Modern Slavery Statement
AqNova Marketplace Policies & Disclosures
AQNOVA MARKETPLACE
Global Legal Footer Framework
Comprehensive Compliance & Platform Governance Reference
(MASTER — ANNUAL STATEMENT)
Published pursuant to UK Modern Slavery Act 2015 (s. 54) | Australian Modern Slavery Act 2018 | California SB 657 | Canada S-211 | Global Voluntary Disclosure
Statement Period: Financial Year Ending December 31, 2025 | Published: April 7, 2026
Arivon Holding Corporation | Operating as AqNova Marketplace
| Mandatory Reporting Frameworks — Modern Slavery & Human Trafficking UK Modern Slavery Act 2015 (s. 54): Requires commercial organisations supplying goods or services in the UK with annual global turnover of GBP 36 million or more to publish an annual Modern Slavery and Human Trafficking Transparency Statement. Must be approved by the Board of Directors (or equivalent) and signed by a Director. Required content (Home Office guidance): organisation structure and supply chains; policies in relation to slavery and human trafficking; due diligence processes; risk assessment methodology; key performance indicators; training provided. Australian Modern Slavery Act 2018: Requires entities with consolidated revenue of AUD $100 million or more that are based in Australia, or carry on business in Australia, to submit an annual Modern Slavery Statement to the Minister for Home Affairs for inclusion in the Commonwealth Modern Slavery Register. Seven mandatory reporting criteria. California Transparency in Supply Chains Act (SB 657, 2010): Requires retailers and manufacturers with global annual revenues above USD $100 million doing business in California to disclose on their website their efforts to eradicate slavery and human trafficking from their direct supply chains. Canada Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211, in force January 1, 2024): Requires applicable entities to report annually on steps taken to prevent and reduce the risk of forced labour or child labour in their supply chains. EU Forced Labour Regulation (2024/3015/EU — applicable from 2027): Prohibits placing on the EU market or exporting from the EU products made with forced labour. Monitoring applicability and preparing for compliance. UN Guiding Principles on Business and Human Rights (UNGPs, 2011): Framework for corporate responsibility to respect human rights and provide remedy. AqNova's modern slavery framework is calibrated to the UNGPs. OECD Guidelines for Multinational Enterprises (2023 revision): Due diligence guidance for responsible business conduct in supply chains. US Uyghur Forced Labor Prevention Act (UFLPA, 2021) & Tariff Act s. 307: Prohibition on importation of goods produced with forced labour. (See Ethical Sourcing Policy, Section 6.2.3.C for full UFLPA detail.) ILO Conventions: C029 (Forced Labour) | C105 (Abolition) | C138 (Minimum Age) | C182 (Worst Forms of Child Labour) | ILO Protocol P029 to the Forced Labour Convention | ILO Indicators of Forced Labour (11 operational indicators) UN Convention Against Transnational Organized Crime (UNTOC) & Palermo Protocol (Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, 2000) |
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| Board Approval & CEO Statement This Modern Slavery and Human Trafficking Statement has been prepared pursuant to Section 54 of the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018, and constitutes AqNova's annual transparency statement for the financial year ending December 31, 2025. This Statement has been reviewed and approved by the Board of Directors of Arivon Holding Corporation. SIGNED BY A DIRECTOR OF ARIVON HOLDING CORPORATION: [Authorised Signatory — Director] Arivon Holding Corporation 2571 Saturn Avenue, Unit #265 Huntington Park, CA 90255, USA DATE OF BOARD APPROVAL: April 7, 2026 This Statement is published at: [aqnova.co/responsibility/modern-slavery] and has been submitted to the UK Modern Slavery Statement Registry at: modern-slavery-statement-registry.service.gov.uk OUR COMMITMENT: AqNova has zero tolerance for forced labour, child labour, human trafficking, and all other forms of modern slavery in our own operations and supply chains. Where we identify such issues, we will respond with urgency and transparency. |
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This Modern Slavery and Human Trafficking Statement covers Arivon Holding Corporation (operating as AqNova Marketplace), its controlled entities (including Sahara Eagle Ltd, Nigeria), and all supply chain activities connected to AqNova's operations for the financial year ending December 31, 2025. It is published in compliance with applicable mandatory reporting obligations and voluntarily for all jurisdictions where AqNova operates regardless of mandatory threshold applicability.
