OPERATIONS: Policies & Procedures MANUALwebapps.framinghamma.gov/weblink/0/edoc/1138115/HCA - Framingham MA…Page 1 OPERATIONS: Policies & Procedures MANUAL CONFIDENTIAL NewCann Group,

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OPERATIONS: Policies & Procedures

MANUAL

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 OPERATIONS: Policies & Procedures MANUAL. 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.

Operations: Policy & Procedures Manual - CONFIDENTIAL January 28, 2019 NewCann Group, LLC

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OPERATIONS: Policy & Procedures Manual Contents

◆ EXECUTIVE SUMMARY ..................................................................................................... 1

◆ APPROACH TO SECURITY DESIGN ...................................................................................... 2

◆ SECURITY PLAN ................................................................................................................. 2

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◆ STAFF & CUSTOMER SECURITY .......................................................................................... 5

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◆ EXTERNAL SECURITY ......................................................................................................... 6

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◆ INTERNAL SECURITY .......................................................................................................... 9

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◆ Product Security ............................................................................................................. 12

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◆ EMPLOYEE HANDBOOK .................................................................................................. 14

⚫ Summary .................................................................................................................................. 14

⚫ Policies & Procedures ............................................................................................................... 14

⚫ Qualifications ........................................................................................................................... 15

⚫ Job Descriptions ....................................................................................................................... 16

⚫ Business Office ......................................................................................................................... 16

⚫ Retail Shop ............................................................................................................................... 17

⚫ Hours of Operation ................................................................................................................... 18

Table 1: Proposed Hours of Operation (NewCann) ......................................................................... 19

Table 2: Framingham Liquor Stores ............................................................................................... 19

⚫ Customer Foot Traffic ............................................................................................................... 19

⚫ Customer Vehicle Traffic ........................................................................................................... 20

⚫ Recruitment ............................................................................................................................. 21

⚫ Hiring Process ........................................................................................................................... 21

⚫ Employee Training .................................................................................................................... 22

⚫ Employee Parking ..................................................................................................................... 23

⚫ Training Roles & Responsibilities ............................................................................................... 23

⚫ Roles & Access Levels ................................................................................................................ 23

⚫ Staff Retention & Bonuses ........................................................................................................ 25

EXHIBIT III Managers, Members, and Board of Advisors................................................................. 26

◆ STORAGE OF MARIJUANA .............................................................................................. 27

◆ INVENTORY PROCEDURES .............................................................................................. 29

◆ PREVENTION OF DIVERSION ........................................................................................... 31

◆ RECORD-KEEPING PROCEDURES ..................................................................................... 33

◆ DISPENSING PROCEDURES ............................................................................................. 34

◆ MAINTENANCE OF FINANCIAL RECORDS ........................................................................ 35

◆ DIVERSITY PROGRAM..................................................................................................... 36

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◆ EXECUTIVE SUMMARY NewCann Group LLC (NewCann) was founded in December 2018 to pursue a Massachusetts marijuana establishment retail license. This manual is intended to provide permitting and licensing authorities with a detailed understanding of NewCann’s approach to operations and how the shop will interact with customers, employees, suppliers, neighbors, regulators, City officials, and the host community of Framingham at large. NewCann’s policies and procedures have been developed to be aligned with the various provisions of 935 CMR 500.000 “Adult Use of Marijuana” and includes the additional operational requirements for a Retail Shop, pursuant to 935 CMR 500.105. NewCann considered those additional operational requirements for a Marijuana Retailer set forth in 935 CMR 500.140. Massachusetts security consultant DCRM Security Solutions will implement the security system and provide off-site monitoring.


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◆ APPROACH TO SECURITY DESIGN The holistic approach we provide for security, includes active and passive measures, industry-best policies and procedures for addressing employees, customers, vendors, and the public. In addition to listing technologies and summarizing certain procedures, we describe everyday nightmare scenarios to illustrate our plan’s methods in action. Each scenario presents a problem, followed by a solution. By slowly dissecting each scene and working the problem backwards, we analyzed technology, training, processes, and procedures, to manage, minimize, or eliminate risk. This encouraged us to select “industry-best” practices and tools for accomplishing our goals. This security plan will be customized to the retail shop’s location, size, lay-out, environment, and property construction.

◆ SECURITY PLAN NewCann’s approach to security is "defense in depth.” This incorporates a holistic view of security and safety; integrating policy and procedures within the operational plan, pursuant to 935 CMR 500.110 “Security Requirements for Marijuana Establishments”. It means more than just physical security barriers.

Employees will be instructed on retail shop 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 access to minors and trespassers. Strong access control measures will limit movement in restricted areas. Much of the training will be conducted by contracted industry veterans and centers on scenarios to help staff understand how to assess that situation and respond according to policy, procedures and technology.

