Sustainability Standards & Claims Policy

AQNOVA MARKETPLACE

Global Legal Footer Framework

Comprehensive Compliance & Platform Governance Reference

(MASTER)

AqNova's Complete Framework for Anti-Greenwashing, Supply Chain Accountability, Environmental Compliance, Ethical Sourcing & Consumer Sustainability Transparency

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

Sustainability and ethical sourcing are not peripheral commitments for AqNova — they are the Platform's founding purpose. AqNova was founded on the conviction that the marketplace for sustainable consumer products deserves an infrastructure that matches the rigor of the claims made within it: a place where "organic" actually means certified organic; where "fair trade" actually means workers were paid fairly; and where "sustainable" is not a marketing word but a substantiated fact. This Section 6 sets out the legal and policy framework that gives that conviction practical teeth.

Every element of this framework serves a dual purpose: protecting Buyers from misleading sustainability claims (anti-greenwashing), and enabling Vendors who genuinely operate with sustainable and ethical practices to demonstrate that authenticity credibly and competitively. AqNova is not in the business of perfect sustainability — every global marketplace generates carbon, involves complex supply chains, and faces trade-offs. But AqNova is in the business of honest sustainability: transparency about what is known, accountability for what is claimed, and continuous improvement toward measurable goals.

6.1 AqNova's Sustainability Philosophy — Founding Principles

AqNova's sustainability framework is rooted in the personal experience that led to the Platform's creation: the difficulty of finding genuinely sustainable consumer products that could be trusted — not merely marketed as green — when it mattered. That founding experience shapes every policy in this Section.

6.2 Anti-Greenwashing Framework — Global Regulatory Standards

Greenwashing — making false, misleading, or unsubstantiated environmental or sustainability claims — is AqNova's most significant sustainability compliance risk. As a platform dedicated to sustainable products, AqNova is simultaneously the most attractive target for greenwashers (who benefit from operating on a trusted platform) and the most at risk from their conduct (which undermines the platform's core value). AqNova's anti-greenwashing framework draws on the most demanding global regulatory standards.

A. United States — FTC Green Guides

The Federal Trade Commission's Guides for the Use of Environmental Marketing Claims (Green Guides, 16 C.F.R. Part 260, last updated 2012, under revision as of 2023–2024) are the primary US anti-greenwashing framework. All AqNova Vendor sustainability claims targeting US consumers must comply with the Green Guides' general substantiation requirement: environmental benefit claims must be substantiated by competent and reliable scientific evidence; are specific and not overstated; and are presented in a context that does not mislead consumers about the extent of the environmental benefit. Specific Green Guides requirements by claim type are addressed in Section 6.4.

B. European Union — EU Green Claims Directive

The EU Green Claims Directive (Proposal 2023/0085(COD), COM/2023/166) — expected to be finalized and implemented progressively from 2024 — introduces legally binding requirements for substantiating and communicating environmental claims to EU consumers. Key provisions:

Pre-verification of claims: before making an environmental claim, traders must conduct a scientific assessment that confirms the claim is accurate, based on widely recognized scientific evidence, and not omits or obscures relevant information.

Prohibited claim types: the Directive explicitly prohibits: (a) claims based solely on emissions offsetting schemes claiming a product is 'climate neutral,' 'carbon neutral,' 'carbon positive,' etc. without addressing direct emissions; (b) claims covering only part of a product's life cycle without disclosing this; (c) comparative claims without a specified basis; (d) unsubstantiated sustainability labels from non-certified schemes.

Third-party verification: independent verification of pre-market claims is required for most environmental claims targeting EU consumers. AqNova proactively applies this standard for EU-marketed products regardless of whether the Directive is formally implemented in a specific Member State.

Simplified certification scheme labels: only sustainability labels that are independently verified and based on transparent criteria are permitted. AqNova's Tier 1 sustainability verification program is designed to qualify under this requirement.

C. United Kingdom — CMA Green Claims Code

The UK Competition and Markets Authority (CMA) Green Claims Code (September 2021) sets out the principles that UK businesses must follow when making environmental claims. The six CMA principles: (1) claims must be truthful and accurate; (2) claims must be clear and unambiguous; (3) claims must not omit or hide important information; (4) comparisons must be fair and meaningful; (5) claims must consider the full lifecycle of the product; (6) claims must be substantiated. AqNova applies the CMA Code as its UK anti-greenwashing standard.

