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BUSINESS PLAN CONFIDENTIAL NewCann Group, LLC PREPARED FOR The City of Framingham Marijuana Advisory Team January 28, 2019 This is a CONFIDENTIAL DOCUMENT and is to be redacted from public access documents. It sets forth details of the issuer’s Business Plan. It should not be copied, disseminated, shared, or otherwise disclosed without the issuer’s prior written approval or used for any other purpose other than regulatory review.

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Page 1: CONFIDENTIAL - Framinghamwebapps.framinghamma.gov/weblink/0/edoc/1138116/HCA... · CONFIDENTIAL NewCann Group, LLC PREPARED FOR The City of Framingham Marijuana Advisory Team January

BUSINESS PLAN

CONFIDENTIAL

NewCann Group, LLC

PREPARED FOR The City of Framingham

Marijuana Advisory Team January 28, 2019

This is a CONFIDENTIAL DOCUMENT and is to be redacted from public access documents. It sets forth details of the issuer’s Business Plan. It should not be copied, disseminated, shared, or otherwise disclosed without the issuer’s prior written approval or used for any other purpose other than regulatory review.

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BUSINESS PLAN - CONFIDENTIAL January 28, 2019 NewCann Group, LLC

BUSINESS PLAN Contents

◆ EXECUTIVE SUMMARY ................................................................................................... 1 ⚫ Overview ...................................................................................................................................1 ⚫ Mission ......................................................................................................................................1 ⚫ Vision .........................................................................................................................................1 ⚫ Core Values ................................................................................................................................1 ⚫ Keys to Success ..........................................................................................................................2

◆ ORGANIZATION & MANAGEMENT .................................................................................. 3 ⚫ Legal Entity ................................................................................................................................3 ⚫ Start-Up Summary ......................................................................................................................3 ⚫ Start-Up Financing ......................................................................................................................4 ⚫ Long-Term Viability ....................................................................................................................4 ⚫ Leadership Team and Key Advisors .............................................................................................5

◆ INDUSTRY ANALYSIS ...................................................................................................... 6 ⚫ Market Size - Massachusetts .......................................................................................................6 ⚫ Average Market Rate (AMR) .......................................................................................................7 ⚫ Industry Marketing Data & References........................................................................................7 ⚫ S.W.O.T. Analysis .......................................................................................................................8 ⚫ Marketing & Promotional Strategy .............................................................................................9 ⚫ Branding & Positioning ............................................................................................................. 10 ⚫ Competition ............................................................................................................................. 11 ⚫ Sales Strategy ........................................................................................................................... 11

◆ RETAIL SHOP LOCATION ............................................................................................... 13 ⚫ Property Description ................................................................................................................ 13 ⚫ Building Description ................................................................................................................. 14 EXHIBIT I: Site Plan ....................................................................................................................... 15 EXHIBIT II: Site Building ................................................................................................................ 15 ⚫ Hours of Operation ................................................................................................................... 16 Table 1: NewCann: Proposed Hours of Operation .......................................................................... 16 Table 2: Framingham Liquor Stores – Average Operating Times ..................................................... 16 Table 3: Framingham Liquor Stores – Actual Operating Times ....................................................... 16 ⚫ Customer Foot Traffic ............................................................................................................... 17 Table 4: Check-out Station Count (Average: 7.5 minute cycle) ....................................................... 17 Table 5: Check-out Station Count (Average: 10 minute cycle) ........................................................ 17 ⚫ Customer Purchase Experience ................................................................................................. 17 ⚫ Customer Vehicle Traffic ........................................................................................................... 18 ⚫ Vehicle Traffic Flow .................................................................................................................. 19 EXHIBIT III: Vehicle Traffic Flow .................................................................................................... 20 ⚫ Parking Availability ................................................................................................................... 20 ⚫ Securing the Site ...................................................................................................................... 21 ⚫ External Security ...................................................................................................................... 21 ⚫ Internal Security ....................................................................................................................... 22

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BUSINESS PLAN - CONFIDENTIAL January 28, 2019 NewCann Group, LLC

