HomeMy WebLinkAbout2023 CON NC Investment Group - Cannabis Business License Development AgreementDocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
COMMERCIAL CANNABIS BUSINESS LICENSE
DEVELOPMENT AGREEMENT
This Development Agreement ("Agreement") is made and entered into as of June 20,
2023 (the "Effective Date") between the CITY OF NATIONAL CITY, a California municipal
corporation ("City"), and NC Investment Group, a California LLC doing business as NC
Investment Group ("Licensee"). City and Licensee are hereinafter collectively referred to as the
"Parties" and singularly as "Party."
RECITALS
A. The City Council previously adopted an ordinance to add Chapter 9.60 to
National City Municipal Code ("NCMC") to permit limited commercial cannabis activities.
B. Pursuant to Resolution No. 23-, the City Council adopted Application Procedures
and Guidelines (the "Guidelines'') governing the issuance of commercial cannabis licenses.
C. Licensee submitted an application for a commercial cannabis license dated April
7, 2022 (the "Application"), which was reviewed by the City in accordance with the Guidelines.
D. The Licensee identified in the Application that it was at least 51% owned by
residents of National City, which made the Licensee's Application eligible to receive the local
preference criteria contained in the Guidelines.
E. On [June 20, 2023], the City awarded a Commercial Cannabis Permit to Licensee
("Permit"), to operate a retail and distribution, cannabis business which will be located at 3020
Hoover Avenue, National City, CA 91950, also known as San Diego County APN 562-220-06-
00 (the "Property").
F. Pursuant to NCMC Section 9.60.100 and the Guidelines, the Licensee must enter
into an Development Agreement with City prior to commencing operations.
G. The City and Licensee freely and voluntarily negotiated the terms and conditions
of this Development, and the City Council adopted Resolution No 23- approving this Agreement.
H. The Parties acknowledge that this Agreement is not a statutory development
agreement authorized by Government Code section 65864 and that this Agreement confers no
entitlement or vested rights of any kind to Licensee to operate a cannabis business.
AGREEMENT
NOW, THEREFORE, in consideration of the covenants and obligations set forth herein,
the receipt and adequacy of which is hereby acknowledged, the parties agree as follows:
1. Incorporation of Recitals.
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The recitals and defined terms set forth above are hereby incorporated into this Agreement.
2, Effective Date and Term.
This Agreement shall commence on the Effective Date and remain in effect until the expiration,
termination, surrender, or revocation of Licensee's Commercial Cannabis Permit, unless sooner
terminated as provided for herein.
3. Description of Business and Ownership.
Licensee's has been awarded a Commercial Cannabis Permit dated June 20, 2023 to operate a
commercial cannabis business at the Property (the "Business"). Licensee shall operate the
Business as a retailer and distributor, as those terms are defined in NCMC Chapter 9.60. The
terms and conditions of the Commercial Cannabis Permit are incorporated into this Agreement
by reference.
4. Applicable Laws and Regulations.
4.1 General. Licensee shall at all times comply fully with all current and future State
and City laws and regulations applicable to Licensee's Business, including but not limited to
NCMC Chapter 9.60. Licensee shall ensure such compliance by all of Licensee's employees,
contractors, vendors, and members of the public invited or allowed access to the Business.
4.2 State License, Licensee shall promptly apply for and obtain all State licenses
required for the Business's operations. Failure to obtain and maintain required State licenses
during the term of this Agreement shall constitute a default under this Agreement and shall be
grounds for termination.
5. Conditions of Approval.
In addition to the requirements contained in the Plans, as defined in Section 6 below, the
Licensee shall at all times operate the Business in accordance with the Conditions of Approval
for the Business, attached hereto as Exhibit A and incorporated herein by reference (the
"Conditions of Approval"). To the extent there is a conflict or inconsistency between the
Conditions of Approval and the Plans, the Conditions of Approval shall control. To the extent
the Conditions of Approval conflict with any applicable state or local law or regulation, currently
existing or enacted in the future, the applicable law or regulation shall control. The City
Manager, or his or her designee, shall have the authority to amend the Conditions of Approval
subject to the requirements of this Agreement.
6. Operating Requirements.
6.1 Operating Requirements. In addition to any other applicable requirements,
Licensee shall at all times operate the Business in accordance with the operating procedures
contained in Exhibit B, attached hereto and incorporated by reference. Such operating procedures
include requirements for the opening and closing of the Business, customer check -in, product
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delivery, use of specific point -of -sale software, inventory control, diversion prevention, product
distribution, transportation procedures, odor control, and quality control. Nothing in this section
shall prevent the Licensee from changing the mix and type of cannabis products at the Business.
6.2 Safety Plan. hi addition to any other applicable requirements, Licensee shall at all
times operate the Business in compliance with the Safety Plan contained in Exhibit C, attached
hereto and incorporated by reference, including but not limited to all fire prevention and
suppression measures, accident and reporting procedures, medical emergency response
procedures, and waste management procedures identified therein.
6.3 Security Plan. In addition to any other applicable requirements, Licensee shall at
all times operate the Business in compliance with the Security Plan submitted with the
Licensee's application and on file with the City. The Security Plan identifies access control
requirements, perimeter security standards, inventory control measures, cash handling
procedures, information/records security, lighting and surveillance requirements, theft and
diversion prevention strategies, and employee training policies, among other topics.
6.4 Amendments. Licensee shall operate Business in accordance with the
requirements of the this Section 5 and the plans contained in Exhibit B and C attached hereto
(collectively, the "Plans") , with such amendments or changes approved by the City Manager, or
his or her designee. To the extent there is a conflict or inconsistency between the Plans and this
Agreement, this Agreement shall prevail.
7. Community Benefits. Licensee has offered to provide certain community benefits as part
of the operation of the Business, and the City has accepted such offer. The community benefits to
be provided by Licensee are specified in this Section.
7.1 National City Community Benefit Fund.
a. Community Benefit Fund, Licensee hereby agrees to donate an amount
equal to the greater of: i) Fifty Thousand Dollars ($50,000), or ii) one percent (1%) of the Net
Profits of the Business, as defined herein, to nonprofit community organizations located and
doing business within National City, subject to the requirements of this Section (the "National
City Community Benefit Fund").
b. Annual Plan. No later than the October 1 of each year, beginning the year
after the Business commences operations, Licensee shall submit to the City an annual plan for
the disbursement of the National City Community Benefit Fund (the "Annual Plan"). The
Annual Plan shall identify the recipients of the funds, the estimated amount that shall be
provided to each recipient, and such other information as may reasonably be required by the
City. The recipients of the proceeds of the National City Community Benefit Fund shall: i) be
exempt from taxation pursuant to Internal Revenue Code section 501(c)(3), 501(c)(4) or
501(c)(6), ii) shall be in good standing with the laws of the State of California, and iii) shall
provide sufficient services within the City of National City that benefit the public (each a
"Recipient"). The City may, in its sole discretion, determine that a proposed Recipient does not
provide sufficient services within National City that benefit the public, and such determination
shall be conclusive. The City shall review, and either approve or reject, the Annual Plan. If the
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City rejects the Annual Plan, it shall notify the Licensee in writing of the reasons for the
rejection. Thereafter, the Licensee shall submit a revised Annual Plan within forty-five (45) days.
If the City fails to approve or reject the Annual Plan within thirty (30) days of submittal by the
Licensee, the Annual Plan shall be deemed approved. Licensee may at any time apply to amend
its Annual Plan, subject to the same procedures contained in this Section 7.1.
7.2 General Fund Contribution.
a. Voluntary General Fund Contribution. Licensee hereby agrees to
donate an amount equal to five percent (5%) of the Gross Receipts of the Business, as defined
herein, to the City's General Fund, subject to the requirements of this Section 7 (the "General
Fund Contribution"). The General Fund Contribution may be used for any lawful municipal
purpose as determined by the City Council, in its sole and absolute discretion.
b. MonthIy Payments. No later than the 15th day of each calendar month,
Licensee shall pay to the City the General Fund Contribution from the previous calendar month.
The payment shall be accompanied by a report, on a form approved by the City's Finance
Director, identifying the total amount of the Gross Receipts of the Business from the previous
month and any other information requested by the City.
c. Penalty for Delay. If Licensee fails to remit any amount owed pursuant
to Section 7.2(b) within the time required, Licensee shall pay a penalty of ten percent (10%) of
the amount owned in addition to the outstanding amount. The amount of the penalty shall
increase by an additional ten percent (10%) each additional thirty (30) days during which the
Licensee fails to make the requirement payment. Licensee and City agree that this penalty is
necessary in order to ensure that Licensee timely provides the funds it has promised to donate
and which the City has budgeted based on such promise.
7.3 Financial Reporting & Administration.
a. Gross Receipts. As used in this Agreement, "Gross receipts"
includes the total amounts actually received or receivable during a calendar year for the sale of
any cannabis goods for which a charge is made or credit allowed, whether or not such act or
service is done as a part of or in connection with the sale or delivery of cannabis materials,
cannabis services, cannabis goods within the City of National City, or outside the City of
National City when the proceeds are credited to or for the account of the Business. Included in
"gross receipts" shall be all commissions, fees, receipts, receipts from coin -operated equipment,
cash, credits and property of any kind or nature, without any deduction therefrom on account of
the cost of the property sold, the cost of materials used, labor or service costs, interest paid or
payable, or losses or other expenses whatsoever. Excluded from "gross receipts" shall be the
following: i) cash discounts allowed and taken on sales; ii) credit allowed on property accepted
as part of the purchase price and which property may later be sold; iii) any tax required by law to
be included in or added to the purchase price and collected from the consumer or purchaser; iv)
such part of the sale price of property returned by purchasers upon rescission of the contract of
sale refunded either in cash or by credit; v) amounts collected or held in trust for others where
the business is acting as an agent or trustee, to the extent that such amounts are paid to or for the
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benefit of those for whom collected (the collector may require proof of payment or disbursement;
vi) receipts of refundable deposits, except that refundable deposits forfeited and taken into the
income of the business shall not be excluded and vii) non -cannabis materials, goods, wares or
merchandise.
b. Net Profits, As used in this Agreement, "Net profits" shall mean
the net taxable income of the Business as reported annually to the California Franchise Tax
Board on its annual tax return, less any federal, state, or local taxes paid by Business and not
otherwise reported as part of the net taxable income of the business.
c. Reporting of Gross Receipts. No later than February 15 of each
year during the Term of this Agreement, Licensee shall deliver to City a report, on a form
approved by the City's Finance Director, showing:
(i) The Business's Gross Receipts and Net Profits from the
previous calendar year (the "Statement of Receipts");
(ii) The total amount of the General Fund Contribution; and
(iii) The total amount contributed to the National City
Community Benefit Fund and the actual amount of money provided to each Recipient.
d. Statements of Receipts. Licensee shall keep complete, accurate
and appropriate books and records of all receipts and expenses from the Business's operations in
accordance with generally accepted accounting principles ("Books and Records"). Books and
Records, as well as all other relevant documents as City reasonably requires, shall, upon
reasonable written notice, be open for inspection by City, its auditors, or other authorized
representatives. If at any time during the Agreement, such Books and Records are deemed
inadequate in the reasonable judgment of City, Licensee shall, upon the written notice of City, be
given a one quarter period (three months) to cure such inadequacies. If, in the reasonable
judgment of the City, Licensee has not cured the Books and Records inadequacies, City shall
consider Licensee to be in default of this Agreement, and may choose to terminate this
Agreement.
e. Audit. City shall have the right to audit and examine Licensee's
Books and Records, and other relevant documents and items in Licensee's possession ("Audit
Items"), but only to the extent necessary for a proper determination of gross receipts, net profits,
and expenses from operations. Upon written request by City, Licensee shall make all Audit
Items available to the City within thirty (30) days of City's request.
f Retention of Receipts. Licensee shall preserve Audit Items in the
City for a period of at least five (5) years.
g. Copies of Tax Filings, Upon request, Licensee shall provide City
with copies of any reports and tax filings Licensee is required to provide to the County of San
Diego, the State, and the federal government.
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h. Future Revenue Mechanisms. During the term of this
Agreement, if the City imposes an alternative revenue mechanism specifically related to
commercial cannabis business permit holders, Licensee agrees to pay the City the greater of the
payment required under such alternative revenue mechanism or the General Fund Contribution.
Payments that are not specific to commercial cannabis business permit holders (e.g. apply to both
cannabis and non -cannabis businesses), shall be in addition to, and not in lieu of, the payments
required by this Agreement.
7.4 Miscellaneous Community Benefits
a. Community Clean Up. Licensee shall organize and host one
community clean-up event per calendar year. Licensee shall be solely responsible for all costs
associated with such event, and shall obtain any permits and approvals from any responsible
governmental agency necessary for the event. Licensee shall coordinate the location of the
community clean-up events with the City to ensure that community clean-up events sponsored
by cannabis businesses are distributed throughout the City of National City.
b. Drug Prevention Seminars. The Licensee shall participate in at
least two (2) drug prevention seminars hosted collectively by all cannabis businesses operating in
National City. The seminars shall be offered free of charge to the public at a location within the
City of National City, and shall focus on responsible use of cannabis and secure storage of
cannabis to prevent access by minors. Licensee shall work in good faith to develop and sponsor
such seminars.
c. Employment Priorities. In an effort to further restorative justice
and the local economy, the Licensee shall use a good faith effort to ensure that at least thirty
percent (30%) of the employees of the Business are residents of the City of National City and at
least twenty percent (20%) of the employees of the Business are individuals previously convicted
of misdemeanor offenses related to the sale, distribution, use, or cultivation of cannabis.
8. Location Change & Transfer
8.1 Change of Location. The Licensee shall not change the location of the
Business unless and until the Licensee first complies with the requirements of NCMC Section
9.60.430, and obtains the necessary approvals,
8.2 Transfer of Ownership. The Licensee shall not transfer ownership or
control of the Business or the Permit unless and until the Licensee first complies with the
requirements of NCMC Section 9.60.420, and obtains the necessary approvals.
8.3 Local Ownership. The Licensee identified in the Application that it was
at least fifty-one percent (51%) owned by residents of National City. Licensee acknowledges that
it was eligible to receive the local preference criteria in the Guidelines based on this
representation. Notwithstanding anything in NCMC Chapter 9.60 to the contrary, Licensee may
not change its ownership structure in anyway such that less than fifty-one percent (51 %) of the
Licensee is owned by residents of National City. In addition to any other applicable requirement,
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Licensee shall notify the City every time there is a change in its ownership, and shall identify
whether or not the new owner is a National City resident.
9. Processing Fees and Charges.
Licensee shall pay City, processing, inspection, plan checking, permit, and monitoring fees and
charges required by City for processing Licensee's applications and requests for permits,
inspections, approvals and actions, and monitoring compliance with any permits issued or
approvals granted, or the performance of any conditions.
10. No Vested Rights.
The Parties acknowledge and agree that this Agreement is not a statutory development
agreement authorized by Government Code section 65864. This this Agreement confers no
entitlement or vested rights of any kind to Licensee to operate the Business, or engage in any
commercial cannabis activity.
11. Voluntary Agreement.
The terms and conditions of this Agreement are the result of voluntary negotiations between the
Parties, and no term in this Agreement has been imposed by the City, including without
limitation the General Fund Contribution. The City and Licensee have each voluntarily and
freely elected to enter into this Agreement. Each of the Parties have had an equal opportunity to
participate in the negotiating and drafting of this Agreement, and to review the Agreement with
legal counsel, therefore any construction as against the drafting party shall not apply to this
Agreement.
12. Indemnity.
Licensee shall indemnify, defend, and hold harmless to the fullest extent permitted by law, City
and its officers, officials, employees, consultants, attorneys, and volunteers ("lndemnitees") from
and against any and all claims, liability, loss, damage, expense, costs (including without
limitation costs and fees of litigation) of every nature arising out of or in connection with the
operation or existence of the Business, this Agreement, or the Property (including any challenge
to the validity of any provision of this Agreement or the Permit approvals, or Licensee's failure
to comply with any of its obligations under this Agreement, or Licensee's failure to comply with
any current or prospective law); provided, however, that Licensee shall have no obligations
under this Section for such loss or damage which was caused by the sole negligence or willful
misconduct of the Indemnitees. This indemnification obligation shall survive this Agreement
and shall not be limited by any insurance policy, whether required by this Agreement or
otherwise.
13. Waiver & Hold Harmless
Licensee waives, releases, and holds harmless the City and its officers, officials, employees, and
agents from any and all actual and alleged claims, losses, damages, injuries, liabilities, costs
(including attorney's fees), suits or other expenses which arise out of, or which are in any way
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relate to this Agreement, including the enforcement of any term or condition stated herein, the
payment of the General Fund Contribution, the issuance of the Cannabis Business Permit, or the
Operation of the Business. Notwithstanding anything in this Agreement to the contrary, the Parties
acknowledge that the City would not have entered into this Agreement had it been exposed to
liability for damages from Licensee, and therefore, Licensee hereby waives all claims for damages
against the City for breach of this Agreement. Licensee hereby voluntarily and unconditionally
waives any rights it may have to challenge this Agreement or any term contained herein.
Licensee specifically waives the provision of California Civil Code Section 1542, which provides
as follows:
"A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE
CREDITOR OR RELEASING PARTY DOES NOT KNOW OR EXPECT TO
EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THIS
RELEASE, AND THAT IF KNOWN TO HIM OR HER MUST HAVE
MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE
DEBTOR OR THE RELEASED PARTY."
In this connection and to the extent permitted by law, Licensee hereby agrees, represents and
warrants that Licensee realizes and acknowledges that factual matters now unknown to it may
have given or may hereafter give rise to causes of action, claims, demands, debts, controversies,
damages, costs, losses and expenses which are presently unknown, unanticipated and unsuspected,
and Licensee further agrees, represents and warrants that the waivers and releases herein have
been negotiated and agreed upon in light of that realization and that Licensee nevertheless hereby
intends to release, discharge and acquit the City from any such unknown causes of action, claims,
demands, debts, controversies, damages, costs, losses and expenses which might in any way be
included as a material portion of the consideration given to City by Licensee in exchange for
City's performance hereunder.
City has given Licensee material concessions regarding this transaction in exchange for Licensee
agreeing to the provisions of this Section. City and Licensee have each initialed this Section to
further i dicate their awareness and acceptance of each and every t. vi . • n hereof.
CITY'S INITIALS
14. Liability.
otob
LICEN T 'S INITIALS
City shall not assume liability or responsibility for any conditions related to the construction or
use of the Business that may be in violation of local and/or state health and building codes
("Conditions"). City shall not assume responsibility for correcting Conditions, either existing or
discovered during the course of the construction or operation of the Business. Failure to correct
Conditions during the course of construction or operation of the Business shall not imply that
City has accepted Conditions nor forfeit City's right to have Conditions corrected at a future
date.
15. Defaults.
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Notwithstanding other provisions of this Agreement, any failure by either party to perform any
term or provision of this Agreement, which failure continues uncured for a period of thirty (30)
days following written notice of such failure from the other party ("the Complaining Party")
(unless such period is extended by mutual written consent), shall constitute a default under this
Agreement. The Complaining Party's notice ("Default Notice") shall specify the nature of the
alleged failure, and may specify the manner in which the failure satisfactorily may be cured by
the other party ("the Defaulting Party"). If the nature of the alleged failure is such, that it cannot
reasonably be cured within such thirty (30) day period, then no default shall be deemed to have
occurred if: (a) the cure shall be commenced at the earliest practicable date following receipt of
the Default Notice; (b) the cure is diligently prosecuted to completion at all times thereafter; (c)
at the earliest practicable date (if no event later than thirty (30) days after the Defaulting Party's
receipt of the Default Notice), the Defaulting Party provides written notice to the Complaining
Party that the cure cannot practicably be completed within such thirty (30) day period; and (d)
the cure is completed at the earliest practicable date.
Upon the occurrence of a default under this Agreement, the Complaining Party may, in addition
to any and all other rights or remedies of the Complaining Party hereunder and/or provided by
law, shall have the right to: i) terminate this Agreement, or ii) commence an action against the
Defaulting Party for damages, injunction and/or specific performance.
No remedy specified in this Section shall be considered exclusive of any other remedy, but the
same shall be cumulative and shall be in addition to every other remedy provided hereunder or
now or hereafter existing at law or in equity or by statute, and every power and remedy provided
by this Agreement may be exercised from time to time and as often as occasion may arise or as
may be deemed expedient, subject to any limitations set forth herein.
16. Termination.
16.1 By Mutual Consent. This Agreement may be terminated in whole or in part by
the mutual written consent of all the Parties.
