. Remediation expected within 90 days. No immediate enforcement action. Continued monitoring. |
10.9.16 Anti-Greenwashing Law — Global Legal Reference
The following global legal framework shapes AqNova's greenwashing enforcement obligations and Vendor exposure. AqNova's Certification Registry and claim language rules (Sections 10.6 and 10.7) are designed to ensure compliance with the most stringent applicable standard in each jurisdiction.
| Jurisdiction | Key Anti-Greenwashing Law | Maximum Penalty / Enforcement |
|---|---|---|
| United States — Federal | FTC Green Guides (16 C.F.R. Part 260): requires 'competent and reliable scientific evidence' for all environmental claims. FTC Act § 5: unfair or deceptive acts in commerce include unsubstantiated sustainability claims. | Civil penalties up to USD $50,120 per violation per day. State AG enforcement additional. California EMCA: USD $2,500/day/product. |
| California | Environmental Marketing Claims Act (Bus. & Prof. Code § 17580); California UCL; California COPA (organic food). | EMCA: USD $2,500 per day per product. UCL: restitution, injunctive relief, civil penalties. |
| European Union | EU Green Claims Directive (COM/2023/166 — in implementation); EU Empowering Consumers Directive (2024/825/EU): prohibits generic sustainability labels without approved certification; prohibits carbon neutrality claims based on offsets. | Member state penalties. France: up to EUR €100,000 + 80% of advertising spend. Germany: UWG injunctions. |
| United Kingdom | CMA Green Claims Code (2021); Consumer Protection from Unfair Trading Regulations 2008: greenwashing is a criminal offence. | Criminal prosecution; unlimited fines; up to 2 years imprisonment under CPRs. CMA enforcement. ASA sanctions. |
| Canada | Competition Act ss. 74.01, 74.011 (as amended by Bill C-59, 2024): environmental claims must be based on 'adequate and proper testing.' | Administrative monetary penalties up to CAD $10 million (corporations) or 3% of global revenue. Criminal proceedings. |
| Australia | Australian Consumer Law (ACL) — misleading or deceptive conduct; ACCC Guidance on Environmental Marketing. | Civil penalties up to AUD $50 million per corporation. ACCC enforcement. Criminal liability for deliberate conduct. |
| Brazil | CDC Arts. 36–38: advertising must be truthful; CONAR self-regulation. | CDC: civil liability; fines; criminal penalties. CONAR: advertising suspension. |
| Nigeria | FCCPA 2019 — false or misleading representations; ASON advertising standards. | FCCPA civil penalties; ASON advertising sanctions. |
| India | Consumer Protection Act 2019; ASCI Guidelines: substantiation required for environmental advertising claims. | Consumer Protection Act penalties. ASCI: advertising suspension. |
| China | PRC Advertising Law (2021): advertisements must be truthful. | SAMR penalties up to 10× advertising spend. Criminal liability. |
| South Africa | Consumer Protection Act 2008; ASA of South Africa Code. | Fines up to 10% of turnover or ZAR 1 million. Criminal liability. |
10.9.17 Annual Compliance Self-Assessment
All AqNova Vendors must complete this Self-Assessment within 30 days of their onboarding acceptance anniversary and on each annual renewal. Submit completed assessments to: compliance@aqnova.co — Subject: 'Vendor Code Self-Assessment — [Vendor Name] — [Year].' The Self-Assessment is also available digitally in Seller Portal → Compliance → Annual Code Self-Assessment.
| HOW TO COMPLETE THIS SELF-ASSESSMENT For each item: tick the checkbox (☐ → ✓) to confirm compliance, OR note 'Partial' or 'In Progress' with a brief explanation. Where an item is not applicable to your business (e.g., Section B items for a solo digital-only business), mark 'N/A — [brief reason]'. Deliberate false statements on this Self-Assessment constitute a material breach of this Code and the Seller Agreement. AqNova may verify Self-Assessment responses through document review, third-party audit, or direct confirmation. If you have concerns about your compliance status on any item, contact compliance@aqnova.co BEFORE submitting — AqNova's team will help you develop a remediation pathway rather than an enforcement response. |
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SECTION A — PRODUCT HONESTY & MISREPRESENTATION
☐ A1 All product descriptions accurately represent what buyers will receive, including materials, ingredients, dimensions, origin, certifications, and processing methods.
☐ A2 No product listing uses unsubstantiated sustainability claims (eco-friendly, natural, green, sustainable, clean, pure, carbon neutral) without a verified Registry certification or documented evidence.
