Disclosure
Policy

The purpose of this Disclosure Policy is to:

• Establish clear standards for transparent and honest communication across all Lucaso platforms and interactions;
• Ensure customers can make fully informed decisions about Lucaso's products and services;
• Comply with applicable Indian laws including the Consumer Protection Act, 2019, the Advertising Standards Council of India (ASCI) Code, and relevant provisions of the Companies Act, 2013;
• Build and maintain the trust of our customers, partners, and the communities we serve;
• Provide clear guidance to Lucaso employees and representatives on disclosure obligations.

This policy applies to:

• All Lucaso employees, contractors, agents, and authorised representatives;
• All communications channels including website, social media (Instagram, Facebook, X, Pinterest, LinkedIn), email, WhatsApp, print advertising, showroom displays, and verbal communications;
• All content created, commissioned, or approved by Lucaso including blogs, videos, design renders, testimonials, and promotional material;
• All business relationships including dealer partnerships, influencer collaborations, and supplier affiliations.

Lucaso recognises the following groups as stakeholders with legitimate interests in our disclosures:

Lucaso's disclosures fall into two categories — proactive (information we publish without being asked) and reactive (information we provide when requested):

All Lucaso marketing and advertising material — whether on social media, our website, print, outdoor advertising, or any other medium — must be:

• Truthful: All product descriptions, claims, and specifications must be factually accurate;
• Non-misleading: No claim may create a false impression about our products, prices, timelines, or capabilities;
• Substantiated: All performance claims (e.g. "10-year warranty", "45-day delivery") must be factually supportable and consistently honoured;
• Compliant with ASCI Code: All advertising complies with the Advertising Standards Council of India guidelines.

Where we use before-and-after imagery in marketing materials:

• All "after" images must represent actual Lucaso installations, not stock photography or competitor work;
• 3D renders or design visualisations used in marketing must be clearly labelled as "artistic impression" or "design render";
• We do not use digitally enhanced images that misrepresent the actual quality, colour, or finish of our products.

Where Lucaso engages influencers, content creators, or brand ambassadors to promote our products:

• All paid or gifted collaborations must be clearly disclosed with appropriate hashtags such as #Sponsored, #Ad, #PaidPartnership, or #GiftedByLucaso;
• All influencer content must accurately represent the Lucaso products featured and must not make claims beyond what Lucaso has authorised;
• Influencers and creators are not authorised to make warranty, pricing, or availability commitments on behalf of Lucaso;
• Lucaso does not pay for fake reviews, manufactured engagement, or misleading endorsements.

Lucaso operates through an authorised dealer and partner network. Where a customer interacts with Lucaso through an authorised dealer or partner:

• The dealer's identity as an authorised Lucaso partner will be disclosed clearly;
• The dealer's commercial relationship with Lucaso (including any commission or referral arrangement) will be disclosed on request;
• Customers retain the same rights and warranty protections whether they engage directly with Lucaso or through an authorised partner.

Where Lucaso has preferred supplier relationships (e.g. Hettich, Häfele, specific material suppliers), these are disclosed as product features where relevant. Lucaso does not receive undisclosed financial incentives from suppliers that could compromise our recommendation to customers.

Where Lucaso operates a customer referral programme, the existence of the programme and any referral benefits will be clearly disclosed to all parties. Referral arrangements do not influence the advice or product recommendations provided to prospective customers.

Where our website links to third-party websites (supplier sites, payment gateways, delivery partners), these links are provided for convenience only. Lucaso does not endorse and is not responsible for the content, privacy practices, or accuracy of any third-party website. The presence of a link does not imply a formal commercial relationship unless explicitly stated.

Lucaso is committed to displaying only genuine customer reviews and testimonials. Our standards are:

• All testimonials displayed on our website and marketing materials are from real Lucaso customers based on their actual experience;
• We do not fabricate, manufacture, or substantially alter customer reviews;
• We do not pay customers to leave positive reviews;
• We do not suppress or delete negative reviews to create a misleadingly positive impression;
• Where a customer has given consent for their name or photograph to be used, this is documented.

Lucaso may proactively invite customers to leave reviews following installation completion. In such cases:

• The invitation to review is clearly from Lucaso and does not incentivise a positive rating;
• Customers are free to provide any rating or review they choose;
• Negative reviews received through invited review programmes are treated with the same seriousness as complaints.

