HomeMy WebLinkAboutCSE-20-59 Viola Fresno RedactedApplication Type
Social Equity Criteria
Applicant (Entity) Information
Social Equity Cannabis Business
Permit Application
CSE-20-59
Submitted On: Nov 13, 2020
Applicant
Jamil Taylor
jamil@violabrands.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: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
Supporting Information
Applicant (Entity) Name:
VCA-Ops, Inc.
DBA:
Viola Fresno
Physical Address:
420 W. Hurron St., #224
City:
Chicago
State:
IL
Zip Code:
60654
Primary Contact Same as Above?
Yes
Primary Contact Name:
Jamil Taylor
Primary Contact Title:
Director of Operations
Primary Contact Phone:
2404182120
Primary Contact Email:
jamil@violabrands.com
HAS ANY INDIVIDUAL IN THIS APPLICATION APPLIED FOR
ANY OTHER CANNABIS PERMIT IN THE CITY OF FRESNO?:
No
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:
Corporation
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:
--
List all fictitious business names the applicant is operating under including the address where each business is located:
--
Application Certification
Owner Information
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:
Village is the largest 100% black owned cannabis company. Our owners are involved in cultivating, processing and dispensing high
quality cannabis in six states. Members of our Fresno team have pending cannabis applications in Illinois, New Jersey and Virginia.
Our applications in other states (jurisdictions) will not interfere with our Fresno opportunity. We are excited to assist and partner with
Mr. Delanno Hopkins, a long time Fresno citizen, an advocate of social equality and a qualified social equity resident.
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
Director of Operations
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:
Daniel Pettigrew
Owner Title:
COO
Owner Address:
3432 Blake St., #203
Owner City:
Denver
Owner State:
CO
Owner Zip:
80205
Business Name: Viola Fresno SOCIAL EQUITY APPLICANT - IF SUBMISSION REQUIREMENTS MET, APPLICATION PASSES
Application #: CSE-20-59 ADVANCEMENT IS NOT BASED ON PHASE II SCORE PER APPLICATION PROCEDURES.
CANNABIS BUSINESS PERMIT APPLICATION REVIEW - RETAIL Points
Possible
All or
None Exceptional Good Acceptable
Applicant
Score
Evaluation Notes (Explain each time points are
deducted)
SECTION 1: BUSINESS PLAN 300 Points Possible for Section 1
Resume:
Resumes Provided for All Owners: Score 5 5 5
Resumes Provided in 2-page Format: Score 2 2 2
Education: (select highest academic level among ownership team, cannabis specific education
separately)
Cannabis specific education/training (accredited)2 2
High School Degree Reported: Score 4 4
Bachelor's Degree Reported: Score 6 6 6
Master's Degree or Higher Reported: Score 8 8
Experience: (among ownership team, select one at highest level)
Regulated Cannabis Retail Ownership Experience CA 13 13 13
Regulated Cannabis Retail Experience CA (management level or below): Score 10 10
Other Retail Business Experience Reported, More than 5 years: or 8 8
Other Retail Business Experience Reported, Less than 5 Years: Score 5 5
1.1 Sub-Total:30 26
Construction Cost Estimate:
Construction Cost Estimate Provided: Score
8 8 6 4 6
Has construction budget and some explanation
but needs more detailed breakdown
Construction Contingency Factor Included: Score 6 6 6
All Labor, Trades, Materials, Supplies and Permits and other Cost Factors Identified: Score
6 6 4 2 4
Includes permit & architect fees but needs more
info on various construction fees such as material
costs
Reference Data Provided for Unit Cost Factors: Score 5 5 3 1 3 Some reference data included in explanation
Operation and Maintenance Cost Estimates:
Operation and Maintenance Cost Estimate Provided: Score 8 8 6 4 4 Very brief, needs more detail
All Labor, Trades, Materials, Supplies, Utilities, and other Cost Factors Identified: Score 6 6 4 2 2 Very brief, needs more detail
Annual Cost Escalators for Operating Costs Provided: Score
6 6 4 2 2
Some escalating costs shown but not identified
or explained
Reference Data Provided for Unit Cost Factors: Score 5 5 3 1 0 Not included
1.2 Sub-Total:50 27
1.1 Owner qualifications. Resumes are not to exceed two (2) pages per owner. (30 points possible)
1.2 A budget for construction, operation, and maintenance, compensation of employees, equipment costs, utility cost, and other operation costs.(50 points possible)
Criteria Narrative:
Criteria Narrative:
Proof of Capitalization Specific to one or more Owners: Score 5 5 5
Proof of Capitalization Specific to Business Name/Address: Score 5 5
Proof of Capitalization Sufficient to Cover Proforma (3 months) and Construction Costs: Score 15 15 15 in liquid capital
Certified Audited Financial Report Provided for one or more Owners: Score 5 5
Score one of the following for a maximum 20 points:
Capital source is 100% liquid (cash in owners bank, no debt obligation)20 20 20
Capital souce is debt obligation (letter of credit/loan from individual or institution) 10 10
Capital consists of non-liquid assets (i.e. real property)8 8
Capital consists of a mixture of liquid and non-liquid assets 15 15
1.3 Sub-Total:50 40
Three Years of Data Provided: Score 10 10 8 6 6 Very brief, needs more detail
Total Gross Revenue Estimates Provided:3 3 3
Total Gross Revenue by Product Type (flower and manufactured) Identified:3 3
Total Personnel Costs Provided:5 5 4 3 3
Assume they are included in SG&A costs but not
enumerated
Total Property Rental or Purchase Costs Provided:2 2 2
Total Utilities Costs Provided:2 2
Total Cannabis Product Purchase Expense Provided 2 2 2
All Contract Services Identified:2 2
Annual Net Revenue Identified:3 2 2
Annual Cost Escalators Identified:4 4 3 2 2 Some show escalating costs but no detail
Annual Estimated Sales Tax Payments to State Provided:2 2 2
Annual Estimated Sale Tax Payments to City of Fresno Provided:5 2
Annual Business Tax License and Cannabis Permit Fee Provided:2 2
Annual Net Income Provided:5 5 5
Scoring Guidance: full points for realistic figures for all three years. Dock points for severe
miscalculations, unrealistic estimates, or providing less than the request three years.
1.4 Sub-Total:50 27
Hours of Operation Provided: Score 5 5 5
Hours of Operation Provided for all 7 days of the week: Score 3 3 3
Hours of Operation Provided for Holidays: Score 2 2 2
Opening and Closing Procedures Provided: Score 10 10 8 6 8
Missing steps prior to entering facility, physical
inspection, turn off alarm, etc
Scoring Guidance: full points for describing information in detail. Dock points for leaving information out
or not providing enough detail.
1.5 Sub-Total:20 18
1.3 Proof of capitalization in the form of documentation of cash or other liquid assets on hand, Letters of Credit or other equivalent assets which can be verified by the City. (50 Points Possible)
1.4 Pro forma for at least three years of operation.
1.5 Fully describe hours of operation and opening and closing procedures. (20 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
1.6.1 Fully describe the day-to-day operations if your applying for a retail permit:
i. Describe customer check-in procedures.20 20 15 10 20
II. Identify location and procedures for receiving deliveries during business hours.10 10 8 6 10
iii. Identify the name of the Point-of-sale system to be used and the number of Point-of-Sale locations.10 10 10 Flowhub
iv. The estimated number of customers to be served per hour/day.20 20 15 10 15
24 per hour, 288 per day - did not describe rationale
for estimate
v. Describe the proposed product line to be sold and estimate the percentage of sales of flower and
manufactured products.20 20 15 10 20
vi. If proposed, describe delivery service procedures, number of vehicles and product security during
transportation. (if no delivery service application must state this clearly for full points)20 20 15 10 15 did not describe vehicle type
1.6 Sub-Total:100 90
Section 1 Total:300 228
SECTION 2: SOCIAL POLICY AND LOCAL ENTERPRISE 400 Points Possible for Section 2
Description of Commitment to pay a Living Wage provided: Score 10 10 8 6 10
Definition of Living Wage Provided: Score 5 5 4 3 5
Living Wage Defined as Greater than Minimum Wage: Score 5 5 5
2.1 Sub-Total:20 20
Wages and Salary
CCB Entry-Level Hourly Wage Greater than Minimum Wage 5 5 5
CCB Entry-Level Annual Salary Greater than Median Household Income ($50,432)5 5 5 pg 28, starting
Health Care Benefits
CCB Offers Medical Coverage to All Employees: Score 5 5 5
CCB Offers Dental Coverage to All Employees: Score 3 3 3
CCB Offers Vision Coverage to All Employees: Score 3 3 3
CCB Offers Health Reimbursement Account for Qualified Medical Expenses: Score 1 1 1
No HRA mentioned but point given for subsidized
childcare
Employee Pays $0 for Employee Medical Premium: Score 3 3 0 did not mention premium
Employee Pays $0 for Employee Dental Premium: Score 2 2 0
Employee Pays $0 for Employee Vision Premium: Score 2 2 0
Employee Pays less than $500 per month for Family Health Care Coverage (Medical, Dental, Vision):
Score 2 2 0
Leave Benefits
Number of Paid Vacation/PTO Days Per Year: (10+ days = excep; 6-9 days = Good; 3-5 days Acceptable)5 5 4 3 5
Number of Paid Holidays Per Year: (10 or more paid holidays = excep; 4-10 = Good; 1-3 Acceptable)5 5 4 3 3 NY, Christmas, Thanksgiving
2.1 Describe whether the Commercial Cannabis Business is committed to offering employees a Living Wage. (20 points possible)
Scoring Guidance: https://livingwage.mit.edu/counties/06019
2.2 Briefly describe benefits provided to employees such as health care, vacation, and medical leave, to the degree they are offered as part of employment. (50 points possible)
1.6 Daily operations. With as much detail as possible, the Business Plan should describe the day-to-day operations which meet industry best practices. This should include at a minimum the following criteria for each permit type in
which you are applying for a permit. (100 points possible)
Criteria Narrative:
Criteria Narrative:
Number of days paid time off for Sick/Medical time: (7+ days= Exceptional, 4-6 days = Good, 3 days =
acceptable (8 hour day))5 5 4 3 3 offered but unspecified amount
Retirement
Offers employee retirement plan 2 2 0
Offers company match for employee retirement plan 2 2 0
2.2 Sub-Total:50 33
CCB Provides Tuition Reimbursement for Certificates: Score 3 3 0
CCB Provides Tuition Reimbursement for associate degrees: Score 3 3 0 education reimbursement not mentioned
CCB Provides Tuition Reimbursement for bachelor's degrees: Score 3 3 0
CCB Provides Tuition Reimbursement for master's degrees: Score 3 3 0
CCB Provides Tuition Reimbursement for Specialized Commercial Cannabis Business Operations
Training: Score 3 3 3
CCB Offers General Training for Health and Safety, Workplace Environment, Customer Service, etc. 5 5 4 3 5
2.3 Sub-Total:20 8
General Recruitment Plan Provided: Score 10 10 8 6 0
Social Policy Recruitment Plan Provided: Score 10 10 8 6 10
Recruitment Plan Includes Demographic Data for District, City or County: Score 10 10 8 6 10
Recruitment Plan Includes List of CBOs, Non-Profits and Public-Agency Hiring Partners: Score 10 10 8 6 8 Says will partner with CBO's but doesn't name
Recruitment Plan Includes Hiring Targets (percentages) by Demographic Groups: Score 10 10 8 6 10
2.4 Sub-Total:50 38
Owners
Number of Owners:4
Number of Owners that live within the City of Fresno:1
Number of Owners that live in the County of Fresno:0
Number of Owners that Own a Business in the City of Fresno:0
51%+ ownership interest percent of the Owners live or own a business in the City: Score 80 80
51%+ ownership interest percent of the Owners live or own a business in the County: Score 40 40
Less than 50 percent of the Owners live or own a business in the Cityf no owners are local, score zero)20 20 20
Managers
Number of Managers (salaried, non-owners)not specified
Number of Managers that live in the City of Fresno:
2.3 Describe compensation to and opportunities for continuing education and employee training.(20 points possible)
2.4 Describe the Commercial Cannabis Business plan to recruit individuals who meet the criteria listed in the Social Policy Section 9-3316 (b) (1) of the Fresno Municipal Code (FMC) and the percentage of local employees it hires. (50
points possible)
2.5 Describe the extent to which the Commercial Cannabis Business will be a locally managed enterprise whose owners and /or managers reside within or own a commercial business within the City of Fresno, for at least one year prior
to March 2, 2020.(80 points possible)
Data, non-scored. Write response in Evaluation Notes
column
IF full points achieved for Ownership category, don't score managers.
Section is total of 80 points possible.
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
Data, non-scored. Write response in Evaluation Notes
column.
Number of Managers that Own a Business in the City of Fresno:
100 percent of the Managers live or own a business in the City: Score 20 20
75 to 99 percent of the Managers live or own a business in the City: Score 15 15
50 to 74 percent of the Managers live or own a business in the City: Score 10 10
Less than 50 percent of the Managers live or own a business in the City: Score 5 5
2.5 Sub-Total:80 20
Responsibilities Described for All Titles/Positions: Score 20 20 15 10 20
2.6 Sub-Total:20 20
Does CCB have more than five employees: 5 5 5
CCB has signed a peace agreement: Score 5 5 5
2.7 Sub-Total:10 10
Work Force Plan Provided: Score 10 10 8 6 10
Commitment to Local Hire Provided:10 10 8 6 10
Commitment to Offer Apprenticeships Provided:10 10 8 6 10
Commitment paying for continuing education provided 10 10 8 6 10
Description of commitment to paying a living wage provide. (Score same as sec. 2.1)10 10 8 6 10
2.8 Sub-Total:50 50
CCB is willing to serve as Social Equity Business Incubator: Score 100 100 80 60 N/A This is a social equity business
Mentorship and Training: Score
Equipment Donation: Score
Shelf Space: Score
Legal Assistance: Score
Finance Services Assistance: Score
Other Technical Assistance: Score
Scoring Guidance: full points for willingness to serve with detailed plan offering at least three aspects
mentioned above or of similar benefit. Less points for willingness to serve but vague or unclear
commitment. Zero points if there is no clear commitment to serve as Incubator.
2.9 Sub-Total:100 0
Data to inform score on first line of this section. Write
response in Evaluation Notes column.
2.8.3. Commitment to pay a living wage to its employees
2.6 Describe the number of employees, title/position and their respected responsibilities.(20 points possible)
2.7 Describe whether the CCB has five (5) or more employees and whether it has signed a labor peace agreement allowing employees to unionize without interference. (10 points possible)
2.8 Provide a workforce plan that includes at a minimum the following provisions: (50 points possible)
2.8.1. Commitment for 30% of employees to be local hires; the business must show that it has either hired or made a good faith effort to hire bona fide residents of Fresno who have not established residency after the submission of an
application for employment with the applicant/permittee.
2.8.2. Commitment to offer apprenticeships and/or compensation for continuing education in the field; and
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
column.
Criteria Narrative:
2.9 Describe whether the business is willing 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, or other technical assistance support.(100 points possible)
Section 2 Total:400 199
SECTION 3: NEIGHBORHOOD COMPATIBILITY PLAN 300 Points Possible for Section 3
CCB will document complaints (time of complaint, nature of complaint, resolution of complaint): Score 10 10 8 6 6 Needs more detail
CCB will established a dedicated contact person to receive complaints: Score 10 10 10
CCB will establish a dedicated phone number to receive complaints: Score 5 5 5
CCB will establish a dedicated email address to receive complaints: Score 5 5 5
CCB will establish a response time standard for returning complaint calls and emails: Score 5 5 0 Info not provided
CCB will schedule or participate in periodic community meetings to engage with residents about the CCB
operation: Score 10 10 0 Info not provided
Other measure unique to business (i.e. website complaint form)5 5 5
Scoring Guidance: full points for detailed proactive plan addressing all aspects mentioned. Dock points
for leaving out aspect, vagueness, or reactive plans.
3.1 Sub-Total:50 31
CCB will maintain a listserv of community residents to update and information residents of business
operations.
10 10 0 Info not provided
CCB will schedule or attend periodic community meetings (at least annually) to engage with residents
about the CCB operation: Score 10 10 10 Provided in Section 3 3
CCB will prepare a community outreach and engagement plan: Score 50 50 40 30 0 Info not provided
CCB will issue periodic Newsletters to community providing information about CCB operations 10 10 0 Info not provided
CCB will hire residents from the community work at the CCB: Score 20 20 20
Scoring Guidance: full points for detailed proactive plan. Dock points for leaving out aspect, vagueness,
or reactive plans.
3.2 Sub-Total:100 30
CCB has identified sensitive receptors to nuisance odors in vicinity of business operations: Score 5 5 0 Info not provided
CCB has prepared a nuisance odor control plan: Score 10 10 8 6 10
Nuisance odor control plan identifies locations where fugitive emissions may exit the premise boundary:
Score 5 5 5 Provided in Section 3.6
Nuisance odor control plan describes specific odor control measures to reduce fugitive emissions exiting
the premise boundary: Score 5 5 5
CCB has established an odor reporting system: Score 5 5 0 Info not provided
CCB will install a nuisance odor monitoring system: Score 10 10 0 Info not provided
3.3 Describe odor mitigation practices.(40 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
3.1 Describe how the CCB will proactively address and respond to complaints related to noise, light, odor, litter, vehicles, and pedestrian traffic.(50 points possible)
3.2 Describe how the CCB will be managed to avoid becoming a nuisance or having impacts on its neighbors and the surrounding community.(100 points possible)
3.3 Sub-Total:40 20
CCB has identified the potential sources of nuisance odors for the business operation: Score 10 10 8 6 6 Needs more detail
Scoring Guidance: full points for detailed proactive plan. Dock points for vagueness or reactive plans.
3.4 Sub-Total:10 6
Nuisance odor control plan describes specific odor control equipment: Score 10 10 8 6 10
Nuisance odor control plan describes specific odor control measures/techniques: Score 10 10 8 6 10
Odor control measures are identified for different nuisance odor sources: Score 10 10 0 Info not provided
3.5 Sub-Total:30 20
Nuisance odor control plan describes the operation, monitoring, and maintenance requirements for
odor control measures: Score 10 10 0 Info not provided
Nuisance odor control plan describes the staff training required for system operations, maintenance,
repair, and troubleshooting.10 10 0 Info not provided
3.6 Sub-Total:20 0
CCB has identified the sources of waste generated by the business operation: Score
10 10 0 Info not provided
CCB has prepared a source-separation plan to segregate different sources of waste generated by
business operations: Score 10 10 10
The source-separation plan identifies policy, procedures, and locations where different sources of waste
are to be collected for disposal: Score 10 10 8 6 10
The source-separation plan describes specific measures to control the collection and disposal cannabis
waste: Score 10 10 10
The name of licensed cannabis disposal company provided: Score 10 10 0 Info not provided
3.7 Sub-Total:50 30
Section 3 Total:300 137
SECTION 4: SAFETY PLAN 300 Points Possible for Section 4
Safety Plan Prepared by Consultant: Score 10 10
Safey Plan Assessed by Consultant: Score (if prepared by, also give points for assessed by)10 10
Safety Plan Prepared for CCB Address (specific proposed location): Score 10 10
Safety Plan includes Site Plan of Premise: Score 10 10
3.4 Identify potential sources of odor. (10 points possible)
3.5 Describe odor control devices and techniques employed to ensure that odors from cannabis are not detectable beyond the permitted premises. (30 points possible)
3.6 Describe all proposed staff odor training and system maintenance.(20 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
4.1 The Safety Plan shall be prepared and/or assessed by a professional fire prevention and suppression consultant. (50 points possible)
Criteria Narrative:
3.7 Describe the waste management plan. (50 points possible)
Safety Plan includes Building Layout Plan: Score 10 10
4.1 Sub-Total:50 0
Written Accident/Incident Procedure Provided: Score 20 20 15 10
Procedures Address Multiple Accident/Incident Scenarios: Score 10 10 8 6
Total Number of Scenarios Described: Score
Active Shooter Incident Described: Score 10 10
Robbery Incident Described: Score 10 10
4.2 Sub-Total:50 0
Evacuation Plan Provided: Score 20 20 15 10
Adequate Number of Evacuation Routes Identified: Score 20 20 15 10
Evacuation Route Distance to Public Right of Way: Score 10 10 8 6
4.3 Sub-Total:50 0
Location of Fire Suppression System Elements Identified: Score 10 10
Type of Fire Suppression System Elements Identified: Score 20 20 15 10
Location of Fire Extinguishers Identified: Score 10 10
Adequate Number of Fire Extinguisher Locations Identified: Score 10 10 8 6
4.4 Sub-Total:50 0
Written Procedure for Fire Emergencies Provided: Score 20 20 15 10
Written Procedure for Medical Emergencies Provided: Score 20 20 15 10
Cardiac Arrest Medical Emergency Described: Score 20 20 15 10
Gunshot Wound Medical Emergency Described: Score 20 20 15 10
Other Medical Emergency Conditions Described: Score 20 20 15 10
4.5 Sub-Total:100 0
Section 4 Total:300 0
SECTION 5: SECURITY PLAN 300 Points Possible for Section 5
Security Plan Prepared by Consultant: Score 10 10
Security Plan Assessed by Consultant(if prepared by, also give points for assessed by): Score 10 10
Security Plan Prepared for CCB Address (specific proposed location): Score 10 10
Security Plan includes Site Plan of Premise: Score 10 10
Data-write response in Evaluation Notes Column
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
4.4 Location of fire extinguishers and other fire suppression equipment. (50 points possible)
Criteria Narrative:
4.5 Describe procedures and training for all fire and medical emergencies.(100 points possible)
5.1 The Security Plan shall be prepared and/or assessed by a professional security consultant.(50 points possible)
4.3 Describe evacuation routes. (50 points possible)
4.2 Describe accident and incident reporting procedures. (50 points possible)
Criteria Narrative:
Security Plan includes Building Layout Plan: Score 10 10
5.1 Sub-Total:50 0
Premises (Security) Diagram Provided: Score 20 20 15 10
Diagram is drawn to correct scale: Score 5 5
Diagram provides required details for premise: Score 5 5
Diagram shows the location of all security cameras: Score 5 5
Descriptions of activities to be conducted in each area of the premise 5 5
Limited-Access Areas Clearly Marked: Score 5 5
Number and Location of All Security Cameras Identified: Score 5 5
5.2 Sub-Total:50 0
Intrusion Alarm and Monitoring System Identified: Score 15 15
Name and Contact Information for Monitoring Company Provided: Score 5 5
Total Points of Entry into Premise Identified: Score 5 5
All Points of Entry to be Alarmed Identified:5 5
Type of Alarm Identified (motion, infrared, glass break, etc.): Score 10 10
Backup Power Supply Identified: Score 10 10
5.3 Sub-Total:50 0
Written Cash-Handling Procedure Provided: Score 30 30 20 15
Dual-Custody is Practiced for all cash handling: Score 10 10
Video Surveillance Used to Monitor All Cash Handling: Score 20 20
Armored Car Service Used for Bank Deposits: Score 10 10
All Cash Deposited weekly with Bank: Score 10 10
Onsite Vault Provided to Secure Cash Prior to Bank Deposit: Score 20 20
5.4 Sub-Total:100 0
5.2 Premises (Security) Diagram. In addition to diagrams submitted for other sections of the application, applicants are expected to submit a premises diagram (or site plan) which, focuses on the proposed security measures and how
they relate to the overall business. (Pursuant to CCR Title 16, Division 42, §5006. Premises Diagram).
5.2.1 The diagram shall be accurate, dimensioned and to scale (minimum scale ¼"). The scale may be smaller if the proposed location exceeds more than a 1/2-acre parcel but must not be printed on larger than an 11" x 17" sheet of
paper. (Blueprints and engineering site plans are not required at this point of the application process)
5.2.2 The diagram must be drawn to scale and clearly identify property boundaries, entrances, exits, interior partitions, walls, rooms, windows, and doorways. The activity in each room and the location of all cameras must be
identified in the diagram.
Criteria Narrative:
5.2.4 Limited-access areas, defined as areas in which cannabis goods are stored or held and only accessible to permittees, or its employees or contractors and areas used for video surveillance monitoring and storage devices
(Pursuant to CCR Title 16, Division 42, §5000 (m) Limited-Access Area and §5042 Limited-Access Area.
5.2.5 Number and location of all video surveillance cameras. (50 points possible)
5.4 Briefly describe cash handling procedures which covers day to day transactions with customers, vendors armor carrier vehicles and transporting it to the bank.(100 points possible)
5.3 Identify intrusion alarm and monitoring system including the name and contact information for the monitoring company (if the company has been selected).(50 points possible)
Criteria Narrative:
Criteria Narrative:
Criteria Narrative:
5.2.3 Description of cannabis activity that will be conducted in each area of the premise. Commercial cannabis activities that must be identified on the diagram/site plan may include but are not limited to the following if applicable to
the business operations; storage areas, batch sampling areas, loading/unloading of shipment areas, packaging and labeling, customer sales areas, training areas, employee break room areas, extractions, infusions, processing, and
testing areas.
CCB will use onsite security guards: Score 10 10
All onsite guards will be licensed and bonded: Score 10 10
All onsite security guards will be licensed to carry firearms: Score 10 10
Onsite security guards will be on duty before CCB opens for business: Score 10 10
Onsite security guards will be on duty after CCB closes for business: Score 10 10
5.5 Sub-Total:50 0
Section 5 Total:300 0
Section 1: Business Plan Total Points:300 228
Section 2: Social Policy & Local Enterprise Total Points:400 199
Section 3: Neighborhood Compatibility Total Points:300 137
Section 4: Safety Plan Total Points:300 0
Section 5: Security Plan Total Points:300 0
Total Points Achieved:1600 564
PASS
TOTAL SCORE
5.5 Discuss whether the CCB will utilize the services of on-site security guards. Include in the discussion: (50 points possible)
5.5.1 Number of guards.
5.5.2 Hours guards will be on-site.
Criteria Narrative:
5.5.3 Locations at which they will be positioned.
5.5.4 Guards' roles and responsibilities.
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Our proposed property, 755 Van Ness Ave., Fresno, CA 93721, is currently a vacant unit
within a multi-unit building. Our real estate business, Tilstar, LLC plans on leasing the unit from
the owner Mr. James M. Riley and assigning the lease to our operating business. Given our
experience we believe separating the real estate and operating business gives our team greater
business flexibility if cannabis is legalized at the federal level. The unit is roughly 1,940 square
feet, more than enough space for 4 to 6 terminals, serving well over 250 patients per day. There
are multiple units available and if our application is successful, we can expand into the adjacent
vacant space. The land is properly zoned for the use of cannabis retail dispensary. We expect to
successfully receive our Zoning Inquiry Letter (ZIL) and if selected, we can start our project
immediately.
The property will be fully equipped with ADA access for those workers that are disabled,
and we will have over 30 parking spaces for our employees and customers with dedicated
handicap spaces nearest to the entrance. The neighboring businesses will NOT be negatively
affected due to the dedicated parking lot that will ensure traffic is NOT blocking or disturbing
any other building or business. Please see a site / building plan of the current facility. Please see
a photo of the building with the parking lot, an aerial of the various buildings and businesses
nearby and a diagram of the unit within the building.
755 Van Ness Ave., Fresno, CA 93721
Business Plan
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1
1.1 Owner Qualifications
Viola is the largest African American owned cannabis company in the industry. Our
Fresno Commercial Cannabis Business (“CCB”) is an organic and authentic 100% African
American and Minority owned business. Our entity is genuinely majority owned and led locally
by Mr. Hopkins, who suffered and was targeted by the War on Drugs and served 18 months in
Fresno prison, long standing Fresno resident. Viola is providing Mr. Hopkins an opportunity to
partner and learn from one of the premier cannabis brands in the industry. Our operating business
is a certified Minority Business Enterprise (MBE) in multiple states, and diversity is represented
throughout our company in ownership, management and employment. Viola and affiliates
currently operate in the following cannabis markets, California, Oregon, Michigan, Colorado and
have licenses in Maryland and Missouri.
Our local Fresno team is excited about the opportunity to apply for a cannabis business
license in a city where our CEO was convicted of a non-violent cannabis trafficking crime. Our
CCB will leverage Violas business experience and cannabis operations through funding,
employee training, production capabilities, cannabis education and executive salary synergy. Our
CCB Executive team has over 100 years combined operating safe secured cannabis facilities.
Our Board Member and Co-Founder is one of the most experienced cannabis operators,
funders and brand ambassadors in the industry. He has led a team of operators that have
successfully cultivated, processed and dispensed the Viola brand in heavily regulated markets.
Our President has close to a decade experience operating vertically integrated secured cannabis
businesses across the country. Our COO was the former interim CEO of an Illinois medical
cultivation and processing facility, served as the CEO of a vertically integrated medical cannabis
business in New Jersey and served as the COO of medical cannabis dispensaries in
Pennsylvania. Our Director of Cannabis Operations (includes cultivation, processing and
dispensary) has more than eight years’ operating vertical medical cannabis business in Nevada
and Colorado, before joining our Fresno team. That only scratches the surface of our teams’
experience in properly operating and securing cannabis facilities without incident.
Our facilities across the United States include a 12,000 square foot cultivation and
processing facility in Colorado, a 40-acre outdoor cultivation grow in Oregon, a 46,000 square
feet cultivation and processing facility in Michigan, and soon to be 66,000 square foot cultivation
facility in Maryland and 78,700 square foot cultivation and processing facility in Missouri. These
facilities have a combined annual cultivation and processing capacity of over 50,000 pounds.
Our retail facilities include a medical and adult-use cannabis dispensary in Detroit,
Michigan and two medical cannabis dispensaries in the heart of St. Louis, Missouri. These
locations have the ability to serve over 1,000 customers daily.
Our owners have overseen multiple medical cannabis facility designs and build outs in
some of the most regulated medical and adult-use markets, including Michigan, Pennsylvania,
California, New Jersey, Colorado, Nevada, Illinois and Missouri. We designed our Fresno floor
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with one of the largest distributors in the state. We scored the highest-ranking application in
Maryland’s latest round of medical cultivation licenses and we plan to begin construction Q3
2021. Most recently we were awarded a license to cultivate, process and dispense medical
cannabis in St. Louis, Missouri and our medical processing and medical dispensary was awarded
the highest scores out of 1,200+ applicants. Viola’s cannabis products are sold in over 600
dispensaries nationwide in some of the most challenging branding cannabis states in the country.
Please see map above with our current operations and licenses, pending licenses and
potential pipeline for future growth.
COLORADO: We launched our first cannabis operation in 2014. Al Harrington and
Daniel Pettigrew took their first steps in creating their vision, which was unprecedented, in one
of the largest, toughest and stringent medical and adult-use cannabis markets in the country.
The state of Colorado has over 500 cannabis companies and just as many “brands”, many do not
last past 18 months of inception, but with proper operation protocols, hard work and training, our
founders were able to outlast the competition.
Our Colorado operation is an integrated medical and adult-use cultivation and processing
facility. We built our facility in the heart of Denver. The operation cultivates, processes,
packages, and distributes our branded products, which only includes selling cannabis oil
products. Our agents are led by our Director of Cultivation and Director of Processing, both
having over 10 years of cultivation, horticultural and processing experience. All products are
independent laboratory tested and receive great online reviews from consumers.
Key metrics that show our operational success include, increased same-store-sales by
31%, increased production capacity by 51% - through operational efficiencies, increased retail
penetration by 165% while expanding our operating margin from 21% to 33%. While many
operators are focused on “cool” brands, we focus our efforts on consistency and medicinal value,
which increases our product footprint. Our Colorado operations is a perfect example of how to
use a smaller sized facility and produce high quality cannabis products while making a profit.
MICHIGAN. One of the largest medical cannabis markets in the country. We recently
won a vertically integrated license to cultivate and process medical cannabis in one the most
blighted communities in Detroit and operate a state-of-the-art retail dispensary in the same city.
We have finalized construction of a 46,000 square foot cultivation and processing facility with
estimated capacity of over 10,000 pounds annually. We will provide a wide portfolio of products
including flower, extracts, vapes and tinctures. We launched our operations in Q2 2020 and
expect to be profitable shortly after. We own and operate a dispensary in Detroit, that has the
capacity to serve over 400 customers daily.
CALIFORNIA. The many factors that attracted our Company to the California market
was the ability to have brand penetration in the largest cannabis market in the country. We
launched our brand in August 2018 and partnered with Continuum and HERBL, some of the
largest distributors in the State. Within a few months our products had retail penetration in 25%
of all dispensaries, successfully launched 22 SKUs across three product categories. Our team is
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excited to potentially operate a cultivation facility in Fresno, where we can cultivate our own
custom strains rather than rely on other producers to white label our dried flower.
OREGON. We completed our first harvest in December of 2017 on an outdoor
cultivation property. The property sits on 40 acres in Falls City, with a little over 40,000 square
feet of canopy. Annual capacity is more than 12,000 pounds. Our lead cultivator has over 15
years cultivating in outdoor environments.
MARYLAND. Our team scored the highest ranked application in Maryland’s medical
cultivation application process. Our facility will be approximately 66,000 square feet and we are
currently in advanced discussions to purchase and operate two dispensary businesses nearby. We
expect to immediately start cultivating in a medical market that is close to $550 million in total
sales.
MISSOURI. These are the newest licenses added to our business. Our team won a very
competitive license process to cultivate and process in a 78,700 square foot facility in one of the
most disadvantaged neighborhoods in Missouri. Our two dispensaries will be located in the heart
of two “up and coming” neighborhoods in St. Louis and will include a team of pharmacist and
medical professionals operating the business.