☐ A3 All sustainability certifications displayed on listings are: current (not expired); verified in AqNova's Certification Registry; and cover the specific product in the listing.
☐ A4 No certification is applied to a product outside the certified scope of the certificate.
☐ A5 'Was/Now' and time-limited promotional pricing reflects genuine prior pricing for a meaningful period.
☐ A6 No product on my AqNova account is counterfeit or infringes any third party's intellectual property rights.
☐ A7 All 14 major EU allergens are disclosed in full in the ingredient list of every food and applicable personal care product I sell.
☐ A8 Country of origin declared on all listings and customs documentation is accurate.
SECTION B — LABOUR & HUMAN RIGHTS
☐ B1 My business does not use, facilitate, or benefit from any form of forced labour, bonded labour, debt bondage, or human trafficking.
☐ B2 My business does not employ workers below the minimum legal age (absolute minimum: 15 years; 18 for hazardous work). Age verification procedures are documented.
☐ B3 Workers' rights to freedom of association and collective bargaining are respected. No retaliation against workers who organize or raise labour concerns.
☐ B4 My business does not discriminate in employment on the basis of any protected characteristic under applicable law.
☐ B5 All workers are paid at least the legally required minimum wage, on time, in full, in legal tender. Payslips provided.
☐ B6 Working hours do not exceed 48 hours/week regular; 60 hours/week total including overtime. Overtime is voluntary. Workers receive at least 1 rest day per week.
☐ B7 No worker is subjected to physical, psychological, or verbal abuse, harassment, or coercion.
☐ B8 All legally required benefits (social insurance, health, pension, paid leave) are provided.
SECTION C — HEALTH, SAFETY & ENVIRONMENT
☐ C1 Emergency exits are unobstructed at all times during working hours. Functioning fire detection is in place.
☐ C2 Hazardous chemicals are labelled per GHS/CLP standards. SDS available in workers' language. Appropriate PPE provided at no cost.
☐ C3 Workplace accidents and injuries are recorded. Serious injuries/fatalities reported to AqNova within 72 hours.
☐ C4 My business complies with all applicable environmental laws and regulations in every jurisdiction of operation.
☐ C5 No products I list use substances banned under Stockholm Convention (POPs), Montreal Protocol (ODS), EU REACH Annex XVII, RoHS, or CPSIA — in applicable product categories.
☐ C6 Waste — including hazardous waste — is disposed of through lawful means. Hazardous waste through licensed contractors.
☐ C7 My packaging meets AqNova's sustainability packaging standards for the applicable Phase (Section 10.5.14).
SECTION D — BUSINESS INTEGRITY & LEGAL COMPLIANCE
☐ D1 My business does not offer, pay, or receive bribes or corrupt payments in connection with AqNova or any other commercial relationship.
☐ D2 I have disclosed to AqNova any actual or potential conflicts of interest in my commercial relationship with AqNova.
☐ D3 My business complies with applicable competition law. No price-fixing, market allocation, or anticompetitive conduct.
☐ D4 Financial records relevant to my AqNova relationship are accurate and transparent.
☐ D5 My business complies with all applicable export control and sanctions laws. I do not transact with sanctioned parties or restricted destinations.
☐ D6 All customs documentation for product shipments is accurate — correct description, HS code, declared value, and country of origin.
☐ D7 My business complies with all applicable tax law in jurisdictions where it operates.
☐ D8 My business complies with applicable consumer protection law in all markets I sell to via AqNova.
SECTION E — SUPPLY CHAIN & DATA PROTECTION
☐ E1 I can identify all my direct (Tier 1) suppliers for products listed on AqNova on request from AqNova's compliance team.
☐ E2 I have communicated AqNova's Code requirements (or equivalent minimum standards) to my key direct suppliers in high-risk product categories.
☐ E3 For products containing 3TG conflict minerals (tin, tantalum, tungsten, gold): my supply chain demonstrates OECD-aligned conflict-free sourcing.
☐ E4 Where applicable by law (UK Modern Slavery Act; Australia Modern Slavery Act; California SB 657; Canada S-211): I have published my Modern Slavery Statement and share the URL with AqNova on request.
☐ E5 Buyer personal data obtained through AqNova is used only for order fulfillment and not for direct marketing or third-party purposes.
☐ E6 Where I process AqNova buyer personal data as a data processor: a Data Processing Agreement is in place with Arivon Holding Corporation (or is being requested from privacy@aqnova.co).