Lucaso maintains profiles on Google, Justdial, and other review platforms. We do not manipulate these platforms through fake accounts, incentivised reviews, or any other method that violates the platform's terms of service.

Where Lucaso uses installation photographs in marketing or on our website:

• All photographs represent actual Lucaso installations unless explicitly labelled as a design render or stock image;
• Customer consent is obtained before publishing identifiable home photographs;
• Images are not digitally manipulated to misrepresent product quality or appearance.

Every Lucaso quotation is itemised and transparent. Our pricing disclosures include:

• Itemised breakdown of products, materials, and services;
• Clear statement of whether GST is included or excluded;
• Delivery and installation costs, if separate;
• Payment schedule milestones;
• Any optional add-ons or upgrades clearly separated from the base price.

Lucaso is committed to zero hidden charges. The amount stated in the confirmed quotation is the amount you pay. The following will never be added after Order confirmation without written Client approval:

• Material cost increases arising after confirmation;
• Labour or installation surcharges not in the original quotation;
• Delivery charges that were not included in the original scope;
• Any fees described as "standard" or "administrative" that were not in the original quotation.

Where Lucaso offers promotional pricing, discounts, or limited-time offers:

• The original price and the discounted price are both clearly shown;
• The duration or conditions of the offer are clearly stated;
• Promotional prices are genuine reductions from our regular pricing — we do not inflate base prices to manufacture artificial discounts;
• All promotional offers comply with the Consumer Protection Act, 2019.

A "material event" is any change or development that could reasonably be expected to affect a customer's existing or prospective relationship with Lucaso. We commit to prompt, clear communication of all material events.

Where we discontinue a product, material, or finish that a customer has ordered or may be considering:

• Affected customers with active Orders will be notified immediately with alternatives offered;
• Website product listings are updated promptly upon discontinuation;
• Product specifications that change between quotation and delivery will be disclosed and written approval sought from the Client.

Where we make significant changes to our Terms & Conditions, Warranty Policy, Privacy Policy, or this Disclosure Policy:

• Changes are published on our website with a clear "Last Updated" date;
• Existing customers with active Orders are notified of any changes that materially affect their rights;
• A summary of key changes is provided rather than requiring customers to compare full document versions.

Where Lucaso's ability to deliver agreed services is disrupted by force majeure, supply chain issues, or other significant events:

• Affected customers are notified at the earliest possible opportunity;
• A realistic revised timeline is provided with explanation;
• Customers' rights under the cancellation policy are clearly restated.

When Lucaso expands into new cities or withdraws from existing service areas, this information will be published on our website and communicated to relevant stakeholders at least 30 days in advance where operationally possible.

A conflict of interest arises when a personal, financial, or business interest of a Lucaso employee or representative could improperly influence their professional judgment or actions in a way that is adverse to the interests of customers or the Company.

All Lucaso employees and representatives are required to:

• Disclose any actual or potential conflict of interest to their line manager in writing at the earliest opportunity;
• Refrain from recommending or promoting any supplier, product, or service in which they have an undisclosed personal financial interest;
• Not accept gifts, hospitality, or benefits from suppliers or customers beyond our stated acceptable threshold;
• Not use company information or relationships for personal gain.

Where Lucaso has a commercial relationship with a supplier that involves preferential pricing, volume rebates, or other financial arrangements, this will not compromise the quality or suitability of products recommended to customers. All products we use are selected first on the basis of quality, performance, and value for our customers.

Any customer who believes a Lucaso employee or representative has acted under a conflict of interest in a way that has disadvantaged the customer is encouraged to report this to the management team at Info@lucaso.in. All reports are treated confidentially and investigated promptly.

For any questions about this Disclosure Policy, to report a potential violation, or to request information that you believe we are obligated to disclose, please contact us through the following channels:

If you are not satisfied with our response to a disclosure-related complaint, you may escalate the matter to the following bodies depending on the nature of the issue:

• Consumer complaints: District Consumer Disputes Redressal Commission, or National Consumer Helpline (1800-11-4000);
• Advertising complaints: Advertising Standards Council of India (ASCI) at ascionline.in;
• Data privacy complaints: Data Protection Board of India at dpboard.gov.in;
• Corporate governance matters: Ministry of Corporate Affairs, Government of India.

This Disclosure Policy was last reviewed and approved by the management of Lucaso Decor India Private Limited. It is effective from 1st January 2025. We are committed to continuous improvement of our disclosure standards and welcome feedback from all stakeholders.