16.2 Failure to Obtain or Maintain Required State or Local Licenses. If Licensee
fails to obtain or maintain in effect all State and City licenses required for the Business, City may
immediately terminate this Agreement.
16.3 State or Federal Action. In the event that State law permitting the use for which
the Commercial Cannabis Permit was issued is amended or repealed resulting in the prohibition
of such use, either Party may terminate this Agreement.
16.4 Surrender or Revocation of Commercial Cannabis Permit. If Licensee
voluntarily surrenders their Permit, or if Licensee's Permit is revoked by City, Licensee shall
immediately cease all operations at the Business, and this Agreement shall terminate
automatically, without further action required by either Party.
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16.5 Default. If Licensee is in default of any provision of this this agreement, including
but not limited to the requirements of Section 7, the City may terminate this Agreement pursuant
to Section 14.
16.6 Effect of Termination of Agreement on Commercial Cannabis Permit,
Licensee agrees that termination of this Agreement in accordance with this Section, shall also
result in the automatic termination of the Licensee's Commercial Cannabis Permit. Upon
termination of this Agreement, Licensee shall remit all fees and payments due as of the effective
date of the termination.
17. Future Amendments.
The City Manager shall have the authority to approve minor amendments to this Agreement
without further approval from City Council. For the purposes of this section, an amendment shall
be a minor amendment if it substantially conforms with the material terms of this Agreement.
Without limiting the generality of the foregoing, changes to the time for either Party to perform
any obligation and changes in reporting obligations may be made via a minor amendment.
Changes to the amount of gross receipts the Licensee must use for the National City Community
Benefit Fund or the General Fund Contribution shall not be minor amendments. The
determination of the City Manager regarding whether an amendment qualifies as a minor
amendment shall be definitive.
18. Assignment; Binding on Successors.
Licensee may not transfer or assign its interests under this Agreement, in whole or in part,
without the prior written consent of the City, which may be withheld for any reason. Subject to
the restrictions on transfers set forth herein or the NCMC, this Agreement shall bind and inure to
the benefit of the Parties and their respective permitted successors and assigns. Any reference in
this Agreement to a specifically named Party shall be deemed to apply to any permitted
successor and assign of such Party who has acquired an interest in compliance with this
Agreement or under law
19. Notices.
All notices required by this Agreement shall be in writing and personally delivered or sent by
certified mail, postage prepaid, return receipt requested to the following addresses:
Notice to City shall be addressed as follows:
CITY OF NATIONAL CITY
Attn: City Manager
1243 National City Blvd
National City, CA 91950
with copies to:
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CITY OF NATIONAL CITY
Attn: City Attorney
1243 National City Blvd
National City, CA 91950
Notice to Licensee shall be addressed as follows:
NC INVESTMENT GROUP, LLC
316 W. 30th Street
National City, CA 91950
with copies to:
AUSTIN LEGAL GROUP, APC
Attn: Gina Austin, Esq.
3990 Old Town Ave
San Diego, CA 92110
Either Party may change the address stated herein by giving written notice to the other Party, and
thereafter, notices shall be addressed and transmitted to the new address. All notices shall be
deemed received on the earlier of the date that personal delivery is effected or the date shown on
the return receipt.
20. Severability.
If any term, condition, or covenant of this Agreement is declared or determined by any court of
competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions of this
Agreement shall not be affected, and the remaining provisions of the Agreement shall be read
and construed without the invalid, void, or unenforceable provision(s).
21. No Implied Waiver of Breach.
The waiver of any breach of a specific provision of this Agreement does not constitute a waiver
of any other breach of that term or any other term of this Agreement.
22. No Third Party Beneficiaries.
The parties do not intend to create, and nothing in this Agreement shall be construed to create
any benefit or right in any third party.
23. Action or Approval.
Whenever action and/or approval by City is required under this Agreement, the City Manager of
the City of National City, or his or her designee, may act on and/or approve such matter unless
specifically provided otherwise, or unless the City Manager determines in his discretion that such
action or approval requires referral to City Council for consideration.
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24. Governing Law and Forum.
This Agreement shall be construed in accordance with the laws and judicial decisions of the
State of California, and venue or any legal or equitable action shall be in the state or federal
courts of County of San Diego.
25. No Agency, Joint Venture, or Partnership.
City and Licensee hereby renounce the existence of any form of agency relationship, joint
venture, or partnership between City and Licensee, and agree that nothing contained herein or in
any document executed in connection herewith shall be construed as creating any such
relationship between City and Licensee.
26. Entire Agreement.
The provisions of this Agreement comprise all of the terms, conditions, agreements and
representations of the Parties. This Agreement may not be altered or amended, and no provision
hereof may be waived, except by written agreement executed by the authorized representatives
of the Parties. The Parties hereby agree that terms of this Agreement have not been changed,
modified, or expanded by any oral agreements or representations entered into or made prior to or
at the execution of this Agreement.
24. Counterparts.
This Agreement may be executed in one or more counterparts, each of which shall be an original
and .all of which taken together shall constitute one instrument.
Exhibit A
Exhibit B
Exhibit C
Conditions of Approval
Operating Procedures
Safety and Security Plan
[SIGNATURES ON FOLLOWING PAGE]
DocuSign Envelope ID: D1D5340C-722C-4576-8A3D-8822710C2865
IN WITNESS WHEREOF, the Parties hereto have executed this Agreement on the dates set
forth below.
CITY OF NATIONAL CITY, a municipal
corporation
NC Investment Group, L C
By:..-- Si.(PA
Name: Ronnie Webber
Dated: 7 6,7 Its: Manager
6T I) Z3
LDocuSigned by:
6CBFFOFFF2594F2...
Attest:
City Clerk
Approved as to form:
ShAjf
City Y Atto y
5212884.2
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Dated:
By:
A
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Name: ') -- C'.V 19 bbb
of Hilife Group NC, LLC
Its: Manager
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Dated: 5 3 / ' Z
Name: Christopher Garmo of Gido Greens
LLC
Its: Manageerr t�
Dated: J 3 d,, p�
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
EXHIBIT A
CONDITIONS OF APPROVAL
General Conditions:
1. Licensee shall post clearly visible signs at all entrances and exits and at both on and off -
site parking areas, requesting patrons to respect residents of adjacent residential
neighborhoods by being quiet when leaving, reminding patrons of the existence of permit
parking districts within the neighborhoods adjacent to the business, and that the
consumption of cannabis in public areas is not permitted pursuant to state law.
2. A responsible person shall always be on the premises to act as manager and supervise
employees during business hours.
3. The applicant shall comply with the applicable requirement of NCMC Title 12, Noise
Control. Noise complaints shall be immediately addressed.
4. Odor generated by the Business shall not be detectable outside the Business to a person of
normal olfactory sensitivities, including anywhere on adjacent property or public rights -
of -way, or within any other unit located within the same building as the Business. An odor
absorbing ventilation and exhaust system shall be installed so that odor generated within
the Business is not detected outside of the Business.
5. Licensee shall proactively monitor and resolve any issues involving disturbances, loitering
or ingestion of cannabis in parking lots or surrounding streets, sidewalks, and alleys.
6. Licensee shall provide law enforcement and all neighbors within one hundred feet of the
Business with the name and phone number of an on -site community relations employee to
notify if there are operational problems with the establishment.
7. Licensee shall employ a minimum of one (1) on -site security guards during all hours of
operation.. All security guards employed by the Business shall be licensed and possess a
valid Department of Consumer Affairs "Security Guard Card" at all times. In addition, any
security guard employed by the Business or security firm retained by the Business must
first be approved by the City's Chief of Police, in his or her reasonable discretion.
Neighborhood security guard patrols shall be conducted every hour, for a two -block radius
surrounding the Business during all hours of operation.
8. The Licensee shall not employ security guards armed with firearms or tasers.
9. Upon presentation of proper credentials by any Code Compliance or Law Enforcement
Officer, the Licensee shall consent to entry of the place of business at all reasonable times
to enforce the provisions of this Agreement or the NCMC.
10. On -site sales of alcohol or tobacco, and on -site consumption of alcohol or tobacco products
by patrons prohibited.
11. All proposed structures must comply with zoning and building code regulations and pass
all requisite inspections and receive all permits required under applicable law.
12. All cannabis waste must be stored in a secured location and properly disposed by a cannabis
waste collector.
14
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13. The on -site consumption of alcohol, tobacco or cannabis by employees of the Business is
prohibited while such employees are working.
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Exhibit B
Final Inspection and Occupancy
Move in to facility & facility preparation
Open for Business
November 2022
November 2022 — December
2022
January 2023
RETAIL DAILY OPERATIONS
HOURS OF OPERATIONS; OPENING & CLOSING PROCEDURES
NCIG intends to be open to customers seven days a week between the hours of 9:00 a.m. to 9:00
p.m., in compliance with National City Municipal Code ("NCMC") § 9.60.250(G), unless otherwise
required by the City of National City.
OPENING PROCEDURES
The retail store manager and employees arrive at the store at 8:30 a.m. to prepare the
store for opening;
The overnight security guard greets the arriving team and disables the alarm system to
allow employees to enter;
The overnight security guard screens employees and checks bags for weapons;
Employees immediately store their personal items in their own locker in the employee
locker room;
Employees turn on the product display cases and television monitors and then verify that
all product menus (online, digitally displayed, and printed) have been updated to reflect
the current products and pricing;
- Each employee is responsible for ensuring that the counters and display cases are clean,
product display cases are prepared for the day, and the merchandise/accessories are
organized;
Using their individual login, employees will login into the POS system on their assigned
register;
Then each employee goes to the manager's to be given a POS cash drawer with $300 to
begin the day;
- The date, time, register number, and the starting balance will be recorded in the cash
register report form in the POS system;
- Prior to opening the doors to customers at 9:00 a.m., the manager on duty conducts the
opening procedures checklist to verify:
• Everything is clean, organized, and clutter free;
• Each register has the appropriate amount of cash;
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The product display cases have been filled and organized;
All POS systems and equipment are functioning;
All lights and digital displays have been turned on;
The product menus are accurate;
The scheduled staff have clocked in and are wearing their retail store employee
identification badges;
The HVAC system temperature is verified and music is turned on; and
Outside areas have been inspected and all trash has been picked up.
- At this point, the store is ready to open, and an employee will then turn on the 'OPEN' sign
and begin daily sales operations at 9:00 a.m.
CLOSING PROCEDURES
At 8:45 p.m. the "OPEN" sign is turned off and no additional customers are allowed to be
checked -in or enter the customer sales area. All sales transactions will be complete by
9:00 p.m.;
- At 9:00 p.m. the front entrance is locked;
Once all customers have exited the premises and the front door is locked, retail sales
associates close out their POS by counting cash in the drawer, entering their cash count
in the POS, logging out of the POS software, and then taking their POS drawer to the
manager's office;
- Retail sales associates then clean their station and all counter tops are wiped with a
sanitizing cleaning solution, floors are swept and mopped. Televisions, digital display
cases, and lights are turned off;
- The manager on duty confirms the cash counts and documents any discrepancies in the
POS system. All cash is then placed in the safe with a signed cash count ticket attached
to the bundle. The manager on duty will return the cash from the registers to the cash safe
and conduct an audit of all the cash in the vault including cash for registers, change and
coin boxes, bank bags, and bank bundled cash. The total cash safe balance will be verified
on the cash safe audit form and the closing report will be generated from the POS system.
The manager on duty will complete the daily sales spreadsheets and vault balance
spreadsheets and upload the documents to the inventory management system. The cash
safe is then closed and locked.
Prior to exiting the retail store, the manager on duty will verify that:
• All retail store employees have clocked out and exited the facility;
• All cannabis products are properly accounted for in the inventory system and
stored securely;
• All security systems are functioning, all doors are secured, the cash safe and
Inventory Storage room is securely locked; and
• All persons have left the building.
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- The overnight security guard remains on the premises and monitors the security cameras.
CUSTOMER CHECK -IN PROCEDURES
NCIG's check -in procedures include the use of cutting -edge technology that ensures a high-level
of security and accuracy in identification verification, while implementing advances in the industry
in terms of design and customer experience.
Per NCMC § 9.60.250(A), NCIG shall not allow anyone under the age of 21 to enter the premises,
unless between the ages of 18 and 20 with a valid physician's recommendation for the purchase
of medical cannabis.
Upon entry into the premises, each person must present valid government -issued identification
to the check -in staff. "Valid" identification means it is not expired and includes one of the following
forms of identification with all of the required information:
- A document issued by a federal, state, county, or municipal government, or a political
subdivision or agency thereof, including, but not limited to, a valid motor vehicle operator's
license, that contains the name, date of birth, physical description, and picture of the
person;
- A valid identification card issued to a member of the Armed Forces that includes a date of
birth and a picture of the person; or
- A valid passport issued by the United States or by a foreign government.
Check -in staff verifies each person's identification by scanning it through our identification
scanner, TokenWorks Identification Scanner X8pro. TokenWorks' scanner software verifies the
authenticity of the identification. The software also completes a data entry for each scan into our
Treez POS (point -of -sale), which includes the customer's name, the customer's age, identification
and/or driver's license number, and customer's address. Check -in staff then confirms that the
photo on the identification matches the person. After this check -in process, a security guard will
use a metal detection "wand" to scan the person for metal. Guns and other weapons may not be
brought into the premises. Check -in staff and security personnel will manage customer entrance
into the customer sales area and limit entry as needed to ensure there is no overcrowding.
Only persons who are 21 years of age or older, or at least 18 years old with a valid physician's
recommendation and valid identification, are allowed on the premises or into the customer sales
area. Our security guards politely assist with any compliance issues that may arise during this
access verification process.
LOCATION AND PROCEDURES FOR RECEIVING DELIVERIES DURING
BUSINESS HOURS
INVENTORY RECEIVING LOCATION
All deliveries of inventory during business hours will be received through the access point labeled
entry to Receiving/Shipping room on the premises diagram ("Delivery Entrance").
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INVENTORY RECEIVING
The Delivery Entrance is the door through which all cannabis inventory will enter the premises
during business hours of 9:00 a.m. to 9:00 p.m. This Delivery Entrance is separate and apart from
the Main Entrance/Exit that customers and staff use to enter and exit the premises, which
increases security and safety while bringing cannabis products into the premises. This access
point for shipping/receiving leads into the limited -access areas of the premises.
Our established procedure for receiving inventory shipments exceeds State's requirements. All
shipments of inventory are scheduled in advance so that we can ensure proper staffing when
shipments arrive. When onboarding a new distribution partner, we establish specific agreed upon
procedures that the distributor's driver must follow when delivering cannabis products to our retail
premises. Because we are also applying for a distribution license, we intend to fulfill most of our
distribution needs are on our own.
Distribution drivers are required to park behind the building. The driver then calls an NCIG
manager to announce arrival, and waits in the vehicle until a security guard meets the vehicle.
Only then is the shipment unloaded from the vehicle and brought into the premises via
Shipping/Receiving doorway. This process is done under video surveillance and with a security
guard present.
Once inside the premises, the shipping manifest is checked line -by-line to ensure that all items
ordered and only items ordered are being delivered. If the shipping manifest is accurate, the
distribution driver and the NCIG manager sign off on the shipping manifest and the driver exits
the premises. If the shipping manifest is not accurate, notations are made on the shipping
manifest. Items that were not ordered are rejected. If the order is missing items, it is notated on
the shipping manifest and the accurate items are accepted. At this point, the employee who
received the cannabis products brings the cannabis products into an inventory storage room. If
the agreement with the distributor calls for cash on delivery, the distributor is then paid via cash
or check, and then the delivery driver leaves through the Shipping/Receiving doorway with
assistance from the security guard.
INVENTORY DOCUMENTATION
Inventory documentation required is accomplished via our Treez POS and inventory management
software. Within 24 hours of cannabis products being received, cannabis products are logged into
Treez with the following information:
1) description of each item so that cannabis products are easily identified;
2) quantity of each item;
3) date and time cannabis products were received;
4) sell -by or expiration date if any;
5) name and license number of the distributor the cannabis products were received from;
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6) price we paid for the cannabis products including taxes, delivery costs, and other fees.
The Treez inventory management system includes electronic tracking of each package with a bar
code sticker and scanner. Each individual product/unit receives a small sticker with a bar code on
it and is associated with the cannabis product received. When the cannabis product is scanned
to be sold to a customer, inventory counts are updated and we have a record of the sale. This
procedure produces very accurate inventory tracking and makes compliance with state METRc
track -and -trace mandates, including inventory reconciliation, efficient to accomplish, because
METRc is automatically updated through the Treez to METRc API (application programming
interface; an API is how two different software systems work together and transfer data).
POINT -OF -SALE LOCATION AND NUMBER
NCIG will have five (5) point -of -sale (POS) stations at the location marked "Cashier" on the
premises diagram: 4 traditional registers; and 1 ADA accessible register and point -of -sale system.
Each point -of -sale station has a video surveillance camera positioned in a location to enable the
recording of the purchaser's and seller's facial features as required per state law. The POS
stations are securely affixed to the display counter, so they cannot be moved or picked up.
NCIG will not operate as or with a drive -through window or a slide -out tray to the exterior of the
facility.
ESTIMATED NUMBER OF CUSTOMERS PER HOUR AND DAY
ESTIMATED NUMBER OF CUSTOMERS PER HOUR
Based on careful study of our sales data, we know the peak days of the week and peak hours of
day and staff accordingly. We estimate that on average 17 customers will visit the store each hour
(post -initial operating year). We plan for the following flow of customers per hour:
- Between 9 am to 10 am, we expect 20 customers;
Between 10 am and 2 pm, we expect 75 customers;
- Between 2 pm and 5 pm, we expect 50 customers;
Between 5 pm and 8 pm, we expect 75 customers; and
Between 8 pm and 9pm, we expect 30 customers.
ESTIMATED NUMBER OF CUSTOMERS PER DAY
We estimate that there will be an average of 250 customers will visit our store each day. In this
cannabis retail setting, we know that Fridays and Saturdays are busier than Mondays. Thus, we
plan our staffing levels to accommodate the following expected number of customers by day of
the week.
- Sunday — estimate 275 customers;
- Monday — estimate 200 customers;
Tuesday — estimate 200 customers;
- Wednesday — estimate 220 customers;
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- Thursday — estimate 250 customers;
- Friday — estimate 300 customers; and
- Saturday — estimate 280 customers.
PROPOSED PRODUCT LINE AND PERCENTAGE OF SALES OF FLOWER AND
MANUFACTURED PRODUCTS
All cannabis products for sale will comply with all applicable requirements found in the Department
of Cannabis Control ("DCC") regulations, City of National City Municipal Code, applicable
regulations, and internal policies. Cannabis products for sale will only be sourced from licensed
distributors or licensed microbusiness authorized to engage in distribution. Through our
operational experience, we have developed the highest standards for our cannabis product
selection. NCIG proposes the following product line based on the type of cannabis products.
PROPOSED PRODUCT LINE
Product types to be offered for sale will include, but may not be limited to the following:
- Cannabis flower. NCIG will offer packaged cannabis flower strains including sativa,
indica, and hybrid (hybrid is a mix of the sativa and indica strains). Different potencies of
THC and CBD, prices, and different weights will be offered to meet the interests of the
local community. Examples of weights include 0.5 gram, 1.0 gram, 3.5 grams, 7.0 grams,
14 grams, and 28 grams.
- Pre -rolls and Infused Pre -rolls. Pre -rolls or marijuana rolled like a cigarette are also
known as joints. Pre -rolls can contain only cannabis flower rolled in paper, or they can be
"infused" which means they contain cannabis flower and additional ingredients like
cannabis oil. Different trains of sativa, indica, and hybrid will also be offered in pre -roll form
with different potencies and different weights similar to cannabis flower.
Pre -filled vaporizer cartridges and pods. Vaporizer cartridges and pods include small
vials of cannabis oil that are attached to an apparatus that vaporizes the cannabis oil
allowing one to smoke the cannabis. These vaporized cannabis products are offered in
different THC and CBD blends of sative, indica, sativa, and hybrid in 0.25 grams, 0.5
grams and 1.0 gram.
- Cannabis edibles. Consuming cannabis edibles is a growing trend in the market. The
category includes items like sweet gummy chewables, savory chips, chocolates, baked
goods, and drinks. NCIG will offer a variety of cannabis edibles that are cannabis -infused
and meet strict state requirements for maximum serving and package sizes.
Cannabis extracts and concentrates. Cannabis extracts and concentrates will be
offered in various sizes that are packaged to meet strict state standards and sizes.