Many of the mega multi-state operators started with winning licenses and are struggling
to build a national brand, our Company started with a brand and learned how to successfully
OPERATE the brand, setting us apart from our competition. Given our diversity and local
Fresno ownership, we will be ready to fund, operate and begin our Commercial Cannabis
Business.
Viola’s Business History
Our founders possess the vision and passion to create the largest African American
owned cannabis operating company in the country. Founded in 2013 by 16-year professional
basketball player and his savvy business partner, Al Harrington and Daniel Pettigrew,
respectively, they have created one of the most well-respected cannabis brands in a very
fragmented industry. Viola has built a nationally known medical and adult-use cannabis brand
with a strong track record of providing high quality products to patients and consumers. Viola’s
owners are dedicated to provide resources for social equity individuals that suffered from the
War on Drugs and our history of being on the forefront of that movement is shown through our
actions, our marketing, our social media and our website. Our business is stronger when we can
truly build partnership with those negatively impacted or targeted by the Ware on Drugs.
Mr. Harrington, endured to survive an NBA playing career, while fighting off the effects
of 12 surgeries. He traded in a dangerous pile of prescription pain medications on a doctor’s
recommendation for the wide-spread health benefits derived from the cannabis plant, and it
worked wonders. The founders saw this as a viable opportunity to empower a community that
was negatively affected by the War on Drugs.
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His grandmother, who has glaucoma, could finally read her bible again after trying
cannabis for the first time. The namesake of the company is in honor of his grandmother, who
encouraged him to learn more about the positive medical effects of cannabis. Our combined
medical and adult-use cannabis licenses are in five states including Colorado, Oregon, Michigan,
Missouri, and Maryland.
Currently, our company has over 50,000 pounds of annual cultivation and processing
capacity. Our cultivation team has one of the most robust catalogs of over 200 strains of flower
and multiple varieties of extract, concentrate and processed products. Our team has successfully
launched over 40 cannabis SKU’s across four product categories. Our team consists of retail and
sales experience in some of the most regulated markets in the country.
Our Company is in an amazing position within the cannabis industry. While being
licensed in multiple regulated states, we continue to be well funded and we operate and
understand all phases of the cannabis industry. We have organically created strong best-in-class
brands to serve all markets, patients and customers -- THC based Viola Brands and CBD based
Harrington Wellness and Hemp based RePlay. We have sold over 1,000,000 grams of medical
and adult-use cannabis, something we are extremely proud of. We are TRULY MINORITY
OWNED and our Fresno CCB is TRULY LOCALLY OWNED.
We are the definition of being an outlier in the cannabis industry. We are not among the
novice applicants who lack experience or expertise. We are who we are. Our founders have
invested millions of their own capital, betting on themselves. In only a few short years our
Company has built a dynamic, fast-growing, revenue producing cannabis company.
We are a proven entity as we have been trusted by multiple States to operate medical
cannabis businesses with adherence to comprehensive rules and regulations, and in so doing, we
have developed successful “pharmacy-like” protocols, procedures and best practices.
Within this application, the Fresno City Manager placed a heavy emphasis on diversity
and real partnership with social equity applicants. In most markets, we are the ONLY company
with diversity in all parts of our company. We are NOT a white owned operating company
partnering with a minority Fresno resident to gain points on this application. We have been a
successful minority owned company since the beginning. Viola is a minority owned cannabis
company partnering with minority Fresno resident. If the City Manager is serious about awarding
licenses to experienced, Fresno majority owned, minority owned and well-funded companies,
then we feel we are the most qualified.
We are excited about the opportunity to bring our vertical operating experience to Fresno.
Management Biographies and Relevant Experience
Below we not only outline our Owners and Executive Team. We also showcase Key
Personnel that will be integral to our mobilization and training plan, helping train and day-to-day
operations in Fresno. The agents who run these operations have considerable expertise, including
multiple decades of collective knowledge and real-world experience in retail dispensing,
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application. We are the exact opposite of many of our competitors as we strive for true diversity
at every level of our business.
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1.2 BUDGET FOR CONSTRUCTION, OPERATION, AND MAINTENANCE,
COMPENSATION OF EMPLOYEES, EQUIPMENT COSTS, UTILITY COST
AND OTHER OPERATION COSTS.
Overview: Organized charts and
professional graphics aside, a successful
Financial Plan requires smart planning coupled
with execution. The companies who succeed
are those that can accurately predict and then
manage costs without unforeseen surprises,
while at the same time sufficiently
understanding the market to accurately project
revenues and build out operations and staffing
proportional to actual demand.
Budget – Start-Up Costs: We estimated
and budgeted for overall start-up costs to be
for our facility, which includes
10% construction contingency of
Based on our prior similar construction
projects, our construction partner and COO
believes this to be a conservative but realistic
estimation. This includes the following:
Real Estate: We will purchase the
vacant property for approximately
plus fees and closing, contingent upon a
successful application. The option to purchase
will be held for 90 days after January 29, 2021.
Our team has the capital to reserve the property
for additional months if more time is needed
for the City Manager to award licenses.
Construction & Build Out: Our Company projects construction and build out costs of
which include mechanical services (plumbing, electric, HVAC), sitework,
landscaping, building the interior and exterior. The dispensary will consist of a 3,000 to 5,000
square foot building. The size is more than adequate to serve more than 500 customers daily.
The other start-up cost categories are summarized above. Estimates are based on previous
experience, and reflect our research gathered from contractors regarding pricing on construction
and build out. These estimates are adjusted to reflect the unique regulatory market of Fresno. Our
assumptions are conservative, and our cash commitment leaves room for a 20% increase due to
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unforeseen situations. As discussed below, our revenue assumptions are likewise conservative,
taking into account our analysis of Fresno’s’ customer growth rate in 2022, 2023 and beyond.
Anticipated Demand: Based on our operating experience in other States with comparable
cannabis programs, we have modeled expected patient demand and growth for Fresno. A key
component of success in this industry is properly understanding and planning for the market as it
exists, not as one might wish it to be. Our estimates are necessarily subject to uncertainty, as no
one knows precisely how many Fresno citizen will purchase cannabis products. Our construction
plan calls for a build out that we’ve already completed before, the benefit that we can start
operations as soon as possible.
Revenue: Our total revenue projection for 2022P is . Our 2023P revenue
estimate is a better reflection, as it will be our first full year operating. In 2023P we estimate
in revenue. An estimate based on a number of assumptions, including the
projected number of customers in the total market, as well as our ability to attract customers to
our best-in-class brands. We feel our numbers are conservative and reflect our approach to
providing high quality cannabis products.
Our facility is strategically located in Fresno, California, near expressways and simple
delivery routes. We will sell a variety of products including dried flower, vape cartridge, edibles,
tinctures, capsules, lotions / topicals and transdermal patches. THC products using our nationally
known brand Viola Brands and CBD products using Harrington Wellness and RePlay. We will
put a strong emphasis to purchase from local Fresno cultivation and processing businesses. We
believe our broader menu selection, as well as our past success in creating desirable products and
expanding education, will attract customer to our CCB.
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Expenses: In 2022, during our first year, we
hope to generate close to nine months of revenue.
We will incur monthly expenses at least six to three
months prior to planting our first seed. As demand
increases, annual expenses will also increase while
the business grows. Employing conservative
projections, we assume revenues to exceed
expenses immediately with overall break-even of
our investment closer to Q2 2023P.
Based on our prior experience, our CFO has
confidence in our projected operating expenses. Within 2022P, our first full year, we expect to
incur of expenses, approximately per month. On average, roughly
39.6% of all operating expenses are attributable to labor costs ( per month). We will
hire and retain the best local employees for each position while fostering a culture of integrity,
loyalty and achievement; which means paying a fair and desirable wage and providing generous
benefits. Our Company believes that every employee should have health benefits and should be
able to participate in our company equity program, allowing our workforce to participate in the
success of our business.
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1.3 PROOF OF CAPITALIZATION IN THE FORM OF DOCUMENTATION OF
CASH OR OTHER LIQUID ASSETS ON HAND, LETTERS OF CREDIT OR
OTHER EQUIVALENT ASSETS WHICH CAN BE VERIFIED BY THE CITY.
Evidence of Sufficient Capital
Our investors and owners have more than enough sufficient capital to successfully carry
out our activities described in this Application. We will NOT have any delay with our operations
due to lack of sufficient capital. In other states winners sometimes lost time when they had to
raise capital to make good on what their applications promised. One of our goals is to get to
market as quickly as possible, without compromising our operations and that cannot be
accomplished if we are not well capitalized.
We have liquid assets on hand, ready to
capitalize our business and start operations
immediately. Our high net worth owner, Al
Harrington, set aside in liquid
assets. The will remain in his
possession but is contractually committed for
Fresno projects, until licenses are awarded. As
much as we would like to use debt financing, it
is hard as investors would like to participate in
the growth and upside of the business. At the
moment, debt capital interest rates tend to be as high as 15% to 20%. If successful, we will use
Mr. Harrington’s assets to purchase our property, build out operations and fund startup costs.
Proof of funds showing are proven in the owner’s bank statements.
We are confident from prior experience building similar facilities that our proposed
facility will cost roughly to build-out, to purchase the property, and we
have allotted another for 10%+/- contingency. We are thus ready to execute as soon as
we are approved. Being well capitalized is important to start operations immediately after being
awarded.
There are substantial advantages to having ready access to our own capital. Our Company
can draw immediately on the committed , we do not plan on being beholden to
outside investors not within our current capital table. We will have enough funds to complete a
state-of-the-art build out. This is a big advantage, because the process of raising money is
necessarily uncertain and often delayed. Moreover, the need to satisfy third-party investors can
also translate to undue focus on short-term results rather than long-term foundations. Our
Company has a long history of operating within good financial responsibility and we have never
defaulted on vendors. Due to the celebrity nature of our high-net worth investor, we do not
anticipate any scenario where our operations would be delayed due to lack of capitalization. If
we were to raise capital, we will ensure Mr. Hopkins maintains majority ownership. We can
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TIMELINE OF OPERATIONS
Set forth in our timeline below, we will have an immediate advantage to start
construction as we have built government relationships throughout Fresno. Our COO will further
work toward finalizing all designs with architects to prepare for the possibility that we will be
selected. This plan advances the construction timetable by initiating these processes before we
are actually awarded a license. We will have the appropriate staff to complete the dispensary
build out.
We can move as quickly as possible and be successful because we are the most
experienced 100% minority owned cannabis company in the US, we are self-funded which
provides a competitive advantage to avoid delays needed to raise money and we have created
supplier relationships to help with beginning inventory.
Immediately after winning a license and local construction approval, we will begin
finding property on Day 1 and begin construction well within 3 months, below are key dates in
our construction, process and dispensary timeline. We will have operations up and running
within six months of award.
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1.4 PRO FORMA FOR AT LEAST THREE YEARS OF OPERATION
Market Share Estimates: Many applicants make flawed revenue assumptions solely based
on overall market size. The real variable for success is the number of how many customers can
the dispensary serve and customer buying trends. See our Market Size and Market Share
estimates below:
We begin our assumptions with customers and their purchasing patterns, and from there
determine how many Point-of-Sale terminals we need to properly operate. Given our facility
size, we will maximum our customer experience. We believe with the number of total
dispensaries in Fresno, we can be profitable and that’s unique in an industry where the larger
cannabis companies are cash flow negative. We are fully confident we will be an asset to the
Fresno market by branding our existing products and diversifying the majority owned cannabis
industry.
Other Competitive Advantages: Another important asset of our Financial Plan is our
tested and proven Mobilization Plan. Our team members have built similar facilities multiple
times in the past, we have the experience, personnel, relationships, and training protocols
necessary to finish construction and begin selling product immediately of being deemed
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operational. Upon recently being awarded a vertical license in Michigan, for example, we were
one of the first to market licensed operation in Detroit, and we expect to be profitable within 24
months.
Many of these assumptions were derived by our experience operating in similar medical
cannabis markets, but also conducting research using the Annual Marijuana Business Factbook –
8th Edition as well as using data from New Frontier Data. Please see below an annual version of
our Pro Forma Income Statement and Cash Flow Statement.
Our CCB will maintain accurate books and records in an electronic format, detailing all
of the revenues and expenses of the business, and all of its assets and liabilities. On no less than
an annual basis, or at any time upon reasonable request of the city, each CCB will file a sworn
statement detailing the number of sales by the CCB during the previous twelve month period,
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provided on a per-month basis. The statement will also include gross sales for each month, and
all applicable taxes paid or to be paid. On an annual basis each owner and operator will submit to
the city a financial audit of the business’s operations conducted by an independent certified
public accountant, per SEC 9-3331(a).
Per SEC 9-3331(d), subject to any HIPAA regulations, we will allow the city to have
access to our business’s books, records, accounts, together with any other data or documents
relevant to our permitted commercial cannabis activities, for the purpose of conducting an audit
or examination. Books, records, accounts, and any and all relevant data or document will be
produced no later than 24 hours after receipt of the city’s request, unless otherwise stipulated by
the city. All documents submitted will be in an electronic format that is compatible with the
city’s software and hardware.
Please see our detailed financial model, attached in this exhibit, with our quarterly pro
forma operating assumptions and production.
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1.5 FULLY DESCRIBE HOURS OF OPERATION AND OPENING AND CLOSING
PROCEDURES.
Hours of Operation
Dispensary: We plan to have our dispensary operations open seven days a week and
closed on major national holidays including New Years day, Christmas and Thanksgiving. We
understand we are dispensing high quality products and we want customers located in and
around the Fresno area to have an equal opportunity to purchase, medicate and relieve their
symptoms with consistent hours of operation. We will be open for an estimated 8-12 hours each
day, ranging on the weekdays and weekends, based on previous historical cannabis operations.
We expect to be busy every day after 5:00pm, busy on most Fridays due to payday and
the start of the weekend and busy weekends near opening. Typically, the down days are
Tuesdays and Wednesday as many customers purchase products during the weekend. If we
notice customer trends, we will adjust our hours and properly announce on our website, email list
to customer, post signage at our location, social media and through other marketing platforms. In
no instance will we be open earlier than 6:00am or close later than 10:00pm, per SEC 9-
3310(a)(1). Our proposed schedule has our dispensary open for 12 hours every day on average.
We base our operating decisions on industry research and past experiences. A cannabis
analytics firm – Headset – conducted research on when are the most popular days and times to
purchase from a dispensary. They collected data from over 715,000 transactions and below is a
snapshot of their findings:
“Legal marijuana is most likely to be purchased between 3 and 5 o’clock on Fridays, Headset
found. Another quarter of purchases occurred during the traditional happy hours between 6 and
8 o’clock. In another less-than-shocking finding, just 13 percent of purchases are made between
9 and 11 in the morning. The early bird, it appears, does not get the legal weed.” – Headset,
Bloomberg, September 23, 2016 “The Early Bird Does Not Get the Legal Weed”
We believe being open for 70+ hours a week best optimizes our business but also allows
customers to purchase their products or medicine seven days a week, like a Walgreens, CVS or
Fresno Dispensary Hours of Operation
Sunday Monday Tuesday Wednesday Thursday Friday Saturday
Open 10:00 AM 9:00 AM 9:00 AM 9:00 AM 9:00 AM 9:00 AM 9:00 AM
Close 7:00 PM 9:00 PM 9:00 PM 9:00 PM 9:00 PM 9:00 PM 9:00 PM
Hours Open 9 hours 12 hours 12 hours 12 hours 12 hours 12 hours 12 hours
Total Hours 81 hours
Average Hours 12 hours
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Walmart pharmacy. If our dispensary has to close during our normal business hours, we will
implement procedures to notify customers when we will resume normal hours of operation. We
will update our website real time, we will have a present voice messaging system to notify the
customers that may call before they arrive, we will have conspicuously posted signs at the
entrance, we will send out alerts using social media and we will email all customers when we
will reopen. We believe these are great ways to contact and reach our customers during a closure
or change in schedule. If our dispensary is or will be closed during our normal hours of operation
for longer than two business days, we will immediately notify the City Manager.
Opening & Closing Procedures
Dispensary: Our CEO, Dispensary Manager and Security Manager will ensure all
procedures are followed when opening and closing the facility for the day. At no time will our
CCB be open or in operation, unless the CEO, Dispensary Manager or Security Manager is on
premise and directly supervising the activity within the facility. The CEO and Dispensary
Manager will ALWAYS open the facility with a security guard on site. Each employee that
enters will have to check in using their limited access keycard and show ID, all hourly paid
employees must “clock” or “punch” in before entering any part of the sales floor. The security
guard will check all employees in at the vestibule. All employees working the morning shift
(opening the facility) will be asked to be on site one hour before opening to properly prepare and
stage the sales floor. The CEO or Dispensary Manager will do the following: (i) properly check
all inventory from the night before, (ii) check all cash accounts within the Vault, (iii) properly fill
all cash registers at each Point-of-Sale (“POS”) station with daily starting cash, (iv) conduct a
security check of the cameras and surveillance system with the security guard, (v) update menu
items if necessary based on inventory and (vi) ensure all customer areas are clean and sanitary
including bathrooms, waiting area and sales floor.
At close, all hourly paid employees must “clock” or “punch” out before leaving at the end
of the business day. Our CEO will follow the procedures outlined: (i) remove all product from
the sales floor and transfer to the inventory carts, the CEO with restricted access will deposit the
inventory cart in the vault once cash accounting is completed, (ii) All terminal cash drawers and
receipts will be reconciled using a closing report log in our POS system, (iii) all cash will be
counted, sorted, bundled, stored and logged in our cash vault, (iv) conduct nightly inventory and
reconcile with sale receipts, (v) dispensary agents will complete their daily cleaning station
checklist, which include organizing the sales floor for the morning agents, (vi) shut down all
computers and turn off all lights in the dispensary, and (vii) activate the security alarm, leave as a
team (security guard is always last to leave) and make sure all entrance doors are locked. Our
CEO, Dispensary Manager and Security Manager will monitor all employees to ensure
adherence to all closing procedures.
Please find below an example of our dispensary flow of customers and employees.
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5. Upon completion of the transaction, the customer will be escorted to the sales floor exit
door leading back to the waiting area. As you can see from the diagram above, a separate
exit from our sales floor to the waiting room creates a smooth flow and movement of
customers and agents and a safe way to prevent the spread of COVID-19.
6. Customer exits the dispensary and is monitored until they get in their vehicle.
Customers will only have access to four areas in the dispensary part of the facility:
Waiting Room; Private Consultation Room; Sales Floor (where the Patient must be escorted at
all times) and Restrooms, designated for customers and not the public. We will have surveillance
of each customer at all times, (obviously not in the bathroom, but within entry and exit of the
bathroom). The limited access to customer allows our security team to easily track customer
movement through our dispensary.
Clock in and Clock Out Procedures: To ensure our agents, employees and staff are
compensated for time worked, each area manager will keep accurate record of employee’s work
schedules in the back office. Employees will be trained properly on how to use our electronic
punch-in and punch-out system. All employees must punch-in at the start of their shift, punch-
out for lunch breaks, punch-in once returned from lunch and punch-out at the end of their shift. If
working more than six hours in a shift, all employees will be required to take a 30-minute lunch.
All employees will receive 15-minute breaks for every four hours worked. We plan on using an
electronic Timelogix TL50 Smart Punch In/Out system that tracks all daily employee data on our
secure servers. The system allows employees to clock in and out using their personal mobile
devices (within 50 feet of our system) and the system sends alerts regarding breaks and
employee hourly data. Each employee will have a unique user and password to punch in and out.
The system can also integrate with agent access cards so employees that forget their user and
password can record their time in and time out by swiping with the machine. All employees will
receive their paycheck every 2 weeks on a Thursday. We will have payment options of direct
deposit or a mailed check, we advise all employees to request direct deposit, but it will be the
employee’s choice.
COVID-19 Procedures: Our dispensary will ensure all customers and employees are safe
and follow all COVID-19 protocols, including wearing a mask, that is covering the nose and
mouth, upon entry, receiving a temperature check directly within entry, and staying 6 feet away
from other customers while in the waiting area and in the sales floor. If a customer or employee
has a fever or high temperature or flu like symptoms, our CEO will ask they immediately leave
the facility and seek immediate medical attention. If a customer does not have a mask, we will
have a box of medial grade masks to be provided upon entry. All items that customers can access
(floors, chairs, desks, menus, tablets, countertops) will be wiped down and sprayed with paraben
and phthalate free sanitizer. We will have hand sanitization stations spread throughout our
facility, including in the: Waiting Room; Private Consultation Room; Sales Floor; and
Restrooms. Some of our customers will have serious pre-existing conditions and life-threatening
diseases and could be fatal if exposed to COVID-19.
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STRENGTHS, WEAKNESSES, OPPORTUNITY, THREAT (SWOT) ANALYSIS
A Business Plan is not complete without a Strengths, Weaknesses, Opportunities and
Threats (SWOT) analysis. This analysis is important, so our executive team understands the
positives and negatives of our Fresno business venture. It serves as the backbone of our decision
to enter into a cannabis market. Given our long-standing operational experience, we have many
STRENGTHS in the cannabis industry that will benefit the Fresno market. Due to experience
from our team, mostly all the topics within this application are considered our strengths. The fact
of the matter is we operate in multiple highly regulated states. We feel WEAKNESSES from
lack of experiences no longer exist within our Company and our team turned those early
mistakes into learning experiences that are now strengths.
Fresno will be a large market, there is OPPORTUNITY to increase our brand awareness
and serve customers with high-quality consistent products. We plan on being first to market
taking advantage of low supply and high demand of product. We will not price our products
based on supply and demand economics; we think first-to-market creates brand loyalty amongst
customers. We believe our biggest THREAT is mass-consolidation. Cannabis companies are
selling equity for millions and billions of dollars, the stakes are higher than ever before, and
many applicants create loopholes to control and own more licenses than legally allowed,
especially when it comes to social equity licenses.
Strengths:
National Brand – Our brand is very well recognized as we are the largest African
American cannabis brand in the US. The celebrity nature of our brand gives us access to a
network of intelligent, well respected business minds to further our brands’ presence in existing
and new markets. Our brand is a major strength to any new market, it represents high-quality,
consistent, competitively priced, minority-owned community focused ideals.
Well Capitalized – We have liquid assets and cash on hand, ready to capitalize our
business and start immediately. We set aside more than $10 million in liquid assets. Our liquid
capital on hand exceed our projected costs/capital burn, thereby allowing us to begin our
operations immediately.
Proven Standard Operating Procedures – Our COO honed a first-class step-by-step SOP
and application that will make our dispensary effective, efficient and safe to dispense cannabis.
Our SOPs are outlined throughout this application, which proves the success of the business. Our
facilities have NEVER had a criminal incident, NEVER experienced internal diversion and
ALWAYS maintained an adequate supply of product.
Strong Executive Team – One of the strongest business, marketing, branding, legal,
financial, operating, community relations and cannabis industry teams in the business. Many of
our team members have been involved in the cannabis industry since the beginning of
legalization in most states and have formal and informal cannabis training.
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Dispensary Experience – Most of our team members have experience designing,
constructing and operating dispensary facilities in regulated states. Our team has overseen 9
dispensary projects in high barrier to entry cannabis markets.
Community Impact & Engagement – Our Company is majority owned by resident that
has deep community roots in local low-income communities. We will build relationships with
community leaders and government relations and cannabis officials to provide economic
development, jobs and opportunity for all residents in Fresno, not just the wealthy.
Diversity and Inclusion – Less than 5% of all cannabis companies have majority minority
participation in ownership and California lacks majority minority owned cannabis businesses.
Our Company has 100% of the equity held by minorities as commonly defined. Our diversity
gives our Company a unique perspective when analyzing new products.
Weaknesses:
Vertical Integration Not Guaranteed – Our team does not cultivate or process in
California and any new dispensary will be at the mercy of cultivators as they will have a supply
shortage as they also own dispensaries (which they will supply first before supplying any new
entrants). Supply and demand will likely dictate prices. Our customers will experience major
pricing pressure if there are standalone retail dispensaries. We plan to mitigate by entering early
supply agreements with multiple cultivators and processing brands upon awarding of license and
applying for our own cultivation license.
Opportunity:
First to Market / New Industry in Fresno – Because of our strong brand recognition we
want to be first to market to create customer loyalty and take advantage of initial high demand.
Limited Supply and High Demand – We have the capital to start construction
immediately and the experience to dispense without interruption. We plan to have products ready
for sale shortly after being awarded a license. This creates brand and product loyalty amongst
customers. Our relationships will allow us to purchase products and brands immediately to serve
the Fresno residents.
Economic Development – the potential location of our dispensary is a green field project
that will provide construction jobs as well as permanent jobs for our operations. We will fill
positions not only at our facility, but also within ancillary industries such as – marketing,
accounting, real estate, sales, packaging etc. We will commit to targeting low-income
communities for at least 33% of our workforce.
LOW Minority Ownership: Currently in California less than 5% of dispensaries are
African American majority owned. Being the largest African American cannabis brand in the
industry, many African American customers see our brand and feel connected visiting,
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purchasing and using our products. Our business will be a model business for Fresno’s social
equity program and we will not disappoint.
Threats:
Misleading Social Equity – Companies that are non-minority owned will create predatory
partnerships with social equity applicants. Large companies will put a social equity applicant as
the figure head owner and buy their equity for pennies on the dollar. We do not want to see
predatory agreements (i.e. companies doing applications for “free” because they suddenly care
about diversity). The City Manager will have to sift through all applications to ensure these are
real partnerships and authentic long-term minority Social Equity Applicants.
Vertical Integration – With cultivators, processors, and dispensaries all under the
management of one parent company. Many of the vertical integrated businesses tend to sell only
to their dispensary and can use transfer-pricing methods to drive out competing operations.
Essentially blocking all new companies from competing with their dispensaries. Our CCB is also
applying for a cultivation license and we want our strong brand to be in ALL Fresno stores and
our dispensary will carry other local Fresno products.
We feel we have the perfect team and perfect location to mitigate these issues presented
in our SWOT analysis.
Regulatory Compliance
We have extensive experience operating cannabis facilities in highly regulated states. We
have an impeccable record in compliance. Never failing an inspection and have always
maintained regulatory compliance rules and regulations. Our regulatory team is composed of
three ideals of complete regulatory compliance: (i) Operating Compliance, (ii) Legal Regulatory
Compliance and (iii) Government Affair Regulatory Compliance. We will assign a Quality
Assurance Manager to oversee any dispensary we own in Fresno, to ensure our dispensary
complies with Fresno, State and Federal rules and regulations.
Adam Day, serves as our Chief Compliance Officer. He is responsible for making sure
ALL our operations follow local, state and national regulatory compliance codes. He has over 5
years of medical and adult-use cannabis regulatory compliance experience. Under Mr. Day’s
guidance our Company has never failed an inspection and has never faced a disciplinary action
by any regulatory body. He will be a key member of our Fresno mobilization plan.
Kevin Slaughter, JD, serves as our Company legal counsel. He has over 2 years working
as general counsel for our affiliated cannabis businesses. He is currently an attorney at Levenfeld
Pearlstein, he helped start their cannabis practice and is the lead counsel to all their cannabis
clients. His experience in navigating state-wide rules and regulations for limited license cannabis
proves as an invaluable resource to our Company’s growth in the industry.
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Fawn Pettigrew, serves as our Director of Government & Regulatory Affairs. She has
over 18 years of government regulatory affairs experience. She utilizes grassroot strategies to
protect and enhance our Company’s brand image when dealing with local government officials.
All products that are sold in our dispensary will have been tested by an independent
laboratory approved by the City Manager and State of California. All test results will be
available for customer display at our facility and in our dispensary website. This maintains
transparency between our customers and those that are looking for various forms of relief for
cannabis.
Our in-house regulatory compliance team is one of the best in the cannabis industry and
has always steered our business to being fully compliant, no matter the state. In every
jurisdiction, our Company has exceeded regulatory mandates to gain entry into a licensed market
and has maintained licensure by elevating its facilities to be the gold standard in cannabis
business operations. All will take continuing education courses, to understand any compliance
rule changes. We will be a market leader in Fresno in terms of product, compliance and customer
satisfaction.
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1.6 DAILY OPERATIONS. WITH AS MUCH DETAIL AS POSSIBLE, THE
BUSINESS PLAN SHOULD DESCRIBE THE DAY-TO-DAY OPERATIONS
WHICH MEET INDUSTRY BEST PRACTICES. THIS SHOULD INCLUDE AT
A MINIMUM THE FOLLOWING CRITERIA FOR EACH LICENSE TYPE IN
WHICH YOU ARE APPLYING FOR A PERMIT.
1.6.1 Fully describe the day-to-day operations if your applying for a retail permit:
a. Describe customer check-in procedures
Customer
Dispensing Procedures:
We will follow all rules
and regulations
outlined in SEC. 9-
3310. Upon entry to
our dispensary
customers are required
to first check in with
our security guard. As
customer enter, they
will notice on our
waiting area wall, we
will post our
dispensary license and
the hours of operation. Before we dispense any cannabis to a purchaser we must verify the age
of the customer checking a government-issued identification card by using our Flow Hub NUG
Mobile Scanner. The portable custom-build scanner is an iPhone like device used by our agents
to verify a customer’s age using a government-issued ID with authenticity software. The ID’s
barcode on the back is scanned. The security guard verify the validity of the government-issued
ID card and using our software platform, can place the customer in queue to be escorted to the
sales floor or schedule a private consultation with our dispensary agents. All customers will be
escorted to the sales floor by a dispensary agent, maintaining a 1:1 customer to dispensary agent
ratio, and will begin their shopping experience. Once the customer is escorted in the sales floor
and before closing any transaction, our dispensary agent must again verify the validity of the
government-issued ID by scanning the back with our Flow Hub NUG, which will pull up the
customers unique “Customer Homepage” and information to close out the purchase. Our
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35
led to speak with our agents in a private consultation room. A non-medical professional
will NOT provide medical advice to customers.
3. The agent will escort the customer to the sales floor, through the separate secured entry
door leading to the sales floor, the separate entry allows for smooth flow and movement
of customers and agents to prevent the spread of COVID-19. On the sales floor each
customer will receive advice on which products best suits their lifestyle. There will
always be a 1:1 ratio of customer to a dispensary agent on the sales floor and a few of our
agents will be floating in the sales floor to answer questions about products on display.
4. Customers will check out at one of our POS terminal locations. All terminals will be
more than six feet apart per our COVID-19 guidelines and for customer privacy. Our
agents will follow all procedures and dispense cannabis products, per our SOPs.
5. Upon completion of the transaction, the customer will be escorted to the sales floor exit
door leading back to the waiting area. As you can see from the diagram above, a separate
exit from our sales floor to the waiting room creates a smooth flow and movement of
customers and agents and a safe way to prevent the spread of COVID-19.
6. Customer exits the dispensary and is monitored until they get in their vehicle.
Customers will only have access to 4 areas in the dispensary: Waiting Room; Private
Consultation Room; Sales Floor (where the customer must be escorted at all times) and
Restrooms, designated for customers and not the public. We will have surveillance of each
customer at all times, (obviously not in the bathroom, but within entry and exit of the bathroom).
All restroom facilities will remain locked and under the control of management. SEC. 9-
3310(a)(6). The limited access to customers allows our security team to easily track customer
movement through our dispensary.
We will comply with SEC.9-3309(i)(1-4). Persons under the age of twenty-one (21)
years will not be allowed on the premises of a cannabis retail business or a commercial cannabis
business and will not be allowed to serve as a driver for a delivery service. It will be unlawful
and a violation of this Article for any person to employ any person who is not at least twenty-
one (21) years of age. The entrance to our business will be clearly and legibly posted with a
notice that no person under the age of twenty-one (21) years of age is permitted to enter upon the
premises of the commercial cannabis business. Persons at least eighteen (18) years old will be
allowed on the premises of a medical cannabis retail business to purchase medicinal cannabis or
medicinal cannabis products. The entrance to our business will be clearly and legibly posted
with a notice that no person under the age of eighteen is permitted to enter upon the premises of
our dispensary. Our facility agent will be trained to not violate the regulations by selling to any
person under the age eighteen (18) or to sell cannabis or cannabis products to any person under
the age of twenty-one (21).
After checking in, customers will be able to sit in our comfortable waiting area where
they can read information about our products, look at our digital menus – through stationary
tablets and learn about the Fresno cannabis program in our “Cannabis 101"library.
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Signage and Notices: We will comply with SEC. 9-3309(h)(1-6). Our facility signage will
conform to the requirements of Chapter 15, Article 26 of the Code, including, but not limited to,
seeking the issuance of a city sign permit. No signs placed on the premises of the cannabis
business will obstruct any entrance or exit to the building or any window. Each entrance will be
visibly posted with a clear and legible notice indicating that smoking, ingesting, or otherwise
consuming cannabis or cannabis products on the premises or in the areas adjacent to the business
is prohibited. Business identification signage will be limited to that needed for identification only
and will not contain any logos or information that identifies, advertise, or lists the services or the
products offered. Advertising will not be visible from the exterior of the establishment and will
be prohibited on the exterior of the establishment. No cannabis retail business or commercial
cannabis business may advertise by having a person holding a sign and advertising the business
to passerby, whether such person is on the premises or elsewhere including, but not limited to,
the public right-of-way.
