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HomeMy WebLinkAboutCSE-20-57 Traditional Fresno ME RedactedApplication Type Social Equity Criteria Applicant (Entity) Information Social Equity Cannabis Business Permit Application CSE-20-57 Submitted On: Nov 13, 2020 Applicant Maritza Estrada maritza.estrada@southcordholdings.com In order to qualify as a social equity applicant, applicants must satisfy at least one of the following criteria: 1. Low income household and either: a. A past conviction for a cannabis crime, or b. Immediate family member with a past conviction for a cannabis crime. 2. Low income household in a zip code identified as at least 60% according to the CalEnviroScreen for five (5) consecutive year period and either: a. A past conviction for a cannabis crime, or b. Immediate family member with a past conviction for a cannabis crime. 3. Low income household and either: a. Five (5) years cumulative residency in a zip code identified as at least 70% according to the CalEnviroScreen, or b. Ten (10) years cumulative residency in a zip code identified by CalEnviroScreen. 4. Business with no less than fifty-one percent (51%) ownership by individuals who meet Criteria 1 and 2 above. 5. Cannabis social enterprise with no less than fifty-one percent (51%) ownership by individuals who meet Criteria 1 and 2 above. 6. An individual with a membership interest in a cannabis business formed as a cooperative. Do you meet the above criteria, and want to apply as a Social Equity Applicant? Yes Please state your annual income: 8245 Do you have a past cannabis conviction? No Do you claim eligibility based on a family member past cannabis conviction? No Do you represent a cannabis social enterprise? No Do you have a membership interest in a cannabis cooperative? No Application Type Proposed Location Applicant (Entity) Name: Traditional - Fresno - ME LLC DBA: -- Physical Address:City: Los Angeles State: CA Zip Code: 90011 Primary Contact Same as Above? No Primary Contact Name: Arthur Reyna Primary Contact Title: Attorney at Law Primary Contact Address: Primary Contact City: Glendale Primary Contact State: CA Primary Contact Zip Code: 91202 Primary Contact Phone: 2108850517 Primary Contact Email: ar@arthurreynalaw.com HAS ANY INDIVIDUAL IN THIS APPLICATION APPLIED FOR ANY OTHER CANNABIS PERMIT IN THE CITY OF FRESNO?: Yes Select one or more of the following categories. For each category, indicate whether you are applying for Adult-Use (“A”) or/and Medicinal (“M”) or both Both Please make one selection for permit type. If making multiple applications, please submit a new application for each permit type. Permit Type Retail (Storefront) Business Formation Documentation: Limited Liability Company Property Owner Name: -- Proposed Location Address: -- City: -- State: -- Zip Code: -- Property Owner Phone: -- Property Owner Email: -- Assessor's Parcel Number (APN): -- Proposed Location Square Footage: -- Supporting Information Application Certification Owner Information List all fictitious business names the applicant is operating under including the address where each business is located: -- Has the Applicant or any of its owners been the subject of any administrative action, including but not limited to suspension, denial, or revocation of a cannabis business license at any time during the past three (3) years? No Is the Applicant or any of its owners currently involved in an application process in any other jurisdiction? Yes If so, please list and explain: Majority Member / Owner, Maritza Estrada, has an approved / pending operational license as an owner of 8301 Western Holdings LLC in the City of Los Angeles, CA. Minority Member / Owner, Aaron Mamann, has (i) active / operational licenses as an owner of California Organic Treatment Center, Inc., in the City of Los Angeles, CA, and Essential Co LLC in the City of Adelanto, CA, (ii) approved / pending operational licenses as an owner of Demeter Retail Group LLC, Kore Retail Group LLC, and Ash Retail Group LLC in the City of Los Angeles, CA, and Essential Co LLC in the City of Adelanto, CA, and (iii) a pending application as an owner of Virid Retailers LLC in the City of Stanton, CA. I hereby certify, under penalty of perjury, on behalf of myself and all owners, managers and supervisors identified in this application that the statements and information furnished in this application and the attached exhibits present the data and information required for this initial evaluation to the best of my ability, and that the facts, statements, and information presented are true and correct to the best of my knowledge and belief. I understand that a misrepresentation of fact is cause for rejection of this application, denial of the permit, or revocation of a permit issued. In addition, I understand that the filing of this application grants the City of Fresno permission to reproduce submitted materials for distribution to staff, Commission, Board and City Council Members, and other Agencies to process the application. Nothing in this consent, however, shall entitle any person to make use of the intellectual property in plans, exhibits, and photographs for any purpose unrelated to the City's consideration of this application. Furthermore, by submitting this application, I understand and agree that any business resulting from an approval shall be maintained and operated in accordance with requirements of the City of Fresno Municipal Code and State law. Under penalty of perjury, I hereby declare that the information contained in within and submitted with the application is true, complete, and accurate.I understand that a misrepresentation of the facts is cause for rejection of this application, denial of a license or revocation of an issued license. Name and Digital Signature true Title Majority Member Please note: the issuance of a permit will be determined based on the application you submit and any major changes to your business or proposal (i.e. ownership, location, etc.) after your application is submitted may result in a denial. For details about the information required as part of the application process, see the Application Procedures & Guidelines, City of Fresno Municipal Code Article 33 and any additional requirements to complete the application process. All documents can be found online via this link. For questions please contact the City Manager’s Office at 559.621.5555. Owner Name: Maritza Estrada Owner Title: Majority Member TRADITIONAL - FRESNO - ME LLC ATTN: ARTHUR REYNA, ATTORNEY AT LAW PHONE: | EMAIL: AR@ARTHURREYNALAW.COM Page 1 of 19 Business Plan for Traditional - Fresno - ME LLC Introduction & Executive Summary Traditional - Fresno - ME LLC (our “Company”), through its Owners / Members and officers has an unmatched track record of successful and timely development, establishment, and operation of cannabis businesses—in particular cannabis retail businesses—throughout the State of California. Our Company’s Owners / Members are a team of experienced professionals and stalwarts of the cannabis industry that include: (i) the owner and operator of one of the largest and most successful cannabis business portfolios in California and the U.S. with an established dedication and investment in social equity cannabis businesses and (ii) a young Latina that overcame growing up one of the most heavily impacted communities by the War on Drugs to graduate from college and go on to be a Majority Owner of a social equity retail cannabis business in the City of Los Angeles. Through its Owners / Members and officers, our Company will bring the Traditional brand to the City of Fresno (“Fresno” or the “City”) and operate an all-inclusive, elevated cannabis retail business that is custom-tailored and completely integrative and symbiotic with the local neighborhood. I. Company Organizational Chart for Traditional - Fresno - ME LLC Section 1 – Business Plan Page 3 of 19 Aaron Mamann, Minority Owner / Member & Retailer Manager of Traditional - Fresno - ME LLC Aaron’s vision with regard to the Traditional brand was to create a company that prided itself as a premiere cannabis brand in California, but as a distinguished employer, as well. Aaron and his management team have focused on creating a positive work environment with some of the best employee benefits in the industry and ample opportunity for professional growth. Over the last several years, Aaron has diversified Traditional’s portfolio by investing and developing commercial and industrial properties for cannabis cultivation, manufacturing, distribution, and retail facilities. The Traditional family of commercial cannabis businesses own in excess of 75,000 square feet of office property and are completing the development of over 630,000 square feet of industrial buildings. As the founder of the Traditional brand, Aaron has worked hard to develop one of the leading, fully operational, fully vertically integrated commercial cannabis companies. Aaron has overseen the acquisition and development of seven operating facilities holding 17 California state licenses for cultivation, manufacturing, distribution, and retail activities throughout Southern California with confirmed expansions of two additional retail dispensaries in Los Angeles and five additional confirmed expansions of cultivation, manufacturing, and distribution operations in the state. Aaron brings with him extensive commercial cannabis business experience as a co-founder and owner of the Traditional brand. With over 15 years of experience in the California cannabis industry, Aaron has created and grown several successful and profitable cannabis businesses in various segments of the industry. He specializes in designing and building out licensed world- class cultivation, manufacturing, and distribution facilities and retail dispensaries that both maximize production while minimizing costs and inputs. Aaron has managed specialized cannabis employees and processes on all levels of the cannabis industry for many years. He is a hands-on leader who will be involved in the day-to-day executive management of the business. Aaron has a penchant for negotiation and an eye for spotting and fostering talent from within his businesses. In addition to the Traditional’s own branded products, by leveraging Aaron’s long-standing industry relationships, he ensures a varied, consistent supply of high-quality, tested, and compliant cannabis and cannabis products is stocked in each of the retail dispensaries under the Traditional family of commercial cannabis businesses. Aaron’s deep knowledge of designing state-of-the-art cultivation facilities has allowed Traditional to develop a line of high-quality flower that it sells and distributes the rapidly growing Traditional brand. Aaron’s guidance on every level of Traditional’s cultivation operations has contributed Section 1 – Business Plan Page 4 of 19 greatly to the overall success of the brand by ensuring that all of Traditional’s retail dispensaries are always fully stocked. The contributions Aaron has made to the building designs and systems layouts of Traditional’s large-scale cultivation, manufacturing, and distribution facilities have become industry-leading examples. With an eye for quality cannabis genetics and a skill for selecting the right phenotypes, Aaron’s ongoing work developing the line of cannabis flower products that Traditional offers cannot be understated. As the Traditional brand continues to expand across California, this growing menu of strains makes the brand even more desirable. With Aaron ensures not only high- quality flower in every Traditional jar, but also a wide variety of flavors that keep customers interested in the brand and its research and development of different strains of cannabis flower. Aaron has a long history of creating well-paid, full time jobs with benefits in the expanding cannabis industry. He is a passionate leader who aims to continue setting the industry standards for licensed cannabis operators in California. This commitment to quality shines through in all of Traditional’s facilities, operations, and product offerings. Section 1 – Business Plan Page 5 of 19 II. Operating Budget & Pro Forma for Traditional - Fresno - ME LLC Our Company’s pro forma is based on the real-world experience of its Owners / Members successfully developing and operating numerous other cannabis business—in particular, cannabis retail businesses—throughout Southern California. In other words, our Company’s pro forma is NOT based on estimates or some “model”, but rather is built from the actual financial data from an existing cannabis retail business operation. More specifically, our Company has taken the existing financial performance of the highly successful cannabis retail business and extrapolated that data based on the following assumptions: A. After having submitted its original Commercial Cannabis Permit application in November 2020, the City of Fresno will approve our Company’s Commercial Cannabis Business Permit Application by May 2021. B. Our Company will spend approximately in professional fees to prepare its Commercial Cannabis Business Permit Application and will owe the City’s additional fees upon submission and approval. C. Upon approval of its Commercial Cannabis Business Permit Application, our Company will engage legal counsel, land use consultants, and architects and spend in professional fees to acquire a Certificate of Occupancy. D. Our Company will have a construction budget and schedule prepared by our Owners / Members’ long-time cannabis construction contractor. E. The estimated construction budget for our Company’s proposed cannabis retail business is (not including budgeted for furniture, fixtures, and equipment). F. In the extensive experience of our Owners / Members’ successfully developing cannabis retail businesses in California, upon approval of our Company’s Commercial Cannabis Business Permit Application in June 2021, development of our Company’s cannabis retail business will follow the timeline below: 1. May 2021 to July 2021: In our Company’s experience, it takes 45 to 60 days to prepare a building permit application and 30 to 60 days for local approval of said building permit application. Our Company will submit its building permit application as soon as logistically and legally possible. 2. August 2021 to October 2021: Upon the approval of building permits, our Company will immediately commence construction according to the following 13-week schedule: Section 1 – Business Plan Page 6 of 19 3. October 2021: Our Company will begin hiring and training employees in the month prior to opening. G. Our Company’s cannabis retail business will commence operations in November 2021 and owe approximately in licensing fees to the City and the State prior to legally commencing operations. H. Our Company’s proposed cannabis retail business will take 12 months to reach the current revenue levels of our Owner / Member’s existing cannabis retail businesses. I. After attaining the current revenue levels of our Owner / existing cannabis retail businesses, gross revenue at our Company’s proposed cannabis retail business will grow approximately 2% every month. J. Our Company will agree to a public / community benefits / social equity contribution to the City of 3% of gross revenue. K. Our Company considers the first year of rent and the first three months of estimated operating expenses and inventory on hand as startup costs for a cannabis retail business. L. Our Company’s Owners / Managers will serve as officers of our Company and perform vital executive roles for our dispensary without the guarantee of salary compensation, but pay all other employees a Living Wage plus benefits. II.A Proof of Capitalization for Traditional - Fresno - ME LLC Our Company will be capitalized by the personal wealth of our Owner’s / Member’s and his highly successful existing cannabis businesses. Section 1 – Business Plan Page 7 of 19 II.B Prospective Start-Up Costs II.C Employees & Payroll Section 1 – Business Plan Page 8 of 19 II.D Cannabis Retail Business Operations Pro Formas II.D.1 Cannabis Retail Business Operating Pro Forma – 2020 Section 1 – Business Plan Page 9 of 19 II.D.2 Cannabis Retail Business Operating Pro Forma – 2021 Section 1 – Business Plan Page 13 of 19 III. Cannabis Retail Business Operations Our Company will establish and operate cannabis retail business (the “dispensary”), pursuant to a Commercial Cannabis Business Permit issued by the City. At a high-level, the Company will conduct the following activities as part of its dispensary operation: (i) Our Company will purchase, from licensed distributors, finished cannabis and cannabis products (“cannabis products”) that have undergone the quality assurance, inspection, and testing procedures contained in Section 26110 of the California Business and Professions Code (the “B&P Code”) and (ii) our Company will offer cannabis products for retail sale to customers and patients (“customers”) at the dispensary and via delivery vehicles from the dispensary, as follows: III.A Day-to-Day Operations 1. Following security check-in, transportation vehicles of licensed distributors approach rear of the dispensary and then distribution personnel enter Vendor Entry, and our Company's employees offload cannabis and cannabis products. 2. The Company’s employees transfer cannabis and cannabis products from the Vendor Entry to Intake / Order Processing / Prep, and after verifying that cannabis and cannabis products have (i) passed the quality assurance and inspection procedures contained in Section 26110 of the B&P Code, (ii) been issued a certificate of analysis pursuant to Section 26110 of the B&P Code, and (iii) all applicable METRC tags and matches the cannabis products in the METRC system, our Company’s employees transfer the cannabis products into their METRC packages and physically from Intake / Order Processing / Prep to Secure Storage. 3. Prior to staging and display for final sale, our Company’s employees transfer cannabis products from Secure Storage to Intake / Order Processing / Prep for barcoding, and then our Company’s employees transfer properly tagged cannabis products staged and entered into our point-of-sale system from Intake / Order Processing / Prep (i) to Vendor Entry for loading into delivery vehicles by the Company’s delivery drivers for retail sale to customers via delivery vehicles or (ii) to Product Point-of-Sale Stations for purchase by customers via the Retail-Buy Room. 4. Customers enter the dispensary via the Lobby where employees and security scan their government issued identification and verify medical recommendations for patients to ensure they are allowed to purchase cannabis products. 5. Validated customers enter the Retail-Buy Room via a limited access door and (i) interact with the employees, (ii) observe securely displayed cannabis and cannabis products, and (iii) have limited and/or supervised interaction (touching, smelling, etc.) with securely displayed cannabis products; validated customers purchase and take possession of processed orders of cannabis products at the Product Point-of-Sale Stations. After finishing their business purpose for visiting the dispensary, customers are securely allowed to exit the dispensary by our Company’s employees. Section 1 – Business Plan Page 15 of 19 III.C Hours of Operation & Closing Procedures Our Company shall operate the dispensary Monday through Sunday (seven days a week) pursuant to the following daily schedule: (i) Morning-shift employees and security disarm the alarm and open the dispensary for non-public operations at 9:00 a.m.; (ii) from 9:00 a.m. to 10:00 a.m., morning-shift employees stage cannabis products for display and ultimate retail sale to customers; (iii) morning-shift employees open the dispensary for public operations at 10:00 a.m.; (iv) from 10:00 a.m. to 10:00 p.m., the dispensary is open to the public and customers may engage in the retail purchase of cannabis products; (v) evening-shift employees close the dispensary for public operations at 10:00 p.m.; (vi) from 10:00 p.m. to 11:00 p.m., evening-shift employees return unsold cannabis and cannabis products back to overnight secured storage; and (vii) evening-shift employees close the dispensary and arm the burglar alarm at 11:00 p.m. An overnight camera monitoring service observes to ensure no one enters or comes near the dispensary until the following day at 9:00 a.m. Any time the dispensary is not open for operations, our Company shall ensure the following: (i) the dispensary will be securely locked with commercial-grade, non-residential door locks; (ii) the dispensary’s alarm system shall be active and an overnight security monitoring service will watch to ensure no one attempts to get close or enter the dispensary; (iii) all cannabis products shall be stored in a locked safe or vault; and (iv) only authorized employees and contractors shall be allowed to enter the dispensary. III.D Cash Handling & Opening Procedures Many customer transactions at our Company’s dispensary will be conducted in cash. As a result, our Company has developed special procedures. Our Company will have all cash in locked fire and waterproof safes inside a secure vault accessible only with a key code. The cash safes will be monitored 24/7 with a camera and our alarm monitoring service. Prior to opening our dispensary for business each day, our onsite manager who has access to the vault room and safe and a witness will remove the cash left in vault and count out the cash and sign off on a receipt with date, time amount, and name and signature of person leaving the cash in vault. This same procedure will be repeated every day at closing. Every two hours, the onsite manager will pull cash from all the registers and above procedure will take place with receipt before placing the cash in the vault room and safe. Employees will be instructed to place all large currency bills under the top drawer and to have the onsite manager remove the funds prior to every two hours if their register count is higher than . Cash is not to be accepted or disbursed by employees unless that employee has been authorized by the onsite manager to handle cash for a specified purpose. When an employee receives cash, it is to be deposited promptly as authorized. Any employee that handles cash is responsible for that cash. Retention of cash received from outside sources for use as petty cash or for making change is prohibited. Use of cash funds or cash receipts for cashing checks is prohibited. Access to cash shall be limited and all funds shall be kept secure at all times. Cash receipts / handling operations are subject to management review. In all instances, one person will check the work performed by another. All cash receipts must be completely and accurately recorded in the financial records of the dispensary. Appropriate separation of duties shall be employed in all cash operations/handling functions. All cash receipts shall be deposited daily. Employees shall count all cash drawers and safe transfers Section 1 – Business Plan Page 16 of 19 in a location in the dispensary that is not accessible by customers. Employees shall not count or reconcile cash drawers while standing at the cash register during business hours. All change funds and cash register drawers shall be kept in a locked safe when not in use. Deposits bags shall be stored in a separate, locked section of the safe. Only the onsite manager shall have access to the safe combination and the safe room. Our Company will attempt to contract with a local financial institution for arrangements to be made for armored car cash pickups daily for same financial institution. In the event that our Company is unable to procure financial institution-based armored car services, our Company has identified The Night Drop Retrieval System for aiding the safe transportation and depositing of cash. In addition to the above, whenever possible our Company will evaluate and develop cashless business solutions. III.E Receiving Deliveries & Product Handling Procedures Our Company shall prearrange the receipt and transportation of cannabis and cannabis products, and preauthorized transportation personnel shall schedule time to arrive at the dispensary. Prior to receiving or transporting cannabis and cannabis products, the Company shall request a complete electronic shipping manifest which shall contain the following information to provide a clear chain of custody to include and shall make it available upon request to the State or the City: (i) Our Company’s name and license number; (ii) the distributor’s name and license number; (iii) the names of authorized transportation vehicle drivers; (iv) a list of all cannabis products, including a description of the quantity transported; (v) the METRC UID of the cannabis products; (vi) the time and location of departure; (vii) the time and location of expected arrival; (viii) the make, model, and license plate number of the transportation vehicle; and (ix) any other information required by the State or City. Upon arrival at the dispensary, the transportation personnel shall check-in with a security guard, and the security guard will inform the onsite manager. The onsite manager will then allow the transportation personnel to enter the dispensary and provide the licensed distributor’s personnel a visitor badge and have them sign into a visitor log. Once signed in, security personnel escort the distributor’s vehicle to the limited access Vendor Entry for our Company’s employees to help offload cannabis products. Our Company’s employees then transfer the cannabis products from Vendor Entry to Intake / Order Processing / Prep for review. After verifying that (a) the cannabis products have (i) passed the quality assurance and inspection procedures contained in Section 26110 of the B&P Code, (ii) been issued a certificate of analysis pursuant to Section 26110 of the B&P Code, and (iii) all applicable METRC tags and (b) the shipping manifest that has all the information pursuant to Section 5049 of the BCC Regulations, our Company’s employees then verify the manifest also matches the cannabis products in the State’s online METRC system so that our Company can transfer the cannabis products into our Company’s METRC packages. Our Company then pays the distributor for excise tax and any money owed before physically moving the cannabis products from Intake / Order Processing / Prep to Secure Storage. Upon receipt of a shipment of cannabis products, the Company shall create a record verifying receipt of the shipment and the details of the shipment. After accepting cannabis products from a licensed distributor, our Company shall enter the following information into our internal point-of- sale tracking system: (i) The name and license number of the State licensed distributor providing the cannabis products; (ii) the name and employee number of the person entering the cannabis Section 1 – Business Plan Page 17 of 19 products into our Company’s internal point-of-sale tracking system; (iii) the best-by, sell-by, or expiration date of the cannabis products; (iv) the date of receipt of the cannabis products; (v) the METRC UID; (vi) the quantity, product name, and individual price, and applicable tax amounts; (vii) laboratory-test results; and (viii) any other information required elsewhere by the City or State. All records collected by our Company related to the receipt and acceptance of cannabis products shall be maintained for a minimum of seven (7) years and shall be made available by our Company to the officers, employees, or agents of the State or the City upon request. III.F Inventory Control Procedures & Track-and-Trace Systems Our Company shall create and maintain an active account within METRC, the State’s track and trace system prior to buying or selling any cannabis products. Our Company’s onsite manager shall serve as our Company’s designated track and trace administrator. Our Company will utilize TREEZ for its Point-of-Sale and inventory tracking system. Our Company will