Ethical Sourcing Policy
AqNova Marketplace Policies & Disclosures
AQNOVA MARKETPLACE
Global Legal Footer Framework
Comprehensive Compliance & Platform Governance Reference
(MASTER)
AqNova's Complete Framework for Supply Chain Human Rights, Labour Standards, Living Wage, Supplier Audits & Global Ethical Sourcing Compliance
Effective Date: April 7, 2026 | Version 1.0 | Arivon Holding Corporation
| Regulatory & Legal Frameworks — Ethical Sourcing Policy International Labour: ILO Declaration on Fundamental Principles and Rights at Work ILO Convention C029 — Forced Labour (1930) ILO Convention C105 — Abolition of Forced Labour (1957) ILO Convention C087 — Freedom of Association (1948) ILO Convention C098 — Right to Organise / Collective Bargaining (1949) ILO Convention C100 — Equal Remuneration (1951) ILO Convention C111 — Discrimination in Employment (1958) ILO Convention C138 — Minimum Age (1973) ILO Convention C182 — Worst Forms of Child Labour (1999) ILO Tripartite Declaration of Principles (MNEs & Social Policy) UN Guiding Principles on Business and Human Rights (UNGPs, 2011) OECD Guidelines for Multinational Enterprises (2023 revision) United States: US Tariff Act (19 U.S.C. § 1307) — ban on forced labor imports Uyghur Forced Labor Prevention Act (UFLPA, Pub. L. 117-78, 2021) Trafficking Victims Protection Reauthorization Act (TVPRA) California Transparency in Supply Chains Act (SB 657, 2010) California Assembly Bill 701 — warehouse worker protection Federal Acquisition Regulation (FAR) — forced labor prohibition European Union: EU Corporate Sustainability Due Diligence Directive (CSDDD, 2024/1760/EU) — mandatory human rights and environmental DD EU Forced Labour Regulation (2024/3015/EU — effective 2027) EU Conflict Minerals Regulation (2017/821/EU) EU Batteries Regulation (2023/1542/EU) — supply chain DD EU Deforestation Regulation (2023/1115/EU) — human rights United Kingdom: UK Modern Slavery Act 2015 (ss. 54, 57) UK Modern Slavery (Amendment) Bill (pending) UK Bribery Act 2010 (supply chain corruption prevention) The Modern Slavery Act 2015 Transparency in Supply Chains etc. Guidance for Businesses (Home Office, 2017) Canada: Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211, 2023) — reporting requirement Customs Tariff — prohibition on goods produced by forced labour Canadian Business and Human Rights Benchmark Australia: Modern Slavery Act 2018 (Cth) — entity reporting Commonwealth Modern Slavery Register Fair Work Act 2009 — supply chain wage theft provisions Germany: Lieferkettensorgfaltspflichtengesetz (LkSG, 2023) — supply chain due diligence for companies with 1,000+ employees France: Loi de Vigilance (Law 2017-399) — duty of vigilance Norway: Transparency Act (Åpenhetsloven, 2022) — UNGPs-based DD Netherlands: Responsible Business Conduct Agreement framework Brazil: CLT (Consolidação das Leis do Trabalho) — labour code Constitutional prohibition on slave-like labour conditions Ministry of Labour 'Dirty List' (Lista Suja do Trabalho Escravo) Nigeria: Labour Act (Cap. L1 LFN 2004) | Child Rights Act 2003 Trafficking in Persons (Prohibition) Enforcement and Administration Act South Africa: Basic Conditions of Employment Act 75 of 1997 | LRA Child Justice Act 75 of 2008 | Broad-Based Black Economic Empowerment Act (B-BBEE) 53 of 2003 India: Bonded Labour System (Abolition) Act 1976 Child Labour (Prohibition and Regulation) Amendment Act 2016 Minimum Wages Act 1948 | Factories Act 1948 Code on Wages 2019 | Code on Occupational Safety 2020 Australia / Asia-Pac: Australian Fair Work Act | Malaysia Employment Act Bangladesh Labour Act (as amended) | Cambodian Labour Law Vietnam Labour Code 2019 | Thailand Labour Protection Act |
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| IMPORTANT NOTICE ALL VENDORS ON AQNOVA REPRESENT AND WARRANT, AS A CONDITION OF THE VENDOR AGREEMENT, THAT THEIR SUPPLY CHAINS COMPLY WITH AQNOVA'S ETHICAL SOURCING STANDARDS AS SET OUT IN THIS POLICY. VENDORS ARE REQUIRED TO CONDUCT DUE DILIGENCE ON THEIR SUPPLY CHAINS, NOT MERELY TO REPRESENT COMPLIANCE. A REPRESENTATION OF COMPLIANCE WITHOUT UNDERLYING DUE DILIGENCE IS A MATERIAL BREACH OF THE VENDOR AGREEMENT. VIOLATIONS MAY RESULT IN IMMEDIATE LISTING SUSPENSION, ACCOUNT TERMINATION, AND REFERRAL TO APPLICABLE LAW ENFORCEMENT AND REGULATORY AUTHORITIES. |
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AqNova's Ethical Sourcing Policy establishes the complete framework governing the human rights and labour standards that all Vendors must meet throughout their supply chains — from their own facilities and operations, through their tier-1 suppliers (direct suppliers), and into higher tiers of the supply chain for high-risk product categories. This Policy reflects AqNova's conviction that a genuinely sustainable marketplace cannot separate environmental sustainability from human rights: products that meet the highest environmental standards but are manufactured using forced or child labor are not sustainable products by any meaningful definition.
This Policy is a condition of the Vendor Agreement (Section 2.2) and applies to every Vendor on the Platform, regardless of size, country of establishment, or product category. The standards set out in this Policy are calibrated against international best practice — the ILO Core Conventions, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises — and are consistent with the most demanding national mandatory due diligence frameworks, including the EU CSDDD, UK Modern Slavery Act, Germany's LkSG, Australia's Modern Slavery Act, and Canada's S-211.