Signage will not be directly illuminated, internally or externally. No banners, flags,
billboards or other prohibited signs may be used at any time. In accordance with state law and
regulations, holders of a commercial cannabis business permit shall be prohibited from
advertising any commercial cannabis business or cannabis retail business located in the city
utilizing a billboard (fixed or mobile), bus shelter, placard, aircraft, or other similar forms of
advertising, anywhere in the state. This paragraph is not intended to place limitations on the
ability of a commercial cannabis business or cannabis retail business to advertise in other legally
authorized forms, including on the internet, in magazines, or in other similar ways. In addition,
any cannabis advertising, including such advertising that is not connected to a cannabis business
operating in the city, using any means described above, is strictly prohibited within the city
limits.
Signage in the Dispensary: All signage will be posted inside the dispensary, in our public
access, limited access and restricted access areas will be no smaller than 24 inches tall by 36
inches wide, with typed letters no smaller than 2 inches. The signage will be clearly visible and
readable by all customers entering our facility. Signs will include the following statements:
“Cannabis consumption can impair cognition and driving, is for adult use only, may be habit
forming, and should not be used by pregnant or breastfeeding women”, “Edible cannabis-infused
products were produced in a kitchen that may also process common food allergens” and “The
effects of cannabis products can vary from person to person, and it can take as long as two hours
to feel the effects of some cannabis-infused products. Carefully review the portion size
information and warnings contained on the product packaging before consuming”.
Signs will be located in our sales floor (limited access area) area the only place where
cannabis and cannabis-infused products will be sold within our dispensary. We will have Spanish
versions of each sign or placard.
We will also post notices inside our dispensary that state activities that are strictly
prohibited and punishable by law, include:
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1. No minors permitted on the premises unless the minor is a minor qualifying medical
patient;
2. Distribution to persons under the age of 21 is prohibited;
3. Transportation of cannabis or cannabis products across state lines is prohibited;
4. Reselling any cannabis products may result in criminal charges; and
5. Diversion, Loitering, Public Consumption or Illegal activity is not permitted.
Dispensing Process/ID Capture: Dispensing may occur only in face-to-face transactions
with customers that have been verified by our security guard. We will follow all check-in and
verification procedures discussed above in our “Customer Dispensing Procedures”. Products will
only be sold to customers during business hours. Only designated dispensary agents can execute
transactions, which must take place at one of our point-of-sale machines on the sales floor.
We will not provide cannabis at no cost or free, unless the customer has built loyalty
reward points allowable for a discount, similar to a retail pharmacy or grocery store. We will not
make the dispensing of cannabis to a customer conditional upon the purchase of a device,
instrument or service provided at a dispensary facility or at a location other than the dispensary,
such as another dispensary facility.
A reliable inventory process is central to our operations and vital to our efforts to prevent
diversion, theft and to effectively recall products. Our inventory management practices reflect
this fact, combining thorough traceability for all cannabis products, with clearly delineated agent
job responsibilities and access limitations.
Our designated Chief Executive Officer (CEO) and Inventory Manager (IM) will have
primary oversight of our Inventory Tracking System (ITS), which will integrate with our point-
of-sale (POS) and Customer Relationship Management (CRM) system. Our Quality Assurance
Manager (QAM) will maintain quality control over our processes and audit our CEO and IM to
make sure we are following procedures outlined in our Inventory and Recordkeeping Plan,
among other things. Given our experience in tracking and having a perfect inventory record in
our other facilities we are confident our well-trained team will account for every product, down
to the gram, within our facility. Our ITS and POS systems will be real-time, web-based, and
accessible by the City Manager at any time. Our POS system will have the ability to track, at a
minimum the date of sale, amount, price, currency and product description including brand,
strain, cultivation or processor.
During our destruction procedures we will render all cannabis products unusable,
schedule destruction and contact the City Manager at a minimum 48 hours before destruction or
disposal. Destruction must be approved by the City Manager. We will contact the City Manager
using written approval for all scheduled destruction and disposal. All destruction will be
completed in a designated area with proper surveillance and captured in our ITS and electronic
documentation of destruction will be maintained for three years.
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INVENTORY MONITORING
Monitor Purchases
Our team has over 30
years of combined sales and
purchasing experience in the
cannabis industry. We plan to
maintain adequate supply of
inventory by tracking our
inventory daily (manually and
electronically), tracking and
understanding customer
purchase habits and building
relationships with Fresno and
California licensed cultivators
and processors to purchase
product wholesale. We plan on using a Customer Relationship Management platform, LeafLink
to provide best-in-class wholesale ordering. LeafLink is the largest online marketplace for
wholesale ordering of cannabis. It will provide our product purchasing team with a suite of
products including streamlined ordering, reporting tools and fulfillment and shipment queues.
As one of the leading CRM platforms, our Product Sales Supervisor will have the ability
to be alerted, through email or direct message when inventory of a various product is running
low as well as track all purchasing trends for future wholesaling purchases. LeafLink integrates
with BioTrack THC, METRC and Quickbooks, giving our dispensary agents the ability to
visually see the stock of each item while dealing directly with customers. Our CEO will set
automatic ordering for staple products, such as pre-rolls, various dried flowers and edible
products that quickly sell out (or hard to come products), similar to automatic refills for a
prescription at a pharmacy. Our CEO will be able to monitor and track products, batch and lot
numbers, weight, strains being purchased and used by customers to build future inventory. Along
with ordering, the system creates reports, such as detailed ordering summaries, products sold in a
certain time frame, summary of ordering status where products are in the chain of custody
procedures and even brand performance reporting – tracking how quickly various brands move
through our dispensary from shelf-to-sale.
When fully operational, we estimate to serve over 500 customers per day, each
purchasing over of cannabis products per day totaling monthly sales of close to .
Our team will need to have the most technologically advanced inventory system to track
customer ordering. Only our CEO, Dispensary Manager and Product Sales Supervisor will
access credentials to LeafLink and have the ability to order directly from cultivators, processors
and distributors. As we do in other states where we operate, to monitor purchasing and proper
inventory we plan to purchase 2-3 weeks’ worth of cannabis product. This allows are dispensary
Sales Dashboard –Tracking Orders and Sales
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agents to sell products at a
steady pace, while we
continue to build inventory
as our customer base grows.
The platform ensures our
agents select products from
the oldest stock of a
cannabis product and
distribute first. The system
also allows our agents to
monitor payment, create
payment terms, instruct
shipping details (times of
delivery), as well as track our dispensary agents individual sales to determine which brands and
products they tend to sell.
Denial of Sales: Our agents will verify the age of the purchaser by checking a
government-issued ID card by use of our electronic reader or electronic scanning device. We will
deny the entry to our dispensary and deny the sale of product to anyone under the age of 21 years
old at the date of sale, unless they are a medical customer and are at least 18 years of age. We
will deny sale to anyone without proper identification, which includes a government authorized
ID (state driver’s license, state identification or passport). If our dispensary agent can not
properly identify the person on the ID with the customer, they will be trained to deny the sale
and record the denial of sale in our electronic database. If we discover a fake ID is being used,
we will confiscate the ID, notify local law enforcement and report the incident to the City
Manager. We will have a ZERO tolerance policy of allowing sales to individuals minors.
Inventory Tracking System
We will use it as an electronic management system to track our inventory in real time and
integrate to a point-of-sale. This includes all receipt of product, movement of product within the
facility, and dispensing of product or other disposition (such as a return to the cultivator,
processor or distributor). As a result, the City Manager and law enforcement, if requested will
have twenty-four hours a day, seven-day per week access to all of our inventory and dispensing
activities online, through the ITS and CRM platforms. The system also can generate warning
flags, such as notification alerts to our CEO if any inventory data or reports are overwritten by
manual entry. Per SEC 9-3309(e), our business will a management inventory tracking system
that can track and report on all aspects of the business including, but not limited to, such matters
as cannabis tracking, inventory data, gross sales (by weight and by sale) and other information
which may be deemed necessary by Fresno. Our CCB will ensure that all information is
compatible with the city’s record-keeping systems. In addition, they system will have the
Ordering Summary –Tracking Wholesale Orders
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capability to produce historical transactional data for review. Furthermore, any system selected
will be approved and authorized by the City Manager prior to being used.
Data Contents: Our ITS will document the following: (1) each sales transaction at the
time of sale and each day’s beginning inventory, acquisitions, sales, disposal and ending
inventory; (2) acquisition of cannabis and cannabis processed products a California or Fresno
licensed cultivation, processor or distributor. This includes a (i) description of the products,
including the quantity, strain, variety and batch number of each product received, (ii) the name
and registry identification number of the licensed cultivation, processor or distributor providing
the cannabis and cannabis infused products, (iii) the name and registry ID number of the
transportation agent delivering the cannabis, (iv) the name and registry ID number of our
dispensary agent receiving the cannabis, and (v) the date of acquisition; (3) the disposal of
cannabis which will include a description of the products (quantity, strain, variety, batch number,
reason for disposal), the method of disposal, the reason for disposal (damaged, defective, expired
or contaminated) the date and time of disposal.
Our ITS will also capture a great deal more data. This includes: complete product
descriptions such as serial numbers and dates of expiration; records of physical inventories
(daily, monthly, and annual); product location with the facility; RFID records of agent movement
and product movement within the facility; customer identification and visits; visitor logs;
maintenance logs; purchase and sale transaction details (including agents involved); and
quarantined product (damaged, defective, expired or contaminated medical marijuana product
awaiting return to a grower/processor or disposal), among others.
Access Credentials: We ensure the validity of accountability for the data in the system by
limiting access to the ITS, CRM and POS systems based on each agents’ job functions. This also
limits the potential for human error. Agent access is tracked via passwords. The highest level of
access is reserved for the CEO. The CEO will designate agent access, which includes the
Inventory Manager, CEO, COO and Dispensary Manager. These are the only positions with the
credentials to load product inventory into the system or to update the product location in the
system. This level of access corresponds to our restrictions on agent handling of cannabis
products as only these positions have access to the Vault Room, where final product is kept, and
product may only be moved into or out of the Vault Room by them or under their immediate
supervision. The Security Manager has visibility to all system data including inventory but does
not have credentials to alter inventory or change its location.
The intermediate level of access is reserved for Dispensary Agents. They have system
authority to execute transactions which move automatically removes product out of inventory.
They can do so only using the point-of-sale equipment on the sales floor and only after a
customer’s identification has been downloaded to our system. The lowest level of access is for
the security guard. The guard is responsible for confirming customer identification and
uploading copies to the city’s verification system. The guard also has authority to enter
information and scan IDs for receiving delivery team personnel and visitors. The guard has no
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authority to execute any inventory change. Our inventory control and reporting system will
accurately document the present location, amounts and descriptions of all cannabis and cannabis
products for all stages of the growing and production or manufacturing, laboratory testing, and
distribution processes until purchase as set for MAUCRSA, per SEC 9-3331(c).
Receipt of Inventory/Transportation Manifest
We accept delivery of cannabis products only from licensed distributors. Delivery will
take place in the rear of the building, in our enclosed Receiving, Shipping and Loading (RSL)
area, under full surveillance and security procedures. The Security Manager verifies the
Transportation Manifest and credentials of the transport vehicle and delivery team and logs the
information before open our receiving gate to the vehicle. Our CEO, Security Manager and an
authorized Dispensary Agent will handle all deliveries to our dispensary. The CEO along with
the Inventory Manager (IM) will count and physically scan each product and confirm the
product’s name, strain name, weight and identification number on the manifest matches the
information on the cannabis products label and package. The product name listed, and the weight
listed in on the manifest shall match the product packaging.
The CEO and IM while also examining all packages for signs of tampering, damage or
expiration. Once the CEO and IM has verified against the Transportation Manifest, the CEO and
IM will provide the transportation team with a receipt of the delivery. The manifest and receipt
are scanned into the Inventory Tracking System. Newly delivered items are immediately stored
in our Vault Room where the CEO and IM will upload each package into the ITS, recording its
location in the Vault. The product list is updated and will include all information on the new
products including, name, type, and weight and quantity.
Movement of Inventory To/From the Sales Floor
Per our procedures, product can be located in one of only three locations within the
facility: (i) the Vault Room; (ii) the locked cabinets in the restricted access area portion of the
dispensary; or (iii) a quarantine container within the Vault Room that stores recalled or damaged
product. Every time a unit of product is moved from one area to another, we indicate this in the
ITS. This enables management, agents and the City Manager to know in real-time where each
unit of product is located. When product is sold, it is automatically deducted from the rolling
inventory on our ITS and POS and the product list is updated.
The Vault Room is used for storage of cannabis products, not for direct dispensing. Only
the CEO and designated Level 4 agents have access credentials. At the beginning of each
business day, the CEO, IM and Dispensary Manager selects from the Vault the amount of
product expected to be sold during the day and moves it themselves, or under their supervisions,
via the inventory cart to the locked cabinets on the sales floor. The CEO and IM are responsible
to update the ITS in real time using handheld scanners at each location to reflect the change in
location. If the supply proves insufficient for the day’s sales, the CEO and IM can obtain
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additional product form the Vault Room following these same procedures. At the end of the day,
the CEO and IM follows the procedure in reverse, moving the unsold product back to the Vault
Room and updating the location in the ITS and POS.
Movement Logs: After the CEO, or Dispensary Agent under his/her direct supervision
finishes, stocking the staging area and display cases (i.e., the secure, locked display cabinets on
the sales floor), s/he must confirm the product inventory by signing the “Daily Inventory Log”
reflecting the product moved to the staging area. Similarly, after the CEO, or Dispensary Agent
under his/her direct supervision finishes, moves the unsold product back to the Vault Room, s/he
completes the log. This log will be kept manually and scanned electronically daily and kept on
file in our secured filing cabinet for three years.
Physical Inventories
Our inventory control procedures include conducting daily inventory reconciliation and
reviews documenting and balancing cannabis inventory by confirming the city’s verification
system matches our POS system and the amount of physical product at the dispensary. Our CEO
and Inventory Manager will conduct daily, monthly and annual comprehensive inventories,
which include opening and closing accounts of product. We will keep records in the ITS
documenting each inventory, which includes the date of the inventory, a summary of the
inventory findings, and the agent identification numbers and titles or positions of the individuals
who conducted the inventory.
Opening and Closing Inventory: Daily inventory count will be completed at the start and
close of each business day to minimize the risk of loss, theft or diversion of cannabis product.
The CEO, IM and an authorized dispensary agent under direct supervision will conduct a
physical inspection of the inventory to account for each unit of product. One agent will conduct
the inventory, count and scan the products, while the other agent witnesses and records the
product results.
The findings are logged on the “Daily Inventory Log”, noting name of the agent;
title/position; summary of each product inventory; any discrepancy; and agent signature. The log
will be kept in a binder and scanned electronically so that it can easily be produced for the City
Manager upon request. At opening, the CEO or Dispensary Manager will compare the physical
product with the inventory record from the previous end of business day, using our ITS and POS
track and trace scanners. At closing, the CEO and IM will compare the physical inventory to the
opening inventory plus any sales or deliveries during the day. Should there be any discrepancy,
we will follow our discrepancy procedures discussed in our SOPs. If there happens to be an
inventory discrepancy our CEO will notify the City Manager immediately and must receive
approval from the City Manager before completing an inventory adjustment. We will provide a
detailed reason for the adjustment and review our inventory procedures to ensure a discrepancy
does not repeat itself. All inventory adjustment documentation will be kept on location for 2
years from the date performed.
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If our CEO or IM identifies an imbalance in the amount of cannabis after the daily
inventory reconciliation due to mistake, we will determine how the imbalance occurred and
immediately upon discovery take the document corrective action. If we can not identify the
reason for the mistake within 2 calendar days (48 hours) after first discovery, we will inform the
City Manager immediately in writing of the imbalance and the corrective action taken to date.
Our staff of experienced inventory agents will work diligently to determine the reason for the
mistake.
If our CEO or IM identifies an imbalance in the amount of cannabis after the daily
inventory reconciliation due to theft, criminal activity or suspected criminal activity, the CEO
will immediately determine how the reduction occurred and take and document corrective action.
Our Company has a ZERO tolerance policy for diversion of product or currency. If an agent is
suspected of diverting product or currency, they will be immediately put on temporarily agent
leave and our team will conduct a thorough investigation. If our findings show a diversion of
product or currency, we will notify the City Manager and Fresno law enforcement in writing
within 24 hours and the agent will be immediately terminated from our dispensary. Within 24
hours after the first discovery of the reduction due to theft, criminal activity, or suspected
criminal activity, our CEO will inform the City Manager and Fresno law enforcement in writing.
Only the CEO, Level 4 agents and dispensary agents under direct supervision are allowed
in the Vault Room. Their entry into the Vault Room and identities are also logged. During
opening and closing inventory, we will also ensure that there is no expired or damaged product
and that the tamper resistant seals are intact. Any such product will be put into Quarantine
Product Lock Boxes located in the Vault Room, with that change being noted in our ITS and
CRM.
Monthly Inventory Reviews and Annual Audits: In addition to the beginning-of-day and
end-of-day inventories, we will conduct monthly inventory reviews and annual comprehensive
inventories of all cannabis at our facility. Our Chief Financial Officer (CFO) and Controller will
file annual compilation reports with the City Manager, including financial statements but not
limited to, income statements, balance sheets, profit and loss statements, statement of cash flow,
wholesale cost and sales, as well as inventory working capital statements or other documents
requested by the City Manager in writing. Our CFO has experience maintaining these documents
at our other cannabis locations across the United States and will include any other information
the City Manager deems necessary in order to effectively administer the rules in the Act. The
financial statements will be filed with the City Manager within 60 days after the end of the
calendar year and the compilation report will include a letter authored by a licensed certified
public accountant (CPA) that states they have REVIEWED all documents necessary and the
documents are accurate based on the information provided. Even though our financial documents
do not need to be audited, unless required by the City Manager, we will conduct annual audits
prepared in accordance with Generally Accepted Accounting Principles (GAAP) by an outside
auditor or CPA.
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Records Retention: We will maintain all inventory data required by the City Manager in
electronic format or written format and back up electronic copies onto our secure server located
in our Security Information Technology Room (SITR) within our restricted access area for a
minimum of three years from the date on the document. We will provide any documentation
required to be maintained in this section to the City Manager for review and if we are
maintaining a bank account, retain for a period of three years a record of each deposit or
withdrawal from our account. We are confident that by combining the inventory control features
provided by METRC or BioTrack THC and LeafLink with our internal monitoring inventory
procedures, we will be able to track and maintain accurate inventory data in compliance with all
laws and regulations and thereby prevent diversion, imbalances and other criminal activity.
In addition, maintaining our own, separate inventory controls will enable us to ensure
accurate record keeping if our ITS or CRM system is not functional for any period of time.
Should there be any discrepancy during any inventory, we will report it to the CEO and to the
City Manager within 24 hours of discovery and follow our anti-diversion procedure. Before
issuing a customer return policy we will seek prior approval from the City Manager.
b. Identify location and procedures for receiving deliveries during business
hours
Receiving, Shipping and Loading Dock
Ordering and Preparation for Delivery: Product ordering is conducted by our Product
Sales Supervisor (PSS) and Dispensary Manager (DM), with guidance by our Inventory Manager
(IM) all under the supervision of the CEO. The Dispensary Manager may only order such
quantities and varieties of products as are required to meet our dispensaries reasonably expected
near-term requirements. We will make orders daily or every week depending on demand. We
like to maintain 2-4 weeks’ worth of inventory in our Vault Room in case of a product shortage
while keeping our customers favorite products in stock. All products we order will be obtained
from a California licensed cultivator, processor and distributor. Our wholesale ordering and
Customer Relationship Management (CRM) and point-of-sales (POS) platforms, LeafLink and
Flow Hub respectively, will allow us to track our inventory and make wholesale orders of
product more user friendly and back up our customer data and buying habits through our POS
integration. By eliminating the guessing of wholesale orders our dispensary agents will be more
efficient in their day-to-day customer experience and our facility will not waste money buying
products that our customers have little to no interest.
The CEO must confirm each order for it to be valid, needing all responses in written form
of communication. Delivery may only be scheduled for a date/time when the CEO, DM and a
Security Guard are at the facility.
Preparing for Receipt of Cannabis Deliver: The day before any cannabis is transported to
our dispensary, we will request an electronic manifest from the distribution business, at least 24
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hours in advance. The manifest will be faxed or emailed to our CEO and Dispensary Manager
with the precise details of the delivery, including: the identification of the delivery team
members accompanying the transport; the transport vehicle license plate number; the date and
approximate time of departure; the date and approximate time of arrival; and the quantity, by
weight or unit, of each cannabis batch or lot contained in the transport, along with the
identification number for each batch or lot.
Our dispensary will request to receive a call that indicates the transportation vehicle is
twenty minutes away from our dispensary. From the time that our dispensary facility is in view,
until the delivery team has safely departed the dispensary, the focus of the Receiving Team will
be to ensure a safe and secure delivery. As such, security personnel will remain vigilant for any
suspicious activity inside, outside, or in proximity of our facility.
The Receiving, Shipping and Loading Area: The Receiving, Shipping and Loading (RSL)
area consists of a fenced in, enclosed loading area. The privacy gate is 10 feet tall with barbed
wire, making it impossible to climb, breach or see inside. The gate will also have motion sensors
that will detect an intruder touching, cutting or smashing the iron gate. Immediately off to the
rear, includes a mantrap that secures and separates the interior of our dispensary from all delivery
activity. Our dispensary will only accept cannabis deliveries using our RSL restricted access
area. Deliveries will NOT be accepted through our public entrance or any limited access area,
unless otherwise approved by the City Manager. All areas of facility were designed to comply
with all State and Fresno building, fire and zoning requirements or regulations, including our
RSL area.
Receiving Operations and Staffing: Ideally, we would like to receive delivery of product
in the early am, before opening of business. We understand and will request deliveries to arrive
during business hours before 5:00pm. If deliveries are during regular business hours our
Receiving Team will be prepared to possibly suspend or conclude a customer interaction until
the delivery process is complete. All persons not specifically involved in the receiving process
will continue to do their daily tasks but will be asked to be vigilant of any suspicious behavior.
Our security team will monitor the Receiving, Shipping and Loading area cameras at all times
during delivery, and the CEO, Dispensary Manager and security guard overseeing delivery will
maintain situational awareness.
Workflow During Delivery: We use the following workflow to ensure safety, security
and accountability for all cannabis products delivered to the dispensary and described in more
detail in the following:
1. The Receiving Team will consist of our CEO, Dispensary Manager, a designated
Dispensary Agent and our Security Manager or a Security Guard.
2. Our dispensary Security Manager will meet the delivery vehicle at our RSL gate, in
the rear of the dispensary and, after proper verification, open the automated gate and
allow the delivery vehicle into the gated and enclosed area. Our RSL area will be
large enough to fit any size sprinter, truck or van typically used for delivery of
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product. The gate will close, and the Security Manager will begin a thorough
inspection of the vehicle.
3. The CEO and the Dispensary Manager will compare the delivery to the transportation
manifest with all delivered items. Our CEO along with the Dispensary Manager will
inspect and count product before finalizing the delivery;
4. If there is any discrepancy between the product delivered and the product listed on the
transportation manifest, the CEO will immediately alert the Manager at the
cultivation center and processor. If we suspect theft or diversion, we will immediately
notify the City Manager and law enforcement.
5. All packages will be checked for expiration date and to ensure that they are
undamaged and that the seal is intact.
6. Once accepted, inventory will be logged and scanned into our Inventory Tracking
System. All products will be sorted and stored in the appropriate inventory carts,
within our Vault Room and we will follow our inventory management procedures,
including labeling all products to include our legal dispensary name on the packaging.
Acceptance Procedures: Upon each delivery, at least two members of our Receiving
Team will immediately conduct a thorough inventory of the cannabis products delivered in order
to compare it to the transport manifest sent the day prior as well as to the transport manifest
provided at the time of delivery. If this inventory is accurate, meaning what has been physically
delivered matches the transport manifests, these employees will then follow our inventory
policies and procedures. Each employee will sign and countersign the manifest to attest to its
accuracy and print a receipt to provide to the delivery team. We will use handheld barcode
scanners in the secure enclosed area to scan the unique barcode of each cannabis product into the
product description module of our ITS and POS software. The module will create and auto -
populate unique “Product Descriptions”. Each product description includes, but not limited to
product category (flower, edibles, topicals etc.), brand, product name, product type, description
of the product, batch number, batch date, invoice number, weight and test results. Our CEO can
assign security levels so only designated employees have the ability to manually change or
upload test results for each product (as they vary from product to product).
We will, if requested, provide a copy of a printed transportation manifest (or copies of
our Receiving, Shipping and Loading logbook), and any printed receipts for cannabis being
transported to our dispensary, to the City Manager, its authorized agents, or to law enforcement.
Unloading Procedures: As indicated previously, all delivery vehicles will be unloaded in
our secure and enclosed RSL area. Delivery vehicles will be parked in view of our surveillance
camera(s) for real time viewing and so any potential incidents can be recorded. Unloading will
commence only once the vehicle is securely in the RSL area and the gate is closed. At that time,
the team will confirm that the RSL is securely locked, gate and entrance to the man trap is not in
use. The Receiving Team will then unlock the secure container(s) for that delivery and scan the
barcode for each item being delivered. The real time reporting allows our CEO to verify the
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delivery and minimizes any opportunity for diversion by our employees. For each package, the
team member will visually confirm that the package appears to be intact and that the proper
labels are affixed. In the event of a discrepancy between the scan and the electronic manifest, or
if an item appears to be expired or damaged, the team member will photograph the package(s)
and contact our CEO or COO for further instructions. All of this can be done using our mobile
handheld scanning device.
Once unloading has been completed, one member of the transport / delivery team and one
member of our receiving team will both sign the Transportation Manifest with each team
member retaining a copy of the document. Our CEO will then provide the delivery team with a
printed receipt for the cannabis products received. The transport / delivery team member will
confirm that the manifest and the receipt agree and will contact the Security Manager to release
and open the RSL area gate to exit.
We will keep all completed transportation manifests and receipts on file, in print and
electronically scanned, as well as copies of our transportation logbook for three years, copies of
which will be available to the City Manager or to law enforcement upon request.
Evidence of Adverse Loss During Transport: If any dispensary employee discovers
evidence of, or reasonably suspects, a theft or diversion of cannabis products during transport, or
should there be any discrepancy in the transportation manifest upon delivery and the
quantity/description of the items to be delivered (including, but not limited to, a shortage of
product or product that was not ordered), the dispensary agent will immediately notify the CEO,
Dispensary Manager or Security Manager. The Security Manager will immediately alert the City
Manager and law enforcement of any loss or diversion is suspected. The Security Manager will
also conduct an investigation and preserve all surveillance video and data associated with the
delivery.
As mentioned in our Security Plan, we have a ZERO tolerance policy when it comes to
diversion or theft of any kind. If we suspect a transportation company employee or one of our
employees of stealing from our company, we will immediately place that employee on
administrative leave, remove all access control, conduct an investigation, gather security footage
and notify the City Manager and law enforcement. If subsequent investigation confirms
misconduct, we will terminate that employee and, if appropriate, refer him or her for prosecution.
Inventory following acceptance/ Notifications: Upon getting an appropriate count of all
products, the CEO and designated employee will immediately place the received products into
the Vault Room and update the inventory log in our ITS. The CEO will then update our ITS with
the all information deemed necessary by the City Manager regarding the accepted product as
well as any returned product. Our Inventory Tracking System, Customer Relationship
Management and Point of Sale platform all works together and automatically integrates in real-
time.
Surveillance and Recording: We will follow all security procedures outlined in SEC. 9-
3310(b) Security Measures in our security plan. The interior of the RSL area are equipped with
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surveillance cameras and signs indicating that the area is being recorded. The on-site security
guard will observe the RSL area and mantrap throughout the receiving process, using the
monitor behind the reception desk. All lighting outside and inside the dispensary will be in good
working order and wattage to make sure cameras can record properly.
Training: As part of the onboarding process, all dispensary agents will be trained and
tested on our receiving procedures, including participating in no less than five mock deliveries.
We will train on all possible scenarios – including theft, diversion, transportation manifest
mistakes etc. our team will be prepared for all scenarios. All agents must be able to conduct the
above procedures before passing loading and receiving training.
STORAGE AND INVENTORY OF CANNABIS
Our dispensary will approach the storage of cannabis with three main goals: (i) our
storage facilities match the expected volume of daily customers; (ii) ensuring that we maintain
product quality and potency; and (iii) limiting access to prevent diversion and/or theft. These are
critical goals, core to our mission of providing safe unaltered quality products to all customer,
and fully achievable through robust product storage policies and procedures. All storage areas
will be maintained in accordance with security requirements in SEC 9-3310(b). As explained
below all cannabis will be stored at appropriate temperatures and under appropriate conditions to
help ensure that its packaging, strength, quality and purity are not adversely affected.
Physical Storage Measures: All cannabis products in our facility will be stored only in
one of three locations: (1) the Vault Room; (2) the locked cabinets (safes) in the restricted access
area behind the sales counter in our sales room; or (3) quarantine container within the Vault
Room that stores recalled or damaged product. All inventory of product will be stored on
premises and secured in our restricted access area and tracked consistently within our inventory
tracking rules. Our Company prohibits the following: (i) a single employee completing inventory
in the Vault Room and/or placing cannabis in the locked secure storage areas behind and under
the sales counters without supervision; (ii) any Level 3 or below employee entering the Vault
Room alone; and (iii) leaving the Vault Room unlocked or unarmed. Cannabis products in our
facility will always be stored in plain sight of our surveillance system.
Every time a unit of product is moved from one area to another, we indicate this in our
ITS. This enables management, employees and the City Manager to know in real-time where
each unit of product is located. When product is sold, it is automatically deducted from the
rolling inventory in our ITS, CRM and POS software and the product list is updated.
Vault Room: The Vault Room is used for final storage of all cannabis products. Per
standards set by our Director of Security and our architect, the Vault Room will be located
centrally, in our back office area near the back-interior of the facility (i.e., away from the main
road and parking) and constructed in compliance with 21 CFR 1301.72(a)(3), DEA’s
requirement for Schedule I Controlled Substances.
1. Our walls, floors and ceiling of our Vault Room will be constructed of the following;
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a. 8-inch reinforced concrete,
b. (i) 18-gauge structural studs made of galvanized sheet metal meeting
requirements of ASTM A1003, (ii) 9-gague, Type II, Class 1 carbon steel
security mesh and attachment clips meeting ASTM F1267 on either side of the
studs, and (iii) an interior covered by UL and ULC Classified, Type X (per
ASTM C1658), impact-resistant, moisture-resistant, noncombustible gypsum
board tested to ASTM E136; or
c. comparable materials and standards.
2. The door and frame unit of a vault should conform to the following specifications or
the equivalent: 30 man-minutes against surreptitious entry, 10 man-minutes against
forced entry, 20 man-hours against lock manipulation, and 20 man-hours against
radiological techniques;
3. A vault, if operations require it to remain open for frequent access, should be
equipped with a "day-gate" which is self-closing and self-locking, or the equivalent,
for use during the hours of operation in which the vault door is open;
4. The walls or perimeter of a vault should be equipped with an alarm, which upon
unauthorized entry transmits a signal directly to a central station protection company,
or a local or State police agency which has a legal duty to respond, or a 24-hour
control station operated by the registrant;
5. The door of a vault should be equipped with contact switches.
Per 21 CFR 1301.72, the Vault Room will have proper man-minutes / man-hours
specifications for forced entry, all vaults will be bolted or cemented to the floor, equipped with
alarm system that will be triggered in an unauthorized or forced entry. It is a Level 4 restricted
access area, meaning only the CEO, Dispensary Manager and Security Manager have access
credentials. A diagram at the end of this section shows the Vault Room, storage and cabinet
locations within the facility.
At the beginning of each business day, the CEO, Dispensary Manager or Inventory
Manager selects from the Vault Room the amount of product expected to be sold during the day
and moves it, under security and surveillance supervision, via the inventory cart to the locked
cabinets on the sales floor. During this process, the agents will re-inspect all product for quality
assurance purposes, and in order to make sure the product has not expired, been in any way
damaged and/or deteriorated, recalled, and/or opened and/or otherwise breached in any way. If
products are outdated, damaged, deteriorated, misbranded or adulterated we will segregate and
destroy with written documentation. The CEO or Dispensary Manager is responsible for
updating our ITS in real time using the scanner at each location to reflect the change in location.
If the supply proves insufficient for the day’s sales, the CEO or Dispensary Manager can obtain
additional product form the Vault Room following these same procedures. At the end of the day,
the CEO and Dispensary Manager follows the procedure in reverse, moving the unsold product
back to the Vault Room and updating the location in our ITS.
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At the close of business each day, the CEO or Dispensary Manager will take stock of any
products remaining in the sales floor cabinets and contact the Product Sales Supervisor to order a
sufficient supply for the next week expected sales. The Inventory Manager is responsible to
update our ITS in real time using scanner at each location to reflect the change in location.
To help ensure against dispensing error and to assist in quarantining product in the event
of a recall, the Vault Room will be divided into separate storage racks that will be color-coded
and labeled based on the final product stored on the rack. There will be color coded racks, rows
and bins dedicated to brands with various products, including but not limited to: flower, vape
cartridges, capsules, tinctures, topical, concentrates and edibles (for example, flower may be
assigned the color purple such that all flower are stocked in purple racks, rows or bins). Products
will be organized with THC or CBD and popularity of product with customers.
