Human Rights Policy
AqNova Marketplace Policies & Disclosures
AQNOVA MARKETPLACE
Global Legal Footer Framework
Comprehensive Compliance & Platform Governance Reference
HUMAN RIGHTS POLICY
Aligned with the UN Guiding Principles on Business & Human Rights
Extending Beyond Modern Slavery — A Comprehensive Human Rights Framework
Arivon Holding Corporation | AqNova Marketplace
Effective Date: April 7, 2026 | Version 1.0
| "Business has the power to lift communities or to exploit them. AqNova exists to be the former — a platform that creates genuine, dignified economic opportunity for every person in its ecosystem, and that refuses to profit from the suffering of any human being, anywhere in the world." — AqNova Leadership Team |
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This Human Rights Policy ("the Policy") sets out AqNova Marketplace's comprehensive commitment to respecting, protecting, and advancing human rights across all dimensions of our global operations — as a technology platform, as an employer, as a marketplace facilitator, and as a corporate citizen.
This Policy is aligned with the United Nations Guiding Principles on Business and Human Rights (UNGPs, 2011) — the globally recognized framework for business and human rights — and goes materially beyond a conventional Modern Slavery Statement. It addresses the full spectrum of internationally recognized human rights that are relevant to a global e-commerce platform operating across more than 25 jurisdictions, including civil and political rights, economic, social and cultural rights, labor rights, digital rights, Indigenous peoples' rights, and environmental rights.
This Policy is a standalone document. It is distinct from and supplements the AqNova DEI Statement (Section 6A), the Anti-Discrimination Policy (Section 6B), and the Sustainability & Ethical Standards Policy (Section 6D). Where those documents address related matters, cross-references are provided.
| Policy Scope — Who and What This Policy Covers This Policy applies to: (a) Arivon Holding Corporation and all operating entities under the AqNova brand; (b) All employees, contractors, and temporary workers engaged by AqNova globally; (c) All Vendors listing products on the AqNova Platform; (d) All supply chain participants — manufacturers, processors, raw material suppliers — whose products appear on the Platform; (e) All technology partners, payment processors, logistics providers, and third-party integrators; (f) All Buyers, insofar as Platform interactions implicate human rights (e.g., data privacy, accessibility); (g) Communities affected by AqNova's operations or the operations of its value chain partners. |
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6C.1.1 UN Guiding Principles on Business & Human Rights (UNGPs)
The UN Guiding Principles on Business and Human Rights ("UNGPs"), endorsed unanimously by the UN Human Rights Council in Resolution 17/4 (June 2011) and developed under Special Representative John Ruggie, constitute the most authoritative global framework for business and human rights. The UNGPs are structured around three foundational pillars, which provide the architecture for this Policy:
| PILLAR 1 — THE STATE DUTY TO PROTECT States must protect against human rights abuses by third parties, including business enterprises, through appropriate policies, regulation, and adjudication. AqNova acknowledges this duty and commits to operating in a manner that supports — rather than undermines — states' ability to fulfill it. Where laws fall below international human rights standards, AqNova will apply international standards as its operational baseline. |
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| PILLAR 2 — THE CORPORATE RESPONSIBILITY TO RESPECT Business enterprises have an independent responsibility to respect human rights — meaning to avoid infringing on the human rights of others, and to address adverse human rights impacts with which they are involved. This responsibility exists independently of states' abilities or willingness to fulfill their own human rights obligations, and applies across all of AqNova's global operations and value chain relationships. |
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| PILLAR 3 — ACCESS TO REMEDY Those whose human rights are negatively affected by business activity must have access to effective remedy — both through judicial mechanisms (courts, tribunals) and non-judicial mechanisms (grievance platforms, ombudsman, mediation, industry bodies). AqNova commits to providing and supporting access to effective remedy for all persons affected by AqNova's activities or those of its value chain. |
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6C.1.2 Core International Human Rights Instruments
AqNova's human rights commitments are grounded in the full corpus of internationally recognized human rights standards, including:
| Instrument | Key Rights Relevant to AqNova |
|---|---|
| Universal Declaration of Human Rights (UDHR, 1948) | Foundation of all international human rights law. Articles 1–30 establish the full range of civil, political, economic, social, and cultural rights to which all people are entitled. |
| International Covenant on Civil & Political Rights (ICCPR, 1966) | Right to life; freedom from torture; freedom of expression; privacy rights; right to fair trial; right to non-discrimination; freedom of association. Directly relevant to platform governance, data privacy, and vendor/worker relations. |
| International Covenant on Economic, Social & Cultural Rights (ICESCR, 1966) | Right to work and fair conditions; right to education; right to health; right to adequate standard of living; right to participation in cultural life. Relevant to AqNova's economic opportunity mission and supply chain responsibilities. |
| ILO Declaration on Fundamental Principles & Rights at Work (1998) | Eight fundamental ILO Conventions covering: freedom of association; collective bargaining; elimination of forced/compulsory labor; abolition of child labor; elimination of discrimination. These form the non-negotiable baseline for all AqNova vendor and supply chain relationships. |
| UN Convention on the Rights of the Child (UNCRC, 1989) | Rights of children including protection from economic exploitation and hazardous labor; right to education; right to protection from abuse. Directly governs AqNova's child labor prohibition and age verification requirements. |
| UN Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW, 1979) | Prohibits discrimination against women in all areas of life. Relevant to AqNova's gender equity commitments in workforce, vendor program, and supply chain. |
| UN Convention on the Rights of Persons with Disabilities (CRPD, 2006) | Guarantees equal rights for persons with disabilities including in employment, education, and access to information and services. Directly governs AqNova's platform accessibility commitments. |
| UN Declaration on the Rights of Indigenous Peoples (UNDRIP, 2007) | Establishes individual and collective rights of Indigenous peoples, including rights to land, culture, identity, language, employment, health, education, and Free, Prior and Informed Consent (FPIC). Relevant to AqNova's Indigenous vendor and sourcing policies. |
| OECD Guidelines for Multinational Enterprises (2023 Update) | Responsible business conduct guidelines covering human rights, labor, environment, anti-corruption, and supply chain due diligence for multinational enterprises. |
| UN Global Compact Ten Principles | AqNova aligns its operations with the UNGC Ten Principles covering human rights (Principles 1–2), labor (Principles 3–6), environment (Principles 7–9), and anti-corruption (Principle 10). |
6C.2 Human Rights Due Diligence Framework
Under UNGP Principle 17, business enterprises are expected to carry out human rights due diligence proportionate to the scale of their operations, the complexity of their supply chains, and the severity of their potential human rights impacts. AqNova's human rights due diligence (HRDD) framework is designed to meet — and where possible exceed — this standard.