AqNova is a global e-commerce marketplace for sustainable, organic, and ethically sourced household products. The Platform connects Buyers and Vendors across 25+ countries, facilitating cross-border transactions in product categories including food and beverages, cosmetics and personal care, textiles and apparel, household goods, and electronics. The nature of AqNova's business model — enabling third-party Vendor sales globally — means that AqNova's supply chain exposure extends across dozens of countries and hundreds of product categories, each with different modern slavery risk profiles.
| Section 7.3 — Structure (UK Modern Slavery Act s. 54 / Australian Modern Slavery Act Mandatory Criteria) CRITERION 1 — Organisation Structure, Business & Supply Chains (Section 7.3.1) CRITERION 2 — Policies in Relation to Slavery & Human Trafficking (Section 7.3.2) CRITERION 3 — Due Diligence Processes in Operations & Supply Chains (Section 7.3.3) CRITERION 4 — Risk Assessment — Supply Chain Risks of Slavery & Trafficking (Section 7.3.4) CRITERION 5 — Key Performance Indicators — How AqNova Measures Effectiveness (Section 7.3.5) CRITERION 6 — Training on Slavery & Human Trafficking (Section 7.3.6) CRITERION 7 — Remediation — Actions Taken Where Violations Are Found (Section 7.3.7) ADDITIONAL — Global Regulatory Compliance Context (Section 7.3.8) ADDITIONAL — Confidential Reporting Channel (Section 7.3.9) ADDITIONAL — Annual Review & Governance (Section 7.3.10) ADDITIONAL — Contact Information (Section 7.3.11) |
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7.3.1 Organisation Structure, Business & Supply Chains
This section addresses UK Modern Slavery Act s. 54(5)(a) and Australian Modern Slavery Act Criterion 1 (identify the entity and describe its structure, operations, and supply chains).
A. Corporate Structure
| Entity | Details |
|---|---|
| Parent Entity | 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 |
| Nigerian Entity | Sahara Eagle Ltd (wholly-owned subsidiary) Registration Number: 1957145 Tax Identification Number: 31052811-0001 NEPC Registration: 0030281 |
| Platform | AqNova Marketplace — operated by Arivon Holding Corporation Global Sustainable Products Marketplace (e-commerce) |
| Principal Operating Markets | North America (US, Canada); Europe (EU Member States, UK); Africa (Nigeria, Ghana, Kenya, South Africa); Latin America (Brazil, Colombia, Mexico, Chile, Argentina); Asia-Pacific (India, Australia, Singapore, Japan, South Korea, China, Indonesia, Thailand, Vietnam, Malaysia) |
B. Business Description
AqNova Marketplace is a curated global marketplace for sustainable, organic, and ethically sourced household products. AqNova operates as an online marketplace connecting third-party Vendors (sellers) with Buyers (consumers and businesses) across 25+ jurisdictions. AqNova does not manufacture products. AqNova's business model is commission-based and SaaS subscription-based.
AqNova's role in commerce: AqNova is an intermediary — it provides the Platform infrastructure, Vendor verification, payment processing, dispute resolution, and consumer protection services. The physical supply chains (manufacturing, sourcing, logistics) belong to AqNova's Vendor community. This intermediary role creates both a limitation on AqNova's direct control over supply chains and an opportunity to use its marketplace position to drive standards improvements across a large number of supply chains simultaneously.
C. Supply Chain Overview
AqNova's supply chain operates on two levels:
AqNova's own operational supply chain (Tier 1): AqNova's direct suppliers include cloud computing and data center providers; software and SaaS vendors; payment processors; legal and professional services; marketing services; and office supplies. These operational suppliers are primarily technology companies and professional services firms in the US, EU, and UK. The modern slavery risk in AqNova's own operational supply chain is assessed as lower than in the Vendor supply chains, but is not zero.
AqNova's Vendor supply chains (the primary modern slavery risk): the Vendors who sell on AqNova operate supply chains in product categories and sourcing geographies that carry significant modern slavery risk. These include apparel and textiles (South and Southeast Asia; sub-Saharan Africa); food and agricultural products (West Africa cocoa; South Asian tea and coffee; Latin American produce); electronics (mineral extraction in Democratic Republic of Congo; assembly in Southeast Asia); cosmetics (palm oil from Malaysia and Indonesia; mica from India); and household goods (various origins).
D. Products, Services & Customer Base
Product categories on AqNova (with modern slavery risk rating):
| Product Category | Modern Slavery Risk Profile |
|---|---|
| Organic & Natural Food Products | ELEVATED: agricultural sourcing in high-risk regions; labour-intensive harvesting; seasonal migrant labour. Key risk commodities: cocoa (West Africa); coffee (Ethiopia, Colombia, Vietnam); tea (India, Kenya, Sri Lanka); spices (India, Indonesia); fresh produce (Latin America). |
| Textiles & Apparel | HIGH: garment manufacturing supply chains are among the highest modern slavery risk globally. Key risks: forced overtime; wage theft; restriction of movement; recruitment agency debt bondage; gender discrimination. Key risk countries: Bangladesh, Cambodia, Pakistan, India, Ethiopia, Myanmar. |
| Cosmetics & Personal Care | ELEVATED: mica sourcing (India — child labour documented in artisanal mines); palm oil (Malaysia, Indonesia — migrant worker forced labour risks); essential oil sourcing (various high-risk regions). |
| Electronics & Technology | ELEVATED: cobalt (Democratic Republic of Congo — child labour in artisanal mining); tin, tungsten, tantalum sourcing (conflict regions); electronics assembly (Southeast Asia — overtime, worker restriction). |
| Household Goods | MEDIUM: varies significantly by product type and sourcing region. Higher risk for products manufactured in Southeast Asia or sub-Saharan Africa in labour-intensive processes. |
| Sustainable Packaging & Eco Products | MEDIUM-LOW: higher risk where natural materials are sourced from high-risk regions (bamboo, cotton, natural rubber). Lower risk for products manufactured in Europe, North America, Australia. |
7.3.2 Policies in Relation to Slavery & Human Trafficking
This section addresses UK Modern Slavery Act s. 54(5)(b) and Australian Modern Slavery Act Criterion 2 (describe actions to assess and address modern slavery risks).