ensure that following policies are put into place in regards to allowing access to METRC and TREEZ. Our Company’s designated track and trace administrator will authorize additional representatives to obtain administrator accounts for both METRC and TREEZ (“track and trace systems”). Each authorized representative who is authorized to access the track and trace systems on behalf of our Company, shall obtain his or her own unique track and trace systems administrator log-on and password. Authorized representatives of our Company shall only log into the track and trace systems and submit information to the track and trace systems using a log-on that has been assigned to that representative. Our Company will maintain a complete and accurate list of all track and trace systems administrators and shall ensure that only authorized individuals are able to access the track and trace systems on behalf of our Company. Our Company shall accurately record all transactions involving the purchase, sale, physical movement, or destruction of cannabis and cannabis products in the track and trace system. Upon the retail sale of cannabis and cannabis products to a customer or patient, our Company shall collect the following information into TREEZ: (i) The name of our Company employee who processed the sale; (ii) the name or identification number of the customer who made the purchase; (iii) the date and time of the transaction; (iv) a list of all of the cannabis and cannabis products, including a description of the quantity purchased by weight and count; (v) the METRC Unique Identifier associated with the cannabis and cannabis products; (vi) any other information required by the State or City. Our Company will maintain an accurate record of its inventory and provide the City or the State with the record of inventory containing the following information for all cannabis products our Company has in its inventory: (i) A description of each item such that the cannabis and cannabis products can easily be identified; (ii) an accurate measurement of the quantity by weight and count of the item; (iii) the date and time the cannabis products were received by our Company; (vi) the sell-by or expiration date provided on the package of finished cannabis products; (v) the name and license number of the distributor that transported the cannabis products to our Company; (vi) the price paid for the cannabis products, including taxes, transportation costs, and any other costs; (vii) the gross sales by weight or count depending on the particular cannabis product. Our Company will provide a unique user login for TREEZ to the City to access our inventory at any time in real-time. Further, our Company can provide historical data using TREEZ’s reports functions that are able to access all sales that can be either printed or provided via .CSV or PDF Section 1 – Business Plan Page 18 of 19 file depending on the preference of the City. The City can readily track our Company’s cannabis inventory via TREEZ by the following categories: (i) Licensed distributor name, (ii) product type (flower, concentrate, edibles, tinctures, etc.), (iii) price, (iv) area where cannabis product is in dispensary (retail floor, vault, delivery vehicle), (v) date of entry into system, (vi) product name, weight, and count. Our Company will keep and maintain all inventory and sales data on file for at least seven (7) years. To verify that our Company’s physical inventory matches our Company’s records pertaining to inventory, our Company shall perform a reconciliation of its inventory at least once every 14 days. The results of inventory reconciliation shall be retained in our Company’s records and shall be made available to the City and the State upon request. If a significant discrepancy is discovered between our Company’s physical inventory and our Company’s inventory records, our Company shall notify the City and the State pursuant to our Regulatory Compliance Program. III.G Customer Check-In Procedures Our Company will require that all customers and qualified patients (and the latter’s primary caregivers) caregivers who wish to obtain cannabis goods must present one of the following types of identification (“ID”) upon arrival at the dispensary: (i) A document issued by a federal, state, county, or municipal government, or a political subdivision or agency thereof, including, but not limited to, a valid motor vehicle operator's license, that contains the name, date of birth, height, gender, and photo of the person; (ii) a valid identification card issued to a member of the Armed Forces that includes the person’s name, date of birth, and photo; or (iii) a valid passport issued by the United States or by a foreign government. The receptionist will run a customer’s ID through a certified ID scanner to confirm it is valid and the customer is the required age to enter the dispensary. All non-medicinal cannabis customers must possess a valid form of ID showing they are 21 years old or over; medicinal customers must possess a current and valid form of ID showing they are 18 years old or over with a valid medical recommendation or medical cannabis identification card. If the ID scanner clears the ID, but the receptionists still suspects that the ID is fraudulent, the receptionist will confirm with security the validity of the ID and do an online search (e.g., Google, Facebook, Instagram, Twitter, etc.) of the customer or cardholder’s name to see if the search shows that they are underage. Employees will go through these protocols to verify medical recommendations: (i) Only the original Medical Recommendation will be acceptable (no copies), which should have an embossed seal and/or authenticity mark; (ii) verify the Medical Recommendation directly with the issuing physician or a reputable online service; and (iii) only accept Medical Recommendations from licensed California physicians. Our Company shall have the Retail-Buy Room entrances locked at all times. All customers shall be “buzzed-in” by electronic entry to ensure limited and controlled access from the Lobby to the Retail-Buy Room. There will be a large lobby space to accompany people waiting to get into the Retail-Buy Room. Our Company follows a strict policy of no more than three (3) customers allowed on the Retail- Buy Room per one (1) employee. III.H Product Line & Customers Our Company expects to have sell a wide variety of cannabis and cannabis products including: cannabis flower, cannabis pre-rolls, infused pre-polls, vape cartridges, concentrates, edibles, tinctures, topicals, and capsules. The expected volume of sales of flower versus manufactured Section 1 – Business Plan Page 19 of 19 products is about a 50-50 ratio based on our Company’s Owners / Members previous experience operating cannabis retail businesses. The Company's dispensary will have seven point-of-sale locations and anticipates that about 15 to 30 customers will be served per hour and 175 to 300 customers served per day on a typical business day. During particularly busy days such as the unofficial cannabis holiday, 4-20, our dispensary could serve up to 50 patients per hour and 500 customers per day. III.I Delivery Service Procedures Our Company shall operate out of our dispensary initially consisting of one delivery vehicle. During deliveries, the Company’s drivers shall carry the following kept in the secured vehicle at all times: (i) A copy of our Company’s permits, licenses, and approvals; (ii) the driver’s California Driver’s License; and (iii) the driver’s laminated identification badge issued by the Company. Our Company’s drivers shall also maintain a copy of the delivery request, which shall comply with State and City law regarding the protection of confidential medical information. Our Company may only deliver cannabis and cannabis products to a physical address in the State; but shall not deliver cannabis products to a physical address located on publicly owned land or any address on land or in a building leased by a public agency. Our Company’s delivery vehicles shall be (i) insured at or above the legal requirement for the State; (ii) capable of securing (locking) finished cannabis and cannabis products during delivery; and (iii) temperature controlled for the storage of cannabis products during delivery. Further, our Company shall equip its delivery vehicles with web-based closed-circuit video monitoring equipment meeting the requirements of the Company’s Security Plan and incorporated into the Company’s video surveillance system. The Company shall equip its delivery vehicles with an active vehicle alarm system and all doors and windows shall be locked when unoccupied. Our Company’s delivery vehicle drivers shall ensure that cannabis and cannabis products are not visible to the public from the exterior of the delivery vehicle, and our Company’s delivery vehicles shall not display advertising or symbols visible from the exterior of the delivery vehicle that suggest the driver or delivery vehicle is used for the delivery of cannabis products. During delivery, cannabis products shall be locked in a fully enclosed box, container, or cage that is secured on the inside of the vehicle, includes the trunk. However, no portion of the enclosed box, container, or cage shall be comprised of any part of the body of the vehicle or trailer. In processing delivery orders, our Company will request customers email our Company a copy of their government issued ID and in the case of a qualified patient or primary caregiver, a copy of their medical recommendation or primary caregiver registration card, prior to requesting a delivery. Our Company will first verify the medical recommendations and primary caregiver registration card directly with the issuing physician or a reputable online service and only accept medical recommendation from licensed California physicians. When the delivery driver arrives, they will use a certified ID scanner to verify the ID as well as verify the customer matches the ID that was sent via email. For qualified patients and primary caregivers, the driver will request the original medical recommendation and primary caregiver cards for the particular qualified patient to verify it matches what was sent via email. Once the delivery driver returns to the dispensary, the delivery driver gives the dispensary employee who prepared the order, the signed record receipts and that dispensary employee closes out the sale in TREEZ to verify the delivery occurred. The dispensary employee will then put the payment received into the cash register and put the signed receipt along with the final TREEZ receipt to be scanned and saved digitally. TRADITIONAL - FRESNO - ME LLC ATTN: ARTHUR REYNA, ATTORNEY AT LAW PHONE: ( | EMAIL: AR@ARTHURREYNALAW.COM Page 1 of 21 Social Policy & Local Enterprise Plan for Traditional - Fresno - ME LLC Introduction & Executive Summary Traditional - Fresno - ME LLC (our “Company”), through its Owners / Members and officers has an unmatched track record of successful and timely development, establishment, and operation of cannabis businesses—in particular cannabis retail businesses—throughout the State of California. Our Company’s Owners / Members are a team of experienced professionals and stalwarts of the cannabis industry that include: (i) the owner and operator of one of the largest and most successful cannabis business portfolios in California and the U.S. with an established dedication and investment in social equity cannabis businesses and (ii) a young Latina that overcame growing up one of the most heavily impacted communities by the War on Drugs to graduate from college and go on to be a Majority Owner of a social equity retail cannabis business in the City of Los Angeles. Through its Owners / Members and officers, our Company will bring the Traditional brand to the City of Fresno (“Fresno” or the “City”) and operate an all-inclusive, elevated cannabis retail business that is custom-tailored and completely integrative and symbiotic with the local neighborhood. I. Social Policies & Local Enterprise Our Company has set forth a Social Policies & Local Enterprise Plan that we are confident will meet and exceed the requirements set forth by City. On that note, we consider the employees to be our most valuable resources and the local community to be our most important stakeholder. As such, our Company will offer employee training and continuing education to ensure our staff is knowledgeable about customer service, as well as trends and information on the cannabis products we carry. It is our intention to have a locally diverse, well-educated, and knowledgeable staff from social equity backgrounds. Training shall include topics such as, but not limited to: (i) Applicable local and State rules and regulations; (ii) safe handling of cannabis and cannabis products, including an overview of common industry hazards, current health and safety standards, and cannabis retail business best practices; (iii) guidelines provided by the City and State, (iv) METRC, the State’s track and trace system; (v) proper use of security measures and controls adopted to prevent diversion, theft, or loss of cannabis products; (vi) legal requirements for remaining compliant as a licensed employee; regulatory inspection preparedness; (vii) law enforcement interaction; (viii) diversity, including gender identity, racial equity, and inclusivity; and (ix) HR policies. Our Company is an equal opportunity employer, looking to invest in the local community. We will have a Company policy preference to hire local employees and those from social equity backgrounds, and we will pay our all employees a “living wage”. Section 2 – Social Policy & Local Enterprise Plan Page 2 of 16 II. Community Reinvestment In support on the Social Policies & Local Enterprise Plan articulated below, our Company will commit via a Community Benefits Agreement to donate the equivalent of 3% of “gross receipts” to local community organizations / nonprofits in Fresno and/or the Fresno Community Reinvestment Fund with the specific allocation of funds to be determined by our Company working with the City and local community organizations / nonprofits in Fresno—over and above any cannabis business taxes! III. Workforce Plan – Employee Commitments III.A Living Wage Our Company is committed to providing a living wage to employees and will ensure our wages are in compliance with the current minimum wage as adopted by the State. Our Company uses the following benchmark for the definition of “living wage”: 200% of the Federal Poverty Level for a family of two. The current Federal Poverty Level for a family of two is . Using these benchmarks (which are just the bare minimum), our Company’s definition of “living wage” is at least per year for full-time employees and (ii) per hour for part-time employees and independent contractors. This is above the current minimum wage as adopted by the State of per hour. Demonstrating its commitment to paying its employees a “living wage”, below the employment roles in our cannabis retail business and the annual salary for those positions: (i) Retailer Manager: N/A - Owner / Member; (ii) Chief Compliance Officer: ; (iii) Real Estate Development Officer: ; (iv) Chief Medical Officer: ; (v) Community Liaison: ; (vi) Bookkeeper / Administration: ; (vii) Dispensary General Manager: ; (viii) Assistant Dispensary General Manager: ; (ix) Dispensary Sales Representatives: ; and (x) Delivery Drivers: Our Company shall conduct semi-annual performance reviews to ensure employees are meeting satisfactory work standards, and we shall use this opportunity to administer raises. Our Company utilizes a system of formal performance evaluations as a necessary management tool to ensure satisfactory performance is maintained at all times and to aid in decisions regarding promotions, compensation, training, and disciplinary action. Employees will be given an opportunity to provide feedback on their work performance as well. Our Company believes having open communication is paramount to our success. The appraisal system is designed to focus on the job performance of the individual as it relates to the individual’s job description, to assess progress, set goals, and identify improvements needed. The performance evaluation process enhances teamwork and promotes open, ongoing communication. Section 2 – Social Policy & Local Enterprise Plan Page 3 of 16 III.B Employee Education Assistance Our Company will reasonably accommodate and assist any employee who wants to attend conferences, classes, or educational workshops, in particular educational workshops held by our Company, which will allow them to become more knowledgeable and, therefore, better employees. We strongly encourage educational programs, which highlight safety and security in cannabis to ensure the Company can provide the best experience for our customers. Our Company will pay any fees associated with any conferences, classes, or educational workshops that employees wish to attend in order to allow them these opportunities of continuing education. Our Company will be a leader in educating its staff and thereby its customers about the different strains of cannabis current availability, methods of ingestion and the effects of each strain. We will coordinate with medical professionals knowledgeable regarding cannabis and cannabinoid therapies to curate ongoing staff and educational materials. By employing this strategy our staff will have the tools to provide customers and patients with the most up-to-date information about cannabis and the growing list of aliments it can benefit and the effects on the body and mind. III.C Overtime Non-exempt employees will be paid overtime (one and one-half times the regular rate of pay) for all hours worked over eight in one workday, over 40 in one work week, and for the first eight hours of work performed on the seventh consecutive workday in one work week, without regard to the total number of hours worked in the previous six days. Overtime is paid at the rate of double the regular rate of pay for every hour worked after the completion of eight hours worked on the 7th consecutive workday in any workweek. In addition, overtime is paid at the rate of two times the regular rate of pay for every hour worked after the completion of 12 hours worked in one workday. III.D Rest & Meal Periods Non-exempt employees who work shifts over five hours in length are required to take an unpaid 30-minute meal period, to be taken before the end of the 5th work hour. Non-exempt employees who work in excess of 10 hours in a day are entitled to a 2nd, 30-minute meal period, to be taken before the end of the tenth hour. Meal periods should not be taken at the employee’s work area. III.E Personal Leave of Absence Unpaid personal leave of absence may be granted, upon request, to regular full-time employees for important pressing personal needs subject to the following provisions: unpaid personal leave may only be requested once all other appropriate leave balances have been exhausted. Our Company will attempt to hold an employee’s position open for the period of unpaid personal leave if such leave is six weeks or less. If leave is greater than six weeks, the employee, if qualified, will be entitled to the first reemployment opportunity available over the next six months. Employee health benefits will be continued in the same manner as received prior to the leave, if the leave is for six weeks or less, but the employee will be expected to remit payment for the employee's portion of the health insurance premium prior to departing for unpaid personal leave, and in an amount equivalent to the expected period of absence. If an employee requests leave which will extend beyond the 6-week period, he/she will be advised of his / her COBRA rights. Section 2 – Social Policy & Local Enterprise Plan Page 4 of 16 III.F Vacation Vacation accrual begins after completing the 90-day orientation period per the schedule below: Years of Service Hours per year Hours accrual rate 0-4 years 80 .058 5+ 120 .061 III.G Sick Leave All employees part-time, full-time, and temporary employees will receive sick leave as follows: (i) Lump Sum Method: Our Company will provide eligible employees with five days or 40 hours of paid sick time on their first day of employment with our Company that will be bank each year on the employee’s anniversary date; (ii) Accrual Method: Employees will accrue one hour of paid sick leave for every 30 hours worked. III.H Leave for Specific Circumstances Our Company’s Employee Handbook grants employee leave under the following specific circumstances: (i) Time off to Vote; (ii) Bereavement Leave; (iii) Jury Duty; (iv) Witness Duty; (v) Temporary Disability Leave; (vi) Volunteer Emergency Responder Leave; (vii) Victims of Felony Crime Leave; (viii) Civil Air Patrol Leave; (ix) School Leave for Disciplinary Matters; (x) Bone Marrow Donation Leave; (xi) Organ Donation Leave; (xii) Pregnancy Disability Leave; (xiii) Military Leave; (xiv) Military Spousal Leave; (xv) School Activities Leave; (xvi) Domestic Violence / Sexual Assault Leave; and (xvii) Rehabilitation Leave. III.I Workers’ Compensation As required by law, our Company provides workers’ compensation benefits for the protection of employees with work-related injuries or illnesses. Workers’ compensation insurance provides coverage to employees who receive job related injuries or illnesses. If an employee is injured or becomes ill as a result of his/her job, it is the employee’s responsibility to immediately notify a supervisor of their injury in order to receive benefits. Our Company will advise the employee of the procedure for submitting a workers’ compensation claim. If necessary, injured employees will be referred to a medical care facility. Employees should retain all paperwork provided to them by the medical facility. An employee’s report should contain as many details as possible, including the date, time, description of the illness or injury, and the names of any witnesses. A separate insurance company administers the worker’s compensation insurance. Representatives of this company may contact injured employees regarding their benefits under the plan. III.J Health Benefits Our Company will make group health benefits available to full-time employees who work 30+ hours a week. Pursuant to its desire to provide a “living wage”, our Company shall contribute at least per hour or per year per employee. Part-time employees will also be given Section 2 – Social Policy & Local Enterprise Plan Page 5 of 16 an opportunity to participate partially in health group benefits after being employed for at least six months. All employees will receive details about benefits provided, contribution rates, and eligibility in their hiring packet. III.K Retirement Benefits Our Company will make retirement benefits available to full-time employees who work 30+ hours a week after working one year with the Company. Pursuant to its desire to provide a “living wage”, our Company shall look to provide a matching contribution of 3% to whatever the employee contributes to their retirement plan up to a maximum of IV. Workforce Plan – Hiring Practices IV.A Local & Social Equity Hiring Policy As stated above, our Company’s policy will be to hire employees who live close to our cannabis retail business from the City of Fresno and from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code. In an effort to support our policy initiative, we will also seek to utilize professional services from within the local area to stimulate all sectors of business from physical construction to professional services such as accountants, bookkeepers, and web developers. Accordingly, our Company will commit via a Community Benefits Agreement to having (i) at least 50% of all our employees reside in Fresno and at least 50% employee personnel hours are from employees residing in Fresno AND (ii) at least 50% of all our employees are from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code and at least 50% employee personnel hours are from employees from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code. Our Company will take an all-inclusive approach to hiring and prioritize adults over the age of 21 from Fresno with social equity backgrounds. For our Company, this is a two-fold process. First, residents of Fresno with social equity backgrounds must be actively targeted with job offers and postings. For our Company this means, rather than using traditional job-posting media such Indeed, Craigslist, or other mainstream Internet websites, going directly to local publications targeted / catered towards Fresno residents. On that note, our Company will look to post flyers outside of the company’s proposed cannabis retail business a few months prior to opening with a link to all job postings and availabilities for the cannabis retail business in order to help with hiring local residents. Most importantly and well-beyond passive publications, our Company will look to establish deep ties with local nonprofits and public service organizations. Often times, local nonprofits and public service organizations missions are geared towards helping the members of the local community that our Company seeks to hire as employees. Relatedly, Fresno has a robust educational base for sourcing / recruiting employees with the presence of Fresno State University, Fresno City College, and Clovis Community College. With that point in mind, our Company has already begun engaging with the State Center Community College District on community engagement and hiring initiatives. The second element of our Company’s hiring program involves the interview process, with that point in mind, and recognizing that job interviewing is a specific skill, our Company will work with its community engagement partners to provide interview training to Fresno residents from social equity backgrounds before interviewing with our Company. Section 2 – Social Policy & Local Enterprise Plan Page 6 of 16 To show the good faith effort to hiring 50% of employees from the City of Fresno with social equity backgrounds, our Company will document the following: (i) Records of emails reaching out to community members and organizations; (ii) printed job flyers and list of addresses where flyers were posted and dropped off; (iii) links to localized online job postings; and (vi) proof of attending any local job fairs. In addition, our Company will keep track of job applications that were submitted to our Company and a list of all candidates that were interviewed by our Company where we will have copies showing their home address indicating if they are residents of Fresno. As for verifying social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code, the presents additional challenges for our Company, as certain qualifications for social equity status under Section 9-3316(b)(1) of the Fresno Municipal Code (for example, “Former foster home youth who was in foster care as a minor” and “receiving public assistance”) are inappropriate, or arguably unlawful, inquiries during the interview process. As a result, our Company will employ legal counsel specialized in employment law to develop solutions for acquiring and retaining verification documentation of social equity status as defined in Section 9- 3316(b)(1) of the Fresno Municipal Code in a way that provides all potential social equity backgrounds an equal opportunity in our Company’s hiring process. One such solution that our Company is considering to this legal / human resources obstacle is to partner with the City or local community organizations to have the City or local community organizations do the vetting of social equity status under Section 9-3316(b)(1) of the Fresno Municipal Code (who may not have the same legal obstacles as our Company) and then forward vetted candidates to our Company for interviews. If after our Company reaches out to various resources in order to hire local, social equity candidates, our Company is unable to meet its goals of 50% of employees personnel