Examples of extracts and concentrates including but limited to the following: tinctures,
capsules, wax/budder/crumble; shatter; rosin; distillate, and live resin (batter; diamond;
sauce; sugar; and high terpene extract). Extracts and concentrates can be consumed like
edibles or smoked like cannabis flower.
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- Cannabis topical products. NCIG will offer cannabis topical products including items
like lotions, creams, balms, oils, and transdermal patches.
PERCENTAGE OF SALES OF CANNABIS FLOWER AND
PRODUCTS
NCIG has extensive experience
operating cannabis retail stores.
As shown in the chart be►ow,
based on our own sales data we
expect that cannabis flower will
make up approximately 55% of
sales and all other manufactured
cannabis products will make up
approximately 45% percentage of
our sales in National City. The
market is continuously growing
and changing. We take pride in
staying abreast of new product
develops, market trends
MANUFACTURED
Percentage of Sales
Cannabis Flower vs Other
Manufacturered Cannabis
Products
45%
goo 55%
Flower - Including Non -Infused Joints
■ Manufactured Cannabis Products
consumer preferences, and product safety and compliance standards. We will continue to assess
the needs of the National City market to ensure that we are offering a range of products that meet
the needs and preferences of the local community.
DELIVERY SERVICE PROCEDURES
NCIG intends to conduct customer sales on -site and via delivery. NCIG intends to develop a
website at which retail customers can order delivery online. The procedures below provide a high
level overview of what NCIG's retail delivery process looks like.
VERIFICATION OF DELIVERY ADDRESS
Prior to assembling a delivery order, the Retail Store Manager will verify that the address is a
deliverable address per the laws and regulations. Specifically, the manager will confirm that the
address is not:
• Located on publicly owned land or any address on land or in a building leased by a
public agency;
• Located at a school providing instruction in kindergarten or any grades 1 through 12, day
care center, or youth center;
• Not located outside the State of California.
ORDER PREPARATION AND DELIVERY REQUEST RECEIPTS
An order fulfillment associate assembles each order into an exit package. The manager reviews
the point -of -sale delivery report and checks each order and exit bag for accuracy. Each delivery
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order is stapled with a copy of the delivery receipt and the bag is placed in a secure location prior
to being loaded into the delivery vehicle. The manager prepares a planned route for the delivery
driver and ensures that not more than $5,000 in retail value of cannabis goods is in any one
delivery vehicle at one time.
ARRIVAL AT CUSTOMER'S DELIVERY ADDRESS
The driver calls the customer upon arrival at the delivery address, takes the order to the door,
verifies identity of the customer, collects payment, requires the customer to sign the delivery
receipt, provides the cannabis products to the customer, and then returns to the vehicle. Delivery
orders are only released to the person who placed the order.
Once in the vehicle, the driver documents the necessary information on the inventory ledger and
stop log, and then heads to the next customer. If cannabis goods are not deliverable for any
reason, the cannabis goods are returned to the vehicle's locked storage box. Upon return to the
premises, all undelivered cannabis goods are checked back into inventory by the Retail Store
Manager. All signed delivery request receipts, inventory ledgers, and stop logs are given to the
manager.
CONFIRMING AGE, CUSTOMER IDENTITY, AND PHYSICAL DELIVERY ADDRESS
During the online ordering process, customers are required to upload a copy of their valid
identification card and a physician's recommendation when applicable. Delivery orders are not
fulfilled unless this pre -identification process is completed.
Upon arrival, the delivery driver requests to see the customer's driver's license or other
government -issued identification. When the delivery driver reviews the government -issued
identification, he/she ensures the name matches the order and verifies age/date of birth.
DELIVERY RECEIPT
NCIG shall provide a delivery receipt to the customer upon completion of the sale and purchase
of cannabis goods. The receipt will include the following information: name and address of NCIG;
first name and employee number of the delivery driver; first name and employee number of who
prepared the order for delivery; first name of the customer and customer number; date and time
the delivery order was placed; delivery address; detailed description of each cannabis product
ordered; total amount paid for the delivery order including any taxes, fees, etc.; and signature of
the customer.
DELIVERY INVENTORY LEDGER AND DELIVERY STOP LOG
During the delivery process, the driver is required to keep a Delivery Inventory Ledger and
Delivery Stop Log. Prior to leaving the premises, the delivery driver is provided with two copies of
the delivery receipt. One copy of the delivery receipt is stapled to the customer's exit bag and the
other is given to the driver as the delivery inventory ledgers and the delivery stop log.
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When the driver returns to the vehicle, delivery driver documents on the retained delivery receipt
the date and time of delivery, his/her own employee id number, and employee signature, all of
which is the inventory ledger and an accurate and updated reflection of the current inventory in
possession of the delivery driver. This documentation along with the planned travel route is the
stop log, which is accurate and will reflect all stops made by the delivery driver including deliveries,
fueling, breaks, unexpected maintenance, and any other stop for any reason. When the driver
returns to the premises, he/she gives to the manager all the signed delivery receipts with the
delivery inventory ledgers and delivery stop log information.
CANNABIS GOODS CARRIED DURING DELIVERY
NCIG only loads cannabis products into its delivery vehicles for specifically identifiable customers
with delivery orders placed as explained above. We do not stock delivery vehicles with cannabis
and add delivery orders to a driver's pre -planned route after the driver has left the premises on a
delivery route.
DELIVERY DRIVERS
Delivery drivers receive specific training on the laws and regulations governing cannabis delivery.
Drivers shall be 21 years of age or older and carry the following during deliveries: copy of NCIG's
current retail license; a copy of the QR Code Certificate issued by the DCC; inventory ledgers;
employee's driver's license; and laminated NCIG identification badge.
DELIVERY VEHICLES
Pursuant to Section 9.60.270, NCIG will provide the following information to the City prior to
commencing delivery operations:
• Proof of Ownership or Valid Lease for Vehicles
• Year, Make, Model, Color, License Plate Number & VIN for Vehicles
• Proof of Automobile Insurance
NCIG will notify the City within 30 days for any changes to the vehicle information provided. This
shall be the responsibility of the NCIG General Managers Ray Ibrahim and Chris Garmo.
Each vehicle used by NCIG for delivery meets the requirements and is outfitted with an active
alarm system and dedicated GPS. The alarm system is activated by the driver each time upon
exiting the vehicle. If a break-in is attempted, a loud strobe sound is emitted to warn of the
intrusion. GPS units include real-time route tracking and remote visibility of the vehicle's location.
The GPS units are owned by NCIG and are not permanently affixed to the vehicles.
RETAIL DELIVERY SAFETY AND SECURITY RULES
Delivery drivers shall not consume controlled substances drugs or alcoholic beverages prior to,
or during, the operation of a delivery vehicle.
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Delivery drivers shall not leave cannabis goods in an unattended motor vehicle unless the motor
vehicle is locked and equipped with an active vehicle alarm system.
Delivery vehicle drivers shall ensure that cannabis products are not visible to the public from the
exterior of the delivery vehicle.
Cannabis products shall be placed in locked containers within the vehicle; and
Delivery vehicles shall not display advertising or symbols visible from the exterior of the delivery
vehicle that suggest the driver or delivery vehicle is used for the delivery of finished cannabis and
cannabis products.
PRODUCT HANDLING PROCEDURES
EMPLOYEE PRODUCT HANDLING
Employees will be trained on proper product handling procedures. During the process of receiving
shipments of inventory, employees will ensure that cannabis products are in shipping containers
that protect cannabis products from damage and/or exposure to heat, excessive cold, sunlight,
water, or other things that could damage or contaminate the packaging. Cannabis products are
stored on shelves in a manner that reduces the need for employees to handle individual units
when organizing inventory or stocking retail sales area shelves.
Upon the direction of a manager, an employee may be directed to open a package of cannabis
flower to place in a specially -designed glass display jar so that customers can smell and see the
cannabis flower as allowed per state regulations. The employee shall remain with the customer
at all times and shall not allow the customer to touch the cannabis flower. The customer will be
allowed to hold the jar to inspect the cannabis. Cannabis flower that is used for display in this
manner shall not be sold and shall be treated as cannabis waste when it is no longer used for
display.
CUSTOMER PRODUCT HANDLING
At no time will customers be allowed to open cannabis products on the premises whether the
cannabis product is available for sale or purchased by the customer. However, upon the
assistance of an employee, customers may inspect the cannabis product label to educate
themselves and ask questions.
Our business model is to allow customers to pick up cannabis products with the purpose of
reading the product labels and inspecting the packaging. We encourage customers to be informed
about cannabis product labels, testing results, product ingredients THC and CBD potency,
manufacturing and packaging dates, and the many other pieces of data. We do this because we
believe that an informed customer is a more responsible cannabis consumer. We also believe
that when customers are able to handle cannabis products for the purpose of inspecting the child -
resistant packaging, tamper evident seals, testing results, and labeling, they will be more aware
of the need to store cannabis in their own homes in a manner that prevents children from gaining
access to products they bring home.
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CASH HANDLING PROCEDURES
Traditionally, cannabis has been a cash business. However, NCIG's good banking relationships
allow it to accept debit card transactions in addition to cash. Because of these banking
relationships, we typically have less cash on -hand than most cannabis retailers. Even so, cash
remains an important way that cannabis business is transacted.
ACCEPTING CASH FROM CUSTOMERS
Employees will be training on cash handling procedures. When customers pay for cannabis
products using cash, the employee will accept the cash and place it on a small ledge above the
cash register drawer. Then the employee will count the change due out loud to the customer as
calculated by the Treez POS. Once the customer has been given change, the employee places
the cash payment in the cash drawer. If the customer has provided a bill larger than a $20 bill,
the employee will use a currency marker pen to determine the authenticity of the bill.
POS CASH DRAWER MANAGEMENT AND LIMITS
At the beginning of each day, each casher drawer at each POS will have a balance of $300 to
make change for customers. Throughout the day, when a POS cash drawer contains a total
amount of $2,000 cash, the manager will remove the cash drawer and replace it with a new cash
drawer with $300. The cash drawer with the approximately $2,000 is taken to the manager's office
where the manager counts the cash and documents the amount on a cash count ticket that is
then attached to the cash bundle. The cash bundle is then placed in the cash safe located in
Office 2 as labeled on the floor plan.
CASH COUNTING AND RECONCILIATION
Cash counting is performed by the manager out of view of general staff and public. Cash counts
occur each time the manager removes a cash drawer from the retail sales floor and at the end of
the business day. The manager runs a report in our Treez POS to determine how much cash
should be in each cash drawer. The manager then counts the cash and documents the cash count
result on a cash count ticket that includes the manager's name conducting the cash count, the
amount of cash counted, the date of the cash count and entry into the cash safe, and the
manager's signature. The cash count ticket is then bundled with the cash and placed in the cash
safe.
The manager also runs an end -of -day report from the Treez POS to determine total sales for the
day and reconciles the end -of -day totals with all payment types received from customers. If there
is a discrepancy of more than $100, then the manager conducts an audit that may include
recounting the cash, viewing video surveillance, discussing the discrepancy with the employee,
and further action depending on the circumstances.
CASH STORAGE IN A SAFE
Cash is stored in a cash safe in the manager's office. The cash safe will weigh at least 800 pounds,
be made of metal, be anchored to the permanent structure of the building, be burglary resistant,
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and maintain fire resistance for at least one hour. Access to the safe is restricted to managers.
The safe shall be closed and locked at all times when the safe is not in active use. Only a limited
and necessary amount of cash remains in the cash drawers on the sales floor. Video surveillance
will record where the safe is located.
CASH PAYMENTS TO OTHER CANNABIS LICENSEES
NCIG often transacts business with other cannabis licensees in cash as is standard practice in
the cannabis industry. For example, when we receive a delivery of cannabis inventory we may
pay the distributor in cash. All cash payments are documented on sales invoices and cash
payment receipts at the time that the cash exchange occurs.
CASH DEPOSITS INTO BANKING INSTITUTION
When a deposit of cash needs to be made into a banking institution, a manager removes the cash
from the safe and documents it in the Treez POS. The cash is placed in a locking bank bag and
taken to the banking institution during daylight hours. A security guard accompanies the manager
to the vehicle to ensure safety. Alternatively, NCIG may use armored vehicle services to pick-up
cash and deposit into our bank.
INVENTORY CONTROL PROCEDURES
POINT -OF SALE AND INVENTORY MANAGEMENT SOFTWARE
We will use Treez seed -to -sale business management software platform as our point -of -sale and
inventory tracking software system. This system fully integrates with the state of California's
METRc track -and -trace software system and will be compatible with the City's record keeping
system.
The General Managers and Store Managers are responsible for accuracy and timely compliance
with all State -required track -and -trace requirements including daily maintenance of data entry or
data transfer from Treez and weekly inventory reconciliation. Under the guidance of the manager,
the following track -and -trace requirements will be met:
Ensure only authorized employees have access to the METRc track -and -trace system.
Each employee is provided with a unique Treez system log -on and password, and the
employee shall only use that log -on and password.
- Maintain a complete and accurate list of all track -and -trace system administrators and
users.
Accurately record all transactions involving inventory of cannabis products, physical
movement, or destruction of cannabis products in the track -and -trace system.
- Ensure that all transactions are entered into the track -and -trace system no later than the
end of the day that the transaction occurred.
- If, for any reason, either Treez or METRc is not accessible, the manager shall create and
maintain paper records detailing all transactions that would have been entered into the
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track -and -trace system. Upon the restoration of access to the track -and -trace system, all
transactions that occurred while access to the track and trace system was not available
shall be accurately entered into the track -and -trace system.
Only enter accurate information into the track -and -trace system and shall correct any
known errors in the information entered into the track -and -trace system immediately upon
discovery.
RECEIVING OF CANNABIS PRODUCTS
Upon receipt of cannabis products from a licensed distributor, the manager or designated
employee enters the following information into our Treez system that then automatically populates
the state's track -and -trace system: distributor's name and license number; type and kind of
cannabis products; amount received, by weight or count; best -by, sell -by, or expiration date of the
batch, if any; person who holds title to the cannabis products; date of receipt of the cannabis
products; unique identifiers/UID associated with the cannabis products and the batch number;
any other information required elsewhere by the State or county cannabis law.
METRC TRACK -AND -TRACE SOFTWARE
Per state requirements as required by the Department of Cannabis Control, all licensees shall
use the METRc track -and -trace software system. The Treez software has an API (application
programming interface) that ensures all data and transactions entered into Treez is automatically
and electronically sent to METRc continuously.
INVENTORY RECONCILIATION
NCIG reconciles inventory every seven (7) days. Reconciliation is a process where the manager
compares track and trace reports to Treez reports to ensure correct data entry and accuracy
between the two systems. Then all physical inventory will be counted and compared to track and
trace system reports. If there is a discrepancy between the physical inventory count and the track
and trace reports, an audit will be conducted. After the audit, any discrepancies of physical
inventory of more than 3 percent of the average monthly sales for the prior six months that cannot
be resolved shall be reported in the track and trace system as well as be reported to the
Department of Cannabis Control.
PREVENTING UNAUTHORIZED ACCESS TO CANNABIS PRODUCTS
Preventing unauthorized access to cannabis products involves security measures and security
policies and procedures that are documented in the Security Procedures section of this
application. Employees are trained about their responsibilities to prevent unauthorized access to
cannabis. Managers are trained about their responsibilities to ensure adherence and compliance
with procedures that have been implemented to prevent unauthorized access to cannabis
products.
Cannabis products that are not displayed in the customer sales area are stored in limited -access
inventory storage rooms. Access to the inventory storage rooms is strictly managed by our
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electronic keypad system. Only managers and employees who are assigned to inventory
management responsibilities are given keypad access to these limited -access storage areas.
Because our keypad security system is electronic, access can be changed in real-time to change
any employee's access as needed. In the event of a power outage, doors remain automatically
locked and can only be access via a regular key.
LIMITED -ACCESS AREAS
Customers are never allowed in limited -access areas. All entry into limited -access areas is
controlled by our electronic keypad entry system. If there is a need for non -employees to enter
limited -access areas where cannabis products are stored, those persons are required to sign -in
and must be accompanied by an employee at times. All non-employees/authorized visitors who
are granted access to limited -access areas are required to sign-in/sign-out with the following
information: name, company name, reason for visit, data and time of entry/exit.
DIVERSION, THEFT, AND LOSS PREVENTION
Our Security Plan (see Section D of the Application) details how we prevent diversion and theft
of cannabis products. Employees are thoroughly trained on diversion and theft prevention
methods and reporting requirements. Video surveillance, METRc track -and -trace inventory
reconciliation and audits, security guard and management oversight, confidential reporting of
suspicious activities and investigation ensure compliance and proper follow-up.
Our primary method for preventing diversion, theft, and loss is the anti -theft stickers placed on all
cannabis products. Each individual unit of cannabis product has a magnetic tag or sticker placed
on it. There are sensors at the access point doors that emit a visual and audio alarm signal if the
sensor is not deactivated before the cannabis product crosses the threshold of the doorway.
These sensors are demagnetized at check-out when the cannabis product is scanned as part of
the purchase process. This anti -theft system deters shoplifting by both staff and customers.
STORAGE AND TRANSPORTATION PLAN
All cannabis inventory is securely stored in a limited -access room. Once cannabis products are
received via our inventory receiving process explained above, cannabis products are immediately
moved to the limited -access inventory storage room. The inventory storage room is climate
controlled to ensure cannabis products are not exposed to excessive heat. The inventory storage
room has sufficient video surveillance to record with the ability to identify the facial features of all
persons who enter/exit and other security features detailed in our Security Plan. The door to this
room remains closed and locked when not in active use. Access to the inventory storage room is
controlled by our security system that uses an electronic keypad where each person granted
permissions enters a unique PIN code to enter the room. Employees who are not given
permissions to enter the Inventory Storage room shall not enter with employees who do have
permissions to enter. The electronic keypad system allows the manager to change and update
permissions in real-time.
Cannabis products are stored on shelves in containers to prevent degradation of the packaging.
Cannabis products are never stored on the floor. The shelving system we use allows for cannabis
products to be organized by product category; thus, for example, all cannabis edibles are stored
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in a similar location on the shelves. We use a first -in first -out approach to inventory storage and
management where the products that we received first are rotated on the shelves to ensure that
when we stock cannabis products on the customer sales floor we are stocking with cannabis
products that have been in our Inventory Storage room the longest. Storage is additionally
organized so that cannabis products that may be expiring or reaching their "best by" date are
stored in a manner that ensures that inventory is stocked first.
Each individual unit of cannabis product receives a bar code sticker when it enters the Inventory
Storage room. When cannabis products are removed from the Inventory Storage room, the bar
code sticker is scanned and an entry is made into Treez that updates the location of each unit of
cannabis product. This technology and process system allows for highly effective cannabis
inventory and storage management procedures.
Transportation of cannabis inventory is the express responsibility of distributors. Please see
NCIG's distribution operations detailed below for NCIG's transportation plan. NCIG will store
cash/currency in a cash safe according to our cash handling procedures detailed in this Business
Plan. If NCIG needs to transport cash, it will comply with all laws and may hire armored transport
if cash amounts are significant.
QUALITY CONTROL
Upon receipt of cannabis products from a licensed distributor, the manager conducts an initial
quality control review of all cannabis products received. This initial quality control review is
designed to ensure that contaminated products, product that might have been damaged in the
transport process, or products that are not properly packaged, labeled or tested do not enter into
our inventory storage area.
INITIAL QUALITY CONTROL REVIEW
The initial quality control review includes the following items:
• Cannabis products are from a distributor with active and valid licenses;
• Cannabis products have not exceeded their expiration date, "best by" date, or "use by"
date;
• Containers holding cannabis products are not damaged and show signs of proper
storage, for example, the containers are clean (do not have filth or dirt on them);
• Sales invoice and shipping manifest are included and accurate;
• Initial inspection demonstrates tamper -evident seal are present and cannabis product
packaging is not damaged; and
• The laboratory Certificate of Analysis (COA) includes the UIDs of the cannabis products
received and is not more than 12-months old.
CANNABIS PRODUCT TESTING
NCIG only sources cannabis products from licensed distributors that meet or exceed laboratory
testing requirements. We independently verify on the DCC's website the distributor's license and
the laboratory's license to ensure the licenses are current. Only cannabis products that have
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received a "PASS" designation on the testing result COA are accepted through our receiving
process must be accompanied by a shipping manifest from the distributor and the COA from the
laboratory.