6C.2.1 The Four Components of AqNova's HRDD Process
| Component | What AqNova Does | Frequency & Trigger |
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| 1. Identify & Assess Impacts | Map actual and potential adverse human rights impacts across AqNova's own operations and value chain using a salient issues approach (see Section 6C.3). Assess severity, likelihood, and AqNova's degree of involvement (cause, contribution, or direct linkage). | Annual full assessment + ad hoc assessment upon material changes to operations, market entry, or supply chain. |
| 2. Integrate & Act | Translate findings from the assessment into concrete policies, contractual requirements, operational procedures, and management systems. Prioritize action based on severity of impact and AqNova's leverage to address it. | Continuous. Integration timelines set at assessment; reviewed quarterly. |
| 3. Track & Monitor | Monitor the effectiveness of AqNova's human rights responses through quantitative and qualitative indicators, vendor audits, grievance data analysis, independent assurance, and stakeholder feedback. | Ongoing; formal review annually with results incorporated into Human Rights Report. |
| 4. Communicate & Report | Publish an annual Human Rights Report addressing findings from the HRDD process, progress against commitments, grievances received and resolved, and material human rights incidents and responses. | Annual publication by June 30 each year. |
6C.2.2 Mandatory Disclosure Frameworks
AqNova's HRDD approach is informed by and designed to comply with the following mandatory human rights disclosure and due diligence regulations:
| Jurisdiction / Law | Applicable HRDD Requirement |
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| EU Corporate Sustainability Due Diligence Directive (CSDDD, 2024/1760/EU) | Requires large companies operating in the EU to conduct mandatory human rights and environmental due diligence across their entire value chain, including identification, prevention, mitigation, and accountability for adverse impacts. Requires a transition plan and civil liability for harm caused through failure of due diligence. |
| EU Corporate Sustainability Reporting Directive (CSRD) | Requires detailed sustainability reporting including human rights matters under ESRS S1 (Own Workforce), S2 (Workers in Value Chain), S3 (Affected Communities), and S4 (Consumers and End-Users). Applies to qualifying AqNova EU entities. |
| EU Forced Labour Regulation (2024/3015) | Prohibits placing products made with forced labour on the EU market; establishes an investigation and market ban procedure. Directly governs AqNova's vendor and supply chain screening obligations. |
| EU Conflict Minerals Regulation (2017/821) | Responsible sourcing of tin, tantalum, tungsten, and gold from conflict-affected and high-risk areas. Applies to any AqNova vendor supplying qualifying products. |
| UK Modern Slavery Act 2015 (s. 54) | Requires commercial organizations with UK annual turnover of GBP 36M+ to publish an annual Modern Slavery Statement. AqNova publishes a comprehensive statement exceeding the minimum disclosure requirements (see Section 6C.5). |
| UK Bribery Act 2010 | Prohibits bribery; requires adequate procedures to prevent bribery in commercial operations and supply chains. |
| Germany — Supply Chain Due Diligence Act (LkSG, 2023) | Requires companies with 1,000+ employees to conduct HRDD in their own operations and direct suppliers, covering forced labor, child labor, discrimination, wages, safety, environmental harms, and freedom of association. Applies to AqNova's German market operations above applicable thresholds. |
| France — Duty of Vigilance Law (Loi de Vigilance, 2017) | Requires large French companies to establish and publish a vigilance plan covering human rights, fundamental freedoms, health/safety, and environment across their operations and supply chains. Informs AqNova's France market operations. |
| Norway — Transparency Act (Åpenhetsloven, 2022) | Requires Norwegian enterprises and foreign enterprises selling to Norwegian consumers to conduct HRDD and publish findings. Applies to AqNova's Norway market sales. |
| Canada — Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211, 2024) | Requires reporting entities to publish an annual report on steps taken to prevent and reduce forced and child labour in their supply chains. Applies to qualifying AqNova Canadian entities. |
| Australia — Modern Slavery Act 2018 | Requires entities with consolidated revenue AUD 100M+ to report annually on modern slavery risks and actions taken. Informs AqNova's Australia market operations. |
| United States — Uyghur Forced Labor Prevention Act (UFLPA, 2022) | Creates a rebuttable presumption that goods manufactured in Xinjiang, China, or by entities on the UFLPA Entity List, are produced with forced labor and are prohibited from US import. Directly governs AqNova's supply chain screening. |
| United States — California Transparency in Supply Chains Act (SB 657) | Requires retail sellers and manufacturers doing business in California with global annual revenues of USD 100M+ to disclose their efforts to eradicate slavery and human trafficking from their direct supply chains. |
| Brazil — National Plan to Eradicate Slave Labour | Brazil's ongoing national framework for combating work analogous to slavery (trabalho escravo). AqNova prohibits sourcing from entities on Brazil's "Dirty List" (Lista Suja) of employers found to use slave labor. |
6C.3 AqNova's Salient Human Rights Issues
"Salient human rights issues" are those human rights that face the most severe potential negative impact through an enterprise's activities and business relationships, whether as a cause, contributor, or through direct linkage. AqNova has identified the following as its salient human rights issues based on its global assessment:
| Salient Issue | Basis for Salience — Why This Matters for AqNova |
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| 1. Forced & Compelled Labor | AqNova's supply chain spans agricultural, artisanal, textile, and manufacturing sectors in regions with documented forced labor risk (South/Southeast Asia, West Africa, Central Asia, Latin America). Platform products include product categories (seafood, textiles, cocoa, palm oil, cotton, electronics) historically associated with forced labor risks. |
| 2. Child Labor | Similar supply chain geographies carry child labor risk. AqNova's product categories include agriculture, artisan crafts, and manufacturing where child labor has been documented in global supply chains. The severity of harm — impact on children's development, health, and education — makes this a highest-priority salient issue. |
| 3. Labor Rights — Freedom of Association & Collective Bargaining | Many of AqNova's vendor sourcing markets restrict workers' rights to form and join unions or to bargain collectively. Suppression of these rights is linked to wage theft, unsafe conditions, and exploitation. AqNova's scale creates both risk and leverage. |