hours from Fresno residents from social equity backgrounds, our Company will attempt to coordinate with the City and other approved cannabis businesses in City to host a local “Cannabis Job Fair”. If after hosting its own “Cannabis Job Fair”, our Company is still unable to meet local and social equity hiring goals, we will then look to use more traditional job platforms such as Indeed and ZipRecruiter to hire the remaining employees needed to properly staff the cannabis retail business, and our Company will collaborate with the City to determine other ways to divert additional community benefits to the City of Fresno and its residents, such as increased public benefits via its Community Benefits Agreement. IV.B Expungement Clinics Our Company is committed to helping individuals from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code overcome obstacles to employment regardless of whether such individuals end up working for our Company. One such obstacle is criminal records. Our Company will host expungement fairs for individuals from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code and others with community partners. IV.C Social Equity Incubator / Apprenticeship Program Our Company will commit via a Community Benefits Agreement to serve as a Social Equity Business Incubator by offering support to local cannabis social equity businesses in the form of mentorship, training, equipment donation, a percentage of shelf space dedicated to Fresno equity business products, legal assistance, financial services assistance, and/or other technical assistance support. Appreciating that it is paramount to address the negative consequences of the War on Section 2 – Social Policy & Local Enterprise Plan Page 7 of 16 Drugs, our Company believes that individuals negatively impacted by the War on Drugs should have resources available to assist them in participating in the cannabis industry. Accordingly, our Company’s Owners / Members have a long history of embracing cannabis Social Equity Programs throughout the State and through their existing cannabis retail business operations. To illustrate, Minority Owner / Member & Retailer Manager, Aaron Mamann, is an Owner / Member of three Social Equity cannabis businesses in the City of Los Angeles and Majority Owner / Member, Maritza Estrada, is an Owner / Member of one Social Equity cannabis retail business approved applicant in the City of Los Angeles. IV.D Diversity Policy Consistent with its our mission, we will provide a welcoming workplace and will promote the involvement of diverse employees and diverse groups in its operations. As a result, our Company will implement a zero-tolerance policy relating to discrimination and employees will be encouraged to report any and all occurrences of workplace discrimination. Our Company will monitor discrimination in the workplace and immediately address any discovery of discrimination. We will also train employees to identify workplace discrimination in the context of two general categories: (i) overt discrimination and (ii) covert discrimination. IV.E Equal Opportunity Employment It is the policy of our Company to provide equal employment opportunities to all qualified individuals and to administer all aspects and conditions of employment without regard to the following: race, color, age, sex, sexual orientation, gender, gender identity, religion, national origin, pregnancy, marital status, AIDS/HIV, genetic information, including family medical history, physical or mental disability, medical condition, political activities or affiliations, child or spousal support withholding, domestic violence, assault, or stalking victim status, lawful conduct occurring during nonworking hours away from the employer’s premises, military or veteran status, credit report or credit information, prior non-conviction arrest record, citizenship and/or immigration status, or any other protected class, in accordance with applicable federal, state, and local laws. We take allegations of discrimination, intimidation, harassment, and retaliation very seriously and will promptly conduct an investigation when warranted. If any of our employees are caught violating this policy, they will be subject to IMMEDIATE disciplinary action. V. Workforce Plan – Employee Training V.A Regulatory Knowledge & Education Our Company’s top priority when training its employees will be for it to understand the rules and regulations that govern the cannabis retail business in order to run a safe and compliant workplace. Our Company will ensure that the training will be at least two hours long and cover the below modules: (i) Health and safety concerns of cannabis use, including the responsible use of cannabis, its physical effects, onset of physiological effects; (ii) Recognizing signs of impairment and appropriate responses in the event of overconsumption; (iii) Laws and regulations on driving while under the influence; (iv) Prohibiting sales to minors; (v) Daily sales limits to customers and patients; (vi) Acceptable forms of identification as well as how to check identification and common Section 2 – Social Policy & Local Enterprise Plan Page 8 of 16 mistakes made in verification; (vii) Safe and secure storage of cannabis; (viii) Compliance with all inventory tracking system regulations; (ix) Waste handling, management, and disposal; (x) Health and safety standards; (xi) Maintenance of records; (xii) Security and surveillance requirements; (xiii) Permitting inspections by the City and State; and (xiv) Packaging and labeling requirement for all cannabis products. V.B Cannabis Knowledge Our Company will train employees about general information in regards to cannabis in order to better inform themselves and the customer. This will include the detailed information that goes over the following topics: (i) What cannabis is; (ii) The different ways cannabis is smoked and consumed; (iii) How cannabis effects the brain in short-term and long-term effects; (iv) Suggested consumption methods and dosing guidelines; (v) Understanding edible consumption and dosage; (vi) Customers guidelines to safe cannabis use; (viii) What the physical effects are of using cannabis and cannabis products; (ix) The mental effects of cannabis and cannabis products; (x) Long term effects of cannabis use; (xi) Treatments for Cannabis Use Disorder; (xii) Effects of secondhand cannabis smoke; (xiii) Cannabis as a possible gateway drug; (xiv) Overdosing on cannabis; (xv) Cannabis addiction; and (xvi) Dangers of synthetic cannabinoids. Dispensary employees will be trained on how to interact with customers, give recommendations based on their requests, give advice, guidance, and counsel customers on products. Dispensary employees will not give medical advice, as they are not licensed health professionals, and will be advised to tell customers to talk to their physician. Our Company holds a high expectation for employees’ knowledge of cannabis quality and strains. Accordingly, our Company will put together Information Sheets from the cannabis products we receive from our vendors and compile it in a binder that all staff can access and reference. These Information Sheets will include a description of the product, how it was cultivated or manufactured, and what effects to associate with the product. Our Company will require employees to take a quiz on Cannabis and Regulatory Knowledge and be expected to pass it by their third try. If they do not pass the quiz the employee will not be hired. V.C Security Training Our Company understands that security is of paramount importance. We are keenly aware of the added security challenges that a business of this nature faces, and we have taken extensive measures to have professionally-vetted policies, procedures, and systems in place to provide comprehensive protection, not only for our physical store, but also for our employees. Our Company will train managers on how to use the security alarms set up by the alarm company and then train all necessary employees on how the system works. It is critical that employees understand exactly what to do when specific breaches and threats take place. This ensures employee and customer safety and gives law enforcement and security personnel the ability to respond to a specific rapid response without fear of injury. Our Company’s Security Officer will provide specific training to management and employees in the following areas: (i) Security awareness training; (ii) responding to a robbery attempt; (iii) interacting with a disruptive customer; (iv) alarm activation response; (v) attempted theft; (vi) working with local law enforcement; (vii) medical emergencies; (viii) proper use of the “panic button”; (ix) being a good Section 2 – Social Policy & Local Enterprise Plan Page 9 of 16 witness/report writing; (x) theft and diversion training; (xi) OSHA compliance; and (xii) training developed for all compliance issues. In addition to the items listed above, our Community Liaison will work with security companies and with management to design and implement continued training in security related matters on a regular basis. Employees shall be tested on training content and must pass a comprehensive test by their third attempt in order to remain employed. All staff shall also go through periodic refresher seminars, as well as new training on any policy updates or changes in procedure. All emergency procedures will be rehearsed in periodic drills. In addition to training and periodic drills, all employees will receive official Company reference material, written in plain English and presented in an easy-to-use outline format, explaining all operational, safety, and security policies and protocols. In developing our official safety and security policies, our Company shall consult with local law enforcement. We shall also work with local law enforcement to develop effective ongoing employee training seminars and practices especially in developing our policies and training procedures on crime prevention and security threat response. After the security-related training, all employees should be able to: (i) know how to assess situations to determine the type and level of threat they may pose; (ii) know how to respond to different kinds of security threats; (iii) know which types of situations warrant the activation of panic buttons; and (iv) know how to proceed when a security alarm goes off or a panic buttons has been activated V.D Dispensary Operational Procedures V.D.1 Training Delivery Our Company believes that the better informed our employees are, the better they can answer questions and teach our customers how to safely use and enjoy the cannabis products we will carry. To ensure all employees are properly, our Company utilizes the following approaches to employee training: (i) New hire training; (ii) hands-on training; and (iii) employee-to-employee training. Additionally and as highlighted above in training subject specific sections, employees will be tested on training content and must pass the test by their third attempt in order to remain employed. All employees will go through annual refresher training, as well as new training on any policy updates or changes in procedure as they arise. V.D.2 New Hire Training Upon starting with our Company, all new employees will attend a full eight hour Employee Educational Course that will coincide with the Regulatory and Cannabis Knowledge, and Security Measure Training and focus on the following subjects: (i) Point-of-sale (“POS”) system; (ii) State inventory system, METRC; (iii) time and attendance system; (iv) medical patient verification; (v) adult-use age verification; (vi) inventory control; (vii) cannabis laws and regulations; (viii) secure electronic record keeping; (ix) procedures for patient and customer reception and registration; and (x) procedures for cannabis product sales. Further, our Company will also encourage all employees to work on continuing their education in all these fields and will be encouraged to attend third-party courses offered by our Company to pursue the highest levels of cannabis retail business employee qualification. Section 2 – Social Policy & Local Enterprise Plan Page 10 of 16 V.D.3 Hands-On Training Our Company follows up new hire training with work one-on-one with new employees to review training materials with them. Regardless whether training is about cannabis products or proper procedures, our Company believes it is important to follow up and test staff’s knowledge. We want staff to be able to articulate knowledge in both words and actions. This ongoing training with staff also ensures employee retention and consists of the following methods: • Management will ask employees a series of increasingly complicated questions. Our Company will work to do their best to ensure staff can be successful when being quizzed. The goal will not be to stump the employees, but to work on building their confidence in being knowledgeable in all policies and procedures. • Management will do role-playing training exercises with employees. Although it can sometimes be an awkward training method, it is also very effective. Role-playing allows our Company to see if employees can effectively articulate information back to us and how employees handle themselves in common operational scenarios. Management will not focus on delivery as is common with forced scenarios, but rather focus on employees’ knowledge and understanding of the training materials and decision-making in the role- playing scenarios. • Management will take turns with an employee where first management will deal with a real customer and one where management will watch how the employee interacts with a customer. Employees will pay attention on how the manager is working with customers, and then attempt to mimic / copy those skills. In so doing, management will make close observation of employees as they perform their duties and make notes and either positively correct, or give approval, as needed. V.D.4 Employee-to-Employee Training Employee-to-employee training is a great way for employees to learn information in a non- threatening way and this form of training is the ideal way for employees to learn from one another. Our Company will utilize team-building exercises that allow everyone in the cannabis retail business to come together without the pressures of daily routines. Management will also be responsible for assigning sales associates for training on any area where an employee requires additional training. VI. Workforce Plan – Codes of Conduct VI.A Drug Free / Alcohol Free Our Company is dedicated to providing employees with a workplace that is free of drugs and alcohol. For the safety of our employees and customers, we reserve the right to test any employee for the use of illegal drugs or alcohol under state, federal, or local laws. This may be done in cases where the employee’s job carries a risk of injury or accident due to such use, or if there is an apparent inability to perform the duties required of that position. Any employee found to use, sell, Section 2 – Social Policy & Local Enterprise Plan Page 11 of 16 possess, or distribute drugs that are illegal under state, federal, or local laws, including cannabis, or any unauthorized drugs (including excessive quantities of prescription or over-the-counter drugs) while on the Company premises, performing Company-related duties, or while operating any Company equipment is subject to disciplinary action, up to and including termination of employment. Any suspected illegal drugs confiscated will be turned over to the appropriate law enforcement agency. VI.B Sexual Harassment & Other Unlawful Harassment Applicable federal and state law defines sexual harassment as unwanted sexual advances, requests for sexual favors, or visual, verbal, or physical conduct of a sexual nature when: (i) submission of the conduct is made a term or condition of employment; (ii) submission to or rejection of the conduct is used as basis for employment decisions affecting the individual; or (iii) the conduct has the purpose or effect of unreasonably interfering with the employees work performance or creating an intimidating, hostile, or offensive working environment. Sexual harassment and unlawful harassment are prohibited behavior and against Company policy. Our Company is committed to providing a work environment free of inappropriate and disrespectful behavior, intimidation, communications, and other conduct directed at an individual because of their sex, including conduct that may be defined as sexual harassment. VI.B.1 Other Types of Harassment Prohibited harassment on the basis of race, color, religion, national origin, ancestry, physical or mental disability, veteran status, age, or any other basis protected under local, state or federal law, includes behavior similar to sexual harassment, such as: verbal conduct such as threats, epithets, derogatory comments, or slurs; visual conduct such as derogatory posters, photographs, cartoons, drawings, or gestures; physical conduct such as assault, unwanted touching, or blocking normal movement; and retaliation for reporting harassment or threatening to report harassment. VI.B.2 Retaliation It is against our Company’s policies and unlawful to retaliate in any way against anyone who has lodged a harassment complaint, has expressed a concern about harassment, including sexual harassment, or has cooperated in a harassment investigation. Therefore, the initiation of a complaint, in good faith, will not under any circumstances be grounds for disciplinary action. VI.B.3 Enforcement All managers and supervisors are responsible for: (i) Implementing our Company’s policies on harassment, which includes, but is not limited to, sexual harassment and retaliation; (ii) ensuring that all employees they supervise have knowledge of and understand our Company’s policies; (iii) reporting any complaints of misconduct to the designated Company representative so they may be investigated and resolved immediately; (iv) taking and/or assisting in prompt and appropriate corrective action when necessary to ensure compliance with the policy; and (v) conducting themselves in a manner consistent with our Company’s policies on harassment. Section 2 – Social Policy & Local Enterprise Plan Page 12 of 16 VI.C Abusive Conduct Abusive conduct means malicious conduct of an employer or employee in the workplace that a reasonable person would find hostile, offensive, and unrelated to an employer’s legitimate business interests. Abusive conduct may include repeated infliction of verbal abuse, such as the use of derogatory remarks, insults, and epithets, verbal or physical conduct that a reasonable person would find threatening, intimidating, or humiliating, or the gratuitous sabotage or undermining of a person’s work performance. Our Company considers abusive conduct in the workplace unacceptable and will not tolerate it under any circumstances. Employees should report any abusive conduct to a supervisor or manager with whom employees are comfortable speaking. Supervisors and managers are to assume the responsibility to ensure employees are not subjected to abusive conduct. All complaints will be treated seriously and investigated promptly. During the investigation process our Company will attempt to maintain confidentiality to the fullest extent possible. It is a violation of Company policy to retaliate or otherwise victimize an employee who makes a complaint or a witness who serves in the investigation of the abusive conduct allegation. VI.D Open Door Policy We encourage employees to bring their work-related questions, suggestions, and complaints to our Company’s attention. Employee input is important to us, and they should bring their good faith concerns to the attention of management without the fear of retaliation. We will consider and investigate the concerns brought to our attention in order to attempt to resolve problems and/or improve our operations. We hope to be able to satisfactorily resolve most matters. VI.E Workplace Safety We are committed to providing and maintaining a healthy and safe work environment for all employees. However, a safety program can only be successful if everyone cooperates. Employee assistance in eliminating hazards and unsafe conditions and attention to good housekeeping will do much to make our Company a safe place to work. As a result, every employee is required to follow safe and healthy work practices at all times. Employees may be subject to discipline for engaging in any unsafe or unhealthy work practices. In addition to compliance with safety measures imposed by federal Occupational Safety and Health Act (“OSHA”) and state law, our Company has an independent interest in making its facilities a safe and healthy place to work. Our Company recognizes that employees may be in a position to notice dangerous conditions and practices and therefore encourages employees to report such conditions, as well as all non- functioning or hazardous equipment, to a supervisor or manager immediately. Following employee reporting, our Company will take appropriate remedial measures. Employees will not be retaliated or discriminated against for reporting of accidents, injuries, or illnesses, filing of safety-related complaints, or requesting to see injury and illness logs. Employees are required to promptly report all injuries at work, or other work-related injuries, no matter how minor, to their immediate supervisor. Supervisors are responsible for obtaining first aid and proper medical care, and promptly reporting the injury to Human Resources, who will fill out all appropriate forms and reports. The location of the nearest doctor and/or medical facility is posted on the bulletin board(s). An employee’s employment status will not be affected by the Section 2 – Social Policy & Local Enterprise Plan Page 13 of 16 report of a work-related injury or the filing of a workers’ compensation claim. Our Company provides insurance for all work-related injuries or illness. VII. Number of Employees & Job Descriptions Below is the chart of our expected number of employees for starting up and the first three full years of operation: VII.A Job Descriptions and Duties VII.A.1 Retailer Manager Our Company’s Retailer Manager is the senior executive officer for our overall Company and overall cannabis retail business operation and has direct authority, control, or supervision over all personnel. VII.A.2 Real Estate Development Officer Our Company’s Real Estate Development Officer is a real estate professional to advise our Company’s executive officers on the location, acquisition, development, and construction of cannabis retail businesses in the State. VII.A.3 Community Liaison / Community Organizer Our Company’s Community Liaison is a senior executive officer that serves as our Company’s point-of-contact for on-site community relations to whom government representatives and members of the community can provide notice if there are operating problems associated with our Company’s cannabis retail business. VII.A.4 Chief Medical Officer Our Company’s Medical Officer is a licensed physician responsible for advising our Company’s Section 2 – Social Policy & Local Enterprise Plan Page 14 of 16 executive officers on the selection, purchasing, and development of medical-grade cannabis and cannabinoid pharmaceuticals for our cannabis retail business’s cannabis product inventory. VII.A.5 Chief Compliance Officer Our Company’s Compliance Officer is the senior executive officer that responsible for ensuring our cannabis retail business operates in compliance with the State and City law and day-to-day executive officer responsible for inventory, tracking, and control of all cannabis and cannabis products to include all procurement and quality control of cannabis and cannabis products and has direct authority, control, or supervision over all personnel who engage in accounting for and quality control of cannabis and cannabis products. As a result, our Company’s Compliance Officer will serve as the administrator for our Company’s track and trace systems. VII.A.6 Bookkeeper / Administration Our Company’s Bookkeeper / Administration is an employee that provides general financial and administrative support to our Company and frontline employee working directly for our Company’s Compliance Officer. They will perform analytical reviews of financial results and assist with developing and reviewing key performance indicators as well as execute a variety of general accounting support tasks and will function in accordance with established standards, procedures, and applicable laws VII.A.7 Dispensary General Manager Our Company’s Dispensary General Manager (“GM”) is the day-to-day supervisor of our Company’s cannabis retail business operation and has direct authority, control, or supervision over all personnel who engage in the retail sale of cannabis and cannabis products. The GM serves as a role model, liaison, and resource for cannabis retail business staff concerning products and services, policies and procedures, industry news and changes in regulations. They ensure compliance with all State and local rules and regulations, and directly supervises the activity within the cannabis retail business to include staff training and education. The GM manages the receipt, storage and auditing of all inventory, and are responsible for ordering new inventory and supplies, and maintains accurate records. The GM resolves all inventory discrepancies and reconciliations while accurately documenting all inventory movements to be recorded in the company’s track and trace system and into the State’s track and trace software, METRC in order to identify the proper location and quantity of product at all time. The GM supervises assistant managers on all daily tasks consistent with established procedures with an emphasis on inventory control actions such as receiving, counting and inspecting all incoming cannabis products for quality and compliance; implement HR policies, programs, and systems in support of company initiatives; directs all compliance efforts for the company to minimize risk and deal with any internal conflicts. The GM will conduct investigations: respond to unemployment claims, EEOC, DOL, and/or employee relation issues such as employee complaints, harassment allegations, and civic rights complaints. The GM conduct exit interviews, analyze data, and make recommendations to corporate management team for corrective action and continuous improvement as well as conduct performance reviews with employees and monitor employee productivity, attitudes, and Section 2 – Social Policy & Local Enterprise Plan Page 15 of 16 performance results. They will maintain excellent facilities conducive to enhancing employee productivity and compliance, and ensure employee safety, wellness, health and welfare. VII.A.8 Assistant Dispensary General Managers Our Assistant Dispensary General Managers (“AM”) assist our GM with day-to-day operations of the cannabis retail cannabis retail business in accordance with the State of California, local regulations, and standards set by our Company. The AM will help maintain organization and operations at the cannabis retail business with detail to inventory duties. Assistance is also given to the sales team to ensure efficiency and customer satisfaction. The AM will provide support to store manager and all employees, and patients/customers. Overall duties also include: light cash- handling, training, providing policy and procedure updates, and keeping updated with industry news and cannabis product information. The AM provides management and leadership in the cannabis retail business to include monitoring all point-of-sale transactions. They respond to all staff questions, concerns, or suggestions within scope and reports to the GM for resolution. The AM directs and monitors sales representatives to accomplish goals of the days consistent with established operational procedures. The AM maintains records required by public health law and ensures