The COA is further verified in the state's METRc track and trace system. Employees receiving
the shipment of cannabis products verify the following: i) the batch number and UID (unique
identification number) on the COA corresponds to the batch number and UID on the cannabis
products received; ii) the COA is not more than 12 months old at the time that NCIG receives the
cannabis products; and iii) the THC, CBD, and other cannabinoids on the cannabis product label
matches the results on the COA. If any of the above conditions are not met, the cannabis products
are rejected.
ENHANCED PRODUCT SAFETY REVIEW
NCIG implements an Enhanced Product Safety Review to ensure customer health and safety.
This additional step that we take is to ensure that all cannabis products we sell are of the highest
quality and it gives our employees and customers additional confidence that we are committed to
the health and safety of our customers. The first time that we order and receive a specific cannabis
product into inventory, we put the cannabis product through our rigorous enhanced product safety
review that includes regulatory requirements of the DCC. Once a cannabis product passes our
own enhanced product safety review, we conduct the review again each 6 to 12 months.
We only carry cannabis products acquired from licensed distributors that are in finished form and
that are packaged and labeled according to strict state requirements. We strictly adhere to all
regulations and reject all cannabis products that might be packaged and labelled in a manner that
would be attractive to children. All cannabis products we acquire for our retail operations must be
packaged and labeled with the required labels and warnings. Our enhanced product safety review
includes the following:
PACKAGING REVIEW
Our team conducts a comprehensive review of the cannabis product packaging to ensure
compliance with DCC regulations. Areas of review include the following: i) product container
protects the product from exposure to air and other contaminants; ii) tamper -evident seal is
secured on the outer packaging; iii) the package is resealable if the product has multiple servings;
iv) the packaging is child -resistant; and v) packaging is not attractive to children.
Additional packaging review is conducted as follows:
CHILD RESISTANT PACKAGING
State of California laws and regulations require that all cannabis products distributed to a licensed
retailer shall be packaged in child resistant packaging and that the packaging shall maintain its
child resistant effectiveness throughout the life of the package per regulatory requirements. Child
resistant packaging is especially important when a cannabis good contains more than one
serving.
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Edible cannabis product child resistant packaging must be effective for the life of the product.
Inhalable or topical cannabis products with child resistant packaging effective only until the first
opened must have additional label statement of "This package is not child -resistant after opening."
PRODUCT CONTAINER SEPARABLE FROM OUTER PACKAGING
If the cannabis product has two levels of packaging (an inner package that protects the product
and an outer package), then the packaging has additional state requirements. Edible, topical,
suppository, and oral concentrate products must meet labeling requirements on both the inner
and outer packaging, except cannabinoid content. Inhalable cannabis products must have the
universal cannabis symbol on the inner and outer packaging.
EDIBLE CANNABIS PRODUCTS
Edible cannabis products must be in opaque outer packaging, but may have a clear view strip to
view serving markers if any.
LABELING
A comprehensive review of cannabis product labeling includes a review of the strict labeling
requirements set forth by the DCC.
Primary Panel Label. The primary panel is the front -facing part of the package label. The primary
panel of the cannabis product is reviewed for the following elements: 1) identification of the
cannabis product; 2) net weight or volume in metric and U.S. customary units; 3) if edible, the
words "Cannabis -Infused" above the product identification and in a larger font; and 4) the
universal cannabis symbol.
CA
THC and CBD content can be located on the primary panel or information panel.
Information Panel Label. The information panel label is any other part of the package label that
is not the primary panel label. The information panel of the cannabis product is reviewed for the
following elements: 1) manufacturer's name, website or phone number, and city, state, and zip
code; 2) date of manufacture and packaging; 3) correct government warning (see below); 4) use
instructions (method of consumption and preparation); 5) expiration, use -by, or best -by date if
any; 6) UID and batch or lot number; 7) cannabinoid content (see below); and 8) when applicable,
"For Medical Use Only," food allergens, product ingredients.
Government Warning Label for Flower and Pre -Rolls
"GOVERNMENT WARNING: THIS PACKAGE CONTAINS CANNABIS, A SCHEDULE I
CONTROLLED SUBSTANCE. KEEP OUT OF REACH OF CHILDREN AND ANIMALS.
CANNABIS MAY ONLY BE POSSESSED OR CONSUMED BY PERSONS 21 YEARS OF AGE
OR OLDER UNLESS THE PERSON IS A QUALIFIED PATIENT. CANNABIS USE WHILE
PREGNANT OR BREASTFEEDING MAY BE HARMFUL. CONSUMPTION OF CANNABIS
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IMPAIRS YOUR ABILITY TO DRIVE AND OPERATE MACHINERY. PLEASE USE EXTREME
CAUTION."
Government Warning Lab& for Manufactured Products
"GOVERNMENT WARNING: THIS PRODUCT CONTAINS CANNABIS, A SCHEDULE I
CONTROLLED SUBSTANCE. KEEP OUT OF REACH OF CHILDREN AND ANIMALS.
CANNABIS PRODUCTS MAY ONLY BE POSSESSED OR CONSUMED BY PERSONS 21
YEARS OF AGE OR OLDER UNLESS THE PERSON IS A QUALIFIED PATIENT. THE
INTOXICATING EFFECTS OF CANNABIS PRODUCTS MAY BE DELAYED UP TO TWO
HOURS. CANNABIS USE WHILE PREGNANT OR BREASTFEEDING MAY BE HARMFUL.
CONSUMPTION OF CANNABIS PRODUCTS IMPAIRS YOUR ABILITY TO DRIVE AND
OPERATE MACHINERY. PLEASE USE EXTREME CAUTION."
Cannabinoid Content
Cannabinoid content on labels is checked for adherence to state mandated requirements as
follows:
Edible or Concentrate with Serving Designations
1) THC and CBD in milligrams per serving; 2) THC and CBD in milligrams per package; 3) list in
grams or milligrams sodium, sugar, carbohydrates, and fat; 4) if contains allergens, the word
"contains" and a list of allergens; 5) all ingredients in descending order of prominence by weight
or volume; 6) product expiration date, "use by" date, or "best by" date, if applicable; and 7) Unique
identifier (UID) or batch identification number.
Additional Requirements for Edibles
The words "cannabis infused" shall be included on all edibles. THC and CBD contents shall be
expressed in milligrams per serving and milligrams per package. No edible product shall contain
more than 10 milligrams THC per serving and 100 mg THC per package.
Additional Requirements for Topicals
A topical cannabis good for the adult -use market shall not contain more than 1,000 milligrams of
THC per package. A topical cannabis good for the medicinal -use market shall not contain more
than 2,000 milligrams of THC per package and the label shall include the wording "FOR
MEDICINAL USE ONLY" and is only sold to medical -use patients.
Additional Requirements for Concentrates
A cannabis good that contains more than 0.5% alcohol by volume shall be packaged in no more
than two fluid ounces and shall include a calibrated dropper.
CANNABIS PRODUCT COMPLAINTS AND CANNABIS PRODUCT RECALLS
All cannabis product complaints and cannabis recall notifications will be responded to within 24
hours of receipt. If the product complaint is related to retail operations or the surrounding
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community, the complaint will be handled by our Community Relations contact person. If the
complaint is related to a cannabis product or cannabis product recall, the retail manager or an
owner will respond to the issue.
CANNABIS PRODUCT COMPLAINTS
In the event of a serious adverse event or emergency, customers will be instructed to immediately
seek medical attention and/or call 911.
A manager shall use the Product Complaint Form to gather and document all complaints received.
If the complaint is related to a cannabis product, additional information is needed: 1) complainant's
name and contact information; 2) any illness or injury complained of; 3) detailed description of the
cannabis product complaint (i.e. allergic reaction, illness, object in the product, chemical taste, or
other dissatisfaction, etc.); 4) events and circumstances giving rise to the complaint, including
how the complainant stored and handled the cannabis product; 5) cannabis product name,
package type and size, UID and batch number, manufacturer name and license number (the
customer will be requested to bring in the packaging and/or take a photo of the package and send
it to us); 6) date and location of cannabis product acquisition; and 7) whether the complaint has
been referred to anyone else (i.e. public health, law enforcement, etc.).
Management personnel will investigate the complaint based on the information provided by the
customer. A thorough follow-up and review of the entire seed -to -sale tracking and notification of
appropriate and required regulatory agencies will be completed in a timely manner. A response
will be provided to the customer and depending on the outcome of the investigation, we will
segregate the batch and implement recall procedures if necessary. Outcomes of the cannabis
product complaint process may range from offering the customer to return the cannabis product
in exchange for a different product if the complaint is a customer satisfaction issue, to referral to
our internal legal department for follow-up.
CANNABIS PRODUCT RECALLS
Cannabis product recalls can be initiated by the DCC, San Diego County public health
department, or the licensed distributor or manufacturer in the supply chain. NCIG will immediately
comply with all cannabis product recall requests.
Factors that may necessitate a cannabis product recall include, but are not limited to:
Cannabis product Certificate of Analysis from the licensed laboratory is later determined
to be inaccurate;
Cannabis product is later determined to have packaging or labeling that is inaccurate;
Cannabis product has been misbranded;
Cannabis product batch has later become adulterated at some point in the supply chain;
After researching a customer complaint, it is determined that a cannabis product batch
should be recalled; and
A cannabis regulating authority requires a recall.
Recall Protocol
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1. Receive recall notice from DCC, other authority, or the licensed distributor or
manufacturer of the cannabis products;
2. Begin recall procedures within 24 hours of the recall being initiated;
3. Document the following recall information including:
a. Name of cannabis product;
b. Date and time of recall;
c. UID and/or batch number;
d. Other documentation indicating quantities or counts of the cannabis product
that the licensee has taken possession of;
4. Notify all customers via the following methods:
a. Post recall notice with all relevant cannabis product information and recall
instructions on our website, and use social media and other media as may be
determined to be effective;
b. Contact each customer who may have purchased the recalled cannabis
product via email and telephone to return unused product to the retailer and
provide written recall instructions in email and other methods when possible;
5. Quarantine recalled cannabis product;
6. Arrange for a licensed distributor to retrieve unsold recalled cannabis product;
7. Track-and-trace/METRc data entry and on -site documentation will follow the
requirements set forth in the state regulations.
RECORDS AND RECORD KEEPING
NCIG shall maintain its business records in an electronic format on the licensed premises.
Records will be stored in a manner that maintains their legibility and protects them from natural
or accidental destruction. All records will be made available to authorities upon request. If for
some reason the requested records cannot be reproduced "on the spot', NCIG will produce the
records within 24 hours after the receipt of the City's request.
NCIG will abide by the City's annual sales reporting requirements and the State's record keeping
requirements.
The following records shall be maintained:
➢ Financial records, bank statements, sales invoices, receipts, tax records, and all records
required by the California Department of Tax and Fee Administration;
➢ Personnel records including each employee's full name, social security or individual tax
payer identification number, date employment begins, and date of termination of
employment if applicable;
➢ Training records including full name of attendees, date of training, and training content;
➢ Contracts with other licensees regarding commercial cannabis activity;
➢ All local and state permits and licenses;
➢ Security records (except video surveillance recordings that are only stored for 90 days);
➢ Cannabis waste destruction and disposal;
➢ Track and trace data and documentation; and
➢ All other documents related to license ownership, employees, and commercial cannabis
activity.
Additional records that will be produced and stored include track -and -trace inventory
reconciliation reports and any discrepancy audits.
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COMPLIANCE WITH THE CITY'S ADDITIONAL RETAIL OPERATING
REQUIREMENTS
NCIG has reviewed and acknowledges the City's additional operating requirements for retailers
in Sections 9.60.250 & 9.60.260 of the National City Municipal Code. Our implemented operating
procedures and policies will assist NCIG in complying with these requirements. Specifically,
NCIG's retail operations will adhere to the following City retailer requirements:
• Customer Access. NCIG's retail team will verify the age of all individuals prior to allowing
entrance to the facility or provided cannabis products via retail delivery. Access to the retail
sales area, or to cannabis products via delivery, will be limited to individuals 21+ with valid
government identification, unless 18 and older with a valid physician's recommendation.
• Electronic "Buzz -In" System. A "buzz -in" electronic/mechanical entry system shall be utilized
to limit access to the retail sales floor and to separate it from the reception/lobby area.
Daily Product Limit. NCIG will have only that quantity of cannabis and cannabis products to
meet the daily demand readily available for sale on -site in the retail sales area. Additional
product will be stored in a secured, locked area to which customers, vendors, and visitors
shall not have access.
For our retail delivery operations, NCIG will only have on -site the quantity of cannabis and
cannabis products reasonably anticipated to meet the weekly demand we may need to be
readily available for sale.
• Restrooms. All restroom facilities shall remain locked and under the control of management.
• Limited Access Areas. NCIG shall establish limited -access areas and permit only authorized
individuals to enter the limited -access areas and maintain a log of those who are not
employees but have been granted access.
• Multiple Cannabis Activities. All cannabis activities approved and performed by NCIG will
occur on the same licensed premises.
• Operating Hours. NCIG's storefront and retail delivery hours of operations will be 9am to
9pm, seven days a week.
• Security. NCIG's Security Plan within this Application addresses how NCIG will comply with
Section 9.60.230(M). NCIG shall hire 2 security guards to monitor site activity, control
loitering and site access, and to serve as a visual deterrent to unlawful activities.
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DISTRIBUTION DAILY OPERATIONS
OVERVIEW OF PROPOSED DISTRIBUTION SERVICES
ARRANGEMENT FOR LAB TESTING
NCIG will only transport cannabis and cannabis products between properly licensed cannabis
businesses. Per DCC requirements, as a licensed cannabis distributor NCIG will be required to
arrange for third party laboratory testing of cannabis and cannabis products received from
licensed cultivators and manufacturers. NCIG will use the DCC's license search function on its
website to ensure that each laboratory, cultivator, manufacturer, and retailer it works with has a
valid and current license. All samples obtained by a laboratory for compliance testing will be
handled according to strict chain -of -custody protocols as required 4CCR §15706.
QUALITY ASSURANCE REVIEW
Once NCIG receives cannabis or cannabis products that have undergone and passed regulatory
compliance testing with results reported on a certificate of analysis from that licensed testing
laboratory, we will conduct a quality assurance review. This process will be overseen by our
Distribution Manager.
NCIG will check COAs for the following: (1) that the COA matches the batch UIDs from track -and -
trace; (2) that the date on the COA is less than 12 months old; (3) that the label on the cannabis
or cannabis products is consistent with the cannabinoid content reported on the COA ; (4) that
the packaging and labeling complies with all laws and regulations; (5) that the cannabis goods
have not exceeded their expiration or sell -by date if one is provided; (6) the weight or count of the
cannabis batch comports with that in the track -and -trace system; and (7) finally, that all events
prior to receipt of the COA has been entered into the track and trace system.
STORAGE OF CANNABIS AND CANNABIS GOODS
Our cannabis distribution area shall have adequate locked storage for after-hours storage of
cannabis using commercial -grade locks. Cannabis shall be stored at the distribution facility
property in secured rooms that are completely enclosed and have limited -access controls
including the use of digital keypads to track entry. Limited access will be enforced by owners,
management, and security personnel. Cannabis storage areas will have video surveillance inside
the room to record all activity and immediately outside the room to ensure all personnel entering
and exiting the storage rooms can be identified.
TRANSPORTATION OF CANNABIS AND CANNABIS GOODS
Our distribution associates will only transport orders processed at our facility between licensed
commercial cannabis businesses. All of our employees will be adequately trained on safety
measures during cannabis transport and regulatory requirements related to cannabis transport.
All of our vehicles will be equipped with secure product storage equipment and an alarm system.
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DISTRIBUTION DRIVERS
For our initial operations, NCIG intends to hire 3 distribution employees to fulfill our distribution
services. As we grow, NCIG will hire additional employees to support our expanded activity and
services.
Our distribution drivers will be subject to the same safety standards as our retail delivery drivers.
HOURS OF OPERATION
NCIG's proposed distribution hours of operation 10:OOam to 7:OOpm seven days a week.
DISTRIBUTION VEHICLES '& SECURE TRANSPORTATION PROCEDURES
NCIG will only hire distribution associates who are at least twenty-one (21) years of age, have a
valid California driver's license, have a good driving record, and who have received specific
training on the laws and regulations governing cannabis transportation.
During all transportation, distribution associates must carry the following, (1) a copy of NCIG's
current local and state licenses; (2) his or her driver's license; (3) his or her employee identification
badge; and (4) the shipping manifest, invoice, delivery request receipts, stop logs, and inventory
ledger for the transportation in which the employee is presently conducting.
NCIG's distribution associates are prohibited from carrying cannabis goods in an amount in
excess of that authorized by State law at any time. This shall lower the risk of harm towards
employees due to theft, and lower the risk of major cannabis or cannabis product loss.
All distribution vehicles will be enclosed and equipped with an alarm and GPS system to ensure
that all employees and cannabis and/or cannabis product are safe, and that the whereabouts of
our employees are known at all times. In addition, all of our vehicles used shall be: (1) insured at
or above the legal requirement in California, (ii) capable of securing (locking) the cannabis or
cannabis products during transportation, and (iii) capable of being temperature controlled if
perishable cannabis products are being transported.
Each vehicle shall be outfitted with an active alarm system. The alarm system will be activated by
the driver each time he/she leaves the vehicle. If a break-in is attempted, a loud strobe sound will
be emitted to warn of the intrusion. This alarm shall ensure that all necessary security and safety
measures are employed immediately, and all nearby individuals are warned of criminal or
suspicious activity.
All vehicles shall be outfitted with a dedicated Global Positioning System (GPS) device for
identifying the geographic location of the vehicle. At all times, NCIG will be able to identify the
location of any vehicle, as all employees will be provided a dedicated GPS solution that includes
real-time route management and remote visibility into the location of the vehicle. This will increase
the safety of all employees in case of emergency.
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All vehicles shall not display advertising or symbols visible from the exterior of the vehicle that
suggest that the driver or vehicle is used for the transportation of cannabis and cannabis products.
This measure is implemented to lower the risk of criminal activity directed towards our employees
and our product.
INVENTORY INTAKE PROCEDURES
NCIG's distribution inventory intake procedures are the same as the retail inventory intake
procedures previously described above under Retail Daily Operations — Location and Procedures
for Receiving Deliveries. The primary difference in procedure is where the physical inventory is
stored when received for distribution services rather than retail sale services.
Depending on the service requested, our Distribution Associates will store the received products
in the following rooms:
• Vault Room
• Tested Product Storage Room
• Untested Product Storage Room
• Batch Testing
Each of these rooms are designated as limited -access rooms. This means the rooms are
protected by additional security measures including active video surveillance and alarm system
measures and electronic card reader access for authorized employees and individuals only.
Security personnel are trained in their specific responsibilities during inventory intake to protect
the safety of our employees and cannabis products.
QUALITY CONTROL PROCEDURES (PACKAGING, LABELING, & TESTING)
NCIG's distribution team will follow the quality control procedures detailed above under the
following subsections:
- Quality Control
Enhanced Product Safety Review
- Cannabis Product Complaints and Cannabis Product Recalls
All distribution employees will be required to complete our extensive training program detailed
above which covers packaging requirements, labeling requirements, testing requirements,
personnel hygiene policies, and more to ensure our products maintain the highest of qualities
while in our possession.
COMPLIANCE WITH CITY'S DISTRIBUTION OPERATING REQUIREMENTS
NCIG has reviewed and acknowledges the City's additional operating requirements for
distributors in Section 9.60.290 of the National City Municipal Code. Our implemented operating
procedures and policies will assist NCIG in complying with these requirements. Specifically,
NCIG's distribution operations will adhere to the following City distribution requirements:
NCIG — BUSINESS PLAN Page 45
DocuSign Envelope ID: D1D5340C-722C-4576-8A3D-8822710C2865
• Non -Cannabis Goods Prohibition. NCIG's distribution team shall not store or distribute
non -cannabis goods or non -cannabis accessories that are to be sold to another party on
its licensed premises.
• Arrangement of Testing. After taking physical possession of a cannabis goods batch for
testing, NCIG's distribution team shall contact a testing laboratory and arrange for a
laboratory employee to come to the licensed premises to select a representative sample
for laboratory testing.
• Separate and Distinct Storage of Cannabis Goods. NCIG's distribution team shall ensure
that all cannabis goods are stored separately and distinctly from other cannabis goods on
our premises.
• Batch Size Compliance. NCIG's distribution team shall ensure that the batch size from
which the sample is taken meets the requirements of state law, specifically the testing
provisions within the California Code of Regulations.