◆ PRODUCTS & SERVICES ................................................................................................ 23 ⚫ Customer Values ...................................................................................................................... 23 ⚫ Product Quality ........................................................................................................................ 23 ⚫ Education & Services ................................................................................................................ 23 ⚫ Delivery ................................................................................................................................... 23 ⚫ Product Sourcing ...................................................................................................................... 24 EXHIBIT IV: Product Line ............................................................................................................... 24

◆ FINANCIAL PLAN .......................................................................................................... 25 ⚫ Summary of Project Costs ......................................................................................................... 25 EXHIBIT V: Facility Costs ............................................................................................................... 25 EXHIBIT VI: Personnel Costs .......................................................................................................... 25 EXHIBIT VII: Overhead Costs ......................................................................................................... 25 ⚫ Break-Even Cost Assumptions ................................................................................................... 26 EXHIBIT VIII: Break-Even Projections ............................................................................................. 26 ⚫ General Staffing Levels ............................................................................................................. 26

◆ SECURITY PLAN (Attachment) ....................................................................................... 27

◆ EMPLOYEE HANDBOOK (Attachment)........................................................................... 28

◆ OPERATIONS: Policy & Procedures MANUAL (Attachment) ........................................... 29

Additional Attachments ◆ SECURITY PLAN (Attachment) ◆ Preliminary EMPLOYEE HANDBOOK (Attachment) ◆ OPERATIONS POLICY & PROCEDURES MANUAL (Attachment)

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BUSINESS PLAN - CONFIDENTIAL January 28, 2019 NewCann Group, LLC

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◆ EXECUTIVE SUMMARY

⚫ Overview NewCann Group LLC (NewCann), 17 King Philip Trail, Norfolk, MA 02056-1405, is a Massachusetts limited liability company, No. 001357153, organized December 3, 2018. As defined by 935 CMR 500.002, NewCann is pursuing a Host Community Agreement with the City of Framingham in order to file a license application with the Massachusetts Cannabis Control Commission (“CCC”) to become a fully licensed adult-use marijuana (retail) business establishment. This Business Plan follows requirements for licensure of a marijuana establishment, pursuant to 935 CMR 500.000 “Adult Use of Marijuana” and includes the additional operational requirements for a Retail Shop, pursuant to 935 CMR 500.105. It is also intended to comply with additional operational requirements for a Marijuana Retailer, pursuant to 935 CMR 500.140. NewCann will comply with all CCC regulations pertaining to compliance pursuant to 935 CMR 500.300 Inspections and Compliance.

⚫ Mission NewCann’s mission is to “Operate a community-friendly business that provides safe and secure access to adult-use marijuana for age appropriate customers in the Commonwealth of Massachusetts.”

⚫ Vision Serve as a model facility that operates in full compliance with City expectations and State law, maintaining the highest standards of professional conduct:

• Operate with complete adherence to state regulations and local ordinances, and maintain an open and fluid working relationship with all government authorities, including law enforcement and members of the Cannabis Control Commission.

• Maintain financial viability to support the ongoing mission to serve customers, the community and the Commonwealth.

• Act as a responsive and responsible neighbor to residents and neighboring businesses; engage with community leaders, citizen groups and the public in a responsible manner.

• Provide Tax-Free cannabis for current DPH medical card holders to improve their quality of life.

• Provide Tax-Free cannabis for U.S. veterans with a Military ID card to improve their quality of life.

⚫ Core Values Our core values will be represented by the following mantra; “Kind staff, kind customers, and kind product”. NewCann will be an approachable, community-oriented, adult-use marijuana retail shop that provides Massachusetts customers with:

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High Quality Products Provide safe, high-quality marijuana products from licensed Massachusetts cultivators with approved third-party processing and quality testing by an approved independent laboratory. Responsiveness Dealings with customers, employees, lenders and the community, providing an open means of communication to complaints and concerns. Transparency Financial data will be audited by an independent certified public accounting firm. Educational Outreach Conduct varied and ongoing community-based outreach activities to serve the needs of the community, provide facts and information on safe use of adult-use cannabis use. Be a “Good Neighbor” Work with the community, the city and police department as a responsible business owner.