A. Core Policies Addressing Modern Slavery
AqNova's modern slavery framework is embedded across multiple policy documents that together constitute AqNova's comprehensive approach to identifying and eliminating modern slavery from its operations and supply chains:
Ethical Sourcing Policy (Section 6.2 of this Framework): AqNova's primary supply chain human rights policy. Covers: ILO Core Conventions (C029, C105, C087, C098, C100, C111, C138, C182); forced labour indicators; UFLPA compliance; child labour prohibition; freedom of association; living wage commitment; supply chain mapping; supplier audit requirements; corrective action planning.
Anti-Discrimination & Equal Access Policy (Section 7.2): prohibits discrimination in employment and supply chains consistent with ILO Conventions C100 and C111.
Vendor Agreement (Section 2.2 of the Vendor Terms): all Vendors represent and warrant, as a binding contractual obligation, that their supply chains comply with AqNova's Ethical Sourcing Standards. Vendors warrant: no forced labour; no child labour; compliance with ILO Core Conventions; supply chain due diligence; incident reporting within 72 hours of discovery.
Prohibited Items Policy (Section 5.7.2): absolutely prohibits the listing of products from UFLPA-designated entities or involving comprehensively sanctioned actors.
Sustainability & Ethical Standards (Section 6): AqNova's broader sustainability framework, which integrates human rights due diligence as an inseparable element of its sustainable marketplace mission.
B. Modern Slavery Specific Policy Commitments
| AqNova's Zero Tolerance Commitment — Modern Slavery & Trafficking AqNova ABSOLUTELY PROHIBITS the following in its own operations and those of its supply chain partners: FORCED LABOUR: — Bonded labour / debt bondage — Compulsory prison or convict labour not within ILO guidelines — State-imposed forced labour (including government-sponsored forced labour programs such as those associated with the XUAR in China) — Indentured labour — Work performed under threat of penalty (dismissal, violence, document confiscation, debt, or other forms of coercion) CHILD LABOUR: — Any employment of children below the minimum legal working age (minimum: 15 years per ILO Convention C138; higher where national law requires) — Any employment of persons under 18 in hazardous work — Worst forms of child labour per ILO Convention C182 HUMAN TRAFFICKING: — Recruitment, transportation, transfer, harbouring or receipt of persons by means of threat, force, coercion, abduction, fraud, deception, or abuse of power for the purpose of exploitation — Sexual exploitation; forced labour exploitation; organ trafficking; any other form of human trafficking as defined by the Palermo Protocol DECEPTIVE RECRUITMENT: — Recruitment of workers through false promises of wages, working conditions, location, or nature of work — Charging workers recruitment fees that create debt bondage — Confiscation of identity or travel documents by employers |
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7.3.3 Due Diligence Processes in Operations & Supply Chains
This section addresses UK Modern Slavery Act s. 54(5)(c) and Australian Modern Slavery Act Criterion 3 (describe actions taken to assess and address modern slavery risks).
A. Vendor Onboarding Due Diligence
AqNova's Vendor onboarding process includes specific modern slavery and forced labour due diligence measures:
Vendor Ethical Sourcing Self-Declaration: all Vendors complete a mandatory Ethical Sourcing Self-Declaration at onboarding, confirming: no use of forced labour or child labour; compliance with ILO Core Conventions; no knowledge of modern slavery in their Tier 1 supply chain; and commitment to supply chain due diligence (see Section 6.2.14).
Sanctions screening: all Vendor entities and beneficial owners are screened against the UFLPA Entity List (US Forced Labor Enforcement Task Force); OFAC Specially Designated Nationals list; UN Security Council consolidated list; and equivalent EU and UK sanctions lists. Vendors on the UFLPA Entity List are rejected and cannot be onboarded.
Supply Chain Questionnaire (SCQ): all Vendors in high-risk product categories (apparel, textiles, electronics, food/agricultural products, cosmetics, mining/minerals) complete AqNova's Supply Chain Questionnaire (SCQ) covering: country of origin; Tier 1 supplier identification; audit history (24 months); certification status; worker grievance mechanism description. See Section 6.2.10.B for full SCQ content.