• Observation of Sampling. An employee of the NCIG distribution team shall be physically
present to observe the laboratory employee obtain the sample of cannabis goods for
testing and shall ensure that the increments are taken from throughout the batch. The
sampling shall be video -recorded, and the recording kept available to state and local
authorities for a minimum of one hundred eighty days, pursuant to Title 4, Section 15305
of the California Code of Regulations.
• Tested Products for Retail Sale. NCIG's distribution team shall not transport cannabis or
cannabis products to a licensed retail facility until and unless it has verified that the
cannabis or cannabis products have been tested and certified by a testing lab as being in
compliance with state health and safety requirements pursuant to Title 4, Sections 15705,
15710, and 15714.
CONFORMANCE WITH STATE AND LOCAL LAW
Commercial cannabis is a heavily regulated industry whose businesses must strictly comply with
all state and local laws in order to maintain the safety of our customers, neighborhood, and
community. Our organization is qualified to meet the exacting standards required of commercial
cannabis businesses. Further, NCIG has retained the services of a cannabis compliance
consulting firm, ALG Strategies, to assist our organization in staying current with the fast -paced
developments in cannabis law in everything from state licensing requirements to day-to-day
operations.
COMPLIANCE WITH COMMERCIAL CANNABIS STATE LAWS
NCIG's operational procedures and policies are compliant with State laws and regulations. We
have experience developing and implementing processes that are consistent with the Medicinal
and Adult -Use Cannabis Regulation and Safety Act (MAUCRSA) codified as Division 10 of the
NCIG — BUSINESS PLAN
Page 46
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
California Business and Professions Code and the Department of Cannabis Control's medicinal
and adult -use commercial cannabis regulations codified as California Code of Regulations Title 4
Division 19.
COMPLIANCE WITH LOCAL LAWS
NCIG's proposed project, operational procedures, and policies are also compliant with the City of
National City's Municipal Code and Zoning Code. Our team has also reviewed the general
operating requirements imposed on all commercial cannabis businesses within the City listed
within Sections 9.60.200, 9.60.225, and 9.60.230 of the National City Municipal Code and will
adhere to all City cannabis business requirements:
[NOTE: These Standard Operating Procedures represent a sample of our full and complete
operating procedures in order to fit within the 200-page space limitations of the City of National
City cannabis business application process.]
NCIG -- BUSINESS PLAN Page 47
DocuSign Envelope ID: D1D5340C-722C-4576-8A3D-8822710C2865
Exhibit C
SECTION C: SAFETY PLAN
PREPARED BY CALIFORNIA PROFESSIONAL FIRE PREVENTION AND
SUPPRESSION CONSULTANT
NCIG has engaged licensed safety and fire protection consultants, Klausbruckner and
Associates ("Klausbruckner"), to prepare this Safety Plan. Klausbruckner provides unrivaled
expertise and service nationwide in the areas of code analysis, hazardous materials/dangerous
goods, fire & smoke spread, protection systems, exposures, and egress. A full overview of the
firm's licenses, skills, and expertise can be found here:
http://www. klausbruckner_com/CompanvProfile. html
For this Safety Plan, Klausbruckner prepared two expert reports, a Fire Safety Report and an
Emergency and Evacuation Report, for the proposed cannabis distribution and retail accessory
facility.
A proposed exit analysis floor plan and letter of intent by Specialized Waste Solutions for our
organic and hazardous waste needs (if any) are attached to this Safety Plan.
Note that this Safety Plan is an example and does not include all elements of our typical safety
plans and procedures due to the page limitations of the Commercial Cannabis Business
application process.
NCIG — Safety Plan Page 1
DocuSign Envelope ID: D1D5340C-722C-4576-8A3D-8822710C2865
KLAUSBRUCKNER
2495 Truxtun Road, Suite 205
AND ASSOCIATES San Diego, CA92106
Tel: (619) 677-2004
Fax: (619) 677-2444
NC Investment Group,
LLC
316 W. 30TH STREET
NATIONAL CITY, CA 91950
Section C: Safety Plan
Rev 2.1
April 5, 2022
DISCLAIMER
This report is the property of Klausbruckner & Associates, Inc. and was prepared exclusively for use by NC
Investment Group, LLC (alternatively known as "the owners" or "the business owners" throughout this
report) for the Phase I Fire Code Summary Report. NC Investment Group, LLC conditions and operations
addressed herein are based on information provided for the report by NC Investment Group, LLC.
Discrepancies between the information presented herein and actual conditions and conditions presented on
plans are the sole responsibility of NC Investment Group, LLC. Verification of compliance with the Code
requirements and provisions addressed herein is outside the scope of this report. Copies of this report
retained by NC Investment Group, LLC shall be utilized only by NC Investment Group, LLC for the
conditions and requirements addressed in this report.
This report shall not be used as, or in lieu of, construction documents or plans for this project or any other
project or for any other purpose or conditions not specifically addressed in this report. This is not intended
as a complete code compliances and is only specific to a Phase I summary list of existing and proposed fire
code recommendations.
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
The following is a Phase I summary of the fire protection requirements and additional proposed recommendations
for a new Cannabis light assembly with ancillary retail dispensary facility, namely NC Investment Group, LLC.
). Final plans and reports will be submitted to the city Building and Fire Departments when the application for
business license has been approved and building permit applications/plans are submitted.
Project Description
The proposed project is a 9,620 square foot corrugated metal building on an existing multiple building site located
at the above address. The ancillary retail includes approximately 3,818.36 square feet, less than 40% of the gross
floor area. The building is a one-story building and assumed to be of Type VB Construction. The proposed
occupancy is classified as a non -separated use M, F-1, and S-1, as allowed by CBC Section 508.3. There are no
proposed cultivation, or extraction. Other than light assembly/re-packaging of plant parts (e.g. flowers) and hash,
there is no processing/manufacturing and/or grinding of the leaf/plants within this facility.
The suite will not be used for the following Cannabis operations:
• Extraction
• Cultivation
• Processing of Plants (except re -packaging)
It must also be noted that there is no proposed storage or use of the following materials within the light
manufacturing/packaging, retail, or dispensary:
• Carbon Dioxide gases
• Compressed gases
• Combustible Fibers
• Flammable and/or combustible liquids
• Fumigation and Insecticidal Fogging used for cultivation
• Hazardous materials of any kind, except standard cleaning materials/janitorial products used within a typical
retail store
• High Piled Storage (storage limited to 5 feet in height in M-Occupancy/retail and 10 feet in height for storage
of leaves in S-1/Storage/Processing)
• Liquid petroleum gas (other than natural gas piped to fixed appliances such as hot water stoves, etc. if meeting
California Fuel Gas Code and California Mechanical Code). There is no gas monitoring equipment as there
are no extraction processing (e.g. butane extraction) or growing (e.g. using CO2 gas) occurring.
Fire Prevention Measures
Occupancy Separation: Per CBC Table 508.4, no occupancy separation is required between these occupancies
if addressed as non -separated use, as allowed by CBC Section 508.3. The proposed building is a standalone
building full occupied by NC Investment Group, LLC. Therefore, 1-hour fire barrier walls between NC
Investment Group, LLC and the adjacent suites do not apply. Any unpeiiuitted buildings/structures will be
demolished and removed from the site.
Operational Permits: NC Investment Group, LLC agrees to obtain any operational permits required by the
authority having jurisdiction.
NOTE: Materials Safety Data Sheets/Safety Data Sheets will be on the property and made easily accessible
prior to an occupancy permit. Containers and/or packages related to hazardous materials shall be properly
labeled and warning signage shall be properly displayed and easily visible.
Rev 2.1— NC Investment Group, LLC
Page 1
Section C: Safety Plan
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316 W. 30t Street, National City, CA 91950
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DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
Locks and Key Box: The installation of a key box in an approved location, which will permit timely access to
the facility in the event of an emergency is recommended and proposed. A key box shall be installed in
accordance with CFC Section 506.1. The key box shall contain keys or devices to allow for entry through the
fire depaitu lent access doors. Per CFC 506.1, Where access to or within a structure or an area is restricted
because of secured openings or where immediate access is necessary for life-saving or fire -fighting purposes,
the fire code official is authorized to require a key box to be installed in an approved location. The key box shall
be of an approved type listed in accordance with UL 1037, and shall contain keys to gain necessary access as
required by the fire code official. An approved lock shall be installed on gates or similar barriers where required
by the fire code official. The operator of the building shall immediately notify the fire code official and provide
the new key where a lock is changed or rekeyed. The key to such lock shall be secured in the key box.
Classified Electrical: Not applicable as hazardous materials are not proposed. Ordinary electrical meeting
standard retail in accordance with applicable sections of the CEC (California Electrical Code), CBC (California
Building Code), and CFC (California Fire Code) is appropriate.
Premise Identification: All buildings are required to be provided with address identification. This address
must be visible from the street or road fronting the property and contrasting with the background of the
building. Signage that identifies the name of the business is not regulated by fire code, but may be regulated by
City of National City.
Fire Department Access: Per CFC 503.1.1, approved fire apparatus access roads shall be provided within 150
feet of all portions of the facility and all portions of the exterior walls of the first story of the building as
measured by an approved route around the exterior of the building or facility.
Per CFC 503.2, fire apparatus access roads shall be installed and arranged in accordance with the following:
• Dimensions: Fire apparatus access roads shall have an unobstructed width of not less than 20 feet,
exclusive of shoulders, except for approved security gates in accordance with Section 503.6, and an
unobstructed vertical clearance of not less than 13 feet 6 inches.
• Authority: The fire code official shall have the authority to require or permit modifications to the required
access widths where they are inadequate for fire or rescue operations, or where necessary to meet the
public safety objectives of the jurisdiction.
• Surface: Fire apparatus access roads shall be designed and maintained to support the imposed loads of
fire apparatus and shall be surfaced so as to provide all-weather driving capabilities.
• Turning Radius: The required turning radius of a fire apparatus access road shall be determined by the
fire code official.
• Dead Ends: Dead-end fire apparatus access roads in excess of 150 feet in length shall be provided with
an approved area for turning around fire apparatus.
• Bridges and Elevated Surfaces: See CFC Section 503.2.6
• Grade: The grade of the fire apparatus access road shall be within the limits established by the fire code
official based on the fire department's apparatus.
• Angle of Approach and Departure: The angle of approach and departure for fire apparatus access roads
shall be within the limits established by the fire code official based on the fire department's apparatus.
Access roads are existing and have been previously approved as part of the shell building. There are no proposed
changes to the fire department access roads. Any unpermitted buildings/structures will be demolished and
removed from the site, thereby providing better fire department access.
Rev 2.1—NCInvestment Group, LLC
Page 2
Section C: Safety Plan
KLAL$B LJCK,�NER
316 W. 30t Street, National City, CA 91950
A p aS,��FAr�S
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
Smoking & Sources of Ignition: Smoking shall be prohibited. Approved "NO SMOKING" signs shall be
conspicuously posted. Open flames and ignition sources of any kind shall be prohibited within the proposed
facility.
Housekeeping and Maintenance: Per CFC Sections 901.6, the following are general maintenance and safety
requirements:
• Fire Protection Systems. Fire protection systems shall be maintained in an operative condition at all times
and shall be replaced or repaired where defective. Additionally, any existing non -required fire protection
systems (i.e. extinguishing systems, smoke and heat vents, etc.) shall be inspected, tested and maintained or
removed.
• Path of Egress Travel: All egress components and paths of egress travel shall be maintained and
unobstructed.
Fire Suppression Measures
Automatic Fire Sprinkler System: The building is unsprinklered. Due to the limited size of the building, an
automatic fire sprinkler system is not required for the type of construction, square footage and occupancy. See
architectural plans for allowable area calculation for an unsprinklerd building. Protection of the building will be
accomplished using a combination of detection and manual fire department suppression.
Alarm Systems
Horns & Strobes: Recommended for the retail/sales portion of the facility. Horns and strobes to be designed
by the architect of records as part of the TI (tenant improvement) plans submittal.
Manual Pull Station(s): At least one manual pull station is recommended within the retail portion of the
facility.
Additionally, as mentioned previously, there is no gas monitoring equipment as there are no extraction
processing (e.g. butane extraction) or growing (e.g. using CO2 gas) occurring. Horns and strobes will be
provided for the retaillsales portion of the facility.
Fire Extinguisher Locations
Portable/Handheld Fire Extinguishers: Per CFC Table 906, portable fire extinguishers shall be installed in
new and existing Group F-1, M, and S occupancies
Per CFC Table 906.3(1) & 906.3(2), the following is the proposed fire extinguisher type and layout: 2-A:20-B:C
@ Travel Distance < 50 Feet (i.e. maximum separation of 100 ft)
The owners agree to comply with the requirements for fire extinguishers. One extinguisher may provide coverage
to a maximum of 3000 ft2. Fire extinguisher types and locations will be provided by the owners or fire
extinguisher vendor and approved by the fire department.
Portable fire extinguishers shall be located in conspicuous locations where they will have ready access and be
immediately available for use. These locations shall be along normal paths of travel, unless the fire code official
determines that the hazard posed indicated the need for placement away from normal paths of travel. Portable
fire extinguishers shall not be obstructed or obscured from view. In rooms or areas in which visual obstruction
Rev 2.1— NC Investment Group, LLC
Page 3
Section C: Safety Plan,,,I;111:1)I(1-A17:8R
JCI<NER
316 W. 30t Street, National City, CA 91950
.aria �ssncvar�s
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
cannot be completely avoided, means shall be provided to indicate the location of extinguishers. Proper
maintenance of the installed portable fire extinguishers is the responsibility of the occupant or property owner.
A Phase I fire extinguisher layout has been provided by TECHNE Design as part of the submittal package,
pending fire department submittal and approval. Any revisions to the fire extinguisher layout will be corrected
based on fire plan review comments at the time of the building construction plan submittal package for the tenant
improvement.
Evacuation Routes and Evacuation Plan
Evacuation Plan: A Phase I evacuation plan has been prepared for NC Investment Group, LLC (see Appendix
A), pending fire department review.
Exits, Exit Signage, Egress, Aisles: Plans have been provided by the architect of record (TECHNE Design)
showing compliance with CBC Chapter 10 as part of the Fire and Building Plan submittals. The following general
egress regulations apply to S, F-1, and M Occupancies for an unsprinklered building:
F-1 Occupancy
• Per CBC 1005.3.2, egress width components other than stairways shall be 0.2 inch/occupant.
• Per CBC Table 1006.2.1, spaces with only one exit or exit access doorway shall have a maximum
occupancy load of 49 and the common path of egress travel shall not exceed 75 feet.
• Per CBC Table 1017.2, exit access travel distance shall not exceed 200 feet.
• Per CBC 1020.4 Exception 2, dead ends through common path of egress shall not exceed 20 feet.
M Occupancy
• Per CBC 1005.3.2, egress width components other than stairways shall be 0.2 inch/occupant.
• Per CBC Table 1006.2.1, spaces with only one exit or exit access doorway shall have a maximum
occupancy load of 49 and the common path of egress travel shall not exceed 75 feet.
• Per CBC Table 1017.2, exit access travel distance shall not exceed 200 feet.
• Per CBC 1020.4 Exception 2, dead ends through common path of egress shall not exceed 20 feet.
S-1 Occupancy
• Per CBC 1005.3.2, egress width components other than stairways shall be 0.2 inch/occupant.
• Per CBC Table 1006.2.1, spaces with only one exit or exit access doorway shall have a maximum
occupancy load of 29 and the common path of egress travel shall not exceed:
o 100 feet if occupant load is <30.
o 75 feet if occupant load is >30.
• Per CBC Table 1017.2.2, exit access travel distance shall not exceed 200 feet.
• Per CBC 1020.4 Exception 2, dead ends through common path of egress shall not exceed 20 feet.
A complete exit analysis is outside the scope of this report. A complete exit analysis shall be provided by the
architect of record part of the TI (tenant improvements) submittal package. The package will include (but not
limited to) compliance with Chapter 10 of the California Building Code for any delayed egress devices, sensor
and door hardware release of electrically locked egress doors, etc.
Rev 2.1— NC Investment Group, LLC
Page 4
Section C: Safety Plan
kN KLAUSEU UCKNER
316 W. 30t Street, National City, CA 91950
AND AS.Yn41A!E5
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
Accident and Incident Reporting Procedures
General Guidelines: The accident reporting company policy in this section is designed to outline the
purpose and procedure for reporting any on-the-job accidents. NC Investment Group is committed to enforce all
local, state and federal fire, health, and safety guidelines to avoid such occurrences and expects employees to
comply. However, accidents are sometimes inevitable. The provisions in this section is provided to ensure all
accidents are reported in a timely manner so they can be investigated properly and preventative measures can be
reviewed and reinforced. This accident report policy is applicable to all employees and independent
contractors.
On-the-job accidents that must be reported including, but not limited to, any incidents that may cause minor or
severe injuries or incidents that are results of negligence or inadequate safety precautions. The victims may be
employees who were injured while performing their duties or other people, including customers and visitors,
that were on NC Investment Group LLC premises or vehicles.
Accidents must be reported as soon as possible to help expedite investigation and increase likelihood of any and
all important findings. The sooner the cause or details of the accident are identified, the sooner the NC
Investment Group LLC can establish preventative measures for the future.
Reporting Under This Policy: The NC Investment Group LLC encourages employees to report all accidents
no matter how minor Employees are not obligated to report accidents that involve very minor injuries like
small cuts, non -extensive bruises etc. and would not normally require any action on behalf of the NC
Investment Group LLC (e.g. the breaking of a drinking glass). However, accidents that involve (or could have
involved) more severe injuries and require investigation and action from the NC Investment Group LLC will be
required to be dutifully reported. Employees will be required to report any of the following incidents:
• Any other injury that requires hospitalization or medical care
• Contamination from hazardous substances or transmission of diseases
• Poisoning
• Harm to the nervous system or loss of consciousness through electrocution, hypothermia etc.
• Blows or injuries to the spine, back and ribs
• Damage to the skin (e.g. extensive burns, bruises or cuts)
• Incapacitation or dislocation of limbs that hinder functionality and movement (including paralysis and
amputation)
• Damage to any of the senses (e.g. partial or complete loss of hearing, sight etc.)
• Damage to the head, skull and face
• Fatalities
Employees will be required to report the above -mentioned incidents immediately, especially when an employee
needs medical coverage.
Employees will also be required to report occurrences that may not have involved injuries or victims but could
be potentially dangerous in that respect if repeated. These include, but are not limited to:
• Slippery surfaces
• Inadequate insulation of circuits
• Breaking of window glasses or frames
• Explosions
Rev 2.1 —NC Investment Group, LLC
Section C. Safety Plan
KLAIJ;[3atJC?(PJFR
Page 5
316 W. 30t Street, National City, CA 91950
1
A saclnres
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
• Water or gas leaks
• Collapses of walls, ceilings etc.
Processes & Procedures: When an employee witnesses or is involved in an incident NC Investment Group
LLC will require that they must report it to their immediate supervisor, HR department (personally, in writing
or by phone if the accident occurred remotely) or through an online system if applicable, within one week. If the
employee anticipates an accident due to perceived negligence or inadequate safety, they will be required to
notify their supervisors or HR department as soon as possible so the accident can be prevented.
Depending on the incident, official forms will be required to be completed and submitted.
The accident and any sustained injuries must be recorded to an accident database or file.
The officials responsible will be required to initiate an investigation or request an investigation from authorities
if appropriate.
The employee who reported the accident will be required to cooperate if called in for questioning to provide
details needed. As a general rule, the employee will be required to provide information in the incident report as
accurately as possible on the following:
• The people involved or injured
• The place of the accident
• Their position or involvement in the accident
• The date and time of the accident
• Their actions immediately after the accident
Disciplinary Action and Consequences: NC Investment Group LLC places great importance in this policy. All
employees are required to comply. Any employee that is discovered to have been aware ofa serious accident and
failed to report it will face appropriate disciplinary consequences. When employees are the cause of an accident,
they will be required to report it immediately to minimize legal repercussions.
Hazardous Waste Management Location and Procedures
As cannabis distributor and retailer, it is anticipated that cannabis waste at the facility will be minimal.
Circumstances under, which cannabis goods will be destroyed are as follows:
• If the cannabis goods went unused past the use by or sell by date;
• If quality control assessments determine that the cannabis goods are unusable i.e. adulterated, which includes
inaccurate labeling;
• If the cannabis goods are subject to recall; or
■ If the cannabis goods have been returned by NC Investment Group customers.
