Kibün by Bulbrite Map Policy

BULBRITE INDUSTRIES MINIMUM ADVERTISED PRICING POLICY (MAP POLICY)

-- USA --

Effective Date: May 15, 2025

I. INTRODUCTION

Bulbrite Industries, Inc. ("Bulbrite") has adopted the following Minimum Advertised Pricing Policy ("Policy") for its Kibün By Bulbrite branded product offerings (collectively the "Bulbrite Product(s)") in the US. This Policy applies to all resellers enjoying Bulbrite benefits including Bulbrite Retailers, Showrooms, Wholesalers, Distributors, Kitchen and Bath Dealers, Authorized E-tailers, and Preferred E-tailers (each, a "Bulbrite Reseller"), is effective May 15, 2025, and, together with the Bulbrite Reseller Policy dated May 15, 2025, replaces and supersedes any prior pricing policies.

Bulbrite is an industry-leading manufacturer and supplier of innovative lighting solutions that combine design, efficiency, and reliability in consumers' everyday lives. Bulbrite's product line represents inventive, high-quality brands selling at premium price points. These products have unique features and benefits that customers value over competing products.

Bulbrite has adopted this Minimum Advertised Pricing Policy because reseller practices that promote Bulbrite Products solely on the basis of price, and not product quality, service, and other factors, undermine the integrity of Bulbrite's brands and competitiveness. Such practices could also allow some resellers to unfairly take advantage of the investments other Bulbrite Resellers have made in marketing and supporting Bulbrite Products. Bulbrite does not support the use of our products as loss-leaders, "internet only" promotional products, or other use of our products to solely drive internet sales.

Bulbrite has updated our minimum criteria for sales, advertising, and customer service practices for all active Bulbrite Products including Bulbrite MAP products (as designated by Bulbrite from time to time) to best reflect the high standards and quality associated with the Bulbrite and Kibün By Bulbrite brands. We expect all Bulbrite Resellers, as our partners, will share in this commitment and seek to meet or exceed our minimum criteria.

II. SCOPE

Bulbrite will unilaterally establish a Minimum Advertised Price for specified Bulbrite Products. For all such products, Bulbrite Resellers must comply with the MAP Rules contained in Schedule A.

A. Product Coverage

The list of products to which this Policy pertains, and the minimum advertised prices that belong to each, are published online in the Product List at https://www.bulbrite.com/kibun-map-policy. This list is updated monthly, with any changes effective on the first day of each calendar month.

Bulbrite reserves the right to add to or adjust its Product List and MAP Schedule at any time and at its discretion. Any mid-month adjustments to MAP pricing will be communicated via email to the designated MAP contact person at least 14 days before taking effect.

Note, this Policy relates to "active" products in new condition (i.e., products that are currently being sold by Bulbrite and not designated by Bulbrite in writing as discontinued or to be discontinued). This Policy does not apply to discontinued merchandise or closeouts as clearly identified by Bulbrite.

B. Applicable Resellers

Compliance with this Policy is mandatory for every Bulbrite Reseller. This Policy applies to all Bulbrite Resellers, whether they obtain the products directly from Bulbrite, through a distributor, or any other means. This Policy applies to any advertising for any Bulbrite Product, in either brick-and-mortar locations or online sites, pages, venues, and marketplaces. It applies to online sites, pages, venues, and marketplaces irrespective of whether they are administered directly by the Bulbrite Reseller or a third party.

C. MAP Updates and Communication

MAP updates will be communicated through the following channels:

  1. Email notification to the designated MAP contact person
  2. Updates to the online Product List and MAP Schedule
  3. Quarterly MAP policy webinars (optional attendance)

Resellers are responsible for checking the current MAP pricing before creating new advertisements or promotional campaigns. The online Product List and MAP Schedule should be considered the definitive source for current MAP prices.

III. DEFINITIONS

For clarity and consistency, the following terms are defined as they relate to this Policy:

A. Product

As used herein, a "Product" is defined as any item manufactured or marketed by Bulbrite that is intended for sale. All such products are subject to this Policy, and all products—and the minimum advertised prices that pertain to each—are listed in the Product List and MAP Schedule furnished by Bulbrite at https://www.bulbrite.com/kibun-map-policy.