| 4. Digital Rights & Privacy | As a global data-collecting platform, AqNova processes personal data of millions of users. Surveillance, data exploitation, algorithmic profiling, and unauthorized data transfer are human rights risks inherent in digital platform operation. Data privacy is a human right recognized under ICCPR Art. 17 and regional human rights instruments. |
| 5. Discrimination & Unequal Access | Algorithmic systems, linguistic barriers, financial exclusion, and platform design can create and perpetuate discriminatory access to economic opportunity. This affects vendors from underrepresented communities and buyers facing barriers to equal participation. |
| 6. Women's Rights & Gender-Based Violence in Supply Chains | Women make up the majority of workers in many of AqNova's priority supply chain sectors (garment, agricultural, domestic care products). They face disproportionate risk of wage discrimination, sexual harassment, unsafe conditions, and exclusion from decision-making. |
| 7. Indigenous Peoples' Rights | AqNova sources products from vendors in Indigenous-led production traditions and culturally significant regions. Without proper safeguards, commercial exploitation of Indigenous knowledge, cultural property, and land-based resources can occur, violating UNDRIP principles. |
| 8. Migrant & Refugee Worker Rights | Global supply chains disproportionately employ migrant and refugee workers, who face heightened vulnerability to wage theft, debt bondage, document confiscation, and discrimination. This risk is acute in AqNova's sourcing regions in South/Southeast Asia, the Gulf, and West Africa. |
| 9. Safe & Healthy Working Conditions | Workers producing goods sold on AqNova — including in domestic manufacturing, artisanal production, and warehousing and logistics — have the right to safe and healthy workplaces. Occupational injury and illness represent both a human rights harm and a legal liability. |
| 10. Access to Remedy | Affected workers, communities, and users must have accessible and effective channels to raise concerns and seek remedy for human rights harms linked to AqNova's platform or value chain. Inadequate grievance mechanisms are themselves a human rights gap. |
6C.4.1 ILO Core Labor Standards Baseline
AqNova's minimum labor standards baseline for all vendors and supply chain partners is the ILO Declaration on Fundamental Principles and Rights at Work (1998), which encompasses the eight fundamental ILO Conventions covering four core areas:
Freedom of Association and the Right to Collective Bargaining (ILO Conventions 87 and 98): Workers must have the right to form and join trade unions and to bargain collectively, free from interference, intimidation, or retaliation. Vendors operating in jurisdictions that restrict these rights must implement alternative mechanisms to allow workers to voice concerns and participate in decisions affecting their employment.
Elimination of Forced and Compulsory Labor (ILO Conventions 29 and 105): No vendor or supply chain partner may use, benefit from, or facilitate forced labor, bonded labor, debt bondage, prison labor in violation of international standards, or any other form of compelled work in the production of goods listed on AqNova.
Abolition of Child Labor (ILO Conventions 138 and 182): No child under the age of 15 (or the local school-leaving age, whichever is higher) may be employed in the production of goods listed on AqNova. No person under 18 may be employed in hazardous work, as defined by ILO Convention 182 and the relevant national hazardous work list.
Elimination of Discrimination (ILO Conventions 100 and 111): All workers must receive equal pay for work of equal value. No worker may be subject to discrimination in employment on the basis of race, color, sex, religion, political opinion, national origin, or social origin. Vendors must extend this principle to all protected characteristics recognized under applicable national law.
6C.4.2 Fair Wages
AqNova requires all vendors and direct supply chain partners to pay workers at minimum the legally mandated minimum wage in their jurisdiction, without deduction through wage theft, unlawful deductions, or sham "productivity" schemes that reduce effective wages below the legal minimum. AqNova additionally encourages vendors to pay a living wage — defined as a wage sufficient to meet the basic needs of a worker and their family — and will prioritize vendors demonstrating a commitment to living wage standards in Platform curation and marketing.
AqNova recognizes that minimum wages in many operating jurisdictions fall below living wage benchmarks. AqNova will publish living wage benchmarks for major sourcing regions in its Annual Human Rights Report and will use its commercial relationships and convening power to advocate for progress toward living wages across its value chain.
6C.4.3 Working Hours & Rest
Vendors must comply with applicable national laws on maximum working hours, mandatory rest periods, and overtime compensation. In the absence of adequate national law, vendors must adhere to the ILO standard of a maximum 48-hour regular work week, with overtime not exceeding 12 hours per week and all overtime compensated at a premium rate. Workers must be able to refuse overtime without retaliation.
6C.4.4 Occupational Health & Safety
All vendors and supply chain partners must provide workers with a safe and healthy working environment consistent with ILO Convention 155 (Occupational Safety and Health Convention) and applicable national law. Specific requirements include:
Provision of appropriate personal protective equipment (PPE) at no cost to workers.
Regular health and safety training, conducted in workers' primary languages.
Functional grievance and near-miss reporting mechanisms for workers to raise safety concerns without fear of retaliation.
Compliance with applicable chemical, machinery, and electrical safety standards.
Workers' right to refuse unsafe work without penalty.
Access to appropriate medical facilities and first aid.
Special protections for pregnant and nursing workers, including right to maternity leave at minimum at the standard required by applicable law.
6C.4.5 AqNova Workforce — Employment Standards
AqNova applies the following standards to its own global workforce:
All employees receive contracts specifying terms of employment, compensation, working hours, and leave entitlements, in the primary language of their jurisdiction.
AqNova complies with all applicable national labor laws, including minimum wage, overtime, leave entitlements, and termination notice requirements.
AqNova provides safe and healthy workplaces in all jurisdictions where it maintains physical facilities.
AqNova prohibits retaliation against any employee who raises a workplace concern, reports a suspected violation of this Policy, or participates in a human rights grievance process.