The following infottuation on waste management has been provided by NC Investment Group:
"A NC Investment Group Manager along with at least one other employee acting as witness, will be present prior
to the destruction of any cannabis goods. To be rendered as cannabis waste for proper disposal, cannabis goods
shall first be destroyed on the licensed premises and recorded on video surveillance in an area designated for
such activity to limit cross- contamination. This includes, at a minimum, removing or separating the cannabis
goods from any packaging or container and rendering it unrecognizable and unusable. Cannabis goods will be
Rev 2.1— NC Investment Group, LLC
Page
SectionC.• Safety Plan
KGA,13,X1r,E<NErR
316 W. 30t Street, National City, CA 91950
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
ground up and then mixed into a 50/50 bokashi mix in order to render the cannabis and cannabis products as
unrecognizable and unusable.
Once the rendering of cannabis waste is complete, a NC Investment Group employee will self- haul the waste to
the local waste facility set up to handle such waste. The employee will obtain a certified weight ticket, which will
then be kept on file at the facility in accordance with NC Investment Group's recordkeeping procedures, If the
quantity of waste increases in the future to a level that management is not comfortable internally handling, NC
Investment Group has identified Cannabis Waste Solutions to contract as a certified third party waste hauler.
Cannabis Waste Storage and Security Measures: It is the duty of NC Investment Group to ensure that all waste
is handled in a manner that is safe and environmentally conscious and complies with local and state regulations.
Improper cannabis waste management can impose risk such as theft/vandalism of trash enclosures, disposal of
harmful chemicals into traditional waste bins, and danger to the safety of others from exposure to hazardous
cannabis by products. An appropriate waste management plan (WMP) ensures that NC Investment Group will
operate under safe conditions, not only mitigating employee and public risk, but also allowing NC Investment
Group to perform with respect to the local and global environment.
NC Investment Group is proactively taking the necessary steps to set the highest industry standard, by ensuring
compliance to cannabis waste disposal requirements set forth by the Department of Cannabis Control and the
City of National City.
NC Investment Group will secure storage receptacles for its cannabis waste within its facility that are separate
and distinct from other cannabis goods. The "secured waste receptacle" is located in the back of house area,
which is accessible only by authorized personnel and the third party waste hauler, should one be used in the
future. This will protect against diversion of cannabis from the waste receptacles. Daily security checks will
ensure the waste area remains clean and bins are properly labeled. The designated NC Investment Group
employee will remove all goods from packaging and render the cannabis goods unrecognizable and unusable in
full view of NC Investment Group's surveillance cameras.
Waste Record Keeping NC Investment Group's operations will keep accurate records of all actions related to
cannabis product recalls, quarantines and waste destruction and disposal of recalled and/or quarantined
cannabis product. NC Investment Group will keep a record of the date of destruction and how much was destroyed
and keep a record of the date of disposal of cannabis waste. NC Investment Group will maintain the records for
destruction and disposal for a 7-year period.
If cannabis goods are being destroyed or disposed of we will record in the track and trace system the following:
• The name of the employee performing the destruction or disposal;
• The reason for destruction and/ or disposal;
• The entity disposing of the cannabis waste; and
• A description for the destruction/disposal, including, but not limited to, (i) spoilage or fouling of the cannabis
goods or (ii) any event resulting in damage, exposure or compromise of the cannabis goods."
This summary requirement is a Phase I analysis only. Final plans and reports will be submitted to the city Building
and Fire Depaitinents when the application for business license has been approved and building peunit
applications/plans are submitted.
Rev 2.1—NC Investment Group, LLC
Page 7
Section C: Safety Plan
x�ausaaQcxr Ea
316 W 30t Street, National City, CA 91950"�
ASSOCIATES
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
By way of my signature, NC Investment Group, LLC agrees to meet the storage conditions required and specified
in this letter.
Ray Ibrahim (Cell 619-857-3001)
Prepared By:
Elley Klausbruckner, FPE, PE License # 1403
04/05/2022
Date
Rev 2.1— NC Investment Group, LLC
Page 8
SectionC: Safety Plan
; KLAti.58>t..CX.NER
316 W. 30t Street, National City, CA 91950
ANDay '._ ,. ATE .
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
APPENDIX A
EMERGENCY EVACUATION REPORT
Rev 2.1 — NC Investment Group, LLC
Page 4
SectionC: Safety Plan
KLAUSGRUEf<rlcR
316 kV30t Street, National City, CA 91950
AND ASSOCIATES
DocuSign Envelope ID: D1D5340C-722C-4576-8A3D-8822710C2865
KLAUSBRUCKNER
2495 Truxtun Road, Suite 205
AND ASSOCIATES San Diego, CA92106
Tel: (619) 677-2004
Fax: (619) 677-2444
NC Investment Group,
LLC
316 W. 30' STREET
NATIONAL CITY, CA 91950
Section C: (Appendix A) - Emergency Evacuation
Report
Rev 2.1
April 5, 2022
DISCLAIMER
This report is the property of Klausbruckner & Associates, Inc. and was prepared exclusively for use by NC
Investment Group, LLC (alternatively known as "the owners" or "the business owners" throughout this
report) for their Phase I emergency evacuation plan. NC Investment Group, LLC conditions and operations
addressed herein are based on information provided for the report by NC Investment Group, LLC.
Discrepancies between the infomiation presented herein and actual conditions and conditions presented on
plans are the sole responsibility of NC Investment Group, LLC. Verification of compliance with the Code
requirements and provisions addressed herein is outside the scope of this report. Copies of this report
retained by NC Investment Group, LLC shall be utilized only by NC Investment Group, LLC for the
conditions and requirements addressed in this report.
This report shall not be used as, or in lieu of, construction documents or plans for this project or any other
project or for any other purpose or conditions not specifically addressed in this report. This is not intended
as a complete code compliances and is only specific to an evacuation plan.
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
Table of Contents
1. INTRODUCTION 1
2. EVACUATION DRILL POLICY 1
3. EMERGENCY REPORTING PROCEDURE (PROVIDE TO ALL EMPLOYEES) 1
4. EMERGENCY PHONE NUMBERS 2
5. CONTACT PERSONNEL 2
6. EVACUATION COORDINATOR RESPONSIBILITIES 3
7. CONTACT PERSONNEL RESPONSIBILITIES 3
8. EVACUATION COORDINATOR'S EVACUATION PROCEDURE 3
9. EVACUATION PROCEDURES FOR INDIVIDUALS WITH A DISABILITY 4
9.1 EVACUATION PROCEDURES FOR INDIVIDTJALS WITH A DISABILITY 4
9.2 PRIVACY 4
9.3 BUDDY SYSTEM OPTION 4
9.4 EVACUATION OPTIONS DURING AN EMERGENCY 4
9.5 DISABILITY GUIDELINES 5
9.6 BUDDY LIST 5
10. EMPLOYEE RESPONSIBILITIES 5
10.1 ASSEMBLY POINT/AREA PLAN 6
11. EMERGENCY/EVACUATION FLOOR PLAN & ASSEMBLY POINT/AREA PLAN 7
12. CONCLUSION 7
13. ATTACHMENT A: SAMPLE EMERGENCY EVACUATION SPECIAL NEEDS
NOTIFICATION 8
Rev 2.1—NC Investment Group, LLC
Section C (App, A) - Emergency Evacuation Plan
316 W. 30th Street, National City, CA
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AND ASSOCIATES
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1. Introduction
Per the requirement for City of National City an Emergency Evacuation Plan is required in buildings used for
retail/sales of marijuana, leaves and extracted and/or blended materials.
During certain emergency conditions, it may be necessary to evacuate a building. Examples of such occasions
include but not limited to: smoke/fire, gas leak, bomb threat. Pre -planning and rehearsals are effective ways to
ensure that building occupants recognize the evacuation alarm and know how to respond. Practicing an evacuation
during a non -emergency drill provides training that will be valuable in an emergency situation.
2. Evacuation Drill Policy
1. Evacuation drills shall be conducted at least once every four months at unexpected times and under varying
conditions to simulate the unusual conditions that occur should an evacuation be necessary. These drills
may be obstructed, (having various means of exit made temporarily unavailable) in order to familiarize
occupants with secondary routes of evacuation, or unobstructed.
2. Evacuation drills will be scheduled by the business owner or a person designated by the owner trained for
this procedure, at least one week prior to the drill. The business owner or his designee will be considered
as the "The Evacuation Coordinator."
3. Evacuation drills shall involve all occupants. Everyone shall leave the building when the fire alarm sounds.
Exceptions are strongly discouraged. It may be advisable to notify anyone needing special assistance prior
to planned evacuation drills.
4. In the conduct of drills, emphasis shall be placed upon orderly evacuation under proper discipline rather
than upon speed. All staff including the Evacuation Coordinator is expected to perform his or her assigned
duties as if in an actual emergency situation.
5. Provisions should be made for timing and evaluating the orderliness of each drill. The Evacuation
Coordinator will provide Evacuation Drill Report forms.
3. Emergency Reporting Procedure (Provide to ALL
Employees)
If the need for an Evacuation is discovered:
1. Activate manual alarm pull station if possible
2. If you are not in immediate danger, notify the Emergency Operator (911) and provide the following:
a. Your Name
b. Building Address Including Suite Number
c. Size and Type of Emergency
d. Any Additional Information Requested by the Operator
3. If you are not in immediate danger, also notify the Evacuation Coordinator. Your Evacuation Coordinator is
(the General Manager on Duty).
4. If you are trained in the proper use of portable fire extinguishers and are not in immediate danger, you may
attempt to fight the fire if the fire only involves ordinary combustibles. Do not attempt to fight the fire using
handheld extinguishers if hazardous materials are present in the room. Do not place yourself or others in
unnecessary danger.
5. All employees should be trained to understand that silencing the alarm is NOT a signal for personnel to re-
enter
Rev 2.1 — NC Investment Group, LLC
Section C (App. A) - Emergency Evacuation Plan
316 IV. 306 Street, National City, CA
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If you are trapped in the building and cannot find an escape route, call Emergency Operator (911) and
give your exact location.
4. Emergency Phone Numbers
Post this page near Entrances to the building. During employee drills and training make employees aware of this
page and location of posted:
Name
Phone#
Emergency Operator (All life -threatening Emergencies) 911
a. Your Name
b. Building Address Including Suite Number
c. Size and Type of Emergency
d. Any Additional Information Requested by the Operator
Area Maintenance (Building Problems and Repair) (TBD)
After-hours Maintenance (TBD)
Environmental Health & Safety Dept. (Chemical spills/problems) (TBD)
After normal work hours. (TBD)
Building Evacuation Coordinator (TBD) (TBD)
National City Police 911
National City Police Department (Non -Emergency) (619) 336-4411
National City Fire Department 911
National City Fire Department (Non -Emergency) (619) 336-4550
5. Contact Personnel
Name
Office Location
Office Phone
Cellular
Title
Ray Ibrahim
316 W. 30thStreet,
National City, CA
619-857-3001
619-857-3001
Owner
TBD (Store
Manager)
316 W. 30t1 Street,
National City, CA
TBD
TBD
Evacuation Coordinator
TBD
316 W. 30th
National City, CA
TBD TBD
TBD
Alternative to Evacuation
Coordinator
TBD
316 W. 30th Street
National City, CA
TBD
TBD
Employee #1 Responsible
for Evacuation of
Customers
TBD
316 W. 30th Street
National City, CA
TBD
TBD
Employee #2 Responsible
for Evacuation of
Customers
Rev 2.1— NC Investment Group, LLC
Section C (App. A) - Emergency Evacuation Plan
316 W. 306 Street, National City, C4
K LA USER UCK NER
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6. Evacuation Coordinator Responsibilities
The following are the Evacuation Coordinators Responsibilities:
1. Serve as a liaison with emergency responders (e.g., fire department, police department, ambulance,
Environmental Health & Safety).
2. Meet responders upon their arrival and convey specific information about hazards in the building,
access, locations of persons with special needs, etc.
3. Maintain communication with Contact Personnel regarding the status of the emergency.
4. Upon receiving clearance from the emergency responders, notify Contact Personnel and building
occupants that the building is safe for re-entry.
5. Keep and update Evacuation Plan, Contact Persons and Numbers, and Floor Diagrams.
6. Conduct and/or assist in Fire Drills,
7. Assign area to assemble after evacuation.
8. Assist in training and/or scheduling of training the building occupants in emergency procedures.
7. Contact Personnel Responsibilities
1. Routinely inspect for possible fire hazards on site and report to the Evacuation Coordinator.
2. Know locations of and how to use all fire protection equipment in the building suite.
3. Ensure that occupants (including new employees) are familiar with evacuation procedures.
4, Understand the responsibilities on evacuating customers.
5. Be aware of building occupants with special needs who may need assistance during an evacuation (e,g.,
hearing- or sight -impaired, on crutches, in a wheelchair),
6. As an integral part of the building's emergency communication network, Contact Personnel are to ensure
that occupants in the building are aware of an emergency and the need to evacuate.
7. Call 911 whenever a situation could pose immediate danger to people, property, or processes in the
building.
8. Assist in the evacuation process as indicated in the Evacuation Coordinator's Evacuation Procedure.
9. Proceed to your assigned entrance until further notice from the Evacuation Coordinator. Do not allow
personnel to re-enter the building until you have been notified to do so. Emergency personnel often silence
the alarm in order to communicate with each other. ALL employees should be trained to understand that
silencing the alarm is NOT a signal for personnel to re-enter.
8. Evacuation Coordinator's Evacuation Procedure
1. Notify the Emergency Operator (911) if you have information related to the emergency. Be ready to
provide:
a. Your Name
b. Building Address Including Suite Number
c. Size and Type of Emergency
d. Any Additional Information Requested by the Operator
2. Alert all occupants in the building. Check remote areas such as restrooms and storerooms and close doors
if possible on your way out. Maintain orderly evacuation of occupants.
3. Ensure that all personnel with special needs are alerted and that someone is assisting with their
evacuation.
4. If you are not in immediate danger:
Rev 2.1—NCInvestment Group, LLC
Section C (App. A) - Emergency Evacuation Plan
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• You may attempt to determine which smoke detector or pull station was activated.
• If you are trained in the proper use of portable fire extinguishers, you may attempt to fight or contain
a fire. Do not place yourself or others in unnecessary danger.
5. Evacuate the building and report pertinent information to the emergency responders (e.g., evacuation
status, location of persons with special needs, type and location of emergency).
6. Do not allow personnel to re-enter the building until you have been notified to do so. Emergency
personnel often silence the alarm in order to communicate with each other. ALL employees should be
trained to understand that silencing the alarm is NOT a signal for personnel to re-enter.
9. Evacuation Procedures for Individuals with a
Disability
9.1 Evacuation Procedures for Individuals with a Disability
Persons with a disability or medical condition may not be able to evacuate without special assistance. Employees
should inform their Contact Personnel of any special needs that may be necessary during an emergency situation
using the Emergency Evacuation Special Needs Notification (See Attachment A). The Contact Personnel will
communicate the special needs with the Evacuation Coordinator and other emergency personnel as appropriate.
The Contact Personnel should ensure that individuals with disabilities are provided with assistance during an
emergency situation.
9.2 Privacy
The ADA and the Rehabilitation Act strictly limit how, when, and what type of information can be gathered about
an employee's medical condition, even for purposes of emergency preparedness. Additionally, the Rehabilitation
Act, Federal Privacy Act and the Information Practices Act of 1977 require that medical information be kept in a
file separate from the employee's personnel file.
NC Investment Group, LLC agrees to comply with all Federal and State Laws related to Privacy.
9.3 Buddy System Option
Buddy System Option
Make use of a "Buddy System." Individuals with a disability should inform colleagues of any special assistance
that may be required in the event of an emergency or emergency evacuation (i.e, hearing the alaiiii, guidance
during the alarm, etc.).
When there has been notification of an emergency situation, the "Buddy" will make sure of the location of the
person with a disability, then go outside and inform emergency personnel that a person in that location needs
assistance in leaving the building. Emergency personnel will then enter the building and evacuate that person.
9.4 Evacuation Options During an Emergency
Use of the "Buddy System" along with the following evacuation options will help to assure the prompt evacuation
of any person with a disability.
• Horizontal Evacuation
Move away from the area of imminent danger to a safe distance (i.e. another wing, adjoining building,
opposite end of corridor, outside to ground level).
Rev 2.1 — NC Investment Group, LLC
Section C (App. A) - Emergency Evacuation Plan
316 W. 30th Street, National City, CA
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• Stay in Place
Unless danger is imminent, remain in a room with an exterior window and a telephone closing the door if
possible. Dial 911 (if this hasn't been done). The operator will give emergency personnel the location of
the disabled person who needs evacuation assistance. If phone lines fail, the disabled person can signal
from the window by waving a cloth or other visible object.
9.5 Disability Guidelines
Prior planning and practicing of emergency evacuation routes are important to ensure a safe evacuation
• Mobility Impaired (Wheelchair & Non -Wheelchair)
Persons using wheelchairs should stay in place or move to an area of refuge created by NC Investment
Group, LLC with their "buddy" when they are notified of an emergency situation. If a building evacuation
is required, the Mobility Impaired individual, with the assistance from their "buddy" should then proceed
to the evacuation assembly point outside the building and tell emergency personnel the location of the
person with the disability. If the person with the disability is alone, the person should dial 911 and tell the
emergency operator their location and that they need assistance.
• Visually Impaired
The proposed M Occupancy (retail sales) will be equipped with fire horns/strobes that sound the alarm
and/or flash strobe lights. The horn is for sight -impaired persons. Most people with a visual impairment
will be familiar with their immediate surroundings and frequently traveled routes. Since the emergency
evacuation route is likely different from the commonly traveled route, persons who are visually impaired
may need assistance in evacuating. The employees will be trained and should offer help to the individual
with visual impairment and guide him/her through the evacuation route.
9.6 Buddy List
Person Needing Assistance "Buddy"
(Insert person's name here) (Insert Buddy's name here)
NOTE: There are no persons needing assistance at this time. This list will be updated should a person needing
assistance is employed by NC Investment Group, LLC in the future. Additionally, correspondences and forms
similar to those in Appendix A will be sent to all employees by the Evacuation Coordinator.
10. Employee Responsibilities
1. You are responsible for your own safety! Stay calm - avoid panic and confusion.
2. Know the locations and operation of fire extinguishers.
3. Know how to report an emergency (911).
4. When the fire alarm sounds, make sure other personnel and customers in your immediate area are aware
of the alarm.
5. Infotm visitors of pertinent infoiniation about evacuation procedure as soon as visitors arrive.
6. Close but DO NOT LOCK doors as you leave. Items requiring security may be placed in a locking file
cabinet or desk drawer on the way out. Turn off unnecessary equipment, if possible.
7. Know the locations of primary and alternate exits. During an emergency, walk to the nearest exit and
evacuate the building.
8. Go to your assigned area of assembly outside the building and wait there. Do not leave the area unless
you are told to do so.
Rev 2.1— NC Investment Group, LLC
Section C (App. A) - Emergency Evacuation Plan
316 W. 30h Street, National City, CA
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T=CIN-
9. List areas of assembly. More than one area may be needed. Areas of assembly should be approximately
200 feet from the building and clear of emergency vehicle access. See Section 10.1 for preliminary
location for area of assembly, along with the site plan showing access roads. Elowever, this location can
be changed by the Evacuation Coordinator and is pending fire department approval.
10. Persons needing special assistance not able to exit directly from the building are to proceed to and remain
in an area of refuge. Inform evacuating occupants to notify the Evacuation Coordinator of your location.
Fire Department personnel will evacuate occupants needing special assistance from the building.
11. Do not re-enter the building until you have been notified to do so. Emergency personnel often silence the
alarm in order to communicate with each other. Silencing the alarm is NOT a signal for occupants to re-
enter!
10.1 Assembly Point/Area Plan
The following are some preliminary recommendations for Assembly Point/Area in the event of an incident
(NOTE: Site plan by TECHNE Design): Assembly Point/Area
SITE PLAN LEGEND
I I
I I
SITE PLAN Notes
•
•
116W Ykht.
Moen!ety. CO 919.+1
APPIIVM
owournaixt4r.p., U.[
lblT Lanni Ogme
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unuoirn
SITE PLAN -
PROPOSED
A101
Rev 2.1— NC Investment Group, LLC
Section C (App. A) - Emergency Evacuation Plan
316 W. 30th Street, .National City, CA
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11. Emergency/Evacuation Floor Plan & Assembly
Point/Area Plan
The Emergency/Evacuation drawings are provided by the architect of record (TECHNE Design). See
architectural plans for detail
12. conclusion
By way of my signature, NC Investment Group, LLC agrees to meet the conditions required and specified in this
report.