High-Risk Country Enhanced Due Diligence: Vendors sourcing from countries identified as high-risk by the US DOL ILAB List, the State Department TIP Report (Tier 2 Watch List or Tier 3), or the Global Slavery Index are subject to enhanced due diligence including: Tier 2 supply chain mapping; third-party audit requirement; senior compliance team review.
B. Ongoing Vendor Monitoring
Annual compliance self-certification: all Vendors are required to complete an annual compliance self-certification (Section 5.5.12.C) confirming ongoing compliance with AqNova's Ethical Sourcing Standards, including the modern slavery and forced labour commitments.
Continuous sanctions screening: Vendor entities and beneficial owners are re-screened against applicable sanctions lists (including the UFLPA Entity List) on a daily automated basis. Any potential match is escalated immediately.
Adverse media monitoring: Vendors in high-risk categories are subject to automated adverse media monitoring for supply chain human rights violations on a weekly basis.
CBP Withhold Release Orders (WROs) monitoring: AqNova monitors active US CBP Withhold Release Orders and immediately geo-blocks products from WRO-designated entities from the US market.
Audit report review: Vendors are required to share third-party audit reports (SMETA, SA8000, BSCI, or equivalent) within 24 months of onboarding and upon each renewal. AqNova's compliance team reviews audit findings and ensures corrective action plans are in place for identified issues.
C. AqNova's Own Operations Due Diligence
Internal workforce: AqNova employs and engages workers directly in the US (California), Nigeria (Sahara Eagle Ltd), and through remote working arrangements in other jurisdictions. AqNova's own employment practices comply with applicable labour law, the Living Wage standard, and AqNova's Code of Business Ethics (Section 7.4).
Operational supply chain (direct suppliers): AqNova's direct operational suppliers (cloud providers, payment processors, professional services) are screened for modern slavery risks at onboarding, including sanctions screening and review of their own published modern slavery statements where applicable.
Preferred supplier program: AqNova's procurement function prioritizes suppliers who: publish credible modern slavery statements; hold SA8000 or equivalent social certification; participate in the Sedex platform; or demonstrate other meaningful social compliance credentials.
7.3.4 Risk Assessment — Supply Chain Risks of Slavery & Trafficking
This section addresses UK Modern Slavery Act s. 54(5)(d) and Australian Modern Slavery Act Criterion 4 (describe actions taken to assess and address risks).
A. Risk Assessment Methodology
AqNova uses a risk-based approach to prioritize modern slavery due diligence resources, recognizing that risk varies significantly by product category, sourcing geography, supply chain structure, and Vendor characteristics. AqNova's risk assessment framework draws on the following intelligence sources:
US Department of Labor (DOL) List of Goods Produced by Child Labor or Forced Labor (ILAB List): identifies specific goods and countries associated with child and forced labour. AqNova cross-references all high-risk category Vendor products against the current ILAB List.
US State Department Trafficking in Persons (TIP) Report: annual assessment of countries' trafficking prevention and prosecution efforts. AqNova applies enhanced due diligence for Vendors sourcing from Tier 2 Watch List and Tier 3 countries.
Global Slavery Index (Walk Free Foundation): country-level estimates of modern slavery prevalence. Used in AqNova's country-level risk tiering.
US CBP Withhold Release Orders (WROs) and Findings: AqNova monitors active WROs and applies immediate geo-blocking for affected products.
UFLPA Entity List: daily monitoring; immediate rejection of UFLPA-listed entity applications and existing Vendor reviews.
Sedex RADAR risk assessment tool: used by AqNova's audit partners to assess country and commodity risk scores.
ILO 11 Indicators of Forced Labour: operational indicators applied to Vendor audit findings and supply chain intelligence.
Platform incident data: reports received through AqNova's supply chain grievance mechanism (Section 7.3.9) and Trust & Safety enforcement actions.
B. Risk Tiering — Products & Geographies
AqNova applies the following risk tiers to guide due diligence intensity:
| Risk Tier | Characteristics & Due Diligence Applied |
|---|---|
| TIER 1 — HIGH RISK | Products from the US DOL ILAB List; countries rated Tier 3 (worst) or Tier 2 Watch List on the TIP Report; Vendors sourcing from XUAR China (UFLPA); products from WRO-designated entities; garment manufacturing in Bangladesh, Cambodia, Myanmar; artisanal mining in DRC; cocoa in West Africa; mica in India. DUE DILIGENCE: Tier 2 supply chain mapping mandatory; third-party audit within 12 months; senior compliance review; annual enhanced re-verification. |
| TIER 2 — ELEVATED RISK | Products from TIP Report Tier 2 countries; labour-intensive manufacturing in South and Southeast Asia, East Africa, and Latin America not meeting Tier 1 threshold; product categories on the ILAB List without country-specific designation. DUE DILIGENCE: Tier 1 supply chain mapping mandatory; third-party audit within 24 months; annual SCQ completion; standard compliance review. |
| TIER 3 — STANDARD RISK | Products from countries with effective modern slavery legislation and enforcement (EU Member States, UK, North America, Australia, Japan, South Korea); digital products; professional services. DUE DILIGENCE: Annual Ethical Sourcing Self-Declaration; sanctions screening; standard SCQ where high-risk product categories are involved. |
C. Identified Risks — Financial Year 2025
AqNova's 2025 risk assessment identified the following material modern slavery risk areas in its Platform supply chains. This is an honest assessment intended to demonstrate AqNova's understanding of its risks — not a list of confirmed violations:
Mica in cosmetics supply chains: mica (a mineral used in cosmetics for shimmer/gloss effects) has documented child labour risks in Indian mining communities. Several AqNova Vendors in the cosmetics category source products containing mica. AqNova has engaged these Vendors to: confirm their mica supply chain origin; require Responsible Mica Initiative (RMI) membership or equivalent traceability from Indian sources; accept alternative mineral-based options.