We will also have a refrigerator if products need to be stored at temperatures below our
Vault Room temperature. We maintain separate, marked Quarantine Product Lock Boxes within
the Vault Room for the storage of recalled or damaged product which are labeled:
“HAZARDOUS WASTE/RECALL PRODUCT – DO NOT DISPENSE.” These boxes will be
moved to our Quarantine Room, at the end of each day or as needed, in our RSL upon following
our destruction protocols.
The interior and exterior of the Vault Room are under constant video surveillance. Access
to the room requires both RFID access card reader and a 4-6 digit access code or biometric
fingerprinting scanner. The keypad is programed with a separate code for each credentialed
person or biometric fingerprinting access as well as a holdup alarm code.
The Vault Room will be temperature controlled to maintain freshness and pureness of all
inventory. It will have a separate HVAC system from the main facility that will be used solely to
control the temperate, humidity, and airflow within that room. All our storage facilities will
maintain adequate lighting, ventilation, temperature, humidity control and equipment. The
primary control systems/settings will be:
• Lighting – within the Vault Room we will use LED occupancy energy efficient lights
controlled with override lighting to a desired 1,000 LUX, lumen/m squared. The purpose
of which is to provide ideal conditions for the visual inspection of our cannabis products.
• Ventilation & Air Purity – as a part of the closed loop filtration, all air will be circulated
and cleaned utilizing carbon and EnviroKlenz filters for the purposes of air purity
(reduction of particulate) and for odor control elimination. The EnviroKlenz technology
is a highly effective “destructive absorbent” material designed for chemical containment
and neutralization.
• Temperature – control for the Vault Room shall be independent of the rest of the
dispensary to provide ideal conditions for product storage and integrity of stored cannabis
product so as not to exceed 65 degrees Fahrenheit.
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• Humidity – will be controlled through a closed loop system of filtration and removal of
air moisture and the reintroduction of water content to achieve and maintain the desired
humidity level of 55% (+/- 2%). This level of humidity will optimize terpene retention
while reducing the potential for mold to form.
The room itself is designed to be a cool, low energy usage room with proper ventilation,
temperature and humidity control equipment. Our procedures ensure little activity or movement
of the product because of such things as rough handling, high heat, light and/or air exposure may
lower the quality and potency of the product and/or may lead to inadvertent product
contamination.
Movement logs: After the CEO or Dispensary Manager under direct supervision finishes,
stocking the staging area and display cases (i.e., the secure, locked display cabinets on the sales
floor), they must confirm the product inventory by signing the “Daily Inventory Log” reflecting
the product moved to the staging area. Similarly, after the CEO or Dispensary Manager under
their direct supervision closes the dispensary for the day, all unsold product moves from our
secured sales cabinets back to our Vault Room and the Daily Inventory Log is completed. This
log will be kept manually and scanned electronically weekly and kept on file in our secured
filing cabinet for three years.
Sales Floor Secure Cabinets: A moderate supply of daily cannabis products will be stored
in the secured, locked cabinets on the sales floor, during business hours ONLY. Per SEC 9-
3310(a)(5), our business will only have the quantity of cannabis and cannabis products readily
available to meet the daily demand for sale on-site in the retail sales area of the premises. This
allows for quick but secure access to conduct a sale to customers. The cabinets are located
behind the sales counter and Point-Of-Sale terminals in the restricted access sales area. This is a
Level 3 secure area, accessible to the CEO, Dispensary Manager, security guards and designated
dispensary agents. Dispensary area storage cabinets will be bolted or cemented to the floor or
wall in such a way that they cannot be readily moved and will be equipped with an alarm system
which, upon attempted unauthorized entry, will transmit a signal directly to a central protection
company or a local or State police agency which has a legal duty to respond. All cabinets will
have RFID access card technology to unlock, again tracking which of our dispensary agents is
opening each cabinet.
At the beginning of each business day, the CEO and Dispensary Manager selects from
the Vault Room the amount of product expected to be sold during the day and moves it into the
locked cabinets, updating our ITS. The cabinets work in conjunction with our POS terminals,
allows us to track in real time if product is located in the storage cabinet or Vault Room.
Designated dispensary agents have system authority to execute transactions for product in the
cabinets only using the point-of-sale equipment on the sales floor. All product samples will be
displayed in our display cabinets in our Level 3, restricted access area, on our sales floor. All
cannabis samples will be in a sealed container and have not more than 1 gram of each flower
product for viewing within the sealed container or display case.
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locked restricted access Quarantine Product Lock Box located within the Vault Room. Using the
Vault Room to quarantine these products allows the dispensary to keep all such products highly
secured until they can be properly destroyed or disposed of by our dispensary.
Employees tasked with quarantine transfers must inspect all quarantined products and
product packaging to assess the integrity of the containers, the likelihood of the spread of
contamination to our facility or to other inventory, any health, sanitation, safety, or security
threats posted by such products; update our Inventory Tracking System to reflect the transfer of
the products to the Quarantine Product Lock Box; update the City Manager’s electronic tracking
system (if applicable).
Once all proper inspections have taken place and the proper records have been updated,
the Dispensary Manager will store all affected cannabis products in the appropriately designated
commercial-grade, lockable and air-tight storage bin in the Vault for safe storage of the
quarantined products. These storage bins will be used as single-purpose, dedicated units for the
secure storage of specific types of quarantined products (i.e. one bin for expired products, one
bin for contaminated products, one bin for recalled products, etc.). The lettering on the labels of
these dedicated bins will be in red ink with letters a minimum of two (2) inch tall.
To the extent possible, no expired, damaged, deteriorated, mislabeled, contaminated,
recall-ed, or opened or otherwise breached products should remain at the dispensary more than 7
calendar days. Regardless, quarantined products will remain in the Quarantine Product Lock Box
in the Vault Room until such time as the products are destroyed by our CEO and disposed of a
local waste company.
Under no circumstances will any cannabis product that has been placed in quarantine for
any reason be dispensed and/or re-dispensed to a customer.
Vault Room Access Restrictions: The Vault Room is protected from unauthorized access
through our use of various security and surveillance technologies, including RFID access card
readers, motion sensors, keypad, hold-up, panic and duress alarms, as well as electronic and
mechanical locking systems. The Vault Room entry door will have a dual-access control that
requires both a RFID access card reader and a 4-to-6 digit pass code for entry or biometric
fingerprinting access. Furthermore, entrance to the Vault Room will be restricted to a bare
minimum number of employees and can only be accessed by Level 4 employees (e.g. the CEO,
Dispensary Manager, Security Manager), which is the highest clearance level at our dispensary.
We will require that two employees, including one of our Level 4 employees, be present when
anyone is entering the Vault Room. The Vault Room will also be under constant video
surveillance with cameras mounted on both the inside and outside of the room which will be
capable of providing a 360-degree view of the Vault Room, 24 hours a day, 7 days a week, 365
days a year.
To track all movement in and out of the Vault Room, our security technology will
electronically track and log all individuals who enter or exit the Vault Room via RFID card
access readers or fob readers (all employee identification badges and visitor passes contain RFID
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technology). We have developed further security protocols to prevent human error in terms of
access to the Vault Room, including receiving alerts when a non-Level 4 employee’s access card
is physically located in the Vault Room or if the Vault Room door is ajar for more than 30
seconds. Additional protocols for access to the Vault Room include:
• No employee may enter the Vault Room alone and must include a designated Level 4
employee.
• Before entering the Vault Room, employees with the appropriate level of clearance must
log enter the date, time and reason for going into the Vault Room. A second authorized
employee will then confirm the information.
• The CEO, Dispensary Manager and Security Manager shall be the only persons with the
list of employees who have access to the Vault Room.
• The CEO, Dispensary Manager and Security Manager shall be the only persons with
access to any PIN codes and/or passwords required for accessing the Vault Room.
Inventory Management Process: A reliable inventory process is central to our operations
and vital to our efforts to prevent diversion and to effectively recall products. Our inventory
management practices reflect this fact, combining thorough traceability for all cannabis products,
with clearly delineated employee job responsibilities and access limitations. We will not enter
into exclusive agreements with any cultivation or processor. When ordering wholesale products,
we will us our wholesale ordering and Customer Relationship Management platform that
integrates with our ITS and POS. We plan to provide all our customers with an assortment of
products and no single supplier will be more than 40% of the total inventory available for sale.
Our ITS and CRM software can track what percentage of supplier we are carrying in inventory
and we will install system alerts if an order reaches 40% of our total inventory.
Our inventory control procedures include conducting daily inventory reconciliation and
reviews documenting and balancing cannabis inventory by confirming the State’s verification
system matches our POS system and the amount of physical product at the dispensary. Our CEO
and Inventory Manager will conduct daily, monthly and annual comprehensive inventories,
which include opening and closing accounts of product. We will keep records in the ITS
documenting each inventory, which includes the date of the inventory, a summary of the
inventory findings, and the agent identification numbers and titles or positions of the individuals
who conducted the inventory.
Opening and Closing Inventory: Daily inventory count will be completed at the start and
close of each business day to minimize the risk of loss, theft or diversion of cannabis product.
The CEO, Dispensary Manager or Inventory Manager and an authorized dispensary agent under
direct supervision will conduct a physical inspection of the inventory to account for each unit of
product. One agent will conduct the inventory and count the products, while the other agent
witnesses and records the products. The findings are logged on the Daily Inventory Log, noting
name of the agent; title/position; summary of each product inventory; any discrepancy; and agent
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signature. The log will be kept in a binder and scanned electronically so that it can easily be
produced for the City Manager upon request.
At opening, the CEO and Dispensary Manager will compare the physical product with
the inventory record from the previous end of business day, using our ITS, CRM and POS
platform track and trace scanners. At closing, the CEO and DM will compare the physical
inventory to the opening inventory plus any sales or deliveries during the day. If there happens to
be an inventory discrepancy our CEO will notify the City Manager immediately and must
receive approval from the City Manager before completing an inventory adjustment. We will
provide a detailed reason for the adjustment and review our inventory procedures to ensure a
discrepancy does not repeat itself. All inventory adjustment documentation will be kept on
location for 2 years from the date performed.
If our CEO or DM identifies an imbalance in the amount of cannabis after the daily
inventory reconciliation due to mistake, we will determine how the imbalance occurred and
immediately upon discovery take the document corrective action. If we cannot identify the
reason for the mistake within 2 calendar days (48 hours) after first discovery, we will inform the
City Manager immediately in writing of the imbalance and the corrective action taken to date.
Our staff of experienced inventory agents will work diligently to determine the reason for the
mistake.
If our CEO or DM identifies an imbalance in the amount of cannabis after the daily
inventory reconciliation due to theft, criminal activity or suspected criminal activity, the CEO
will immediately determine how the reduction occurred and take and document corrective action.
Our Company has a ZERO tolerance policy for diversion of product or currency. If an agent is
suspected of diverting product or currency, they will be immediately put on temporarily agent
leave and our team will conduct a thorough investigation. If our findings show a diversion of
product or currency, we will notify the City Manager and the Fresno law enforcement in writing
within 24 hours and the agent will be immediately terminated from our dispensary. Within 24
hours after the first discovery of the reduction due to theft, criminal activity, or suspected
criminal activity, our CEO will inform the City Manager and proper law enforcement in writing.
Only the CEO, Level 4 agents and dispensary agents under direct supervision are allowed
in the Vault. Their entry into the Vault and identities are also logged. During opening and closing
inventory, we will also ensure that there is no expired or damaged product and that the tamper
resistant seals are intact. Any such product will be put into Quarantine Product Lock Boxes
located in the Vault Room, with that change being noted in our ITS.
c. Identify the name of the Point-of-sale system to be used and the number
of Point-of-sale locations
Point-of-Sale Platform: Given our experience in the cannabis industry, we like to uniform
our Standard Operating Procedures, our employee manuals, our training, our technology
platforms including our point-of-sale (POS) systems. In our Michigan and Missouri dispensary’s
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our agents use and prefer the functionality of Flowhub as their POS platform provider. For
clarification – Our team can be trained to use any City Manager approved POS system including
BioTrack THC or others. Flowhub is a cannabis leader in state-of-the-art cannabis POS and
customer relationship management (CRM) software systems. They serve over 1,000 clients
across 12 regulated states, and provide innovative, real-time, state regulated and trusted
dispensary management tools to track inventory, track customer records and successfully check-
in and check-out customer purchases with ease and reliability. As we already use Flowhub in our
cannabis dispensary, we have provided screen shots of our system to show the City Manager it’s
easy to follow platform and full capabilities. Familiarity with the system allows our Key
Personnel to train our Fresno employees as quickly as possible. We plan to have six (6) terminals
to be able to serve over 500 customers per day, as well as one quick service area.
Flowhub gives our dispensary a chance to select the type of hardware kits we plan on
using for our location. For example, we plan on using an all-in-one “Performance Kit” that
includes, an Apple iMac 21.5” touch screen or Acer AIO 24” touch screen, Zebra GK420 Label
Printer, Epson TM-T88VI Thermal Receipt Printer, Star Micronics Cash Drawer or Automated
Cashier cashless drawer, Honeywell 1900G-SR Laser Scanner with Stand, 7 Port USB Hub
Tower, A&D FX-1200iN FX-Series Precision Lab Balance Scale and a Flowhub NUG Mobile
Scanner. The Performance Kit works well for our dispensary as it is designed for our layout, with
our dispensary agents behind the counter showcasing available products. The compact computers
and scanners save space on our counters and provide fast and fluid transaction experience for our
agents. We plan to have six (6) terminals all with the below equipment.
Unique to Flowhub is their portable Flowhub NUG Mobile Scanner. The portable
custom-build scanner is an iPhone like device used by our security and dispensary agents to
verify a customer’s age using a government issued ID with authenticity software, streamline
inventory location of a various product and check customers in our POS queue. These handheld
mobile devices will be used to track an entire customers experience. When customers check-in,
our security guard will verify the customer by scanning the back of the customer’s ID, this will
instantly start a timing device and when the customer checks out, our dispensary agent will again
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verify and scan the customers ID. The timing device will allow our team to track customer
waiting times, through their experience at our dispensary, allowing our executive team to track
the efficiency of our customer flow. We see this software platform as a competitive advantage to
not only track inventory and execute transactions, but to improve the customer experience.
Flowhub integrates with a myriad of
state regulated inventory tracking systems,
including METRC, BioTrack THC and MJ
Freeway. The Flowhub system can be easily
downloaded to our secure server system and
fully integrate mid-operation if needed, using a
unique inventory mapping system to quickly
upload product information. Flowhub’s
software can integrate with any hardware
scanner, printer, monitor, cash register or
automated cashier we decide to use. The
platform will integrate with our Inventory
Tracking System, through the use of a
handheld scanner. As products are delivered to
our dispensary, we will scan each products’
barcode along with the electronic manifest and
Flowhub will automatically create and populate a product description to an “Add New Inventory
Item” dashboard – as seen above. This includes a “Product Description” for each brand, product
and SKU. Each product description includes, but not limited to product category (flower, edibles,
topicals etc.), brand, product name, product type, description of the product, batch number, batch
date, invoice number, weight and test results. Our CEO can assign security levels so only
designated employees have the ability to manually change or upload test results for each product
(as they vary from product to product).
The Flowhub platform allows our dispensary agents to communicate with our real-time
inventory on the back-end (inventory and delivery) and on the front-end (inventory and customer
interaction), which makes this POS platform unique. Once all products are scanned and properly
inventoried, our Inventory Manager along with our CEO will double check to make sure all
Flowhub: New Inventory Item
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products are represented correctly, per Fresno’s rules and regulations. Our updated inventory list
will be uploaded to Leafly, Weedmaps or any other online menu system with the click of a
button. The automated system eliminates human error on having to input weights, strain names
and other product information that are often mislabeled. The POS software will allow our
designated agents to properly label all products. All products will be scanned using their unique
barcode and our agents will affix labels to each product during the transaction. After the
transaction is complete the POS platform will print a receipt that includes all necessary
information (see our dispensing procedures below).
Upon scanning a customer’s ID our POS platform will be able to track all customer
purchases. Every customer will have a unique “Customer Homepage” that keeps record of the
following, past purchased items, current items in their cart, last purchase date, any loyalty points
gained, payment details, create custom notes about the customers buying habits and a sliding
scale that tracks the total weight of the purchase with a click. If there are limits to customer’s
purchases, the system will track and automatically deny sales.
This feature protects the customer and our dispensary agents, because if the Cannabis
Legal Limit feature reaches over the allowable limit the Flowhub software will not allow the
transaction to proceed through check out, again eliminating human error or product diversion.
The platform will track and keep all data on a secured server and all private information will
remain in our possession. By tracking all transactions and customers, we can send recall
messages to those that purchased the recalled, damaged or defective products. All information
can be provided to the City Manager upon request.
Flow Hub: Customer Homepage
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Unique Dashboard and Reporting: The Flowhub POS gives our CEO and Managers daily
real-time reporting of our dispensary sales, number of customers served, sales by location,
average customer wait times, sales tracked by hour and day – to determine busy and down times
of each day, sales by each dispensary agent and a number of other interactive tools to help
facilitate efficiency and real-time tracking. All information recorded on our secured server will
be available upon request by the City Manager.
Training: Flowhub offers various training for our dispensary agents, including live-video
interaction tool kits / modules, onsite training for however long is needed, virtual trainers that
are available 7 days a week, as well as phone and video support.
Below, we further discuss how our agents and the POS system work in collaboration to
process customer purchases and dispense cannabis products.
Customer Dispensing Procedures: We will follow all rules and regulations when
dispensing products to medical patients above 18 years of age and non-medical customers above
21 years of age. Upon entry to our dispensary customers are required to first check in with our
security guard. Before we dispense any cannabis to a purchaser, we must verify the age of the
customer checking a government-issued identification card by using our Flowhub NUG Mobile
Scanner. The portable custom-build scanner is an iPhone like device used by our agents to verify
a customer’s age using a government-issued ID with authenticity software. Mentioned earlier,
we will follow all rules outlined in SEC 9-3309(i) Minors.
Flow Hub: Dashboard
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will not have the ability to manual adjust any manifest, inventory record, discount record without
given proper security override privileges from our CEO.
Our dispensary agents will be trained to deny sale to anyone that makes suspicious
buying request or buying habits in large amounts within short time periods that could be
mistaken for illegally re-selling cannabis products or other illegal activity. If we suspect our
products being resold illegally, we will notify law enforcement and the City Manager within 24
hours. For any customer that triggers a denial of sale our agents will take note of the customers
name, their contact information and any details about the customer if an investigation is needed.
All denial of sales will be tracked and kept on file for three years.
d. The estimated number of customers to be served per hour/day
Our facility will have six terminals, with two quick service counters. Our facility will be
sizeable where we can expand our sales floor. Per COVID-19, all our terminals will be six feet
away. In our full first year we plan to service customers every 15 minutes and as customers get
comfortable and develop purchasing habits they tend to lower their time spent in our dispensary.
Over time we estimate customers will spend only 8 minutes in our dispensary. Customers will
also have the ability to order products online for pick up, increasing our dispensary capacity of
the number of customers we can serve daily. Please find below our estimate of the number of
customers to be served per hour/day.
e. Describe the proposed product line to be sold and estimate the percentage
of sales of flower and manufactured products
Products Offered
We plan on operating the premiere Fresno dispensary, which includes keeping our
shelves stocked with all forms of product that is offered in the market: dried flower, vapes (pre-
Fresno Dispensary Number of Customers Served
2022 2023 2024 2025 2026
Hours Open Each Day 12 12 12 12 12
Days Open Each Week 7 7 7 7 7
Weeks in a Year 52 52 52 52 52
Hours per Period (Annually)4,368 4,368 4,368 4,368 4,368
# of Payment Terminals 6 6 6 6 6
Mintues to Serve an In-Store Customer 15 12 10 8 8
Customers Served per Hour 24 30 36 45 45
Customers Served per Day 288 360 432 540 540
Number of Transactions Year
Average Ticket per Transaction
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loaded and disposable), edibles, topicals, oils,
concentrates, transdermal patches,
suppositories, CBD and THC products and any
other allowable form of product. Our staff will
be knowledgeable about all forms and will be
trained about the pros and cons of each form.
We will sell a full spectrum of allowable
cannabis products. We estimate that flower will represent 40% of the sales within our dispensary
and manufactured products will represent 60% of the sales. In California, the illegal market
flower thrives and prices are typically a lot lower and we estimate that many of our customers
will initially purchase products for the items they cannot get as easily such as tinctures, vape
cartridges, concentrates and edibles. Over time customers will start to purchase more flower as
we will have high quality branded flower that will be unique only to the Fresno cannabis
industry. Please see a breakdown of our estimates sales of flower and processed products.
We will only dispense forms of cannabis products purchased from a California licensed
cultivator, processor or distributor that has been tested and meets general requirements. We will
place priority of products that are produced locally in Fresno. With the City Manager’s
approval, we may offer for sale, or provide at our facility, instruments, devices and services
related to the use of cannabis. Typical devices we may sell include but are not limited to;
vaporizers, water pipes, hemp rolling papers, lighters, product carrying cases and other items the
Department deems acceptable. We will also offer merchandise, t-shirts, sweatshirts, hoodies, hats
so our customers can support our business and brand. We will donate 5% of all Company
merchandise sold to local community organizations, as part of our Community Impact Fund. No
product or device will be visible from outside of the sales floor.
Services Offered
Our employees will have extensive knowledge about all products offered in the
dispensary so they can educate customers and help them select the products that will most
effectively fit their lifestyle. Employees will be able to recommend strains for each customer
dependent upon the individual’s needs. In addition, employees will be well-versed in the
methods of administration a customer may prefer based on factors including age, lifestyle, and
his/her physical needs. Some customers may find they prefer to make or buy edibles, others may
find that a vaporizer best suits their needs. Employees will be able to provide recommendations
in a collaborative effort, treating customers with dignity and with sensitivity to their particular
experience. Employees will also be well-versed and up-to-date on the laws surrounding cannabis
usage. These educational resource services and exceptional agent knowledge will separate our
dispensary from the competition.
Fresno Dispensary Product Sales
% of Sales
Flower (Dry Flower & Pre-Rolls)40.0%
Vape Cartridges / Pre-loaded Pens 17.0%
Concentrates 10.0%
Edibles 15.0%
Infused Beverages 5.0%
Oil & Tinctures 10.0%
Non-medicated (CBD)3.0%
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f. If proposed, describe delivery service procedures, number of vehicles and
product security during transportation.
While coronavirus (COVID-19) cases are rising, we do NOT want customers with pre-
existing and qualifying conditions potentially being exposed to the virus while in our dispensary.
Medical patients will be the most vulnerable due their qualifying conditions and we will NOT
risk our customer’s health in order to make a profit. Our team will create customer delivery
pharmacy protocols outlined so our customers can receive their cannabis products with limited
exposure to the virus and being detrimental to their health.
Older customers that may not have access to automobiles or have access to a registered
caregiver that can order and pick up their products, we will make available a scheduled delivery
service to their place of residence. Our proposed dispensary will be centrally located so everyone
within Fresno will have equal driving distance and access. We plan to have two to four
designated vehicles used for the delivery of cannabis to customers.
We will comply with SEC 9-3310(a)(7), delivery vehicles will be unmarked vehicles
with no indication that the vehicles are transporting cannabis or cannabis products. Our fleet of
unmarked sprinter vans or vehicles will serve as safe and secure delivery vehicles, all procedures
including storage, handling, transport, delivery, security, recordkeeping documentation and chain
of custody. All agents will be trained for delivery.
Delivery Agents: We will only deliver to customers only AFTER their initial visit and
patient consultation to our physical dispensary location. If customers are disabled and cannot
visit the dispensary, we will ensure delivery will be available. We will ONLY deliver to
customers within a 30-mile radius of our licensed dispensary location. All transactions will be
cashless and paid in advance using our online service or over the phone, eliminating our vehicles
of being targets of theft and diversion. Our 30-mile radius will allow all customers without the
ability to drive or access to vehicles access to product. We will designate delivery agents to make
customer deliveries in secure unmarked vehicles, that include GPS tracking devices, in-cargo
surveillance and locked cabin containers. Our CEO or Dispensary Manager will create an
electronic manifest for each delivery.
All delivery agents will complete an 8-hour training course developed by our National
Director of Delivery & Transportation and Security Manager. Topics include: proper handling;
recordkeeping; diversion prevention; safety procedures for robbery, burglary and criminal
incident. All delivery agents must pass a delivery exam and complete five test deliveries before
certification as a delivery agent. Theft or attempted theft or any criminal incident must be
reported immediately, our CEO will report to the City Manager within 24 hours.
For every transaction our dispensary must receive the order directly from the customer,
by phone or via our online ordering form. Each customer is verified by our CEO, through that
the customer is currently authorized to purchase product. In the case of a delivery order, we must
receive payment before the cannabis products leaves our dispensary, subject to refund if the
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delivery cannot be completed. At the time of the delivery, we will require production of the
customers government issued photo ID, and/or a California cannabis customer identification
card.
Once the delivery manifest is created, we will ensure all chain of custody protocols are
followed by our delivery agents. All information will be recorded in our ITS detailing the same
information as if the sale happened in person. Two agents will accompany the delivery at all
times. Our customer delivery agents will follow the same protocols to ensure safety and security
during all deliveries. The customer order will be placed in a lock box that can only be unlocked
with the access card of the delivery agents. The boxes RFID will allow the recording of all
agents that access the box, our customer will have record how many times the box was opened
and by who. We will have a fleet of delivery vehicles with custom made compartments to ensure
all cannabis products are safe and free from theft, loss or diversion.
Once the delivery agents arrive at the customer’s residence, the customer must show
proof of identification that matches the delivery manifest, the delivery manifest must be signed
by the customer or the registered caregiver. We plan on using tablets, that link to our ITS for
real-time reporting, so customers can sign off on their purchase. All customers will receive all
proper documentation, receipts and safety inserts to remind the customer on how to use each
product ordered safely. Upon leaving the customers residence, the delivery agent must also sign
off on the manifest which will ensure a safe, secure and successful delivery.
All deliveries will be completed in a safe and secure manner.
Threats in Transit
ALL delivery vehicles (two to four vehicles) will have a GPS system, which will be
activated while the vehicle is in operation, as well as internal video surveillance and locked
storage containers.
We will use Samsara Live GPS Fleet Tracking, to supply secure discrete bags with GPS
tracking devices that the delivery agents will use. The GPS device is a completely self-contained
and weather-resistant GPS Tracking device that provides detailed reports of routes traveled, the
MPH as well as alerts during the transport, such as “hard” stop, is position accurate within three
meters and weighs only 0.13 pounds. Our Security Manager will be able to monitor the
movement of each vehicle. The GPS device will notify the supervisor and track route progress
and receive automatic ETA alerts.
Along with the GPS tracking device in each RFID box, we will install the CashTrack™
system, which is an advanced, self-contained satellite tracking system that is covertly disguised
as stacked currency. We will also use discreet security bags/boxes that have GPS and a
comprehensive web-based tracking interface. Each vehicle will include a “panic” alarm for
emergency purposes. We use only inconspicuous delivery vehicles with no markings. Neither the
cargo area nor product will be visible from outside the vehicle. Each vehicle will be equipped
with a secure lockbox or locking cargo for the sanitary and secure transport of cannabis products.
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We will have commercial liability insurance in a commercially reasonable amount not less than
$1 million per incident. All vehicles will display current state inspection and registration stickers.
All delivery routes are randomized and changed routinely by our team. Only those with a
“need to know” will be made aware of routes. We will notify the City Manager of our delivery
schedule including routes and delivery times in a manner prescribed by the City Manager. We
will also minimize the opportunity for surveillance by setting delivery times that fall within fairly
wide time ranges during the hours of 7:00 am and 9:00 pm only. Per SEC 9-3310(a)(1), cannabis
retail businesses, including delivery of cannabis, may operate between the hours of 6:00 am and
10:00 pm.
One employee will remain with the vehicle at all times that the vehicle contains cannabis
products. Transportation team drivers will be required to go directly from our facility to the
receiving customer without making any intervening stops. The vehicle will be fueled fully before
leaving for a delivery. Each delivery team member will carry his/her employee and agent ID and
will produce it upon demand to the City Manager or law enforcement. Each delivery team
member will also have a secure cell-phone at all times the vehicle contains cannabis products.
Our Delivery team will develop and maintain an Operations and Management Practices Plan.
We scan in real time to our tracking system all delivered product, simultaneously
updating our own records and our pharmaceutical processing records. This ensures that there is a
clear and instantaneous transfer and acceptance record, eliminating potential opportunities for
internal diversion. We will maintain a logbook for each transport with the date/time the transport
commenced and was completed; the employees on the delivery team; the weight of cannabis
transported; the serial number of each package as well as the lot number of the medical
marijuana, the name of strain and whether it is high, medium or low potency. The log will be
signed by each employee on the delivery.
Should there be any vehicle accidents, diversions, losses, breach of security, activation of
the security system, failure of the security system, or other reportable events that occur during
the transport of cannabis, we will immediately notify law enforcement. We will follow this
verbal notification with a written notification within 10 business days or by electronic
communication with the City Manager in a manner prescribed by the City Manager and to law
enforcement. The written notification will include an explanation of the reportable event as well
as our findings and any corrective measures taken. We will maintain all documentation for three
years.
RECALL POLICIES & PROCEDURES
Our dispensary agents will immediately notify the City Manager and our CEO upon
becoming aware of any complaint made by a customer or practitioner who reports an adverse
event from using cannabis dispensed by our dispensary. We will immediately cease dispensing
the affected product and quarantine it. We will also send out recall warning emails, phone calls
and physical letters to any customer that has purchased the affected product. Our dispensary will
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have the ability to track all sales to customers using our inventory tracking system, point-of-sale
system and customer identification (during check out). We will coordinate with our customers,
the dispensary and notify cultivators / processors the return of all recalled products as quickly as
possible and follow our operating procedures below.
Our dispensary will have a separate locked quarantine container in the restricted access
Vault Room for storage of cannabis that is expired, damaged, deteriorated, mislabeled,
contaminated, recalled or whose containers or packaging have been opened or breached until the
cannabis is returned to our facility for further for testing and/or destruction, destroyed or
otherwise disposed.
Recall Procedures: Once our dispensary agents receive notification from a customer of an
adverse event associated with the use of product we dispensed, our employee will notify the
CEO, Dispensary Manager and Recall Supervisor. The CEO will immediately contact the City
Manager and the cultivator / processing facility where the product was derived from to determine
the specific product batches or lots that may be affected. Our Dispensary Manager will search all
cannabis product storage areas, including our Vault Room and storage floor vaults and begin
identifying and isolating any potentially affected product. All potentially affected product will be
removed from our physical inventory into the locked quarantine container labeled
“HAZARDOUS WASTE/RECALL PRODUCT – DO NOT DISPENSE” and ensure the lock
box is secure. The CEO will then update the location of each quarantined package in our ITS
and create warnings that notify our agents, in real-time, the product is no longer available.
We will log the affected product as quarantine/recalled in our ITS, create a “Waste and
Recall Manifest” and make sure all our beginning inventory of that product matches all returned
product. The Waste and Recall Manifest will be manually created by our Dispensary Manager
and uploaded electronically to our secured server and keep on file for five years. We will then
coordinate the return of affected product to our dispensary and ultimately to destruction or
shipped back to the cultivator or processor. Our ITS and POS will allow us to scan each product
and track weights, strains and brands.
Communication with Customers: Our Recall Supervisor will schedule notifications,
through our web-based mobile application, our customer emailing list as well as using push text
message notifications, social media (Facebook and Instagram), to contact customers that
purchased affected product. Our POS platform will have the ability to keep track of all purchased
items and which customer purchased those items.
We will ask all customers and continuing customers to sign up to our Company
dispensary email list. Customers will have the ability to sign into a secured portal without
displaying any personal information. Instead they will gain access to the portal with a personal
identification number or code that will be associated with their dispensary customer number.
The application will have push notifications, any emergency recall notifications will not
have the option to be turned off by the customer. Recall notifications will identify the cause for
concern, the affected products and a warning to cease using it immediately, with instructions for
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immediate product return. Our agents will suggest alternative products that will best provide
similar effects. Each customer will receive credit to purchase a similar product in our inventory.
In the event we do not have ideal alternative products in stock, the customer will receive a refund
of the affected product and we will make every effort to obtain a similar or comparable product
in the near future. Our notifications will include information on our dispensary policy for return
of all recalled product. All customers must provide their email and phone number to our
dispensary, when filling out our new customer registration form, this will allow us to collect
information and send information on our dispensary. We believe all these tools are great
mechanisms that have been reasonably calculated to contact customers who have likely obtained
the product from our dispensary.
Procedures on Returning Recalled Product(s) to our Dispensary: Upon receipt of returned
product, the CEO or Dispensary Manager will receive the product and take a physical inventory
count and place all returned product (used or unused) in the designated Quarantine Product Lock
Boxes labeled “HAZARDOUS WASTE/RECALL PRODUCT – DO NOT DISPENSE”. These
lock boxes will remain locked and secure at all times. When there is a product recall and
customers need to return product, the CEO will create a Return Transport Manifest which will
include the quantity, by weight or unit, of each cannabis harvest batch, harvest lot or process lot
contained in our Quarantine Product Lock Box. We will then notify our waste hauler or a
licensed distribution to schedule a pickup of the recalled, damaged, defective or returned
product, after being rendered unusable.
Identification of Recalled Product: Immediately upon the decision to initiate a recall, the
Recall Supervisor will create a Recalled Product List identifying all products within the scope of
recall. If the recall includes multiple container sizes of a product, then each container size will be
listed separately. The Recalled Product List will include the detailed information to identify each
product and product size affected by the recall including: common names used in labeling the
product, product code, container size, date range of manufacture, date range of packaging, the
date range of sale, and the serial number range.