AqNova will not engage contractors or temporary workers as a mechanism to deny those workers the protections they would be entitled to as direct employees, consistent with applicable misclassification laws including California AB5, EU Platform Workers Directive, and equivalent frameworks.
6C.5.1 Policy Statement
AqNova has a zero-tolerance policy for modern slavery in all its forms — including chattel slavery, debt bondage, forced or compulsory labor, labor trafficking, sex trafficking, domestic servitude, and forced marriage — in its own operations and throughout its entire value chain. Modern slavery is never a cost of doing business. It is a crime and a fundamental violation of human dignity that AqNova will not tolerate, facilitate, or ignore.
This section constitutes AqNova's Modern Slavery Statement for the purposes of the UK Modern Slavery Act 2015 (s. 54), the Australian Modern Slavery Act 2018, the California Transparency in Supply Chains Act (SB 657), Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211), and equivalent mandatory disclosure frameworks.
6C.5.2 Risk Assessment — High-Risk Sectors & Geographies
Based on AqNova's global HRDD process and recognized international benchmarks (including the Global Slavery Index, the US Department of Labor List of Goods Produced by Child Labor or Forced Labor, and the ILO Special Action Program to Combat Forced Labour), the following product categories and geographies carry heightened modern slavery risk for AqNova's value chain:
| Risk Category | Identified High-Risk Indicators |
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| Textiles & Apparel | Garment manufacturing in Bangladesh, Myanmar, Cambodia, Pakistan; cotton sourcing in Xinjiang (China — UFLPA rebuttable presumption applies); stitching units employing home-based workers in India and Pakistan. |
| Agricultural Products | Cocoa in West Africa (Ghana, Ivory Coast — documented child labor); palm oil in Indonesia and Malaysia; seafood in Southeast Asia (Thailand, Philippines — documented labor trafficking on fishing vessels); coffee and tea in East Africa. |
| Artisanal & Small-Scale Mining | Gold, cobalt, coltan, and mica in DRC, Madagascar, and parts of West Africa — documented child labor and hazardous conditions. |
| Electronics Components | Supply chains involving cobalt (battery technology), rare earth elements, and PCB manufacturing in high-risk regions. |
| Domestic & Care Products | Supply chains involving migrant domestic workers — particularly in Gulf Cooperation Council (GCC) countries operating under the Kafala (sponsorship) system, which creates structural conditions for labor exploitation. |
| Fast-Moving Consumer Goods (FMCG) | Supply chains involving seasonal agricultural workers, including undocumented and migrant laborers in North Africa, Southern Europe, and Latin America. |
6C.5.3 Vendor Screening & Contractual Safeguards
AqNova implements the following measures to identify and mitigate modern slavery risks in its vendor and supply chain relationships:
Pre-Onboarding Screening: All new vendors are screened against AqNova's prohibited-party database, OFAC/SDN lists, EU and UN sanctions lists, Brazil's Lista Suja, and sector-specific risk databases. Vendors in high-risk product categories and geographies undergo enhanced due diligence.
Contractual Prohibitions: All Vendor Agreements include a binding Modern Slavery and Forced Labor clause requiring vendors to: (a) warrant compliance with ILO Conventions 29 and 105 (forced labor) and Conventions 138 and 182 (child labor); (b) provide supply chain transparency on request; (c) permit AqNova to conduct or commission audits; and (d) notify AqNova of any discovered violation within 48 hours.
Supply Chain Mapping: AqNova requires vendors in high-risk categories to disclose their Tier 1 suppliers and, where feasible and material, Tier 2 and Tier 3 suppliers. This mapping is maintained in AqNova's supply chain transparency database and updated annually.
Third-Party Audits: AqNova engages accredited third-party social compliance auditors to conduct facility audits of high-risk vendors and supply chain participants. Audit protocols include private worker interviews conducted away from management, to enable workers to report conditions freely.
Certification Requirements: For product categories with established certification schemes (e.g., Fairtrade International, Rainforest Alliance, Better Cotton Initiative, Responsible Jewellery Council), AqNova gives preference to certified vendors and will require certification as a condition of listing in specified high-risk categories by 2027.
6C.5.4 Survivor-Centered Approach
AqNova recognizes that addressing modern slavery requires centering the voices and experiences of survivors. Our survivor-centered commitments include:
Ensuring that grievance mechanisms for reporting suspected modern slavery are accessible to workers — including undocumented migrant workers and workers who may fear retaliation — through anonymous, multilingual channels.
Partnering with survivor-led organizations and NGOs specializing in labor trafficking and forced labor to inform our HRDD processes and audit protocols.
Not automatically canceling vendor relationships upon discovery of forced labor violations in their supply chains, where doing so would harm affected workers. Instead, AqNova will engage vendors in time-bound remediation, with exit only where remediation fails.
Cooperating fully with law enforcement and regulatory authorities investigating modern slavery in connection with products on the AqNova Platform.
6C.6.1 UNICEF Children's Rights & Business Principles
AqNova aligns its approach to children's rights with the UNICEF Children's Rights and Business Principles (CRBP), which extend beyond prohibition of child labor to encompass the full range of ways that business can respect and support children's rights across its operations and value chain.
6C.6.2 Child Labor — Zero Tolerance
AqNova maintains an absolute prohibition on child labor in its own operations and across its vendor and supply chain relationships. This prohibition is consistent with ILO Conventions 138 and 182 and is defined as follows:
No child under 15 years of age (or the local minimum school-leaving age, if higher) may perform any work — paid or unpaid — in connection with the production, processing, or transportation of goods listed on AqNova.
No young person under 18 may perform hazardous work — defined as any work likely to harm their health, safety, or morals — as specified in ILO Convention 182 and applicable national hazardous work lists.
"Light work" performed by children aged 13–15 that does not interfere with schooling and is compliant with national law does not constitute child labor under ILO standards; however, AqNova does not rely on this exception in high-risk sourcing contexts.
6C.6.3 Child Protection in Platform Design
AqNova's commitment to children's rights extends to the design and operation of the Platform itself:
AqNova prohibits any product listing that endangers, exploits, or sexualizes children in any way.
AqNova does not knowingly collect personal data from children under 13 (US COPPA standard) or under 16 (EU GDPR Article 8 standard), and implements age verification mechanisms accordingly.