⚫ Keys to Success • Act as a responsible business in the community and develop close working relationships

with civic, business, and government leaders and their staffs.

• Highly detailed planning and execution is critical.

• Put significant effort into the staffing, training, and infrastructure plans required to reliably provide safe and secure, high-quality cannabis, delivered via an industry-envious staff.

• Planning for cash flow and general financial management.

• Maintain high standards and apply industry best practices across the entire operation with a focus on continuous learning and improvement.

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◆ ORGANIZATION & MANAGEMENT

⚫ Legal Entity NewCann Group, LLC (NewCann), 17 King Philip Trail, Norfolk, MA 02056-1405, is a Massachusetts limited liability company, No. 001357153, founded December 3, 2018, to pursue a Massachusetts adult-use marijuana establishment license, in accordance with 935 CMR 500.002. As a limited liability company, there is no Board of Directors but the members have elected to oversee the entity with a five-person advisory board consisting of three members and two outside advisors. Day-to-day operations are managed by two managing members.

⚫ Start-Up Summary Following are some of the milestones NewCann has accomplished thus far:

• Researched locations and attended numerous Framingham Community Outreach and Planning Board meetings to understand resident and planning board concerns for marijuana and cultivation operations.

• We secured a location west of the Golden Triangle (and west of FSU) that has (a) ample parking (76 spaces), opportunity for overflow parking from an industrial property on an adjoining lot; (b) access from BOTH Worcester Road and a thoroughfare roadway (Winter Street), thus alleviating full dependence upon Route 9 entry and exit; and (c) no immediate retail neighbors where our customers could clog their parking lot.

• We secured a Letter of Intent (LOI) with the landlord on January 21, 2019, to site a Massachusetts adult-use marijuana retail establishment at:

1094 Worcester Road (Route 9), Framingham, MA 01702

• This site address has been submitted to the Framingham Planning Department (Amanda Loomis) for an informal site assessment. The response back did not raise any initial issues or concerns.

• According to the Framingham Zoning Department, 1094 Worcester Road, is located within Framingham’s Marijuana Retail Establishment Overlay District.

• Prepared to submit a Massachusetts adult-use marijuana establishment license application with the Massachusetts Cannabis Control Commission. This application is divided into three distinct packets;

1. Application of Intent Packet; 2. Background Check Packet; 3. Management and Operations Profile Packet.

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⚫ Start-Up Financing Management has assumed a start-up budget of $1 million as follows:

Working capital through opening (rent, fees, professionals) $100,000

Demolition and Fit-up $150,000

Retail Fixtures $60,000

Security, Lot Lighting $40,000

Start-up Capital (90-days costs) $240,000

Start-up Capital (prepaid and deposits) $40,000

Inventory $220,000

Misc. and Contingencies $100,000

The NewCann team members have ample resources to fund the costs without need of investors or borrowing. However, our intention is to allow in outside investors upon securing confirmation our application packet has been received by the CCC and confirmed as complete (e.g. award of an HCA).

⚫ Long-Term Viability NewCann will ensure its long-term viability through a continuing focus on three key pillars of operation:

Stay True to the Mission NewCann’s mission is to “Operate a community-friendly business that provides safe and secure access to adult-use marijuana for age appropriate customers in the Commonwealth of Massachusetts.” This mission statement acts as a yardstick against which we measure our actions and performance.

Involving Stakeholders Stakeholders actively participate in shaping the direction and future of the retail shop. Conduct ongoing efforts to seek feedback from stakeholders including customers, employees, suppliers, neighbors, government officials, and the host community at large on key matters involving NewCann. We do this by conducting periodic surveys, hosting open meetings, and actively encouraging submission of feedback.

Financial Viability We are committed to providing services at a fair value. As a limited liability company, there is no Board of Directors but the members have elected to appoint a five-person advisory board to oversee the entity consisting of three members and two outside advisors. Day-to-day operations are managed by two managing members.