| Section 6.2 — Structure 6.2.1 AqNova's Ethical Sourcing Philosophy 6.2.2 ILO Core Conventions — Minimum Labour Standards 6.2.3 Forced Labour & Modern Slavery — Zero Tolerance 6.2.4 Child Labour — Absolute Prohibition 6.2.5 Freedom of Association & Collective Bargaining Rights 6.2.6 Non-Discrimination & Equal Opportunity 6.2.7 Living Wage Commitment 6.2.8 Workplace Health & Safety 6.2.9 Working Hours & Rest 6.2.10 Supply Chain Mapping — Tier Disclosure Requirements 6.2.11 Supplier Audit Program — Requirements & Recognized Standards 6.2.12 High-Risk Country & Commodity Framework 6.2.13 Specific Global Legislative Requirements 6.2.14 Vendor Self-Declaration & Annual Certification 6.2.15 Grievance Mechanisms & Worker Voice 6.2.16 Corrective Action Planning 6.2.17 Ethical Sourcing Enforcement 6.2.18 Contact Information — Ethical Sourcing |
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6.2.1 AqNova's Ethical Sourcing Philosophy
AqNova's approach to ethical sourcing is grounded in three convictions that distinguish it from the minimum compliance approach taken by many marketplace operators:
| AqNova's Three Ethical Sourcing Convictions CONVICTION 1 — SUSTAINABILITY INCLUDES PEOPLE: A product cannot be genuinely sustainable if it is made under conditions that exploit the people who make it. AqNova's 'verified sustainable product' standard covers both environmental and social dimensions. Vendors who excel environmentally but maintain forced or child labor in their supply chains do not qualify as sustainable Vendors on AqNova. CONVICTION 2 — DUE DILIGENCE, NOT JUST DECLARATION: Requiring Vendors to simply declare compliance with ethical sourcing standards is insufficient. Modern supply chain human rights abuses are concentrated precisely where oversight is weakest — in tier-2 and tier-3 suppliers in high-risk jurisdictions where Vendors often have limited visibility. AqNova's framework requires active due diligence, not passive attestation. CONVICTION 3 — IMPROVEMENT IS THE GOAL: Supply chain remediation — not supplier termination — is the first response to identified issues in most cases. Workers in supply chains with problems are often better served by their employer being helped to improve than by the employer losing contracts. AqNova's framework prioritizes corrective action and improvement, reserving termination for cases of serious violation or failure to remediate within agreed timelines. |
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6.2.2 ILO Core Conventions — Minimum Labour Standards
The International Labour Organization's (ILO) Core Conventions, consolidated in the 1998 Declaration on Fundamental Principles and Rights at Work, establish the global minimum standards for labour rights that apply to all workers in all countries regardless of whether the specific country has ratified the relevant convention. AqNova requires all Vendors and their supply chain partners to comply with all eight ILO Core Conventions. These form the non-negotiable floor of AqNova's Ethical Sourcing Standards.
| ILO Convention | Content & AqNova's Application |
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| C029 — Forced Labour Convention (1930) | Prohibits all forms of forced or compulsory labour — work exacted from any person under the menace of any penalty and for which the person has not offered themselves voluntarily. AqNova applies the ILO's 11 indicators of forced labour in assessing supply chain risks: debt bondage; restriction of movement; isolation; physical/sexual violence; intimidation and threats; retention of identity documents; withholding wages; debt bondage; deceptive recruitment; excessive overtime; abusive working and living conditions. |
| C105 — Abolition of Forced Labour Convention (1957) | Prohibits the use of any form of forced or compulsory labour: (a) as a means of political coercion or education or punishment for political views; (b) as a method of mobilising and using labour for purposes of economic development; (c) as a means of labour discipline; (d) as a punishment for participation in strikes; (e) as a means of racial, social, national or religious discrimination. AqNova monitors for government-compelled forced labour programs, particularly relevant in specific jurisdictions. |
| C087 — Freedom of Association and Protection of the Right to Organise Convention (1948) | Guarantees workers the right to establish and join organisations of their own choosing without prior authorisation and to organise their activities and programmes. AqNova requires that Vendors and their suppliers: do not interfere with workers' rights to form or join trade unions; do not retaliate against workers for union membership or activity; and do not compel workers to join company-controlled unions as a condition of employment. |
| C098 — Right to Organise and Collective Bargaining Convention (1949) | Protects workers against anti-union discrimination and requires employers to bargain in good faith with freely chosen worker representatives. AqNova requires that collective bargaining processes are genuine and conducted in good faith in all Vendor facilities and those of their tier-1 suppliers. |
| C100 — Equal Remuneration Convention (1951) | Requires equal remuneration for men and women workers for work of equal value. AqNova requires Vendors to conduct or be prepared to conduct a gender pay gap analysis for their facilities and to address unexplained gender pay differentials. 'Work of equal value' is interpreted consistent with ILO guidance — including work of a substantially similar character, irrespective of job title or classification. |
| C111 — Discrimination (Employment and Occupation) Convention (1958) | Prohibits discrimination in employment based on race, colour, sex, religion, political opinion, national extraction, or social origin. AqNova extends this to include discrimination based on disability, age, sexual orientation, and gender identity in accordance with evolving international standards. Vendors must maintain non-discrimination policies and grievance procedures covering all protected characteristics. |
| C138 — Minimum Age Convention (1973) | Requires a minimum working age of no less than 15 years (14 for developing countries with limited economic development) for general employment; no less than 18 for hazardous work. AqNova adopts a global minimum of 15 years for light work and 18 years for any hazardous work or manufacturing process. AqNova requires Vendors to maintain age verification records for all production workers. |
| C182 — Worst Forms of Child Labour Convention (1999) | Requires immediate and effective measures to prohibit and eliminate: all forms of slavery and trafficking; use, procuring, or offering of children for prostitution, pornography, or illicit activities; use of children in armed conflict; and work likely to harm health, safety, or morals of children. AqNova treats any involvement in worst forms of child labour as grounds for immediate account termination with no corrective action pathway. |
6.2.3 Forced Labour & Modern Slavery — Zero Tolerance
Forced labour and modern slavery represent the most severe category of human rights violation in commercial supply chains. AqNova has zero tolerance for any form of forced labour, debt bondage, human trafficking, or modern slavery at any tier of the Vendor's supply chain. This zero tolerance is operationalized through the following framework:
A. Indicators of Forced Labour — AqNova's Monitoring Framework
AqNova applies the ILO's 11 Indicators of Forced Labour as the analytical framework for assessing forced labour risk in Vendor supply chains:
Abuse of vulnerability: exploitation of workers' irregular immigration status, social vulnerability, or lack of alternatives.
Deception: recruiting workers by false promises regarding the type of work, location, hours, accommodation, and wages.
Restriction of movement: preventing workers from leaving their workplace or living quarters; confiscating or destroying travel documents.
Isolation: working and living in isolated locations, preventing contact with the outside world.
Physical and sexual violence: actual use or threat of physical force, sexual assault, or other violence.
Intimidation and threats: threats to the worker or their family members, including threats of reporting immigration status to authorities.
Retention of identity documents: confiscation of passports, national identity cards, or other identity documents as a means of control.
Withholding of wages: non-payment, underpayment, or irregular payment of wages; payment in kind rather than in money.
Debt bondage: workers recruited with recruitment fees that are then held against them, creating a debt they must work to repay.