Each serial number range will be further broken down by our agents to which it was or
may have been sold. All reasonable efforts will be made to remove affected cannabis products
from commerce and our system will create warnings that notify our agents, in real-time, the
product is no longer available. We will immediately remove that product from our website until
further notification from the City Manager. Using the Recalled Product List, the Inventory
Manager will retrieve all potentially affected products that have not left our facility or that are in
the process of delivery but have not yet been delivered to a dispensary. Products will be
quarantined in labeled locked container(s) used only for that purpose.
Communication with Cultivator, Processors & Distributors: As soon as feasible after
giving notification to the City Manager, the Recall Supervisor shall prepare a draft Recall
Notification Letter to be sent by mail, email and fax. Our Recall Supervisor will directly contact
through phone, the cultivation and processor, where we purchased the product, operations
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manager within 24 hours of receiving customer complaint. Once approved, the Recall Supervisor
will immediately send the Recall Notification Letter to the cultivators and processors. This
should occur as soon as practicable and, in no event, longer than 24 hours after approval. This
same information will be made available in electronic form useable by our inventory tracking
system. We believe these methods of communication mechanisms have been reasonably
calculated to contact cultivation and processors that manufactured the recalled cannabis.
Retrieval from Dispensaries: As soon as practicable after our dispensary has notified the
affected customers of the recall and given them sufficient opportunity to return the products. Our
agents begin to take custody of all containers subject of the recall, we will only accept returns if
half or more of the product is still within the original packaging. There will be a Recalled
Product Custody Form to be filled out at the time of collection from each customer, which
includes number and the size of containers.
Following acceptance by agents, the Inventory Manager will place the returned product
into the locked quarantine room in a designated container in a restricted access area. The
packages of product will be tagged with a tracking number with an identifier, as well as a
statement of the date and reason for recall. The returned product may not be removed until it is
ready for disposal in accordance with our policy addressing the disposal of cannabis.
The Recall Supervisor will maintain a list, by serial number, of the quarantined
containers as well as notify the City Manager on a rolling basis of how many recalled products
have been quarantined and how many remain in commerce. All information will be logged and
kept on file for three years.
Premises Accessibility
All persons must enter through the monitored mantrap entryway which is controlled by
an onsite security guard. The guard can see and speak with those seeking entry via a video
intercom before releasing the entry door through an electronic “switch or buzzer” or release
button. Using the GB2 Door Monitor & Intercom, each person can identify themselves before
entry.
If a CUSTOMER, the security guard will have the customer sign into our daily log,
complete our New Customer Registration form that outlines our dispensary policies and verify
government Identification by scanning the back of their ID with our FlowHub Mobile Nug. Our
security guards will be trained to check the validity of the ID including making sure the ID is not
expired, verifying the photo matches the customer and any evidence of worn or tampered ID.
Upon completion the customer will wait for their name to be called to enter the sales floor. We
will maintain a 1:1 ratio of Dispensary Agents to Customer in our sales floor. The use of cell
phones, cameras and any other recording device is prohibited inside our facility, unless
authorized by the City Manager.
If a VISITOR, upon entry to the facility, the security guard will scan the entrant’s
government issued ID into our Visitor Tracking System and then issue a numbered visitor ID
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All visitors, maintenance and vendors must have a scheduled appointment, reported in
advance to the Security Manager. We keep the visitor log for three years and make it available
upon request by the City Manager and law enforcement.
All points of ingress and egress of our facility will be secured with Building Code
compliant commercial-grade, non-residential door locks. Our facility will have a single site
entrance for customers, leading to our Public access waiting area, the door will be a commercial
grade double opening 10” bottom rail standard, ¼ inch glass to meet local and national building
codes. The dispensary will also have emergency exits to comply with local and state building
codes. All exterior emergency exit doors will be commercial grade solid steel installed with
commercial grade locks. We provide notice to the City Manager and other appropriate public
agencies in the event of any emergencies as well as internally to our employees.
Outer Layer Procedures: Any person who is not an employee or a customer of the facility
will need to request visitor access at the reception desk in the waiting area. Once the visitor is
authorized to be on the grounds, the security officer must request the visitor’s identification and
record it into the electronic visitor management system, which will print a self-expiring visitor
badge that will be attached to an RFID lanyard. The security guard must make note of the visitor
once processing is completed. The security guard will retain the identification of visitor, the
visitor will receive their ID after they sign out of our visitor log.
At no time will the visitor be unescorted or left alone, and the security guard must
monitor the movement of the visitor via the digital surveillance camera system. Upon the
completion of the visit, the security guard will assist the visitor with the exit process.
Middle Layer Procedures: Perimeter doors are under constant video surveillance and will
require advanced electronic card access to enter from the outside. In addition to the perimeter
doors being secured with electronic access control devices and surveillance monitoring, door
position sensors and intrusion detection technology are also utilized. All employees will be
required to wear their photo IDs, which will include RFID access. Visible and certain team
members will carry wireless duress buttons that will notify our alarm monitoring station and
Fresno police.
Door position sensors monitor the position of the doors and provide an audible alert back
to the onsite monitoring center when the alarm is disengaged or if the door is ajar for an extended
period. The intrusion detection system, while enabled, will send an alarm signal to the offsite
monitoring center for police response if a breach is detected. Perimeter doors are free egress but
require electronic card access to enter. To protect against the intrusion system being
compromised, a backup offsite monitoring center will also be utilized. The intrusion detection
system will be zoned to arm all overhead doors and perimeter doors 24/7 until negotiated by the
card access system, which will disengage the alarm.
During an attempted breach to the property, the security officer will be alerted by a
screen pop priority camera image displayed on the monitor. The security guard will notify
management personnel and begin the talk down operation, instructing the intruder to leave the
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grounds due to trespassing. Regardless if the intruder yields or fails to yield, the security guard
must notify the local authorities via 911 and continue to monitor the movements of the intruder.
The security guard is not to use physical force unless employees or customers are threatened or
until local authorities are present. The incident will be recorded on our surveillance system and
the security officer must bookmark the video footage for further investigation and corrective
actions plan generation.
Inner Layer Procedures: Our facility design uses delay subsystems that place barriers in
the path of a would-be adversary. In the unlikely event of such an intrusion during business
hours, our security personnel will be present to execute all procedures regarding protection of all
persons present and notification of police. Further, our staff will be trained to use the panic
buttons and not to engage with a potential assailant. Guard presence in the waiting area and
exterior parking station will provide an additional method by which unauthorized access to the
grounds and facility will be prevented. Our facility will have a mantrap within the main entrance.
We will comply with SEC 9-3310(a)(4), entrances will be locked at all times with entry strictly
controlled. A “buzz-in” electronic/mechanical entry system will be utilized to limit access to and
entry to the retailer to separate it from the reception/lobby area. Individuals must show their
identification in order to gain access into our dispensary.
Access to key areas of the facility is managed by an advanced card access control system.
Every door that houses product or industry trade secrets will require card access to enter. Each of
these doors will be monitored by digital surveillance cameras that integrate to the card access
system and record each “swipe” of the card access system.
DUTY TO REPORT
All dispensary agents will be tasked with monitoring for suspicious activity, unusual
usage or purchases, or questionable disposition of cannabis products. All such suspicions must
be promptly reported to the CEO or Dispensary Manager, who will make reports to the City
Manager and local law enforcement immediately, as appropriate. All dispensary agents must also
notify the Dispensary upon discovery of any fraudulent or otherwise unlawful activity. The
Dispensary Manager will immediately notify the CEO who will immediately notify the City
Manager and local law enforcement. All notifications must be logged through written
community, email or fax.
SIGNAGE, MARKETING AND ADVERTISING
Our dispensary will follow all rules and regulations regarding marketing our dispensary
and our products. We believe our location will be a “destination” location, meaning that we do
not need to have elaborate signage or lights pointing to our location.
Exterior Signage: All outdoor signage if visible to the public, must comply with all local
township ordinances for signs or advertising and will not display any text other than our
facility’s business name, address, phone number, website or social media handles. We will not
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utilize images or visual representations that indicate the presence of cannabis plants, products or
paraphernalia, such as smoke. Our discrete signage will consist of purple text on a white
background and signage will only be illuminated during business hours. We will not advertise
the price of cannabis on the exterior of the facility, except providing a catalog, digital or printed
list of the prices and products available in our dispensary. We will not display any paraphernalia
from the exterior of our building or any cannabis leaves or “Vegas style” or neon flashing lights.
We will follow all local signage and lighting rules, outlined in SEC 9-3309(d). No cannabis or
cannabis products or graphics depicting cannabis or cannabis products will be visible from the
exterior of any property issued a commercial cannabis business permit, or on any of the vehicles
owned or used as part of the commercial cannabis business or cannabis retail business. No
outdoor storage of cannabis or cannabis products is permitted at any time.
Marketing & Advertising: We will NOT market or advertise to minors and all marketing
materials, billboards, flyers or any marketing campaigns will not advertise or be marketed within
1,000 feet of K-12 schools, daycares or playgrounds. Our Director of Marketing & Branding will
submit all marketing materials to the City Manager, before use all materials must be approved by
the City Manager.
Our market plan was developed by our experienced Director of Sales, Director of
Marketing & Branding and CEO. We plan to use all forms of Direct Marketing and limited or
strategic Mass Marketing. We realize the sensitivity of mass marketing as more eyes and ears are
focused on the positives and negatives of a cannabis program, potentially children that do not
qualify for the program. Direct marketing is a form of communicating where organizations
communicate directly to a pre-selected customer and supply a method for a direct response. Our
professional team budgeted per month on marketing and advertising.
We will direct market through extensive customer education. Our team will host a series
of monthly townhall style Cannabis Education events in our Community Education & Training
Center (CETC). These events will cover many topics, including but not limited to; Introduction
to Cannabis “101”, Rules and Regulations of Fresno Cannabis Program, Introduction of our
Company and Brand, THC vs CBD, Cultivation and Processing Brand Introductions and Forms
of Use: Inhalation, Edible and Topical, Sativa, Indica and Hybrid. We will collect names, emails
and phone numbers, as well ask all customers to register for our mobile application.
These forms of contact will allow our Marketing & Branding team to directly contact
those individuals that showed interest in the cannabis program and our business. These
educational events will be great for customers to meet our team members, ask questions to
educated agents regarding the program and learn our Company’s corporate values. These events
will serve as our marketing outreach to the community and it’s a way to eliminate marketing to
minors or those not interested in using cannabis in our respective neighborhood.
Along with these community education events, we plan to market using strategic
traditional marketing. We will speak with and market to hospice services, local nursing homes,
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palliative care facilities, hospitals and other facilities where their customers would significantly
benefit for the use of cannabis.
We feel direct marketing to individuals that have interest in using cannabis is the best
place to start as we do not want to market or reach minors with a message to use cannabis, unless
it’s for medicinal purposes. We plan on hosting Brand Appreciation events, where our
dispensary staff members can learn about the high-quality details of products, meet cultivators
and ask product questions. The goal is to introduce smaller, microbusinesses to and Fresno
cultivators and processors to our customers. We hope the smaller microbusinesses or Fresno
growers represent the local neighborhoods. We will use our social media following and branding
to promote local Fresno companies.
Community Benefits and Investment Plan
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7.1 The CCB Application should describe the social responsibility plan. This should
include all benefits the CCB has provided or plans to provide to the local
community for example by directly aiding, participating in, or funding the work of
local non-profits, community-based organization, civic organization, or social
services organization. Benefits may be in the form of volunteer services, monetary
donations, financial support of City-sponsored activities or organizations, in-kind
donations to the City or other charitable organizations and/or contributions to the
Fresno Community Reinvestment Fun. It may also include, but is not limited to:
7.1.1 Providing funding for or hosting expungement clinics or outreach services.
7.1.2 Incorporating an environmentally sustainable business model including
energy efficient buildings and vehicles.
7.1.3 Utilizing vacant buildings, brownfields land, or blighted areas of the city for
the business
Our Company operates as a leading national branded cannabis company under our
flagship Viola. We feel we best represent the challenges of being targeted by the War on Drugs
as being minority owned in the cannabis industry which is 97% owned by white males. Our
Fresno team consists of many owners, managers and employees that were born, raised or
currently live in some of the most economically disadvantaged neighborhoods in the country. We
are majority owned by Mr. Delanno Hopkins, he was convicted of a non-violent cannabis drug
trafficking offense and served 18 months in Fresno prison. He is the best representation of Viola
partnering with individuals that were negatively affected by the War on Drugs and now have an
opportunity to participate as an owner and operator of a Commercial Cannabis Business.
As a team we acknowledged our passion of social economic empowerment and how it
can be realized through business ownership and having strong ties to our local communities. Our
Company is looking forward for the opportunity to provide high quality cannabis relief to
customer in Fresno suffering from some of the most challenging diseases and symptoms. Once
established in Fresno, we will allocate time to meet with directors, officers, executives and
founders of community organizations, which allows us to gain insight on how we can best
impact the immediate needs of the local community and organization. Our local Director
Community Outreach – Laneesha Senegal, is currently the CEO of HOPE, a 5013C non-profit
vocational training and entrepreneurship program that targets low-income communities.
Given the diversity of our team we have the perfect formula to give Fresno best-in-class
community service, not providing “lip service” to provide resources to the community. Our
Compassionate Benefits and Investment Plan (“CBIP”) mission is based on four pillars, (i)
providing affordable medicine for ALL, (ii) providing financial assistance to our local partners
that provide substance abuse programs in our Community Education and Training Center, (iii)
creating recidivism, expungement and job reentry programs, and (iv) have ample square footage
at our facility to demonstrate a commitment to community engagement.
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We have begun to show community commitment, not for points on this application, but
because we care about disadvantaged communities, because they mirror or remind our owners
and employees of the communities they were born, raised and/or currently live. Our Company
has created a Community Impact Fund (“CIF”). The CIF will use proceeds from our operations
to donate and invest back into the community where we operate. We anticipate budgeting more
than , or more, annually. Before applying for Fresno licenses, most recently we already
donated to the Association of the Advancement of Minorities Owners in Cannabis, an
organization that supports minority ownership in cannabis. We show our advocacy and
community engagement by actions.
Fresno Demographics: Community impact is a core value for our Company and our team
members. We believe when municipalities enact cannabis programs, those programs typically
create opportunities for wealthy individuals to amass more wealth and leave out the individuals
and communities that were affected most by the War on Drugs and opioid addiction. Fresno has
a 26% poverty rate, according to datausa census data and an unemployment rate of 10.1%
according the Bureau of Labor Statistics. Median household income in Fresno is , more
than below the California median household income of per US Census. Our
CCB will bring more than 30 jobs, economic development through construction and tax revenue
through the sales of cannabis products.
DISCOUNT PROGRAM FOR QUALIFYING CUSTOMERS
Given COVID-19 and the pandemic, unemployment across the country is near an all-time
high and many customers with qualifying conditions may not be able to afford medical cannabis
for relief. In Fresno, unemployment is 10.1%, as of September 2020. Since cannabis is a
Schedule I drug, cannabis cannot be purchased through health insurance, this means that all
purchases of cannabis will be conducted out of pocket for the patient. On average patients in
medical cannabis markets spend to per visit and typically purchase products weekly
or every 10 days. Many patients will spend nearly annually on cannabis and in today’s
current environment of high unemployment and economic uncertainty, our products will be
made affordable to all. We will make a pledge that our products will be affordable to all,
especially low-income customers, through (i) introducing a “low income fund” to customers that
qualify, (ii) offer frequent buyer points for product discounts and (iii) introducing programs for
pediatrics and senior citizens.
Low-Income Fund: We plan to give all customers that live with government assistance a
20% discount on cannabis products. Given our Company’s strong diversity and social equality
roots, we believe customers qualifying for government assistance should not have to make
choices about medicating based on financial imperatives. If customers qualify for California or
Federal government assistance, subject to our verification of their income and documentation,
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they can join our “Customer Low-Income Program”. We estimate regular volume customers
will spend close to a year on their cannabis, and these savings will add up.
Our Community Impact Fund will help sponsor qualified low-income customers.
Through our CIF we will allocate in helping low-income customers or
unemployed parents of registered minor patients. This will be similar to a need-based
scholarship, where the customer or guardian must complete a two-page application explaining
their need and why they should qualify for the scholarship. The customer or guardian must show
verification of their income, through tax returns and provide photo identification and their patient
registration number (if applicable). Once selected those customers will have money allocated
from the Community Impact Fund to the purchase of cannabis products. Those customers
selected must commit to 8 hours annually of community service and the “scholarship” will last
one calendar year before re-applying. The scholarship does not “roll-over” to the next year.
Frequent Buyer Program: Many of the customers that qualify for our Low-Income
Program will qualify for our frequent buyer program rewards. Similar to other big box
pharmacies (Walgreens, CVS, RiteAid or Walmart) that offer reward points, our dispensary will
offer a frequent buyer program for our most loyal and in need customers. Customers can sign up
for the program at any time and will be rewarded with points for every purchase. For every
spent the patient receives 0.25% discount and they can use their discount anytime within the
calendar year. The more a customer purchases the more points they build, similar to any other
point reward system at other pharmacies. No customer can earn more than a 10% discount on
products purchased, once they use their 10% discount the reward points roll over. We believe
this will save close to 10% every 15-25 purchases. This will build patient loyalty in our
community and allow our low-income customers to receive further discounts.
Pediatrics, Senior Citizens & Veterans: Another of our affordability goals is to provide
relief for pediatric patients and their caregivers. Any patient registered as a minor (under 18) will
receive a 25% discount on all medical cannabis oil. We are deeply sympathetic to minors who
need medical cannabis products for conditions such as epilepsy, cancer or other painful
conditions. Our Inventory Tracking System and our Customer Relationship Management
software Flow Hub will verify caregivers that are purchasing on behalf of minors or pediatric
patients. This is a real economic gap in most states as parents will pay high out of pocket
expenses for opioids for their children. Parents or guardians should not have to choose either
medicating their children in a safe and responsible way or other living expenses. Medical bills
add up and our Company will try and do our part with providing relief to the pediatric patients
and to their guardian’s income.
Seniors in our community are often on a fixed income or social security and insurance or
Medicaid does not cover the cost of medical cannabis. We are dedicated to providing our senior
citizens with financial assistance. Specifically, we will provide a 10% discount on all cannabis
products for all customers above the age of 65. They will be verified when they registered with
our dispensary by providing their date of birth.
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Veterans in most communities are overlooked when it comes to providing medical
assistance. Our team consists of multiple military veterans and we will honor their service by
providing a 15% discount on all products in our facility. Many veterans suffer from Post-
Traumatic Stress Disorder (“PTSD”) and we will do our best to serve them just as they have
served us. Upon registration of our dispensary, the veteran customer will provide their DD-214
or military identification along with their photo identification. Our agent will scan their forms
and when they purchase products in the future their information will be registered in the system,
so if that veteran forgets to bring their military identification, they can still receive the discount.
Founded by minorities deeply committed to social equality, we believe medicine should
be affordable to all patients. In every state we operate in, we’ve chosen economically distressed
communities where we can make a bigger impact, Fresno is no different. As exemplified by our
diversity, access to our products by people of all sociodemographic groups is something our
Company values.
COMMUNITY EDUCATION AND TRAINING CENTER (“CETC”)
Given our strong commitment to community engagement, our CEO, COO and architects
designed our proposed facility with a Community Education and Training Center (“CETC”).
This space will be separate of our facility, with its own entrance and exit and does not have
entrance access to any part of our production or storage areas. We will seek to educate
community members on responsible cannabis use and how to cope with substance addiction. We
will help facilitate counseling services, as our local partners will have the experience in
providing much needed human services programs to underserved populations and people living
with an array of health and human service needs.
Our partnered curriculum will include (i)
Alcohol/Substance Abuse Treatment, (ii) Mental Health
Services, (iii) Disability Services, (iv) Violence
Prevention and Trauma; and (v) Coping Strategies. Their
informational pamphlets will be in our CETC. We will
also work with other substance abuse service companies
located across Fresno. Fresno and surrounding cities,
like many other cities, has seen the devastating effects of
the opioid epidemic. If a non-profit or counselor needs
to have a private counseling session, our CETC will be
fully built out and equipped with state-of-the-art
technology, a cannabis education library (with take
home brochures), bathrooms, a kitchen and private
consultation offices. Community organizations will have access to our Community Education
and Training Center to host these events at no to little cost.
Floor Plan of our CETC
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We will plan to host a series of year-round information sessions, at our Community
Education and Training Center. The topics and dates will be scheduled, advertised, and listed on
our website and in our waiting area display screens giving customers the opportunity to plan
their attendance in advance and receive the information that is most valuable to them.
We will create informational brochures and place them in highly visible common areas of
our facility such as the waiting area, the sales floor and display areas. Topics include alternative
methods and forms of consumption or inhalation by which one can use cannabis, signs and
symptoms of substance abuse, opportunities to participate in substance abuse programs and
information on tolerance, dependence and withdrawal. This will allow customers to quickly
obtain valuable information that they can review on their own time, refer to, and share with other
potential customers. All materials will be available for inspection by the City Manager upon
request.
We welcome Fresno residents and adult members of the community to visit our
dispensary so they can learn more about the products we dispense and gain a comfort level with
the terminology and our welcoming well-trained staff. Some of the community members and
prospective customers have never been inside a professional dispensary and typically have a
negative stigma about cannabis dispensaries, confusing legalized dispensaries with “head shops”
or “smoke / vape shops”. All of our educational sessions will be open to the public (18 years or
older) and typically last two hours where perspective customers can ask our trained agents
general questions. We will include a sign in sheet, requesting name, email and reason for visit.
Veteran and Indigent Services: Some of our team members have served in the military or
come from military families. We will support our veterans with mental, physical and social
services. In partnership with other local organizations our Director of Community Outreach will
host the following services and events at our CETC: (i) Periodic social worker consultations.
Many homeless veterans and other indigents have difficulty accessing public services because of
the lack of “simple” things like a state-issued ID or bus fare. One way we can help is by funding
social workers to guide them through these processes as well as the paperwork necessary to
begin receiving more substantial public services. (ii) Pet therapy. For many, pet therapy has
been shown to be an effective treatment for anxiety and PTSD. It also helps build community for
the veterans and indigent participants, many of whom have become reclusive because of mental
conditions. (iii) Addiction counseling. Substance abuse of all types often creates a vicious cycle
for suffering veterans and others and (iv) Resume writing and career preparation. All services
conducted in our CETC will be free of charge.
RECIDIVISM, EXPUNGEMENT AND JOB REENTRY PROGRAMS
Expungement and Job Reentry Programs is one of the major initiatives of our CEO – Mr.
Delanno Hopkins. Through this opportunity he will have a chance to have majority ownership in
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a successful cannabis operation and help those negatively affected by the War on Drugs.
Members of our team have spoken with Fresno business owners and council members who want
to see skilled labor jobs in technology, agriculture and retail newly introduced but also provide
recidivism and job re-entry programs for those residents with non-violent cannabis criminal
records. All the community engagement that we have done and plan to do is in line with the
wants and need of local government officials.
As community partners we will offer our CETC to be used to encourage effective
wraparound services that will be provided to assist individuals previously arrested for nonviolent
cannabis offenses and traumatized to the experience of incarceration. Our Company has
committed financial and volunteer resources to Job Reentry Initiatives across the country. These
services include health screening, rehabilitative services, substance use treatment, mental health
services, training and care coordination services, thus also addressing key social determinants of
health which may lead to high rates of recidivism for our targeted population.
These services increase the individual’s employability and productivity. One of our
targeted approaches is helping the recently expunged with Post Traumatic Stress Disorder
(“PTSD”). According to research conducted by the Illinois Criminal Justice Information
Authority (2018), recognizing trauma histories within incarcerated individuals is important
because prison itself can exacerbate PTSD symptoms. Further, prevalence rate of PTSD is higher
among those in correctional facilities than those in the general population and are often as high
or higher than those individuals that served in the military. Wraparound services are needed to
find housing, employment, treatment and other services to reintegrate those individuals into our
communities. We will also create programs around life skills, such as job readiness, resume and
interview training, money management and community engagement. We plan to provide
periodic social worker consultations. Many homeless or veterans and other indigents have
difficulty accessing public services because of the lack of “simple” things like a state-issued ID
or bus fare. One way we can help is by funding social workers to guide them through these
processes as well as the paperwork necessary to begin receiving more substantial public services.
Most recently, in 2020, we launched “Viola Cares” with a partnership with a national
nonprofit organization “Rood & Rebound”. Our Company, in conjunction with Root & Rebound,
will produce a first-of-its-kind toolkit designed specifically for people with non-violent cannabis-
related convictions, to be entitled: “A New Leaf: A How-To Guide for Successful Reentry After
a Cannabis Conviction.” An excerpt from the February 2020 article written in Cannabis Business
Times:
“Viola’s first strategic alliance within its Viola Cares program kicks-off with Root &
Rebound. Root & Rebound is home to lawyers and advocates committed to restoring power and
resources to the communities most harmed by mass incarceration and the War on Drugs. Their
work combines direct legal services with systems-changing policy advocacy and public
education, in an effort to move society toward greater racial and economic equity, justice,
collective liberation and intergenerational healing. Their educational resources like the
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California Roadmap to Reentry, the Reentry Planning Toolkit, the National Fair Chance
Housing Toolkit, and others have supported thousands of people as they work to navigate the
collateral consequences of an arrest or conviction history.” – Patrick Williams, Cannabis
Business Times
We fully understand that the Fresno’s unemployment rate is at an all-time high around
10.1%, according to the Bureau of Labor Statistics, September 2020. Many Fresno residents are
without jobs due to COVID-19 shutdowns, major corporations looking to cut expenses and
squeeze profit margin given the pandemic, but in ALL states that operate cannabis programs,
they deem cannabis an essential business. If our Company is awarded a CCB license, we plan on
staffing our facility immediately. We plan on creating a Layoff Reemployment Program,
where if an individual has been recently laid off due to “big industry or industrialization” our
Director of Human Resources will place their resume near the top of the pile when looking to
staff our locations. Every month, California publishes a WARN Activity Listing, that outlines
massive layoffs by companies due to closing or budget cuts. We realized that many of these
layoffs are targeted at minorities and women. Our Compassionate Benefits and Investment Plan
would like to help those individuals by providing and training those individuals with new skills
to be candidates for jobs in cannabis in Fresno.
OTHER COMMUNITY ENGAGEMENT INITIATIVES
It is very important that our Company empower and educate local community members
about the following: (i) the science, history and health benefits of cannabis, (ii) empowerment
through voting registration expressing your right to vote and (iii) community training on law
enforcement interactions. The War on Drugs not only negatively impacted families of color
through incarceration, the opioid epidemic has done huge harm to the fabric of American
families and how Schedule II-IV drugs that are prescribed can be considered “gateway drugs” to
cocaine, methamphetamine or heroin and other illegal substances.
Without proper education many residents despise the use of cannabis as an alternative to
opioids or other addictive / abusive drugs. Often times, the lack of cannabis education can
project a valid sense of ignorance, but after speaking with knowledgeable agents that understand
the community needs, community members become more receptive to cannabis use. We will
conduct community meetings to educate those individuals on the positive health benefits of using
cannabis within one’s daily lifestyle. We will also discuss the Fresno rules and regulations, to
make sure our community members are not misinformed on consumption and possession laws.
During education sessions we will use our Fresno law enforcement relationship to
provide information on how to interact with police when stopped with medical cannabis in
possession. We do not want any of our customers to think decriminalization means disregard for
the law. Our Company promotes safe and responsible use of medical cannabis at all times. Led
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
8
by our Director of Community Outreach, we will inform customers on the “do’s and don’ts” of a
traffic stop, hopefully reducing the amount of criminal offenses because of cannabis possession.
Not only will we meet with community members, but we will also educate local law enforcement
officers on things to look for when confirming possession of cannabis. We believe everyone
wants to see all communities policed in a responsible, safe and respectful manner.
The diversity of our team is proven through actual diversity of our actions. In 2020 we
partnered with a non-profit, Yo Soy Ella Inc., which is a woman owned, operated and funded
organization that provides mental and emotional wellness services, and holistic healing to
marginalized Latinx women. Yo Soy Ella has served over 300 Latinx women annually. The
founder is first generation American and her parents fled financial instability from their native
country of Panama to seek refuge in America. Yo Soy Ella was founded in 2012 and served a
need in the Latinx neighborhoods as Latinx women were being marginalized and not provided
culturally appropriate services to deal with physical and mental abusive households. Our
Company has developed a partnership with Yo Soy Ella, to lead cannabis education classes in
Spanish and the founder will serve as our Heritage Liaison, bridging the gap between the Latinx
culture and the positives of cannabis in majority Latinx neighborhoods. Fresno has a large Latinx
community consisting of 49.6% of the total population. We will partner and collaborate with
Fresno Latinx community organization to provide financial assistance and cannabis education.
The level of our commitment to local community can be seen anywhere we operate. For
example, in Detroit we hosted a Turkey Giveaway Drive for those families in need of providing
food for their Thanksgiving. We gave away more than turkeys and sides to more than 2,000
families in need, we spent $ on the event and signed up more than 500 volunteers. The
event was co-sponsored by Viola, local radio station, local hip hop entertainers and athletes.
Community engagement is a serious pledge within our Company, so serious that Al Harrington,
our founding partner personally hosted, and hand delivered turkeys. In Fresno, we plan to
provide turkey giveaways, community branding campaigns, neighborhood beautification
projects, sponsoring local youth athletic teams, sponsoring health and fitness days and
sponsoring a back to school drive, giving away backpacks to those parents in need of assistance.
An excerpt from the December 2019 article written in Forbes:
“The event, a result of a partnership between Harrington’s cannabis brand, Viola, and Motown
Records (the legendary label that put out records by some of the biggest names in music history,
from Stevie Wonder and Marvin Gaye, to Diana Ross, the Jackson 5 and Bruno Mars) saw
Detroit Mayor Mike Duggan and the celebs come together to gift people 2,000 turkeys and diner
sides for Thanksgiving.” – Javier Hasse, Senior Contributor, Forbes
All community programs will be funded using proceeds from our operations placed in
our Community Impact Fund. Upon being hired all agents must commit to 8 hours of local
community service. We expect to have well over $ annually in our Community Impact
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
10
Ms. Sengal’s service also includes serving in an advisory capacity for initiatives like The
Children’s Movement of Fresno and the Mayor’s Citizen’s Academy. In her role as the Co-
Facilitator for the Mayor’s Citizen’s Academy Laneesha was a visionary who championed the
citywide effort to forge a partnership between non-profits and parks and recreation centers.
Ms. Senegal received a Bachelor of Arts in Organizational Leadership from Fresno
Pacific University.
7.2 Describe the Commercial Cannabis Business plan to develop a public health
outreach and educational program that outlines the risks of youth use of cannabis
and that identifies resources available to youth related to drugs and drug addiction.
Given our strong commitment to community engagement, our CEO, COO and architects
designed our proposed facility with a Community Education and Training Center (“CETC”).
This space will be separate of our facility, with its own entrance and exit and does not have
entrance access to any part of our production or storage areas. We will seek to educate
community members on responsible cannabis use and how to cope with substance addiction. We
will help facilitate counseling services, as our local partners will have the experience in
providing much needed human services programs to underserved populations and people living
with an array of health and human service needs.
Our partnered curriculum will include (i)
Alcohol/Substance Abuse Treatment, (ii) Mental Health
Services, (iii) Disability Services, (iv) Violence
Prevention and Trauma; and (v) Coping Strategies. Their
informational pamphlets will be in our CETC. We will
also work with other substance abuse service companies
located across Fresno. Fresno and surrounding cities,
like many other cities, has seen the devastating effects of
the opioid epidemic. If a non-profit or counselor needs
to have a private counseling session, our CETC will be
fully built out and equipped with state-of-the-art
technology, a cannabis education library (with take
home brochures), bathrooms, a kitchen and private
consultation offices. Community organizations will have access to our Community Education
and Training Center to host these events at no to little cost.
Addiction & Drug Abuse Support: We will also seek to educate at risk youth on the risks
of early cannabis use and addiction. We will facilitate counseling services through a local Fresno
human services agency that uses a continuum of care approach to provide much-needed
programs to underserved populations and people living with an array of health and human
service needs. We will work in partnership to develop a curriculum regarding (i)
Floor Plan of our CETC
Compassionate Benefits and Investment Plan TRADE SECRET
Appendix A: Evaluation Criteria
11
Alcohol/Substance Abuse Treatment, (ii) Mental Health Services, (iii) Disability Services, (iv)
Violence Prevention and Trauma; and (v) Coping Strategies.
At Risk Youth Programs
We will us our celebrity platform to speak with at risk Fresno youth regarding risks of
youth use of cannabis, early addiction and prevention. We will offer a few programs that include:
• Mentoring program designed to empower young adults and teenagers into becoming
leaders by encouraging positive relationships with adults to make positive impacts.
Desired outcomes include participating youth will have better school attendance,
higher academic performance and improved social and emotional skills. These
outcomes typically lower engagement in unhealthy behaviors like drug and substance
abuse or violence.
• Creative learning and entrepreneurship programs to identify the gifts of teenagers and
young adults and bring their talents to the forefront.
• Multi-faceted youth development program. Its purpose is to instill in youth the core
elements and needed competencies for healthy human development.