EMPLOYEE HANDBOOK - CONFIDENTIAL January 28, 2019 NewCann Group, LLC

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◆ STAFF & CUSTOMER SECURITY ⚫ Staff Hiring All employees will have been subject to pre-employment screening by the Cannabis Control Commission, pursuant to 935 CMR 500.030: Registration of Marijuana Establishment Agents. They will also be subjected to in-person interviews to monitor their behavior, demeanor and responses to interview questions. ⚫

⚫ Staff Training All employees participating in a paid training session prior to onboarding will have already successfully completed the background investigation, pursuant to 935 CMR 500.030. During this training, time and effort will be spent discussing proper policies and procedures and what is appropriate for employees. Learning to keep customers and other employees safe and secure will be the backdrop for the training. Employees will learn their roles and be able to train within the retail shop. These tasks will be completed before an employee will be allowed to handle product or interact alone with customers. This will be followed by ongoing in-service training to reinforce customer service, security and product knowledge. If a problem is discovered, its resolution will be a top priority. An incident response team comprised of management will follow through with documenting the post-incident report. This analysis will seek the root cause and a solution for preventing a repeat of the incident, whether through precautionary measures or changes in policy. This information is then used as feedback to further strengthen the security policy and/or its practical implementation. The incident report will document why the incident happened, despite precautions and controls, and how best to make the necessary changes and eliminate this issue in the future. NewCann will report incidents to the CCC and law enforcement as required. ⚫ Customer Security Customer safety and security will be paramount throughout employee training sessions for retail shop policies and procedures. Keeping all retail shop visitors feeling safe while also being secure will be rehearsed in scenarios during training. What roles the staff plays during emergency situations, Police, Fire or EMS calls will also rely on learned procedures and the use of technology.


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⚫ Customer Parking The property at 1094 Worcester Road has ample customer parking. There are 76 parking spots deeded to the property that are positioned in the front and side of the building. The property’s parking lot is accessed from a business entrance on Worcester Road (Rte.9) and another entrance on Winter Street. This makes entry and egress safe and easy. There will be ample lighting to assist customers and The additional parking in the rear of the building, while mainly used for employees, will also act as an overflow lot. During the first 6 months to one year, NewCann plans to deploy parking lot attendants to monitor the customer traffic flow and provide some order and discipline to the process (as necessary based upon traffic flow). ⚫ Employee Parking While the property has ample customer parking, employees will use the parking spots in the rear of the building. This will be explained during the employee training session but it is mainly to provide the premium spots in the front and side of the building for customers.

Since employees will be at the retail shop for extended

periods of time, the employee parking will use the spots furthest from the entrance.


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⚫ Customer Entrance A large vestibule is used to corral guests and customers and will be designed large enough to accommodate fire department apparatus in the event of an emergency. Vestibule size and door offsets will be specifically designed to allow easy access by a stretcher (or such other equipment size as identified by the fire department as needing to have quick and efficient access to the retail shop). ⚫ Customer Exit Depending upon the final interior design agreed to by the business team, the retail shop’s frontage and size, allows for the customer exit to be segregated from the welcoming customer entrance. This exit would be to the side of the building, parallel to Winter Street and would greatly assist with customer foot traffic. This configuration dictates that customers use a single entrance for arrivals and a separate exit for leaving the retail shop, post purchase or just to exit.

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⚫ Check-out Stations Retail sales will be concluded at one of several check-out stations (intended to be counters with tablet-style registers) and there will be:

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⚫ POS Software (Green Bits) All registers at check-out stations will use an approved cannabis-based POS system, pursuant to 935 CMR 500.140 (6)(a). NewCann has selected software vendor Green Bits as its cannabis POS software. This vendor is listed as an approved vendor by the Massachusetts Cannabis Control Commission and thus integrates seamlessly with the Metrc inventory system. It on-boards new inventory manifests seamlessly, processes sales and incoming cash and tracks ongoing revenue, while adhering to the compliance regulations specific to the Massachusetts marijuana market, pursuant to 935 CMR 500.105 (5)(f). Green Bits POS software is compatible and will include the following features:


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CCC Compliance Because Green Bits is an improved CCC vendor, it integrates effortlessly with the Metrc inventory system and tracks product sales for state compliance. It can generate template or custom reports to display the health of the retail shop. Tracking customer sale limits, pursuant to 935 CMR 500.140 (4), “a Marijuana Retailer may not sell more than one ounce of marijuana or five grams of marijuana concentrate to a consumer per transaction”.

Online Inventory Integration Green Bits integrates directly with the CCC Metrc system, saving the retail shop the staff time and effort from duplicating input efforts. Not only does the inventory exactly match the items on-hand but new delivery items will be added from the electronic manifest and subtracted through sales at the check-out stations. The company’s website will accurately reflect the current menu and reflect it on Leafly, Weedmaps and other online sites. Customers will be able to order and pay online and have the order waiting for pick up in the retail shop after age verification. Representing an online menu that is always up-to-date will reflects favorably on the retail shop and will be appreciated by customers.