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⚫ Leadership Team and Key Advisors • David Rabinovitz

• Jack Madigan

• Judy Leary

• Beth Goldstein

• Dr. Edward B. Kaiser The leadership team provides direct management over all facets of the business. Leadership Team responsibilities include:

• Developing and implementing business strategy and plan for NewCann retail shops and related activities (including social impact initiatives)

• Represents NewCann as the public face in the host community

• Developing and motivating staff; oversight of day-to-day business operations including security, inventory control, and staff development

• Monitoring financial performance

• Assuring complainace in all facets (CCC, tax, other regulatory, host community)

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• Age Distribution: Henry J. Kaiser Family Foundation, Population Distribution by Age (2016)

• Population Density: United States Census Bureau, American Fact Finder, PEPANNRES Annual Estimates of the Resident Population: April 1, 2010 to July 1, 2015, 2015 Population Estimates

• AMR: Colorado Department of Revenue https://www.colorado.gov/pacific/sites/default/files/AMRChangeFactSheet July2018 final.pdf

• Local Pricing: www.priceofweed.com http://www.priceofweed.com/prices/United-States/colorado.html http://www.priceofweed.com/prices/United-States/massachusetts.html

⚫ S.W.O.T. Analysis This SWOT analysis (Strengths/Weaknesses/Opportunities/Threats) provides an opportunity to examine the internal strengths and weaknesses that NewCann must address. It also examines the opportunities and potential threats that are beyond the control of NewCann.

Strengths The following strengths are specific to NewCann:

• Executives - qualified, professional management team with backgrounds in business and management, strong advisory board, and a strong support team of outside professionals.

• Technology - heavy reliance on technology and financial systems (e.g. employee and physical access controls, cameras, Green Bits POS, Metrc, and Cloud Storage, etc.).

• Retail Shop Site - Ideal location in Framingham, Massachusetts, ample parking (~76+ parking spots), exit and entry access to Rte.9 is excellent but not exclusive (access from Winter Street), and located with convenient access to Rtes. 495 and I-90.

• Community - experience as Framingham employers with real ties to the community.

• Capital - Access to sufficient financial resources. Weaknesses The following weaknesses are internal to NewCann:

• Lack of comprehensive market data for the adult-use retail marijuana market.

Opportunities The following are opportunities NewCann can leverage that lie outside of its organization or control:

• Public acceptance of adult-use marijuana consumption is growing.

• State and federal policies toward legal adult-use marijuana are more tolerant.

• There is a significant underserved, legal adult-use marijuana market in Massachusetts.

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Threats The following factors represent potential threats that lie outside NewCann's organization and control:

• There are still significant negative images by society about cannabis use. NewCann will continue to monitor trends and work to effect change through high operational standards, good community relations and by playing an active role in changing public attitudes about retail and medical cannabis.

• The dynamic tension between federal and state government regarding legalities of medical and retail cannabis is not fully resolved. NewCann will be compliant with state and local ordinances.

• Irresponsible users of cannabis will negatively impact the product.

• The economy could slow and dampen NewCann’s performance forecast.

⚫ Marketing & Promotional Strategy Many marijuana retail shops have found that word of mouth and a media campaign are two of the most important ways to build awareness and attract new guests and retain repeat customers. NewCann will leverage these and other proven methods of marketing to accomplish its stated objectives while complying with the advertising and promotion limitations of 935 CMR 500. In view of data and opportunities presented within this Plan, the following summarizes general marketing objectives for this marijuana retail shop in the next one to two years of operation:

Heighten Standards and Recruit Members NewCann plans to attract and grow both customers and revenue as it fine-tunes operations and expands services. Increase Brand Awareness One of the early challenges for a retail shop is generating awareness and earning high brand loyalty. Our focus will be:

• While many Massachusetts retail stores choose decorative wall décor from tile to stone to barn board, we expect to use much of the wall space for well-designed educational material that can be read or watched (videos) on personal hand held devices (phones and tablets).