D. Australia — ACCC Environmental Claims Guidelines

The ACCC's Making Environmental Claims: A Guide for Business (November 2023 edition) provides guidance on environmental claims under the Australian Consumer Law. The ACCC has prioritized greenwashing enforcement, with public investigations and enforcement actions in the retail and financial services sectors. AqNova applies ACCC guidance as its Australian anti-greenwashing standard.

E. Other Jurisdictions — Anti-Greenwashing Frameworks

AqNova monitors anti-greenwashing regulatory developments across all operating markets:

France: Loi Climat et Résilience (Law 2021-1104) restricts carbon neutrality claims and requires third-party verification of 'carbon neutral' / 'zero carbon' claims for products marketed to French consumers.

Netherlands: the ACM (Autoriteit Consument en Markt) has issued detailed guidelines on sustainable claims and conducted the EU's first significant greenwashing enforcement actions (against Shell, Deutsche Bank, and H&M in 2021–2023). AqNova monitors ACM enforcement and aligns to ACM guidance for Dutch-market products.

India: SEBI (Securities and Exchange Board of India) ESG disclosure requirements apply to listed companies; AqNova monitors development of consumer product greenwashing standards by BIS and consumer protection authorities.

South Africa: National Consumer Commission (NCC) and ASA (Advertising Standards Authority) adjudicate green claims. AqNova's sustainability claims standards are aligned with NCC and ASA guidance.

6.3 The AqNova Sustainability Claims Classification System

All sustainability claims on the AqNova Platform are classified into three tiers under AqNova's Sustainability Claims Classification System. This system operates in conjunction with the Seller Verification & Credentialing Policy (Section 5.5.6) and is the foundational framework for anti-greenwashing enforcement on the Platform.

A. Biodegradable & Compostable Claims

Biodegradable and compostable claims are among the most misused sustainability claims in the consumer products space. AqNova applies the following standards:

Biodegradable: to claim a product is biodegradable, the Vendor must provide: (a) a test report from an ISO 17025-accredited laboratory confirming biodegradation within a reasonably short period under realistic end-of-life disposal conditions (typically 12 months in customary disposal — per FTC Green Guides guidance); (b) specification of the disposal conditions under which biodegradation occurs (industrial composting, marine environment, soil, etc.); (c) identification of any residual materials that are not fully biodegradable. Blanket biodegradable claims without qualification are prohibited.

Compostable: compostable claims require: (a) evidence of compostability in the conditions stated (home compost vs. industrial compost are materially different and must be specified); (b) certification from a recognized body (EU: TUV Austria OK Compost Industrial/OK Compost HOME; US: BPI certification; Australia: AS 4736/AS 5810; EN 13432 for EU packaging compostability). Claims that a product is compostable only in industrial composting facilities must clearly state that home compostable conditions are not sufficient.

B. Recyclable & Recycled Content Claims

Recyclable: a product may be claimed as 'recyclable' only where recycling infrastructure exists in a substantial majority of the Buyer's community (FTC: 60%+ of communities where the product is sold; EU Green Claims Directive: infrastructure availability must be assessed). Products recyclable only through specialist take-back programs must clearly state this.

Recycled content: claims of specific recycled content percentages (e.g., '50% post-consumer recycled PET') require documentation: supplier declarations, SCS Global Recycled Standard (GRS) certification, or equivalent third-party verification of recycled content percentage and origin (pre-consumer vs. post-consumer).

Chemical recycling: claims of 'recycled' content derived from chemical recycling processes must clearly differentiate from mechanical recycling and must comply with applicable mass balance accounting standards. The EU has specific rules for chemical recycling content claims under ISCC PLUS and equivalent schemes.