Garment supply chains in South Asia: multiple AqNova Vendors in the apparel and textiles category source from garment factories in Bangladesh, India, and Pakistan. Risks include excessive overtime, worker restriction, and wage issues. AqNova has required audit coverage for all Tier 1 garment factories supplying these Vendors within 24 months.
West African cocoa: several food product Vendors source cocoa from Côte d'Ivoire and Ghana where child labour prevalence in cocoa farming remains high. AqNova requires Rainforest Alliance Certified or Fairtrade International certification for all cocoa-derived products targeting major markets. Progress: 73% of relevant Vendors now hold Tier 1 certification for their cocoa-sourced products (up from 58% in 2024).
Electronics components: some Vendor products in the electronics category contain components potentially sourced from conflict-mineral supply chains. AqNova requires EU Conflict Minerals Regulation compliance documentation for EU-market electronics Vendors and monitors UFLPA compliance for US-market products.
7.3.5 Key Performance Indicators — How AqNova Measures Effectiveness
This section addresses UK Modern Slavery Act s. 54(5)(e) and Australian Modern Slavery Act Criterion 5 (describe how the entity assesses the effectiveness of its actions).
A. 2025 KPI Performance
| KPI | 2025 Result | 2024 Comparison / Target |
|---|---|---|
| % of high-risk category Vendors completing Supply Chain Questionnaire (SCQ) | 84% | Target: 90% | 2024: 71% |
| % of high-risk category Vendors with Tier 1 or Tier 2 supply chain mapping on file | 76% | Target: 80% | 2024: 62% |
| % of high-risk category Vendors with audit coverage within 24 months | 68% | Target: 75% | 2024: 54% |
| Number of Vendor applications rejected due to UFLPA Entity List / sanctions match | 12 rejections | 2024: 8 rejections |
| Number of supply chain incidents (potential modern slavery) reported through AqNova grievance channel | 6 reports received | 3 investigated; 2 closed (no violation); 1 under investigation |
| Number of Vendor listings suspended / removed for modern slavery policy violation | 4 listings suspended | 3 confirmed violations; 1 false positive |
| % of AqNova employees completing modern slavery training | 91% | Target: 100% | 2024: 78% |
| % of cocoa-derived product Vendors with Rainforest Alliance or Fairtrade certification | 73% | Target: 85% by 2026 | 2024: 58% |
| Number of Vendors enrolled in Vendor Diversity & Inclusion Program (from underrepresented supply chain regions) | 247 enrolled | Target: 300 by 2026 |
| Number of remediation actions (CAPs) initiated for supply chain human rights issues | 11 CAPs | 8 closed satisfactorily; 3 in progress |
B. Areas of Improvement
AqNova acknowledges the following areas where performance fell short of targets in 2025, with commitments for 2026:
Audit coverage (68% vs. 75% target): audit completion rates for high-risk Vendors were below target due to: Vendor capacity constraints in scheduling third-party audits; audit supply constraints in some markets; onboarding of new Vendors in H2 2025 not yet within audit cycle. 2026 commitment: implement audit scheduling assistance for Vendors through AqNova's compliance portal; target 78% audit coverage.
Employee training (91% vs. 100% target): training completion fell short due to onboarding timing for new employees in Q4 2025. 2026 commitment: 100% completion target maintained; training integrated into onboarding workflow for same-month completion.
West African cocoa certification (73% vs. 85% target): progress was made but target not met. 2026 commitment: enforce certification requirement as a condition of listing continuation for all cocoa-derived product Vendors in major markets by June 2026.
7.3.6 Training on Slavery & Human Trafficking
This section addresses UK Modern Slavery Act s. 54(5)(f) and Australian Modern Slavery Act Criterion 6 (describe actions taken to assess and address modern slavery risks, including training).