☐ E7 My business has a documented worker grievance mechanism (where 10 or more workers employed). Anti-retaliation protections are in place and communicated to workers.
SECTION F — PRODUCT SAFETY & IP
☐ F1 All products I list on AqNova comply with the EU General Product Safety Regulation (GPSR, 2023/988/EU) as global baseline, and with applicable mandatory safety standards in destination markets.
☐ F2 I hold all required regulatory registrations in markets I sell to (NAFDAC for Nigeria; FSSAI for India; ANVISA for Brazil; SFDA for Saudi Arabia — as applicable).
☐ F3 Product conformity documentation (test reports, Declarations of Conformity, certifications) is current, held on file, and available to AqNova on request.
☐ F4 I will notify AqNova within 24 hours of any product safety incident, recall, or regulatory enforcement action affecting any product listed on AqNova.
☐ F5 No product listed on my AqNova account infringes any registered trademark, copyright, design right, or other intellectual property of any third party.
SELF-ASSESSMENT DECLARATION
I declare on behalf of the business named below that the above statements in this Annual Self-Assessment are accurate to the best of my knowledge and belief, and that the business named below is in material compliance with AqNova's Vendor Code of Conduct (Section 10.9) as of the date below.
I acknowledge that deliberate false statements on this Self-Assessment constitute a material breach of the Seller Agreement (Section 1.3) and this Code, and may result in account termination, payout forfeiture, and legal action.
Submit to: compliance@aqnova.co — Subject: 'Vendor Code Self-Assessment — [Vendor Name] — [Year]'
BINDING EXECUTION DECLARATION
| IMPORTANT LEGAL NOTICE THIS SECTION IS THE BINDING ACCEPTANCE OF THE VENDOR CODE OF CONDUCT. SIGNING THIS DECLARATION CONSTITUTES LEGAL AGREEMENT TO COMPLY WITH EVERY PROVISION OF THE AQNOVA VENDOR CODE OF CONDUCT (SECTION 10.9). THIS DOCUMENT HAS CONTRACTUAL EFFECT AND IS RETAINED BY ARIVON HOLDING CORPORATION AS PART OF THE VENDOR'S ACCOUNT RECORD. DO NOT SIGN UNLESS YOU HAVE READ AND UNDERSTOOD THE FULL CODE. |
|---|
The Vendor identified below ('the Vendor') has read the AqNova Marketplace Vendor Code of Conduct (Section 10.9, Version 1.0, effective April 7, 2026) in its entirety and, by executing this Onboarding Acceptance Declaration, agrees as follows:
AGREEMENT TO COMPLY: The Vendor agrees to comply with every provision of the Vendor Code of Conduct in its operation of the AqNova Vendor account and in the conduct of its business as it relates to the AqNova Platform.
AUTHORITY: The person signing this Declaration is duly authorized to bind the Vendor to these obligations.
ACCURACY OF REPRESENTATIONS: All information submitted in the Vendor onboarding process, including business identity, certifications, product descriptions, and all account information, is accurate and complete as of the date of this Declaration.
ONGOING OBLIGATION: The Vendor acknowledges that the Code creates ongoing obligations — not one-time acceptance — and that changes in the Vendor's business, products, certifications, or supply chain must be reflected promptly in the Platform account and listings.
ANNUAL SELF-ASSESSMENT: The Vendor agrees to complete the Vendor Code of Conduct Annual Self-Assessment (Section 10.9.17) each year within 30 days of the anniversary of this Declaration, and on each annual account renewal.
CONSEQUENCES OF NON-COMPLIANCE: The Vendor acknowledges that material violations of the Code may result in immediate listing suspension, account termination, payout forfeiture, referral to regulatory authorities, and legal proceedings, as set out in Section 10.9.15.
UPDATES TO THE CODE: AqNova may update this Code from time to time with 30 calendar days advance written notice. Continued use of the Platform after the notice period constitutes acceptance of the updated Code. EU/UK Vendors: updates comply with EU P2B Regulation Art. 5.
GOVERNING LAW: This Declaration and the Code are governed by the laws of the State of California, USA, and applicable federal US law. For Vendors who qualify as consumers under applicable mandatory law in their jurisdiction, mandatory consumer protection provisions apply alongside California law. EU Vendors: P2B Regulation rights are non-waivable and apply in full.