AqNova maintains a zero-tolerance policy for child sexual abuse material (CSAM) on the Platform and will immediately remove any such content, preserve evidence, and report to the National Center for Missing & Exploited Children (NCMEC) in the US and equivalent authorities globally, consistent with legal reporting obligations in each jurisdiction.
AqNova prohibits the listing of any product that could be used for child grooming or exploitation, including products that may appear innocuous but are marketed or commonly used to facilitate harm to children.
6C.7.1 Women's Rights in the Value Chain
Women constitute the majority of workers in many of AqNova's priority supply chain sectors. They are disproportionately represented in the lowest-paid, most precarious, and most vulnerable roles in global supply chains — and are disproportionately subject to gender-based discrimination, sexual harassment, pregnancy discrimination, and wage gaps. AqNova's commitment to women's rights in its value chain includes:
Requiring vendors to implement and enforce sexual harassment prevention policies that meet or exceed applicable national law and the ILO Violence and Harassment Convention (C190, 2019).
Requiring vendors to prohibit discrimination on the basis of pregnancy, maternity, marital status, and family responsibilities — consistent with ILO Convention 183 (Maternity Protection) and CEDAW.
Actively sourcing from and supporting women-owned enterprises across all operating regions, with specific targets set out in the Supplier Diversity Program (DEI Statement, Section 6A).
Ensuring that worker interview protocols used in social compliance audits include gender-sensitive approaches and create safe spaces for women workers to report gender-based violations.
6C.7.2 Gender-Based Violence & Harassment (GBVH)
Gender-based violence and harassment (GBVH) in the workplace — including physical, verbal, psychological, and sexual abuse — constitutes a violation of fundamental human rights. AqNova's commitments include:
Maintaining a zero-tolerance policy for GBVH in AqNova's own workplace in all jurisdictions.
Requiring vendors to demonstrate effective prevention, reporting, and response mechanisms for GBVH consistent with ILO Convention C190 and applicable national law (including India's POSH Act 2013, South Africa's Employment Equity Act, Brazil's Lei Maria da Penha, and equivalents).
Reporting on GBVH-related grievances received through AqNova's own grievance mechanisms in the Annual Human Rights Report, in appropriately aggregated and anonymized form.
6C.8.1 UN Declaration on the Rights of Indigenous Peoples (UNDRIP)
AqNova recognizes and affirms the rights of Indigenous peoples as set out in the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP, 2007), including:
The right to self-determination and the right to maintain, control, protect, and develop their cultural heritage, traditional knowledge, and traditional cultural expressions.
The right to maintain, protect, and develop their cultural heritage including traditional medicines, biodiversity, and traditional knowledge.
The right to Free, Prior and Informed Consent (FPIC) before any decision is made that may affect their territories, lands, resources, or cultural and spiritual significance.
The right to maintain, control, protect, and develop their intellectual property over such cultural heritage, traditional knowledge, and traditional cultural expressions.
6C.8.2 Free, Prior and Informed Consent (FPIC)
AqNova requires that any product on the Platform that incorporates, is derived from, or makes commercial use of Indigenous cultural heritage, traditional knowledge, sacred symbols, place names, or biological resources held by an Indigenous community must demonstrate that it has obtained Free, Prior and Informed Consent (FPIC) from the relevant community authority. FPIC means:
Free: Consent given voluntarily and without coercion, manipulation, or intimidation.
Prior: Consent obtained before any commercial activity commences — not retroactively.
Informed: Consent based on full and accurate information about the nature, scope, scale, and purpose of the commercial activity.
Vendors claiming FPIC must be able to provide documented evidence of the consent process and the community authority that granted it, in a form that AqNova's compliance team can verify.
6C.8.3 Indigenous Cultural Heritage & Appropriation
AqNova prohibits the listing of products that constitute cultural appropriation — the unauthorized commercial exploitation of Indigenous cultural elements for profit without benefit to the originating community. AqNova will:
Maintain a list of product categories and design elements subject to heightened Indigenous cultural heritage review, developed in consultation with Indigenous rights organizations.
Remove products found to constitute cultural appropriation upon notification by an affected Indigenous community or recognized representative body.
Promote authentic Indigenous-owned enterprises on the Platform and provide dedicated visibility and support to Indigenous vendor communities in Canada, Australia, the United States, Latin America, and other applicable markets.
6C.9 Migrant & Refugee Worker Rights
Migrant and refugee workers are among the most economically vital and most human rights-vulnerable populations in global supply chains. Their vulnerability arises from multiple sources: documentation status, language barriers, distance from family and support networks, dependency on employers for housing, and in some systems, structural legal frameworks (such as the Kafala system in the Gulf) that tie legal residency to a single employer.
6C.9.1 AqNova's Migrant Worker Standards
AqNova requires all vendors and supply chain partners employing migrant and/or refugee workers to adhere to the following minimum standards, consistent with the International Organization for Migration (IOM) Ethical Recruitment Framework and the Dhaka Principles for Migrant Worker Recruitment:
Zero tolerance for document confiscation: No employer may retain workers' passports, identity documents, or work permits as a condition of employment or to restrict freedom of movement.
Zero tolerance for recruitment fees: Workers must never be required to pay recruitment fees to obtain employment — consistent with the "employer pays" principle. Any such fees constitute debt bondage and are prohibited.
Freedom of movement: Workers must be free to leave their employer and the country of employment within applicable legal requirements, and must not be subject to threats, deposit schemes, or other mechanisms that restrict this freedom.
Language-accessible terms of employment: All employment contracts must be provided in a language the worker understands prior to their departure from their country of origin.
Access to grievance mechanisms in workers' languages: AqNova's supply chain grievance channel is available in multiple languages specifically to enable migrant workers to report concerns.
Non-discrimination: Migrant and refugee workers must receive the same wages, benefits, and working conditions as national workers doing equivalent work.
6C.10 Digital Rights & Privacy as Human Rights
The right to privacy is enshrined in Article 17 of the International Covenant on Civil and Political Rights (ICCPR), Article 12 of the Universal Declaration of Human Rights, and Article 8 of the European Convention on Human Rights. The UN Human Rights Council has recognized, in Resolutions 20/8, 26/13, and 32/13, that the same rights people have offline must also be protected online.