Marketing Tools A POS system should include marketing tools as part of the service. Having the ability to send digital marketing campaigns through email and text can greatly enhance how the retail shop engages with customers. Defining customer categories will allow the retail shop to send targeted promotions to specific demographics. Green Bits can boost foot traffic with easy to offer discounts to veterans, high value customers, social media followers, etc.

Encrypted Cloud Storage Preventative measures further indicate that the POS software should automatically copy and encrypt all data and video surveillance. Sending this data to the cloud by utilizing 256-bit SSL file encryption, will ensure that the information is stored safely and securely.


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Green Bits also performs additional core functions for the retail shop with data-driven dashboards previewing day/week/month sales and inventory figures. Properly implemented, this system can save a significant amount of time and labor. It will help the retail shop staff maximize sales, improve the customer experience, and even assist with record keeping and compliance concerns. It is also compatible with NewCann’s growth plans and easily integrates with multiple retail shop locations. ⚫ Order Online/Pick-Up in Retail shop One value-added feature that NewCann plans to offer is the online order/pick-up option. This is very appealing to our management team as the system will decrease customer wait times and increase customer capacity, and reduce any traffic issues. Through the Green Bits POS system, all potential customers will be able to “view” the up-to-date menu offering on the company website, or through Leafly or Weedmaps. For NewCann’s repeat customers with existing accounts, they will be able to make their selection, place an order and pay, then head to the retail shop immediately or later to pick-up their reserved and paid selection. Obviously, due to the restricted, adult-only sales of this product, there will be 100% certainty that the online party is the same individual picking up the product; matching the customer’s state or government-issued ID and the credit card used for the online sale.

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◆ EMPLOYEE HANDBOOK ⚫ Summary Preliminary: EMPLOYEE HANDBOOK contains subjects, policies, procedures, roles and responsibilities necessary to comply with state regulations 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. All personnel policies will be outlined for the staff in the Employee Handbook, pursuant to 935 CMR 500.105(1). Each member will be expected to have read it and will be quizzed on different sections, enough to encourage learning. Some of the policies will be role specific and will be included in the training manual while others will be NewCann specific. Host communites expect their residents to be first in line to be; recruited, interviewed, hired and trained per the agreement put forth in most host community agreements (HCA). ⚫ Policies & Procedures Providing extensive training of NewCann’s policies and procedures, pursuant to 935 CMR 500.000, will allow employees to operate at an extremely high level of professionalism in the adult use of marijuana industry. Policies and procedures will guide employees on the proper way to handle product, money, regulations and compliance while also interact with customers and the public.

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⚫ Qualifications Selecting knowledgeable employees from the local area and preferably from the host community will be an important but difficult goal. Most applicants will be budtenders (sales associates working the floor) and will found through industry networking, word of mouth and local newspaper postings. These employees will be 21+ years old and receive ~$15.00/hr upon starting and after a 3-month probationary period, their rate will go up to $17.00/hr with regular pay raises and bonuses throughout employment. All proposed wages and salaries will be at the upper end of market rate. There will be several days of paid training for all new employees on the premises. Training will be done by contracted industry veterans. They will take industry newcomers and transform them into knowledgeable budtenders (sales associates). They will teach strain preferences, attributes, product choices and industry trends in order to educate and inform customers. There will be NewCann’s policies and procedures to learn and it will finish by shadowing another employee on the retail floor for a day to view customer questions and interactions. As NewCann matures, opportunities will be available for advancement and new employees will be trained to join the staff. Providing the proper tools through training and then rewarding that success is sound business principles but it also improves output and morale. Allowing employees to advance encourages dedication amid an expectation of a quality performance. All NewCann Group employees will undergo a complete background check including a CORI check. NewCann is registered with the iCORI System and the account is activated as an Employer with Required Level 1 access. All employees of NewCann will be required to sign an Acknowledgement Form at the time of Application for Employment as well as a Release of Information Authorization. Each of these forms will be executed annually on the anniversary of hire. CORI checks will be completed through iCORI at least annually and/or at other times when warranted. All CORI and background information will remain confidential and maintained in a


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locked filing cabinet. Any information derived from a CORI check will be provided to the affected employee prior to any discussion about same. ⚫ Job Descriptions Typically, there will be an abundance of applicants who are eager to enter the growing marijuana industry and while it is best to hire employees with as much experience as possible, we expect to hire a blend of knowledgeable staff and less-experienced Framingham residents who will be improved through training. In a new industry, experience may be lacking but training can teach the information if the candidate wants to learn. Customer-facing roles include Retail Shop Manager, Receptionist and Budtender. Attracting talented and knowledgeable budtenders will mean above average compensation with desirable staff retention programs and bonus policies. The extra cost will be offset by staff efficiencies and lower turnover. This combination will result in a high customer retention rate, as well as, increased sales. Providing extensive product and industry training (paid) prior to onboarding a new staff member will be beneficial for a cohesive staff that is equally knowledgeable and comfortable in the role. All NewCann employees will be assigned a tablet computer to assist customers. Additional digital displays will be on the walls and behind the counter, along with a customer-friendly smart phone app. The retail shop’s website will be designed so customers can review the inventory, available products, prices and cannabinoid properties (Strain Name, THC%, THCA & CBD%) prior to visiting the retail shop. Industry resources and reviews will also be available online through Leafly and Weedmaps. ⚫ Business Office