B. Price

As used herein, "Price" means the net advertised price for a consumer to receive ownership of the goods, i.e., the advertised amount adjusted for any discounts, rebates, coupons, credits, premiums, freemiums, loyalty rewards, combinations, shipping costs, or the like, but before any applicable taxes.

C. Advertising

As used herein, "Advertising" means any act of communication intended to induce people to buy or use a Product and includes but is not limited to communication in print or via any electronic means. Such communication includes all internet communications, including but not limited to communication on Amazon (and other online open marketplaces, stores, or shops), on eBay (and other auction sites), in search-related ads or links (e.g. on Google, Yahoo, Bing), in graphic or textual ads (banners, links, etc.), on social media (including Facebook, Pinterest, Snapchat, Instagram, LinkedIn or other sites), on television, radio, or via telephone (including SMS or related text messages), and in any communications in physical media of any kind (e.g., billboards, newspapers, magazines, newsletters, flyers, print ads, window banners, coupons, direct mail, or posters). An "Advertisement" means any communication that includes Advertising as defined herein.

D. Reseller Categories

For the purposes of this Policy, Bulbrite Resellers are categorized as follows:

  1. Retailers: Physical stores selling directly to end consumers
  2. Showrooms: Display-focused outlets with dedicated Bulbrite displays
  3. Wholesalers: Businesses selling primarily to other businesses
  4. Distributors: Authorized regional or national product distributors
  5. Kitchen and Bath Dealers: Specialized retailers for these verticals
  6. Authorized E-tailers: Online retailers approved to sell Bulbrite Products
  7. Preferred E-tailers: Online retailers with enhanced Bulbrite relationship and privileges

IV. MAP RULES

Rule 1: Advertisements for products MUST state the final Price of the Product offered before taxes and/or additional fees.

  • Advertisements that claim "Too Low to Publish," "Call for Pricing," "Email/Click for Pricing," "Special In-Cart Pricing," and the like for any listed product are ALL violations of this Policy because they do not state the final advertised Price of the listed product offered.
  • Advertisements stating or suggesting that a Bulbrite Reseller will "beat any competitor's advertised price" on a listed product is a violation because they do not state the advertised Price of the product.

Rule 2: The Price is determined net of all discounts and rebates (see the definition of "Price" above) and MUST NOT be below the MAP price.

Rule 3: Advertising of any Bulbrite Product must NOT be at a Price below the MINIMUM price (MAP) established for that Product.

A: Discounts

The value of any discount, rebate, credit, free item, loyalty reward, or the like must be calculated at retail value in determining the final price of a Product.

Example 1: If a Kibün By Bulbrite ficture has a MAP of $599, and a reseller offers a $100 store credit with purchase, the effective advertised price is $499, which violates MAP.

Example 2: If a Kibün By Bulbrite light fixture has a MAP of $299 and a reseller offers a free installation kit valued at $50 with purchase, the effective advertised price is $249, which violates MAP.

B: Percentage Off

Advertisements that state a percentage off that will net the Bulbrite Product below MAP are NOT allowed.

Example: If a Kibün By Bulbrite product has a MAP of $199 and a reseller advertises "20% off all lighting products," this violates MAP unless the reseller clearly excludes Kibün By Bulbrite products from the promotion or establishes a price floor that maintains MAP compliance.

C: Rebates

Advertising of rebates MUST include the Bulbrite Product's final price after the rebate, AND the rebate combined with any other form of discount or credit must not net the Price below the MAP.

Example: If a Kibün By Bulbrite product has a MAP of $249, a reseller can advertise a $25 mail-in rebate only if they show the final price as $249, not $224.

D: Shipping

Advertising "Free Shipping" or providing credit for shipping is NOT a violation of this Policy UNLESS there is a dollar value mentioned that nets a Product below the MAP.

Example: A reseller can advertise "Free Shipping" on a Kibün By Bulbrite product with a MAP of $399, but cannot advertise "$50 off shipping, making the final delivered price $349" if the MAP is $399.

E: Bundling

Where a Bulbrite Product is bundled with or sold as part of a package that includes another Bulbrite Product, it shall be a violation of this Policy to sell or advertise the bundle or package at a price that is lower than the combined MAP of the bundled products.