A. Employee Training Program
| Training Module | Audience, Content & Frequency |
|---|---|
| Modern Slavery Foundations (Mandatory) | ALL employees and contractors at onboarding AND annually. Content: definition of modern slavery (forced labour, child labour, debt bondage, trafficking); ILO 11 indicators; AqNova's Ethical Sourcing Policy; how to identify potential modern slavery in supply chains; how to report concerns confidentially. Duration: 2 hours. Format: interactive e-learning with assessment. Completion tracked by People & Compliance team. |
| Supply Chain Due Diligence (Mandatory — Supply Chain Roles) | Compliance team; Vendor onboarding team; product category managers; Trust & Safety team. Additional content: risk-based due diligence methodology; UFLPA compliance; ILAB List application; audit standards (SMETA, SA8000, BSCI); SCQ review and assessment; corrective action planning; supplier engagement. Duration: 4 hours. Format: instructor-led workshop + case studies. |
| Modern Slavery Risk — Leadership Briefing (Annual) | Senior leadership; Board. Content: Annual risk assessment findings; key supply chain incidents; KPI performance review; regulatory developments (new legislation, enforcement trends); strategic priorities for the year ahead. Duration: 1 hour. Format: facilitated Board session presentation. |
| Customer Service Awareness (Modern Slavery Indicators) | Customer service team; Trust & Safety analyst team. Content: indicators that a product or Vendor may involve labour exploitation; escalation procedures for supply chain concern reports; how to handle reports from Vendors, Buyers, or external parties. Duration: 1 hour. Format: e-learning. |
B. Vendor Awareness & Education
Vendor Learning Center — Modern Slavery Module: AqNova provides a freely accessible Modern Slavery Awareness module in the Vendor Learning Center covering: what constitutes forced and child labour; the ILO 11 indicators; how to conduct supply chain due diligence; how to use the Supply Chain Questionnaire; resources for audit certification.
High-risk onboarding briefing: Vendors in high-risk product categories receive a dedicated written briefing at onboarding explaining AqNova's modern slavery requirements, the UFLPA implications for US-market goods, and the audit and certification requirements.
Annual compliance communication: all Vendors receive an annual compliance reminder email outlining modern slavery obligations, upcoming audit deadlines, and any regulatory changes affecting their market or product category.
7.3.7 Remediation — Actions Taken Where Violations Are Found
This section addresses Australian Modern Slavery Act Criterion 7 (describe remediation of forced labour and child labour) and supplements the Corrective Action Planning framework in AqNova's Ethical Sourcing Policy (Section 6.2.16).
A. Remediation Philosophy
AqNova's remediation approach is guided by the principle that the most effective response to identified modern slavery in supply chains is usually engagement and remediation — not immediate supplier termination. Terminating a supplier relationship can worsen the situation for workers who lose income without access to alternative employment or welfare support. AqNova's remediation framework prioritizes: the welfare of affected workers; root cause analysis to prevent recurrence; and sustainable improvement of supply chain practices. Termination is reserved for cases where: the violation is severe and ongoing; the supplier refuses to engage constructively; or there is evidence of deliberate concealment.
B. Remediation Tiers
| Violation Severity | Remediation Response & Timeline |
|---|---|
| CRITICAL — Active forced labour, child trafficking, worst forms of child labour | Immediate listing suspension. AqNova engages external expert (ILO IPEC partner, NGO, social auditor) to conduct independent investigation within 10 Business Days. Worker welfare interventions coordinated with NGO partners. If confirmed: account termination. Referral to law enforcement and applicable regulatory authority (CBP, UK GLAA, Australian ABF, etc.). Worker remediation fund: AqNova contributes to immediate welfare support for affected workers (emergency fund administered through verified NGO). Buyer notifications issued. No relisting without full independent remediation audit. |
| MAJOR — Systematic wage theft, restriction of movement, excessive forced overtime, document confiscation | Listing suspension within 5 Business Days. Corrective Action Plan (CAP) agreed with Vendor within 10 Business Days specifying: immediate payment of withheld wages; return of documents; remediation of working conditions; third-party verification. AqNova engages Vendor's Tier 1 supplier directly in some cases. Follow-up audit within 90 days. Listing restored only upon verified remediation. |
| MODERATE — Single-facility audit finding, isolated policy non-conformance, unverified concern | Listing active. CAP developed within 20 Business Days. Vendor required to implement corrective actions within 90 days. AqNova provides remediation support resources (training; tool access; NGO referral). Follow-up assessment within 180 days. |
C. Worker Welfare Remediation — Specific Commitments
Child labour remediation: where child labour is confirmed, AqNova's protocol prioritizes the child's welfare — not commercial considerations. Children are not simply dismissed from work without welfare support. Remediation includes: education access funding; family income support during education transition; partnership with specialist child welfare NGOs. See Section 6.2.4.B for full child labour remediation protocol.
Worker compensation for withheld wages: AqNova requires Vendor remediation plans to include specific timelines for paying all withheld or underpaid wages to affected workers, with verification documentation.
Worker voice in remediation: where possible, remediation plans are developed with input from affected workers and/or their representatives (trade union, works council, or equivalent). AqNova recognizes that effective remediation requires worker perspective.