Leadership Team

• David Rabinovitz

• Jack Madigan

• Judy Leary

• Beth Goldstein

• Dr. Edward B. Kaiser The leadership team provides direct management over all facets of the business and includes key business advisors. Leadership Team responsibilities will 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


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

Shop Manager Running the day-to-day operations of a cannabis retailer involves a variety of responsibilities including scheduling staff, accepting incoming inventory manifests, and meeting with sales persons. Managers will be required to be fluent in compliance, customer service, and operational protocols. The store manager will be fanatical about personal hygiene in the retail shop. Breath mints in the retail space and Purell dispensers on the wall for employees and customers alike. Perfumes, after shave ad other strong scents will be discouraged amongst the staff. Attracting a discerning clientele means providing marijuana as the focal point without distractions. Ensuring that employees understand strains and are knowledgeable about different attributes. Like a restaurant’s “Daily Catch”, the retail shop’s menu of marijuana strains will be constantly changing weekly and even daily depending on supply and demand. The POS software will integrate automatically with the retail shop’s website menu and Leafly, Weedmaps, and other online menu services, the updated menu will be visible on the digital display above the counter. This, in turn, means that prospective customers will get accurate information—including current inventory, prices, weights, and other relevant data. Customers will order online and can have their product waiting for them at the retail shop as “Take Out”. This allows the budtenders to concentrate on providing top-notch customer service rather than manually updating menu listings online. Receptionist This first point of contact in most retail marijuana shops is the receptionist. The receptionist is responsible for verifying state identification which is vital for compliance.

Budtenders One of the most coveted positions for marijuana industry newcomers is that of the budtender. They are the representatives of the retail shop and will be selected with consideration of the following qualities:


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Customer Service While Some customers may know exactly what they want, others may have just a general idea. A budtender should create a safe space for the customer to explore their options. Budtenders should be able to provide a brief uncomplicated explanation of the products and their effects. The budtender should have a friendly demeanor and be an effective communicator. Knowledgeable It is crucial to have at least a basic understanding of the product and industry before becoming a budtender. Knowing the difference between Indica, Sativa, and Hybrid flower, learning the POS system, weight increments, labeling, and intake are required skills. Multi-Tasker The ability to multi-task during a business day. Dependable Being on-time and dependable is important for budtenders. Etiquette This refers to the handling of marijuana but also how budtenders manage their sales room. Rarely will an experience budtender reach into a jar of Indica or Sativa without the use of tongs or chopstick to handle flower, because they don't want to contaminate the batch, a seasoned budtender will also take the time to explain how to use the product. Diplomatic Not every customer will know or respect the rules inside of a retail shop, but it is important a budtender understands how to deal with these situations with assertiveness and diplomacy.

Parking Lot Attendants During the first 6 months to one year, NewCann plans to hire parking lot attendants to manage the influx of customers discovering NewCann’s retail shop. There are 76 available parking spots which will need to be rotated. All parking lot attendants will have two-way radios to communicate amongst themselves and assist each other when necessary. Assisting incoming and outgoing vehicle traffic will be necessary during peak hours. Incoming traffic will be directed into the Worcester Road entrance or onto Winter Street for the second access entrance. During peak hours, all traffic will exit onto Winter Street and access Worcester Road (Route 9) after the stop sign and taking a right. Having attendants that can communicate with customers in a friendly manner while directing them to follow direction will be important. ⚫ Hours of Operation During the first six months to one year, NewCann will open at 1094 Worcester Road (Rte.9) with the following hours of operation. Sundays opening for eight hours and Monday through Saturday open for 12 hours. These business hours reflect the liquor stores hours in the area, with many


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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 Rte.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 the store will serve between 200 and 300 customer cars per day. NewCann projects 80% of that traffic will occur over six to eight hours. Cultivate reported at a Framingham public meeting that an average retail customer spends five minutes from the time they reach a counter until the customer departs the store. Cultivate estimates their Framingham store will serve 200 customers per day and they allot 15 minutes per customer. These figures are from a Community Outreach Meeting to address concerns by neighbors regarding vehicle traffic and a perceived lack of parking at Cultivate’s proposed Framingham location. ⚫ Recruitment Priority hiring of local residents to work in NewCann’s retail shop is meant to provide local knowledge of the regional customer base while also fullfilling an agreement made in the HCA. This can be beneficial for the City and NewCann. A local employee hearing gossip on the street or from neighbors about a specific concern locally allows NewCann to address flare-ups before they can become full-blown town issues. NewCann’s commitment to a Diverse Workforce:

• Participate in Diversity Job Fairs, partner with a local workforce organization;

• Utilize the MA Supplier Diversity Office to identify certified minority, women, and veteran-owned businesses for vending and contracting services and opportunities;

• Annually measure the diversity of the retail shop employees against the demographics of the host community and publicize the results;

• Promote efforts online and in the local media to make greater impact.