Abusive working and living conditions: conditions significantly below applicable legal minimum standards.
Excessive overtime: workers compelled to work overtime through threat of penalty, dismissal, or violence.
B. High-Risk Forced Labour Jurisdictions & Commodities
AqNova's forced labour risk framework is informed by the following resources, which identify jurisdictions and commodities with elevated forced labour risk:
US Department of Labor (DOL) List of Goods Produced by Child Labor or Forced Labor (ILAB List): identifies goods and their countries of origin where child labor or forced labor has been identified. AqNova monitors this list and applies enhanced due diligence to Vendors sourcing from listed country-commodity combinations.
US Department of State Trafficking in Persons Report (TIP Report): annual country-level assessment of human trafficking risk and government response. AqNova uses the TIP Tier classification in its supply chain risk assessment.
US Customs and Border Protection (CBP) Withhold Release Orders (WROs) and Findings: CBP orders blocking importation of goods from specific entities or regions based on forced labour evidence. AqNova monitors active WROs and prohibits products from WRO-designated entities.
UFLPA Entity List: entities added to the Uyghur Forced Labor Prevention Act Entity List by the US Forced Labor Enforcement Task Force. Goods from UFLPA-listed entities are prohibited from the US market.
Global Slavery Index (Walk Free Foundation): country-level estimates of modern slavery prevalence, used in AqNova's risk tiering.
Sedex Risk Assessment: Sedex's RADAR risk assessment tool, used by AqNova's audit partners to assess country and commodity risk.
C. Specific UFLPA Compliance — Xinjiang, China
| UFLPA Compliance — Xinjiang (XUAR) Policy The US Uyghur Forced Labor Prevention Act (UFLPA, Pub. L. 117-78, effective June 21, 2022) creates a rebuttable presumption that all goods mined, produced, or manufactured in the Xinjiang Uyghur Autonomous Region (XUAR) of China, or by entities on the UFLPA Entity List, involve forced labor and are prohibited from importation into the United States. AQNOVA'S UFLPA POLICY: All Vendors shipping to the United States must certify that: (a) Their products do not contain any component sourced from the XUAR; OR (b) If XUAR-origin components are present, they have compiled and can provide a rebuttable presumption rebuttal package meeting CBP's requirements (clear and convincing evidence that the goods were not produced using forced labor). HIGH-RISK COMMODITY CATEGORIES WITH KNOWN XUAR SUPPLY CHAIN EXPOSURE: Cotton and cotton products | Polysilicon and solar panels Tomatoes and tomato products | Garlic and other agricultural commodities Hair products | Gloves | Electronics components Aluminum and aluminum products VENDORS IN AFFECTED CATEGORIES: Must provide supply chain mapping to at least Tier 2 level for US-bound products demonstrating no XUAR-origin materials; OR a UFLPA-compliant rebuttal package pre-approved by CBP for XUAR-origin goods. DOCUMENTATION SUBMISSION: vendors@aqnova.co [Subject: UFLPA Compliance — [Product Category]] Documentation reviewed within 10 Business Days. US market listing restricted until UFLPA compliance is confirmed. |
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6.2.4 Child Labour — Absolute Prohibition
AqNova prohibits the use of child labour at any tier of the Vendor's supply chain. The ILO's Conventions C138 and C182 establish the global minimum standards that AqNova applies:
A. AqNova's Child Labour Standards
Minimum age: no worker in production of goods destined for AqNova listings may be under the age of 15 (or the legal minimum age in the country of production, whichever is higher). For light work performed outside school hours: no worker under 13 (or the applicable legal minimum for light work).
Hazardous work: absolutely no worker under the age of 18 in any hazardous work process — as defined by ILO Convention C182 and applicable national hazardous work lists. Hazardous work includes: work in mining; work with heavy machinery; exposure to hazardous chemicals; work at heights; night work.
Worst forms: AqNova treats any involvement in the worst forms of child labour (ILO C182) as a ground for immediate account termination. Worst forms include: child trafficking; debt bondage and serfdom; use in armed conflict; use in prostitution, pornography, or illicit activities; and work that harms health, safety, or morals.
Age verification: Vendors must implement age verification procedures for all production workers. Acceptable verification: government-issued birth certificate; national identity document. Records must be maintained for a minimum of 5 years.
Young workers (15–17): where young workers (aged 15–17 in jurisdictions where this is legal) are employed, Vendors must ensure: restricted working hours; no hazardous work; access to educational opportunities not disrupted; enhanced health and safety protection.
B. Remediation for Child Labour
Where child labour is identified in a Vendor's supply chain, the remediation approach must prioritize the welfare of the child:
Immediate removal from work: the child must be immediately removed from the harmful work environment.
Education support: where the child was working due to economic necessity of the family, the Vendor is expected to provide or fund access to education for the child, and where possible, wage support for the family during the child's education period.
No punitive termination: immediately dismissing child workers without welfare support and education alternatives often causes greater harm. Remediation plans must include continued welfare support.
Root cause analysis: the Vendor must identify how the child worker entered the supply chain (directly employed; subcontractor; recruitment agency failure) and implement systematic corrective measures to prevent recurrence.
6.2.5 Freedom of Association & Collective Bargaining Rights
Freedom of association and the right to collective bargaining are recognized by AqNova as foundational rights that are often most under threat in exactly the supply chains where other labour abuses are also most common. AqNova's standards:
Right to organize: workers in Vendor facilities and those of their direct suppliers must be free to form, join, and participate in trade unions or workers' associations of their own choosing, without interference, retaliation, or penalty from management.
Non-interference: management may not interfere in the formation or functioning of worker organizations, including by establishing and promoting management-controlled or 'yellow' unions designed to undermine genuine worker representation.
Collective bargaining: where workers' organizations have been duly established, management must bargain in good faith with elected worker representatives on matters of wages, working conditions, and other relevant terms of employment.
Anti-retaliation: Vendors must have a documented policy prohibiting retaliation against workers for trade union membership, organizing activities, or participation in lawful industrial action. Workers dismissed or penalized for union activities must have access to a grievance and appeal mechanism.
AqNova acknowledges that in certain jurisdictions, legal restrictions on freedom of association exist (e.g., countries with single-union systems or bans on independent trade unions). In these jurisdictions, Vendors are required at minimum to ensure workers have access to effective alternative mechanisms for collective representation — whether through works councils, workplace committees, or equivalent bodies — and that these mechanisms are genuinely independent of management control.
6.2.6 Non-Discrimination & Equal Opportunity
AqNova requires that all employment decisions in Vendor facilities and those of their direct suppliers are based solely on relevant occupational requirements — not on characteristics unrelated to a worker's ability to perform the job. AqNova's non-discrimination standard covers the following protected characteristics, as a minimum:
ILO C111 characteristics: race; colour; sex; religion; political opinion; national extraction; social origin.