Along with the above programs, many of our team members grew up on D.A.R.E. (Drug
Abuse Resistance Education) programs in elementary schools which taught us that drugs are
harmful, addictive and can lead to incarceration or death. This had a positive lasting impact when
faced with drug interactions as a youth in middle or high school or even college. While many
D.A.R.E. programs are obsolete, we plan to partner with the local Public Schools’ Department of
Social and Emotional Learning to initiate conversations of drug awareness. Many public schools
sponsor Red Ribbon Week, which is a weeklong program that implements drug awareness,
similar to D.A.R.E., by allowing parents, teachers, educators and community organizations to
raise awareness of the problems caused by drug abuse.
Our Director of Community Outreach will sponsor Red Ribbon Week in all communities
where we operate, typically partnering with local elementary and middle schools. Red Ribbon
Week is a curriculum that teaches the destructive effects of drug abuse and opioid abuse. Action
can be taken by the smallest and largest of events, such as sponsoring an anti-drug poster and
essay contest, creating an anti-drug Public Service Announcement (PSA) to be posted on our
Company social media account, hosting community drug awareness events, such as health and
wellness days, bike-a-thons, classroom decorating contest and taking the pledge to promote
living a healthy, drug-free lifestyle. Our team has reached out Chicago Public Schools about
sponsoring these programs and we look forward to sponsoring in all areas where we operate.
Proceeds from our Company’s operations will be used for our Community Impact Fund which
will be used to sponsor and host drug awareness events.
Photo: Jorge Meza Viola Launches Viola Cares with National Nonprofit Organization Root & Rebound
The social impact initiative aims to destigmatize minority representation and increase
social equity within the cannabis industry.
SUBSCRIBE
February 28, 2020
Posted by Patrick Williams
Vendor News
On Feb. 26, Viola, a nationwide leader in the production and sale of premium quality
cannabis products, founded by NBA veteran Al Harrington, announced the official
launch of its social equity initiative, Viola Cares. Through education, equitable offerings,
expungement, and incubation programs, the initiative will result in more than 10,000
jobs, hundreds of new business owners and expanded industry diversity by increasing
representation, facilitating community building and providing employment opportunities.
Viola’s first strategic alliance within its Viola Cares program kicks-off with Root &
Rebound. Root & Rebound is home to lawyers and advocates committed to restoring
power and resources to the communities most harmed by mass incarceration and the
War on Drugs. Their work combines direct legal services with systems-changing policy
advocacy and public education, in an effort to move society toward greater racial and
economic equity, justice, collective liberation and intergenerational healing. Their
educational resources like the California Roadmap to Reentry, the Reentry Planning
Toolkit, the National Fair Chance Housing Toolkit, and others have supported
thousands of people as they work to navigate the collateral consequences of an arrest
or conviction history.
Viola, in conjunction with Root & Rebound, will produce a first-of-its-kind toolkit
designed specifically for people with cannabis-related convictions, to be entitled: “A New
Leaf: A ‘How-To Guide’ for Successful Reentry After A Cannabis Conviction.”
“At Viola, we live and breathe the belief that a cannabis conviction should never be
considered a life sentence,” said Al Harrington, founder, Viola. “In joining forces with
Root & Rebound, we will look to help those communities of color who have historically
been the victims of cannabis-related incarceration and who have fallen on hard times,
and turn those struggles into opportunities for success within this rapidly growing
industry.”
Opportunity within the cannabis industry only continues to grow as legalization
progresses and passes into law across the country, and Viola is breaking the barrier of
entry for minorities to contribute to that growth through cultivation and entrepreneurship.
“We’re honored to be working side-by-side with Viola on such an important initiative--
one that positively impacts thousands who have been unfairly stigmatized by their prior
cannabis-related incarceration,” Katherine Katcher, founder and executive director of
Root & Rebound. “Together we’re changing that conversation, leveling the playing field
for minorities and creating opportunities for those deserving of a second chance.”
Viola hosted the official launch of Viola Cares on the evening of Feb. 26 at its Hollywood
HQ.
The evening commenced with Viola CMO Ericka Pittman, who welcomed guests with
opening remarks.
Viola co-founder Al Harrington then introduced the partnership sharing how Viola plans
to use their platform to amplify the work and impact of Root & Rebound.
Root & Rebound team Eliana Green and Sandra Johnson led by founder and Director
Katherine Katcher joined Harrington to kick off the moderated panel. The fireside chat,
“The Effect of Social Impact and the Path Forward,” dove into the current issues our
country currently faces with mass incarceration. Sandra candidly shared her first-hand
experiences being collateral damage from the war on drugs and disclosed her re-entry
journey through Root & Rebound. Sandra tearfully explained how the system had held
her hostage to her past as she struggled to find and hold jobs despite doing everything
right.
Al Harrington opened up about the brand legacy that has shaped the New Leaf initiative
and the ways in which it will alter the trajectory of social equity moving forward. Both
Viola and Root & Rebound shared with the room the victorious outcome they envision
through the alliance: the ability to employ every person that returns from incarceration
as they reintegrate back into society.
https://www.cannabisbusinesstimes.com/article/viola-launches-viola-cares-root-and-
rebound-social-equity/
Multi-State Operator Cannabis Business
Social Equity Policies in Cannabis Industry
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 1/7
Vices
A column about cannabis, hemp, CBD and psychedelics.
Why Kash Doll And Vezzo
Partnered Up With Al
Harrington’s Weed Company,
Even Though They Don’t Smoke
EDITORS PICK 932 views Dec 6, 2019, 04:09pm EST
Javier Hasse Senior Contributor
It was a festive occasion in Detroit as people gathered to meet rappers
Kash Doll and Vezzo, as well as NBA star Al Harrington – and get a free
turkey ahead of Thanksgiving out of it all!
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 2/7
Vezzo takes a sel e with a child and
mother. BREANN WH E
Vezzo, Kash Doll, Al Harrington (L-R) BREANN WH E
The event, a result of a partnership between Harrington’s cannabis brand,
Viola, and Motown Records (the legendary label that put out records by
some of the biggest names in music history, from Stevie Wonder and Marvin
Gaye, to Diana Ross, the Jackson 5 and Bruno Mars) saw Detroit Mayor
Mike Duggan and the celebs come together to gift people 2,000 turkeys and
diner sides for Thanksgiving.
The giveaway coincided with the opening of Viola’s first flagship retail store
in the Motor City.
A Smoke-Free Environment
Beyond the obvious relevance of such a generous act and the joy these
celebrities brought to the good people of Detroit, what makes this
partnership really interesting is the fact that neither Kash Doll nor Vezzo
consume cannabis.
Yes, you read right: rappers Kash Doll
and Vezzo are not into weed – at all. In
fact, both lead lives that are pretty much
free of all mind-altering substances.
Vezzo never drinks, while Kash might
have a few glasses of champagne a
month, tops.
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11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 3/7
“I don’t like to smoke weed or take pills. I don’t have an issue with people
who do, but I don’t,” Kash explained.
Vezzo added, “I don’t consume cannabis either. Ever. But I’m not against
other people consuming cannabis.”
He also called for more research around marijuana and explained he
understands the difference between this plant and other dangerous things
like cocaine, heroin or guns. These should remain outlawed, he noted. But
cannabis: we have to make up our minds; “we either want it legalized or
not.”
“This is a gray area and, for me, there’s no balance in gray areas – you know
what I’m saying? How is it possible that some people can have rooms full of
legal plants while others go to jail for the rest of their lives for the same
plant?” Vezzo continued.
See Also: Eric B. & Rakim’s ‘Follow The Leader’ Reimagined
Displaced Michael Bublé From His #1 Billboard Spot—And
Cannabis Played A Big Role
“I believe cannabis should be legal on the federal level. You look at
Michigan, you look at all of the states that have legalized recreational
marijuana, and you see an impact on the [employment, fiscal revenue, etc.]
numbers.”
So, what in the world made them want to partner with a weed company, of
all businesses in Michigan?
“I take my hat off to Vezzo and Kash Doll for
being open minded enough to partner with a
cannabis company even though they don’t
consume themselves.”
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 4/7
An Unexpected Partnership
When asked about this unexpected partnership, Kash Doll explained, “Viola
and Al are bringing new business and jobs to Detroit… I’m happy to partner
with anyone that’s investing back into the city and helping give new positive
opportunities to the people of Detroit.”
DETROIT, MI HIGAN MAR H 09 Detroit rapper Kash Doll performs in support of The Motivation Tour
at ... [+] GE Y MAGES
She repeated: it’s all about picking good people to collaborate with. Period.
“I don't care what you’ve done in the past, who you are, or whatever. I love
to just collaborate with people trying to do something great for the people,
so I was honored that they wanted to work with me,” Kash went on.
Al didn’t mind Kash and Vezzo’s position either. “We wanted to do
something good and partner with local rappers, entertainers, even athletes,
to make an real impact on the community,” he explained. “Being from
Detroit, Kash and Vezzo helped us, out-of-towners, really get the job done.
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 5/7
Al Harrington and Vezzo in Detroit.
BREANN WH E
See Also: Key Committee In Congress Approves Marijuana
Legalization Bill
“Kash and Vezzo really made a difference. A lot of people showed up and I
feel like they are going to have a better holiday because of them,” Harrington
continued.
Vezzo was first and foremost drawn to
Viola because of Al Harrington’s
history of involvement with the Detroit
community. But there was another
component to the Motown-Viola
partnership: willingness to help.
“What’s really sad is I went to many
companies and brands, and nobody
else wanted to help,” he said. “It’s crazy
that it takes a cannabis brand to help
these people.”
For readers who are not particularly
familiar with the cannabis industry,
there’s one thing you should know:
cannabis brands are already exposed to
extremely high taxes when compared to any other business out there, and
many of these charitable donations cannot be deducted from their taxes
either, due to provisions in Section 280E of the Internal Revenue Code.
“What’s really sad is I went to many
companies and brands, and nobody else
wanted to help... It’s crazy that it takes a
cannabis brand to help these people.”
11/16/2020 Why Kash Doll And Vezzo Partnered Up With Al Harrington’s Weed Company, Even Though They Don’t Smoke
https://www.forbes.com/sites/javierhasse/2019/12/06/kash-doll-vezzo-harrington-weed/?sh=79f6ef302b31 6/7
“I take my hat off to Vezzo and Kash Doll for being open minded enough to
partner with a cannabis company even though they don’t consume
themselves,” Al concluded. “I think it’s admirable that they realize that this
is bigger than if they use the product or not… What we need to realize as
blacks and minorities is that this is a unique opportunity for us to
participate in an industry that pretty much was built on our backs. So it’s
great that we can break these barriers, change the stigma,
Sharing The Green
Vezzo said he went to all kinds of companies, from the food to the clothing
space, looking for partners to help him bring some joy to people during the
holidays. “Nobody wanted to help with this giveaway,” he disclosed. “We
have so many big businesses and corporations just in Detroit alone that it’s
crazy it takes a small cannabis business to actually want to give out to the
community.
“I asked myself this question many times… On top of not helping anyone,
many companies out here are making people work for 60 hours, making
them build an entire car, but not offering health insurance and things like
that. They just leave their employees to figure out things on their own, even
Christmas and Thanksgiving. Even though they know many can’t provide a
nice meal for their families, they won’t lift a finger to help. But Viola did.”
Vezzo, Kash Doll and Al Harrington all seemed extremely moved with the
Thanksgiving event and turnout. “It feels great,” they said once and again.
“I feel it’s a blessing to be in a position where we could provide many
families a full Thanksgiving meal, which is not cheap,” Vezzo said.
“It was just amazing, it made my heart happy.
This was one of my favorite things to do.”
Neighborhood Compatibility Plan
Appendix A: Evaluation Criteria
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
1
3.1 Describe how the CCB will proactively address and respond to complaints related to
noise, light, odor, litter, vehicles and pedestrian traffic
Our Commercial Cannabis Business (CCB) will have a Neighborhood Committee (NC),
that consists of the CEO, Dispensary Manager and designated dispensary agents. If there are any
issues with noise, light, odor or trash, our neighbors can contact our committee through our
website, or social media. Along with our public information, our CCB will provide the name,
telephone number and email address of our Neighborhood Committee contact to whom notice of
problems associated with the business can be provided. We will provide our contact information
to all businesses and residences located within one hundred (100) feet of our business. SEC 9-
3309(m)(1). Our Neighborhood Committee will receive complaints, review complaints and
provide solutions for the compliant. Please see below how we prevent noise, light, odor and
waste management
Loitering, Nuisance Prevention & Onsite Parking
Our Company believes in being good neighbors and complying with all rules and
regulations. Our facility will operate like any other law-abiding business. Unlike many other
local businesses, we will have security officer(s) roaming the exterior of the facility, preventing
loitering from customers or others. Our facility will have a no loitering policy and “NO
LOITERING” sign will be visibly placed at our entry door and near all parking spaces.
Employees are expected to leave the parking lot promptly after work. A security guard roaming
our building will consistently and systematically prevent individuals from remaining on the
premises if they are not engaging in activity permitted by the Act or rules, which includes
preventing loitering in and around our property. If individuals are loitering, our security staff will
ask them to leave our property and record any information regarding license plate or physical
description of the individuals. If we see the individuals loitering multiple times, we will notify
Fresno law enforcement. Per SEC 9-3309(l) our CCB will prohibit loitering by persons outside
the facility both on the premises and within fifty (50) feet of the premises.
Cannabis will NOT be allowed to be consumed by any person on the premises; no person
will cause or permit the sale, dispensing, or consumption of alcoholic beverages on or about the
premises of our CCB; and no person will cause or permit the sale of tobacco products on or
about the premises of our CCB. SEC 9-3309(a)(b)(c).
Our building will have all the necessary attributes to serve employees and the
community. We will have a large, private and dedicated onsite parking lot that provides handicap
Americans with Disability Act (ADA) spaces. Our security staff would monitor our parking lot
and we would comply with our typical surveillance plan. The parking lot will have dedicated
security surveillance, including 1 camera and exterior light for every 5 parking spaces. Cameras
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
2
will be equipped with license plate recognition and low light high definition capabilities to over
100 feet from the exterior of the building.
Our facility will provide law enforcement and neighbors within 100 feet of our building
with the name, phone number and email of our CEO and Security Manager to notify during and
after operating hours whom they can report problems if they were to arise.
Lighting
Our CCB will keep the outside perimeter well-lit. All cameras are equipped with infrared
illuminators, in the event that lighting is compromised; these infrared illuminators will produce
clear visible video data in absolute darkness.
Our facility will be well lit during all hours of the day
using smart lighting. Exterior lighting will not distract or
hinder the local neighborhood activities but will make visible
any intruder trying to divert product. Our design will comply
with Fresno Outdoor Lighting Ordinance rules as well as
Fresno lighting for security code. Our lighting system will
provide sufficient illumination and clear visibility to all
outdoor areas of premises, including all points of ingress /
egress and parking lots, reduce light pollution and will not
trespass onto adjacent properties.
We plan on installing LED Cobra Head Lights in all parking areas. These style lights are
often used for street lighting because they’re shaped in such a way that diffuses light to cover a
wide area of ground. Our delivery doors will also include LED lights that will monitor the
receiving, shipping and loading area during all hours of the day. Our Cobra Head Lights will be
maximum heights of 16 feet with compact housings emitting 120-277 watt lights. For safety and
security, during business hours, all parking areas and heavy pedestrian areas will be equipped
with Cobra Head Lights that will provide a minimum one-foot candle of light at ground level
during the hours of darkness. We plan to install one exterior light for every 5 parking spaces. Our
lights will be shielded or recessed to reduce light bleed to adjoining properties. Our local
construction partners will make sure light bulbs are not visible from off the site and check for
glares and reflections within boundaries of our facility.
All of our exterior lights will face downward and away from adjoining properties and
public rights-of-way so that no on-site light fixture directly illuminates an area off the site. None
of our exterior lights will permanently blink, flash or be of unusually high intensity or brightness.
All exterior lights will be sufficient to deter nuisance and criminal activity and facilitate
surveillance and must not disturb surrounding businesses or neighbors.
LED Cobra Light -Example
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
3
Community Involvement
We believe the detection of cannabis odors from outside our facility will be a team effort
with our surrounding neighbors. As experienced cannabis operators, many times we become
“nose-blind” to the odor of cannabis. We will regularly monitor the site and point sources of
odor generation. By forming the Neighborhood Committee, we will validate that our technology,
maintenance and testing are all functioning properly. Finally, given our proximity to neighboring
buildings we will have a process for the reporting of odor detection by staff and the public to
facilitate immediate response. Every business and resident within one hundred (100) feet will be
given the contact information of our Neighborhood Committee. If any issues arise the local
neighbors can contact our facility directly.
Proactive communication through the NC is an excellent way to promote the emergence
of communication between the employees of our facility and nearby businesses and residents. In
the process of setting up the NC, a group of volunteers from the community are trained to
recognize and quantify odors and how to report odors in a consistent manner. The NC provides
an effective communication channel between members of the community and our CCB
employees.
Our security staff will constantly remind our employees, customers and visitors to be
mindful of our neighbors and our neighborhood to ensure they are entering and leaving our
facility, parking in designated spaces and not being a nuisance in and around our CCB.
This helps to convey the odor mitigation plans objectives and odor observations relevant
for environmental monitoring and management operations. On a regular basis, members of the
NC are invited to review the results of their participatory monitoring and actions implemented by
our CCB.
The Neighborhood Nuisance Form will be provided on our website. The form can be
downloaded submitted by email, in person at our facility or mailed to our facility.
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
4
3.2 Describe how the CCB will be managed to avoid becoming a nuisance or having
impacts on its neighbors and the surrounding community
Our Company believes in being good neighbors and complying with all rules and
regulations. Our facility will operate like any other law-abiding business. Unlike many other
local businesses, we will have security officer(s) roaming the exterior of the facility during
business hours, preventing loitering or negative impacts from customers, visitors or others.
Having security onsite will prevent many of these issues and typically cannabis businesses tend
to have positive impacts on communities because of the constant security presence. Our facility
will be managed with local Fresno residents. We feel this is important because local residents
tend to care about their neighborhoods and this has proven to be true in our other facilities. We
will have a Neighborhood Committee that will be provide solutions if our CCB becomes a
nuisance to the community.
Our facility will have a no loitering policy and “NO LOITERING” sign will be visibly
placed at our entry door and near all parking spaces. Employees are expected to leave the
parking lot promptly after work. A security guard roaming our building will consistently and
systematically prevent individuals from remaining on the premises if they are not engaging in
activity permitted by the Act or rules, which includes preventing loitering in and around our
property. If individuals are loitering, our security staff will ask them to leave our property and
record any information regarding license plate or physical description of the individuals. If we
see the individuals loitering multiple times, we will notify Fresno law enforcement. Per SEC 9-
3309(l) our CCB will prohibit loitering by persons outside the facility both on the premises and
within fifty (50) feet of the premises.
Cannabis will NOT be allowed to be consumed by any person on the premises; no person
will cause or permit the sale, dispensing, or consumption of alcoholic beverages on or about the
premises of our CCB; and no person will cause or permit the sale of tobacco products on or
about the premises of our CCB. SEC 9-3309(a)(b)(c).
Our building will have all the necessary attributes to serve employees and the
community. We will have a large, private and dedicated onsite parking lot that provides handicap
Americans with Disability Act (ADA) spaces. Our security staff would monitor our parking lot
and we would comply with our typical surveillance plan. The parking lot will have dedicated
security surveillance, including 1 camera and exterior light for every 5 parking spaces. Cameras
will be equipped with license plate recognition and low light high-definition capabilities to over
100 feet from the exterior of the building.
Our facility will provide law enforcement and neighbors within 100 feet of our building
with the name, phone number and email of our CEO and Security Manager to notify during and
after operating hours whom they can report problems if they were to arise.
Our CCB will continually maintain the premises and its infrastructure so that it is visually
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
5
attractive and not dangerous to the health, safety and general welfare of employees, patrons,
surrounding properties and the general public. The premises will not be maintained in a manner
that causes public or private nuisance. Litter will be removed daily from the premises, including
adjacent public sidewalks and all parking lots under the control of the cannabis retail business or
commercial cannabis business. All areas will be swept or cleaned daily, on a weekly basis to
control debris and upkeep and operating characteristics will be compatible with abutting
properties and the surrounding neighborhood, per SEC 9-3309(n).
Neighborhood Compatibility Plan TRADE SECRET
Appendix A: Evaluation Criteria
6
3.3 Describe odor mitigation practices
Our facility will operate 7 days a week, using our odor mitigation plan and other
environmentally friendly procedures we will minimize our impact to the community. We
understand that cannabis odor could be a major concern for all residents nearby our facility. Our
Company is prepared to take preventative measures to ensure that our facility does not disturb
the environment or culture in the neighborhood. We will do our best to comply with local
ordinance and odor prevention rules and regulations. Our odor mitigation plan will outline the
steps that will be taken to mitigate cannabis odors and establish a responsible plan of action if
cannabis odors are detected outside our facility.
It is important to our management that our various community plans remain transparent
so all community members understand the importance of mitigated cannabis odors. Thus, our
mitigation plan and records will be made available to the public and documents can be requested
at our facility. We plan on presenting our findings and methods of prevention at monthly
community meetings, if necessary. Communicating this plan to our neighbors, Fresno residents
and local community members is a key component to our Neighborhood Compatibility Plan.
Establishing a Neighborhood Committee (NC) will be tasked at the first community meeting.
Volunteers from the community will be asked to participate in the detection and relay of odor
observations. The NC will volunteer and designate one of the local business / homeowners,
within one hundred (100) feet of our facility, to be the individual that files formal complaints or
comments to our Company and to the City Manager.
Occasionally the dispensing of cannabis products will produce an odor, but please
understand that all cannabis products we sell to customers will be pre-packaged on site in our
final packaging area, and cannabis will NOT be in the open and available on our sales floor.
To be on the safe side, our Company will take extra measures to prevent undesirable
odors by utilizing various bio-filtration systems to reduce the odor, air-sealed storage techniques
and technological monitoring tools.
Prevention
Our Company believes odor prevention and mitigation helps protect our local
community and better the environment. We will design our Fresno facility putting procedures
in place to prevent the smell of cannabis odors from escaping our premises into the rest of the
building. To follow SEC 9-3309(j)(1)(2), we will have the best available odor control
technology and devices will be incorporated in our CCB to ensure that odors from cannabis are
not detectable off-site. A sufficient odor absorbing ventilation and exhaust system will be
provided so that odor generate inside the premises that is distinctive to its operation is not
detected outside the facility, anywhere on adjacent property or public rights-of-ways, on or
about the exterior or interior common area walkways, hallways, breezeways, foyers, lobby
areas, or any other areas available for use by common tenants or the visiting public, or within
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7
any other unit located inside the same buildings as the CCB. The following equipment, or any
other equipment which the Planning and Development Director or his/her designee(s)
determine is a more effective method or technology must be installed and maintained:
1. An exhaust air filtration system with odor control that prevents internal odors and
pollen from being emitted externally;
2. An air system that creates negative air pressure between the premises’ interior and
exterior, so that the odors generated inside the premises are not detectable outside
the premises.
In NO state, where we operate, have we experienced odor complaints from our
neighboring businesses or residents. These steps detect, mitigate and prevent odors from
reaching the public.
Charcoal Air Filters and HVAC: A charcoal air purifier or charcoal filter, also commonly
known as an activated carbon air filter, works by absorbing the gases and odors in the air. The
charcoal pellets are activated carbon that has been treated with oxygen to open up millions of
pores in between the carbon atoms. This works so well because the millions of tiny cells that are
in the charcoal in addition to being very porous also attract and capture odors and gases.
Charcoal filters help clean air of particles as to reduce airborne odors, all the while our HVAC
will consist of a carbon filtration system to circulate and remove odors and toxic chemicals.
Our facility will have multiple new energy
efficient HVAC systems that will include charcoal
air filters and monitoring tools that will be utilized
to clean and reduce smells. The filtration system
will consist of one or more fans, activated carbon
filters and be capable of scrubbing the air. At a
minimum, the fan(s) will be sized for cubic feet
per minute (“CFM”) equivalent to the volume of
the building (length multiplied by width
multiplied by height) divided by three. The
filter(s) will be rated for the applicable CFM.
Bulk carbon filters will attach directly to the exhaust of each air handling unit. Carbon
filters make use of active carbon that is equipped with highly porous charcoal that allows air to
pass through, but the odor is trapped, preventing smells from circulating the facility. Our carbon
filters will use 1050+ IAV charcoal, which is one of the most absorbent charcoals available. The
filters will be made out of heavy-duty galvanized stainless steel for maximum durability and
longevity with perforations at 53% open to maximize airflow and odor management. Our
engineers suggest we use EnviroKlenz filters. The EnviroKlenz technology is a highly effective
“destructive absorbent” material designed for chemical containment and neutralization. We will
ensure our EnviroKlenz system is in good working order with monthly inspections from our
certified engineer. We also plan to use ozone generators that will be utilized when necessary to
Charcoal Carbon Filter
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Appendix A: Evaluation Criteria
8
measure Dilution to Threshold (“D/T”) ratios indicated by the HVAC’s D/T sensors. All controls
will be monitored in such a way to know how efficient and effective our facility is mitigating
odors.
Controlled Storage: All cannabis products will be securely stored in our Vault Room. As
detailed in our Security Plan the Vault Room will comply with all rules and regulations. The
Vault Room will be temperature controlled, maintaining 55-65 degrees. All products will be
vacuum sealed and placed on shelves for final inventory. Our COO believes in vacuum sealing
our inventory to prevent cannabis odors, meanwhile keeping the product fresh from oxidation,
which maintains the products medicinal qualities. All flower raw material will be maintained in
vacuum sealed bags.
Design: Our facility will have stationary windows, meaning they cannot be opened. All
our doors will be sealed with proper weather stripping, keeping air circulating and filtered inside
of our facility. Onsite use of cannabis products will be strictly prohibited, which we believe helps
further mitigates any potential cannabis odors from reaching to our neighbors. Negative air
pressure will be maintained inside the building.
Packaging: All cannabis products we dispense will be packaged and sold in childproof
packaging. All dried cannabis flower and all cannabis display containers will be enclosed within
our sales floor. We will NOT display raw flower in jars and weigh on the sales floor, all cannabis
will be pre-packaged before sale.
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3.4 Identify potential sources of odor
Our CCB will operate as a retail facility and the only source of odor will be cannabis
odor from the products we sell within our dispensary. Our dispensary is NOT cultivating or
producing cannabis products. Close to 60% of our products will be pre-packaged and sold in its
original packaging. The only cannabis not packaged in its original packaging will be wholesale
dried flower that we plan on packaging in our dispensary in sealed child-proof bags or vials. As
mentioned within this application, we mentioned the following to prevent odors: charcoal filters
and HVAC, controlled storage, design and pre-packaged products.
Cannabis will NOT be allowed to be consumed by any person on the premises; no person
will cause or permit the sale, dispensing, or consumption of alcoholic beverages on or about the
premises of our CCB; and no person will cause or permit the sale of tobacco products on or
about the premises of our CCB. SEC 9-3309(a)(b)(c).
In NO state, where we operate, have we experienced odor complaints from our
neighboring businesses or residents. These steps detect, mitigate and prevent odors from
reaching the public.
No outdoor storage of cannabis or cannabis products is permitted at any time, per SEC 9-
3309(d).
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3.5 Describe odor control devices and techniques employed to ensure that odors from
cannabis are not detectable beyond the permitted premises
We fully understand the importance of cannabis odor mitigation and will do our best to
prevent the issue, but if odors were to be detected outside our facility we have a plan to monitor,
detect and remediate. Our devices and techniques are below:
Monitor: Each day the CEO and Dispensary
Manager will assess the on-site and off-site odors for
potential release of objectionable odors. While
driving in the facility each day we will be able to
physically monitor odors from outside the facility.
The CEO will designate an agent to be responsible
for assessing and documenting odor impacts daily.
To enhance our odor detection, we plan on
purchasing the Nasal Ranger. The Nasal Ranger is
an ISO 9001 certified device, based on a scientific
method, which can quantify odor strength in terms
of Dilution to Threshold (“D/T”) ratios.
Detect: Studies have determined that a 7:1 D/T ratio was a detectable level of cannabis
odor. Our Company will use a 6:1 D/T ratio for a measurable maximum threshold. The Nasal
Ranger also has a subscription web-based application that provides electronic repository for all
odor data.
For example the Odor Track'r™ permanently stores odor inspection data, such as
date/time; location code numbers, descriptions, and GPS data; odor strength as D/T from the
Nasal Ranger, butanol intensity or word scale intensity; odor character descriptors; and
meteorological data (temperature, humidity, barometric pressure, wind direction, wind speed,
precipitation and sky cover). If we decide to use the subscription web-based application. Our
CEO or designated agent will input that data into our Inventory Tracking System and make
available to the City Manager. The City Manager will have the ability to visually track and
monitor cannabis odor outside our facility in real time.
If necessary, the sensors in our HVAC will be able to read, record and store D/T levels as
well. We will use all data received to adjust our Odor Plan accordingly. Most likely and the most
effective way to detect the smell of cannabis odors outside our facility will be: customers,
outside personnel, delivery drivers, the public and other neighboring businesses.
Remediate: If highly questionable or objectionable off-site cannabis odors are detected by
local residents, the following protocols will be put into immediate action: (i) Investigate the
likely source of the odor; (ii) Utilize on site management practices to resolve the odor event
including monitoring tools to document D/T; (iii) Take steps to reduce the odor-generating
source; (iv) Determine if the odor traveled off-site by surveying the perimeter and making
Nasal Ranger
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Appendix A: Evaluation Criteria
11
observations of existing wind patterns; and (v) Document the event for further operational
review and the formulation of a corrective action plan. If employees are not able to take steps to
reduce the odor-generating source, they are to immediately notify the CEO. All communication
will be documented, and our team will come up with a proper solution, if applicable. All
employees will be trained on how to detect, prevent and remediate cannabis odors. Our odor
mitigation plan and records related to odor mitigation will be maintained at our facility and will
be available to any of our neighboring buildings upon request, to ensure our community
members are engaged with eliminating odors.
Design: Our facility will have stationary windows, meaning they cannot be opened. All
our doors will be sealed with proper weather stripping, keeping air circulating and filtered inside
of our facility. Onsite use of cannabis products will be strictly prohibited, which we believe helps
further mitigates any potential cannabis odors from reaching to our neighbors. Negative air
pressure will be maintained inside the building.
While other applicants may see an environmental plan as an option, we see it as
necessary to our operations. We feel it is our Company duty to educate the residents and lead by
example to eliminate odor and lower our carbon footprint and positively impact our local
environment. A well-engineered facility that properly employs well-maintained carbon filtration
technology (and ozone generation if this is insufficient) can then operate without imparting
offensive odors on the community.
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3.6 Describe all proposed staff odor training and system maintenance
We will train our agents to detect odors when they enter our CCB and we budgeted for a
maintenance engineer, which will allow us maintain our HVAC and filtration system in good
working order. As mentioned in this section we will follow all rules and regulations outlined in
SEC 9-3309(j)(1)(2).
We will have the best available odor control technology and devices will be incorporated
in our CCB to ensure that odors from cannabis are not detectable off-site. A sufficient odor
absorbing ventilation and exhaust system will be provided so that odor generate inside the
premises that is distinctive to its operation is not detected outside the facility, anywhere eon
adjacent property or public rights-of-ways, on or about the exterior or interior common area
walkways, hallways, breezeways, foyers, lobby areas, or any other areas available for use by
common tenants or the visiting public, or within any other unit located inside the same buildings
as the CCB. The following equipment, or any other equipment which the Planning and
Development Director or his/her designee(s) determine is a more effective method or technology
must be installed and maintained:
3. An exhaust air filtration system with odor control that prevents internal odors and
pollen from being emitted externally;
4. An air system that creates negative air pressure between the premises’ interior and
exterior, so that the odors generated inside the premises are not detectable outside
the premises.
In NO state, where we operate, have we experienced odor complaints from our
neighboring businesses or residents.
Charcoal Air Filters and HVAC: A
charcoal air purifier or charcoal filter, also
commonly known as an activated carbon air filter,
works by absorbing the gases and odors in the air.
The charcoal pellets are activated carbon that has
been treated with oxygen to open up millions of
pores in between the carbon atoms. This works so
well because the millions of tiny cells that ar e in
the charcoal in addition to being very porous also
attract and capture odors and gases. Charcoal
filters help clean air of particles as to reduce
airborne odors, all the while our HVAC will consist of a carbon filtration system to circulate and
remove odors and toxic chemicals.
Our facility will have multiple new energy efficient HVAC systems that will include
charcoal air filters and monitoring tools that will be utilized to clean and reduce smells. The
filtration system will consist of one or more fans, activated carbon filters and be capable of
Charcoal Carbon Filter
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Appendix A: Evaluation Criteria
13
scrubbing the air. At a minimum, the fan(s) will be sized for cubic feet per minute (“CFM”)
equivalent to the volume of the building (length multiplied by width multiplied by height)
divided by three. The filter(s) will be rated for the applicable CFM.
Bulk carbon filters will attach directly to the exhaust of each air handling unit. Carbon
filters make use of active carbon that is equipped with highly porous charcoal that allows air to
pass through, but the odor is trapped, preventing smells from circulating the facility. Our carbon
filters will use 1050+ IAV charcoal, which is one of the most absorbent charcoals available. The
filters will be made out of heavy-duty galvanized stainless steel for maximum durability and
longevity with perforations at 53% open to maximize airflow and odor management. Our
engineers suggest we use EnviroKlenz filters. The EnviroKlenz technology is a highly effective
“destructive absorbent” material designed for chemical containment and neutralization. We will
ensure our EnviroKlenz system is in good working order with monthly inspections from our
certified engineer. We also plan to use ozone generators that will be utilized when necessary to
measure Dilution to Threshold (“D/T”) ratios indicated by the HVAC’s D/T sensors. All controls
will be monitored in such a way to know how efficient and effective our facility is mitigating
odors.
