NAVRITU DIGITAL

INFLUENCER & FTC DISCLOSURES

Effective Date: August 22, 2026

This policy explains how NavRitu Digital approaches sponsored content and material-connection disclosures across our Influencer Marketing and Ads & Marketing services, in line with the FTC Endorsement Guides (United States), ASCI's Guidelines for Influencer Advertising (India), the UK ASA/CAP Code, and applicable EU transparency rules for commercial communications.

1. Why Disclosure Matters

When an influencer, creator, or media partner has a material connection to a brand — payment, free products, affiliate commissions, or any other benefit — that connection must be disclosed clearly to the audience. This protects consumers, protects our clients' brands, and keeps campaigns compliant with the advertising regulator in each relevant market.

2. Regulatory Frameworks We Apply

Framework	Core Requirement We Follow
FTC Endorsement Guides (USA)	Clear and conspicuous disclosure of any material connection between an endorser and a brand, using unambiguous language (e.g., “Ad,” “Sponsored,” “Paid partnership”) placed where it can't be missed or buried in a hashtag block
ASCI Guidelines for Influencer Advertising (India)	Mandatory disclosure labels (e.g., “Ad,” “Collaboration,” “Sponsored”) displayed prominently on the post itself, not just in a bio or linked page, for any content involving a material connection
UK ASA / CAP Code	Advertising must be obviously identifiable as such, with disclosure labels like “Ad” used consistently across marketing communications
EU Transparency Rules	Commercial communications, including influencer content, must be clearly identifiable as such to the average consumer, consistent with EU consumer protection and digital services rules

3. Our Disclosure Standards for Campaigns We Run

• Disclosure labels are placed in the first line of a caption or within the first few seconds of a video — not hidden after a “see more” cut-off or buried among unrelated hashtags
• We use each platform's native disclosure tool where available (e.g., Instagram/Facebook's Paid Partnership label, YouTube's paid promotion checkbox) in addition to a written disclosure in the caption
• Disclosure wording is in plain, unambiguous language appropriate to the local market (e.g., “Ad,” “Sponsored,” “Paid partnership with [Brand],” or the equivalent in the local language)
• Free products, discounts, affiliate links, and any other material benefit are disclosed, not just direct cash payment

4. Influencer & Creator Contract Requirements

Every influencer or creator we engage on a client's behalf is contractually required to include the required disclosure in their content, and to keep it in place for the life of the post. We review content before or shortly after publication to confirm disclosure requirements have been met.

5. Non-Compliance

If a creator publishes content without the required disclosure, we will request an immediate correction, and repeated non-compliance may result in the creator being removed from current and future campaigns.

6. Client Responsibilities

Clients are responsible for reviewing and approving disclosure language as part of campaign sign-off, and for informing us of any market-specific disclosure requirements beyond the frameworks listed above.

7. Contact Us

Questions about disclosure requirements for a specific campaign or market can be sent to legal@navritu.digital.