Example: If a Kibün By Bulbrite pendant light (MAP $199) is bundled with a Kibün By Bulbrite fixture (MAP $49), the bundle cannot be advertised for less than $248.

NOTE: All product bundles, when these are not already expressly identified as products, must be pre-approved by Bulbrite. It shall violate this Policy if products are bundled with or sold as part of a package that includes items not expressly approved for such a bundle by Bulbrite. Any promotions involving such bundles also need to be approved by Bulbrite.

F: Platform-Specific Guidelines

1. Amazon and Marketplace Platforms

  • Product listings must display the MAP price or higher
  • "Sale" or "List" prices must not create the impression of a discount below MAP
  • Quantity discounts must maintain MAP pricing for all quantity levels
  • "New Other" or "Open Box" conditions must be clearly marked as such

2. eBay and Auction Sites

  • Starting bids must be at or above MAP
  • "Buy It Now" prices must be at or above MAP
  • Reserve prices do not exempt listings from MAP compliance

3. Social Media

  • Promotional posts must not advertise prices below MAP
  • Flash sales and limited-time offers must maintain MAP pricing
  • Influencer codes/discounts must not reduce price below MAP

G. Bundling Approval Process

To obtain approval for a product bundle:

  1. Complete the Bundle Approval Request Form (available in Appendix C)
  2. Submit the form to service@bulbrite.com at least 30 days before intended promotion
  3. Include detailed information on all bundled items, proposed pricing, and promotional period
  4. Wait for written approval before advertising the bundle

Bundle approvals are valid for 90 days unless otherwise specified in the approval notice.

V. PROPRIETARY RIGHTS

A. No Association with Bulbrite

Except as otherwise authorized, Advertisements MUST NOT state, suggest, or lead a consumer to conclude that the sale is from Bulbrite or imply any false association with or endorsement from Bulbrite.

B. No Infringement

Print ads, online ads, and auction listings may not use any copyrighted materials, including photographs, or the Bulbrite logo, except as used by Authorized or Preferred E-tailers.

C. Approved Usage of Bulbrite Materials

Authorized E-tailers may:

  • Use official Bulbrite product images available in the Media Resource Center
  • Use approved product descriptions found in the Reseller Portal
  • Display the "Authorized Bulbrite Reseller" badge on their website

Preferred E-tailers receive additional privileges:

  • Use of the Bulbrite logo in advertising
  • Access to enhanced product imagery
  • Use of select promotional content developed by Bulbrite

All Bulbrite Resellers must respect brand guidelines available at https://www.bulbrite.com/brand-guidelines.

VI. COMPLIANCE AND MONITORING

A. Compliance Verification Process

Bulbrite monitors MAP compliance through:

  1. Automated price tracking software
  2. Mystery shopping program
  3. Competitor reporting
  4. Consumer reports
  5. Quarterly compliance audits

Monitoring covers both online and offline channels, with special attention to major e-commerce platforms, marketplaces, and promotional periods.

B. Regular Review Schedule

Bulbrite conducts compliance reviews according to the following schedule:

  • Daily: Automated price tracking of major online platforms
  • Weekly: Manual review of flagged potential violations
  • Monthly: Comprehensive audit of all Authorized and Preferred E-tailers
  • Quarterly: Review of all Bulbrite Resellers

C. Self-Monitoring Resources

Bulbrite provides the following resources to help resellers maintain compliance:

  1. MAP Compliance Checklist (available in the Reseller Portal)
  2. Pre-launch advertisement review service (allow 3 business days)
  3. Dedicated compliance support email: service@bulbrite.com

D. MAP Compliance Training

Bulbrite offers the following training resources:

  1. Online MAP Policy training course (required for all new Bulbrite Resellers)
  2. One-on-one consultation for complex promotional campaigns

VII. ENFORCEMENT PROCEDURES

The following enforcement procedures apply to this Policy. Upon discovery by Bulbrite, violations of this Policy will be handled as follows:

A. Violation Notices and Consequences

  • First Violation Notice: Warning notice
    • Timeframe: Must be corrected within 48 hours of notification
    • Required Response: Written acknowledgment and correction verification
  • Second Violation Notice: Second warning notice
    • Timeframe: Must be corrected within 24 hours of notification
    • Required Response: Written action plan to prevent future violations
    • Consequence: Temporary removal from "Find a Retailer" locator for 14 days
  • Third Violation Notice: Bulbrite will stop shipping products that have received First and Second Violation Notices (30-day penalty)
    • Timeframe: Must be corrected immediately upon notification
    • Required Response: Management-level meeting with Bulbrite representative
    • Consequence: 30-day suspension from shipping specified products
  • Fourth Violation Notice: Bulbrite will stop shipping all MAP SKUs indefinitely
    • Timeframe: Indefinite suspension
    • Required Response: Formal reinstatement application after 90 days
    • Consequence: Complete loss of authorization to sell Bulbrite products

Bulbrite Reseller will have no recourse against Bulbrite with respect to any loss or damages allegedly incurred because of such final violation consequences of the Bulbrite Reseller's rights resulting from a violation of this Policy.

B. Communication Protocol

All violation notices will be communicated via:

  1. Email to the designated MAP contact person (primary method)
  2. Certified mail to the business address on file
  3. Phone call to the designated MAP contact person (for Third and Fourth violations)

Violation notices will include:

  1. Specific violation details including product, advertised price, and location
  2. Supporting evidence (screenshots, photos, etc.)
  3. Required correction timeframe
  4. Required response actions
  5. Consequences if not addressed

C. Required Response Time

Resellers must acknowledge receipt of violation notices within the following timeframes:

  • First Violation: Within 24 hours
  • Second Violation: Within 12 hours
  • Third Violation: Within 4 hours
  • Fourth Violation: Within 24 hours (for reinstatement request process)

D. Documentation Requirements

Resellers must provide the following documentation when responding to violation notices:

  1. Written acknowledgment of the violation
  2. Evidence that the violation has been corrected (screenshots, photos, etc.)
  3. Action plan to prevent future violations
  4. Contact information for follow-up verification

VIII. DISPUTE RESOLUTION

A. Formal Dispute Process

Resellers who believe a violation notice was issued in error may dispute the notice by:

  1. Submitting a formal dispute using the MAP Violation Dispute Form (available in Appendix B)
  2. Providing clear evidence that no violation occurred
  3. Submitting the dispute within 72 hours of receiving the violation notice

B. Required Evidence

Acceptable evidence for disputes includes:

  1. Timestamped screenshots showing compliant pricing
  2. Documentation of approved promotions or bundles
  3. Evidence of third-party error (e.g., marketplace listing errors)
  4. Proof that the advertised product is not covered by MAP (e.g., discontinued items)

C. Review Timeline

Bulbrite will review all properly submitted disputes according to the following timeline:

  1. Acknowledgment of dispute receipt: Within 24 hours
  2. Initial review completed: Within 3 business days
  3. Final determination: Within 5 business days
  4. Implementation of decision: Immediate upon final determination

D. Decision Communication

Dispute decisions will be communicated in writing to the designated MAP contact person and will include:

  1. Determination (upheld, modified, or rescinded)
  2. Reasoning for the decision
  3. Any corrective actions still required
  4. Appeal process, if applicable

For disputes of Third and Fourth Violations, resellers may request an appeal to be reviewed by the Bulbrite MAP Policy Administrator, whose decision will be final.

IX. EXCEPTIONS

A. Standard Exceptions

Bulbrite Policy does NOT apply to the following:

  • In-store advertising including but not limited to in-store displays, banners or price markings for Bulbrite Products
  • Signage on the interior or the exterior of the Bulbrite Reseller's store (including the retail facility and surrounding parking lot)
  • Advertising on the site of a local event or local trade show
  • The price at which Bulbrite products are actually sold or offered for sale to an individual customer at "check out"
  • "Shopping cart" and similar check-out pages or windows on websites and mobile applications
  • Personal communications to an individual customer in connection with that customer's inquiries, specific expressions of interest, or business with the Bulbrite Reseller, including e-mail, text messages, letters, and quotes from the Bulbrite Reseller to that customer

B. Seasonal/Promotional Exceptions

Bulbrite may, at its sole discretion, establish limited-time promotional periods during which modified MAP guidelines apply. These exceptions will be:

  1. Communicated in writing to all Bulbrite Resellers at least 14 days in advance
  2. Limited to specific products and specific date ranges
  3. Clearly detailed with temporary minimum advertised prices
  4. Applicable to all Bulbrite Resellers equally

Common promotional periods may include:

  • Annual Lighting Sales Event (typically August)
  • Holiday Season Promotions (November-December)
  • New Product Launch Periods (as announced)

C. Grace Period for Policy Changes

When substantive changes are made to the MAP Policy, Bulbrite will provide:

  1. A 30-day notification period before changes take effect
  2. Written documentation of all changes
  3. Training resources for significant changes
  4. A 14-day grace period after implementation for inadvertent violations related specifically to the changes

D. Market Disruption Contingencies

In the event of significant market disruptions (e.g., major competitor liquidation, industry-wide supply chain issues), Bulbrite may temporarily modify MAP requirements. Such modifications will:

  1. Be communicated in writing to all Bulbrite Resellers
  2. Include specific start and end dates
  3. Detail any temporary changes to enforcement procedures
  4. Be applied consistently across all Bulbrite Resellers

X. INTERNATIONAL CONSIDERATIONS

A. Guidelines for International Resellers

While this MAP Policy is specific to the USA market, international resellers who advertise or sell into the USA market must:

  1. Comply with all aspects of this Policy for advertisements targeting USA consumers
  2. Display prices in USD at or above MAP when targeting USA consumers
  3. Ensure any currency conversion does not result in below-MAP pricing
  4. Adhere to all other aspects of this Policy

B. Currency Conversion Policies

For international Bulbrite Resellers advertising in multiple currencies:

  1. The advertised price in USD must meet or exceed MAP
  2. Prices in other currencies must be set to ensure the USD equivalent does not fall below MAP due to currency fluctuations
  3. Currency conversion rates should be reviewed weekly to maintain compliance
  4. MAP is always based on the USD price, regardless of the transaction currency

For questions regarding international compliance, contact service@bulbrite.com.

XI. THIRD-PARTY COMPLIANCE

A. Responsibility for Third-Party Listings

Bulbrite Resellers are responsible for ensuring MAP compliance across all channels, including:

  1. Their own websites and physical locations
  2. Marketplace listings (Amazon, eBay, Walmart, etc.)
  3. Affiliate marketing partners
  4. Dropship partners
  5. Any third party displaying the Bulbrite Reseller's offerings

B. Addressing Marketplace Aggregators

For issues with marketplace aggregators (e.g., Google Shopping, PriceGrabber):

  1. Resellers must regularly monitor aggregator listings of their products
  2. Incorrect pricing must be addressed within 48 hours of discovery
  3. Documentation of correction requests must be maintained
  4. Persistent issues must be reported to service@bulbrite.com

C. Unauthorized Reseller Management

While this Policy applies to authorized Bulbrite Resellers, Bulbrite also monitors unauthorized resellers. Authorized Bulbrite Resellers can support these efforts by:

  1. Reporting suspected unauthorized resellers to service@bulbrite.com
  2. Providing documentation of potentially diverted product
  3. Not supplying Bulbrite Products to known unauthorized resellers
  4. Implementing Bulbrite's Serial Number Tracking Program for high-value products

XII. MISCELLANEOUS

A. Policy Modifications

Bulbrite reserves the right to change, amend, or discontinue this Policy at any time.

B. Program Modifications

Bulbrite reserves the right to modify the rules, conditions, benefits, or awards pertaining to this Policy and any promotional or discount program at its sole discretion without notice.

C. Correspondence Limitations

Bulbrite and its affiliates are not responsible for requests or correspondence relating to any promotional or discount program statements which are lost or delayed in the mail or otherwise in transit.

D. Participation Rights

Bulbrite reserves the right to refuse an applicant's participation in any promotional, rebate, or discount program for any reason and at any time.

E. Termination Rights

Bulbrite reserves the right to terminate the participant's participation in any promotional, rebate, or discount program, with or without cause, at any time, upon giving five (5) days' notice to the participant.