quality assurance plans, including but not limited to plans to detect, identify, and prevent dispensing errors related to product packaging and labeling. The AM monitors employee productivity, attitudes, and performance results, and make recommendations to the GM for corrective action and continuous improvement for product and policies. The AM Responds to all patient/customer complaints, requests, concerns, suggestions and takes action when directed by the GM to resolve conflicts including responses and replies across social platforms. The AM manages the receipt, storage, record keeping, and auditing of all inventory, and maintaining cannabis retail business compliance and cleanliness. The AM performs inventory control actions such as receiving, counting, and inspecting for quality and compliance. The AM assists the GM (i) in accurately documenting all inventory movements to be recorded in the company’s track and trace system and into the State’s track and trace software, METRC to identify the proper location and quantity of product at all time and (ii) with bi-monthly reconciliation inventory counts based on company requirements, and works with the store manager to resolve all inventory discrepancies and light-cash handling. VII.A.9 Dispensary Sales Representatives Our sales representatives (“SR”) assist guests, clients, vendors, and management whenever possible. Our SR assist the management team with the activities and operations of the store, while abiding by policies, procedures, and operational guidelines. The SR is responsible for helping customers, checking them out, cash handling, and customer service. They welcome visitors by warmly greeting them, in person or on the telephone and answering or directing inquiries through proper channels. They accurately process payments from customers; issues receipts, refunds, credits, and change. They establish or identify prices of goods, services or admission; tabulates bills using calculators, cash registers, and optical price scanners. The SR operates a cash register and itemize total purchases by recording prices, departments, taxable and nontaxable items and balance cash drawers by counting cash at beginning and end of work shift to ensure that amounts are correct and that there is adequate change. The SR helps maintain a compliant and clean Section 2 – Social Policy & Local Enterprise Plan Page 16 of 16 cannabis retail business and assures side-work completion every shift. They establish, develop, and maintain relationships with current and prospective customers to generate business for our cannabis products. They use information-based training to educate customers with the SR expected to continue education on all products. They maintain product knowledge of all products in-store in order to communicate to customers and patients. They ensure the sales floor is properly stocked and the cleanliness of the store is well maintained. The SR promotes a work environment that is positive, customer-service oriented, and compliant with established policies and procedures. VII.A.10 Delivery Drivers Our delivery drivers have similar responsibilities to our SR, but with the added responsibilities of handling proper record receipts to be given and signed by customers, and understands safety and delivery compliance protocols for all deliveries. They must obey all traffic laws and always have all necessary paperwork required by the City and State at all times via hard copy or electronically. VII.A.11 Security Guards Our Company will use a third-party security company that will ensure the safety of customers and employees and the protection of assets. This is accomplished through the use of foot patrols, professional presence, camera monitoring, escort procedures, access control, and enforcement of company security policies. All security guards will be certified through the Bureau of Security and Investigative Services. They will check identification cards for all persons entering cannabis retail business to ensure only those over the age of 21, or those over 18 with a proper medical recommendation are let inside the cannabis sales area. TRADITIONAL - FRESNO - ME LLC ATTN: ARTHUR REYNA, ATTORNEY AT LAW PHONE: | EMAIL: AR@ARTHURREYNALAW.COM Page 1 of 21 Social Policy & Local Enterprise Plan for Traditional - Fresno - ME LLC Introduction & Executive Summary Traditional - Fresno - ME LLC (our “Company”), through its Owners / Members and officers has an unmatched track record of successful and timely development, establishment, and operation of cannabis businesses—in particular cannabis retail businesses—throughout the State of California. Our Company’s Owners / Members are a team of experienced professionals and stalwarts of the cannabis industry that include: (i) the owner and operator of one of the largest and most successful cannabis business portfolios in California and the U.S. with an established dedication and investment in social equity cannabis businesses and (ii) a young Latina that overcame growing up one of the most heavily impacted communities by the War on Drugs to graduate from college and go on to be a Majority Owner of a social equity retail cannabis business in the City of Los Angeles. Through its Owners / Members and officers, our Company will bring the Traditional brand to the City of Fresno (“Fresno” or the “City”) and operate an all-inclusive, elevated cannabis retail business that is custom-tailored and completely integrative and symbiotic with the local neighborhood. I. Social Policies & Local Enterprise Our Company has set forth a Social Policies & Local Enterprise Plan that we are confident will meet and exceed the requirements set forth by City. On that note, we consider the employees to be our most valuable resources and the local community to be our most important stakeholder. As such, our Company will offer employee training and continuing education to ensure our staff is knowledgeable about customer service, as well as trends and information on the cannabis products we carry. It is our intention to have a locally diverse, well-educated, and knowledgeable staff from social equity backgrounds. Training shall include topics such as, but not limited to: (i) Applicable local and State rules and regulations; (ii) safe handling of cannabis and cannabis products, including an overview of common industry hazards, current health and safety standards, and cannabis retail business best practices; (iii) guidelines provided by the City and State, (iv) METRC, the State’s track and trace system; (v) proper use of security measures and controls adopted to prevent diversion, theft, or loss of cannabis products; (vi) legal requirements for remaining compliant as a licensed employee; regulatory inspection preparedness; (vii) law enforcement interaction; (viii) diversity, including gender identity, racial equity, and inclusivity; and (ix) HR policies. Our Company is an equal opportunity employer, looking to invest in the local community. We will have a Company policy preference to hire local employees and those from social equity backgrounds, and we will pay our all employees a “living wage”. Section 2 – Social Policy & Local Enterprise Plan Page 2 of 16 II. Community Reinvestment In support on the Social Policies & Local Enterprise Plan articulated below, our Company will commit via a Community Benefits Agreement to donate the equivalent of 3% of “gross receipts” to local community organizations / nonprofits in Fresno and/or the Fresno Community Reinvestment Fund with the specific allocation of funds to be determined by our Company working with the City and local community organizations / nonprofits in Fresno—over and above any cannabis business taxes! III. Workforce Plan – Employee Commitments III.A Living Wage Our Company is committed to providing a living wage to employees and will ensure our wages are in compliance with the current minimum wage as adopted by the State. Our Company uses the following benchmark for the definition of “living wage”: 200% of the Federal Poverty Level for a family of two. The current Federal Poverty Level for a family of two is $17,240.00. Using these benchmarks (which are just the bare minimum), our Company’s definition of “living wage” is at least per year for full-time employees and (ii) $ per hour for part-time employees and independent contractors. This is above the current minimum wage as adopted by the State of $12.00 per hour. Demonstrating its commitment to paying its employees a “living wage”, below the employment roles in our cannabis retail business and the annual salary for those positions: (i) Retailer Manager: N/A - Owner / Member; (ii) Chief Compliance Officer: ; (iii) Real Estate Development Officer:; (iv) Chief Medical Officer: ; (v) Community Liaison:; (vi) Bookkeeper / Administration: ; (vii) Dispensary General Manager: ; (viii) Assistant Dispensary General Manager: ; (ix) Dispensary Sales Representatives: 0; and (x) Delivery Drivers: . Our Company shall conduct semi-annual performance reviews to ensure employees are meeting satisfactory work standards, and we shall use this opportunity to administer raises. Our Company utilizes a system of formal performance evaluations as a necessary management tool to ensure satisfactory performance is maintained at all times and to aid in decisions regarding promotions, compensation, training, and disciplinary action. Employees will be given an opportunity to provide feedback on their work performance as well. Our Company believes having open communication is paramount to our success. The appraisal system is designed to focus on the job performance of the individual as it relates to the individual’s job description, to assess progress, set goals, and identify improvements needed. The performance evaluation process enhances teamwork and promotes open, ongoing communication. Section 2 – Social Policy & Local Enterprise Plan Page 3 of 16 III.B Employee Education Assistance Our Company will reasonably accommodate and assist any employee who wants to attend conferences, classes, or educational workshops, in particular educational workshops held by our Company, which will allow them to become more knowledgeable and, therefore, better employees. We strongly encourage educational programs, which highlight safety and security in cannabis to ensure the Company can provide the best experience for our customers. Our Company will pay any fees associated with any conferences, classes, or educational workshops that employees wish to attend in order to allow them these opportunities of continuing education. Our Company will be a leader in educating its staff and thereby its customers about the different strains of cannabis current availability, methods of ingestion and the effects of each strain. We will coordinate with medical professionals knowledgeable regarding cannabis and cannabinoid therapies to curate ongoing staff and educational materials. By employing this strategy our staff will have the tools to provide customers and patients with the most up-to-date information about cannabis and the growing list of aliments it can benefit and the effects on the body and mind. III.C Overtime Non-exempt employees will be paid overtime (one and one-half times the regular rate of pay) for all hours worked over eight in one workday, over 40 in one work week, and for the first eight hours of work performed on the seventh consecutive workday in one work week, without regard to the total number of hours worked in the previous six days. Overtime is paid at the rate of double the regular rate of pay for every hour worked after the completion of eight hours worked on the 7th consecutive workday in any workweek. In addition, overtime is paid at the rate of two times the regular rate of pay for every hour worked after the completion of 12 hours worked in one workday. III.D Rest & Meal Periods Non-exempt employees who work shifts over five hours in length are required to take an unpaid 30-minute meal period, to be taken before the end of the 5th work hour. Non-exempt employees who work in excess of 10 hours in a day are entitled to a 2nd, 30-minute meal period, to be taken before the end of the tenth hour. Meal periods should not be taken at the employee’s work area. III.E Personal Leave of Absence Unpaid personal leave of absence may be granted, upon request, to regular full-time employees for important pressing personal needs subject to the following provisions: unpaid personal leave may only be requested once all other appropriate leave balances have been exhausted. Our Company will attempt to hold an employee’s position open for the period of unpaid personal leave if such leave is six weeks or less. If leave is greater than six weeks, the employee, if qualified, will be entitled to the first reemployment opportunity available over the next six months. Employee health benefits will be continued in the same manner as received prior to the leave, if the leave is for six weeks or less, but the employee will be expected to remit payment for the employee's portion of the health insurance premium prior to departing for unpaid personal leave, and in an amount equivalent to the expected period of absence. If an employee requests leave which will extend beyond the 6-week period, he/she will be advised of his / her COBRA rights. Section 2 – Social Policy & Local Enterprise Plan Page 4 of 16 III.F Vacation Vacation accrual begins after completing the 90-day orientation period per the schedule below: Years of Service Hours per year Hours accrual rate 0-4 years 80 .058 5+ 120 .061 III.G Sick Leave All employees part-time, full-time, and temporary employees will receive sick leave as follows: (i) Lump Sum Method: Our Company will provide eligible employees with five days or 40 hours of paid sick time on their first day of employment with our Company that will be bank each year on the employee’s anniversary date; (ii) Accrual Method: Employees will accrue one hour of paid sick leave for every 30 hours worked. III.H Leave for Specific Circumstances Our Company’s Employee Handbook grants employee leave under the following specific circumstances: (i) Time off to Vote; (ii) Bereavement Leave; (iii) Jury Duty; (iv) Witness Duty; (v) Temporary Disability Leave; (vi) Volunteer Emergency Responder Leave; (vii) Victims of Felony Crime Leave; (viii) Civil Air Patrol Leave; (ix) School Leave for Disciplinary Matters; (x) Bone Marrow Donation Leave; (xi) Organ Donation Leave; (xii) Pregnancy Disability Leave; (xiii) Military Leave; (xiv) Military Spousal Leave; (xv) School Activities Leave; (xvi) Domestic Violence / Sexual Assault Leave; and (xvii) Rehabilitation Leave. III.I Workers’ Compensation As required by law, our Company provides workers’ compensation benefits for the protection of employees with work-related injuries or illnesses. Workers’ compensation insurance provides coverage to employees who receive job related injuries or illnesses. If an employee is injured or becomes ill as a result of his/her job, it is the employee’s responsibility to immediately notify a supervisor of their injury in order to receive benefits. Our Company will advise the employee of the procedure for submitting a workers’ compensation claim. If necessary, injured employees will be referred to a medical care facility. Employees should retain all paperwork provided to them by the medical facility. An employee’s report should contain as many details as possible, including the date, time, description of the illness or injury, and the names of any witnesses. A separate insurance company administers the worker’s compensation insurance. Representatives of this company may contact injured employees regarding their benefits under the plan. III.J Health Benefits Our Company will make group health benefits available to full-time employees who work 30+ hours a week. Pursuant to its desire to provide a “living wage”, our Company shall contribute at least per hour or per year per employee. Part-time employees will also be given Section 2 – Social Policy & Local Enterprise Plan Page 5 of 16 an opportunity to participate partially in health group benefits after being employed for at least six months. All employees will receive details about benefits provided, contribution rates, and eligibility in their hiring packet. III.K Retirement Benefits Our Company will make retirement benefits available to full-time employees who work 30+ hours a week after working one year with the Company. Pursuant to its desire to provide a “living wage”, our Company shall look to provide a matching contribution of 3% to whatever the employee contributes to their retirement plan up to a maximum of . IV. Workforce Plan – Hiring Practices IV.A Local & Social Equity Hiring Policy As stated above, our Company’s policy will be to hire employees who live close to our cannabis retail business from the City of Fresno and from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code. In an effort to support our policy initiative, we will also seek to utilize professional services from within the local area to stimulate all sectors of business from physical construction to professional services such as accountants, bookkeepers, and web developers. Accordingly, our Company will commit via a Community Benefits Agreement to having (i) at least 50% of all our employees reside in Fresno and at least 50% employee personnel hours are from employees residing in Fresno AND (ii) at least 50% of all our employees are from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code and at least 50% employee personnel hours are from employees from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code. Our Company will take an all-inclusive approach to hiring and prioritize adults over the age of 21 from Fresno with social equity backgrounds. For our Company, this is a two-fold process. First, residents of Fresno with social equity backgrounds must be actively targeted with job offers and postings. For our Company this means, rather than using traditional job-posting media such Indeed, Craigslist, or other mainstream Internet websites, going directly to local publications targeted / catered towards Fresno residents. On that note, our Company will look to post flyers outside of the company’s proposed cannabis retail business a few months prior to opening with a link to all job postings and availabilities for the cannabis retail business in order to help with hiring local residents. Most importantly and well-beyond passive publications, our Company will look to establish deep ties with local nonprofits and public service organizations. Often times, local nonprofits and public service organizations missions are geared towards helping the members of the local community that our Company seeks to hire as employees. Relatedly, Fresno has a robust educational base for sourcing / recruiting employees with the presence of Fresno State University, Fresno City College, and Clovis Community College. With that point in mind, our Company has already begun engaging with the State Center Community College District on community engagement and hiring initiatives. The second element of our Company’s hiring program involves the interview process, with that point in mind, and recognizing that job interviewing is a specific skill, our Company will work with its community engagement partners to provide interview training to Fresno residents from social equity backgrounds before interviewing with our Company. Section 2 – Social Policy & Local Enterprise Plan Page 6 of 16 To show the good faith effort to hiring 50% of employees from the City of Fresno with social equity backgrounds, our Company will document the following: (i) Records of emails reaching out to community members and organizations; (ii) printed job flyers and list of addresses where flyers were posted and dropped off; (iii) links to localized online job postings; and (vi) proof of attending any local job fairs. In addition, our Company will keep track of job applications that were submitted to our Company and a list of all candidates that were interviewed by our Company where we will have copies showing their home address indicating if they are residents of Fresno. As for verifying social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code, the presents additional challenges for our Company, as certain qualifications for social equity status under Section 9-3316(b)(1) of the Fresno Municipal Code (for example, “Former foster home youth who was in foster care as a minor” and “receiving public assistance”) are inappropriate, or arguably unlawful, inquiries during the interview process. As a result, our Company will employ legal counsel specialized in employment law to develop solutions for acquiring and retaining verification documentation of social equity status as defined in Section 9- 3316(b)(1) of the Fresno Municipal Code in a way that provides all potential social equity backgrounds an equal opportunity in our Company’s hiring process. One such solution that our Company is considering to this legal / human resources obstacle is to partner with the City or local community organizations to have the City or local community organizations do the vetting of social equity status under Section 9-3316(b)(1) of the Fresno Municipal Code (who may not have the same legal obstacles as our Company) and then forward vetted candidates to our Company for interviews. If after our Company reaches out to various resources in order to hire local, social equity candidates, our Company is unable to meet its goals of 50% of employees personnel hours from Fresno residents from social equity backgrounds, our Company will attempt to coordinate with the City and other approved cannabis businesses in City to host a local “Cannabis Job Fair”. If after hosting its own “Cannabis Job Fair”, our Company is still unable to meet local and social equity hiring goals, we will then look to use more traditional job platforms such as Indeed and ZipRecruiter to hire the remaining employees needed to properly staff the cannabis retail business, and our Company will collaborate with the City to determine other ways to divert additional community benefits to the City of Fresno and its residents, such as increased public benefits via its Community Benefits Agreement. IV.B Expungement Clinics Our Company is committed to helping individuals from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code overcome obstacles to employment regardless of whether such individuals end up working for our Company. One such obstacle is criminal records. Our Company will host expungement fairs for individuals from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code and others with community partners. IV.C Social Equity Incubator / Apprenticeship Program Our Company will commit via a Community Benefits Agreement to serve as a Social Equity Business Incubator by offering support to local cannabis social equity businesses in the form of mentorship, training, equipment donation, a percentage of shelf space dedicated to Fresno equity business products, legal assistance, financial services assistance, and/or other technical assistance support. Appreciating that it is paramount to address the negative consequences of the War on Section 2 – Social Policy & Local Enterprise Plan Page 7 of 16 Drugs, our Company believes that individuals negatively impacted by the War on Drugs should have resources available to assist them in participating in the cannabis industry. Accordingly, our Company’s Owners / Members have a long history of embracing cannabis Social Equity Programs throughout the State and through their existing cannabis retail business operations. To illustrate, Minority Owner / Member & Retailer Manager, Aaron Mamann, is an Owner / Member of three Social Equity cannabis businesses in the City of Los Angeles and Majority Owner / Member, Maritza Estrada, is an Owner / Member of one Social Equity cannabis retail business approved applicant in the City of Los Angeles. IV.D Diversity Policy Consistent with its our mission, we will provide a welcoming workplace and will promote the involvement of diverse employees and diverse groups in its operations. As a result, our Company will implement a zero-tolerance policy relating to discrimination and employees will be encouraged to report any and all occurrences of workplace discrimination. Our Company will monitor discrimination in the workplace and immediately address any discovery of discrimination. We will also train employees to identify workplace discrimination in the context of two general categories: (i) overt discrimination and (ii) covert discrimination. IV.E Equal Opportunity Employment It is the policy of our Company to provide equal employment opportunities to all qualified individuals and to administer all aspects and conditions of employment without regard to the following: race, color, age, sex, sexual orientation, gender, gender identity, religion, national origin, pregnancy, marital status, AIDS/HIV, genetic information, including family medical history, physical or mental disability, medical condition, political activities or affiliations, child or spousal support withholding, domestic violence, assault, or stalking victim status, lawful conduct occurring during nonworking hours away from the employer’s premises, military or veteran status, credit report or credit information, prior non-conviction arrest record, citizenship and/or immigration status, or any other protected class, in accordance with applicable federal, state, and local laws. We take allegations of discrimination, intimidation, harassment, and retaliation very seriously and will promptly conduct an investigation when warranted. If any of our employees are caught violating this policy, they will be subject to IMMEDIATE disciplinary action. V. Workforce Plan – Employee Training V.A Regulatory Knowledge & Education Our Company’s top priority when training its employees will be for it to understand the rules and regulations that govern the cannabis retail business in order to run a safe and compliant workplace. Our Company will ensure that the training will be at least two hours long and cover the below modules: (i) Health and safety concerns of cannabis use, including the responsible use of cannabis, its physical effects, onset of physiological effects; (ii) Recognizing signs of impairment and appropriate responses in the event of overconsumption; (iii) Laws and regulations on driving while under the influence; (iv) Prohibiting sales to minors; (v) Daily sales limits to customers and patients; (vi) Acceptable forms of identification as well as how to check identification and common Section 2 – Social Policy & Local Enterprise Plan Page 8 of 16 mistakes made in verification; (vii) Safe and secure storage of cannabis; (viii) Compliance with all inventory tracking system regulations; (ix) Waste handling, management, and disposal; (x) Health and safety standards; (xi) Maintenance of records; (xii) Security and surveillance requirements; (xiii) Permitting inspections by the City and State; and (xiv) Packaging and labeling requirement for all cannabis products. V.B Cannabis Knowledge Our Company will train employees about general information in regards to cannabis in order to better inform themselves and the customer. This will include the detailed information that goes over the following topics: (i) What cannabis is; (ii) The different ways cannabis is smoked and consumed; (iii) How cannabis effects the brain in short-term and long-term effects; (iv) Suggested consumption methods and dosing guidelines; (v) Understanding edible consumption and dosage; (vi) Customers guidelines to safe cannabis use; (viii) What the physical effects are of using cannabis and cannabis products; (ix) The mental effects of cannabis and cannabis products; (x) Long term effects of cannabis use; (xi) Treatments for Cannabis Use Disorder; (xii) Effects of secondhand cannabis smoke; (xiii) Cannabis as a possible gateway drug; (xiv) Overdosing on cannabis; (xv) Cannabis addiction; and (xvi) Dangers of