⚫ Hiring Process NewCann’s hiring policy will follow all state and federal requirements regarding equal employment, non-discrimination, and civil rights of persons with disabilities. NewCann will complete the Certification of Assurance of Compliance: ADA and Non-Discrimination based Disability. NewCann has already researched organizations to assist with disabled worker employment services and training. The selected location for NewCann’s retail shop has been vetted for ADA compliance for staff and customers (street level, no stairs, fully ADA compliant). All NewCann employees will undergo a complete background review including a CORI check. NewCann is registered with the iCORI System and the account is activated as an Employer with Required Level 1 access. All employees of NewCann will be required to sign an Acknowledgement Form at the time of Application for Employment as well as a Release of Information Authorization. Each of these forms will be executed annually on the anniversary of hire. CORI checks will be completed through iCORI at least annually and/or at other times when warranted.


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All CORI and background information will remain confidential and maintained in a locked filing cabinet. Any information derived from a CORI check will be provided to the affected employee prior to any discussion about same. NewCann will maintain a CORI Policy that will conform to the standards set by DCJIS. ⚫ Employee Training In addition to policies and procedures, training shall be tailored to the roles and responsibilities of the job function of each employee. There will be instruction on the medical and recreational marijuana industries; including current products and new arrivals and trends in the industry, pursuant to 935 CMR 500.105(2)(a). Prior knowledge of the industry will not be necessary, but personality and demeanor with a willingness to learn will be considered assets. Training will also address employee conduct and how best to interact with customers and how best to educate them on a regulated product sold only to adult customers 21 years or older. A budtender will start at $15.00/hr during the 3 month (90 day) probationary period for all new employees and a raise to $17.00/hr at that point. Growing a future customer base relies heavily on reputation. Producing new and return customers means creating positive interactions with the NewCann staff and leaving satisfied by the experience and better informed on your purchase. NewCann will educate employees on the CCC regulations and how to be compliant through adherence to company policies and procedures, pursuant to 935 CMR 500.300 Inspections and Compliance. Investing in NewCann’s employee learning and development will be worth the outlay. Employees who are treated well, treat their employers well. In a fast-growing business and industry, when every month a new state is legalizing recreational or medical marijuana, staying on top of training and development is paramount. This includes ensuring that all staff is well-versed on safety procedures, security protocols and how best to detect and respond to theft and threats, and ensure the safety of customers. Training topics will address:

• What's the difference between THC and CBD?

• How do Indica and Sativa differ?

• What's the correct dosage for edibles?

• What's the advantage of vaping as opposed to smoking?

• What are the state’s limits for individual customer quantity for retail marijuana? The personnel policies will be outlined fully for the staff in the EMPLOYEE HANDBOOK, pursuant to 935 CMR 500.105(1). Each member will be expected to read the Handbook and be quizzed on different sections, enough to encourage learning. Some of the policies will be role specific and will be included in the training manual while others will be NewCann specific. These policies will include:


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Diversity • Equal Employment Opportunity

Commission (EEOC) Statement • Anti-Harassment Policy and

Complaint Procedures • Americans with Disabilities Act

(ADA) & Amendments Act (ADAAA)

Employment • Employee Classification Categories • iCori, Background and Reference

Checks • Internal Transfers/Promotions • Nepotism, Employment of Relatives

and Personal Relationships • Progressive Discipline • Separation of Employment

Workplace Safety • Workplace Bullying • Violence in the Workplace • Safety • Drug & Smoke-Free Workplace

Workplace Expectations • Conflicts of Interest • Attendance and Punctuality • Attire and Grooming • Electronic Communication, Internet

& Social Media - Acceptable Use • Solicitations, Distributions and

Posting of Materials • Employee Personnel Files

• Proposed Wages/Time Off/Leaves of Absence/Benefits

⚫ Employee Parking Every employee will be directed to specific employee-only parking spots located in the back of the property, 1094 Worcester Road, and indicated with Employee Only signage (until customer traffic reaches a normalized activity level). This will leave the most convenient and valuable spots in the front of the building for customers and guests. If an employee visits the shop on a non-work day, they are entitled to park in any spot on the property. ⚫ Training Roles & Responsibilities As this is a Preliminary Employee Handbook, the final version of this document will include a break-down of each employee’s role and responsibilities. Each process and procedure will be examined during the employee training sessions. It is important to communicate the roles of each employee and what is and is not expected from the staff. This will include the following movements for dealing with cannabis, money, security and data. The following are just some of the procedures that require a more meaningful analysis:

• Inventory Procedures

• Prevention of Diversion

• Record-Keeping Procedures

• Maintenance of Financial Records

• Dispensing Cannabis Procedures ⚫ Roles & Access Levels Each role with the retail shop will require specific training as the roles and responsibilities are analyzed and defined. It will be important to discuss the actual movements for each individual


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employee, and the responsibilities expected from employees.