Additional AqNova minimum: AqNova extends its minimum non-discrimination standard to also cover: disability; age; pregnancy or maternity; sexual orientation; gender identity and expression.
Hiring and recruitment: job advertisements, selection criteria, and recruitment processes must not directly or indirectly discriminate against applicants based on protected characteristics. AqNova prohibits pregnancy testing as a condition of employment in Vendor facilities.
Pay equity: consistent with ILO C100, equal pay for work of equal value is required. Vendors must be able to demonstrate the absence of unexplained pay differentials across protected groups, including gender pay gaps.
Migrant workers: migrant workers (including foreign contract workers in manufacturing contexts) must receive the same employment conditions as local workers in equivalent roles. Recruitment fees paid by migrant workers must not be charged — the employer bears all recruitment costs (consistent with the Dhaka Principles and the responsible recruitment framework).
6.2.7 Living Wage Commitment
A living wage is a wage that enables workers and their families to afford a decent standard of living — covering basic needs (food, housing, healthcare, education, transportation) with a modest discretionary amount. A living wage is distinct from and typically higher than the legal minimum wage, which in many manufacturing countries falls below a subsistence level.
A. AqNova's Living Wage Standard
AqNova's living wage commitment operates on a three-tier framework:
Tier 1 — Minimum floor (all Vendors): all workers in direct manufacturing operations supplying AqNova-listed products must receive at least the legal minimum wage in their country of production, including all legally required benefits and contributions. Legal minimum wages are the absolute floor — not the standard.
Tier 2 — Living wage commitment (encouraged for all, required for high-risk category Vendors): Vendors in high-risk supply chain categories (apparel, footwear, electronics assembly, agriculture, food processing) are required to make a documented living wage commitment: a time-bound, actionable plan for progressing toward payment of a living wage. AqNova recognizes that living wages cannot be mandated uniformly immediately, but requires evidence of genuine commitment and progress.
Tier 3 — Living wage achieved (recognized in AqNova's Vendor profile): Vendors who can demonstrate they pay a living wage to all direct production workers (benchmarked against the Anker Living Wage Reference Value, MIT Living Wage Calculator where applicable, or equivalent recognized benchmark) are recognized with an AqNova 'Living Wage Committed' designation in their Vendor profile.
B. Living Wage Benchmarks — By Region
| Region / Country | Primary Living Wage Benchmark & Reference |
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| Global (all countries) | Anker Research Institute Living Wage Reference Values — the most comprehensive global living wage database, covering 100+ countries with family-size adjustments. Primary reference for AqNova's living wage assessment. (ankerresearch.com) |
| United States | MIT Living Wage Calculator (livingwage.mit.edu) — county-level living wage estimates. California: additional context provided by UC Berkeley Labor Center regional living wage research. |
| United Kingdom | Living Wage Foundation — Real Living Wage (differentiated UK rate and London rate). livingwage.org.uk. |
| European Union | Minimum Wage Directive (2022/2041/EU) establishes a framework for adequate minimum wages; country-specific living wage benchmarks from Eurofound and ETUC. |
| Bangladesh | Asia Floor Wage Alliance (AFWA) — Asian Floor Wage: primary reference for garment sector living wage in Bangladesh. WageIndicator Foundation country-level data. |
| India | National Floor Level Minimum Wage; state-specific minimum wages; AFWA Asian Floor Wage for garment/textile sector; Anker Reference Values. |
| China | Provincial minimum wages (vary significantly by province and city); Anker Reference Values by region. |
| Vietnam | Regional minimum wage zones (Zones I–IV); WageIndicator data; AFWA Asian Floor Wage for garment sector. |
| Cambodia | Minimum wage for garment and footwear sector (Ministry of Labour); AFWA Asian Floor Wage. |
| Indonesia | Provincial Minimum Wage (UMP) and Sectoral Minimum Wage (UMSP); Anker Reference Values. |
| Pakistan | Provincial minimum wages; WageIndicator Foundation data. |
| Ethiopia | No statutory minimum wage in most sectors; Anker Reference Values used as benchmark. |
| Kenya | Kenya Minimum Wage Orders (sector-specific); Anker Reference Values. |
| Nigeria | National Minimum Wage (NMW) — ₦70,000/month as of 2024; Anker Reference Values. |
| South Africa | National Minimum Wage (NMW) — R27.58/hour as of 2024; Living Wage Foundation South Africa data. |
| Brazil | Salário mínimo (national); Dieese Minimum Necessary Living Wage (Salário Mínimo Necessário). |
| Mexico | Salario mínimo general; CONEVAL poverty line; Anker Reference Values. |
| Colombia | Salario mínimo mensual legal vigente (SMMLV); Anker Reference Values. |
6.2.8 Workplace Health & Safety
AqNova requires all Vendor facilities and those of their direct suppliers to maintain workplaces that are safe and healthy for all workers. AqNova's health and safety standards are based on the ILO's OSH Convention (C155) and the following minimum requirements:
A. Facility Safety Requirements
Building structural integrity: all production facilities must be structurally sound and regularly assessed for building safety risks. Following the Rana Plaza disaster (2013, Bangladesh — collapse of an eight-story garment factory killing 1,134 workers), structural integrity assessment is a non-negotiable requirement for apparel and textile manufacturing facilities. AqNova supports the Bangladesh Accord successor frameworks and equivalent monitoring programs in other markets.
Fire safety: adequate fire exits, fire suppression systems, and emergency lighting; fire evacuation drills at least twice per year; no locked emergency exits during working hours; clear emergency egress paths.
Chemical safety: all hazardous chemicals must be properly labeled and stored; Safety Data Sheets (SDS) must be available in the local language for all hazardous substances; workers must receive training on chemical handling; appropriate PPE (personal protective equipment) must be provided at no cost to the worker.
Machine guarding: all dangerous machinery must have appropriate safety guards; workers must be trained in safe machine operation; lockout/tagout procedures must be in place for machinery maintenance.
Ventilation and lighting: adequate natural or mechanical ventilation; sufficient lighting for all work tasks; prevention of excessive heat or cold exposure.
Sanitation: clean drinking water available to all workers at all times; adequate and clean sanitation facilities; food storage and preparation areas must be clean and hygienic.
PPE: appropriate personal protective equipment (gloves, masks, ear protection, eye protection, foot protection) provided free of charge to workers and required in all hazardous tasks.
B. Health & Safety Management Systems
Health and Safety Committee: facilities with 10 or more workers should have a joint management-worker Health and Safety Committee with authority to identify and address hazards.