synthetic cannabinoids. Dispensary employees will be trained on how to interact with customers, give recommendations based on their requests, give advice, guidance, and counsel customers on products. Dispensary employees will not give medical advice, as they are not licensed health professionals, and will be advised to tell customers to talk to their physician. Our Company holds a high expectation for employees’ knowledge of cannabis quality and strains. Accordingly, our Company will put together Information Sheets from the cannabis products we receive from our vendors and compile it in a binder that all staff can access and reference. These Information Sheets will include a description of the product, how it was cultivated or manufactured, and what effects to associate with the product. Our Company will require employees to take a quiz on Cannabis and Regulatory Knowledge and be expected to pass it by their third try. If they do not pass the quiz the employee will not be hired. V.C Security Training Our Company understands that security is of paramount importance. We are keenly aware of the added security challenges that a business of this nature faces, and we have taken extensive measures to have professionally-vetted policies, procedures, and systems in place to provide comprehensive protection, not only for our physical store, but also for our employees. Our Company will train managers on how to use the security alarms set up by the alarm company and then train all necessary employees on how the system works. It is critical that employees understand exactly what to do when specific breaches and threats take place. This ensures employee and customer safety and gives law enforcement and security personnel the ability to respond to a specific rapid response without fear of injury. Our Company’s Security Officer will provide specific training to management and employees in the following areas: (i) Security awareness training; (ii) responding to a robbery attempt; (iii) interacting with a disruptive customer; (iv) alarm activation response; (v) attempted theft; (vi) working with local law enforcement; (vii) medical emergencies; (viii) proper use of the “panic button”; (ix) being a good Section 2 – Social Policy & Local Enterprise Plan Page 9 of 16 witness/report writing; (x) theft and diversion training; (xi) OSHA compliance; and (xii) training developed for all compliance issues. In addition to the items listed above, our Community Liaison will work with security companies and with management to design and implement continued training in security related matters on a regular basis. Employees shall be tested on training content and must pass a comprehensive test by their third attempt in order to remain employed. All staff shall also go through periodic refresher seminars, as well as new training on any policy updates or changes in procedure. All emergency procedures will be rehearsed in periodic drills. In addition to training and periodic drills, all employees will receive official Company reference material, written in plain English and presented in an easy-to-use outline format, explaining all operational, safety, and security policies and protocols. In developing our official safety and security policies, our Company shall consult with local law enforcement. We shall also work with local law enforcement to develop effective ongoing employee training seminars and practices especially in developing our policies and training procedures on crime prevention and security threat response. After the security-related training, all employees should be able to: (i) know how to assess situations to determine the type and level of threat they may pose; (ii) know how to respond to different kinds of security threats; (iii) know which types of situations warrant the activation of panic buttons; and (iv) know how to proceed when a security alarm goes off or a panic buttons has been activated V.D Dispensary Operational Procedures V.D.1 Training Delivery Our Company believes that the better informed our employees are, the better they can answer questions and teach our customers how to safely use and enjoy the cannabis products we will carry. To ensure all employees are properly, our Company utilizes the following approaches to employee training: (i) New hire training; (ii) hands-on training; and (iii) employee-to-employee training. Additionally and as highlighted above in training subject specific sections, employees will be tested on training content and must pass the test by their third attempt in order to remain employed. All employees will go through annual refresher training, as well as new training on any policy updates or changes in procedure as they arise. V.D.2 New Hire Training Upon starting with our Company, all new employees will attend a full eight hour Employee Educational Course that will coincide with the Regulatory and Cannabis Knowledge, and Security Measure Training and focus on the following subjects: (i) Point-of-sale (“POS”) system; (ii) State inventory system, METRC; (iii) time and attendance system; (iv) medical patient verification; (v) adult-use age verification; (vi) inventory control; (vii) cannabis laws and regulations; (viii) secure electronic record keeping; (ix) procedures for patient and customer reception and registration; and (x) procedures for cannabis product sales. Further, our Company will also encourage all employees to work on continuing their education in all these fields and will be encouraged to attend third-party courses offered by our Company to pursue the highest levels of cannabis retail business employee qualification. Section 2 – Social Policy & Local Enterprise Plan Page 10 of 16 V.D.3 Hands-On Training Our Company follows up new hire training with work one-on-one with new employees to review training materials with them. Regardless whether training is about cannabis products or proper procedures, our Company believes it is important to follow up and test staff’s knowledge. We want staff to be able to articulate knowledge in both words and actions. This ongoing training with staff also ensures employee retention and consists of the following methods: • Management will ask employees a series of increasingly complicated questions. Our Company will work to do their best to ensure staff can be successful when being quizzed. The goal will not be to stump the employees, but to work on building their confidence in being knowledgeable in all policies and procedures. • Management will do role-playing training exercises with employees. Although it can sometimes be an awkward training method, it is also very effective. Role-playing allows our Company to see if employees can effectively articulate information back to us and how employees handle themselves in common operational scenarios. Management will not focus on delivery as is common with forced scenarios, but rather focus on employees’ knowledge and understanding of the training materials and decision-making in the role- playing scenarios. • Management will take turns with an employee where first management will deal with a real customer and one where management will watch how the employee interacts with a customer. Employees will pay attention on how the manager is working with customers, and then attempt to mimic / copy those skills. In so doing, management will make close observation of employees as they perform their duties and make notes and either positively correct, or give approval, as needed. V.D.4 Employee-to-Employee Training Employee-to-employee training is a great way for employees to learn information in a non- threatening way and this form of training is the ideal way for employees to learn from one another. Our Company will utilize team-building exercises that allow everyone in the cannabis retail business to come together without the pressures of daily routines. Management will also be responsible for assigning sales associates for training on any area where an employee requires additional training. VI. Workforce Plan – Codes of Conduct VI.A Drug Free / Alcohol Free Our Company is dedicated to providing employees with a workplace that is free of drugs and alcohol. For the safety of our employees and customers, we reserve the right to test any employee for the use of illegal drugs or alcohol under state, federal, or local laws. This may be done in cases where the employee’s job carries a risk of injury or accident due to such use, or if there is an apparent inability to perform the duties required of that position. Any employee found to use, sell, Section 2 – Social Policy & Local Enterprise Plan Page 11 of 16 possess, or distribute drugs that are illegal under state, federal, or local laws, including cannabis, or any unauthorized drugs (including excessive quantities of prescription or over-the-counter drugs) while on the Company premises, performing Company-related duties, or while operating any Company equipment is subject to disciplinary action, up to and including termination of employment. Any suspected illegal drugs confiscated will be turned over to the appropriate law enforcement agency. VI.B Sexual Harassment & Other Unlawful Harassment Applicable federal and state law defines sexual harassment as unwanted sexual advances, requests for sexual favors, or visual, verbal, or physical conduct of a sexual nature when: (i) submission of the conduct is made a term or condition of employment; (ii) submission to or rejection of the conduct is used as basis for employment decisions affecting the individual; or (iii) the conduct has the purpose or effect of unreasonably interfering with the employees work performance or creating an intimidating, hostile, or offensive working environment. Sexual harassment and unlawful harassment are prohibited behavior and against Company policy. Our Company is committed to providing a work environment free of inappropriate and disrespectful behavior, intimidation, communications, and other conduct directed at an individual because of their sex, including conduct that may be defined as sexual harassment. VI.B.1 Other Types of Harassment Prohibited harassment on the basis of race, color, religion, national origin, ancestry, physical or mental disability, veteran status, age, or any other basis protected under local, state or federal law, includes behavior similar to sexual harassment, such as: verbal conduct such as threats, epithets, derogatory comments, or slurs; visual conduct such as derogatory posters, photographs, cartoons, drawings, or gestures; physical conduct such as assault, unwanted touching, or blocking normal movement; and retaliation for reporting harassment or threatening to report harassment. VI.B.2 Retaliation It is against our Company’s policies and unlawful to retaliate in any way against anyone who has lodged a harassment complaint, has expressed a concern about harassment, including sexual harassment, or has cooperated in a harassment investigation. Therefore, the initiation of a complaint, in good faith, will not under any circumstances be grounds for disciplinary action. VI.B.3 Enforcement All managers and supervisors are responsible for: (i) Implementing our Company’s policies on harassment, which includes, but is not limited to, sexual harassment and retaliation; (ii) ensuring that all employees they supervise have knowledge of and understand our Company’s policies; (iii) reporting any complaints of misconduct to the designated Company representative so they may be investigated and resolved immediately; (iv) taking and/or assisting in prompt and appropriate corrective action when necessary to ensure compliance with the policy; and (v) conducting themselves in a manner consistent with our Company’s policies on harassment. Section 2 – Social Policy & Local Enterprise Plan Page 12 of 16 VI.C Abusive Conduct Abusive conduct means malicious conduct of an employer or employee in the workplace that a reasonable person would find hostile, offensive, and unrelated to an employer’s legitimate business interests. Abusive conduct may include repeated infliction of verbal abuse, such as the use of derogatory remarks, insults, and epithets, verbal or physical conduct that a reasonable person would find threatening, intimidating, or humiliating, or the gratuitous sabotage or undermining of a person’s work performance. Our Company considers abusive conduct in the workplace unacceptable and will not tolerate it under any circumstances. Employees should report any abusive conduct to a supervisor or manager with whom employees are comfortable speaking. Supervisors and managers are to assume the responsibility to ensure employees are not subjected to abusive conduct. All complaints will be treated seriously and investigated promptly. During the investigation process our Company will attempt to maintain confidentiality to the fullest extent possible. It is a violation of Company policy to retaliate or otherwise victimize an employee who makes a complaint or a witness who serves in the investigation of the abusive conduct allegation. VI.D Open Door Policy We encourage employees to bring their work-related questions, suggestions, and complaints to our Company’s attention. Employee input is important to us, and they should bring their good faith concerns to the attention of management without the fear of retaliation. We will consider and investigate the concerns brought to our attention in order to attempt to resolve problems and/or improve our operations. We hope to be able to satisfactorily resolve most matters. VI.E Workplace Safety We are committed to providing and maintaining a healthy and safe work environment for all employees. However, a safety program can only be successful if everyone cooperates. Employee assistance in eliminating hazards and unsafe conditions and attention to good housekeeping will do much to make our Company a safe place to work. As a result, every employee is required to follow safe and healthy work practices at all times. Employees may be subject to discipline for engaging in any unsafe or unhealthy work practices. In addition to compliance with safety measures imposed by federal Occupational Safety and Health Act (“OSHA”) and state law, our Company has an independent interest in making its facilities a safe and healthy place to work. Our Company recognizes that employees may be in a position to notice dangerous conditions and practices and therefore encourages employees to report such conditions, as well as all non- functioning or hazardous equipment, to a supervisor or manager immediately. Following employee reporting, our Company will take appropriate remedial measures. Employees will not be retaliated or discriminated against for reporting of accidents, injuries, or illnesses, filing of safety-related complaints, or requesting to see injury and illness logs. Employees are required to promptly report all injuries at work, or other work-related injuries, no matter how minor, to their immediate supervisor. Supervisors are responsible for obtaining first aid and proper medical care, and promptly reporting the injury to Human Resources, who will fill out all appropriate forms and reports. The location of the nearest doctor and/or medical facility is posted on the bulletin board(s). An employee’s employment status will not be affected by the Section 2 – Social Policy & Local Enterprise Plan Page 13 of 16 report of a work-related injury or the filing of a workers’ compensation claim. Our Company provides insurance for all work-related injuries or illness. VII. Number of Employees & Job Descriptions Below is the chart of our expected number of employees for starting up and the first three full years of operation: VII.A Job Descriptions and Duties VII.A.1 Retailer Manager Our Company’s Retailer Manager is the senior executive officer for our overall Company and overall cannabis retail business operation and has direct authority, control, or supervision over all personnel. VII.A.2 Real Estate Development Officer Our Company’s Real Estate Development Officer is a real estate professional to advise our Company’s executive officers on the location, acquisition, development, and construction of cannabis retail businesses in the State. VII.A.3 Community Liaison / Community Organizer Our Company’s Community Liaison is a senior executive officer that serves as our Company’s point-of-contact for on-site community relations to whom government representatives and members of the community can provide notice if there are operating problems associated with our Company’s cannabis retail business. VII.A.4 Chief Medical Officer Our Company’s Medical Officer is a licensed physician responsible for advising our Company’s Personnel Annual Salary 2020 2021 2022 2023 2024 Retailer Manager 1 1 1 1 1 Chief Compliance Officer 0 1 1 1 1 Community Liaison 0 1 1 1 1 Chief Medical Officer 0 1 1 1 1 Real Estate Development Officer 0 1 1 1 1 Bookkeeper / Administration 0 1 1 1 1 Dispensary General Manager 0 1 1 1 1 Assistant Dispensary General Manager 0 2 2 3 3 Dispensary Sales Representatives 0 4 5 6 7 Delivery Drivers 0 1 1 2 2 Security Guards 0 4 4 5 5 1 18 19 23 24Total Section 2 – Social Policy & Local Enterprise Plan Page 14 of 16 executive officers on the selection, purchasing, and development of medical-grade cannabis and cannabinoid pharmaceuticals for our cannabis retail business’s cannabis product inventory. VII.A.5 Chief Compliance Officer Our Company’s Compliance Officer is the senior executive officer that responsible for ensuring our cannabis retail business operates in compliance with the State and City law and day-to-day executive officer responsible for inventory, tracking, and control of all cannabis and cannabis products to include all procurement and quality control of cannabis and cannabis products and has direct authority, control, or supervision over all personnel who engage in accounting for and quality control of cannabis and cannabis products. As a result, our Company’s Compliance Officer will serve as the administrator for our Company’s track and trace systems. VII.A.6 Bookkeeper / Administration Our Company’s Bookkeeper / Administration is an employee that provides general financial and administrative support to our Company and frontline employee working directly for our Company’s Compliance Officer. They will perform analytical reviews of financial results and assist with developing and reviewing key performance indicators as well as execute a variety of general accounting support tasks and will function in accordance with established standards, procedures, and applicable laws VII.A.7 Dispensary General Manager Our Company’s Dispensary General Manager (“GM”) is the day-to-day supervisor of our Company’s cannabis retail business operation and has direct authority, control, or supervision over all personnel who engage in the retail sale of cannabis and cannabis products. The GM serves as a role model, liaison, and resource for cannabis retail business staff concerning products and services, policies and procedures, industry news and changes in regulations. They ensure compliance with all State and local rules and regulations, and directly supervises the activity within the cannabis retail business to include staff training and education. The GM manages the receipt, storage and auditing of all inventory, and are responsible for ordering new inventory and supplies, and maintains accurate records. The GM resolves all inventory discrepancies and reconciliations while accurately documenting all inventory movements to be recorded in the company’s track and trace system and into the State’s track and trace software, METRC in order to identify the proper location and quantity of product at all time. The GM supervises assistant managers on all daily tasks consistent with established procedures with an emphasis on inventory control actions such as receiving, counting and inspecting all incoming cannabis products for quality and compliance; implement HR policies, programs, and systems in support of company initiatives; directs all compliance efforts for the company to minimize risk and deal with any internal conflicts. The GM will conduct investigations: respond to unemployment claims, EEOC, DOL, and/or employee relation issues such as employee complaints, harassment allegations, and civic rights complaints. The GM conduct exit interviews, analyze data, and make recommendations to corporate management team for corrective action and continuous improvement as well as conduct performance reviews with employees and monitor employee productivity, attitudes, and Section 2 – Social Policy & Local Enterprise Plan Page 15 of 16 performance results. They will maintain excellent facilities conducive to enhancing employee productivity and compliance, and ensure employee safety, wellness, health and welfare. VII.A.8 Assistant Dispensary General Managers Our Assistant Dispensary General Managers (“AM”) assist our GM with day-to-day operations of the cannabis retail cannabis retail business in accordance with the State of California, local regulations, and standards set by our Company. The AM will help maintain organization and operations at the cannabis retail business with detail to inventory duties. Assistance is also given to the sales team to ensure efficiency and customer satisfaction. The AM will provide support to store manager and all employees, and patients/customers. Overall duties also include: light cash- handling, training, providing policy and procedure updates, and keeping updated with industry news and cannabis product information. The AM provides management and leadership in the cannabis retail business to include monitoring all point-of-sale transactions. They respond to all staff questions, concerns, or suggestions within scope and reports to the GM for resolution. The AM directs and monitors sales representatives to accomplish goals of the days consistent with established operational procedures. The AM maintains records required by public health law and ensures quality assurance plans, including but not limited to plans to detect, identify, and prevent dispensing errors related to product packaging and labeling. The AM monitors employee productivity, attitudes, and performance results, and make recommendations to the GM for corrective action and continuous improvement for product and policies. The AM Responds to all patient/customer complaints, requests, concerns, suggestions and takes action when directed by the GM to resolve conflicts including responses and replies across social platforms. The AM manages the receipt, storage, record keeping, and auditing of all inventory, and maintaining cannabis retail business compliance and cleanliness. The AM performs inventory control actions such as receiving, counting, and inspecting for quality and compliance. The AM assists the GM (i) in accurately documenting all inventory movements to be recorded in the company’s track and trace system and into the State’s track and trace software, METRC to identify the proper location and quantity of product at all time and (ii) with bi-monthly reconciliation inventory counts based on company requirements, and works with the store manager to resolve all inventory discrepancies and light-cash handling. VII.A.9 Dispensary Sales Representatives Our sales representatives (“SR”) assist guests, clients, vendors, and management whenever possible. Our SR assist the management team with the activities and operations of the store, while abiding by policies, procedures, and operational guidelines. The SR is responsible for helping customers, checking them out, cash handling, and customer service. They welcome visitors by warmly greeting them, in person or on the telephone and answering or directing inquiries through proper channels. They accurately process payments from customers; issues receipts, refunds, credits, and change. They establish or identify prices of goods, services or admission; tabulates bills using calculators, cash registers, and optical price scanners. The SR operates a cash register and itemize total purchases by recording prices, departments, taxable and nontaxable items and balance cash drawers by counting cash at beginning and end of work shift to ensure that amounts are correct and that there is adequate change. The SR helps maintain a compliant and clean Section 2 – Social Policy & Local Enterprise Plan Page 16 of 16 cannabis retail business and assures side-work completion every shift. They establish, develop, and maintain relationships with current and prospective customers to generate business for our cannabis products. They use information-based training to educate customers with the SR expected to continue education on all products. They maintain product knowledge of all products in-store in order to communicate to customers and patients. They ensure the sales floor is properly stocked and the cleanliness of the store is well maintained. The SR promotes a work environment that is positive, customer-service oriented, and compliant with established policies and procedures. VII.A.10 Delivery Drivers Our delivery drivers have similar responsibilities to our SR, but with the added responsibilities of handling proper record receipts to be given and signed by customers, and understands safety and delivery compliance protocols for all deliveries. They must obey all traffic laws and always have all necessary paperwork required by the City and State at all times via hard copy or electronically. VII.A.11 Security Guards Our Company will use a third-party security company that will ensure the safety of customers and employees and the protection of assets. This is accomplished through the use of foot patrols, professional presence, camera monitoring, escort procedures, access control, and enforcement of company security policies. All security guards will be certified through the Bureau of Security and Investigative Services. They will check identification cards for all persons entering cannabis retail business to ensure only those over the age of 21, or those over 18 with a proper medical recommendation are let inside the cannabis sales area. TRADITIONAL - FRESNO - ME LLC ATTN: ARTHUR REYNA, ATTORNEY AT LAW PHONE: | EMAIL: AR@ARTHURREYNALAW.COM Page 1 of 19 Neighborhood Compatibility Plan for Traditional - Fresno - ME LLC Introduction & Executive Summary Traditional - Fresno - ME LLC (our “Company”), through its Owners / Members and officers has an unmatched track record of successful and timely development, establishment, and operation of cannabis businesses—in particular cannabis retail businesses—throughout the State of California. Our Company’s Owners / Members are a team of experienced professionals and stalwarts of the cannabis industry that include: (i) the owner and operator of one of the largest and most successful cannabis business portfolios in California and the U.S. with an established dedication and investment in social equity cannabis businesses and (ii) a young Latina that overcame growing up one of the most heavily impacted communities by the War on Drugs to graduate from college and go on to be a Majority Owner of a social equity retail cannabis business in the City of Los Angeles. Through its Owners / Members and officers, our Company will bring the Traditional brand to the City of Fresno (“Fresno” or the “City”) and operate an all-inclusive, elevated cannabis retail business that is custom-tailored and completely integrative and symbiotic with the local neighborhood. Accordingly, our Company will manage its operations in a manner that curbs any potential nuisance or detriment to the public health, safety, convenience, and welfare of people residing, working, visiting, or recreating in the area and the larger community. The following policies— which together constitute our “Good Neighbor Policy”—are in place to demonstrate how we as a business will achieve this objective and how we will manage our staff and operations to minimize and remove any and all negative impacts. I. Nuisance Mitigation & Neighborhood Protection Our Company