• With a focus on educational material and financial incentives for staff to keep learning and developing expertise, we intend to leverage knowledge to create a leading edge customer experience.

• With our affiliation with CannaVenture Labs (a cannabis business incubator), we hope to have a wide selection of locally-produced craft products and plan to highlight the entrepreneurs and their story on a rotating basis.

• Offer specific focused promotions (e.g. veterans, cancer patients, etc.).

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Public Relations Managed coverage in local media is another way NewCann will work to increase awareness and positive information about its services. Periodic press releases will be furnished to local press, including the Massachusetts newspapers, community newsletters, hospice and customer bulletin boards to highlight the retail shop’s progress and work in the community. We plan to offer educational sessions for Framingham seniors interested in understanding the therapeutic benefits of cannabis in coordination with the Framingham Council on Aging/The Callahan Center. We intend to develop a similar relationship with Framingham Veterans Services. Client Marketing NewCann will actively work to increase customer numbers and encourage loyalty with promotions to our client base. Because of this relationship, marketing must be permission-based and low-key. However, tasteful communications to members that educate and gently promote products are not inappropriate providing they respect privacy and do not violate any laws. Messaging will include on-site promotional material, as well as occasional emailed communications to members who have specifically opted in. Viral Marketing Satisfied clients can be the most effective means to promote NewCann, particularly once a strong brand has been established. Therefore, additional effort will be directed at better leveraging its customer population to evangelize on NewCann’s behalf. NewCann will develop a formal “guest referral program” at the check-out stations during the sales process. A new customer will have the opportunity to name a referring party’s name and every 3 or 5 referrals will be eligible to promotional reward. This will encourage and benefit current clients to refer NewCann’s name and location to new guests and potential customers.

⚫ Branding & Positioning NewCann’s staff focus will be professional in appearance, and highly knowledgeable with the product, the industry and other aspects of marijuana. Customer interactions should be positive and allow guests to see themselves as a positive, integral part of the community—rather than as an isolated subculture standing in opposition to the mainstream. This approach is designed to better meet the needs of customers who seek a modern, clean, safe and professionally managed facility. General differentiators that appeal to customers will include the following:

Service Orientation NewCann’s staff will include customers and caregivers (with a preference for Framingham residents), with some who have survived an illness. We are truly committed to service quality and providing a high degree of information to customers in a consultative format.

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High Quality Cannabis NewCann will focus on providing safe, high-quality marijuana without chemicals, pesticides or mold. Approved independent laboratories must test every cannabis batch prior to the sale by a licensed wholesale cultivator. Use of Current Technology NewCann will utilize POS software, Metrc and bar-coding of products to track inventory and manage transactions. Technology provides more data points for analysis and helps better decisions be made and improves ways to service customers.

⚫ Competition Competition is difficult to gauge in an industry that is developing and in its earliest stage. NewCann believes that:

• Between Framingham and Natick there will be (8 stores) along 9.6 miles of Rte. 9.

• Additional local competition will be Shrewsbury (3 stores), Marlborough (4 stores) and Hudson (2 stores). Within the Rte.128 / Rte.95 / Rte.495 / Rte.9 block, all other towns except Millis (1 store) have banned retail marijuana.

• To the north, Weston, Wayland, Sudbury, and Stow have all banned retail marijuana sales (Wayland’s ban will not become official until a town meeting vote in April).

Based upon these factors we believe the Worcester Road area, with the limited zoning from Natick and Framingham, could become the equivalent of the Norwood Automile but for marijuana. In such a case, the concentration of competitors may serve to increase, rather than decrease, revenue opportunities. We believe – with no formal research but relying on the knowledge of two of our executive team members, one current and one former Framingham resident, that locals will prefer retail locations on the less congested parts of Rte.9 rather than in the heart of the Golden Triangle.

1. Judy Leary is a current 62-year Framingham resident. She was born and raised in town and married and raised her own family here. She and her brother operated the business they assumed from their father in Framingham for over 30 years.

2. David Rabinovitz is a former Framingham resident (Winter Street) and opened his first business on New York Avenue in Framingham.