C. Natural & Clean Claims

Natural: 'natural' or '100% natural' claims for cosmetics, personal care products, food supplements, and cleaning products are highly contested and unregulated in many jurisdictions. AqNova requires Vendors making 'natural' claims to: (a) define what 'natural' means for their product (percentage of natural-origin ingredients; defined standard used); (b) provide an ingredient list demonstrating the basis for the claim; (c) not use synthetic ingredients that are marketed as 'natural' without clear disclosure. EU: NSF/ANSI 305 or COSMOS certification strongly recommended for cosmetic 'natural' claims.

Clean: 'clean' claims (particularly in beauty and personal care) imply freedom from specific ingredients often perceived as harmful. AqNova requires 'clean' claims to: (a) specify what 'clean' means in the context of the product (list of absent ingredients); (b) not imply safety equivalence or superiority to conventional products without substantiation.

D. Cruelty-Free & Vegan Claims

Cruelty-free: this claim typically means no animal testing was conducted on the finished product or its ingredients. AqNova requires: Leaping Bunny Program certification (Corporate Standard of Compassion for Animals) or PETA Beauty Without Bunnies certification for 'cruelty-free' claims. Vendors in markets where animal testing is mandated by law (China for certain imported cosmetics) may not claim 'cruelty-free' for those products without disclosure.

Vegan: claims that a product is 'vegan' (contains no animal-derived ingredients or by-products) require either: Vegan Society Trademark certification; or a complete ingredient list demonstrating absence of animal-derived ingredients, with supplier declarations confirming no hidden animal-derived processing aids.

6.5 Supply Chain Due Diligence & Human Rights

AqNova believes that environmental sustainability and human rights in supply chains are inseparable. A product certified as organic but produced by forced or child labor is not a sustainable product by AqNova's definition. The following supply chain due diligence framework applies to all Vendors on the Platform.

A. EU Corporate Sustainability Due Diligence Directive (CSDDD, 2024/1760/EU)

The EU CSDDD requires certain large EU companies and non-EU companies with significant EU operations to conduct due diligence on actual and potential adverse human rights and environmental impacts in their own operations and their supply chains. For AqNova:

AqNova as a marketplace operator: AqNova evaluates its own CSDDD threshold applicability (based on employee numbers and EU turnover). AqNova's CSDDD compliance status and approach are published in its annual Sustainability Statement.

Vendor obligations: Vendors who are independently subject to CSDDD (as large EU or non-EU companies meeting applicable thresholds) must comply with CSDDD independently. AqNova may request CSDDD compliance documentation from large Vendors as part of its enhanced Vendor due diligence program.

Cascade effect: the CSDDD requires in-scope companies to address adverse impacts in their supply chains, which effectively cascades supply chain due diligence requirements to smaller suppliers who sell to CSDDD-in-scope companies. AqNova provides a Supply Chain Questionnaire (SCQ) to assist Vendors in preparing for CSDDD cascade requirements from their downstream customers.

B. Germany — Lieferkettensorgfaltspflichtengesetz (LkSG)

Germany's Supply Chain Due Diligence Act (LkSG, effective January 1, 2023 for large companies; extended to smaller companies from January 1, 2024) requires companies with 1,000+ employees operating in Germany to conduct due diligence on human rights and environmental risks in their supply chains. AqNova monitors LkSG compliance requirements for German-market Vendors who meet applicable thresholds.

C. France — Loi de Vigilance (Duty of Vigilance Law)

France's Law No. 2017-399 (Duty of Vigilance Law) requires large French companies to publish and implement a vigilance plan (plan de vigilance) identifying and preventing serious violations of human rights, fundamental freedoms, health/safety, and environmental harms in their operations and supply chains. AqNova monitors compliance requirements for French-market Vendors subject to this law.

D. Norway — Transparency Act (Åpenhetsloven)

Norway's Transparency Act (Åpenhetsloven, effective July 1, 2022) requires larger enterprises operating in Norway to conduct human rights due diligence consistent with the UN Guiding Principles on Business and Human Rights (UNGPs) and OECD Guidelines for Multinational Enterprises, and to publish an annual report on their due diligence activities. AqNova monitors compliance for Norwegian-market Vendors subject to this Act.