will establish and operate a cannabis storefront retailer (the “dispensary”), pursuant to a Commercial Cannabis Business Permit issued by the City. At a high-level, the Company will conduct the following activities as part of its dispensary operation: (i) our Company will purchase, from licensed distributors, finished cannabis and cannabis products (“cannabis products”) that have undergone the quality assurance, inspection, and testing procedures contained in Section 26110 of the California Business and Professions Code (the “B&P Code”) and (ii) our Company will offer cannabis products for retail sale to customers and patients (“customers”) at the dispensary and via delivery vehicles from the dispensary. Section 3 – Neighborhood Compatibility Plan Page 2 of 19 I.A Nuisance Mitigation & Consumer Protection Practices As part of our Company’s Good Neighbor Policy, the dispensary shall implement and enforce the following operational requirements to prevent its cannabis dispensary from becoming a public nuisance: • An Onsite Manager to whom emergency notice can be provided shall be present in the dispensary at all times during hours of operation. Our Company will also provide employees, the City, and local business and residents with the name and telephone number of an Owner or Manager to whom emergency notice may be provided twenty-four (24) hours a day. Contact information for our Company’s Onsite Manager(s) and community relations contact (“Community Liaison”) shall be made readily available both via our Company’s website and on file with the City and State. • Our Company will provide the City and all businesses and residences located within 1,000 feet of the dispensary premises with the name, telephone number, and email address of a designated Community Liaison to whom notice of problems associated with the business can be provided. The Community Liaison shall respond to any such complaints within forty-eight (48) hours of receipt of any complaint. • Our Company shall prominently display a copy of its State and City-issued permits in a conspicuous location visible and accessible to customers and the public. • At no time shall any of the following items be allowed in the dispensary or on the property grounds: (i) any controlled substance, other than cannabis; (ii) any paraphernalia used for the ingestion of any type of controlled substance, including cannabis (except for cannabis accessories for incidental retail sale to customers); (iii) alcoholic beverages; or (iv) firearms, except in strict compliance with federal, State, and City laws and regulations. These prohibitions will be strictly enforced by employees and security personnel. • All cannabis products sold by our Company shall be cultivated, manufactured, and transported by licensed facilities that maintain operations in full conformance with State and local regulations; to track and report on all aspects of the cannabis outlet, our Company shall have in place a point-of-sale or management inventory tracking system, which shall have the capability to produce historical transactional data for review and shall be in compliance with the State’s track-and-trace system, METRC. • Our Company shall not sell alcoholic beverages or tobacco at the dispensary and shall prohibit the smoking, vaporization, ingestion, or consumption of alcohol, tobacco, or cannabis in any form at the dispensary and on the dispensary premises. No employee shall be under the influence of alcohol or drugs while on the dispensary premises. • Our Company shall not have an onsite physician for the purpose of evaluating patients for issuance of a medicinal cannabis recommendation or identification card nor shall our Company give or offer to give any form of remuneration to a physician if the physician or his or her immediate family have a “financial interest” (as that term is defined in Section Section 3 – Neighborhood Compatibility Plan Page 3 of 19 650.01 of the California Business and Professions Code (“B&P Code”) in our Company or its cannabis outlet. • Our Company shall not distribute any form of advertising for physician recommendations for medicinal cannabis unless the advertisement bears the notice contained in Section 2525.5 of the B&P Code. • Our Company shall not hire to employ any person under 21 years of age at the dispensary. Our Company shall not allow any individual under the age of 21 in the dispensary unless the individual has a medical recommendation and is over the age of 18. • Our Company shall not discriminate or exclude patrons in violation of local, State, or federal laws and regulations. • Our Company shall ensure that no outdoor storage of cannabis or cannabis products occurs at the dispensary at any time and shall ensure that cannabis or cannabis products, or graphics depicting cannabis or cannabis products, shall not be visible with the naked eye from the exterior of the dispensary or from any public or other private property owned or controlled by our Company. • Our Company shall ensure outdoor trash receptacles shall be available near the entrances to and exits of the dispensary, and the dispensary shall be continuously maintained in a safe, clean, and orderly condition with twice daily litter pick‐up within 50 feet of the dispensary. Such litter pick‐up shall include inspections for graffiti, which shall be removed within 24 hours of detection. • Our Company shall ensure that all areas recorded by the video surveillance system shall at all times have adequate lighting to allow the surveillance cameras to effectively record images. • All exterior windows, doors, loading and unloading docks or bays, and any points of ingress or egress into the dispensary shall be secured from unauthorized entry by commercial grade, nonresidential locks, and in a manner approved by the Fresno Police Department. The exterior of each of the foregoing areas shall be illuminated during evening and early morning hours. The ingress and egress points of any storage areas for cannabis or cannabis products shall be locked and secured at all times, and under the control of and accessible only by our Company’s authorized personnel. • All waste generated by or resulting from commercial cannabis activities shall be disposed of as required by law, and pending disposal shall be stored in a locked and secure area that is under the control of and accessible only by our Company’s authorized personnel. • Our Company shall employ odor control devices and techniques to ensure that odors from cannabis and cannabis products are not detectable offsite of the dispensary. Section 3 – Neighborhood Compatibility Plan Page 4 of 19 • Signage for the dispensary shall comply with the Fresno Municipal Code, including, but not limited to, seeking the issuance of a sign permit, if required. • Our Company shall notify customers of the following verbally (or by written agreement) and by posting of a notice or notices in a minimum of 24-point font conspicuously within the dispensary: o “The sale or diversion of cannabis or cannabis products without a license issued by the City of Fresno is a violation of State law and the Fresno Municipal Code.” o “Secondary sale, barter, or distribution of cannabis or cannabis products purchased from a licensee is a crime and can lead to arrest.” o “Customers must not loiter in or near these premises and may not consume cannabis or cannabis products in the vicinity of this business or in any place not lawfully permitted. These premises and vicinity are monitored to ensure compliance.” o “WARNING: The use of cannabis or cannabis products may impair a person’s ability to drive a motor vehicle or operate heavy machinery.” o “CALIFORNIA PROP. 65 WARNING: Smoking of cannabis and cannabis- derived products will expose you and those in your immediate vicinity to cannabis smoke. Cannabis smoke is known by the State of California to cause cancer.” • Our Company shall prevent loitering within 50 feet of the dispensary; our Company shall take all reasonable steps to discourage and correct conditions that constitute a nuisance in parking areas, sidewalks, alleys and areas surrounding the dispensary and adjacent properties during business hours. “Reasonable steps” shall include immediately calling the Fresno Police Department upon observation of the activity and requesting that those engaging in activities that constitute a nuisance or are otherwise illegal to cease those activities, unless personal safety would be threatened in making the request. Our Company will post 12” x 12” signs at entrances, exits, parking lots, and other conspicuous places stating, “LOITERING, PUBLIC DRINKING, OR PUBLIC SMOKING, VAPING, INGESTING OR OTHERWISE CONSUMING CANNABIS ON THE PREMISES OR IN THE AREAS ADJACENT TO THE PROPERTY IS PROHIBITED; NO ONE UNDER THE AGE OF TWENTY-ONE SHALL BE PERMITTED WITHIN THE PREMISES EXCEPT A QUALIFIED PATIENT OVER THE AGE OF EIGHTEEN”. • 12" x 12" signs will be posted in conspicuous places in- and outside of the dispensary stating, “THESE PREMISES ARE BEING DIGITALLY RECORDED; ALARM MONITORED”, notifying the public that the surveillance cameras and alarm monitoring system is operative and is actively monitoring. A visual presentation of our Company’s nuisance mitigation practices can be seen in the architectural renderings presented below. A more detailed discussion on specific nuisance mitigation practices follows the architectural renderings. Section 3 – Neighborhood Compatibility Plan Page 6 of 19 I.B.1 Customer & Patient Policies Agreement Our Company believes each customer and patient acts as an ambassador for our entire cannabis dispensary as well as the cannabis community and the City of Fresno. We want our customers to feel cared for, to be recognized as important to society, and to leave our dispensary inspired to be a positive voice for cannabis and the local community. We have developed the below policies to maintain strong relationships with our surrounding neighborhood and to ensure that all of our customers are treated with respect and dignity. Each customer is required to comply with these policies and our Company reserves the right to refuse service for any violations with no warnings or second chances. These policies will be posted prominently in the lobby and retail sales area and each customer will need to sign a statement agreeing to adhere to these policies. • Customers and patients agree to turn phones, video gaming devices, or other electronics to “silent” or “vibrate”, and to refrain from making or receiving calls while on the sales floor. • Customers and patients agree that they will not use any electronic communication or recording devices while in the dispensary. • Customers and patients may not take photographs or record video or audio on the premises without consent from an authorized employee. • Customers are required to carry valid, government-issued identification and patients must provide proof of their status as a valid California qualified patient or primary caregiver whenever they are visiting the dispensary. • All cannabis obtained through the dispensary is for the personal use of the customer or patient and may not be resold or distributed under any circumstances. • Customers and patients shall be respectful of the neighborhood where the dispensary is located. No loitering, loud music, littering, posting, or soliciting is allowed on or in the vicinity of the dispensary. • Customers and patients and staff are to treat each other with respect and courtesy at all times; offensive, abusive and/or threatening language and/or behavior is prohibited. • Customers and patients are not to bring and/or use alcohol, illegal drugs, or weapons inside or around the dispensary. • Customers and patients are not to misrepresent our Company by posting stickers, posters, or any other materials in any public spaces. • Guests other than prospective customers or patients are prohibited from the dispensary and premises; each customer or patient is responsible for guest behavior at all times on or in the vicinity of the dispensary. • No consumption of cannabis is allowed on or in the vicinity of the dispensary. Section 3 – Neighborhood Compatibility Plan Page 7 of 19 • Customers and patients are limited to one visit per day at the dispensary. • Only qualified service animals are allowed inside the dispensary; all other pets are not allowed. • All cannabis and cannabis products shall be kept in opaque exit packaging and out of sight before leaving the dispensary. • Customers and patients shall be friendly and are encouraged to support our neighbors with patronage. • In case of an emergency (law enforcement action, fire, power outage, etc.) customers and patients are to stay calm and follow instructions from the staff. I.B.2 Noise Preventative Measures To comply with Article 1 of Chapter 10, Noise Regulations, of the City of Fresno Municipal Code, our Company will abide by the following regulations. • Our Company will not exceed 65 decibels (“dBa”) for exterior sounds that may be emitted from the dispensary during business hours and no more than 60 dBa when the business is closed. Our Company will make sure interior sounds do not exceed 50 dBA. • Within the area of the dispensary, our Company will not create, maintain, cause or allow any sound on the property which causes the above sound level, when measured on any other property, to exceed: (i) The allowable exterior sound level for a cumulative period of more than 30 minutes in any hour; (ii) the allowable exterior sound level plus five dBA for a cumulative period of more than 15 minutes in any hour; (iii) the allowable exterior sound level plus ten dBA for a cumulative period of more than five minutes in any hour; (iv) the allowable exterior sound level plus 15 dBA for a cumulative period of more than one minute in any hour; or (v) the allowable exterior sound level plus 20 dBA for any period of time. In the event the ambient sound level exceeds any of the first four sound level categories above, the dispensary will allow the exterior sound level applicable to the category to be increased to reflect ambient sound level. • If the sound level is continuous and goes beyond the reasonably allotted time, security will work with the Onsite Manager to make sure the noise is discontinued or stopped for a time period to the allowable exterior and interior sound level. • Sounds associated with the maintenance of the dispensary will be exempt from the above measures, but our Company will ensure these activities occur between the hours of 7:00 a.m. and 6:00 p.m. every day. Relatedly, sounds associated with the maintenance and inspection of emergency machinery, vehicle, work, or alarm will only occur between the hours of 7:00 a.m. and 6:00 p.m., Monday through Friday. Section 3 – Neighborhood Compatibility Plan Page 8 of 19 • If our Company receives noise complaints that are deemed outside of the parameters of the above, we will give all neighboring businesses the Onsite Manager’s information to whom notice can be provided, as well as the name and telephone number of an Owner or Manager of our Company. If our Company receives the complaint, we will immediately address the problem within the hour. I.B.3 Lighting Measures Outdoor lighting systems shall be designed and installed to comply with the following: • The minimum requirements in the California Energy Code for Lighting Zones 1-4 as defined in Chapter 10 of the California Administrative Code; • Backlight, Uplight, and Glare (“BUG”) ratings as defined in IES TM-15-11; and • Allowable BUG ratings not exceeding those listed in the City Municipal Code. The only exceptions to the above outdoor lighting system requirements will be the following: • Luminaires that qualify as exceptions in Section 140.7 of the California Energy Code; • Emergency lighting; • Building façade lighting meeting the requirements in Table 140.7-B of the California Energy Code, Part 6; and • Custom lighting features as allowed by the local enforcing agency. For both interior and exterior lighting, our Company shall utilize best management practices and technologies for reducing glare, light pollution, and light trespass onto adjacent properties, and shall ensure compliance with the following standards: • Exterior lighting systems shall be provided for security purposes in a manner sufficient to provide illumination and clear visibility to all outdoor areas of the dispensary, including all points of ingress and egress. Exterior lighting shall be stationary, fully shielded, directed away from adjacent properties and public rights of way, and of an intensity compatible with the neighborhood. All exterior lighting shall be California Building Code and Fresno Municipal Code compliant. • Outdoor lighting shall utilize energy-efficient fixtures/lamps, such as high-pressure sodium, hard-wired compact florescent, or other lighting technology that is of equal or greater energy efficiency. • Interior light systems shall be fully shielded, including adequate coverings on windows, to confine light and glare to the interior of the structure. The windows will also be tinted to help reduce light trespassing. Section 3 – Neighborhood Compatibility Plan Page 10 of 19 limited and/or supervised interaction (touching, smelling, etc.) with securely displayed cannabis and cannabis products. • Validated customers (i) purchase and take possession of processed orders of cannabis products at the Product Point-of-Sale Stations or (ii) return cannabis products that may be adulterated to our Company at the Product Point-of-Sale Stations. • After finishing their business purpose for visiting the dispensary, customers are securely allowed to exit the dispensary at the direction of our Company’s employees. Our security guard will also take a walk around the building every hour to ensure no loitering is occurring, as well as to ensure that no customers are inhibiting other pedestrians from being able to leave the premises or to go to the other businesses in the area. If there is no room in the Lobby, staff will ask customers who are willing to wait to provide us with their phone number and to wait in their vehicle. We will then call them when it is time for them to enter the dispensary. II. Odor Mitigation Plan Our Company shall have an air treatment system professionally installed and properly maintained to ensure there is not cannabis odor detectable from adjacent properties or the community. The main, and likely only, potential source of odor at the dispensary will be the cannabis products. The air treatment system will consist, as described below, of carbon filtration on the exhaust side of the ventilation system and negative pressurization of the dispensary in relation to the exterior ambient condition. Employees, customers, and patients shall immediately report odor to management, who will then take corrective action such as implementing upgrades to the system, to the dispensary, or to the internal handling process of product within the dispensary to further deter odors. II.A Air Filtration Systems An exhaust and ventilation system shall be utilized to prevent both off-site odors and odors within the dispensary areas. The dispensary’s operations shall not create dust, noxious gasses, odor, smoke, unsafe conditions, or other impacts that create a public nuisance or adversely affect the health or safety of the nearby residents or businesses. The industry standard for air filtration calls for an activated carbon filtration system, photo catalytic oxidation (“PCO”), or a similar air- scrubber system. These systems greatly reduce, and often eliminate, the odors that can be associated with cannabis products. For the proposed dispensary, the configuration and design of the filtration system will be finalized during the building permit phase to allow for City input, thereby ensuring that the proper system is utilized. The filtration system ultimately installed will ensure that odors from cannabis are mitigated in the following locations: (i) off-site; (ii) adjacent properties; (iii) any public rights-of-way; and (iv) common tenant areas. Plans for our Company’s odor-combatting filtration system will be submitted to the City for approval, and our Company will schedule an audit with the City within thirty (30) days of commencing operations at the dispensary to confirm compliance with approved plans. The above Neighborhood Compatibility Schematic contains a schematic type diagram of how the air-scrubbing filtration system works to remove unwanted odors and impurities. The system creates negative pressure between the dispensary interior and exterior, thus keeping any odors inside the dispensary and not detectable Section 3 – Neighborhood Compatibility Plan Page 11 of 19 from the outside. Meanwhile, a carbon-zeolite mixture and a true medical HEPA filter absorb and remove and odors and gases. II.B General Odor Control Measures and Maintenance The dispensary shall incorporate and maintain adequate odor control measures such that the odors of cannabis cannot be detected from outside of the structure in which the business operates. Our Company will regularly inspect and maintain its air filtration system to ensure that the odor mitigation system remains functional. Our Company will also train staff in procedures and protocols for air quality and odor control, including procedures to implement when odors above baseline are detected, appropriate emergency response procedures for potentially harmful or noxious odors, best practices for minimizing the release of odors outside the dispensary and for ensuring proper ventilation, and practices to ensure that the filtration system is on and functioning properly. The odor mitigation systems and plans will be updated regularly to maintain consistency with accepted and best available industry-specific technologies designed to effectively mitigate cannabis odors. II.C Specific Commercial Cannabis Air Quality Measures Within the Retail-Buy Room, the only potential odor concerns our Company anticipates are those from the cannabis products themselves. Our Company’s dispensary will utilize technology, such as double-sealed doors and an air-scrubbing carbon unit, that will remove most if not all of the odors from the area. To further reduce cannabis odors, all cannabis products will be stored in sealed packages, as required by State law, apart from the small quantity used for display purposes. II.D Dispensary Ventilation Requirements All areas of the dispensary shall have sufficient ventilation to facilitate proper cannabis products storage and to provide a reasonable condition of comfort for each employee, consistent with the job performed by the employee. Restrooms shall be vented to the outside air by means an openable, screened window, an airshaft, or a light-switch activated exhaust fan, consistent with the requirements of local building codes. II.E Staff Training All employees shall be trained on how to detect, prevent, and remediate odor outside the dispensary and all corrective options outlined herein. Should complaints about objectionable off-site odors be received, the complaints shall be recorded and staff will be trained to take the following steps: (i) Investigate the likely source of the odor; (ii) utilize on-site management practices to resolve the odor event; (iii) take steps to reduce the source of objectionable odors; (iv) determine if the odor traveled off-site by surveying the perimeter and making observations of existing wind patterns; and (v) document the event for further operational review. If staff is unable to take steps to reduce the odor-generating source, they are to immediately notify the Onsite Manager, who shall create a proper solution, if applicable. If necessary, our Company shall re-engage a licensed certified engineer to review the issue and make recommendations for corrective action(s). Section 3 – Neighborhood Compatibility Plan Page 12 of 19 II.F Odor Detection Documentation The Odor Detection Form (Section VIII) shall be provided to those who suspect objectionable odors emanating from inside the dispensary. The Odor Detection Form will be made available on- site by request. Our Company shall maintain records of all odor detection notifications and/or complaints that will include the remediation measures employed. The records shall be made available to the City upon request and maintained for a period of not less than seven (7) years. III. Waste Management Plan Our Company shall destroy cannabis waste and by-products using a third party waste hauler or by making arrangements with a licensed distributor to have cannabis products destroyed under the following circumstances: (i) If the cannabis products went unused; (ii) if internal quality control assessments determine that the cannabis products are unusable; (iii) if the cannabis products are subject to recall; or (iv) if the cannabis products have been returned to our Company. The Onsite Manager will log the following information into the waste management log before putting the prospective waste into the third-party waste hauler’s bin: • Name and type of the cannabis goods; • Unique identifier of the cannabis goods; • Amount of the cannabis goods, by weight or count; • The total wholesale cost of the cannabis goods, as applicable; • The date the product was put into the waste bin; and • Name and license number of the distributor involved in the activity or transaction. Our Company shall ensure that the third-party waste hauler transforms the cannabis products into cannabis waste by rendering them non-retrievable. “Non-retrievable” means that the cannabis products have been rendered unrecognizable and unusable for all practical purposes. The rendering of the cannabis products into cannabis waste shall be recorded by video camera on site. Following the destruction of any cannabis products, an inventory record shall be generated from the third-party waste hauler with the following information: • The reason the cannabis products were destroyed; • The manner in which the cannabis and cannabis products were destroyed; • The amount of cannabis products destroyed; • The date and time upon which the cannabis products were destroyed; and • Those persons present during the destruction of the cannabis products. Section 3 – Neighborhood Compatibility Plan Page 13 of 19 III.A Disposal of Cannabis Waste Our Company shall use Cannabis Waste Solutions, (“CWS”) a full-service waste management solution, as the third-party waste hauler for the collection and disposal of cannabis waste. All authorized staff will be trained both to use our own internal waste management procedures and to follow CWS’s Standard Operating Procedures included as part of the service agreement. Our Company shall ensure that CWS performs the disposal of cannabis products in the dispensary pursuant to the following operational procedures: • Our Company’s Onsite Managers, along with at least one other personnel authorized to handle cannabis products acting as witness, shall be present prior to the destruction of any cannabis products. • Before the actual destruction of any cannabis products, the general manager and other authorized personnel shall photographically depict the cannabis products as originally packaged. • After photographically depicting the cannabis products as originally packaged, CWS shall transform the cannabis products into a cannabis waste by rendering the cannabis products non-retrievable. • “Cannabis waste” means waste that is not hazardous waste that contains cannabis and that has been made non-retrievable. “Non-retrievable” means that the cannabis and cannabis products have been rendered unrecognizable and unusable for all practical purposes. • The rendering of cannabis and cannabis products into cannabis waste shall be recorded on the video surveillance system. III.B Storage of Cannabis Waste CWS will provide a secured lockable storage bin for all waste earmarked for destruction. The bin is designed to ensure that with proper use, no cross contamination will affect cannabis products available for retail sale. As needed, our