6C.10.1 Privacy as a Human Right
AqNova treats data privacy not merely as a legal compliance obligation, but as a human rights commitment. The mass collection, exploitation, and unauthorized transfer of personal data — including purchasing behavior, location data, biometric data, and communications — can facilitate surveillance, discrimination, identity theft, and political persecution. AqNova's privacy-as-human-rights commitments include:
Collecting only the minimum personal data necessary for Platform operation and legal compliance (data minimization).
Never selling personal data of users to third parties for commercial use.
Never cooperating with government requests for user data except where required by a valid legal process from a competent authority, after exhausting all available legal challenges. AqNova will notify affected users of government data requests where legally permitted to do so.
Conducting human rights impact assessments (HRIAs) for any new data collection, processing, or sharing initiative that could create heightened risk for users in vulnerable political or social contexts.
Publishing a Transparency Report annually, disclosing government data requests received, challenges made, and data provided.
Article 19 of the ICCPR protects freedom of expression, including the right to seek, receive, and impart information and ideas of all kinds. As a platform, AqNova's content moderation decisions can affect this right. AqNova commits to:
Applying content moderation rules that are transparent, consistently enforced, and subject to appeal — consistent with the Manila Principles on Intermediary Liability and the Santa Clara Principles on Transparency and Accountability in Content Moderation.
Ensuring that algorithmic systems do not systematically suppress legitimate expression or commercial activity on the basis of the identity or political views of the user or vendor.
Conducting human rights impact assessments before making material changes to Platform content moderation policies that could affect freedom of expression.
6C.10.3 Algorithmic Accountability
Automated decision-making systems can amplify or create human rights violations — including discriminatory profiling, manipulation of consumer choice, suppression of minority vendors, and facilitation of surveillance. AqNova commits to:
Conducting annual algorithmic impact assessments examining the human rights implications of AqNova's recommendation, search, fraud detection, and pricing algorithms.
Ensuring that no algorithmic system makes consequential decisions about users or vendors based on protected characteristics, including race, religion, national origin, gender, disability, or sexual orientation.
Complying with the EU AI Act (2024/1689) risk classification requirements for automated decision-making systems deployed in the EU, including transparency, human oversight, and non-discrimination obligations.
Maintaining the right of any user or vendor subject to a significant algorithmic decision to request human review of that decision.
6C.11 Environmental Rights & the Right to a Healthy Environment
The UN General Assembly declared access to a clean, healthy and sustainable environment a universal human right in Resolution 76/300 (July 2022). The UN Human Rights Council recognized this right in Resolution 48/13 (October 2021). Environmental degradation — including air and water pollution, deforestation, climate change, and toxic contamination — disproportionately affects Indigenous peoples, low-income communities, and communities of color. AqNova treats environmental rights as human rights.
6C.11.1 Environmental Human Rights Commitments
AqNova will not knowingly source from or feature vendors whose production activities have been credibly linked to displacement of communities, contamination of water sources, deforestation of Indigenous territories, or other environmental harms that deprive communities of their environmental rights.
AqNova supports the rights of environmental human rights defenders and will not knowingly feature products from enterprises that have engaged in or benefited from threats, harassment, or violence against environmental activists.
AqNova will conduct environmental human rights screening as part of its supply chain due diligence in high-risk product categories, including palm oil, timber, rubber, mining outputs, and soy.
AqNova will publicly support the Escazu Agreement (Regional Agreement on Access to Information, Public Participation and Justice in Environmental Matters in Latin America and the Caribbean) and its principles in its Latin America market operations.
AqNova commits to carbon-neutral platform operations by 2030 and will report annually on progress, consistent with the science-based targets initiative (SBTi) methodology.
6C.12 Jurisdiction-by-Jurisdiction Legal Compliance Framework
AqNova's human rights commitments are underpinned by binding legal obligations across all jurisdictions where it operates. The following table maps the primary human rights-related legal obligations by region:
6C.12.1 United States
| Law / Regulation | Human Rights Relevance |
|---|---|
| Trafficking Victims Protection Act (TVPA, 2000 & amendments) | Federal law prohibiting human trafficking, with civil liability provisions for corporations that benefit from trafficking ventures. Directly governs AqNova's supply chain obligations. |
| Uyghur Forced Labor Prevention Act (UFLPA, 2022) | Creates a rebuttable presumption that goods produced in Xinjiang involve forced labor. AqNova prohibits listing products subject to UFLPA import bans. |
| California Transparency in Supply Chains Act (SB 657) | Requires disclosure of efforts to eradicate slavery and human trafficking from direct supply chains for qualifying California companies. |
| Federal Acquisition Regulation (FAR) 22.17 | Prohibits trafficking in persons in federal contractor operations worldwide. Applicable where AqNova or affiliates hold federal contracts. |
| Dodd-Frank Act s. 1502 (Conflict Minerals) | Disclosure obligations for SEC registrants regarding use of conflict minerals (3TG) from the DRC region. Informs AqNova's conflict minerals supply chain policy. |
6C.12.2 European Union
| Law / Directive | Human Rights Relevance |
|---|---|
| EU Corporate Sustainability Due Diligence Directive (CSDDD, 2024) | Mandatory HRDD obligation across value chains; civil liability for harm caused through HRDD failure. Phased implementation from 2027. |
| EU Forced Labour Regulation (2024/3015) | Market ban on products made with forced labor. AqNova's supply chain screening must satisfy investigation and traceability requirements. |
| EU Corporate Sustainability Reporting Directive (CSRD) | Detailed human rights reporting under ESRS standards for qualifying entities. |
| EU AI Act (2024/1689) | Risk-based regulation of AI systems including algorithmic decision-making tools deployed on EU users. |
| EU Whistleblower Protection Directive (2019/1937) | Mandatory whistleblower protection for employees reporting breaches of EU law, including human rights violations. |