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Maintenance of Financial Records The CFO, the retail shop manager and the CPA will have access to any financial records. All will have Read Only access but the CFO will also have Edit access and will manage any additional or necessary access to the data. Otherwise, the retail shop manager and budtenders may have access to custom reports on their Tablets, generated through the


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Green Bits POS system but this will be viewing up-to-date financial reports, documents on customer purchases and individual reports.

⚫ Staff Retention & Bonuses Staff turnover can be a stressful situation for any business but especially for a marijuana retail shop. Hiring a new employee requires a thorough interview process, verifying references from previous employers, and strong intuition. There will be a starting hourly wage of $15.00/hr for budtenders and after a successful 3 month probationary period, a raise to $17.00/hr with bonuses. In addition to policies and procedures, there will be education on the medical and recreational industries, current products and new arrivals and trends in the industry. Prior knowledge of the industry will not be necessary, but personality, a nice demeanor and an interest to learn will be considered assets. Growing a future customer base relies heavily on reputation. Producing new and return customers means creating positive interactions with the NewCann Group staff and leaving satisfied by the experience and better informed on your purchase. NewCann will reward budtenders that inform and educate new visitors while greeting returning customers with friendliness and great service. This approach needs to be acknowledged with visible bonuses that increase sales and removes the mystery of the product. A pool of money that will be made available on a quarterly basis to fund bonuses with spot rewards (gift cards, movie passes, etc.) for exceptional performance. Personality and knowledge can be successful, similar in personality to a good bartender. This bonus program will quickly increase the effective hourly rate from $15/$17/hr.


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EXHIBIT III Managers, Members, and Board of Advisors

NewCann Group LLC

Functional Role Name Date of

Birth

Business Email Business Address

1 Strategy & Finance David Rabinovitz 12/07/1959 [email protected] 17 King Philip Trail Norfolk, MA 02056-1405

2 Operations, Inventory

& Customer Experience John E. Madigan 12/21/1964 [email protected]

215 Prairie Street Concord, MA 01742

3 Marketing & Customer

Experience Prof. Beth Goldstein 05/07/1963 [email protected]

92 Wingate Road Holliston, MA 01746

4 Operations, Security &

Compliance Judy Leary 06/12/1956 [email protected]

24 Ashmont Drive Framingham, MA 01702

5 Advisor Dr. Edward Kaiser 10/01/1944 [email protected] 17 King Philip Trail Norfolk, MA 02056-1405


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◆ STORAGE OF MARIJUANA

Safe Storage While on the premises, proper storage containers will be used to preserve the quality of cannabis extracts, flowers and other products. However, through their training, budtenders will be able to educate adult customers on the proper storage of marijuana products in their own homes. Not only is keeping marijuana out of sight and hidden from children encouraged, it also has an added benefit, it maintains the quality of the product. The rules for proper long-term storage are the same for the retail shop or a customer at home:


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• Keep cool - Avoid the warmth. Keep away from pipes, the backs of heaters, hot water systems etc.

• Keep dark - Light degrades THC potency. Be clean: Make sure jars, bags and containers are clean.

• Cured properly - Providing properly cured marijuana to customers, its long-term storage depends on it.

• Proper containers - Use glass or glazed ceramic jars. Plastic can encourage sweating. Employee Handling Marijuana flower product should be stored in a sealed bag or container. The containers will have unique labels on the exterior to allow that item to be tagged for sale at the check-out station. In some cases, there will be a sister label in the bag to allow tracking even if the exterior label is destroyed or illegible. The retail shop will offer either a refund for returned bags or a discount for collecting and returning a specific number of bags. Aside from practicing responsible environmental stewardship, this policy will encourage customers to retain the bags and return them for future discounts and dispose of them properly.