Company will arrange secured pick up for cannabis waste. Our Company expects minimal cannabis waste and will arrange a monthly pick up as needed with CWS. The Cannabis Waste bin will be located and kept in the secure storage room, a limited access area that can only be entered by authorized personnel using a security keycard, and a camera will be directly aimed at the bin in order to monitor any possible tampering. IV. Cannabis Product Recall Our Company shall recall any cannabis products sold by our Company if the any of the following are true: (i) The manufacture, distribution, or sale of the cannabis product creates or poses an immediate and serious threat to human life or health and (ii) other procedures available to remedy or prevent the occurrence of the situation would result in an unreasonable delay. Section 3 – Neighborhood Compatibility Plan Page 14 of 19 IV.A Misbranded Cannabis Products Our Company shall consider finished cannabis products “misbranded” if there exists any of the following: (i) Labeling that is false or misleading or (ii) labeling or packaging that does not conform to the requirements of applicable laws set forth by the Department of Public Health Office of Manufactured Cannabis Safety or the local jurisdiction. IV.B Adulterated Cannabis Products Our Company shall consider finished cannabis products “adulterated” if there exists any of the following: • They have been produced, prepared, packed, or held under unsanitary conditions in which they may have become contaminated with filth or in which they may have been rendered injurious; • They consist in whole or in part of any filthy, putrid, or decomposed substance; • They bear or contain any poisonous or deleterious substance that may render them injurious to users under the conditions of use suggested in the labeling or under conditions as are customary or usual; • They bear or contain a substance that is restricted or limited under applicable law and the level of substance in the product exceeds the limits specified in the applicable law; • Their concentrations differ from, or their purity or quality is below, that which they are represented to possess; • The methods, facilities, or controls used for their manufacture, packing, or holding do not conform to, or are not operated or administered in conformity with, practices established by applicable law to ensure that the cannabis products meet the requirements of applicable law as to safety, have the concentrations they purport to have, and meet the quality and purity characteristics that they purport or represent to possess; • Their container is composed, in whole or in part, of any poisonous or deleterious substance that may render the contents injurious to health; or • A substance has been mixed or packed with them after testing by a testing laboratory so as to reduce their quality or concentration or if any substance has been substituted, wholly or in part, for the edible cannabis product. IV.C Recall Procedures In the event of a recall, the Onsite Manager shall initiate and coordinate all recall activities and be the point of contact for the implementation of all recall procedures. The Onsite Manager will also coordinate with upper management, who will reach out to the Bureau of Cannabis Control and any Section 3 – Neighborhood Compatibility Plan Page 15 of 19 other relevant regulatory or law enforcement authorities, if necessary. Upon receiving notification of a product recall, the Onsite Manager will confirm if any of the cannabis product is in their stock or has been sold to a customer. The steps below shall be based on the level of risk. The Onsite Manager shall: • Provide contact details for key personnel to the Bureau of Cannabis Control and any other relevant regulatory or law enforcement authorities; • Formulate a plan on how best to notify the distributor and to halt any further delivery of affected goods; • Ask the distributor if there is a need to reach out to consumers that have, or could have, obtained the cannabis products, including communication and outreach via media, as necessary and appropriate; • If applicable, ensure that the notification of recall from distributors includes the following information: (i) the name, pack size, and adequate description of the product; (ii) identifying features of the products and lots concerned; (iii) the nature of the defect; (iv) actions required, with an indication of the degree of urgency involved; and (v) the name of contact and telephone number of contact who can supply further information; • Ensure the proper treatment of withdrawn or recalled material or product, which should be quarantined, until a decision is made on whether the distributor wants our Company to destroy the cannabis product or return it to the distributor; • Ensure that quantities of the recalled lot of product are reconciled with the total lot quantity in question. Once reconciled, make sure that any products that are to be recalled and sent back to the distributor are documented and reconciled into our Company’s Point-of-Sale system and METRC; • Ensure that any recalled cannabis products not picked up by the distributor be destroyed in accordance with the waste management plan, while recording the following information into the waste management log: (i) name and type of the cannabis goods; (ii) unique identifier of the cannabis goods; (iii) amount of the cannabis goods, by weight or count, and total wholesale cost of the cannabis goods, as applicable; (iv) date and time of the recall; and (v) name and license number of the licensee who requested the recall; and • Finally, work with the distributor to either be provided with new cannabis products similar to those that were recalled, a credit with the distributor for future orders, or a complete refund of the cost of goods sold to our Company. The Onsite Manager will work with the distributor to decide what is the best course of action in this instance. V. Public Education & Awareness Our Company will create a public awareness campaign for responsible cannabis consumption by sponsoring free on and off-site workshops and seminars to the general public on topics related to Section 3 – Neighborhood Compatibility Plan Page 16 of 19 responsible cannabis use as well as legal and policy updates regarding commercial cannabis. By becoming embedded into the fabric of the community, our Company will seek to emerge as a touchstone for reliable information and a trusted partner to the community’s residents. Below is a sample of the types of educational materials our Company intends on disseminating: • Factsheets utilizing photographic examples and written descriptions, charts and graphs that discuss topics pertaining to medical cannabis qualifying conditions and other information relevant to the consumption of cannabis and cannabis infused products. • Management will work with cannabis-knowledgeable medical professionals to compose and update instructional guidance on test dosing; distinguishing by the type and method of medication to be consumed by qualified patients. The instructional guide / educational materials will include directions on how to keep a medical cannabis journal allowing the patient to generate anecdotal evidence on what type and strain works best for their condition. This will be made available to our trained employees in addition to being available on our website. A section of our Company’s age-verified website will be designated for educational purposes maintaining a weekly blog with the latest news regarding health, technology, updates to state and federal laws, links noteworthy scientific articles, and customer testimonials. The website will include a designated portal where visitors are encouraged to leave feedback and ask questions. The main purpose of the “listening corner” is to listen and find ways to be responsive. Our Company will be able to post real time responses to queries and encourage an open dialogue between all participants. VI. Environmental Impact Mitigation Our Company will implement the following sustainable practices into its construction and design plans to minimize any potential negative environmental impacts from its operations: (i) Green energy; (ii) water conservation; (iii) green / sustainable materials; (iv) green waste management; and (v) green / sustainable business practices. Our Company will encourage alternative transportation options to minimize its carbon footprint, including human-powered transportation (i.e., walking or biking), public transit, rideshare options, compressed workweeks, carpools, and green vehicles. Our Company’s employees will be incentivized and encouraged to utilize public transportation or non-automotive transportation to reduce carbon emissions. Furthermore, information regarding public bus routes will be provided to our Company’s employees, and secured bike racks will be installed in the parking area to accommodate cyclists. Our Company will offer reasonable reimbursement for the use of public transportation and incentives for carpooling, including reserved parking spots, and will potentially offer reserved spots for electric vehicles (“EVs”). In so doing, our Company will minimize its “carbon footprint”, while relieving the neighborhood of an additional parking burden. Our Company will utilize best management practices for the responsible usage of electrical services. These practices will include energy efficient light practices, the use of energy-efficient building materials and insulation to minimize drastic temperature changes, and sufficient Section 3 – Neighborhood Compatibility Plan Page 17 of 19 deployment of equipment to ensure that there is no over burdening of the power supply. Natural gas as an alternative heat source is a possibility, which will be determined at the construction phase of the project. Our Company will do its part to help conserve California’s precious water resources. To that end, its building remodel will ensure water conservation through the use of low-flow plumbing fixtures, rainwater collection practices, and drought-resistant landscaping and Best Management Practices (“BMPs”) for water use, as described further below. Our Company will use low-flow, water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with the following non-residential mandatory water efficiency and conservation measures set forth in the California Green Building Standards Code (“Green Building Code”), Chapter 5, Division 5.3. Our Company will also implement the following indoor water conservation BMPs, as appropriate specifically with regard to the dispensary operation: (i) Repairing all water leaks immediately and being especially alert for leaks in toilets, faucets, and irrigation systems for parking lot landscaping (if used) and (ii) capturing the flow for other uses while waiting for running water to warm or cool for use on landscaping or in cleaning. Our Company is committed to using “green” construction procedures and to using recycled materials during construction and in its day-to-day operations whenever feasible. Development and build-out will include reclaimed materials and practices that reduce construction waste. In addition, our Company will use locally sourced materials and low-VOC paints to the extent possible. Our Company’s proposed construction will target waste diversion above the City’s requirements. All remodeling undertaken at the dispensary will seek LEED certification in order to maximize sustainability. During construction, our Company will manage construction with a focus on satisfying the requirements of the City’s Public Works Department. Accordingly, the following protocols will be followed to prevent run-off into storm drains: A. Our Company will fully comply with the storm water management and/or erosion control requirements established by the City’s Municipal Code and its Public Works Department; and B. Our Company will implement an effective combination of erosion and sediment control and good housekeeping BMPs to prevent the loss of soil through wind or water erosion. In the event that our Company reseals or repaves any parking areas following the completion of construction, our Company will work with its neighbors to ensure that any paving is performed in a manner that does not interfere with the operations of any business. The construction plans will ultimately dictate the manner of site grading and drainage system controls that will manage all surface water flows to ensure water does not enter the buildings, but our Company is likely to utilize a combination of the following methods: (i) Swales; (ii) Water collection and disposal systems; (iii) French drains; (iv) Water retention gardens; and/or (v) Other water measures to keep surface water away from buildings and aid in groundwater recharge. In an effort to reduce greenhouse gas (“GHG”) emissions, our Company will fully comply with State requirements mandating commercial recycling in accordance with Assembly Bill 341 and Section 3 – Neighborhood Compatibility Plan Page 18 of 19 Senate Bill 1018. Since our Company anticipates that seventy-five percent (75%) of all dispensary waste will be recyclable, it will initially maintain a 95-gallon blue recycling cart on site and request larger or additional bins from the City as demand requires. Our Company will post a list of recyclable products near each waste bin to encourage its employees to implement BMPs and comply with our Company’s zero-waste policy. A co-benefit of increased recycling is reduced methane emissions at landfills from the decomposition of organic materials. Use of composted organic materials also provides environmental benefits such as carbon storage in soils and reduced use of fertilizers, pesticides, and water. The Mandatory Commercial Recycling Measure focuses on increased commercial waste diversion as a method to reduce GHG emissions. As part of its mission to ensure green business practices throughout its dispensary operations, our Company will have a strong preference towards working with and obtaining cannabis products from “Clean Green Certified” cannabis producers to the extent possible. The Clean Green Certified program, modeled after the USDA’s National Organic Program, provides a means of ensuring environmentally clean and sustainable practices within the cannabis industry. Section 3 – Neighborhood Compatibility Plan Page 19 of 19 VII. Odor Detection Form TRADITIONAL - FRESNO - ME LLC ATTN: ARTHUR REYNA, ATTORNEY AT LAW PHONE: ( | EMAIL: AR@ARTHURREYNALAW.COM Page 1 of 3 Location Plan for Traditional - Fresno - ME LLC Introduction & Executive Summary Traditional - Fresno - ME LLC (our “Company”), through its Owners / Members and officers has an unmatched track record of successful and timely development, establishment, and operation of cannabis businesses—in particular cannabis retail businesses—throughout the State of California. Our Company’s Owners / Members are a team of experienced professionals and stalwarts of the cannabis industry that include: (i) the owner and operator of one of the largest and most successful cannabis business portfolios in California and the U.S. with an established dedication and investment in social equity cannabis businesses and (ii) a young Latina that overcame growing up one of the most heavily impacted communities by the War on Drugs to graduate from college and go on to be a Majority Owner of a social equity retail cannabis business in the City of Los Angeles. Through its Owners / Members and officers, our Company will bring the Traditional brand to the City of Fresno (“Fresno” or the “City”) and operate an all-inclusive, elevated cannabis retail business that is custom-tailored and completely integrative and symbiotic with the local neighborhood. I. Location Planning Consistent with our neighborhood integration business model, our Company takes the position that location planning starts with site selection. On that note, our Company’s Owners / Members are experienced real estate developers and owners and operators of active cannabis retail businesses with outstanding reputations in their local community. With that in mind, our Company’s proposed location at 6926 N. Weber Avenue, Fresno, CA 93722, is located specifically to develop a cannabis retail business in the Bullard Neighborhood of Fresno to continue revitalization of the area and further commercial revitalization of the area of northeastern Bullard directly adjacent to Highway 99 and N. Golden State Boulevard. II. Location Information II.A Location Analysis As demonstrated by the comprehensive Location Plan Set attached here as Appendix A, 6926 N. Weber Avenue is a commercial building located in a section of the Bullard Neighborhood on Weber Avenue northeast of N. Golden State Boulevard and northwest of W. Herndon Avenue. 6926 N. Weber Avenue is located in the City’s CH (Commercial - Highway and Auto) zoning district and is not located within the 800-foot radius of any sensitives uses such as schools, Section 6 – Location Plan Page 2 of 3 daycares, or youth centers. 6926 N. Weber Avenue is surrounded by other commercial businesses that serve the area of northeastern Bullard directly adjacent to Highway 99 and N. Golden State Boulevard. The commercial areas immediately southwest of N. Golden State Boulevard and southeast of W. Herndon Avenue have been developed with modern, complimentary commercial establishments such as Starbucks, Panera Bread, Hampton Inn, and Target, our Company’s development of 6926 N. Weber Avenue as a Traditional-branded cannabis retail business will continue this trend. Overall and as further demonstrated by the comprehensive Location Plan Set attached here as Appendix A, our Company’s cannabis retail business is totally complimentary to the commercial areas in the area of northeastern Bullard directly adjacent to Highway 99 and N. Golden State Boulevard, and our Company’s development of 6926 N. Weber Avenue as a Traditional-branded cannabis retail business will be a centerpiece for the continued commercial development of the area. II.B Design Concept As demonstrated by the comprehensive Location Plan Set attached here as Appendix A, our Company’s cannabis retail business at 6926 N. Weber Avenue shall meet the following design guidelines: (1) Demonstrate compatibility with the surrounding character of the neighborhood and blend in with existing buildings; our cannabis retail business will look like any other similarly situated building; (2) comply with all applicable zoning and related development standards including, but not limited to, parking, lighting, materials, and colors; and (3) signage, as described in Section 9-3309(h) of the Fresno Municipal Code, shall be limited to that needed for identification only and shall not contain any logos or information that identifies, advertises, or lists the services or the products offered. II.C Environmental Review As demonstrated by the comprehensive Location Plan Set attached here as Appendix A, our Company’s proposed cannabis retail business at 6926 N. Weber Avenue will comply with the with the requirements of the California Environmental Quality Act (“CEQA”) and the CEQA Guidelines because: Our Company’s cannabis retail business is required to meet all local, state, and federal health and safety regulations to ensure that that there are no significant environmental impacts to the cannabis retail business and surrounding properties. Moreover, cannabis retail business is similar to already existing permitted general uses on the property such as “General Market” and “Convenience Retail”, with the difference being the product sold. More still, our Company’s cannabis retail business will be designed and operated to integrate and be compatible with the local community and with a plan to directly mitigate environmental impacts as demonstrated by the comprehensive Location Plan Set attached here as Appendix A. Section 6 – Location Plan Appendix A – Location Plan Set for 6926 N. Weber Avenue, Fresno, CA 93705 [Page intentionally left blank] Street View of the Front of the Building TRADITIONAL - FRESNO - ME LLC ATTN: ARTHUR REYNA, ATTORNEY AT LAW PHONE: (| EMAIL: AR@ARTHURREYNALAW.COM Page 1 of 10 Community Benefits & Investments Plan for Traditional - Fresno - ME LLC Introduction & Executive Summary Traditional - Fresno - ME LLC (our “Company”), through its Owners / Members and officers has an unmatched track record of successful and timely development, establishment, and operation of cannabis businesses—in particular cannabis retail businesses—throughout the State of California. Our Company’s Owners / Members are a team of experienced professionals and stalwarts of the cannabis industry that include: (i) the owner and operator of one of the largest and most successful cannabis business portfolios in California and the U.S. with an established dedication and investment in social equity cannabis businesses and (ii) a young Latina that overcame growing up one of the most heavily impacted communities by the War on Drugs to graduate from college and go on to be a Majority Owner of a social equity retail cannabis business in the City of Los Angeles. Through its Owners / Members and officers, our Company will bring the Traditional brand to the City of Fresno (“Fresno” or the “City”) and operate an all-inclusive, elevated cannabis retail business that is custom-tailored and completely integrative and symbiotic with the local neighborhood. Accordingly, our Company has prepared this Community Benefits & Investments Plan to establish a process by which the local community, including its residents and businesses, can express themselves regarding our operations; to inform the community about cannabis education, issues and developments; and to ensure that our corporate actions genuinely reflect the community’s needs. I. Community Reinvestment As demonstrated, by the pro formas accompanying this Application, our Company estimates that its operation of its cannabis retail business will result in $ in Measure A taxes by the end of 2024. Moreover and consistent with our “Weed for the People” motto and business model and in support on the Social Policies & Local Enterprise Plan articulated below, our Company will commit via a Community Benefits Agreement to donate the equivalent of 3% of “gross receipts” to local community organizations / nonprofits in Fresno and/or the Fresno Community Reinvestment Fund with the specific allocation of funds to be determined by our Company by working with the City and local community organizations / nonprofits in Fresno—over and above Measure A cannabis business taxes! As further demonstrated, by the pro formas accompanying this application, our Company estimates that its additional 3% contribution will result in an additional in public revenue by the end of 2024—bringing our Company’s estimated direct monetary contribution to the City and its residents to over by the end of 2024. Section 7 – Community Benefits & Investments Plan Page 2 of 7 II. Appointment of a Community Liaison Our Company shall appoint a Community Liaison (hereinafter, the “Liaison”) to educate and actively engage with the community and be the original point of contact for any concerns that may arise from the community. Our Liaison will be responsible for the day-to-day management of our Community Benefits & Investments Plan, working with management on putting together the program’s operational budget and establishing a system for tracking and reporting on its performance. Our Liaison’s contact information shall be made readily available both via the Company’s website and shall be on file with the City. Further, our Company shall provide the Liaison’s information to its business and residential neighbors located within 1,000 feet of our cannabis retail business, or greater distance if required by the City. Further, our Company will establish a permanent 24/7 community hotline that will be available to residents so that it can promptly address any issues identified by our neighbors. Furthermore, our Company will actively engage future neighbors to assess their awareness of the project as well as the needs of the community and will canvass all residents and businesses within 1,000 feet of the cannabis retail business with a survey. Amongst other things, our Liaison will participate in an ongoing dialogue with the City and County law enforcement to ensure that there are no instances of concern and to develop an anti-abuse campaign. Local police and fire personnel will be invited to our cannabis retail business for regular updates and tours to ensure that our storefront retailer is not vulnerable to break-in and community residents are secure. Our Liaison shall assist our Company with outreach efforts through follow-up correspondence to community stakeholders, informing them that the Company and its management have received their concerns and informing them of what procedures or programs we plan to employ and develop in response to the concerns raised. II.A Interested Parties Quarterly Meeting & Advisory Board Our Liaison will host quarterly open houses at our cannabis retail business to adults over the age of 21 to engage the community, provide transparency about our operations, and receive continuous feedback so we can better serve the local community. The open house event will give community members an opportunity to discuss costs, benefits, and other community issues related to commercial cannabis and our Company’s cannabis retail business. These quarterly meetings will allow the community to express any grievances they feel that may impact the cost of the nearby community from a financial standpoint, while giving our Company the opportunity to discuss the benefits our Company’s cannabis retail business will bring, both from a monetary standpoint and being a role model as a pillar of safety for the community. Our open houses will also be an open forum to discuss any potential issues that the community feels could be an issue to the community and how our Company can work to resolve these issues and improve upon anything that is requested by the community. Members of the community, local business owners, law enforcement, city officials, and other interested parties will be invited to attend the quarterly meetings. In particular, our Company recognizes that Fresno is home to many admirable public services and charitable organizations and plans to align with these services and organizations accordingly. In addition to the quarterly meetings, our Liaison will create an advisory board consisting of reputable members of the local community and cannabis industry to advise our Company and ensure that our Company has continued input from the community and leaders within the industry, Section 7 – Community Benefits & Investments Plan Page 3 of 7 as well as expert knowledge of the ever growing and evolving cannabis field. With the establishment of the advisory board, our Company will use the quarterly meetings to discuss areas of improvement within the community and ways we can help, whether it is in the form of monetary donations or volunteer efforts from our employees. II.B Engagement with Local Nonprofits and Community Organizations Engagement with local nonprofits and community organizations is a critical component of our Company’s Community Benefits & Investments Plan. Accordingly, our Company has already begun the process of identifying numerous meritorious local nonprofits and community organizations such as UFCW Local 8, Fresno United, the Central Cal Baseball Academy, and the State Center Community College District for engagement and participation in our Community Benefits & Investments Plan. III. Local Hiring and Social Equity Community Commitments III.A Living Wage Our Company is committed to providing a living wage to employees and will ensure our wages are in compliance with the current minimum wage as adopted by the State. Our Company uses the following benchmark for the definition of “living wage”: 200% of the Federal Poverty Level for a family of two. The current Federal Poverty Level for a