04/05/2022
Ray Ibrahim Date
Ce11 619-857-3001
Rev 2.1-- NC Investment Group, LLC
Section C (App. A) - Emergency Evacuation Plan
316 W. 30th Street, National City, CA
K LAUSBRUCKNER
AND ASSOCiAtES
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13. ,Attachment ,A: Sample Emergency
Evacuation Special Needs Notification
Date:
To: All Employees
From:
Subject: Identifying Employees Needing Assistance During an Emergency
Currently, our Department is in the process of reviewing and updating our Emergency Plan. An essential
component in a comprehensive plan is identifying all employees who may need assistance during an emergency.
The need for assistance may be permanent or temporary such as when you are recovering from surgery or a broken
leg. When completing this form, evaluate your situation thoroughly and honestly. You might not think you need
assistance, but a heart condition, asthma or pregnancy can reduce your stamina to the point where you need
assistance during an emergency. In addition, a hearing loss might limit your ability to respond to an audio alarm
or evacuation information.
Describe in detail the type of assistance you think you will need. It is not necessary to give medical details.
If you want colleagues to assist you, you can either select your own or choose from a list of volunteers the
department has on file. If you choose your own, list their names and phone numbers. You should select a primary
aide and a back-up as well. Make sure you select "emergency aides" who can handle their assigned tasks.
Please complete the attached form and return it to the Evacuation Coordinator
Coordinator will contact you to discuss your request.
, in Room . The
This information will be kept confidential according to the Federal Privacy Act (P.L. 93-579) and the Information
Practices Act of 1977 (Civil Code Sections 1798, et seq.). This information will be used only to provide assistance
during an emergency.
It is our goal to safely and efficiently protect every employee, client, customer, and visitor during an emergency
and to preserve everyone's personal dignity in the process.
It is our responsibility to provide a safe place for you to work. However, we cannot be held liable for your
safety if you do not identify your need for assistance.
Thank you,
Signature
Attachment
Rev 2.1— NC Investment Group, LLC
Section C (App. A) - Emergency Evacuation Plan
316 W. 30th Street, National City, CA
KLALI9E1RUCKNER
AND A.SSoCFAYES
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Date:
Name:
Office:
Address:
Room Number:
Phone Number Office:
Model Form
Emergency Evacuation Information
Do you need assistance during an emergency?
NO
Cell:
Yes- The only evacuation assistance I request is sighted -guide assistance out of the building with
whoever is closest and available.
Yes -The Type of assistance I will need is:
(Please do not provide medical information)
Do you wish to choose your aides from a list of volunteers: :Yes No
If no, list the names and phone numbers of two coworkers you wish to assist you.
Do you wish to be evacuated during drills and minor emergencies? :Yes = :No
If you do not wish to be evacuated, go to the area of refiige during drills and minor emergencies.
The purpose of this form is to identify employees who need evacuation assistance during an emergency. The
need may be permanent or temporary such as when an employee is recovering from surgery or a broken leg.
Some employees might not think they have a disability, but a heart condition, asthma or pregnancy can reduce
stamina to the point of needing assistance when quickly moving downstairs, or a person's hearing loss might
limit the ability to respond to an evacuation alarm or verbal announcement.
The information will be given to the Evacuation Coordinator who will contact you to discuss your request and
will notify your emergency floor warden. All information will be kept confidential pursuant to the Federal
Privacy Act (P.I. 93-579) and the Information Practices Act of 1977 (Civil Code Sections 1798, et seq.).
If you have any questions, please contact your Evacuation Coordinator at
Rev 2.1—NC.Investment Group, LLC
Section C (App. A) - Emergency Evacuation Plan
316 W. 30`h Street National City, CA
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LONGEST PATH TO EXIT: 101'-4"
EXIT 3 - PROPOSED EGRESS DOOR
MIN. EGRESS WIDTH: 4 X 0.2 = 0.8"
ACTUAL WIDTH: 36"
(CBC 1005.3.2)
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DocuSign Envelope ID: D1D5340C-722C-4576-8A3D-8822710C2865
® ®5jfJ!5
Specialized Waste Solutions, Inc.
®9 SPE AUZEOWASTE
� 12067 Riverside Dr.
Lakeside, CA 92040
(858) 699-7785
April 05, 2022
City of National City
City Manager's Office
1243 National City Blvd.
National City, CA 91950
Re: NC Investment Group, LLC Environmental Engagement
NC Investment Group, LLC located at 316 W. 30th St. National City, CA 91950 has
contracted with Specialized Waste Solutions, Inc. to manage, transport, and dispose of all
waste generated materials stemming from distribution and retail production.
Our agreement of services include organic, hazardous, and universal waste
characterizations, manifesting, and transportation & disposal to Federal, State, and
Locally permitted disposal sites.
Specialized Waste Solutions, Inc.
Prepared By Jonathan Lisicki
Title
Signature
Date
President
04/05/22
DocuSign Envelope ID: D1D5340C-722C-4576-8A3D-8822710C2865
SECTION D: SECURITY PLAN
PREPARED BY PROFESSIONAL SECURITY CONSULTANT
NCIG has engaged security surveillance and alarm specialist, Martin Samo of Elite Security
& Surveillance, to prepare this Security Plan.
Martin Samo is the founder of Electronic Security Systems (later merged with Elite Security &
Surveillance). Elite Security & Surveillance has been serving local businesses in the greater San
Diego area for approximately 40 years providing a variety of security needs, including alarm
system installation and monitoring, surveillance system installation and monitoring, perimeter
monitoring, access control, and more. Mr. Samo also has direct experience in advising
commercial cannabis businesses in its security needs.
Included in the Plan is the Security Premises Diagram requested by the City. It can be located
near the end of the attached document.
NCIG — Security Plan Page 1
DocuSign Envelope ID: D1D5340C-722C-4576-8A3D-8822710C2865
Eiit'�
Security & Surveillance
Electronic Security System
Martin Samo
6350 El Cajon Blvd.
San Diego, CA 92115
Tel (619) 588-6964
Fax (619) 324-7795
Lic #: 457107 & ACO 6970
Email: msamo(&,,sd-elite.com
April 4, 2022
City of National City
Re: Security Plan & Review
NC Investment Group, LLC.
316 W. 30th Street,
National City, CA 91950
I am the C.E.O. of Elite Security. I am considered a qualified physical security expert. I have
developed dozens of cannabis business security plans that have been submitted with cannabis
business license applications. I have analyzed many cannabis businesses in California and other
states. Like other cannabis security consultants, I observe and advise these businesses regarding
their security risk and how to be compliant. In addition to understanding the theory, I manage the
day-to-day operations of a security company with a significant client base focused on cannabis.
Personal Qualifications include;
• ALARM COMPANY QUALIFIED MANAGER (Current)
• ALARM COMPANY OPERATOR (Current)
• NICET certified
• Security consultant since 1999
• Certificates/course completion — First Alert (DSC)
• Potter Fire Alarm Certified Technician/Training
• Honeywell/Silent Knight Fire Alarm System Certification
• Designed over 90 licensed cannabis facilities in California
• Authored over 75 SOP for licensed cannabis facilities in California
• Electrical Engineer 1990 SDSD BS Degree
2
Standard Operating Procedures and Security Plan
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
The Diagram and Plan incorporate the following best practices:
Building design, the lends itself to being secured;
Physical entry and access control;
Security lighting;
Intrusion detection;
- Video surveillance;
The Diagram and Plan identify all active security measures including the assignment of uniformed
security officers, live -monitored video surveillance (during business hours) and an array of UL
listed and monitored alarms inclusive of contact points, motion detectors and duress/robbery
alarms situated.
There will be two (2) redundant alarm systems. The alarm systems will be wired with door
contacts, motion sensors, sirens, keypad and duress/hold-up switches. The alarm panel will be
placed in a secure office or dedicated closet/cabinet. The Alarm system will detect movement in
all required areas within the premise when i.t is vacant using motion detectors placed throughout
the facility. In the event of an intrusion, the alarm system will notify the central dispatch center
that will immediately get in contact with its authorized assignee and Security Guard Company on -
site. If the authorized assignee cannot be reached, local police will be notified and dispatched.
The burglar alarm practices meet or exceeds those requirements of the City of National City, the
State of California, and best industry practices.
Passive security measures are described in appropriate detail and will be effective. The measures
incorporated into the Plan include a robust surveillance system exceeding State and local
requirements, as well as comprehensive CPTED (crime prevention through environmental design)
concepts inclusive of target hardening, territorial reinforcement, and natural surveillance.
The security camera plan is described in appropriate detail and will be effective. It involves 52
cameras, each operating at 90 days recording at 4MP resolution and 30 frames per second. The
camera layouts are provided for both interior and exterior environments, ensuring no blind spots
and distinctive coverage of all areas where cannabis and currency may be stored, loaded, unloaded,
moved, or transacted upon and about the premises.
Incorporated into the Plan are customer parking spaces situated for strong natural surveillance
from the public thoroughfare, sufficiently near the structure to provide for uniform, white lighting,
3
Standard Operating Procedures and Security Plan
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
and sufficiently close to the structure to provide for high- quality video production of these areas.
Outdoor perimeter detection for any overnight delivery vehicle.
A detailed premise diagram demonstrating stringent access control and staff protection, enhanced
natural surveillance and placement of critical areas (security infrastructure, cannabis storage and
currency storage) in areas that cannot be seen by customers, and which maximize the time and
distance that an offender would have to overcome in accessing these critical areas of the premises.
The design inherently reduces opportunities for diversion, restricting access to these areas to
management personnel.
Within the product security heading of the Security Plan that follows, procedures are outlined that
describe how the retail area will maintain only that stock required to support average daily sales,
how cannabis goods will be securely stored after hours.
Beyond the local and state requirements, the Plan implements a vast array of best practices
including but not limited to exterior lighting commitments, specific training standards/ content
for employees, off -premises security measures for delivery personnel, contingency plans, crime
prevention measures and more.
For these reasons it is my opinion that the site security Plan and Diagram exceed the City and
State requirements and provide for a very safe and secure operation.
If you have any questions, please contact me at 619-588-6964 Ext.2
Sincerely,
Martin Samo
Elite Security & Surveillance, Inc.
4
Standard Operating Procedures and Security Plan
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
INTRODUCTION
The objective of the Standard Operating Procedures and Security Plan is to lay out a
comprehensive security plan of the measures that will be implemented to ensure the facility will
be operated with the safety and security of the community, staff, and customers. Plan provisions
will comply with local and state laws and ordinances that regulate the selling of Cannabis and
Cannabis Products.
Considering that there may be internal or external security threats to this property, this facility will
implement a security program and employ highly trained and certified security officers at the
facility 24 hours per day 365 days per year to prevent and stop all known and potentially unknown
threats, including but not limited to, theft, burglary, robbery, and cyber security. Access to the
facility and products by unauthorized visitors or persons under 18 years of age will be strictly
prohibited. The retail establishment may be licensed for 18 and over medicinal use and 21 and
over recreational use.
We have developed a detailed security plan, along with training programs that focus on and
increase prevention, awareness, and responsible incident management. The Standard Operating
Procedures and Security Plan is structured and organized to best protect and secure the entire
operation and focus on all aspects of risk, including monetary, regulatory and operational risks.
It's imperative to employ ongoing testing of alarms and security systems and continuously
develop, adapt and revise procedures and protocols to reflect the evolving security and safety
issues of everyday operations.
FACILITY SECURITY
The premises will have a Facility Surveillance Monitors that will be located and monitored at both
the managers offices and the front check -in counters. Authorized Personnel includes surveillance
operations security staff, manager(s), law enforcement authorities, and security service personnel
or contractors. A current list of authorized personnel or contractors who have access to the Facility
Surveillance Center must be maintained by the security manager and will be made available to
appropriate authorities upon request. The Facility Surveillance Center will allow the Security
Team to monitor all activities in and around the facility in real-time, will remain locked at all times,
and will not be used for any other purpose.
PHYSICAL BUILDING
Location
Walls, doors, windows, gates, safes, vaults, cabinets, etc. are critical layers of security. Access
control to these vital zones are mandatory, requiring a visible employee identification program.
These secured locations will be labeled with individual location codes which will correspond to
the item's location on a premises map.
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Security Features
The primary objective is to protect life and property and deter criminal activity by serving as a
visible presence. Our operatives serve as a deterrent to criminal or other activity that could result
in destruction of property, injury, or loss of life. Security officers will monitor and notify the
appropriate authorities in the event a crime has been committed or is in progress. Any security
response that is beyond the skills or scope of our operatives, contrary to the policies of the company
or outside the boundaries of the contracted area of responsibility or of the directives of the client
should be reported only to the appropriate authorities.
The Facility Surveillance Center will continuously monitor any activities relating to the sale
and transport of Cannabis and will be staffed 24/7. This facility will be staffed with a sufficient
number of security officers at all times and will continuously monitor the security entrance and all
facility transport vehicles.
Material construction of the facility, including doors, windows, and all other potential points of
entry, must be suitable to withstand forced entry, will require locking devices, and shall be closed
and locked except when authorized personnel are entering or exiting the controlled area. All
windows and skylights must have security bars/screens.
Intrusion Detection Systems will be provided for all storage areas. In addition, a duress switch or
holdup button will be provided in a hidden location to enable personnel to dispatch local police.
Property Lighting
The Retail & Distribution dispensary shall have enough lighting to provide light to all areas of the
building and adjacent sidewalks and parking areas in compliance. The facility and its storage areas
will be provided with both exterior and interior lighting of sufficient intensity to enable visual
surveillance by security personnel, surveillance video systems, or other designated personnel.
Particular attention will be directed to doors, windows, and other possible points of entry. Lighting
shall be adequate to identify all persons entering and exiting the facility and parking areas in
support of the video monitoring system, and lighting must be illuminated during evening hours.
The applicant shall comply with the city's lighting standards regarding fixture type, wattage,
illumination levels, shielding, and other restrictions, and secure the necessary approvals and
permits as needed.
Facility Security Guards
At minimum, one guard will always be present, based on the facility size and layout. Additional
Security Officers will be added as needed and will work closely with local law enforcement and
DCC. Security Officers will be highly trained and will meet or exceed required certifications.
Semi-annual tactical, situational, ID and classroom training will be provided to ensure Security
Officers are best equipped to handle any situations they may encounter in order to maintain their
positions. A proactive approach to security will be taken with zero tolerance for complacency.
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The security manager will oversee all aspects of security and will be responsible for managing all
security personnel on site as well as the transport vehicles. Security Officers will be assignedto
designated areas during their work day in an effort to maximize their effectiveness and the safety
and security of the facility. For staffed points of entry, a guard must be present to allow site access
during working hours.
Background screenings must be conducted on any individual or entity prior to hiring. These
background screenings must be documented and shall include at minimum, verification of personal
identity, a criminal background check, validation of required certifications and ability to operate
within their jurisdiction.
Perimeter Security
The Cannabis facility grounds will be surrounded by a secure perimeter block and will be the focus
of the first layer of security (i.e. a fence, wall, or combination both). The perimeter barriers will
be minimum 6' high and will be constructed of anti -climb and anti -cut. They will define property
boundaries while deterring and/or delaying intruders from gaining access to the property anywhere
other than at designated entry points. Perimeter barriers must completely enclose the facility,
penetrated only at designated access points, and free of view blocks (vegetation, vehicles, etc.)
along the perimeter barriers. Camera and guard views along the perimeter barriers and cleared
adjacent space cannot be obstructed and must be patrolled by Security, and adequate video
surveillance and monitoring systems should be installed. "No Trespassing -Private Property"
signage will be posted all along the perimeter barrier line and at the entrance gate along with video
surveillance and armed Security Forces on duty signage.
Information Protection
The Chief Technical Officer will ensure all technology devices have the proper security features
to protect the company's technology infrastructure, patient information, proprietary information,
trade secrets, and point -of -sale data, records, intellectual property, financial information and seed -
to -sale data for a security breach. Any IT security breach could be catastrophic to the operation
and cause the loss of personal and proprietary information.
Great care is taken to ensure this data is protected and backed up on multiple platforms, secured
with an onsite and offsite firewall and security system. All company technology devices will be
issued and maintained by the Chief Technical Officer with background security measures
operating to detect and quarantine any threats and will immediately notify the Chief Technical
Officer and IT Security Company that a threat has been detected. The Chief Technical Officer will
also run support for the Security Manager assisting with any video or electronic entry systems.
All employees must also implement strict security measures to control access to and protect the
storage and transmission of confidential electronic information. All networks and servers must
be protected by information security functions and may only be stored on secure servers that are
protected from general purpose computer networks by a dedicated firewall. Confidential
electronic information may not be stored on any internal drives to which external portable media
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recordable devices can be attached for the extraction of confidential data. All vital computer
resources must be housed in accordance with equipment manufacturer's operating specifications
for temperature ranges, humidity levels, and other pertinent limitations. Data centers and computer
rooms housing vital computer resources must be equipped with fire suppression systems.
Facility Access by Authorized Staff
All means of access control (keys, alarm codes, access control cards, etc.) in the facility will be
strictly controlled and monitored to ensure that no unauthorized persons can access the facility.
Multiple layers of security have been implemented to prevent any and all violations, including
closed circuit television, access control readers, alarm systems, vaults, etc. Employees will be
issued access control credentials, limiting their access to only the areas of the facility that is
required by their job description.
Employee Identification Badges
Comprehensive policy regarding all Identification Badges and Visitor Policies aim to prevent
unauthorized access to the Cannabis facility. The security measures outlined in this document will
ensure that the site effectively prevents unauthorized access to any area of the Cannabis facility.
Only authorized employees, contractors and visitors will have authorized access to the facility as
well as designated limited access areas.
Explicit security measures have been put in place to protect all employees and the facility from
potential harm, both physically and financially. Only specific personnel will be authorized to
distribute permanent and temporary identification badges and must adhere to a stringent process
in doing so. Identification badges are assigned based on the category level of employees, vendors,
contractors, and visitors. Identification badges are further restricted based on necessary areas of
access, with different levels of access clearly defined for ease of identification by employees and
security personnel.
Limited Access Areas
All entry points to a limited access area will require electronic credentials and will be equipped
with video surveillance. Sensors such as motion detectors will be installed to detect entry and exit
from all secure areas and shall be monitored in real time consistent with FCO §9-3310(b)(1)(ix).
Access control logs generated in accordance with this policy or through employment of digital
access control systems will be retained for no less than 90 days.
Key Cards/Access Control Locks
All key orders should be properly authorized by an authorized employee, in addition to the key
holder, before issuing. The issuance of keys and/or access control cards to employees will be
recorded on a security access log (Appendix A). Each key will have its own appropriate level of
access which will determine which areas of the facility the employee has permission to enter,
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access to safes or vaults, and what data can be accessed within the computer system. The
appropriate level key shall be issued to each individual granting only the appropriate level of access
and shall not be issued by request, but by need. Extra keys and access cards are to be stored in a
vault or safe in the Office. All employees issued a key or access control card will sign a Key/Key
Card User Agreement attesting to their understanding of the procedures (Appendix B). The paper
version of the security access log will be stored in a locked location when not in use. Commercial -
grade locks. Note that all points of ingress and egress to this medical cannabis facility shall ensure
the use of commercial -grade, nonresidential door locks and window locks.
Facility Access by Site Visitors
All vendors, contractors, and visitors must obtain permission to enter the facility 24 hours prior to
arrival, and only authorized visitors will be permitted access to the site. The identity of all visitors
must be verified against government issued identification before they are granted access to the
facility and the identification must be verified electronically or directly by staff security. Upon
arrival, all visitors will be issued an identification badge and will always be escorted by a
designated employee.
Visitors and vendors must always be accompanied by an authorized employee when in the facility
or when accessing secure internal locations. The site shall maintain a visitor log documenting all
visitors and vendors and must be retained for a period of no less than 12 months.
No visitors shall be allowed access to storage areas without prior leadership approval, a
government issued ID, and an authorized escort. Facility Access by retail customers are as follows;
• 18-20 years of age must have an valid government ID and a physician's recommendation
• 21 years and older must have a valid government ID
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Visitor Identification Badges
Short-term guests, vendors, observers, or other visitors will be issued a temporary visitor badge
approved for use by the facility and will always be escorted. The visitor ID cards shall be retrieved
and secured at the end of the temporary worker's shift. Once the temporary worker or contractor
has completed their assignment, the ID card shall be retrieved and returned to Human Resources,
Valid Identification and Age Verification
Security Officers are the first line of defense of the Cannabis facility to ensure only authorized
persons are grated access. All persons granted access to the facility must be 21 years old and
provide valid state or government issued identification. It is imperative Security Officers inspect
identificationlcards closely and use the electronic verification system to verify identification and
age of each person who attempts to enter the Cannabis facility. Under no circumstances are persons
allowed into the facility without valid identification regardless of age.