⚫ Sales Strategy Our sales strategy can be summarized as follows:

1. Use financial incentives to motivate staff to become specific subject matter experts in various marijuana products and applications. Customers will also be incentivized with a customer referral program and tracking customer accounts through the POS to offer points, discounts and sales items. This will target all customers, but specific attention will

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◆ RETAIL SHOP LOCATION

⚫ Property Description The property at 1094 Worcester Road (Route 9) was built by local developer Kevin Giblin as a retail plaza and converted to a medical facility by the current owners to house their business, Framingham Orthopedics. The practice has been steadily downsizing and with some doctors retiring, we were in the right place, at the right time. NewCann has exhaustively scoured the Framingham area, researching and visiting properties since receiving a draft zoning map from the Planning Department’s Amanda Loomis, in late September 2018. Our selection of this property was driven by several factors including discussions with city counselors and other active parties that NewCann members met at zoning and other community outreach meetings. Those interactions informed NewCann’s criteria for the various concerns of abutters to different properties in various locations. The selected site seeks to avoid or minimize objections that have arisen from other Framingham properties.

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The retail shop location at 1094 Worcester Road (Rte.9) in Framingham offered many positive factors that led to its eventual selection:

1. Access and egress are not exclusively onto Worcester Road. This is virtually the only property in the area that is located on the corner of Worcester Road and a thoroughfare (versus a pure side-residential street not designed for pass-through traffic).

2. The building has 76 parking spaces; more than any other available property (other than possibly the Border’s / Ken’s parking lot). The rear of the property is bordered by Mayhew Street and we are in discussions with the owners of the old warehouse on Mayhew to use their parking lot for overflow parking, if needed. That could contribute another 30 to 40 parking spaces.

3. The property is not in the heart of the Golden Triangle. While the Triangle is a great retail location, it also has heavily congested traffic, especially along Rte.9 from Rte.126 and eastward.

4. Located in the “near west” zoning district (versus the “far west” from the Sheraton Tara to the Southborough line), the shop is accessible from either direction of Rte.9 with the convenience of the Edgel Road turnaround and the Temple Street jug handle each within 90 seconds of travel.

5. If Rte.9 is traffic heavy; a. customers can exit onto Winter Street and either travel north to Temple Street; b. or remain on Winter Street to Rte.135; c. or travel east past FSU and access Framingham Center, Edgel Road to Nobscott, or

enter Rte.9 east by St. Bridget’s Church. 6. These options avoid dangerous and congested intersections, and do not contribute to

customers making illegal traffic maneuvers by exiting the parking lot and illegally crossing Worcester Road.

7. This also avoids the Rte.126 underpass and the associated storm water flooding during weather events.

⚫ Building Description A multi-tenant single-level “L” shaped 14,000 SF medical/retail building presently known as Wayside Crossing, at 1094 Worcester Road (Route 9) in the City of Framingham, Massachusetts, 01702 having approximately 76 parking spaces. The building has a medical-use variance and therefore already conforms to the higher parking requirements for medical zoning. Approximately 9,000 SF on the west arm of the building presently occupied by Framingham Orthopedics. NewCann will require 2,500 to 3,000 SF for the proposed retail shop. The rear of the building is concrete block with no access (e.g. no rear doors) and plenty of lighting due to the 9-11 Mayhew property situated in the southeast corner adjacent to the railroad tracks.

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The budtender will check their method of payment name against their government-issued ID, and match both to the order code. Confirm that the order code on the order basket matches the customer’s order code, and complete the transaction with the customer. All transactions and products will be handled in complete view on the shop counter, all visible by internal shop cameras and recorded. The expectation is to have three priority check-out stations dedicated to specific customer groups:

1. For a pre-pay situation, the counter associate will remove the items from the basket and set them out on the counter, let the customer confirm the items match their order, place the items in the bag, seal the bag, and the customer will leave the shop. With no more than one person in line we believe these transactions can be completed in under two minutes.

2. A pick-up-and-pay situation follows the same procedure above except the customer will pay for the order. NewCann believes these transactions can be completed in under three minutes.