Incident reporting: all workplace accidents, injuries, and near-misses must be recorded; serious injuries and fatalities must be reported to AqNova within 72 hours.
Occupational health: access to first aid at all times during working hours; workers in high-risk occupations must have access to periodic health monitoring.
Pregnancy and maternity: pregnant workers must not be assigned to hazardous tasks; maternity leave entitlements must be at least as generous as the applicable legal minimum.
6.2.9 Working Hours & Rest
Excessive and compulsory overtime is one of the most common labour standards violations in global supply chains. AqNova's working hours standards:
Maximum regular hours: regular working hours must not exceed 48 hours per week (consistent with ILO Convention C001 on Hours of Work in Industry).
Maximum total hours (including overtime): total working hours including overtime must not exceed 60 hours per week, except in genuinely exceptional circumstances (not as regular practice).
Overtime voluntariness: all overtime must be voluntary — workers must have the right to decline overtime without penalty, demotion, or dismissal. Compulsory overtime is treated as a forced labour indicator.
Overtime pay: overtime hours must be compensated at a premium rate consistent with applicable law (typically 125–150% of the regular rate). Compensatory time off instead of premium pay must not be used unless explicitly agreed with the worker and permitted by law.
Rest periods: workers must receive at least one rest day per seven-day period (consistent with ILO C014). Daily rest between shifts of at least 11 hours.
Annual leave: workers must receive the legally required annual leave entitlement, which must be taken (not bought out as a standard practice).
Order season management: AqNova acknowledges that production peaks create pressure on working hours. AqNova encourages production planning that avoids forcing chronic overtime through late or last-minute orders. AqNova's Vendor performance assessment takes supply chain working hours compliance into account.
6.2.10 Supply Chain Mapping — Tier Disclosure Requirements
Supply chain mapping — the systematic identification of all suppliers and subcontractors who contribute to a product's production — is the foundation of effective supply chain due diligence. AqNova's mapping requirements recognize that full traceability is a process, not an immediate achievement:
A. Tiered Mapping Requirements
| Supply Chain Mapping — AqNova's Tier Requirements ALL VENDORS — TIER 1 MAPPING (Mandatory): All Vendors must identify and disclose their Tier 1 suppliers (direct suppliers — the entities that directly supply the Vendor with goods or services used in the production of AqNova-listed products). Required information: supplier legal name; country; city/region; number of workers; primary product/service supplied. HIGH-RISK CATEGORY VENDORS — TIER 2 MAPPING (Required): Vendors in high-risk product categories (see Section 6.2.12) must also identify their Tier 2 suppliers (suppliers of their Tier 1 suppliers — one step further upstream in the supply chain). Required information: supplier legal name; country; primary product supplied; relationship to the Tier 1 supplier. ENCOURAGED — TIER 3+ MAPPING: AqNova encourages all Vendors to extend supply chain mapping beyond Tier 2, particularly for high-risk commodities where forced labour risk is concentrated at raw material extraction level (mining; cotton picking; cocoa farming). Third-party tools: SourceMap; Sedex; Open Supply Hub; TrusTrace; etc. PUBLICATION ON SUPPLIER LISTS: Vendors who publish their Tier 1 supplier list publicly (on their website or through the Open Supply Hub at opensupplyhub.org) are recognized in their AqNova Vendor profile as 'Supply Chain Transparent.' This recognition is a competitive advantage on a platform where Buyers are seeking genuinely transparent sustainable brands. SUPPLY CHAIN CHANGES: Vendors must notify AqNova within 30 days of any material change to their Tier 1 supplier base (addition or removal of a significant supplier). |
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B. Supply Chain Questionnaire (SCQ)
All Vendors in high-risk supply chain categories must complete AqNova's Supply Chain Questionnaire (SCQ) at onboarding and on an annual basis. The SCQ collects the following information:
6.2.11 Supplier Audit Program — Requirements & Recognized Standards
Third-party audits of manufacturing facilities are a key tool for verifying labour standards compliance. AqNova's audit requirements balance the need for reliable verification with the practical and financial constraints faced by small and medium-sized Vendors.
A. Audit Requirements by Vendor Category
| Vendor Category | Audit Requirement & Frequency |
|---|---|
| All Vendors (baseline) | Vendors must disclose any third-party audit of their own facilities or those of their direct suppliers conducted within the preceding 24 months. Where an audit has been conducted, the audit report summary (findings and corrective actions) must be shared with AqNova. Where no audit has been conducted, the Vendor must complete AqNova's Supply Chain Questionnaire (SCQ) and provide a self-assessment. |
| High-risk category Vendors (apparel, footwear, electronics assembly, mining/minerals, agricultural raw materials, leather, seafood) | Third-party audit of at least Tier 1 facilities within the preceding 24 months is required as a condition of listing in high-risk categories. If a current audit is not available, the Vendor must commit to arranging one within 90 days of listing activation in the high-risk category. Audits must be conducted by an AqNova-recognized audit body (see below). |
| Vendors above defined revenue thresholds on the Platform (top 10% of revenue) | Annual audit of Tier 1 production facilities; bi-annual audit of Tier 2 facilities in high-risk commodity categories. AqNova may contribute to audit cost-sharing arrangements for eligible Vendors. |
| Vendors subject to national mandatory due diligence requirements (EU CSDDD; German LkSG; Australian Modern Slavery Act; etc.) | Compliance with applicable national due diligence requirements is a condition of the Vendor Agreement. Audit reports and due diligence documentation produced pursuant to national law must be shared with AqNova. |
B. AqNova-Recognized Audit Standards
AqNova recognizes the following audit standards as satisfying its third-party audit requirement. Audits conducted under recognized standards by accredited audit bodies do not need to be replicated for AqNova compliance purposes:
Sedex Members Ethical Trade Audit (SMETA) — 2-pillar or 4-pillar: the world's most widely used social audit standard. 2-pillar covers Labour and Health & Safety; 4-pillar adds Environment and Business Ethics. AqNova accepts SMETA 4-pillar as the most comprehensive option. Audit results shared through the Sedex platform (sedex.com).
SA8000 (Social Accountability International): a certifiable standard based on ILO conventions covering child labour, forced labour, health and safety, freedom of association, discrimination, disciplinary practices, working hours, and compensation. SA8000 certification is the Tier 1 status for AqNova's social audit recognition.
amfori BSCI (Business Social Compliance Initiative) Audit: sector audit standard widely used in retail supply chains. BSCI audit results shared through the amfori platform.
Fair Wear Foundation Brand Performance Check: applicable for apparel and footwear Vendors. FWF's brand performance system evaluates brand-level sourcing practices rather than just factory audits.
ICS (Initiative for Compliance and Sustainability): audit standard used by European retailers.