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Appendix A: Evaluation Criteria
14
3.7 Describe the waste management plan
Waste Disposal: We have developed a strict policy for tracking, storing and disposing of
cannabis waste to ensure that no useable cannabis or cannabis oil is diverted or poses a threat to
our biosecurity. Our CEO will provide the City Manager with notice to dispose of cannabis
products waste at least 48 hours prior to the date of destruction and seek approval. The notice
will identify the items to be destroyed, whether the destruction will be compostable or non-
compostable, the landfill or incinerator that will receive it, and the date and time that the grinding
will occur. The notice will also include the weight and quantity data that is tracked in our
Inventory Tracking System (ITS). We will follow all destruction procedures as the City Manager
sees appropriate. Upon the request of the City Manager, the destruction will be rescheduled to an
alternative time. We will schedule the destruction for a date and time when the pertinent
personnel will be present and the destruction will be completed so that it is viewable by our
surveillance cameras system. Until destroyed, we will store the cannabis and cannabis product
intended for destruction in a locked container marked “Waste Cannabis Material. DO NOT
DISPENSE. Content Scheduled for Destruction.” The container will be located within a
segregated area in the Vault Room designated for product to be destroyed.
Maintaining Garbage: Our Waste Area will be located in our Receiving, Shipping and
Loading area. Garbage room area is very vulnerable to bacterial contamination. The agents
should follow the cleaning and disposal standards to prevent widespread bacterial contamination
of the garbage room and the area around the garbage room. Our facility will have a dedicated
garbage area, away from any cannabis storage or production areas.
1. Cleaning to be done regularly to avoid dirt and also to prevent the spread of bacteria.
2. Must be cleaned at least every day.
3. Garbage collection should be done every day (dry garbage and wet garbage).
4. Cleaning should be done after transporting garbage from the garbage room.
5. Cleaning to be done after garbage transportation.
These steps will provide safety of products and all agents will be trained on these SOPs.
Other effective cleaning standards include maintaining a high standard of cleanliness and regular
disinfection as it’s essential to ensure that cannabis is protected from physical and microbial
contamination and to prevent the accumulation of material which would attract pests.
Destruction Policy: When the Inventory Manager confirms waste is ready for destruction,
all products are given a final weighing by the CEO, and the weight is entered into our ITS in
accordance with the destruction procedure described in our SOPs.
Waste cannabis must be rendered unusable, unrecognizable and indistinguishable from
the components with which it is disposed and incapable of being ingested, inhaled, injected,
swallowed or otherwise used for certified use. We accomplish this by grinding cannabis and
incorporating it with other ground materials, so that the resulting mixture is at least 51% non-
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15
cannabis waste by volume. The CEO is responsible for determining the quantity by volume of
non-cannabis material needed to meet or to exceed the 51% threshold.
The Inventory Manager will notify the Security Manager and the City Manager at least
48 hours in advance of destruction and schedule a time when the Security Manager can
supervise. The entire destruction process takes place in our designated destruction area, in the
shipping and receiving area, in direct line of site of the surveillance recording cameras,
verification conducted by our CEO.
At the outset of the destruction process, the Inventory Manager will supervise the
transportation of all waste cannabis containers of the designated “destruction” area. The Manager
weighs each container’s contents and enters the final weight into our ITS. The cannabis waste
from all products is then ground with the non-cannabis content until the Manager determines it is
no longer usable or recognizable, meaning that it is incapable of being ingested, inhaled,
injected, swallowed or otherwise used for certified use.
The final mix is then weighed, and that weight is entered into our ITS. The post mixture
waste is handled differently based on whether it is compostable or not. Allowable grinding
material for non-compostable destruction include non-cannabis food waste, yard waste, our daily
ground used coffee, vegetable-based grease or oils, paper waste and cardboard waste. Non-
compostable post-mix will be placed in a locked dumpster marked as “Non-compostable Post-
mix”.
Cannabis waste rendered unusable must be promptly disposed. Disposal of any cannabis
wasted rendered unusable will be delivered to a permitted solid waste facility for final
disposition. If we use compostable mixed waste we will schedule for a compost, anaerobic
digester or another facility with approval of Fresno’s Department of Health. If we use non-
compostable mixed waste we will schedule for a landfill, incinerator or another facility with
approval of Fresno’s Department of Health.
The Inventory Manager will note the destination and date and time of waste transport and
will notify the City Manager with all proper information. An electronic documentation will be
maintained for three years.
Disposal of Recalled Products: We will coordinate disposal of recalled cannabis with the
City Manager. The City Manager or its authorized agents may oversee the disposal to ensure that
the recalled cannabis is disposed of in a manner that will not pose a risk to public health and
safety. Product destruction at our facility will take place under CEO and Security Manager
supervision within the Receiving, Shipping and Loading area of our CCB. All destroyed
products will be done in accordance with our policy addressing the disposal of cannabis and
cannabis products.
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2.1 Describe whether the Commercial Cannabis Business is committed to offering
employees a Living Wage
Our Commercial Cannabis Business (CCB) is fully committed to providing our employees
with a Living Wage, as defined by the Fresno Living Wage Calculator researched by to Dr. Amy K.
Glasmeier, Ph.D. Our Company believes in using wage models to fully understand what’s needed
for families to properly provide for their families that draws upon geographically specific
expenditure data related to food, childcare, health insurance, housing, transportation and other basic
necessities. We understand that we will not be able to provide all of our employees with six figure
salaries, but we will look at the below formula to properly come up with salaries that provide Fresno
residents with career opportunities that involve bonuses, healthcare benefits and other perks so our
employees can be proud of their success.
We looked at how the living wage is defined and came up with hourly rates and salaries that
provide employees with a Living Wage according to the City of Fresno:
Living Wage = Basic needs budget + (basic needs budget * tax rate)
Viola has always paid employees above average wages, no employee will make less than
$45,000 per year and that’s an entry level position. After reviewing this section you will see wages
ranging from $55k to $100k depending on the position and experience of the employee.
To show our commitment to empowering and partnering with our workers, our COO signed
a Labor Peace Agreement (“LPA”) with the Local 8-Golden State United Food & Commercial
Workers (“UFCW”), and our meeting with the union representatives Aidan Coffey, left our COO
very encouraged that the union is going to be a valuable resource in terms of helping us hire and
protect talented local residents of Fresno. Our signed LPA is attached within this exhibit. If
selected for Fresno, we will look into signing a Project Labor Agreement (“PLA”). Our PLA will
demand our construction project “…includes requirements as to minorities, women and local
resident hiring on the Project, any negotiated PLA shall be supportive of these requirements.”
A proper labor compliance plan starts with human resource management and compliance
teams that are knowledgeable about federal, state and local labor laws. Our Director of Human
Resource (“DHR”), Teresa Saucedo, has nine years navigating human resource management
techniques and complying to labor laws. Prior to the cannabis industry, Mrs. Saucedo was the lead
human resources recruitment director for LJ Consulting Group. She provided client centric solutions
in the areas of talent acquisition and human resource strategy consulting. Our Chief Compliance
Officer, Adam Day, will support Mrs. Saucedo in her task of making sure we are in full compliance
of labor laws. Given the planned diversity of our workforce and the minority makeup of our team,
all labor compliance training and employee handbooks can be provided in English and Spanish.
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STAFFING FOR LONG-TERM OPERATIONS
One of our core values include hiring more minorities and racial disadvantaged
individuals in an industry that has been dominated mainly by white males. One of our principal
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owners, Al Harrington, wants to provide over 100 jobs nationwide to minorities in legalized
cannabis by 2023, we are close to a quarter way there. Mr. Harrington also wants to create
wealth for 100 black minorities within the cannabis industry, through ownership in legalized
cannabis businesses across the country.
One of our foundations include corporate and social responsibility which can be shown
by the diversity of our owners, investors, management, employees, local partners and
contractors.
We want our CCB to represent the diversity of Fresno’s population in particular near
neighborhoods and communities that need economic development. Our founders believe in
social equality for all, including promotion of discrimination-free workplace, fair wages,
diversity and community involvement. We have consistently exemplified the best of those values
as majority of our owners, investors and management is a member of a racially disadvantaged
group, which include African American, Latinx and Native American. Given our history of
working with groups from diverse racial, ethnic, cultural, socio-economically disadvantage
backgrounds and the inclusion of small businesses, we expect to be among the leading applicants
when it comes to diversity, providing a diverse workforce and creating long-term staffing with
living wages.
Job Creation Plan: Many members of our current management have been with Viola
since the beginning. Most began as entry-level employees and worked their way to managers,
directors, supervisors and owners. We strongly believe in hiring from local communities,
promoting those that work hard and show leadership, providing training for our employees to
begin a career in cannabis not just a job in cannabis and paying above average wages, all keeping
long-term employees. Our employees tend to respond well to good wages and benefits with
loyalty and hard work, with everyone aligning themselves with the interests of the CCB.
Many applicants will make promises and build partnerships to try to earn points on an
application, but our actions have been organic since inception. For example, our team built our
Michigan facility in a very economically distressed region of Detroit, and we plan to pay our
workers above-average wages, plus year-end bonuses. Our pending application in New Jersey is
located in Penns Grove, which has a poverty rate six times the national average. Our soon to be
state-of-the-art cultivation and processing facility in Missouri is located in the heart of St. Louis,
where unemployment is close to 25% and 40% of the zip code’s population live in poverty.
Again, exemplifying we are NOT afraid to operate and hire where most applicants will not.
In Fresno we plan to target the most disadvantaged districts and areas to provide those
residents with job opportunities, economic development and community programs in the
cannabis industry. In Fresno, our entry wage will not be below (well above the per
hour California minimum wage), plus year-end bonus, plus benefits and participation in our
employee equity plan. 100% of our employees will be provided a livable wage. We estimate over
million in annual salaries for our CCB, which includes 34 new job opportunities for
Fresno residents.
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2.2 Briefly describe benefits provided to employees such as health care, vacation, and
medical leave, to the degree they are offered as part of employment
Our CCB will provide all employees with full benefits. Due to our experience in
providing benefits in other cannabis markets, we have relationships and partnerships with United
Healthcare and Blue Cross Blue Shield, that will provide our Fresno employees with full health,
dental and vision coverage. Our employees will have the ability to select between two HMO and
one PPO full-service health plans, which include coverage on pre-existing conditions, low
deductibles, full coverage for dependents and spouses and 100% coverage of preventative care,
including OB/GYN, mammograms, childcare and immunizations. We offer three dental plans,
Delta Dental PPO Dentist, Delta Dental Premier Dentist and Non-Participating Dentist. All
dental coverage options range between 90%-100% (oral exams, cleanings, sealants, x-rays,
fluoride etc.) for diagnostic & preventative services, 80% coverage for basic services (fillings,
simple extractions, oral surgery etc.) and 50% coverage for major services (denture repair,
crowns, implants, bridges). We also provide vision care, in-network services exams, glasses lens
enhancement and discounts on our laser vision care program.
We understand a large barrier to entry in the cannabis industry for single parents is to
receive flexible employment hours, so we will provide assistance for our employers in need of
subsidized childcare or early-education. We do not want any of our single parents to be
burdened, especially while employed, when it comes to affording best-in-class childcare
services. Our subsidized childcare program will include daycare, pre-school, early education
(pre-Kindergarten) and any after school programs that are paid out of pocket. All employees will
receive Paid Time Off, at least two weeks vacation and proper medical leave benefits. With our
relationships and LPA with UFCW we will ensure our employees are provided proper benefits
and healthcare.
Union Protection and Retirement Benefits: The great thing about partnering with the
Local 8-Golden State UFCW is they also provide benefits through a UFCW Industry Pension
Fund and a UFCW National Health and Welfare Fund. Both will keep our plans competitive and
market rate. While many cannabis companies have not implemented retirement plans, especially
since many of these businesses have only been around 5 years, we will work with UFCW and
participate in their Industry Pension Fund. Currently the fund has 300 contributing employers,
10-15 cannabis employers, 100,000 active participants and 70,000 retirees and beneficiaries.
Some of these opportunities are currently in cultivation and process, which like most industries
has a moderate turnover ratio, but after 10 years all participants are fully vested. We plan on
operating a long-term business plan and would love to have Fresno employees fully vested by
experiencing career growth within our Company.
The UFCW National Health and Welfare Fund (Fund) is governed by a joint board of
trustees on which labor and management are equally represented. The Fund is financed by
employer contributions fixed by Collective Bargaining or other written agreement and
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investment of its pooled reserves. The Fund is mostly self-funded – that its benefits are paid by
the Fund from its pooled assets, rather than by an insurance company. The Fund does carry “stop
loss” insurance to spread the risk of catastrophic claims. The Fund is self-administered: that is, it
employs an in-house staff to perform all of the administrative functions such as collecting
contributions, contracting with insurers or other organizations that maintain provider networks or
group purchasing networks, determining eligibility, processing and paying benefit claims,
handling appeals, record-keeping and reporting and disclosure. All of the Fund’s administrative
costs are paid from the Fund’s pool of assets.
The Fund has endeavored to develop innovative means for cost containment including
negotiating contracts with providers such as prescription benefit managers and preferred provider
organizations, promoting preventive care and wellness, engaging in disease management and
forming group purchasing coalitions to maximize bargaining power. As social equality
advocates, we fully support the efforts of the Local 8-Golden State UFCW.
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2.3 Describe compensation to and opportunities for continuing education and employee
training
Employee Training Overview
Our experience operating vertically integrated (cultivation, processing and dispensaries)
cannabis businesses in regulated states allowed our executive team to develop a best-in-class
approach to employee training. We work directly in collaboration with regulators, resulting in
the creation, implementation and partnership to provide highly effective training protocols that
ensure all of our employees are thoroughly trained to understand the rules and regulations of
Fresno CCB organization, have knowledge of any security measures and operating procedures
and advise customers on product offerings and how to safely consume cannabis. Led by our
Director of Cannabis Operations, our COO and various members of our team in other states, our
training curriculum includes separate and specialized training for our customer facing agents so
they are fully prepared to provide customers with the most current evidence based information
regarding cannabis brands, products and use. If we have the space, our facility will have space,
labeled Community Education and Training where we will host classroom training. This space
can be used to conduct mock training sessions but allows our agents to be trained separate from
our sales floor during the construction of our facility and hours of operation, once open.
Not only will our dispensary agents be trained using our internal procedures, they will
have the opportunity to receive training from Hemp Staff or other advanced cannabis training.
All advanced training will be paid by our CCB and employees will be paid during training.
Operations Manual: Because we currently operate cultivation, processing and dispensing
facilities in other regulated states, we have successfully developed and implemented operations
manuals aimed at standardizing procedures and at maintaining our Standard Operating
Procedures that are complete, accurate and confidential. Our operations manual will be located in
our facility, two printed copies and an electronic version will be available as a resource to our
employees and agents. All employees will be trained knowing our dispensary SOPs mentioned in
our operations manual.
Training Experience & Staff
Our ongoing cultivation, processing and dispensary operations in Colorado, Oregon,
Michigan, Missouri and Maryland has led to broad company knowledge on the continuing
development of cannabis.
These operations have also exposed us to new strains and formulations of cannabis, as
well as to new information and procedures on how best to interact with our customers. We share
Fresno’s view on the importance of training customer-facing agents to interact with and to
educate our customers, and our training in this regard is meant to equip all agents and staff
members with the information and knowledge necessary to interact with customers in a
professional and ethical manner. We envision our agents will act as a resource to our customers
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not only on the positives and negatives of cannabis use, but on new science-based research as
well. To that end, we will rely on the following people and procedures to educate our customer-
facing employees.
Chief Operating Officer: Jamil Taylor, operated cannabis facilities in Illinois, California
and Pennsylvania. Served as the CEO of a vertically integrated cannabis business in New Jersey,
was the former COO of some of the highest grossing dispensaries in Northeast Pennsylvania and
led application team for identifying new markets.
Chief Compliance Officer: Adam Day, one of the first employees of the national
Company and developed and oversees all Compliance Programs in each state where we operate.
He has over 6 years of cannabis compliance experience and maintains a near perfect record of
being rules and regulation compliant in one of the most regulated, fast evolving industries in the
county.
Director of Cannabis Operations: Is a 7-year military veteran that owns and operates 5
medical and adult-use cannabis dispensaries in Colorado and Nevada. Through his operational
expertise and marketing and branding efforts, he increased revenue in a tough Las Vegas
cannabis market by 200%. He will train our dispensary agents on how to market products and
brands to customers.
Given our experienced training staff, we are fully confident that our agents will be able to
advise purchasers on how to safely consume cannabis and use individual products offered at our
dispensary.
Internal Company Training
Our CCB will conduct an internal employee training program, which was developed and
implemented by our CEO, our COO, our Director of Cannabis Operations and our Chief
Compliance Officer, consists of an initial on-boarding training course for new employees as well
regular continuing education training courses. Prior to beginning the training of any employee,
our COO, in conjunction with our Director of Cannabis Operations, will review all of our
training materials to ensure that they comply with all Fresno rules and regulations and with City
Manager training requirements, and that they reflect the most up-to-date information on
customer care.
Prior to the beginning of their training, each new employee is provided with written
course materials related to the topics described below. These materials are provided in advance
of training and new employees are expected to have familiarized themselves with these materials
prior to beginning the on-boarding training process. All course materials, along with certificates
of completion, which include the employee’s name, course title, course content, dates of training,
and signatures of both the employee and instructor, are maintained for a minimum of three years
and are available to the City Manager for inspection upon request. We will provide extensive
training that includes 40 hours (1 week) of classroom on-boarding training, sales floor training,
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delivery and inventory training, a 2-day live training at our dispensary facility in Michigan,
which includes a walkthrough of our cultivation and processing facility.
Our mandatory on-boarding training course for all new managers, employees and agents
includes the following topics:
I. Company & Regulatory Training
All employees will complete a one-week orientation of foundational training, including
reviewing the Employee Handbook and our CCB Operations Manual, learning about our
Company mission/vision, and discussion of the following: a) Professional and ethical conduct in
the workplace; b) Informational developments in the field of cannabis; c) The proper use of
dispensary security measures and controls; d) Emergency response, including robberies and/or
other forms of workplace violence; e) Best practice security procedures including how to prevent
and detect the diversion of cannabis; f) Fresno rules and regulations for cannabis use, including
the regulatory requirements of operating a dispensary in the various local jurisdiction; h)
Authorized uses of cannabis; i) Different forms, brands, methods of administration and strains of
cannabis; j) Verification of identification; k) Policies for refusing to dispense cannabis based on
concerns about substance abuse, health, and/or safety concerns; l) Proper handling of cannabis;
m) Proper inventory and recordkeeping; n) Best practice safety procedures; o) our Company
policies for an alcohol, smoke, and drug-free workplace; and (p) sexual harassment, workplace
violence and diversity training. As part of this process, all new employees must sign off on their
review of the Employee Handbook and our dispensary Operations Manual. All employees are
also expected to review these documents annually with the same signature requirement. These
confirmation of review documents are maintained in the employment files of each employee.
II. Security Training
Our in-house training is pertinent to our facility operating in a safe and secure manor. Our
security training is conducted by our Security Manager during the on-boarding process and
consists of introducing employees to our surveillance devices, the various types of alarms that
we employ, and our access limitations and controls. This includes training in the use of our
keypads, panic alarms, hold-up alarms, smoke and fire alarms, motion detectors, surveillance
cameras, glass breakers and door sensors. Security training for new employees also consists of
reviewing all of our security policies and procedures, including procedures for a security breach,
our ZERO tolerance diversion policy and situational awareness in the event of an intrusion.
Security agents will be classroom trained for 8 hours, mock trained for 8 hours and must pass a
Safety and Security exam in order to further employment. Dispensary agents will be classroom
trained for 4 hours, mock trained for 2 hours and must pass a Safety and Security exam in order
to further employment. All safety training and security training materials and attendance records
will be kept on file for three years and be available for inspection by the City Manager.
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We will make sure our physical security vendor commits to a minimum of 8 hours total
of Initial Training on all systems so that all Level 3 and Level 4 employees are familiar with the
operation and maintenance of all systems. Our local security vendor will lead the training of all
security alarm, surveillance and access systems. Employees will be provided with emergency
contact information and are trained on what steps to take in the event of various types of
emergency situations (invasions, robbery, “smash and grab”) and/or natural disasters. Once
employees have been successfully on-boarded, management will consistently remind them of
their duties to be aware of and report any security concerns they observe.
III. Workplace Health and Safety Training
The safety of our employees is of utmost importance to us. We provide all new
employees with OSHA training completed directly by a third-party OSHA-certified trainer. As
part of this training, all employees are encouraged to exercise their rights under OSHA, including
filing an OSHA complaint, participating in an inspection, and reporting injuries or health
hazards. Indeed, all employees are trained that the reporting of hazardous conditions, regardless
of their nature, is mandatory. We also provide all new employees with CPR and first-aid training,
as well as training related to evacuation and emergency planning. This includes training in how
to recognize and/or handle a variety of safety and/or medical emergencies that may arise at our
facility. In terms of medical issues, per our standard operating procedure on “Medical
Emergencies,” all of our employees are trained to:
1. Assess the situation with the utmost care and caution.
2. If the individual is conscious, ask them if anything hurts and to describe the injury
as best as possible. If unconscious, gently inspect the individual for any obvious
signs of injury.
3. Not to move the individual, especially if they are in pain or have experienced a
severe injury, unless the individual is in imminent danger of further injury (e.g.
approaching fire).
4. Call 911.
5. Call the manager if not present to inform them of the situation.
6. Perform first aid if knowledgeable and willing.
7. Not to come into contact with blood, vomit, or other bodily fluids without the
proper protective equipment like single-use medical-grade gloves.
All employees are also trained to recognize serious medical emergencies, and to call 911
or otherwise seek the assistance of emergency medical personnel if they witness any of the
following: Shortness of breath, No breath or pulse, Chest or upper abdominal pain,
Unconsciousness, Spinal or neck injury, Disorientation, Sudden severe pain, Uncontrolled
bleeding, and Major injury or trauma.
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All employees are trained in disaster recovery. For example, in case of a fire, employees
are trained to:
1. Remove all persons from immediate danger without placing themselves at risk.
2. Activate the fire alarm system.
3. Call 911 in order to provide their name, exact location, phone number, and type of
fire.
4. Close all doors in the fire area and in the halls as needed (to contain the fire)
without placing themselves at risk.
5. Evacuate all employees to an area of refuge.
To facilitate the actions of our CCB personnel to address emergency situations, including,
but not limited to, medical emergencies, our CCB will be equipped with the following: fully
stocked first-aid kits, CPR and first-aid instructional posters and materials, signs or other
materials identifying the contact information for local emergency personnel, smoke detectors,
fire alarms, and fire extinguishers, carbon dioxide detectors, signs or other materials identifying
the quickest escape route(s) from the facility in the event of a fire or other emergency requiring
evacuation.
IV. HIPAA Training
During the consultation, Personal Health Information (PHI) may be discussed, so to
protect our customers sensitive information all agents handling and selling cannabis must
understand HIPAA and PHI regulations.
Our HIPAA training for all employees consists of training employees on the Inventory
Tracking System (ITS) and on best practices for data management, including confidentiality
measures, as well as HIPAA requirements for the handling of Personal Health Information.
Several of our company’s executives operate in medical cannabis states and are experienced with
HIPAA regulations. We will ensure all employees with access to patient health-care information
(i.e., customer facing employees) are properly trained and certified.
V. Inventory Management & Recordkeeping Training
Our experience operating vertically integrated facilities taught us that our employee and
continuing education training programs are crucial to maintaining accurate inventory and proper
recordkeeping. As such, as part of our onboarding process, we provide our employees with
comprehensive training on our Inventory Tracking System, our Point-of-Sale system and our
Customer Relationship Management system (for applicable employees). We also provide
continuing education training to all employees at least once a year or whenever those platforms
have software updates. These trainings may include having those platform representatives on
site, virtually or otherwise, to ensure that we are properly using all features and functions of the
software. This training includes live simulations of, among other things, inventory receipt,
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product recall, customer contact upon recall, delivery manifest creation for the return of recalled
product and proper recordkeeping within our dispensary.
VI. Cultivation/Processing Overview Training
While cultivation and processing training is not directly relevant to our dispensary agents,
we want our dispensary agents to understand the process and receive an overview of how
cannabis is grown from a seed and processed to its various forms. This training will help with
questions from customers and allows our agents to better advise and educate customer on
individual products offered at our dispensary. Our Director of Cultivation in conjunction with
our Director of Processing will conduct an overview training that includes:
Cannabis Plant Health and Life Cycle: a) Cultivation stages; b) General information of
each state of a cannabis plant’s growth, including mothers, cloning, seedlings, vegetative,
flowering, harvesting, drying, curing, trimming, testing, packaging and proper storage
techniques; c) The cannabis plant and its various strains including associated cannabinoids (i.e.
THC and CBD) and terpenes; and d) Federal and state cannabis laws and regulations.
All dispensary agents are also educated on the various forms of processing using CO2,
Butane (BHO), or Ethanol, as well as on how those processed cannabinoids are infused into
products we plan to sell at our dispensary. These trainings will help educate our customers on
packaging and storage requirements of their cannabis products and hopefully provide our
dispensary with a deeper customer experience.
VII. Direct Dispensary Agent Training
Customer education at the dispensary is perhaps the most important part of a customers’
experience. Our on-site Dispensary Agents form the first line of our customer experience and
education program.
Dispensary agents go through an extensive training course, explained throughout this
section, that includes classroom training, behind-the-counter training, situational and mock
training exercises, and an exam that must be passed with a score of 80% or greater. Classroom
training will include studying the science behind cannabis and the effects products can have on
the human mind and body, positive or negative, as well as identification of substance abuse. As
described previously, our facility will have a space, labeled Community Education and Training
where we will host classroom training. Agents will learn about strains, cannabinoids and terpene
profiles that make up the products we carry. Not only will dispensary agents receive classroom
training, they will also shadow a peer in their role or job title at our Michigan dispensary, to gain
real world experience in cannabis dispensary operations. Most importantly, agent training will
explore, at length, the: a) Limitations of customer rights to possess and use cannabis pursuant to
the Act; b) Potential side effects of cannabis use and how this shall be communicated to
customers; c) The differing strengths of products dispensed; d) Safe techniques for use of
cannabis and paraphernalia; e) Alternative methods and forms of consumption or inhalation by
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which one can use cannabis; f) Signs and symptoms of substance abuse; and g) Opportunities to
participate in substance abuse programs.
Frequent reinforcement of training goals, reviews of efficacy and annual performance
assessments of employees by their manager will determine each employee’s knowledge of and
adherence to SOPs and identify re-training needs. A written record documenting any completed
training activity will be signed by the participants and trainer for each training session and
maintained in the employee’s record. The Director of Cannabis Operations will be responsible
for creating a position-specific training schedule for each Dispensary Agent at hire, scheduling
training sessions and tracking training requirements.
Every agent will be fully versed on the operating procedures of our dispensary and
equipped to identify any safety concerns by the time s/he begins working on the sales floor. Our
training will include customer-employee role-playing exercises to simulate real world
interaction. All of our customer-facing employees will be expected to be knowledgeable
regarding our customer education materials on our products and alternative methods of use, as
well as on recognizing substance abuse and our procedures for helping customers that our agents
suspect is impaired or abusing cannabis.
Our agents will be taught that two individuals may have different reactions to the exact
same products at the exact same dose. As such, agents will be trained to provide each customer
with educational materials to help them keep track of their usage history and effects. These
materials include: (i) log books maintained by customers by which they can track usage and
effects, (ii) a rating scale for symptoms associated with potential use, and (iii) how to self-assess
outcomes in relation to each product used. The goal is to, in part, train our agents to get
customers involved in responsible use of cannabis products, creating the safest and most
effective adult-use cannabis users in the industry. Our agent training transcends that which can
be studied or read about in a book. We have insight about customer care gained from working
with customers on the dispensary floor as well as cultivating and processing some of the highest
quality cannabis products. Agents are coached on their demeanor, attire (uniform), tone and
language to put customers at ease and create a welcoming atmosphere. Our training aims to
create an environment in which customers can ask questions to gain the comfort level they need.
Customers are assured that dispensary agents will remain available for future questions and will
help guide their process in finding the appropriate product and dosage to accommodate their
lifestyle. Compassion and concern about the customers we serve is as important as appropriate
product selection and dosage, again having a holistic approach on dispensing cannabis.
Education of our agents does not end once they are trained to work behind the counter.
Education is ongoing as studies are published every day, providing greater insight into
appropriate forms and dosage of cannabis to help enhance knowledge of the plant. Our
Dispensary Manager is charged with keeping up to date on new data and relaying it to our
Dispensary Agent staff on a regular and ongoing basis. Our agents will have team meetings
weekly to review and disseminate new information and to discuss how best to integrate that
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information into customers’ daily experience and product recommendations. Each product found
at our site will be labeled to relay its strength and dosage scale.
In addition, handouts will be provided that describe each product, how to use it,
recommended dosage as well as signs of abuse. Potential side effects will be listed as well as the
safest techniques for ingestion or application. Written information on tolerance, dependence and
withdrawal handouts outlining the signs of and symptoms of abuse that provides information for
local substance abuse programs – some hosted in our Community Education & Training Center.
Whether it’s contact information for substance abuse programs or information on the best
techniques to use devices, each customer will have access to private consultation and education
as well as written information to accommodate any and all customer needs. We will strive to be a
full-service resource and seek to provide as much education as possible in a variety of settings.
Our goal is to be the most knowledgeable dispensary in Fresno.
VIII. Continuing Education
Our Director of Cannabis Operation will conduct internal yearly continuing education
courses, using a web-based portal with test materials after each section. All agents must score an
80% on all test materials to continue employment. We will also follow continuing education
regulations from the Act. All dispensary agents must complete a minimum of 8 hours of
continuing education during each calendar year, per our Company policy. Our continuing
education program will cover such topics as: updates to Fresno rules and regulations related to
the cannabis program; cannabis industry trends; new research related to cannabinoids and
terpenes, as well as on the overall efficacy of cannabis in treating various conditions; recognizing
signs and symptoms of substance abuse; recognizing signs of product diversion; and safe
handling of cannabis products, including common industry hazards, current health and safety
standards, and best practices.
IX. Other Training Courses
Other training that our Company sees as very important to our core values, but often
times gets overlooked, include Diversity Training, Sexual Harassment Training and Work Place
Violence.
Diversity Training: All employees will receive diversity and cultural awareness training
as part of the on-boarding process. We will outsource and provide our agents a course on
Diversity in the Workplace. We take diversity and inclusion training very seriously, so we look
to partner with the best and brightest minds regarding cultural, sexual harassment, and workplace
violence awareness. The course is a lecture with group discussions, including problem solving
and team building exercises. Topics include the following: Gender, Cultural and Generational
Differences, Communication, Teambuilding and Conflict Resolution. The goal is to increase
awareness for those working in diverse work environments as well as preventing any issues with
diversity and cultural differences among customers.
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Even as a minority-owned cannabis company, we plan to adopt an Affirmative Action
Plan for ensuring a diverse workforce as well as implement diversity training amongst all levels
of employees. We will conduct annual analyses to measure our diversity plans’ effectiveness,
and the degree to which its objectives have been attained and its obligations fulfilled. We will
monitor and update these analyses each quarter, implementing any necessary actions to increase
its effectiveness. These training tools will create cultural awareness in an industry dominated by
non-minorities and we believe all our agents will benefit and demonstrate proper skills in
resolving diversity and cultural awareness conflict or confrontation with customers and other
employees.
Sexual Harassment: We will include training on sexual harassment identification and
prevention, as part of the on-boarding process. The course is an online, interactive tool, which
includes a back-end tracking system to ensure all employees have completed and have been
tested. Topics include: Inappropriate Physical Conduct, Inappropriate Verbal Conduct,
Inappropriate Non-Verbal Conduct, Complaint Procedures, Sanctions and Disciplinary
Measures, Data Security, and Implementation of our Sexual Harassment Policy. All agents must
take a 1-hour exam on the topics discussed and pass with an 80% or better. Our policy will be
included in the staff handbook and we will require all employees to attend an annual continuing
education training course on content of our policy.
Furthermore, as managers are promoted, they ALL must take an online training course
that discusses sexual harassment laws from a management to employee perspective. The goal of
our sexual harassment training is to increase awareness for those working in diverse work
environments as well as preventing any issues that make any employee, vendor and customer
uncomfortable.
Workplace Violence: All employees will receive OSHA standard training on workplace
violence identification and prevention, as part of the on-boarding process. All agents will be
trained by a certified instructor on Violence in the Workplace.
The course will be a lecture with group discussions, including problem solving and team
building exercises. Topics include: Defining Workplace Violence, Statistics on Violence,
Economic Impact of Workplace Violence, OSHA Guidelines, Administrative Controls, Post-
Incident Response and Recordkeeping. To prevent workplace violence, employees will be
trained on our 5 successful points: (i) create supportive environment, (ii) understand workplace
violence policy, (iii) commit to a non-violence (verbal and non-verbal) workplace, (iv) create
and practice action plans and (v) creation of a zero-tolerance plan.