E. Canada — Fighting Against Forced Labour and Child Labour Act (S-211)

Canada's S-211 (Fighting Against Forced Labour and Child Labour in Supply Chains Act, in force January 1, 2024) requires applicable government institutions and private sector entities to report annually on measures taken to prevent and reduce the risk of forced or child labour in their supply chains. AqNova complies with this Act in respect of its own Canadian operations and encourages Vendor compliance.

F. AqNova's Vendor Supply Chain Questionnaire

All Vendors in high-risk supply chain categories (apparel; electronics; food; natural fibers; agricultural products; minerals) are required to complete AqNova's Supply Chain Questionnaire (SCQ) as part of the Vendor onboarding process and on an annual update basis. The SCQ covers:

Country of origin and primary manufacturing location.

Supplier identification and contact (tier-1 supplier minimum; tier-2 disclosure encouraged for high-risk categories).

Labor practices: wage levels relative to living wage benchmarks; working hours; freedom of association; collective bargaining rights.

Child labor: age verification procedures for workers; compliance with ILO Minimum Age Convention (No. 138) and ILO Worst Forms of Child Labour Convention (No. 182).

Health and safety: workplace health and safety management systems.

Environmental practices: wastewater management; chemical management; energy and water use.

6.6 Modern Slavery & Forced Labour Prohibition

AqNova has zero tolerance for forced labor, child labor, human trafficking, and any other form of modern slavery in the supply chains of products sold on the Platform. This commitment is operationalized through the following framework:

A. Global Legal Framework

B. AqNova's Modern Slavery & Forced Labour Vendor Requirements

Vendor self-declaration: all Vendors must declare, as part of the annual compliance self-certification (Section 5.5.12.C), that they are not aware of any forced labor, child labor, or modern slavery in their supply chains.

High-risk supply chain enhanced due diligence: Vendors in garments/apparel, electronics, natural stone, seafood, cocoa, coffee, minerals, and other ILO-identified high-risk sectors are subject to AqNova's enhanced supply chain due diligence, including third-party audit requirement (Sedex SMETA, SA8000, amfori BSCI, or equivalent).

Incident reporting: Vendors must report to AqNova within 72 hours if they become aware of any incident of forced labor, child labor, or human trafficking in their supply chain. AqNova's response includes immediate review, temporary listing suspension pending investigation, and potential referral to relevant authorities.

6.7 Environmental Compliance — Global Standards by Market

In addition to the anti-greenwashing framework (Section 6.2) and product-specific sustainability certification requirements (Section 5.5.6), Vendors listing on AqNova must comply with applicable environmental regulations in both their country of manufacture and the destination market for their products. The following table identifies key environmental compliance requirements by market:

6.8 Organic & Natural Product Standards

Organic certification is the most common and most valuable sustainability certification on the AqNova Platform. It is also among the most frequently misused. AqNova's organic standards framework addresses the full global landscape of organic certification systems:

A. Organic Certification by Market

6.9 Circular Economy & Packaging Compliance

The shift to a circular economy — in which products and materials are kept in use for as long as possible, waste is minimized, and natural systems are regenerated — is one of the most significant sustainability trends affecting consumer products globally. AqNova's framework addresses both the regulatory obligations and the opportunity for Vendors to differentiate through genuine circular design.

A. AqNova's Packaging Standards

AqNova's preferred packaging standards for Vendors, applicable to all marketplace shipments:

Minimize plastic use: AqNova encourages Vendors to progressively reduce or eliminate single-use plastic packaging, consistent with applicable regulatory timelines in each market.

Recyclable-first: where plastic packaging is necessary, Vendors are encouraged to use materials that are accepted in mainstream recycling streams in the destination market (e.g., PET, HDPE — not PVC, polystyrene, or multi-layer laminates that are difficult to recycle).

Packaging right-sizing: AqNova's shipping guidelines encourage Vendors to right-size packaging — avoiding excess void fill, oversized boxes for small items, and unnecessary layers of protective packaging.

Compostable alternatives: where applicable (e.g., food products, personal care), compostable packaging certified to applicable standards (EN 13432 for EU; AS 4736 for Australia; BPI for US) is strongly encouraged.

No harmful inks and dyes: packaging inks and adhesives should be water-based and non-toxic where possible.