Containers for Cannabis Extracts Cannabis extracts and concentrates can’t just be stored anywhere. Some consistencies of concentrate are not meant to be stored in glass jars. Some stick to glass and can be extremely difficult to get it all out. On the other hand, consistencies like live resin sauce or budder are easier to scoop out of small glass jars. The ideal environmental conditions to properly store cannabis concentrates is about the same for all consistencies. However, the best storage containers will vary based on the consistency of the extract. Containers for Cannabis Flowers Cannabis flowers can remain potent for long periods of time but proper storage is an absolute must. If it is too dry it can reduce quality; too moist and it can run the risk of moldering. These two factors are very important. If the cannabis flower is properly cured, successful long-term storage is possible. Curing will allow for a perfect internal humidity of the plant material. Extracting moisture content preserves quality and discourages mold. Relative Humidity Storage There is no perfect way to store cannabis for long periods. However, monitoring the retail shop’s inventory for aging products can create opportunities for promotions and sales. However, on the consumer side, storage duration depends on the habits of each individual adult consumer. However, the ideal (RH) range for storing cannabis is between 55-62%. This range inhibits mold growth, yet guarantees bud quality and resin integrity. A well-balanced moisture content in their immediate atmosphere will keep buds fluffy, aromatic, and potent for months. Like many food items that are stored long-term, the label will say "Store in a cool, dark place." The same goes for all cannabis. A cool, temperature-stable area away from light is perfect for storing cannabis long-term. Light degrades THC and warmth will cause mold.


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◆ INVENTORY PROCEDURES Metrc System Metrc has both commercial and regulatory system features. The commercial part of the application will be used in the retail shop, and is used to capture the required POS data while the regulatory features are used for enforcement and compliance monitoring, pursuant to 935 CMR 500.140 (G)Recording Sales (1). Inventory control is one of the top features. At all times, with POS software, all movements are recognized and inventory is accurate in real-time. NewCann will be utilizing Green Bits POS software in the retail shop. As a Massachusetts Cannabis Control Commission approved vendor, Green Bits communicates directly with the Massachusetts Metrc system through a push-pull relationship, pursuant to 935 CMR 500.105 (7)(f)(2) & (3). This means Green Bits can push data to and pull data from Metrc. This push-pull relationship is important because it allows Green Bits to report cannabis sales to Metrc without the need for csv uploads. This relationship reduces errors and saves time. In fact, the Green Bits and Metrc integration can save employees 10+ hours per week by accepting incoming inventory manifests and transferring inventory to additional locations.

Inventory Integration Green Bits is currently the only POS system in Massachusetts capable of integrating with Leafly, Weedmaps, Baker, Wikileaf, MERRY JANE, and many others to make real-time updates to the retail shop’s online listings. Every time there’s a change, the updates are reflected in the shop’s selection, quantity or pricing. Green Bits has added three additional compliance resources and integrated them with the Metrc system. Overall, Green Bits offers one of the most comprehensive proactive compliance solutions in the legal Massachusetts cannabis industry:


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• Compliance Team - Green Bits has a dedicated compliance team to be proactive and keep abreast of changes with rules and regulations.

• Audit Tool - This tool allows for bulk inventory adjustments, a function that cannot be done in the Metrc system.

• Shared Best Practices - Most tasks can be performed in Green Bits instead of Metrc, outside accepting and transferring product.

Cannabis POS Software Tracking the inventory through a powerful cannabis POS system will improve the way a marijuana retail shop views the metrics of its business. Technology has revolutionized the way cannabis retailers do business and provides many advantages that can significantly cut down on product loss through inventory tracking, state compliance, and tracking revenues and expenses. It has also improved the ability to produce future marketing programs: Loyalty Programs, Follow-Up Surveys, SMS Campaigns, and Social Media Incentives.

• State Compliance: compliance reporting; tracking of sales and expense reports

• Digital TV Displays: inform and entertain customers, add valuable advertising

•

• Remote Monitoring: viewed as dashboard, real-time updates on sales and customers

• Custom Reports: Gross Sales, Payment Methods, Top Sellers, Top Categories, Customer Analytics, Referral Retention, Expenses, and Average Wait Time.


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◆ PREVENTION OF DIVERSION Diversion may occur wherever controlled substances are found. Detecting product diversion within the retail operations is a challenging task that requires creativity and collaboration among all parties. Product diverters are aware that management is attempting to discover and thwart their actions while their focus is on outwitting surveillance and concealing their activity.

Employee Training While staff can be trained to recognize behavioral signs of diversion, it is important to remember that outward indicators are usually late signs. Employee training will highlight the diversion prevention program and discuss the seriousness of the theft of a regulated product by either an employee or a customer and the requirement to report the incident to law enforcement and the CCC. The message will be delivered clearly, if management investigates and discovers a suspected diverter, reporting to the authorities will be swift and severe, pursuant to 935 CMR 500.110 (7).

First-Rate Employees Hiring good employees, paying them well and treating them respectfully can go a long way to tightening of processes. This can be achieved through open lines of communication expressed during staff meetings and quarterly staff review sessions to gain insights and avoid future issues.