3. Customers with DPH medical cards will have access to a priority line and though we are not a medical dispensary, the products are generally the same and we intend to provide medical customers a discount to offset the sales tax expense. Initially, veterans will not be in a priority group, but will be recognized for their service through the NewCann veteran pricing model when they arrive at the check-out station.

NewCann believes most customers will become returning customers and their purchases will be routine selections. By providing a convenient way to order, we hope to increase efficiency, by decreasing retrieval and purchase times. This should increase our customer capacity while reducing parking demands. If necessary we will apply an appointment-only system using the www.QLess.com app (an app that has become popular with Massachusetts retail marijuana stores). However, we believe by the time we open there will be sufficient open stores that we will not experience the overload that was highly publicized throughout November and early December.

⚫ Customer Vehicle Traffic Estimating customer vehicle traffic is difficult as there is no reliable historical data available. Customer counts at existing Massachusetts marijuana retail establishments are impacted upward by the low count of open stores and the continued newness and novelty of retail adult-use marijuana sales. Our proposed location is further impacted by two forces; many surrounding communities have banned retail marijuana sales; and between Framingham and neighboring Natick, there will be eight marijuana retail establishments over a 9.6 mile stretch of Route 9 / Worcester Road (including a stretch of Route 30 on the backside of the Golden Triangle). Based upon presentations at Community Outreach Meetings by other proposed marijuana retailers, including one with an existing open retail location in another community, we estimate

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⚫ Securing the Site NewCann’s approach to securing the site incorporates a holistic view of security and safety; integrates physical security features along with including security policy and procedures within the operational plan, pursuant to 935 CMR 500.110 “Security Requirements for Marijuana Establishments”.

Employees will be instructed on the retail shop’s security policies, procedures and protocols, as well as being given extensive product and industry training. Providing safe access for employees and age-verified customers, is essential, while restricting minors and trespassers from the property. Strong access control measures will minimize the number of employees essential for efficient operation while limiting movement in marijuana areas and access to check-out stations. Much of the training will be conducted by contracted industry veterans and focuses on scenarios to help staff understand how to assess that situation and respond according to policy, procedures and technology.

⚫ External Security Securing the cannabis product and the retail shop begins with a hardened perimeter.

Prominently displayed and visible signage will be positioned outside the retail shop for all customers to see.

PHOTO#4ParkingLot

Facingeast(parallelRte.9E)

PHOTO#5ParkingLot

Facingsouth(paralleltoWinterStreet)

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⚫ Internal Security

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◆ PRODUCTS & SERVICES

⚫ Customer Values NewCann’s believes that customers want a top-notch, high quality product. This merchandise should be provided in a respectful, friendly manner at a competitive price. The shop is easy to find from any direction, accessible from major highways and the building has 76 parking spaces. If the experience is pleasant, the customer returns and tells others to visit.

NewCann’s Core Values: “Kind staff, kind customers, and kind product”

⚫ Product Quality The following is a general outline of how NewCann plans to approach product quality and service for its product offerings:

Strict Quality Control Guidelines All wholesale product will be tested by an approved third-party laboratory. Each wholesale cultivator will provide a print-out for each batch of product. NewCann will only offer those items which have passed the Massachusetts CCC purity standards, pursuant to 935 CMR 500.160 Testing of Marijuana and Marijuana Products.

Zero Tolerance on Product Performance Issues Any industry product or marijuana strain supply found to have a potential problem in performance, shall not be provided to customers, unless and until it passes further review and inspection.

⚫ Education & Services NewCann places a high emphasis on educational services of all types - providing ample information to help customers choose products appropriately and understand how to use them effectively and responsibly. Subject to customer interest and reception, NewCann will consider offering related services including:

• Pain Management Classes

• Educational programs with speakers and drop-in times with experts on an array of topics, for those new to cannabis

• Cooking Classes (butter, edibles, etc.)

⚫ Delivery Products will be delivered by vendor delivery vehicles or licensed marijuana transport operators.