B. Regulatory Packaging Compliance Requirements

Vendors must comply with applicable packaging regulations in destination markets:

EU: Packaging and Packaging Waste Directive (94/62/EC) — current; PPWR — incoming. Essential requirements (recyclability; hazardous substance avoidance; volume and weight minimization). European Green Deal packaging targets.

UK: Packaging Waste Regulations 2007; Plastic Packaging Tax (April 2022) — applies to plastic packaging components manufactured in or imported into the UK with less than 30% recycled plastic content (rate: GBP 217.85 per tonne as of April 2024). AqNova advises Vendors on UK Plastic Packaging Tax implications.

Germany: Verpackungsgesetz (Packaging Act) — requires packaging to be registered with the Central Agency Packaging Register (ZSVR) and participation in a dual system (e.g., Der Grüne Punkt). Vendors shipping to German consumers must register.

France: Loi AGEC (Anti-Waste for a Circular Economy Law, 2020): progressive bans on single-use plastics; mandatory triman labeling (sorting/recycling information); EPR obligations.

Australia: Packaging Covenant / APCO targets; mandatory Product Stewardship for electronics.

India: Plastic Waste Management Rules 2016 (as amended 2022): EPR registration with CPCB for plastic packaging producers, importers, and brand owners.

6.10 Carbon Footprint, Emissions & Climate Claims

Carbon neutrality, net zero, and climate-related claims are the fastest-growing area of sustainability marketing and, as a consequence, among the fastest-growing areas of greenwashing enforcement. AqNova's standards for carbon and climate claims reflect the most current regulatory and scientific frameworks.

A. Climate Claim Standards — What Is Permitted

B. Climate Claim Standards — What Is Prohibited

6.11 Biodiversity & Ecosystem Protection

AqNova's commitment to sustainability encompasses biodiversity conservation as a core value. The following biodiversity-related standards apply to products listed on the Platform:

Deforestation-free sourcing: Vendors of products derived from high-risk commodity supply chains (palm oil, cocoa, coffee, soya, timber, beef, rubber) must demonstrate deforestation-free sourcing compliance consistent with the EU Deforestation Regulation (2023/1115/EU) and, where applicable, the UK Environment Act 2021 due diligence provisions. Certifications: RSPO (palm oil); Rainforest Alliance; FSC/PEFC (timber); Bonsucro (sugarcane); Proterra (soya); NSF Sustainability (multiple commodities).

Marine ecosystem protection: products derived from marine or aquatic ecosystems (seafood, seaweed, marine cosmetic ingredients) must demonstrate sustainability of sourcing through: MSC (Marine Stewardship Council) or ASC (Aquaculture Stewardship Council) certification; or equivalent national sustainable fishery certification. Unsustainable fishing practices or sourcing from endangered fisheries is prohibited.

No primary forest materials: products containing materials sourced from primary (old-growth) forests that are not covered by FSC certification are prohibited. AqNova applies the High Conservation Value (HCV) framework as a reference for identifying primary forest sourcing risks.

Invasive species: products containing seeds, propagating materials, or other biological materials of species listed as invasive in the destination market are prohibited consistent with applicable biosecurity laws (US Lacey Act; EU Regulation 1143/2014 on Invasive Alien Species; Australian Biosecurity Act 2015).

Coral and marine life: products containing coral, sea shells, or other marine life materials must be verified as legally sourced consistent with CITES Appendix II requirements and applicable national law. Coral and certain shell species are protected under CITES and cannot be commercially traded without permits.

6.12 AqNova's Own Sustainability Operations

AqNova holds itself to the same standards it applies to Vendors. AqNova's operational sustainability commitments are disclosed here and in AqNova's annual Sustainability Statement (published at [aqnova.co/responsibility/sustainability]):

6.13 Vendor Sustainability Obligations — Summary Matrix

The following matrix summarizes the key sustainability obligations applicable to Vendors on the AqNova Platform, by category:

A. AqNova's Annual Sustainability Statement

AqNova publishes an annual Sustainability Statement covering:

AqNova's own GHG emissions (Scope 1, 2, and material Scope 3) for the reporting year.

Progress against AqNova's emission reduction targets and SBTi validation status.