family of two is $17,240.00. Using these benchmarks (which are just the bare minimum), our Company’s definition of “living wage” is at least per year for full-time employees and (ii) per hour for part-time employees and independent contractors. This is above the current minimum wage as adopted by the State of $12.00 per hour. III.B Local & Social Equity Hiring Policy As stated above, our Company’s policy will be to hire employees who live close to our cannabis retail business from the City of Fresno and from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code. In an effort to support our policy initiative, we will also seek to utilize professional services from within the local area to stimulate all sectors of business from physical construction to professional services such as accountants, bookkeepers, and web developers. Accordingly, our Company will commit via a Community Benefits Agreement to having (i) at least 50% of all our employees reside in Fresno and at least 50% employee personnel hours are from employees residing in Fresno AND (ii) at least 50% of all our employees are from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code and at least 50% employee personnel hours are from employees from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code. Our Company will take an all-inclusive approach to hiring and prioritize adults over the age of 21 from Fresno with social equity backgrounds. For our Company, this is a two-fold process. First, residents of Fresno with social equity backgrounds must be actively targeted with job offers and postings. For our Company this means, rather than using traditional job-posting media such Indeed, Craigslist, or other mainstream Internet websites, going directly to local publications targeted / catered towards Fresno residents. On that note, our Company will look to post flyers outside of the company’s Section 7 – Community Benefits & Investments Plan Page 4 of 7 proposed cannabis retail business a few months prior to opening with a link to all job postings and availabilities for the cannabis retail business in order to help with hiring local residents. Most importantly and well-beyond passive publications, our Company will look to establish deep ties with local nonprofits and public service organizations. Often times, local nonprofits and public service organizations missions are geared towards helping the members of the local community that our Company seeks to hire as employees. Relatedly, Fresno has a robust educational base for sourcing / recruiting employees with the presence of Fresno State University, Fresno City College, and Clovis Community College. With that point in mind, our Company has already begun engaging with the State Center Community College District on community engagement and hiring initiatives. The second element of our Company’s hiring program involves the interview process, with that point in mind, and recognizing that job interviewing is a specific skill, our Company will work with its community engagement partners to provide interview training to Fresno residents from social equity backgrounds before interviewing with our Company. To show the good faith effort to hiring 50% of employees from the City of Fresno with social equity backgrounds, our Company will document the following: (i) Records of emails reaching out to community members and organizations; (ii) printed job flyers and list of addresses where flyers were posted and dropped off; (iii) links to localized online job postings; and (vi) proof of attending any local job fairs. In addition, our Company will keep track of job applications that were submitted to our Company and a list of all candidates that were interviewed by our Company where we will have copies showing their home address indicating if they are residents of Fresno. As for verifying social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code, the presents additional challenges for our Company, as certain qualifications for social equity status under Section 9-3316(b)(1) of the Fresno Municipal Code (for example, “Former foster home youth who was in foster care as a minor” and “receiving public assistance”) are inappropriate, or arguably unlawful, inquiries during the interview process. As a result, our Company will employ legal counsel specialized in employment law to develop solutions for acquiring and retaining verification documentation of social equity status as defined in Section 9- 3316(b)(1) of the Fresno Municipal Code in a way that provides all potential social equity backgrounds an equal opportunity in our Company’s hiring process. One such solution that our Company is considering to this legal / human resources obstacle is to partner with the City or local community organizations to have the City or local community organizations do the vetting of social equity status under Section 9-3316(b)(1) of the Fresno Municipal Code (who may not have the same legal obstacles as our Company) and then forward vetted candidates to our Company for interviews. If after our Company reaches out to various resources in order to hire local, social equity candidates, our Company is unable to meet its goals of 50% of employees personnel hours from Fresno residents from social equity backgrounds, our Company will attempt to coordinate with the City and other approved cannabis businesses in City to host a local “Cannabis Job Fair”. If after hosting its own “Cannabis Job Fair”, our Company is still unable to meet local and social equity hiring goals, we will then look to use more traditional job platforms such as Indeed and ZipRecruiter to hire the remaining employees needed to properly staff the cannabis retail business, and our Company will collaborate with the City to determine other ways to divert additional community benefits to the City of Fresno and its residents, such as increased public benefits via its Community Benefits Agreement. Section 7 – Community Benefits & Investments Plan Page 5 of 7 III.C Expungement Clinics Our Company is committed to helping individuals from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code overcome obstacles to employment regardless of whether such individuals end up working for our Company. One such obstacle is criminal records. Our Company will host expungement fairs for individuals from social equity backgrounds as defined in Section 9-3316(b)(1) of the Fresno Municipal Code and others with community partners. III.D Social Equity Incubator / Apprenticeship Program Our Company will commit via a Community Benefits Agreement to serve as a Social Equity Business Incubator by offering support to local cannabis social equity businesses in the form of mentorship, training, equipment donation, a percentage of shelf space dedicated to Fresno equity business products, legal assistance, financial services assistance, and/or other technical assistance support. Appreciating that it is paramount to address the negative consequences of the War on Drugs, our Company believes that individuals negatively impacted by the War on Drugs should have resources available to assist them in participating in the cannabis industry. Accordingly, our Company’s Owners / Members have a long history of embracing cannabis Social Equity Programs throughout the State and through their existing cannabis retail business operations. To illustrate, Minority Owner / Member & Retailer Manager, Aaron Mamann, is an Owner / Member of three Social Equity cannabis businesses in the City of Los Angeles and Majority Owner / Member, Maritza Estrada, is an Owner / Member of one Social Equity cannabis retail business approved applicant in the City of Los Angeles. IV. Public Education & Awareness Our Company will create a public awareness campaign for responsible cannabis consumption by sponsoring free on and off-site workshops and seminars to the general public on topics related to responsible cannabis use as well as legal and policy updates regarding commercial cannabis. By becoming embedded into the fabric of the community, our Company will seek to emerge as a touchstone for reliable information and a trusted partner to the community’s residents. Below is a sample of the types of educational materials our Company intends on disseminating: • Factsheets utilizing photographic examples and written descriptions, charts and graphs that discuss topics pertaining to medical cannabis qualifying conditions and other information relevant to the consumption of cannabis and cannabis infused products. • Management will work with cannabis-knowledgeable medical professionals to compose and update instructional guidance on test dosing; distinguishing by the type and method of medication to be consumed by qualified patients. The instructional guide / educational materials will include directions on how to keep a medical cannabis journal allowing the patient to generate anecdotal evidence on what type and strain works best for their condition. This will be made available to our trained employees in addition to being available on our website. Section 7 – Community Benefits & Investments Plan Page 6 of 7 A section of our Company’s age-verified website will be designated for educational purposes maintaining a weekly blog with the latest news regarding health, technology, updates to state and federal laws, links noteworthy scientific articles, and customer testimonials. The website will include a designated portal where visitors are encouraged to leave feedback and ask questions. The main purpose of the “listening corner” is to listen and find ways to be responsive. Our Company will be able to post real time responses to queries and encourage an open dialogue between all participants. V. Brownfields and Abandoned Buildings / Environmental Sustainability Our Company will implement the following sustainable practices into its construction and design plans to minimize any potential negative environmental impacts from its operations: (i) green energy; (ii) water conservation; (iii) green / sustainable materials; (iv) green waste management; and (v) green / sustainable business practices. Our Company will encourage alternative transportation options to minimize its carbon footprint, including human-powered transportation (i.e., walking or biking), public transit, rideshare options, compressed workweeks, carpools, and green vehicles. Our Company’s employees will be incentivized and encouraged to utilize public transportation or non-automotive transportation to reduce carbon emissions. Furthermore, information regarding public bus routes will be provided to our Company’s employees, and secured bike racks will be installed in the parking area to accommodate cyclists. Our Company will offer reasonable reimbursement for the use of public transportation and incentives for carpooling, including reserved parking spots, and will potentially offer reserved spots for electric vehicles (“EVs”). In so doing, our Company will minimize its “carbon footprint”, while relieving the neighborhood of an additional parking burden. Our Company will utilize best management practices for the responsible usage of electrical services. These practices will include energy efficient light practices, the use of energy-efficient building materials and insulation to minimize drastic temperature changes, and sufficient deployment of equipment to ensure that there is no over burdening of the power supply. Natural gas as an alternative heat source is a possibility, which will be determined at the construction phase of the project. Our Company will do its part to help conserve California’s precious water resources. To that end, its building remodel will ensure water conservation through the use of low- flow plumbing fixtures, rainwater collection practices, and drought-resistant landscaping and Best Management Practices (“BMPs”) for water use, as described further below. Our Company will use low-flow, water conserving plumbing fixtures and fittings. Plumbing fixtures (water closets and urinals) and fittings (faucets and showerheads) shall comply with the following non-residential mandatory water efficiency and conservation measures set forth in the California Green Building Standards Code (“Green Building Code”), Chapter 5, Division 5.3. Our Company will also implement the following indoor water conservation BMPs, as appropriate specifically with regard to the cannabis retail business operation: (i) repairing all water leaks immediately and being especially alert for leaks in toilets, faucets, and irrigation systems for parking lot landscaping (if used) and (ii) capturing the flow for other uses while waiting for running water to warm or cool for use on landscaping or in cleaning. Section 7 – Community Benefits & Investments Plan Page 7 of 7 Our Company is committed to using “green” construction procedures and to using recycled materials during construction and in its day-to-day operations whenever feasible. Development and build-out will include reclaimed materials and practices that reduce construction waste. In addition, our Company will use locally sourced materials and low-VOC paints to the extent possible. Our Company’s proposed construction will target waste diversion above the City’s requirements. All remodeling undertaken at the cannabis retail business will seek LEED certification in order to maximize sustainability. During construction, our Company will manage construction with a focus on satisfying the requirements of the City’s Public Works Department. In an effort to reduce greenhouse gas (“GHG”) emissions, our Company will fully comply with State requirements mandating commercial recycling in accordance with Assembly Bill 341 and Senate Bill 1018. Since our Company anticipates that seventy-five percent (75%) of all cannabis retail business waste will be recyclable, it will initially maintain a 95-gallon blue recycling cart on site and request larger or additional bins from the City as demand requires. Our Company will post a list of recyclable products near each waste bin to encourage its employees to implement BMPs and comply with our Company’s zero-waste policy. A co-benefit of increased recycling is reduced methane emissions at landfills from the decomposition of organic materials. Use of composted organic materials also provides environmental benefits such as carbon storage in soils and reduced use of fertilizers, pesticides, and water. The Mandatory Commercial Recycling Measure focuses on increased commercial waste diversion as a method to reduce GHG emissions. As part of its mission to ensure green business practices throughout its cannabis retail business operations, our Company will have a strong preference towards working with and obtaining cannabis products from “Clean Green Certified” cannabis producers to the extent possible. The Clean Green Certified program, modeled after the USDA’s National Organic Program, provides a means of ensuring environmentally clean and sustainable practices within the cannabis industry. TRADITIONAL - FRESNO - ME LLC ATTN: ARTHUR REYNA, ATTORNEY AT LAW | EMAIL: AR@ARTHURREYNALAW.COM Page 1 of 3 January 28, 2021 City of Fresno Office of the City Manager 2600 Fresno Street Fresno, CA 93721 Phone: (559) 621-5555 Email: cannabis.regs@fresno.gov RE: Proof of Capitalization for Traditional - Fresno - ME LLC To whom it may concern: My name is Traditional - Fresno - ME LLC. I am the Minority Owner / Member Traditional - Fresno - ME LLC (“Traditional - Fresno - ME”). Based on numerous years of experience in the cannabis industry, unmatched business and cannabis expertise, and multiple successful developments of actually operational cannabis retail businesses, Traditional - Fresno - ME assembled the following start-up budget: Please see Traditional - Fresno - ME’s Business Plan for further reference and explanation. DocuSign Envelope ID: 2F0B8961-14AA-4DE4-A4F4-1DB43D75BBCD Page 2 of 2 The purpose of this letter is to provide proof of financial resources for Traditional - Fresno - ME demonstrating access to funds in excess of the above start-up budget. Pursuant to the attached screenshot of my own personal bank account with Salal Credit Union, I have over $6,500,000.00 in cash in bank as of the date of this letter, with which as an Owner / Member of Traditional - Fresno - ME, I will directly capitalize Traditional - Fresno - ME. All told, Traditional - Fresno - ME has direct access to over 0 in liquid assets, which is well in excess of Traditional - Fresno - ME’s start-up budget of . Respectfully submitted, ___________________________________ Aaron Mamann, Minority Owner / Member Traditional - Fresno - ME LLC Enclosures: 1. Screenshot of Bank Account of Aaron Mamann with Salal Credit Union on January 28, 2021 DocuSign Envelope ID: 2F0B8961-14AA-4DE4-A4F4-1DB43D75BBCD ASSIGNMENT OF REAL ESTATE PURCHASE AGREEMENT This Agreement is made as of the 28th day of January 2021 (the “Effective Date”), by and between EEL HOLDING LLC (“Assignor”), and Traditional - Fresno - ME LLC (“Assignee”). RECITALS A. Assignor as Buyer entered into that certain Commercial Property Purchase Agreement and Joint Escrow Instructions, a copy of which is attached hereto as Exhibit A, with John Garabedian, an individual, and Melanie Garabedian, an individual (collectively, “Seller”), in which Seller agreed to sell to Buyer certain real properties located at 6926 N. Weber Avenue, Fresno, CA 93722 (the “Purchase Agreement”); and B. Assignor desires to assign its rights and interest to said contract and Assignee desires to purchase such rights and interests pursuant to the terms of this agreement. NOW, THEREFORE, the parties agree as follows: 1. Assignor hereby assigns to Assignee all of Assignor’s rights and obligations under the Purchase Agreement. Assignee hereby accepts such assignment and agrees to abide by all of the obligations of “Buyer” under the Purchase Agreement. ASSIGNOR: EEL HOLDINGS LLC __________________________________________ By: Elliot Lewis, Managing Member ASSIGNEE: Traditional - Fresno - ME LLC __________________________________________ By: Maritza Estrada, Majority Member __________________________________________ By: Aaron Mamann, Minority Member DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 EXHIBIT A – COMMERCIAL PROPERTY PURCHASE AGREEMENT AND JOINT ESCROW INSTRUCTIONS [Page Intentionally Left Blank] DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 DocuSign Envelope ID: 42D1FDD6-859C-4A57-B76E-5C40E94C9EF4 PLANNING AND DEVELOPMENT DEPARTMENT 2600 Fresno Street • Third Floor Jennifer K. Clark, AICP, Director Fresno, California 93721-3604 (559) 621-8277 FAX (559) 498-1026 February 5, 2021 Please reply to: Rob Holt (559) 621-8056 Maritza Estrada Traditional – Fresno – ME LLC Dear Applicant: SUBJECT: ZONING INQUIRY NUMBER P21-00566 REQUESTING INFORMATION REGARDING CANNABIS RETAIL FOR PROPERTY LOCATED AT 6926 NORTH WEBER AVENUE (APN 504-102-17) Thank you for your inquiry regarding the allowance of new cannabis retail uses. The requested information about cannabis retail uses was analyzed using Article 27, Chapter 15 of the Fresno Municipal Code (FMC) of the City of Fresno. Please note, all research for this inquiry is based on existing land development of the subject property. If there are multiple buildings on the subject property, this research was based on the address provided in the request. This research does not take into effect of future development unless provided in your application request. With that, research of a proposed cannabis retail business on the subject property conveys the following: 1. All cannabis retail businesses must be located on property zoned DTN (Downtown Neighborhood), DTG (Downtown General), CMS (Commercial Main Street), CC (Commercial Community), CR (Commercial Regional), CG (Commercial General), CH (Commercial Highway), NMX (Neighborhood Mixed-Use), CMX (Corridor/Center Mixed- Use), RMX (Regional Mixed-Use), and must meet all of the requirements for development in these zones, including, but not limited to, parking, lighting, building materials, etc. The subject property is zoned CH, which is one of the allowable zone districts for cannabis retail businesses. Development standards of the CH zone district are available in Sections 15-1203, 15-1204, and 15-1205 of the FMC. The subject location meets the zone district requirement, per Section 15-2739.B.1.a of the FMC, for a cannabis retail business. 2. All building(s) in which a cannabis retail business is located shall be no closer than 800 feet from any property boundary containing the following: (1) A cannabis retail business; (2) A school providing instruction for any grades pre-school through 12 (whether public, private, or charter, including pre-school, transitional kindergarten, and K-12); (3) A day care center licensed by the state Department of Social Services that is in existence at the time a complete commercial cannabis business permit application is submitted; and, (4) A youth center that is in existence at the time a complete commercial cannabis business permit is submitted. Zoning Inquiry P21-00566 6926 North Weber Avenue Page 2 February 5, 2021 The subject property is not located within 800 feet of the property boundary of any of the above-mentioned uses. The subject building meets the separation requirements, per Section 15-2739.B.1.b of the FMC, for a cannabis retail business. 3. Prior to commencing operations, a cannabis retail business must obtain a Cannabis Conditional Use Permit from the Planning and Development Department per Section 15- 2739.N of the FMC. 4. No more than 2 cannabis retail businesses may be located in any one Council District. If more than 14 are ever authorized by Council (more than 2 per Council District), they shall be dispersed evenly by Council District. The subject property is in Council District 2. There are currently no cannabis retail businesses located in Council District 2. This location requirement is satisfied for a cannabis retail business. Please review the entirety of Article 33, Chapter 9 (Cannabis Retail Business and Commercial Cannabis), and Section 15-2739 (Adult Use and Medicinal Cannabis Retail Business and Commercial Cannabis Business) of the FMC to understand other requirements of cannabis retail businesses, including but not limited to, application requirements, signage, etc. This information was researched by the undersigned per the zoning request. The undersigned certifies that the above information contained herein is believed to be accurate and is based upon, or relates to, the information supplied by the requestor. The City of Fresno assumes no liability for errors and omissions. All information was obtained from public records held by the Planning and Development Department. A copy of the Fresno Municipal Code may be obtained by contacting the City Clerk’s office at 559-621-7650. The Fresno Municipal Code may also be searched on the Internet, free of charge, by going to www.fresno.gov. If you have questions regarding this matter, please contact me by telephone at 559-621-8056 or at Robert.Holt@fresno.gov. Cordially, Rob Holt, Planner III Development Services Division Planning and Development Department 1 From:No Reply <noreply@fresno.gov> Sent:Thursday, January 28, 2021 2:25 PM To:maritza.estrada@southcordholdings.com Subject:Your City of Fresno Zoning Inquiry Application was successfully submitted. Dear Applicant,  Your planning application P21‐00566 was successfully submitted.  OWNERSHIP ACKNOWLEDGEMENT FORM FOR COMMERCIAL CANNABIS BUSINESS PERMIT APPLICATION It is the intent of the City of Fresno to promote equitable ownership and employment opportunities in the cannabis industry to decrease the disparities in life outcomes for marginalized communities and to provide opportunities for local residents to compete for cannabis business permits. Therefore, this notice is to clarify the eligibility requirements in order to receive qualification as a Social Equity Applicant or points for Local Preference by establishing this acknowledgement to provide additional protections to mitigate against potential predatory practices. In order to qualify as a social equity applicant, or for the full points relating to the local preference criteria, the business entity must have ownership that meets the respective eligibility factors and hold at least 51% ownership interest. The social equity eligibility requirements are identified in FMC section 9-3316(b)(6), while the local preference criteria is identified in FMC 9- 3317(a) and the application evaluation criteria 2.5 (Appendix A). This majority interest can be made up of a single individual that meets this criteria, or any combination of individuals that hold at least 20% interest individually and meet the definition of an owner in FMC 9-3304(j). The cannabis social equity permits, and the local preference criteria are intended for the benefit of the Social Equity or Local Preference Individual Applicants related to business profits, proceeds of the sale of business assets, voting rights and additional protections. This also requires the Social Equity or Local Preference Owner to receive the Equity Share percent of the retained earnings and 100 percent of the unencumbered value of each share of stock, member interest or partnership interest owned in the event of the dissolution of the entity to their equity share, or 100 percent of the value of each of stock, member interest or partnership interest in the event that the stock, member interest or partnership interest is sold. Chief among the concepts of equity share, is unconditional ownership which means such individual(s) will receive equal profits, and distributions or other payments proportionate to their ownership interests. This is intended to ensure true ownership by the Social Equity or Local Preference Individual Applicant and as such, prohibits the divestment or relinquishment of any part of their ownership under any circumstance. In addition, the Equity Share is also expanded to address voting rights on fundamental decisions relating to the business and control of at least the equity share percent of the voting rights on all decisions involving the operation of the business. Furthermore, it requires the Social Equity or Local Preference Individual owner be the highest officer position of the business or that another individual is appointed to that position by mutual agreement of the parties. This requirement is also subject to being audited to assess compliance and the Social Equity or Local Preference Owner can initiate legal action due to a breach of contract agreement, and the City may suspend and/or revoke a license if any provision in an operating agreement violates any of the Equity Share or Local Preference requirements. Lastly, all applicants will be required to incorporate an addendum into their operating agreements that makes any provision ineffective, unenforceable, null and void, if it is inconsistent with, or in violation of, the Equity Share requirements. As proposed, Social Equity Applicants or Local Preference Applicants will be required to verify under Section 9-3316(b)(6), 9-3317(a), and Criteria 2.5 of appendix A that they meet the definition of a Social Equity or Local Preference Owner at the time of applying for a permit or permit renewal. The City shall have the sole and absolute discretion to determine whether the Applicant qualifies as a Social Equity Applicant and the number of points for Local Preference. The undersigned acknowledges that he/she has read and fully understands the content of this Agreement and is the Applicant or his/her/its authorized signatory. __________________________________________________ __________________________________________________ Applicant Signature Date Signed __________________________________________________ __________________________________________________ Print Name Title __________________________________________________ _ Company Name Address/Telephone DocuSign Envelope ID: 5C8A431C-5605-4EA8-94B9-4C937935574D Majority Member November 13, 2020 Maritza Estrada Traditional - Fresno - ME LLC