WRAP (Worldwide Responsible Accredited Production): apparel and footwear factory certification program.
RBA (Responsible Business Alliance) VAP Audit: applicable for electronics and technology supply chains.
Rainforest Alliance Farm / Supply Chain Audit: for agricultural commodities.
Global G.A.P. and SQF: for food and agricultural supply chains.
AIM-PROGRESS Member Audits: AIM-PROGRESS is a forum of leading fast-moving consumer goods companies that share third-party audit results, reducing audit fatigue for shared suppliers.
6.2.12 High-Risk Country & Commodity Framework
AqNova's high-risk supply chain framework identifies the countries and commodity sectors where the risk of forced labour, child labour, and other serious labour rights violations is elevated based on the most current international intelligence. Vendors in high-risk categories are subject to enhanced due diligence requirements as set out in this Policy.
A. High-Risk Commodities (Global)
| Commodity / Sector | Key Risk Profile & AqNova's Enhanced Requirements |
|---|---|
| Apparel, Garments & Footwear | Among the highest-risk sectors globally. Key risks: excessive overtime; wage theft; gender-based discrimination; restriction of freedom of association; precarious employment. High-risk sourcing countries: Bangladesh, Cambodia, Pakistan, India, Ethiopia, Myanmar, Indonesia, Vietnam, China. REQUIRED: SMETA, SA8000, or BSCI audit of Tier 1 production facility within 24 months; Tier 2 mapping of fabric/yarn suppliers. |
| Electronics & Technology Hardware | Significant forced labour and child labour risks in raw material extraction (cobalt in DRC; tin and tantalum in conflict zones); assembly facility overtime and restriction of freedom of association (particularly in China and Southeast Asia). REQUIRED: RBA VAP audit; conflict minerals due diligence per EU Regulation 2017/821/EU; UFLPA compliance for US market. |
| Cotton & Textiles | Forced labour risks in cotton harvesting in Uzbekistan (historically) and Xinjiang, China (UFLPA); child labour in India (Sumangali scheme risks); pesticide exposure risks. REQUIRED: GOTS or BCI certification for cotton sourcing; UFLPA compliance for US market; origin documentation to at minimum field level. |
| Cocoa & Chocolate | Child labour prevalence in West Africa (Côte d'Ivoire, Ghana) — over 1.5 million children estimated in cocoa farming. REQUIRED: Rainforest Alliance Certified or Fairtrade International certification for cocoa-derived products; supply chain mapping to farm level where possible. |
| Coffee & Tea | Child labour and forced labour risks in coffee and tea growing regions. REQUIRED: Rainforest Alliance Certified, Fairtrade International, or UTZ Certified for coffee and tea products. |
| Palm Oil | Forced labour and child labour documented on palm oil plantations in Malaysia and Indonesia; land rights violations affecting indigenous communities. REQUIRED: RSPO (Roundtable on Sustainable Palm Oil) certification — RSPO Mass Balance minimum, RSPO Identity Preserved preferred. |
| Seafood & Aquaculture | Severe forced labour documented on fishing vessels globally; child labour in small-scale fishing communities; trafficked workers on commercial vessels. REQUIRED: MSC (Marine Stewardship Council) or ASC (Aquaculture Stewardship Council) certification; vessel flagging and registration documentation for imported seafood. |
| Precious Metals & Gems | Artisanal and small-scale mining (ASM) of gold, diamonds, and coloured gemstones frequently involves child labour and unsafe conditions. REQUIRED: Kimberley Process for diamonds; Responsible Jewellery Council certification; Fairmined or Fairtrade Gold certification for artisanal gold. |
| Natural Rubber | Child labour and forced labour documented in natural rubber production in Thailand, Côte d'Ivoire, and Cambodia. REQUIRED: FSC or PEFC certification for rubber products; origin documentation. |
| Leather | Hide sourcing linked to abattoirs with poor conditions in some markets; tannery chemical pollution and worker exposure. REQUIRED: Leather Working Group (LWG) certification; chemical compliance per REACH/ZDHC guidelines. |
B. Conflict-Affected and High-Risk Areas (CAHRA)
Products sourced from, or containing materials from, Conflict-Affected and High-Risk Areas (CAHRAs) are subject to AqNova's highest level of supply chain due diligence. AqNova applies the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas as its primary framework for CAHRA sourcing:
EU Conflict Minerals Regulation (2017/821/EU): applies to EU importers of tin, tungsten, tantalum, and gold (3TG) from CAHRAs. AqNova requires EU-market Vendors dealing in 3TG-containing products to demonstrate compliance with the Regulation.
US Dodd-Frank Act Section 1502: US SEC rule on conflict minerals. AqNova monitors compliance for applicable publicly-traded Vendor entities.
Specific materials: cobalt (primarily from DRC — child labour documented in artisanal mines); lithium (from 'Lithium Triangle' — Chile, Bolivia, Argentina — environmental and indigenous rights risks); diamonds (Kimberley Process required).