| EU Charter of Fundamental Rights | Applies to EU institutions and EU member states when implementing EU law. AqNova aligns its EU operations with Charter rights including dignity, equality, solidarity, and citizens' rights. |
6C.12.3 United Kingdom
| Law | Human Rights Relevance |
|---|---|
| Modern Slavery Act 2015 | Annual Modern Slavery Statement requirement for qualifying commercial organizations; Section 54 transparency in supply chains obligation. |
| Human Rights Act 1998 | Incorporates European Convention on Human Rights into UK law. Rights relevant to AqNova include right to privacy (Art. 8), freedom of expression (Art. 10), and prohibition of slavery (Art. 4). |
| Equality Act 2010 | Comprehensive equality and non-discrimination law covering nine protected characteristics in employment and services. |
| Bribery Act 2010 | Anti-corruption obligations with extraterritorial reach across global supply chain relationships. |
6C.12.4 Canada
| Law | Human Rights Relevance |
|---|---|
| Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211, 2024) | Annual reporting on steps taken to prevent and reduce forced labor and child labor in supply chains. Applies to qualifying entities. |
| Canadian Human Rights Act | Prohibits discriminatory practices by federal employers and service providers on 13 protected grounds. |
| Crimes Against Humanity and War Crimes Act | Provides a legal basis for prosecution of crimes against humanity, including systematic enslavement. |
| Indigenous Rights — UNDRIP Implementation | Canada enacted the United Nations Declaration on the Rights of Indigenous Peoples Act (2021), formally incorporating UNDRIP obligations into Canadian law. Directly governs AqNova's engagement with Indigenous vendors and communities in Canada. |
6C.12.5 Africa
| Country / Instrument | Human Rights Relevance |
|---|---|
| African Charter on Human and Peoples' Rights (Banjul Charter, 1981) | Foundational regional human rights instrument recognizing individual rights and peoples' rights across all AU member states. |
| Nigeria — Trafficking in Persons (Prohibition) Enforcement and Administration Act (TIPPEA) 2015 | Comprehensive anti-trafficking legislation; prohibits forced and child labor in commercial contexts. |
| South Africa — Constitution (Chapter 2, Bill of Rights) | Comprehensive rights including human dignity, equality, privacy, and labor rights. AqNova's South Africa operations comply with this Bill of Rights framework. |
| Kenya — Counter Trafficking in Persons Act 2010 | Anti-trafficking framework applicable to commercial operations sourcing from or operating in Kenya. |
| Ghana — Human Trafficking Act 2005 (Act 694) | Prohibits trafficking in persons; creates obligations relevant to AqNova's Ghana market operations. |
6C.12.6 Latin America
| Country / Law | Human Rights Relevance |
|---|---|
| Brazil — Constitutional Art. 149; Penal Code Art. 149 (Trabalho Escravo) | Criminalizes work analogous to slavery. Brazil's Lista Suja (Dirty List) of offending employers is a key screening tool for AqNova's Brazilian supply chain. |
| Brazil — National Pact for the Eradication of Slave Labour | Multi-stakeholder framework for combating forced labor in Brazil's supply chains. AqNova endorses its principles. |
| Colombia — Law 985/2005 (Anti-Trafficking) | Colombia's anti-trafficking legislation applicable to commercial operations. |
| Chile — Law 20.507 (Anti-Trafficking) | Establishes trafficking offenses and preventive obligations. |
| Escazu Agreement (2018) | Regional treaty on environmental rights and environmental defenders in Latin America and the Caribbean. AqNova supports its principles in regional operations. |
6C.12.7 Asia-Pacific
| Country / Law | Human Rights Relevance |
|---|---|
| Australia — Modern Slavery Act 2018 | Annual modern slavery reporting for entities with consolidated revenue AUD 100M+. AqNova complies with reporting obligations for qualifying entities. |
| Australia — Criminal Code Act 1995 (Div. 270–271) | Federal criminal offences of slavery, sexual servitude, deceptive recruiting, and forced labor. |
| India — Bonded Labour System (Abolition) Act 1976; Child Labour (Prohibition and Regulation) Act 1986 (as amended 2016) | Prohibit bonded labor and child labor in India. Directly relevant to AqNova's Indian supply chain sourcing. |
| India — Companies Act 2013 (s. 135, CSR) | Corporate Social Responsibility requirements including human rights and labor protections for qualifying Indian entities. |
| Japan — Act on Promotion of Supply Chain Due Diligence (proposed) | Japan's developing mandatory supply chain HRDD framework, informed by OECD Guidelines. AqNova monitors developments for compliance planning. |
| Thailand — Decent Work Act 2019 and Fisheries Act amendments | Key legislation addressing labor rights in Thailand's fishing and manufacturing sectors — historically high-risk for AqNova's supply chain categories. |
6C.13 Grievance Mechanisms & Access to Remedy
UNGP Principle 29 establishes that business enterprises should establish or participate in effective operational-level grievance mechanisms for individuals and communities who may be adversely impacted by their operations. These mechanisms must be: legitimate; accessible; predictable; equitable; transparent; rights-compatible; a source of continuous learning; and based on engagement and dialogue.
6C.13.1 AqNova's Operational Grievance Channels
| Stakeholder Group | Grievance Channel & Process |
|---|---|
| Supply Chain Workers | Anonymous multilingual hotline available via web form, SMS, and QR code posted at audited facilities. Available in: English, French, Spanish, Portuguese, Yoruba, Swahili, Hindi, Bangla, Thai, Tagalog, Mandarin, and Arabic. All reports reviewed within 5 Business Days; substantive investigations initiated within 10 Business Days. |
| Vendors | humanrights@aqnova.co — dedicated human rights concerns channel. Vendor Appeals Panel reviews substantive disputes. AqNova Human Rights team responds within 5 Business Days. |
| Employees | Internal HR grievance system; anonymous ethics hotline; external ombudsman (to be appointed within 18 months of Platform launch); escalation to Human Rights Lead. |
| Buyers / Consumers | support@aqnova.co; Platform complaint form; national consumer protection agencies; EU ODR platform. |
| Communities | humanrights@aqnova.co; direct engagement with AqNova's Human Rights team; AqNova Human Rights Advisory panel. |
| Whistleblowers | Secure anonymous digital reporting platform compliant with EU Whistleblower Protection Directive (2019/1937), UK Public Interest Disclosure Act 1998 (PIDA), and equivalent national frameworks. No retaliation permitted under any circumstances. |
6C.13.2 Remedy Standards
Where AqNova has caused or contributed to an adverse human rights impact, AqNova commits to providing or facilitating access to appropriate remedy. Remedy may take different forms depending on the nature of the harm:
Restitution: Restoring the affected person to the situation before the harm occurred (e.g., reinstatement of a wrongly terminated worker).
