Anti-Bribery & Corruption Policy

1. Zero tolerance

Handsome (handsomemakers.com), operated by Michael Balleroni — Italian Sole Proprietorship, VAT ID 02871720419, adopts a zero-tolerance policy against any form of active or passive bribery, corruption, undue inducement, trafficking in influence and any conduct contemplated by Italian Criminal Code (Arts. 318, 319, 319-quater, 320, 321, 322, 322-bis) and applicable international standards (UK Bribery Act 2010, US Foreign Corrupt Practices Act).

2. Scope

This Policy applies to the Owner, external collaborators, suppliers, consultants and artisans registered on the platform (sub-merchants) in their dealings with Handsome and with public or private third parties in connection with platform activities.

3. Prohibited conduct

• Direct or indirect offer, promise, giving or acceptance of money, gifts or other benefits to/from public officials or public service officers to obtain or retain an improper advantage.
• Direct or indirect offer, promise, giving or acceptance of money, gifts or other benefits to/from private commercial counterparts (customers, suppliers, artisans, partners) to influence their decisions outside the normal course of business.
• Facilitation payments (small sums to expedite routine procedures): strictly prohibited even where allowed by local law.
• Donations to political parties, electoral campaigns or party organizations through the company. Personal donations by the Owner are permitted only if made with personal funds outside company accounts.
• Sponsorships or charitable contributions used as a shield to obtain commercial advantages.

4. Gifts and hospitality

• Gifts to/from commercial counterparts are allowed only if of modest value (≤ €50 per single gift, ≤ €150 cumulative per year toward the same counterpart) and of symbolic nature (e.g. Handsome-branded promotional items).
• Gifts to/from public officials or public service officers: prohibited at any value, even symbolic.
• Business meals and hospitality during commercial meetings allowed if reasonable and documented.
• Any gift or hospitality exceeding €50 must be recorded in the Gifts & Hospitality Register kept by the Owner.

5. Conflicts of interest

The Owner, collaborators and sub-merchants must disclose any conflict of interest, including potential, that may influence the platform's commercial decisions. Relevant conflicts are managed via recusal, abstention or public disclosure.

6. Counterparty due diligence

Before initiating new significant commercial relationships (volumes > €10,000/year or counterparties operating in high-corruption-risk jurisdictions per Transparency International CPI), the Owner conducts proportional due diligence on reputation, ownership structure, public criminal records, adverse media.

7. Whistleblowing channel

Any party (collaborator, artisan, customer, supplier, third party) suspecting or detecting a violation of this Policy or of anti-corruption principles may report confidentially to:
info@handsomemakers.com (subject: Whistleblowing — Anti-Bribery Policy)

The reporter is protected against retaliation per Italian Legislative Decree 24/2023 (transposing EU Directive 2019/1937 — Whistleblowing). Reports are handled with utmost confidentiality, reporter's identity is never disclosed without written consent.

8. Consequences of violations

• For collaborators: disciplinary measures up to termination of contract;
• For artisans (sub-merchants): immediate suspension of profile and reporting to competent authorities for criminally relevant facts;
• For suppliers and consultants: contract termination for just cause;
• Reporting to competent Judicial Authority for criminally relevant facts.

9. Training and review

The Owner attends annual anti-corruption training (minimum 4 hours/year). This Policy is reviewed annually or upon significant regulatory changes or relevant events.

10. Approval

This Policy has been approved by the Owner as sole executive officer of the Sole Proprietorship on 19 May 2026.