7.3.8 Global Regulatory Compliance Context
AqNova's modern slavery obligations arise under multiple mandatory and voluntary frameworks across its operating jurisdictions. The following summarizes AqNova's compliance status across key frameworks:
| Framework | AqNova's Compliance Status & Actions |
|---|---|
| UK Modern Slavery Act 2015 (s. 54) | AqNova monitors its UK turnover threshold applicability. Where AqNova meets or approaches the GBP 36 million annual global turnover threshold for UK supply, this Statement constitutes AqNova's UK Modern Slavery Statement for the relevant financial year. Statement signed by a Director; published on AqNova's website and submitted to the UK Modern Slavery Statement Registry. Published at: [aqnova.co/responsibility/modern-slavery]. |
| Australian Modern Slavery Act 2018 | AqNova monitors its Australian consolidated revenue threshold applicability (AUD $100 million). Where AqNova meets or approaches this threshold through its Australian operations, this Statement constitutes AqNova's Australian Modern Slavery Statement for the relevant reporting period, addressing the seven mandatory criteria. Submitted to the Minister for Home Affairs / Commonwealth Modern Slavery Register. |
| California SB 657 (Transparency in Supply Chains Act) | AqNova monitors its California revenue threshold (USD $100 million global revenue for retailers/manufacturers doing business in California). AqNova's supply chain transparency disclosure is published at [aqnova.co/responsibility/supply-chains] in compliance with SB 657. |
| Canada S-211 (Fighting Against Forced Labour and Child Labour Act, 2024) | AqNova monitors its Canadian S-211 reporting threshold applicability. Annual reporting covers: structure and supply chains; policies and due diligence; parts of business/supply chains at risk; measures to assess and manage risk; training; assessment of effectiveness. |
| US UFLPA (2021) & CBP WROs | AqNova maintains active monitoring of the UFLPA Entity List and CBP WROs. All Vendors shipping to the US are required to certify UFLPA compliance for their products. Products from UFLPA-designated entities are geo-blocked from US market listings. See Section 6.2.3.C for full UFLPA compliance detail. |
| EU Forced Labour Regulation (2024/3015/EU — applicable from 2027) | AqNova is monitoring EU Forced Labour Regulation implementation and is preparing its compliance framework for the regulation's application from December 13, 2027. Key provisions: prohibition on placing forced-labour products on the EU market; investigative powers for EU national authorities; prohibition and withdrawal orders; online marketplace obligations. |
| EU Corporate Sustainability Due Diligence Directive (CSDDD, 2024/1760/EU) | AqNova monitors its CSDDD threshold applicability (in-scope for large EU and non-EU companies meeting turnover/employee thresholds). CSDDD requires due diligence on adverse human rights and environmental impacts, including forced labour, in own operations and supply chains. AqNova proactively aligns its due diligence framework to CSDDD requirements. |
| Germany LkSG (2023) | France Loi de Vigilance (2017) | Norway Åpenhetsloven (2022) | AqNova monitors the cascade effects of EU Member State mandatory due diligence laws, which impose due diligence requirements on in-scope companies and potentially cascade to their supply chain partners (including AqNova's Vendors who supply to LkSG-covered companies). AqNova's Supply Chain Questionnaire and audit program support Vendors' LkSG/Loi de Vigilance compliance obligations. |
7.3.9 Confidential Reporting Channel
AqNova provides a confidential reporting channel for workers in Vendor supply chains, NGOs, trade unions, industry partners, and the public to report suspected modern slavery, forced labour, or child labour connected to AqNova's Platform:
| Confidential Reporting — Modern Slavery & Labour Rights SUPPLY CHAIN WORKER GRIEVANCE CHANNEL (External): Email: compliance@aqnova.co Subject: Supply Chain Worker Report — [Country/Product Category] Reports may be made anonymously. AqNova maintains confidentiality of reporter identity to the maximum extent possible consistent with investigation requirements. Response: within 5 Business Days (acknowledgment) MODERN SLAVERY INCIDENT REPORT: Email: compliance@aqnova.co [Subject: Modern Slavery Report] Also available via on-platform reporting: Report a Seller ▶ Labour Rights / Modern Slavery Concern VENDOR INCIDENT SELF-DISCLOSURE (for Vendors reporting discovered issues): Email: vendors@aqnova.co [Subject: Supply Chain Incident Report] Vendors are required to report within 72 hours of discovery. Self-disclosure is treated as a mitigating factor in enforcement. WHISTLEBLOWING (AqNova employees — internal channel): Email: ethics@aqnova.co [CONFIDENTIAL] Anonymous reporting permitted. Non-retaliation policy applies. EXTERNAL REPORTING (in parallel with AqNova): UK Gangmasters and Labour Abuse Authority (GLAA): gla.gov.uk | 0800 432 0804 UK Modern Slavery Helpline: modernslaveryhelpline.org | 08000 121 700 US National Human Trafficking Hotline: humantraffickinghotline.org | 1-888-373-7888 ILO Helpdesk: ilo.org/helpdesk ILO 50for Freedom campaign: 50forfreedom.org Australian AFP Modern Slavery: afp.gov.au/crimes/human-trafficking Canada RCMP Human Trafficking: rcmp-grc.gc.ca Nigeria NAPTIP: naptip.gov.ng Walk Free Foundation: walkfree.org |
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AqNova's confidential reporting channel is designed to meet the effectiveness criteria for non-judicial grievance mechanisms set out in the UN Guiding Principles on Business and Human Rights (Pillar III, Principle 31): legitimacy; accessibility; predictability; equitable access; transparency; rights-compatibility; and a source of continuous learning. For full detail on AqNova's grievance mechanism standards, see Section 6.2.15 of the Ethical Sourcing Policy.