By signing below, the Vendor confirms that they have read and understood the AqNova Vendor Code of Conduct in its entirety and agree to be bound by its terms:
| VENDOR DETAILS AUTHORIZED SIGNATORY FOR ARIVON HOLDING CORPORATION (OPERATING AQNOVA MARKETPLACE) Electronic acceptance via aqnova.co/selling-on-aqnova/code-of-conduct has the same legal effect as a handwritten signature per the US E-SIGN Act (15 U.S.C. § 7001), EU eIDAS Regulation (EU 910/2014), UK Electronic Communications Act 2000, and equivalent national electronic signature law in all applicable jurisdictions. |
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10.9.19 Contact — Code of Conduct & Compliance
| AqNova Vendor Code of Conduct — Contact Directory ANNUAL CODE SELF-ASSESSMENT SUBMISSION: compliance@aqnova.co Subject: 'Vendor Code Self-Assessment — [Vendor Name] — [Year]' CODE OF CONDUCT CONCERNS / VIOLATIONS: compliance@aqnova.co Subject: 'Code of Conduct Concern — [Vendor/Company Name]' FORCED LABOUR / CHILD LABOUR / MODERN SLAVERY: compliance@aqnova.co Subject: 'Supply Chain Worker Report — [Vendor Name]' ANTI-BRIBERY / ETHICS REPORTS (CONFIDENTIAL): ethics@aqnova.co Subject: 'CONFIDENTIAL — [Topic]' Anonymous reports accepted. Anti-retaliation guaranteed. GREENWASHING CONCERNS: compliance@aqnova.co Subject: 'Greenwashing Concern — [Product/Vendor Name]' PRODUCT SAFETY EMERGENCIES: safety@aqnova.co Subject: 'PRODUCT SAFETY URGENT — [Product Name] — [Vendor Name]' 24-HOUR NOTIFICATION OBLIGATION FOR RECALLS DATA PROTECTION / DPA QUERIES: privacy@aqnova.co Subject: 'Vendor DPA Request — [Vendor Name]' PRODUCT REGULATORY COMPLIANCE: compliance@aqnova.co Subject: 'Product Safety — [Category] — [Vendor Name]' CERTIFICATION / GREENWASHING ENFORCEMENT LOG: aqnova.co/sustainability/enforcement CODE OF CONDUCT URL: aqnova.co/selling-on-aqnova/code-of-conduct CERTIFICATION REGISTRY (PUBLIC): aqnova.co/sustainability/certifications P2B COMPLAINT PORTAL (EU/UK VENDORS): aqnova.co/p2b-complaints P2B DESIGNATED MEDIATORS: aqnova.co/p2b-mediators SELLER PORTAL — COMPLIANCE CENTRE: vendors.aqnova.co/compliance ANNUAL SELF-ASSESSMENT (DIGITAL): vendors.aqnova.co/compliance/self-assessment KEY EXTERNAL RESOURCES: ILO Core Conventions: ilo.org/core-conventions UN Guiding Principles on BHR: ohchr.org/UNGPs OECD Guidelines for MNEs (2023): oecd.org/responsible-business Anker Living Wage: globallivingwage.org FTC Green Guides: ftc.gov/green-guides EU Green Claims Directive: ec.europa.eu/environment/green-claims UK CMA Green Claims Code: gov.uk/cma-green-claims Open Supply Hub (supplier mapping): opensupplyhub.org UFLPA Entity List: cbp.gov/uflpa REGISTERED OFFICE: Arivon Holding Corporation | C/O Arivon Holding Corporation 2571 Saturn Avenue, Unit #265, Huntington Park, CA 90255, USA EIN: 41-3210066 | CA File No: B20250418195 | D-U-N-S: 142957477 GB EORI: GB511467217000 Nigeria — Sahara Eagle Ltd: Reg: 1957145 | Tax ID: 31052811-0001 | NEPC: 0030281 |
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AqNova Marketplace | Section 10.9: Vendor Code of Conduct | Version 1.0 | April 7, 2026
© 2026 Arivon Holding Corporation. All rights reserved. Operated by Arivon Holding Corporation | Huntington Park, CA 90255, USA
AqNova and AqNova Marketplace are trademarks of Arivon Holding Corporation.
THIS CODE SUPPLEMENTS THE SELLER AGREEMENT (SECTION 1.3) AND PLATFORM T&C (SECTION 1.1). IN THE EVENT OF CONFLICT ON CODE-SPECIFIC MATTERS, THIS CODE GOVERNS. MANDATORY CONSUMER AND WORKER PROTECTION LAW IN EACH APPLICABLE JURISDICTION APPLIES IN FULL ALONGSIDE THIS CODE.