F. Policy Administration

No Bulbrite officer, employee, representative or agent has the authority to alter, deviate from, or impose additional or different conditions of this Policy. The only Bulbrite representative authorized to answer questions regarding this Policy and to comment on them and to whom all questions regarding these Policies must be addressed is service@bulbrite.com. Additionally, no Bulbrite Reseller has any right to rely on an understanding of this Policy obtained from an oral discussion. All interpretations of this Policy will be based on this Policy, and any written clarification or guidance issued by Bulbrite.

(Bulbrite sales and support representatives are not authorized or permitted to discuss or answer questions about the state of MAP compliance of any Bulbrite Reseller or Policy enforcement actions taken against any Bulbrite Reseller.)

G. Reseller MAP Contact

Each Bulbrite Reseller must appoint a person who will be the primary contact for Bulbrite regarding the Policy. Your contact person should ensure that everyone involved with creating and implementing advertising or pricing for Bulbrite products at your store(s) is aware of and understands this Policy.

APPENDICES

Appendix A: Frequently Asked Questions

Q: How do I know if a product is covered by MAP?
A: All Kibün By Bulbrite products are covered unless specifically identified as discontinued or closeout. The current list is available at https://www.bulbrite.com/kibun-map-policy under Appendix D.

Q: Can I offer a coupon that would reduce the price below MAP?
A: No, coupons or discount codes that would result in a below-MAP final price violate the Policy, even if the discount is applied at checkout.

Q: What about price-matching policies?
A: Advertising that you will "match any price" or "beat any price" without specifying that you will not go below MAP violates the Policy.

Q: Are there any times when I can advertise below MAP?
A: Only during officially designated promotional periods communicated by Bulbrite in writing.

Q: What if my competitor is violating MAP?
A: Report violations to service@bulbrite.com. Do not match a non-compliant price, as this would also violate the Policy.

Q: How quickly will Bulbrite respond to reported violations?
A: Bulbrite aims to verify and address reported violations within 3 business days.

 


 

Appendix B: MAP Violation Dispute Form Template

 

MAP VIOLATION DISPUTE FORM

Reseller Information:

  • Company Name: ________________
  • Account Number: ________________
  • Contact Person: ________________
  • Email: ________________
  • Phone: ________________

Violation Notice Information:

  • Violation Notice Date: ________________
  • Violation Number (1st, 2nd, etc.): ________________
  • Product(s) Involved: ________________
  • Platform/Location of Alleged Violation: ________________

Dispute Basis (select all that apply): □ No violation occurred □ Product is not covered by MAP □ Approved promotion/bundle □ Third-party error □ Other: ________________

Evidence Submitted (select all that apply): □ Screenshots (dated/timestamped) □ Promotion approval documentation □ Third-party correspondence □ Other: ________________

Detailed Explanation:

Certification: I certify that the information provided is accurate and complete.

Signature: ________________ Date: ________________

Submit to: service@bulbrite.com

 

Appendix C: Bundle Approval Request Form

BUNDLE APPROVAL REQUEST FORM

Reseller Information:

  • Company Name: ________________
  • Account Number: ________________
  • Contact Person: ________________
  • Email: ________________
  • Phone: ________________

Bundle Information:

  • Proposed Bundle Name: ________________
  • Promotional Period: ________________ to ________________

Bulbrite Products in Bundle:

  1. Product SKU: ________ MAP Price: $________
  2. Product SKU: ________ MAP Price: $________
  3. Product SKU: ________ MAP Price: $________

Non-Bulbrite Products in Bundle (if applicable):

  1. Product Description: ________ Retail Value: $________
  2. Product Description: ________ Retail Value: $________

Proposed Bundle Pricing:

  • Total MAP of Bulbrite Products: $________
  • Total Value of Non-Bulbrite Products: $________
  • Proposed Advertised Bundle Price: $________

Promotional Channels: □ Reseller Website □ Amazon □ eBay □ Print Advertising □ Email Marketing □ Social Media □ Other: ________________

Bundle Marketing Description:

Bundle Image: [Attach proposed bundle image if available]

Certification: I understand that bundle approval is valid for 90 days unless otherwise specified, and that any changes to the bundle composition or pricing require new approval.

Signature: ________________ Date: ________________

Submit to: service@bulbrite.com

 

Appendix D: APPROVED MAP SKU / ORDERING CODES