AqNova's modern slavery statement (UK Modern Slavery Act; Australia Modern Slavery Act; California SB 657; Canada S-211).

Sustainability verification statistics: number of Tier 1 certifications verified; number of greenwashing enforcement actions taken; certification mark violations actioned.

Platform curation impact: estimated aggregate environmental benefit of Platform-certified sustainable product sales (where quantifiable).

Packaging initiatives: progress on reducing plastic packaging in Platform-facilitated orders.

The annual Sustainability Statement is published at [aqnova.co/responsibility/sustainability] by June 30 of each year for the preceding calendar year.

B. Consumer Sustainability Transparency — Product Listings

AqNova provides sustainability information to Buyers at the product listing level:

Verified Certification badge: displays certification name, certifying body, and certificate expiry for Tier 1 verified products. Buyers can access full certificate details by clicking the badge.

Vendor Declared label: for Tier 2 substantiated claims, a 'Vendor Declared' label with a brief methodology summary is displayed, and full documentation is available on request.

Sustainability score (in development): AqNova is developing a simplified, standardized sustainability score for products that integrates multiple factors (certification level, packaging sustainability, carbon footprint estimate, supply chain transparency) into a single consumer-facing metric. The methodology will be publicly disclosed and independently reviewed before launch.

C. Greenwashing Enforcement Statistics

AqNova's annual Transparency Report (see Section 5.17 of Section 5.0) includes a dedicated section on greenwashing enforcement, covering: number of listings investigated for potential greenwashing; number of listings removed for confirmed greenwashing; certification mark violations (by certifying body); Vendor accounts actioned for sustainability claim misrepresentation.

6.15 Consumer Rights — Sustainability Claims

Buyers who have purchased products on AqNova in reliance on sustainability claims that prove to be false or misleading have the following rights:

A. AqNova Sustainability Credential Guarantee

AqNova's Sustainability Credential Guarantee (described fully in Section 5.2.13 of the Buyer Protection Policy) provides Buyers with a full refund where a product bearing a Tier 1 AqNova-Verified Certification is subsequently found to hold a fraudulent, lapsed, or incorrectly applied certification. The Guarantee applies regardless of whether the standard BPP claim window has passed, subject to a 12-month lookback from the date the certification is confirmed fraudulent.

B. Statutory Consumer Rights for Greenwashing

Buyers who purchase products in reliance on false or misleading sustainability claims may have statutory rights under applicable consumer protection law:

EU: EU Omnibus Directive (2019/2161/EU) — misleading commercial practices including false sustainability claims give rise to consumer remedies including contract rescission and price reduction.

UK: Consumer Protection from Unfair Trading Regulations 2008 — misleading actions or omissions in commercial practices give consumers the right to unwind transactions, seek a discount, or claim damages.

US: FTC Act Section 13(b) — FTC enforcement; state consumer protection statutes (California CLRA, UCL, FAL) — private rights of action for misleading sustainability claims.

Australia: ACL — misleading conduct (s. 18); false representations about quality/characteristics (s. 29); consumers may seek damages, rescission, or other remedies.

Brazil: CDC Art. 6(III) — right to accurate product information; Art. 18 — non-conforming products; Art. 20 — non-conforming services.

C. How Buyers Can Report Greenwashing on AqNova

Buyers who believe a product listing contains false or misleading sustainability claims should:

Report through AqNova: Report This Listing > Misleading Information > Sustainability/Environmental Claim. OR email compliance@aqnova.co [Subject: Greenwashing Report — [Listing URL]].

Report to the applicable regulatory authority: FTC (ftc.gov/complaint) in the US; national competition authority in EU; CMA (gov.uk/cma) in UK; ACCC (accc.gov.au) in Australia; NCC in South Africa; FCCPC in Nigeria; etc. See the External Reporting directory in Section 5.1.13.

6.16 Enforcement & Consequences

AqNova's enforcement approach to sustainability and ethical standards violations reflects the severity and nature of the violation:

6.17 Contact Information — Sustainability & Ethics

AqNova Marketplace | Global Legal Footer Framework | Section 6: Sustainability & Ethical Standards

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