6.2.13 Specific Global Legislative Requirements
The following mandatory legislative requirements apply to Vendors operating in or selling to specific markets. Compliance with applicable law is a baseline requirement — AqNova's own standards are in many respects more demanding:
| Legislation / Jurisdiction | Requirements & AqNova's Response |
|---|---|
| UK Modern Slavery Act 2015 (s. 54) | Commercial organisations supplying goods or services in the UK with a global annual turnover of GBP 36 million or more must publish an annual Modern Slavery Statement covering their actions to prevent slavery and trafficking in their operations and supply chains. Statement must be approved by the Board and signed by a Director. AqNova requires qualifying Vendors to provide their Modern Slavery Statement URL. AqNova publishes its own annual Modern Slavery Statement at [aqnova.co/responsibility/modern-slavery]. |
| Australia Modern Slavery Act 2018 | Entities with consolidated revenue above AUD $100 million that are based in Australia or carry on business there must submit an annual Modern Slavery Statement to the Minister for Home Affairs for inclusion in the Commonwealth Modern Slavery Register. AqNova assesses its own threshold applicability annually. |
| Canada S-211 — Fighting Against Forced Labour and Child Labour Act (2023) | Effective January 1, 2024: government institutions and private sector entities (meeting threshold criteria: listed on a Canadian stock exchange; or meeting both the assets/revenue/employees criteria under the CBCA) must report annually on steps taken to prevent and reduce the risk of forced or child labour in their supply chains. |
| US — UFLPA & Tariff Act § 1307 | Section 307 of the US Tariff Act prohibits importation of goods produced by forced labour. The UFLPA (2021) creates a rebuttable presumption for XUAR-origin goods. AqNova prohibits listing of products where the Vendor cannot demonstrate UFLPA compliance for US-market goods. See Section 6.2.3.C. |
| California — SB 657 (Transparency in Supply Chains Act) | Retailers and manufacturers with global annual revenues above USD $100 million that do business in California must disclose their efforts on their website to eradicate slavery and human trafficking from their direct supply chains. AqNova's own disclosure is at [aqnova.co/responsibility/supply-chains]. Qualifying Vendors must have their own disclosure. |
| Germany — LkSG (Lieferkettensorgfaltspflichtengesetz, 2023) | Companies with 1,000 or more employees in Germany must conduct risk-based human rights and environmental due diligence across their supply chains; establish a complaint mechanism; and prepare an annual due diligence report. Non-German companies supplying into German supply chains are subject to due diligence requirements through the cascade effect. AqNova may request LkSG compliance documentation from large Vendors. |
| France — Loi de Vigilance (Law 2017-399) | Large French companies (5,000+ employees in France or 10,000+ worldwide) must publish and implement a vigilance plan (plan de vigilance) identifying and preventing serious violations of human rights, fundamental freedoms, health and safety, and environmental harms in their operations and supply chains. |
| Norway — Transparency Act (Åpenhetsloven, 2022) | Larger enterprises offering goods and services in Norway must conduct human rights due diligence consistent with the UNGPs and OECD Guidelines; publish an annual due diligence account; and respond to information requests from anyone who asks about their due diligence practices. |
| EU CSDDD (2024/1760/EU) | The EU Corporate Sustainability Due Diligence Directive requires in-scope EU and non-EU companies to conduct due diligence on actual and potential adverse human rights and environmental impacts in their supply chains; establish a complaint mechanism; and prepare an annual report. AqNova monitors its own threshold applicability and that of large Vendor partners. |
| Brazil — Labour Ministry 'Dirty List' | Brazil's List of Employers with Slave-Like Work (Lista Suja do Trabalho Escravo) — maintained by the Ministry of Labour and Employment — identifies employers found to have used slave-like working conditions. AqNova monitors this list and prohibits active listing of products from Vendors on the Dirty List. |
6.2.14 Vendor Self-Declaration & Annual Certification
As a condition of listing on the AqNova Platform, all Vendors must make and maintain the following declarations regarding ethical sourcing:
| AqNova Vendor Ethical Sourcing Self-Declaration By activating a Vendor account on AqNova Marketplace and on an annual certification basis thereafter, each Vendor represents and warrants that: 1. LABOUR STANDARDS: To the best of the Vendor's knowledge and belief, all production facilities involved in the manufacture of products listed on AqNova comply with AqNova's Ethical Sourcing Standards, including the ILO Core Conventions on forced labour, child labour, freedom of association, non-discrimination, and equal remuneration. 2. NO FORCED LABOUR: The Vendor does not use, and has no knowledge of its Tier 1 suppliers using, forced labour, debt bondage, human trafficking, or any form of modern slavery. 3. NO CHILD LABOUR: The Vendor does not use, and has no knowledge of its Tier 1 suppliers using, child labour in violation of ILO Conventions C138 and C182 or applicable national minimum age laws. 4. LEGAL COMPLIANCE: All direct production operations comply with applicable national labour laws in each country of manufacture, including minimum wage, working hours, occupational health and safety. 5. SUPPLY CHAIN DUE DILIGENCE: The Vendor has conducted, or is in the process of conducting, reasonable due diligence on its supply chain consistent with AqNova's Supply Chain Mapping requirements (Section 6.2.10) and applicable national mandatory due diligence laws. 6. AUDIT DISCLOSURE: The Vendor has disclosed all third-party audits of its own facilities and those of its Tier 1 suppliers conducted within the preceding 24 months, including findings and corrective actions. 7. INCIDENT REPORTING: The Vendor will notify AqNova within 72 hours of becoming aware of any material labour rights violation (forced labour, child labour, major health and safety incident) in its direct supply chain. 8. MODERN SLAVERY STATEMENT: Where required by applicable law (UK Modern Slavery Act; Australia Modern Slavery Act; Canada S-211; California SB 657), the Vendor has published or will publish the applicable mandatory disclosure statement. This declaration is made annually through the Vendor Dashboard > Compliance > Annual Self-Certification. Providing false information in this declaration is a material breach of the Vendor Agreement. |
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6.2.15 Grievance Mechanisms & Worker Voice
Effective grievance mechanisms enable workers to raise concerns about labour rights violations without fear of retaliation. AqNova's standards for worker grievance mechanisms, consistent with the UN Guiding Principles on Business and Human Rights (Pillar III: Access to Remedy):
A. Vendor Facility Grievance Mechanism Requirements
Legitimacy: the mechanism must be operated by or in cooperation with management and recognized by workers as credible and independent.
Accessibility: accessible to all workers — including migrant workers and those without formal contracts — in languages understood by workers at the facility.
Predictability: a clear, documented procedure for receiving, investigating, and responding to grievances, with defined timeframes for each stage.
Equitable access: workers must be able to access the mechanism without first having to engage with supervisors who may themselves be the subject of the complaint.
Transparency: workers should know how the mechanism operates and can track the progress of their complaints.
Rights-compatible: the mechanism must not compromise the right of workers to seek other remedies (e.g., trade union representation; legal action; regulatory reporting) or condition resolution on agreeing not to pursue other remedies.
Anonymous reporting: facilities must provide a channel for anonymous complaints (suggestion box; anonymous hotline; third-party hotline such as the ILO's or an industry-specific confidential worker helpline).
B. AqNova's External Grievance Channel for Workers
AqNova provides an external channel through which workers in Vendor supply chains can report labour rights concerns directly to AqNova — outside of the Vendor's own grievance process. This channel is particularly important where the Vendor's own mechanism is inadequate or where the complaint relates to conduct by the Vendor itself.
How to report: workers, worker advocates, NGOs, and trade unions may submit labour rights concerns about products or supply chains connected to AqNova by emailing compliance@aqnova.co [Subject: Supply Chain Worker Report — [Country/Product Category]].
AqNova's response: AqNova acknowledges all supply chain worker reports within 5 Business Days and initiates investigation. Where a credible concern is identified, AqNova engages with the Vendor and, where appropriate, the relevant trade union, NGO, or government labor authority.
Non-retaliation: AqNova's policy prohibits any form of retaliation by Vendors against workers who report labour rights concerns through AqNova's external channel. Confirmed retaliation is grounds for account termination.
6.2.16 Corrective Action Planning
When a labour standards violation is identified — whether through audit, self-disclosure, supply chain questionnaire, worker grievance, or AqNova's monitoring — AqNova's default approach is to support remediation rather than to immediately terminate the Vendor relationship. The exception is serious violations (forced labour, child labour worst forms, workplace fatality due to gross negligence) where immediate suspension or termination is the appropriate response.