A. Board-Level Oversight
AqNova's modern slavery program is subject to annual Board-level review as a requirement of UK Modern Slavery Act s. 54 (Board approval) and AqNova's own governance standards:
Annual Board review: the Board of Directors of Arivon Holding Corporation reviews the Modern Slavery Statement annually. The review covers: KPI performance against targets; material risks identified during the year; any confirmed violations and remediation outcomes; regulatory developments affecting AqNova's obligations; proposed priorities for the year ahead.
Board sign-off: this Statement has been approved by the Board and signed by a Director of Arivon Holding Corporation (see Board Approval section above).
Senior leadership accountability: AqNova's Compliance Officer is accountable to the Board for the execution of the modern slavery program, with quarterly reporting on KPI performance and material incidents.
B. Annual Review Cycle
| AqNova Modern Slavery Annual Review Cycle JANUARY — MARCH (Q1): Compliance team compiles annual KPI data for the preceding financial year. Supply chain risk assessment updated based on new TIP Report, ILAB List, Global Slavery Index, and UFLPA Entity List releases. Outstanding corrective action plans reviewed for status. APRIL (Statement Preparation): Annual Modern Slavery Statement drafted by Compliance Officer. Statement reviewed by Legal Counsel for UK Modern Slavery Act, Australian Modern Slavery Act, and S-211 compliance. Statement submitted to the Board for review and approval. APRIL — JUNE (Publication): Statement approved by the Board and signed by a Director. Statement published at [aqnova.co/responsibility/modern-slavery]. Statement submitted to UK Modern Slavery Statement Registry. Statement submitted to Australian Commonwealth Modern Slavery Register (where applicable threshold is met). Statement URL provided to applicable Buyers and stakeholders who request it. JULY — DECEMBER (Implementation): Training program delivered for all employees. Vendor outreach for SCQ completion and audit scheduling. Ongoing monitoring: sanctions screening; WRO monitoring; adverse media. Incident response and remediation for any issues identified. Q3 KPI mid-year review presented to senior leadership. |
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C. Collaboration & Industry Engagement
AqNova engages with industry organizations and multi-stakeholder initiatives on modern slavery prevention: Better Work ILO-IFC joint program; ACT (Action, Collaboration, Transformation — textile sector); Responsible Business Alliance (electronics); Rainforest Alliance and Fairtrade International (food supply chains); Responsible Mica Initiative (cosmetics); Open Supply Hub (supply chain transparency).
AqNova shares supply chain risk intelligence (on a non-commercially sensitive basis) with peer marketplace platforms and industry bodies to support collective action on modern slavery in shared supply chains.
7.3.11 Contact Information — Modern Slavery & Human Trafficking
| AqNova — Modern Slavery Contacts MODERN SLAVERY REPORTS / SUPPLY CHAIN WORKER GRIEVANCES: compliance@aqnova.co [Subject: Modern Slavery Report / Supply Chain Worker Report] Anonymous reports accepted. VENDOR INCIDENT SELF-DISCLOSURE (72-hour reporting requirement): vendors@aqnova.co [Subject: Supply Chain Incident Report — URGENT] COMPLIANCE OFFICER: compliance@aqnova.co MODERN SLAVERY STATEMENT URL: [aqnova.co/responsibility/modern-slavery] UK Modern Slavery Registry: modern-slavery-statement-registry.service.gov.uk Australia Modern Slavery Register: modernslaveryregister.gov.au SUPPLY CHAINS DISCLOSURE (California SB 657): [aqnova.co/responsibility/supply-chains] LEGAL NOTICES: legal@aqnova.com EXTERNAL HELPLINES: UK Modern Slavery Helpline: 08000 121 700 US National Human Trafficking Hotline: 1-888-373-7888 GLAA (UK): 0800 432 0804 ILO Helpdesk: ilo.org/helpdesk Australian AFP Human Trafficking: afp.gov.au Nigeria NAPTIP: naptip.gov.ng 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 7.3: Modern Slavery & Human Trafficking Statement
© 2026 Arivon Holding Corporation. All rights reserved. Published April 7, 2026. Statement Period: FY2025.
Published pursuant to UK Modern Slavery Act 2015 s. 54 | Australian Modern Slavery Act 2018 | California SB 657 | Canada S-211.