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⚫ Product Sourcing As an independent retail shop we will purchase product from licensed manufacturers and cultivators on the open market. Our preliminary research has indicated that several established medical license holders are willing to sell product on a wholesale basis to independent stores as long as the shop is not co-located in the same municipality as one of their shops. Therefore, we are highly confident we will be able to secure product without experiencing supplier shortages. We intend to provide priority consideration to product cultivated (a) in Framingham, (b) by independent cultivators, and (c) by businesses that are generally privately-held and Massachusetts-owned. We believe it benefits the host community if we purchase product from local suppliers who have made effort to employ local residents.

EXHIBIT IV: Product Line PRODUCT LINE DESCRIPTION

Flowers A dried cannabis “buds” that can be smoked in a pipe, rolled into cigarette (or ‘joint’) smoked using a water pipe (commonly called a ‘bong’) or vaporized with vaporizer products (believed to be the safest form of inhalation).

Extracts Extracts such as hashish are manufactured by separating the trichomes (semi-transparent granular hair-like outgrowths) from the cannabis flowers to create a concentrated dose of this specific part of the cannabis plant.

Preparations Joints, tinctures, dermals, nectars, salves

Edibles Edibles are foods cooked with butter or oil that has been infused with cannabis (e.g. bars or cookies). Edible cannabis usually takes longer to take effect (20 minutes to an hour or more) and the effects generally last longer than smoking or vaporizing.

Accessories* Grinders, vaporizers, pipes, etc.

Books Books, DVDs relating to cannabis use and cultivation

*NewCann may offer branded wearable hemp merchandise at some future point.

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◆ SECURITY PLAN (Attachment) The NewCann’s Security Plan includes a comprehensive security plan that guides virtually every aspect of the retail shop’s daily operations regarding security policy, procedures and protocols. The plan totals over 18 pages and provides the framework to discuss NewCann’s approach to all manner of security-based issues and topics, including: Security Plan Contents ◆ APPROACH TO SECURITY DESIGN ◆ SCENARIOS ◆ SECURITY PLAN ◆ STAFF & CUSTOMER SECURITY ◆ EXTERNAL SECURITY ◆ INTERNAL SECURITY ◆ PRODUCT SECURITY ◆ EXHIBIT I: PRODUCT LINE

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◆ EMPLOYEE HANDBOOK (Attachment) The NewCann’s Employee Handbook is a preliminary document that includes a comprehensive guide to virtually every aspect of daily employee interactions within each department. The handbook totals 17 pages and provides the framework to discuss NewCann’s approach to all manner of employee-based issues and topics, including: ◆ EMPLOYEE HANDBOOK

• Policies & Procedures

• Qualifications

• Job Descriptions

• Roles & Responsibilities

• Recruitment

• Hiring Process

• Employee Training

• Staff Retention & Bonuses

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◆ OPERATIONS: Policy & Procedures MANUAL (Attachment) The NewCann’s Operations: Policy & Procedures Manual includes a comprehensive guide to virtually every aspect of operations policy and procedures for each department. The manual totals over 44 pages and provides the framework to discuss NewCann’s approach to all manner of operations-based issues and topics, including: Operations: Policy & Procedures Manual Contents ◆ SECURITY PLAN

• Policy & Procedures

• Technology

• Employee & Customer Security

• External Security

• Internal Security

• Product Security ◆ EMPLOYEE HANDBOOK

• Policies & Procedures

• Qualifications

• Job Descriptions

• Roles & Responsibilities

• Recruitment

• Hiring Process

• Employee Training

• Staff Retention & Bonuses ◆ STORAGE OF MARIJUANA ◆ INVENTORY PROCEDURES ◆ PREVENTION OF DIVERSION ◆ RECORD-KEEPING PROCEDURES ◆ DISPENSING PROCEDURES ◆ MAINTENANCE OF FINANCIAL RECORDS ◆ PROOF OF LIABILITY INSURANCE ◆ PROPOSED OPERATIONAL TIMELINE ◆ DIVERSITY PLAN PROGRAM