A. Corrective Action Plan (CAP) Framework
Non-conformance grading: AqNova adopts a three-tier non-conformance grading system: Critical (immediate risk to life or liberty; forced labour; child labour worst forms); Major (significant non-conformance with a clear path to remediation: excessive overtime; wage underpayment; freedom of association violation; significant health and safety deficiency); Minor (technical non-conformances with low harm potential: documentation gaps; minor procedural issues).
Critical non-conformances: immediate listing suspension. Vendor provided with a 30-day window to demonstrate full remediation of the critical issue, or listing remains suspended and account is reviewed for termination.
Major non-conformances: listing may remain active while a Corrective Action Plan (CAP) is developed and agreed within 10 Business Days. CAP must include: specific corrective actions for each major finding; responsible person for each action; target completion date; verification method. AqNova conducts follow-up verification within 90 days of CAP agreement.
Minor non-conformances: CAP developed within 30 days; completion within 90 days. AqNova may conduct verification at next scheduled audit cycle.
CAP non-completion: failure to complete a CAP within agreed timelines results in escalation to a higher severity classification and listing suspension.
B. AqNova's Support for Remediation
AqNova recognizes that many Vendors — particularly small and medium enterprises — may lack the capacity to address complex supply chain issues in isolation. AqNova provides the following remediation support:
Training resources: AqNova's Vendor Learning Center includes training modules on ethical sourcing, supply chain due diligence, living wage calculation, worker grievance mechanisms, and forced labour risk assessment.
Tool sharing: AqNova provides access to AqNova-vetted third-party tools for supply chain mapping, risk assessment, and audit management (including partnerships with Open Supply Hub and Sedex).
Industry collaboration: for systemic issues in specific countries or commodity sectors, AqNova collaborates with industry associations, multi-stakeholder initiatives (Fair Wear Foundation; ACT — Action, Collaboration, Transformation; Better Work ILO-IFC), and peer marketplace platforms to address root causes collectively.
6.2.17 Ethical Sourcing Enforcement
AqNova's enforcement of the Ethical Sourcing Policy is proportionate to the severity of the violation and the Vendor's response to remediation:
| Violation Category | Enforcement Response |
|---|---|
| CRITICAL — Forced labour confirmed in direct operations or Tier 1 supply chain | Immediate listing suspension within 24 hours of confirmation. Account review for permanent termination. Referral to applicable law enforcement (CBP for UFLPA; relevant national law enforcement authority). Worker welfare interventions coordinated with NGO partners where possible. No relisting without full remediation verified by independent audit. |
| CRITICAL — Child labour (worst forms: trafficking, prostitution, hazardous work) confirmed | Immediate listing suspension; permanent account termination; referral to law enforcement and child protection authorities. AqNova cooperates with NCMEC (US), ILO/IPEC, and applicable national child protection agencies. |
| CRITICAL — Child labour (general) confirmed in direct operations | Immediate listing suspension. 30-day window for child welfare remediation plan (education, family support). Full independent audit required. Listing restored only upon verified remediation. |
| MAJOR — Significant labour standards violation (excessive overtime; wage theft; freedom of association suppression; major health and safety deficiency) | Listing active with Corrective Action Plan (CAP) agreed within 10 Business Days. 90-day remediation window with follow-up verification. Failure to remediate: listing suspension. |
| NON-DISCLOSURE — Failure to complete Supply Chain Questionnaire or audit disclosure | Listing in high-risk category suspended until SCQ is completed. Standard category listings: 30-day completion notice before suspension. |
| FALSE DECLARATION — Knowingly false ethical sourcing self-declaration | Immediate account suspension. Investigation. Confirmed false declaration: permanent account termination. AqNova may refer matter to applicable regulatory authority. |
| UFLPA violation — US-bound product with XUAR-origin component without rebuttal package | Immediate geo-block for US market. 30-day window to provide UFLPA-compliant documentation. Failure: permanent US market geo-block; account review. |
| Modern Slavery Act non-compliance (UK/Australia/Canada threshold companies) | Warning; 30-day window to provide compliant statement. Failure: account suspension for qualifying markets. |
6.2.18 Contact Information — Ethical Sourcing
| AqNova — Ethical Sourcing Policy Contacts SUPPLY CHAIN QUESTIONNAIRE SUBMISSION: vendors@aqnova.co [Subject: SCQ Submission — [Vendor Name]] AUDIT REPORT DISCLOSURE: vendors@aqnova.co [Subject: Audit Report — [Vendor Name] — [Audit Date]] UFLPA COMPLIANCE DOCUMENTATION: vendors@aqnova.co [Subject: UFLPA Compliance — [Product Category]] MODERN SLAVERY STATEMENT URLs: vendors@aqnova.co [Subject: Modern Slavery Statement — [Vendor Name]] WORKER SUPPLY CHAIN GRIEVANCE REPORTS (External Channel): compliance@aqnova.co [Subject: Supply Chain Worker Report — [Country/Category]] LIVING WAGE COMMITMENT / DOCUMENTATION: compliance@aqnova.co [Subject: Living Wage — [Vendor Name]] CORRECTIVE ACTION PLAN SUBMISSION: compliance@aqnova.co [Subject: CAP Submission — [Vendor Name] — [Issue]] ETHICAL SOURCING ADVISORY: compliance@aqnova.co [Subject: Ethical Sourcing Advisory] ANNUAL ETHICAL SOURCING SELF-CERTIFICATION: Vendor Dashboard > Compliance > Annual Self-Certification AQNOVA MODERN SLAVERY STATEMENT: [aqnova.co/responsibility/modern-slavery] AQNOVA SUPPLY CHAINS DISCLOSURE: [aqnova.co/responsibility/supply-chains] KEY EXTERNAL RESOURCES: ILO Conventions: ilo.org/international-labour-standards US DOL ILAB List: dol.gov/agencies/ilab/reports/child-labor/list-of-goods US CBP WROs & UFLPA: cbp.gov/trade/forced-labor UK Modern Slavery Registry: modern-slavery-statement-registry.service.gov.uk Australia Modern Slavery: modernslaveryregister.gov.au Open Supply Hub: opensupplyhub.org Anker Living Wage Data: ankerresearch.com LEGAL NOTICES: legal@aqnova.com Registered Office: Arivon Holding Corporation C/O Arivon Holding Corporation, 2571 Saturn Avenue, Unit #265 Huntington Park, CA 90255, USA California File Number: B20250418195 | EIN: 41-3210066 | 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 | Global Legal Footer Framework | Section 6.2: Ethical Sourcing Policy
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