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◆ RECORD-KEEPING PROCEDURES Technology Solution To effectively manage the unique demands of the rapidly growing cannabis industry, NewCann will rely on business management technology for most its record keeping. All procedures will be tracked within the technology with automatic updates and back-ups done behind the scenes. An effective cannabis-based POS system (Green Bits) will provide real-time dashboards and reports for the accountant and the CFO will have report metrics that are accurate readily available. Making the records of the retail shop available for inspection by the Commission and maintaining the records in accordance with generally accepted accounting principles, pursuant to 935 CMR 500.105(9) Record Keeping. POS System Making sure that the employees rely on the POS system procedures for all transactions will be important and covered during the training period. The cannabis business software solution can be as simple or as comprehensive as necessary. Business intelligence and digital metrics provide in-depth knowledge of the business and processes. It should maximize profits while controlling expenses and manage customer relationships while increasing loyalty. Record Maintenance NewCann’s records will be maintained in accordance with generally accepted accounting principles and will be made available for inspection. Written records that are required for inspection include, but are not necessarily limited to, all records required, in any section of 935 CMR 500.000, in addition to the following:

• Operating Policies & Procedures, as required by 935 CMR 500.105(1);

• Inventory Records, as required by 935 CMR 500.105(8);

• Personnel Records, as required by 935 CMR 500.030(2);

• S2S Tracking Records for all Marijuana Products, as required by 935 CMR 500.105(8)(e);

• Business Records, as required by 935 CMR 500.105(9)(e);

• Background Check Reports, as required by 935 CMR 500.030(e);

• Waste Disposal Records, as required 935 CMR 500.105(12);

• And any other records or documentation required for the retail shop’s business and subject to inspection by the Commission.

Record Disposal A record for all products must be maintained and nothing is disposed of without a written record with an audit trail, as required under 935 CMR 500.105(12). As for physical and digital records, all records must be kept for at least two years, in a form and location acceptable to CCC.


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◆ DISPENSING PROCEDURES Age Verification NewCann’s main concern is safety and security for customers, employees and product within the retail shop.

Transaction Limit Since the initial government-issued ID scan has identified the customer, the budtender will limit the customer’s sales transaction to “one ounce of marijuana flower or five grams of marijuana concentrate, per consumer, per transaction,” pursuant to 935 CMR 500.140 (4). A purchase is not required for entry into the retail shop, but the transaction limit will be strictly adhered to for all marijuana products. If a purchase is within the limit and compliant, the sale will be completed.

The customer then exits the retail shop.


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◆ MAINTENANCE OF FINANCIAL RECORDS Record Maintenance NewCann’s financial records will be maintained in accordance with generally accepted accounting principles and will be made available for inspection. The POS software (Green Bits) can automatically copy and encrypt all financial data and send it to the cloud by utilizing 256-bit SSL file encryption. This will ensure that the data is stored safely and securely by the retail shop for the potential for a CCC audit or inspection. Written records that are required for inspection include, but are not necessarily limited to, all records required, in any section of 935 CMR 500.000. Record Disposal A record for all products must be maintained and nothing is disposed of without a written record with an audit trail, as required under 935 CMR 500.105(12). As for physical and digital records, all records must be kept for at least two years, in a form and location acceptable to CCC.


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◆ DIVERSITY PROGRAM Positive Impact NewCann believes it can promote diversity, as identified in 935 CMR 500.040 and 500.100, with plans to establish a Cannabis-based Incubator and Training Facility; CannaVenture Labs (operated with its own CCC Application and License process). NewCann will target individuals from areas of disproportionate impact, to act as Agents and operate under the CannaVenture Labs license, as entrepreneurs and business training in the cannabis industry. With license approval, the incubator and training facility could be an attractive vehicle for diversity funding by other retail cannabis industry participants seeking to make an impact. Cannabis-based Incubator Each CCC licensee is required to create and promote a diversity plan and an incubator and training facility could be a perfect opportunity for them. The incubator will be a business launch facility; that includes an industrial kitchen, conference room, work cubicles and a receptionist. The training facility will constantly be welcoming speakers and lecturers. The professional services offered will be business and technology subjects. There will be business training offered within the incubator to participants from the host community and our impacted areas. Individuals with recently sealed marijuana records, could use it to launch careers in the marijuana industry. This effort will offer resources and assistance:

• Access to traditional sources of capital and provide debt and/or equity funding;

• Offer business mentors and business support groups for individual entrepreneurs;

• Work with LISC Boston to identify individuals (21+) from areas of disproportionate impact, knowledgeable about entrepreneurship and interested in the cannabis industry;

• Utilize the MA Supplier Diversity Office to identify certified minority, women, and veteran-owned businesses for vending and contracting services and opportunities.

Training Facility Professional services & instructional training will be held at the location during the day and evenings and weekend days. Providing professors, entrepreneurs, and business professionals to conduct training in business, entrepreneurship and the marijuana industry:

Business: accounting, marketing, finance, compliance, regulations Technology: phone, web, computers, POS systems, spreadsheets, MS Word Workspace: industrial kitchen, conference rooms, receptionist, work cubicles

Documents

OPERATIONS: Policies & Procedures MANUALwebapps.framinghamma.gov/weblink/0/edoc/1138115/HCA - Framingham MA…Page 1 OPERATIONS: Policies & Procedures MANUAL CONFIDENTIAL NewCann Group,