All topics will include examples and risk factors of violence and how it can be prevented.
Employees will be trained to recognize and prevent verbal and non-verbal workplace violence.
X. Emergency Procedures and Training
Our Emergency and Prevention Plan includes regular training for our employees on our
standard operating procedures in the event of a crisis/disaster. This training includes scenario
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planning and live drills for fire, hurricane, and flooding procedures. This training also includes
live drills for dealing with active intruders (see Security Plan for more detail). We also provide
all new employees with CPR and first-aid training, as well as training related to emergency
evacuation procedures (including quarterly evacuation drills).
Our crisis/disaster preparedness training is conducted by the members of our Emergency
Response Team (ERT). Per our standard operating procedures, each member of our ERT – CEO,
Security Manager, and Dispensary Manager – is mandated to take FEMA Emergency
Management Institute (EMI) online courses, including, at a minimum, in emergency response
(EMI-IS 317), and to successfully complete the final exam for this course with a score of 90% or
better. Our crisis/disaster preparedness training includes:
Basic Crisis/Disaster Preparedness: Per our standard operating procedures, all facility
employees will be trained to take the following basic steps should our facility experience a crisis,
disaster or other event that severely disrupts our operations:
• To evacuate the facility if necessary.
• To help evacuate customers, and other members of the public at our facility if doing
so would not put themselves at risk of harm.
• If evacuation is necessary, to evacuate to a pre-determined area of refuge (if
possible).
• To direct any evacuated members of the public (non-employees) to a pre-determined
area of refuge (if so doing would not put themselves at risk of harm).
• To call emergency responders and/or 911.
• If the disaster and/or emergency requires sheltering in place, to:
o Determine best location in the facility to take shelter
o Direct any non-employees to the shelter location
o Collect all disaster preparedness kits
o Activate NOAA Weather Radio (if necessary)
• To notify a member of our Emergency Response Team of the ongoing emergency
and/or disaster as soon as possible (as long as doing so would not put themselves at
risk of harm).
Severe Weather Preparedness: In the event of severe weather, including tornado or
hurricane, per our standard operating procedures, all facility employees will be trained:
• To activate a facility NOAA Weather Radio to receive important updates regarding
weather conditions
• To evacuate the facility if advised to do so by local authorities (or by a member of our
ERT who has received instructions from local authorities)
• To help evacuate patients, caregivers, and other members of the public at our facility
if doing so would not put themselves at risk of harm
• If remaining and/or sheltering in place, to:
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o Determine best location in the facility to take shelter
o Direct any non-employees to the shelter location
o To stay away from doors and windows
o To Collect all disaster preparedness kits
o To transfer at least one of the facility NOAA Weather Radios to the place of
shelter
• To call emergency responders and/or 911 (if necessary)
• To notify a member of our Emergency Response Team of the ongoing emergency
and/or disaster as soon as possible (as long as doing so would not put themselves at
risk of harm).
Our severe weather preparedness training also includes educating our employees on the
severe weather-related terms used by the National Weather Service to indicate the severity
and/or potential danger of predicted severe weather, including:
• Advisory: Conditions to cause significant inconveniences that may be hazardous. If
caution is used, these situations should not be life-threatening
• Watch: Issued when severe weather is possible within 48 hours. Tune into NOAA
Weather Radio All Hazards to monitor alerts
• Warning: Issued when severe weather is expected within 36 hours. Tune into NOAA
Weather Radio All Hazards to determine if evacuation required
Our severe weather preparedness training also incorporates instructional materials from
FEMA’s “Turn Around, Don’t Drown” program which explains in detail the drowning danger
posed by walking or driving on flooded roads or through floodwaters. All employees will be
provided with an evacuation information sheet that will list evacuation routes recommended by
the Department of Transportation and the Office of Emergency Management.
Fire Safety: In the event of a fire, per our standard operating procedures, all facility
employees will be trained to do the following:
• Remove all persons from immediate danger without placing themselves at risk;
• Activate the fire alarm;
• Dial 911 and provide their name, exact location, phone number and the type of fire;
• Close all doors in the fire area and in the halls as needed (to contain the fire) without
putting themselves at risk; and
• Evacuate all employees to a pre-determined area of refuge (if possible).
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2.4 Describe the Commercial Cannabis Business plan to recruit individuals who meet
the criteria listed in the Social Policy Section 9-3316(b)(1) of the Fresno Municipal
Code (FMC) and the percentage of local employees it hires
Our CCB will be committed to Social Policy Section 9-3316(b)(1)(i-vii) when it comes to
employing more than 33% of our work staff that (i) has an annual family income below 80%
AMI; (ii) convicted for a cannabis related crime that could have been prosecuted as a
misdemeanor or citation under current State law; (iii) lived in a low to moderate income census
tract in the city for a minimum of three years; (iv) veteran ; (v) former foster home youth who
was in foster care as a minor; (vi) unemployed; or (viii) receiving public assistance. Our business
is majority owned by an individual that was convicted for a cannabis related crime and now has
the opportunity to learn from one of the premier cannabis brands in the industry. This
opportunity will create generation wealth for Mr. Hopkins and his family.
Internal Goals and Benchmarks: Our CCB will adopt the current local percentage of
minorities, women, veterans, indigent and people with disabilities in the civilian labor force as its
hiring benchmark for these disadvantaged groups. Our Company will update our hiring
benchmark as new data is published and updated via the US Census. The hiring benchmarks
apply to the available workforce and not just in particular job groups. Our Director of Human
Resources has collected data and conducted analyses to identify areas of opportunity in the
employment of minorities, women, veterans, indigent and individuals with disabilities. Our
Director of Human Resources will continue to monitor and update these analyses during each
year. We will be looking to hire full-time and part-time employees for the following job groups:
management, supervisors, agents, packaging, delivery, inventory, security, maintenance, finance,
research and development, community outreach and marketing and sales.
We plan on hiring and maintaining the following benchmark goals succeeding many of
Fresno’s available demographics, per SEC 9-3316(b)(1):
Currently, Fresno has a 26.9% poverty rate of its citizens and we believe our team will
have no issues hiring 33% of more of our staff that qualify as (i) has an annual family income
below 80% AMI; (ii) convicted for a cannabis related crime that could have been prosecuted as a
misdemeanor or citation under current State law; (iii) lived in a low to moderate income census
Our Fresno
Protected Group Placement Goals Availability
Minorities - Non-White (racially disadvantaged) 45.0%39.5%
Women 50.0%50.8%
Veteran 5.0%3.6%
Individuals w/ Disabilities 10.5%10.5%
People living in Poverty 30.0%26.9%
Source: US Census demographic information
Our Company used local census and demographic statistics to calculate available population in Fresno.
We will look to hire people in the local community, local county and meet these goals.
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tract in the city for a minimum of three years; (iv) veteran ; (v) former foster home youth who
was in foster care as a minor; (vi) unemployed; or (viii) receiving public assistance.
People with disabilities are a particularly challenging area for recruitment, for most
manufacturing facilities. Such people can face discrimination in the form of undervaluing of their
skills, but many of the job positions at any of our facility types can be performed completely by
disabled individuals as all of our facilities will be fully American Disability Act (“ADA”)
compliant. We will partner with a full-service non-profit community organization that will
provide services for persons with developmental disabilities, mental illness and substance abuse
challenges, among other youth programs. We will work together to provide the able-disabled
with job opportunities.
We plan to adopt an Affirmative Action Plan for ensuring a diverse workforce as well as
implement diversity training amongst all employees. Our Director of Human Resources will
conduct annual analyses to measure its effectiveness, and the degree to which its objectives have
been attained and its obligations fulfilled. Our DHR will monitor and update these analyses each
quarter during each year, implementing any necessary actions to increase its effectiveness to
meet our goals.
Workforce Diversity Outreach Initiatives: Consistent with our diversity values and
building community trust, we will reach out to Fresno business owners regarding hosting
community events to introduce our CCB, Company and team members. We will support a
variety of Fresno service programs, including those designed to improve the employment
opportunities of disadvantaged groups mentioned in Social Policy Section 9-3316(b)(1).
We are committed to fair wages in all states where we operate. To show our commitment
to long-term staffing employees nationwide, we signed a Labor Peace Agreement and Project
Labor Agreement for our pending New Jersey application, and we are under contract with the
UFCW for our Maryland cultivation operations and will partner with UFCW for our national
company.
We will train for long-term success and many employees will be cross trained among job
groups, allowing team members to have well-rounded career experiences. Our goal is to build a
workforce with careers in cannabis and not “jobs” in cannabis.
Many of our competitors hire or place minority figureheads on these type of applications
ONLY to win points or “show diversity”, not hiring or allowing diversity for long-term staffing
needs. Many applicants will provide “lip service” to their staffing practices regarding hiring a
diverse workforce, but our President and COO has experience in executing our Diverse Long-
Term Staffing Plan and looks forward to bringing our ideas to better serve the Fresno workforce.
Other Examples of Advocacy for Social Responsibility in Cannabis: Our team
demonstrates many past and present experiences that promote economic development and
empowerment in disadvantaged areas. Not only in Fresno, but also in other areas where we
operate or plan to operate. These experiences are done by members of our team organically and
not forced due to win points on an application. We truly believe in servicing undeveloped
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excerpt from Sustainable Brands that mentioned Viola’s commitment to providing job
opportunities to those that need it most.
Timing of Hiring: We want to be the standard for diversity hiring and maintaining our
diversity goals for the Fresno cannabis industry. After being awarded a Fresno CCB license we
plan to immediately reach our diversity hiring goals through everything outlined in this plan.
Once operations commence, a utilization analysis of the employment of women, minorities,
veterans, indigent and individuals with disabilities by job group is conducted. The utilization
analysis requires estimating the number of qualified minorities, women, veterans, indigent and
individuals with disabilities available for employment in each job group, expressed as the
percentage of all qualified persons available for employment in the job group.
We estimate that 100% of our workforce will be from Fresno and the surrounding
areas. Our team will collect and revise data annually indicating the number and percentages of
employees in each department by designated job group from various minority groups. Under data
reported to the DHR, our executive team will analyze annually the number and percentages of
employees in each department by designated pay grade and minority classification (women,
minority, veterans, indigent, disabled) levels from various minority groups.
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2.5 Describe the extent to which the Commercial Cannabis Business will be a locally
managed enterprise whose owners and/or managers reside within or own a
commercial business within the City of Fresno, for at least one year prior to March
2, 2020
Our CCB will be locally managed by Mr. Delanno Hopkins, he is the majority owner and
CEO of the Fresno business. Mr. Hopkins will be the day-to-day operator helping the retail
dispensary and having executive control of all operations. Mr. Hopkins has been a lifelong
Fresno resident, he currently resides in, Fresno, California and he was convicted of cannabis
trafficking and served 18 months in Fresno prison. Being locally owned and operated is very
important as it provides a local perspective to our CCB.
Given the partnership of Viola and Mr. Hopkins, we are committed to providing local
management with opportunities for ownership. Our team is proud that Mr. Hopkins has the
ability to own, operate and profit from an industry that is majority white owned after serving
time for cannabis trafficking. Mr. Hopkins is looking forward to managing and owning a local
business and partnering with a majority African American owned vertically integrated cannabis
business.
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2.6 Describe the number of employees, title/position and their respected responsibilities
Job Creation Plan: Many members of our current management have been with our
National Company since the beginning. Most began as entry-level employees and worked their
way to managers, directors, supervisors and owners. We strongly believe in hiring from local
communities, promoting those that work hard and show leadership, providing training for our
employees to begin a career in cannabis not just a job in cannabis and paying above average
wages, all keeping long-term employees. Our employees tend to respond well to good wages and
benefits with loyalty and hard work, with everyone aligning themselves with the interests of the
company.
Many applicants will make promises and build partnerships to try to earn points on an
application, but our actions have been organic since inception. For example, our team built our
Michigan facility in a very economically distressed region of Detroit, and we plan to pay our
workers above-average wages, plus year-end bonuses. Our pending application in New Jersey is
located in Penns Grove, which has a poverty rate six times the national average. Our soon to be
state-of-the-art cultivation and processing facility in Missouri is located in the heart of St. Louis,
where unemployment is close to 25% and 40% of the zip code’s population live in poverty.
Again, exemplifying we are NOT afraid to operate and hire where most pharmaceutical
processor applicants will not.
In Fresno we plan to target the most disadvantaged districts and areas to provide those
residents with job opportunities, economic development and community programs in medical
cannabis. In Fresno, our entry wage will not be below (well above the $12.00 per hour
California minimum wage), plus year-end bonus, plus benefits and participation in our employee
equity plan. 100% of our employees will be provided a livable wage.
Our employee benefits will include workers’ compensation, subsidized health care and
dental coverage, with coverage of preventative care, including ob-gyn, mammograms and
immunizations. All employees, including part-timers, will earn paid time off (“PTO”) and
receive paid holidays. We will reserve 10% in our Company cash flow to allocate to our Fresno
employee profit sharing/equity plan, this allows our managers and employees to receive upside
when the Company does well and incentivizes our employees for long term operational success.
If we decide to award equity, our owners will dilute accordingly to maintain our social equity
status.
Our CCB operation will provide between 25 to 30 full-time part-time jobs in one of the
fastest growing industries. Consistent with all the above benefits.
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Administrative and local executive positions will provide 5 full-time jobs. Consistent
with all the above benefits.
The above charts represent a summary of our anticipated salaries to our Fresno operations
team, administrative and executives that split salary expenses with other operating states, the net
result of which will provide annually in well-paid unionized jobs with full
benefits. As you can see, we pay well above typical cannabis wages and no employee is
scheduled to make less than annually or per hour (Executive Administration).
100% of our employees will pe paid livable wages and 75% of our staff will be full-time. All
our agents will have the ability to earn upward of per year, including annually or hourly
pay, year-end bonuses and participation in our company cash flow/equity program. If we want to
attract the highest level of talent, our agents will receive market level compensation with bonuses
and participation in our Company equity program.
We feel this provides a sustainable living wage for all individuals. If we feel these wages
are not “Fresno market” we will adjust, even if the result lowers our profit margin.
Ensure Employee Representation from the Local Community: We are targeting to hire
our entire CCB staff locally with Fresno residents. For example, if we are awarded a license
Fresno we will first look to hire within the city of Fresno before reaching to outside resources, all
done without discriminating any applicant. In addition, the need to hire local vendor firms for
construction, architecture and design, our facility will bring over 20 well-paying jobs with good
benefits in areas that could benefit from an economic infusion.
We believe strongly that treating and compensating people fairly is not only the right thing
to do, but it is the only way to run a successful business. Our teams have confirmed that providing
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24
generous wages/benefits builds trust, reduces costly turn-over, and promotes loyalty to the
company. Our above-average compensation will attract top local talent.
Our plans do NOT call for bringing out-of-towners to run a local dispensary - like many of
our competing multi-state operators looking to capitalize on California’s cannabis market,
essentially providing out-of-towners with wealth while they file personal taxes elsewhere. We will
build a talented workforce from scratch in Fresno. Unlike some of the corporate public companies
vying for more licenses, we will need to staff up vertically all of the relevant positions with local
residents, just as we have done at our other operations where most of our managers and staff was
hired from the surrounding communities. We not only write about what we are going to do, but
back it up by actions.
Speaking of actions, our Company signed a Labor Peace Agreement with the United Food
& Commercial Workers (UFCW) Local 8-Golden State. The UFCW will be a valuable resources
from the identifying, staffing and hiring local talent.
Our executive team will continue to meet with government officials, hold town hall
meetings at various community and religious centers to cultivate personal contacts with members
of the community, target qualified labor in communities with higher than average minority
populations; and placing job advertisements, when appropriate, in local online job boards and
print media aimed at local residents. We will also look to partner with local Veteran Affair
offices to post job opportunities for veterans, many have a hard time applying for jobs that aren’t
violent in nature (i.e. police and security jobs). Our Company’s business model ensures that local
talent will be hired as majority ownership resides in Fresno.
As themed throughout our Social Policy and Local Enterprise Plan, hiring locally and
hiring a diverse team are core principles of our CCB. We do not consider ourselves “opportunist”
or “outsiders” that are trying to take advantage of the so-called California “Green Rush”. Many
of our owners, managers and employees represent the state of California in many ways. Our
roots in California and Fresno ownerships means we will hire, train and include employees that
live in Fresno for long-term success. We will need to fill approximately 30+/- full-time/part-time
positions, that include managers, agents, security, finance, marketing and sales. Below are the
following key positions in our dispensary along with positions that will be open for hire. Any
employee we hire or have on pay roll or consulting is making above livable wages, typically
above market for their position.
We will submit a list to the City Manager of the names of all service professionals that
will work at our dispensary. Our list will include a description of the type of business or service
provided. Changes to our list of service professionals will be sent to the City Manager
immediately.
Below is description of positions for our dispensary.
Chief Executive Officer: Delanna Hopkins, is the ultimate authority for overall decision-
making for our dispensary operations. Externally, he is responsible for developing business
relationships for the dispensary with cultivation and processing vendors and increasing sales.
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Together with the COO and Dispensary Manager, the CEO develops realistic product acquisition
and sales goals and refines the company’s mission culture and operators as necessary to achieve
those goals. The CEO is also responsible for, together with the COO, approving all operating
policies and procedures as well as all training programs for employees, and updating these
quarterly. The CEO will be trained by our team of experienced operators. This position reports to
the Board of Directors.
Chief Operating Officer: Jamil Taylor, serves as our operations expert. The position is
responsible for the operation and business aspects of our day-to-day dispensary operations and
decision making. In consultation with the various area Directors/Managers and the Dispensary
Manager, the COO determines the types of products we will obtain from growers/processors.
Together with the Dispensary Manager, the COO develops all Standard Operating Procedures.
He is responsible for ensuring that we are following our stated policies and procedures in our
Standard Operating Procedures. He works collaboratively with the CEO to ensure that sales and
product targets are being met and to solve more challenging financial operating problems. The
COO reports to the CEO.
Dispensary Manager(s): To Be Hired Locally, will run the dispensary on a day-to-day
basis sharing responsibility to fulfill dispensary oversight requirements during business hours.
S/he will have oversight of the dispensary agents, including by consulting with customers and
determining the products and modes of ingestion likely to fit the customers lifestyle. S/he will
help train and develop agent training materials and ensure every agent is fully compliant. This
role reports to the CEO and COO.
Dispensary Supervisor: To Be Hired Locally, working with the Dispensary Manager, this
position will assist the Manager and help run the dispensary on a day-to day basis sharing
responsibility to fulfill dispensary oversight requirements during business hours. The Dispensary
Supervisor will supervise the Dispensary Agents and work alongside them, including by
consulting with customers and determining the products and modes of ingestion likely to the
customers lifestyle. This role reports to the Dispensary Manager.
Dispensary Agent(s): To Be Hired Locally, work with customers in the dispensary on a
one-on-one basis. Along with our Managers and Supervisors, our agents will handle daily sales
interactions and use their comprehensive knowledge of cannabis strains, methods of ingestion
and any education on cannabis to assist customers in understanding what best fits their lifestyle.
Dispensary agents will be trained on their cannabis knowledge, marketing and brand awareness
and interpersonal skills in how to deal with customer. Dispensary agents will be stationed in our
retail sales floor, in our reception area and our back office assisting in inventory, recordkeeping,
packaging and receiving. Dispensary agents report to the Dispensary Manager / Dispensary
Supervisor.
Inventory Manager: To Be Hired Locally, will work with our Dispensary Manager to
order and track all incoming inventory during receiving, product ordering, recall and dispensing.
Inventory Manager will count and physically scan each product and confirm the product’s name,
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26
strain name, weight and identification number on the manifest matches the information on the
cannabis products label and package. The Inventory Manager will also conduct daily, monthly
and annual comprehensive inventories, which include opening and closing accounts of product.
This role reports to the COO.
Product Sales Supervisor: To Be Hired Locally, will be in charge of all wholesale
ordering and knowing our Customer Relationship Management software. S/he will manage
vendor relationships, understand all product brands and make sure as many cultivation, craft
growers and infusers have product representation in our inventory. The Product Sales Supervisor
reports to the Dispensary Manager and COO.
Security Manager: To Be Hired Locally, will train and educate staff on all day-to-day
aspects of security and will be responsible for reporting violations or potential violations to the
City Manager and Fresno law enforcement agencies. The Security Manager will also oversee our
product receiving, shipping and loading area procedures. He/she reports to our CEO and COO.
Security Guards: To Be Hired Locally, will carry out the policies, procedures and
protocols of our stringent security plans in accordance with all applicable laws, rules, and
regulations. They are responsible for, among other things: screening visitors, customers and
employees at the entrance; handling perimeter security, site surveillance, access control and
product movement compliance. They report to the Security Manager.
Executive Administration: To Be Hired Locally, S/he will assist our Management staff
with all administrative tasks. S/he will be involved in organizing, recordkeeping and oversight
within our dispensary. S/he will report to the Dispensary Manager.
Controller: To Be Hired Locally, this position is responsible for day-to-day accounting /
bookkeeping and recordkeeping functions of the organization in Fresno. The Controller must
have a finance or accounting background, a bachelor’s degree with at a minimum of five years
and efficient in Microsoft Excel and fully trained in QuickBooks. The Controller reports to the
CEO and COO.
Director of Cannabis Operations: Marques Moore – will work with the Dispensary
Manager to educate staff on the different cannabis strains, methods of ingestion and use, and
effectiveness and recommendations for specific uses. He will lead our agent training program
along with the COO and others from our national team. He will also coordinate, lead and design
all marketing and educational materials used to educate customers at our facility and during
“Cannabis 101” events. Along with training our staff, she will reach out and help educate the
local residents of Fresno on local cannabis rules and laws. With him being our National Director,
the goal is to train a local team member to be our Fresno instructor. The Director of Cannabis
Operations reports to the COO and Dispensary Manager.
Director of Community Outreach: To Be Hired Locally, will be responsible for
developing relationships with the local community, including to provide outreach programs to
bridge the community with our Company, provide educational information regarding cannabis
and serve as our Veteran Affair liaison. S/he will coordinate free seminars for customer, family,
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healthcare professionals and the general public on subjects such as: understanding cannabis; the
laws and regulations governing the Fresno cannabis program. S/he will also help lead social
events the dispensary sponsors in our Community Education & Training Center (CETC),
including fitness classes, substance abuse and community impact, family intervention groups,
cannabis expungement assistance and voting registration assistance. The Director of Community
Outreach reports to the COO.
Director of Technology and Facility Maintenance: To Be Hired Locally, devises the
strategic design, acquisition, management, and implementation of our technology infrastructure
including, without limitation, the Company’s cyber security protocols, Security Information
Technology Room (SITR), ITS/CRM/POS platform software interface with the Department’s
System, security systems and technology training. Any issues with our internal or external
technology systems will be monitored by our Director of Technology and Facility Maintenance
(DTFM) and must have three years of Information Technology experience and a bachelor’s
Information Technology or Computer Science. The DTFM reports to the COO.
All employees will be offered healthcare packages with benefits and an opportunity to
invest in our Company equity plan. We believe in hiring local and using local resources to
accomplish our goal of being the best dispensary in Fresno. Entry level positions will range from
per year and managerial positions ranging from per year,
with end of year performance bonuses. We are paying our employees well above comparable
National retail averages. We plan to inject more than million of new salaries into the
Fresno community.
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2.7 Describe whether the CCB has five or more employees and whether it has signed a
labor peace agreement allowing employees to unionize without interference
The CCB currently does not have five employees as the business is not operating. Upon
winning a license we hire a local Fresno staff. To show our commitment to empowering and
partnering with our workers, our COO signed a Labor Peace Agreement (“LPA”) with the Local 8-
Golden State United Food & Commercial Workers (“UFCW”), and our meeting with the union
representatives Aidan Coffey, left our COO very encouraged that the union is going to be a
valuable resource in terms of helping us hire and protect talented local residents of Fresno. Our
signed LPA and UFCW Cannabis Diversity Plan is attached within this exhibit. If selected
for Fresno, we plan to sign a Project Labor Agreement (“PLA”). Our PLA will demand our
construction project “…includes requirements as to minorities, women and local resident hiring
on the Project, any negotiated PLA shall be supportive of these requirements.”
A proper labor compliance plan starts with human resource management and compliance
teams that are knowledgeable about federal, state and local labor laws. Our Director of Human
Resource (“DHR”), Teresa Saucedo, has nine years navigating human resource management
techniques and complying to labor laws. Prior to the cannabis industry, Mrs. Saucedo was the lead
human resources recruitment director for LJ Consulting Group. She provided client centric solutions
in the areas of talent acquisition and human resource strategy consulting. Our Chief Compliance
Officer, Adam Day, will support Mrs. Saucedo in her task of making sure we are in full compliance
of labor laws. Given the planned diversity of our workforce and the minority makeup of our team,
all labor compliance training and employee handbooks can be provided in English and Spanish.
Please find attached our executed Labor Peace Agreement
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2.8 Provide a workforce plan that includes at a minimum the following provisions:
2.8.1 Commitment for 30% of employees to be local hires; the business must show
that it has either hired or made a good faith effort to hire bona fide residents
of Fresno who have not established residency after the submission of an
application for employment with the applicant/permittee
Ensure Employee Representation from the Local Community: We are targeting to hire
our entire CCB staff locally with Fresno residents. For example, if we are awarded a license
Fresno we will first look to hire within the city of Fresno before reaching to outside resources, all
done without discriminating any applicant. In addition, the need to hire local vendor firms for
construction, architecture and design, our facility will bring over 20 well-paying jobs with good
benefits in areas that could benefit from an economic infusion.
We believe strongly that treating and compensating people fairly is not only the right thing
to do, but it is the only way to run a successful business. Our teams have confirmed that providing
generous wages/benefits builds trust, reduces costly turn-over, and promotes loyalty to the
company. Our above-average compensation will attract top local talent.
Our plans do NOT call for bringing out-of-towners to run a local dispensary - like many of
our competing multi-state operators looking to capitalize on California’s cannabis market,
essentially providing out-of-towners with wealth while they file personal taxes elsewhere. We will
build a talented workforce from scratch in Fresno. Unlike some of the corporate public companies
vying for more licenses, we will need to staff up vertically all of the relevant positions with local
residents, just as we have done at our other operations where most of our managers and staff was
hired from the surrounding communities. We not only write about what we are going to do, but
back it up by actions.
Speaking of actions, our Company signed a Labor Peace Agreement with the United Food
& Commercial Workers (UFCW) Local 8-Golden State. The UFCW will be a valuable resources
from the identifying, staffing and hiring local talent.
Our executive team will continue to meet with government officials, hold town hall
meetings at various community and religious centers to cultivate personal contacts with members
of the community, target qualified labor in communities with higher than average minority
populations; and placing job advertisements, when appropriate, in local online job boards and
print media aimed at local residents. We will also look to partner with local Veteran Affair
offices to post job opportunities for veterans, many have a hard time applying for jobs that aren’t
violent in nature (i.e. police and security jobs). Our Company’s business model ensures that local
talent will be hired as majority ownership resides in Fresno.
As themed throughout our Social Policy and Local Enterprise Plan, hiring locally and
hiring a diverse team are core principles of our CCB. We do not consider ourselves “opportunist”
or “outsiders” that are trying to take advantage of the so-called California “Green Rush”. Many
of our owners, managers and employees represent the state of California in many ways. Our
Social Policy and Local Enterprise Plan TRADE SECRET
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30
roots in California and Fresno ownerships means we will hire, train and include employees that
live in Fresno for long-term success. We will need to fill approximately 30+/- full-time/part-time
positions, that include managers, agents, security, finance, marketing and sales. Any employee
we hire or have on pay roll or consulting is making above livable wages, typically above market
for their position.
We will submit a list to the City Manager of the names of all service professionals that
will work at our dispensary. Our list will include a description of the type of business or service
provided. Changes to our list of service professionals will be sent to the City Manager
immediately.
2.8.2 Commitment to offer apprenticeships and /or compensation for continuing
education in the field
Incubation: Our goal is to train and incubate dispensary agents, so they have the
wherewithal to apply and manage their own Fresno or California CCB. Many of our previous
employees in other states started as entry level employees and have continued a career in
cannabis as managers or moved on to other businesses to generate successful careers. One of the
main reasons why individuals cannot “break” into the cannabis industry is because of lack of
cannabis management experience.
Our incubation program Incubate to Ownership, will incubate our managers and
supervisors by giving them real-time and real-world experience in the cannabis industry. Often
times, people of color or minorities are denied access to ownership because they have ZERO
cannabis experience and their lives were negatively affected by the War on Drugs. If you live in
a state without cannabis opportunities, it’s nearly impossible to enter the industry. If you do enter
the industry, many people of color and minorities are resorted to low level entry jobs that pay
per hour and never have a chance to own a cannabis business. Currently, in
California less than 10% of cannabis businesses are majority owned by African Americans. This
does not reflect the diversity of California and in particular Fresno. We hope to change those
statistics and give people of color a chance at ownership and not just “jobs”.
Our Incubate to Ownership program will select top level managers and supervisors that
qualify as Social Equity Applicants and train, educate and provide resources to those individuals
for the next wave of licenses. This program is designed to ensure that all managers and
supervisors have the skills, knowledge and opportunity to own and operate a CCB in the very
near future. The training course will be designed by our experienced Director of Cannabis
Operations and our COO – all have first-hand operating and ownership dispensary experience.
The course will consist of our typical 40-hour training material and also include continuing
education on Inventory Management, Recordkeeping, Security & Surveillance, Financial
Statement Analysis, Cash Management, Capital Raising, 1-on-1 Managerial training and
Application Assistance.
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This incubation program will prepare managers for ownership of a CCB no matter the
state.
2.8.3 Commitment to pay a living wage to its employees
Our Commercial Cannabis Business (CCB) is fully committed to providing our employees
with a Living Wage, as defined by the Fresno Living Wage Calculator researched by to Dr. Amy K.
Glasmeier, Ph.D. Our Company believes in using wage models to fully understand what’s needed
for families to properly provide for their families that draws upon geographically specific
expenditure data related to food, childcare, health insurance, housing, transportation and other basic
necessities. We understand that we will not be able to provide all of our employees with six figure
salaries, but we will look at the below formula to properly come up with salaries that provide Fresno
residents with career opportunities that involve bonuses, healthcare benefits and other perks so our
employees can be proud of their success.
We looked at how the living wage is defined and came up with hourly rates and salaries that provide
employees with a Living Wage according to the City of Fresno:
Living Wage = Basic needs budget + (basic needs budget * tax rate)
Viola has always paid employees above average wages, no employee will make less than
0 per year and that’s an entry level position. After reviewing this section you will see wages
ranging from depending on the position and experience of the employee.
In Fresno we plan to target the most disadvantaged districts and areas to provide those
residents with job opportunities, economic development and community programs in medical
cannabis. In Fresno, our entry wage will not be below (well above the per hour
California minimum wage), plus year-end bonus, plus benefits and participation in our employee
equity plan. 100% of our employees will be provided a livable wage.
Our employee benefits will include workers’ compensation, subsidized health care and
dental coverage, with coverage of preventative care, including ob-gyn, mammograms and
immunizations. All employees, including part-timers, will earn paid time off (“PTO”) and
receive paid holidays. We will reserve 10% in our Company cash flow to allocate to our Fresno
employee profit sharing/equity plan, this allows our managers and employees to receive upside
when the Company does well and incentivizes our employees for long term operational success.
If we decide to award equity, our owners will dilute accordingly to maintain our social equity
status.
The net result of our operations, administrative and executive team will provide
annually in well-paid unionized jobs with full benefits. As you can see, we pay well
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above typical cannabis wages and no employee is scheduled to make less than annually
or per hour (Executive Administration). 100% of our employees will pe paid livable
wages and 75% of our staff will be full-time. All our agents will have the ability to earn
upward of $ per year, including annually or hourly pay, year-end bonuses and
participation in our company cash flow/equity program. If we want to attract the highest level of
talent, our agents will receive market level compensation with bonuses and participation in our
Company equity program.
Mr. Delanno Hopkins has lived in a low income household zip code
of Fresno, CA for close to a decade that is identified as at least
70% by CalEnviroScreen.The follow page shows that Mr.Hopkins
address is in an area that is 81-90%. Mr. Hopkins is currently
unemployed and meets the low-income qualification.
Mr. Hopkins, like many other social equity candidates he did not
realized that he can apply as a social equity applicant. Upon
learning of his qualification he reached out to our Company on
Thursday November 12, 2020 and he has begun to gather his
proof of residency documents. We hope the City of Fresno will
grant Mr. Hopkins more time to get his documents in order to
submit a timely qualified application.
If we partner with Mr. Hopkins, he will receive majority ownership
(51%), he will be well funded, he will work on a serious business
plan, he will be trained and incubated by our team to operate a
successful vertically integrated cannabis company in Fresno. Given
the address on his Driver’s License we are confident his address
qualifies and we hope we will receive time to summit all
documentation, especially since the application is due in January
2021.
Please feel free to contact –Jamil Taylor
Zoning Inquiry P21-00570
755 Van Ness Avenue
Page 2
February 9, 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 two cannabis retail businesses may be located in any one Council District.
If more than 14 are ever authorized by Council (more than two per Council District), they
shall be dispersed evenly by Council District.
The subject property is in Council District 3. There are currently no cannabis retail
businesses located in Council District 3. 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 559-621-8038 or at Marisela.Martinez@fresno.gov.
Cordially,
Marisela Martinez, Planner II
Development Services Division
Planning and Development Department