Compensation: Providing financial or other material compensation proportionate to the harm suffered, including medical costs, lost income, and other quantifiable losses.
Rehabilitation: Providing medical, psychological, or social support to address the effects of harm.
Satisfaction: Public acknowledgment of the violation and a commitment to non-repetition.
Guarantees of Non-Repetition: Systemic changes to policies, processes, or business relationships to prevent recurrence.
AqNova will never use non-disclosure agreements (NDAs), financial settlements, or other mechanisms to silence victims of human rights abuses or to prevent the public disclosure of systemic violations. Confidentiality of grievance reporters will be maintained unless the reporter consents to disclosure or disclosure is required by law.
6C.13.3 Cooperation with Judicial & Regulatory Remediation
AqNova commits to fully cooperating with judicial and regulatory processes for human rights remediation, including investigations by national human rights commissions, labor inspectorates, ombudsman bodies, and courts. AqNova will not assert jurisdictional defenses or procedural barriers as a mechanism to avoid substantive accountability for human rights violations in its operations or value chain.
6C.14.1 Human Rights Governance Structure
Board Oversight: The Board of Directors (or equivalent governance body) receives annual reporting on human rights performance and has responsibility for oversight of this Policy. Human rights risks are included in AqNova's enterprise risk register.
Executive Accountability: The CEO has primary executive accountability for human rights outcomes. Human rights KPIs are incorporated into executive performance objectives.
Human Rights Lead: AqNova will appoint a dedicated Human Rights Lead or equivalent function within 18 months of Platform launch, responsible for HRDD program management, Policy implementation, grievance system oversight, and Annual Human Rights Report production.
Human Rights Advisory Panel: An external panel comprising recognized human rights experts, civil society representatives, and supply chain labor specialists will be established to provide independent guidance and challenge. Panel composition will be published.
Legal & Compliance Team: AqNova's General Counsel has responsibility for legal compliance with mandatory human rights disclosure and due diligence frameworks across all jurisdictions.
6C.14.2 Annual Human Rights Report
AqNova will publish an Annual Human Rights Report by June 30 of each year, covering the preceding calendar year. The Report will be structured to meet the disclosure requirements of the UK Modern Slavery Act, Australia Modern Slavery Act, Canada S-211, EU CSRD (ESRS S1-S4), and equivalent frameworks. Content will include:
Summary of HRDD activities conducted during the year, including due diligence scope and methodology.
Salient human rights issues assessment and updates, including any new risks identified.
Modern Slavery and Forced Labor Statement (satisfying all applicable mandatory disclosure requirements).
Supply chain mapping progress — percentage of value chain mapped to Tier 1, Tier 2, and Tier 3.
Vendor audit findings — number of audits, findings by category, and remediation status.
Grievances received, investigated, and resolved — disaggregated by type and region, with aggregate data on remedy provided.
Any material human rights incidents that occurred, the response taken, and lessons learned.
Workforce human rights data including gender pay gap (qualifying jurisdictions), safety incident rates, and labor rights compliance findings.
Progress against all commitments set out in this Policy, with year-over-year trend data.
Human rights commitments and priorities for the following year.
6C.14.3 Policy Review & Update Cycle
This Human Rights Policy will be reviewed and updated annually, or more frequently in response to: changes in applicable law; new mandatory due diligence frameworks entering into force; material changes to AqNova's operations, markets, or supply chain; findings from the Annual Human Rights Report; or recommendations from the Human Rights Advisory Panel. All updates will be published on AqNova's Human Rights portal at [aqnova.co/humanrights] with a clear change log and effective date.
6C.15 Contact Information & Reporting Channels
| AqNova Human Rights Contacts Human Rights Policy Inquiries: humanrights@aqnova.co Supply Chain Grievance (Anonymous): [Multilingual anonymous reporting portal — aqnova.co/supply-grievance] Modern Slavery & Forced Labour: ethics@aqnova.co Child Rights Concerns: safeguarding@aqnova.co Indigenous Rights: indigenousrights@aqnova.co Digital Rights / Data Privacy: privacy@aqnova.co Whistleblower (Anonymous): [Secure anonymous platform — to be configured] General Legal & Compliance: legal@aqnova.com Employee Grievances (HR): hr@aqnova.co DEI & Discrimination Concerns: DEI@aqnova.co Human Rights Portal: aqnova.co/humanrights Annual Human Rights Report: aqnova.co/humanrights/report Supply Chain Transparency Database: aqnova.co/supply-chain-transparency Registered Office: Arivon Holding Corporation C/O Arivon Holding Corporation, 2571 Saturn Avenue, Unit #265 Huntington Park, CA 90255, USA |
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| "Human rights are not a checklist. They are the irreducible standard of how people deserve to be treated — everywhere, always, by every enterprise that touches their lives. AqNova will not hide behind complexity, distance, or the limits of visibility. Where we have power to protect human rights, we will use it." — AqNova Human Rights Commitment |
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AqNova acknowledges that the commitments in this Policy are demanding and that the distance between policy and practice is where human rights violations occur. We commit to transparency about that distance — in our Annual Human Rights Report, in our grievance data, and in our honest accounting of where we have fallen short and what we are doing about it.
This Policy is not the final word. It will be tested, challenged, and improved. We welcome that process. Anyone who believes AqNova is failing to live up to the commitments in this document is encouraged to tell us — through humanrights@aqnova.co, through our anonymous grievance channel, or through whatever means is available to them.
AqNova Marketplace | Global Legal Footer Framework | Section 6C: Human Rights Policy
Aligned with the UN Guiding Principles on Business & Human Rights (UNGPs, 2011)
© 2026 Arivon Holding Corporation. All rights reserved. Effective April 7, 2026. Version 1.0.
This Policy constitutes AqNova's Modern Slavery Statement for UK, Australian, Canadian, and California mandatory disclosure purposes. It does not constitute legal advice.