Facility Access by Officers, Officials, and Professionals Other Than Site Visitors or
Authorized Staff
All visitors, vendors and non -employees shall be logged and screened prior to entering the
facility. See log sheet for documentation.
Facility Access Points
The Security Department is required to walk the interior and exterior of the facility on an hourly
basis and are to man the video surveillance area constantly.
ELECTRONIC SECURITY SYSTEM
Video Surveillance Equipment
Cameras will be positioned in strategic locations throughout the facility to monitor activity in all
areas. The resolution of live and recorded playback images must be good enough to clearly
recognize individuals and items/events and will allow for generating images capable of capturing
facial detail. Video surveillance must be maintained 24 hours per day for 90 days and must cover
all sides of the facility and all potential points of entry. Video must be both monitored in real time
and recorded. The surveillance system must include continuous date and time -stamping. Video
recording must be on digital media rather than analog tape. Cameras must be 1280*720-pixel
resolution. All surveillance shall be TCP and remote accessed via the internet. All video footage
will be maintained for a minimum of ninety (90) days and available to law enforcement upon
request. The video surveillance equipment and recordings are stored in a locked secure area that
is accessible only to authorized personnel.
The video surveillance system is equipped with a failure notification system that provides prompt
notification to Elite Security & Surveillance, licensed by the Department of Consumer Affairs,
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Bureau of Security and Investigative Services, of any surveillance interruption or complete failure
of the surveillance system that lasts longer than fifteen (15) minutes. The licensed alarm company
must promptly report any such notification to the National City police department.
The video surveillance system shall have sufficient battery backup to support a minimum of one
hour of recording in the event of a power outage. See additional cut sheet for APC Smart -UPS X
3000VA
The video surveillance system shall stream a live feed accessible to the National City police
department via a secure internet portal, virtual private network or other form of secure remote
access.
Intrusion and Motion Detection
There will be two (2) redundant alarm systems. The alarm systems must be wired with door
contacts, motion sensors, sirens, keypad and duress/hold-up switches. The alarm panel must be
placed in a secure office or dedicated closet/cabinet. The Alarm system will detect movement in
all required areas within the premises when it is vacant using motion detectors placed throughout
the facility.
Burglary Alarm System
A centrally monitored alarm system shall be installed with motion sensors and strikes on all
exterior doors as wellas the safe/vault room and will always be maintained and monitored. The
system will detect unauthorized entrance at all potential entry or exit points of the premises. There
will be two (2) redundant alarm systems. The alarm systems must be wired with door contacts,
motion sensors, sirens, keypad and duress/hold-up switches. The alarm panel must be placed in a
secure office or dedicated closet/cabinet. In the event of an intrusion, the alarm system will notify
the central dispatch center that will immediately get in contact with its authorized assignee. If the
authorized assignee can't be reached, local police will be notified and dispatched.
Alarm system. The medical cannabis facility shall have an audible interior and exterior security
alarm system installed on all perimeter entry points and perimeter windows, operated, and
monitored by a security company licensed by the Department of Consumer Affairs, Bureau of
Security and Investigative Services, and approved by the city. "Perimeter entry points" includes,
regardless of size, all doors, windows, hatches and/or points at which systems (such as HVAC
systems) enter a structure.
Duress Codes and Panic Procedures
All employees will be assigned a 4 digit "duress" code. In the event of an emergency, such as a
threat of violence, robbery, or an employee being coerced into "disarming" the alarm system by
an intruder, by entering the duress code, the alarm system will trigger a "silent" alarm that will
dispatch police.
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Panic buttons can bring 24/7 help in the event of an emergency, as they enable you to remotely
send emergency signals to an alarm system, even if you aren't physically able to access the control
panel. These consist of a single, small button designed to remotely trigger an alarm and are
strategically placed in a discreet and hidden location throughout the facility that, when triggered
by staff, automatically alerts police to an emergency situation. On -duty police in the area will be
dispatched to your Location immediately. Triggering a panic button can either sound an "audible"
alarm or a "silent" alarm which will depend on the potential risk scenario at hand.
Maintenance and Inspection of alarm and surveillance system
The alarm and surveillance systems shall be inspected and tested regularly. All repairs should be
made within and no later than 24 hours of inspection.
Auxiliary Power System
A back up power system for alarm systems and video surveillance equipment shall be maintained
and periodically tested. Power conditioner shall be installed to control any voltage
spikes/abnormal issues.
Fire Safety Management and Emergency PIan
Fire detection and suppression systems will be employed in the data centers and computer rooms
housing critical computer resources. In case of fire or any other emergency that requires
evacuation, the establishment will have a predetermined designated fire Assembly Point outside
the building at least 50 feet away. All occupants should evacuate the building by the nearest exit
to the outside of the building and then proceed to the Assembly Point.
During training all employees will know the locations of fire extinguishers and how to use them.
Fire extinguishers will be mounted and maintained according to fire code regulations. All staff
will follow recommended procedures to prepare for emergencies that require evacuation, and take
preventive measures such as keeping doorways, corridors and exits clear of any obstructions.
Additional emergency actions and fire prevention procedures are detailed in the Fire Prevention
and Safety Plan.
POLICIES AND PROCEDURES FOR FACILITY SECURITY
Incidents and Emergencies Procedures
Visitors, vendors or contractors will not be permitted access to the facility without prior approval
except in cases of an emergency such as plumbing, electrical, HVAC system failure, etc. The
Security Officers or authorized staff will allow a visitor, vendor or contractor access to the facility
only after documenting the emergency circumstances.
Security guards will manage all activities to ensure the safety and wellbeing of all employees and
customers present and will immediately take action to remove from the premises any person(s)
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that are displaying threatening, disruptive, or violent behavior, attempting to use or using products
on site, or appear to be under the influence of drugs and/or alcohol, are in possession of a firearm
or other dangerous weapon, or any other indications of unlawful activity. In all instances, law
enforcement will be notified to assist with the removal of person(s) who fail to leave the premises
upon request.
Emergency exits will be accessible as egress points only in the event an emergency exit is required.
Emergencies and Notifying Authorities
All POS registers, rear offices, and front lobby are equipped with durres/hold-up buttons in case
of robbery or any type of emergency. If a duress button cannot be reached, calling 911 first then
if safe, contact management.
Security Officers may not become involved in a possibly toxic situation involving blood, vomit,
or other bodily fluids, unless properly trained, certified, and equipped. Proper eyewear, plastic
gloves, or other barrier items are required. Security Officers shall not give mouth-to-mouth
resuscitation unless a protective airway is used. A family member or friend may be asked to do so
and should be given instructions. If Security Officers are exposed to possibly toxic substances,
such as blood or any other bodily fluid, they are required to seek immediate medical assistance
and take an HIV test. In all situations requiring medical attention, Security Officers are required
to activate emergency medical services (EMS) by notifying dispatch to call 911 or the appropriate
emergency telephone number.
Closing Procedures
Authorized personnel must walk the premises to ensure all employees/customers are out of the
building, ensure rear and all doors are secured, lights off and with exception of emergency and
approved 24 hr lights to remain on, arm alarm system, and secure front door. Caution must be
taken to ensure a secured path to vehicles and that no suspicious activity outside of the building.
Loss Prevention and Diversion
To detect or deter internal theft, a bag check should take place at the beginning and end of each
shift, or as employees enter and leave the premises. All employees working with product
processing will be required to wear provided pocket -less clothing.
Preventing On -Site Consumption
Any on -site consumption will lead to an immediate termination of any employee/management.
All areas of grounds will be recorded 24 hours per day. Employees will be tested, and all areas
will be monitored by security guards on site for any such activity.
Preventing On -Site Consumption
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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 will be kept for a period no less than 12 months.
On no less than an annual basis (at or before the time of the renewal of a commercial cannabis
business permit issued pursuant to this Chapter), or at any time upon reasonable request of the city
of National City, each commercial cannabis business shall file a sworn statement detailing the
number of sales by the commercial cannabis business during the previous twelve month period (or
shorter period based upon the timing of the request), provided on a per -month basis. The statement
shall also include gross sales for each month, and all applicable taxes and fees paid or due to be
paid. On an annual basis, each owner and operator shall submit to the City a financial audit of the
business's operations conducted by an independent certified public accountant. Each committee
shall be subject to a regulatory compliance review and financial audit as determined by the city
manager or their designee(s).
Incident Log
All incidents will be logged and stored for management. All issues with employees will be noted,
logged and inputted into the respective employee's file.
Suspicious Activity and Loitering
Suspicious activity and security will be noted and logged. The owner and/or operator shall prohibit
loitering by persons outside the facility both on the premises and within fifty feet of the premises.
Manager and/or owner is to notify National City police department if anyone continues to loiter
around the building or premises after all reasonable action has been taken to remove the
individual(s) and the action has failed to do so in a timely manner.
IT Infrastructure & Cyber Security
The IT Chief Technical Officer will ensure all technology devices have the proper security features
to protect the company's technology infrastructure, patient information, proprietary information,
trade secrets, point -of -sale data, records, intellectual property, financial information and seed -to -
sale data for a security breach. Any IT security breach could be catastrophic to the operation and
cause the loss of personal and proprietary information. Great care is taken to ensure this data is
protected and backed up on multiple platforms, secured with an onsite and offsite firewall and
security system. All company technology devices will be issued and maintained by the Chief
Technical Officer with background security measures operating to detect, quarantine any threats
and immediately notify the Chief Technical Officer and IT Security Company that a threat has
been detected. The Chief Technical Officer will also run support for the Security Manager assisting
with any video or electronic entry systems.
OPERATIONS SECURITY
Analyzing routes and threats for all security and employees is crucial for overall security. A Threat
comes from an adversary — any individual or group that may attempt to disrupt or compromise a
friendly activity. Threat is further divided into adversaries with intent and capability. All threats
or compromises should be reported immediately to security and management.
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EMPLOYEE TRAINING & CUSTOMER EDUCATION
All employees will be trained in the variety of products offered for sale, their potency, absorption
time (if known), and effects of the products. Employees will educate all customers on those items
in an effort to ensure responsible consumption. Brochures containing safe consumption as well as
potency/absorption will be handed out with every sale. Manager/owner understands that the city
manager, or their designee shall have the discretion to require other training for the business
operations as they find necessary under any circumstances.
WORKFORCE SECURITY
Staffing Procedures
All hired employees will be given proper background checks for the last 5 years. All employees
must sign security handbooks and will be given proper training on procedures in case of an
emergency. Handbooks will always be kept on site for updating and safekeeping. All security
officers/personnel hired or contracted shall be licensed by the Bureau of Security and Investigative
Services and shall comply with Chapters 11.4 and 11.5 of Division 3 of the Business and
Professions Code.
Staff Security and Emergency Response Training
All employees must adhere to security protocols in this manual and in the emergency response
manual.
First Aid Kits shall be installed in the front lobby and in the rear grow facility. Proper fire
extinguishers based on fire plan (to be provided later w/working drawings) shall be installed.
Protocols of emergency response shall also be provided in the employee handbook.
Cash Handling Procedures
Cannabis is a cash -based operation. Even when other banking options appear, cash will always be
a part of the equation. You must have strict controls for managing cash in your dispensary. Failing
to properly count, store, and manage cash is a liability to your business, including theft, loss, and
inaccurate reporting and accounting. The tighter your controls, the lesser your risk.
This cash handling procedure (SOP) details every step in the process from customer cash payment
to putting the money in safe storage (whether that's a bank account, offsite secure facility, or onsite
safe). This SOP section accounts for how you handle cash at opening, when and how you do drops
during the day, accepting cash/giving change to customers, when and how you close out drawers,
deposit the days' cash at closing, reconcile discrepancies, and storage/transport.
OPENING A CASH DRAWER PROCESS
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A drawer is the physical register or till used to check out customers. The drawer is opened at the
start of each day, or with a new employee starting a shift.
1) Budtender gets a new cash drawer from Shift Manager. Drawers are kept in the Vault.
2) Manager puts the days' starting cash, in various bills, into the drawer as part of the opening
process.
3) Employee inserts till at his or her register.
4) Find the drawer you'd like to open.
5) Employee to verify the entire coin and dollar denomination within the drawer. The total
starting balance is shown. Double -count to ensure accuracy.
6) Add notes if desired and click "Open Cash Drawer."
7) Put the till into the cash drawer at your terminal.
CLOSING A CASH DRAWER PROCESS
A drawer is closed at the end of each day (or shift) to confirm cash/debit totals.
Steps for budtenders:
1) After the last transaction is processed, count all monies in the drawer. If the store is open,
count in the manager's office or other safe room. If the store is closed, money can be
counted at the terminal.
2) Manually count and enter the total of each coin and dollar denomination within the drawer.
Double -count to ensure accuracy. Count the drawer down to zero, meaning no money is
left uncounted in the drawer.
3) Put the cash in a labeled manilla envelope or a sealed cash bag and take the cash and
physical drawer to your manager to review and close.
Note: Be cautious about carrying cash throughout the store when it's open and customers
are present.
Steps for Managers:
1) Receive the cash and physical drawer from the budtender. If the store is open, complete
the closing process in the manager's office or other safe room. If the store is closed, money
can be counted at the terminal.
2) Count the monies in the drawer and compare the expected cash with the actual cash.
3) If they match, close the drawer.
a) If they do not match, recount and update as necessary.
b) If they still don't match, follow the discrepancy process below.
4) Add any relevant notes.
5) Put the funds (along with the 'end of shift print-out) in selected vault/safe.
CASH DROP PROCESS
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Cash drops are when a cash drawer/till is counted and a portion of the cash is removed from the
drawer to be deposited elsewhere. Cash drops are different from payouts, as they do not impact
revenue. The goal is to limit the amount of cash in a drawer at any given time.
** Managers are expected to perform a cash drop when the register exceeds $2000.
Aim to count and remove cash when as few customers are in the store as possible to ensure safety.
1) Count the drawer and physically remove the desired amount of cash.
a) Put the removed cash into a sealed cash bag or locking cash box.
b) Count twice to ensure accuracy.
c) Note: Be sure the surroundings are safe to count money before doing so.
2) Immediately deposit the cash and deposit slip into the safe in Vault.
PAYOUT PROCESS
A payout is when a payment, such as paying a vendor, needs to be taken from a cash drawer/till.
A payout is different than a drop, as the payout will impact revenue.
1) All payouts must be made by manager on duty.
a) Count twice to ensure accuracy.
b) Note: Be sure the surroundings are safe to count money before doing so.
2) Put the money into an envelope and give to the vendor or person you're paying. Ensure
you receive a receipt and place the receipt in or under the cash drawer to include in
documentation during closing.
DEPOSITING MONEY INTO THE SAFE PROCESS
Manager can deposit cash/has access to the safe - Managers and maybe trusted shift leads or
budtenders must follow this process anytime cash is deposited into the safe.
1) Ensure the surroundings are appropriate to open the safe.
2) Attach the deposit slip to the cash.
3) Put the cash and deposit slip in the safe.
4) Close and lock the safe.
COLLECTING PAYMENT/GIVING CHANGE PROCESS
As budtenders process transactions, they will receive cash from customers and hand back the
correct change. This is the process for reducing errors in cash handling during the transaction
process.
1) Once all products are added, and specials applied (if applicable), tell the customer their
total.
2) The customer will hand you the cash. Have them count the cash to you to confirm the
amount.
3) Take the cash and count it down onto the counter in front of the customers as a second
check to verify the amount. Say the amount out loud.
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a) Count the cash one more time while putting the money into the drawer. The payment
screen will show you the amount of change due to the customer.
b) Grab the required change amount from the drawer. Count it as you remove it from
the drawer.
c) Then count the change back to the customer, verifying that amount is what shows on
your screen.
4) Close the drawer.
5) Provide the customer with the receipt.
RECONCILING DRAWER DISCREPANCIES PROCESS
Sometimes drawers are off, sometimes by pennies, and sometimes by significantly more. A drawer
can either be over (meaning it has more cash in it than expected) or under (meaning it has less cash
than expected). The most effective way to reduce drawer discrepancies is to use the triple cash
count process (outlined in the collecting payment/giving cash process above) while accepting
money from customers and counting back change.
If a drawer is off by $5 at the end of the night, the closing manager will follow this process:
1) Run the End of Day (EOD) PDF Report
2) Run a Sales Report
3) On the Sales Report:
a) Confirm that the total number of sales, revenue, and total taxes matches the top
portion of the EOD PDF (see green boxes).
b) Highlight the cash sales column to see the total. Make sure all sales made that day
equal the EOD PDF (see yellow boxes).
4) Verify the drawer number of sales in the EOD PDF.
a) If the drawer is over in the PDF, take the cash value and subtract that from the total
to get the real number in cash sales.
b) If the drawer is under in the PDF, take the cash value and add that to the total to get
the real number in cash sales.
5) Compare drawer cash sales within the EOD PDF with the Sales Report by sorting the Sales
Report by Drawer name and highlighting the Cash Sales column of the specific drawer.
This will tally all cash sales made on this drawer.
6) Look into the Drawer Activity Report to find the employee username associated with that
drawer. Watch for consistent drawer errors from that employee.
7) If applicable, apply and enforce punishment for drawer discrepancies. All employees must
be written up/documented with the amount, time, and date of the discrepancy. All reports
must be noted in the employee's file and the EOD report.
CASH STORAGE & TRANSPORT PROCESS
This process explains how to safely store cash at your dispensary.
1) During the business day, all cash being used for transactions is stored with the open
drawers/tills.
a) Aim to keep drawer totals below $2000.
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2) Do drops at the end of shift or if drawers exceed $2000.
3) Count down and close drawers at the end of the day (or employee shift).
4) Put all cash from drops and drawer closing into the time -triggered safe in vault along with
a deposit slip.
a) Only count money when and where it is safe to do so.
b) Do not count or transport cash when or where customers may see.
c) Only open the safe when no other employees are around.
5) All cash is to be transported to NC Investment Group, LLC selected bank of choice with
pre -selected secured courier.
Security Standards Testing
The security system shall be tested at least once every 30 days. If any issues are found, they must
be reported to management immediately for proper repairs. Repairs must be completed within 24
hours and documented.
Personnel Records
All employee records will be kept on site in a secured office along with backup of records at
corporate headquarters.
Cash Safety Procedures
NC Investment Group, LLC keeps a limited amount of cash on -site and strict controls are applied
to cash handling procedures. It is the policy of NC Investment Group, LLC to follow internal
procedures related to cash management to insure that all cash is safeguarded against waste, loss,
unauthorized use, or theft. The following procedures have been adopted at our other locations and
NC Investment Group, LLC intends to adopt these in the City of National City.
• Cash transactions shall be documented for accountability
• Cash transaction are recorded simultaneously with each transaction
• Consecutively numbered forms are used to document cash transactions and aid in
reconciliation
• Regular review and audit of cash transactions are performed to insure against errors and
loss
• Continuous supervision of cash management activities by management
• Cash related duties, such as maintenance of vault cash, cashiering, accounting, disbursing,
and collecting funds shall be segregated
• Only properly designated employees/management shall handle cash drawers, vault cash
disbursements, and cash reconciliation
• POS and computer accounting programs are used to the maximum extent possible errors
Surveillance Cameras are in operation 24 hours per day throughout the facility. An overhead
ceiling mounted camera will be installed above the cash register to monitor transactions
continuously. The vault remains locked at all times by a combination lock. Lock combinations are
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changed periodically and always when employees are terminated. The vault requires one manager
or supervisor with the vault combination[GA1 ] . All cash drawers are serial numbered and assigned
to a specific POS location. Any vault or safe used for currency storage on the premises will weigh
at least 800 pounds, maintain a fire resistance rating of at least one hour, be made of metal and be
anchored to the permanent structure of the building.
Cash will be transported by a licensed cash management company licensed by the State of
California who will collect cash for transport to NC Investment Group, LLC selected Credit Union.
We anticipate that cash will be collected 4 times a week from the facility with pick up times to be
coordinated by the manager.
Vault Room Procedures/Controls
At each shift change the manager and assigned supervisor must count and verify vault cash
collected in each cash drawer at each shift change. The manager and supervisor open the vault
together and place the vault cash in the vault, sign the cash drawer count with the sales person.
The vault is closed and locked each time.
Each morning, the opening manager and supervisor fill out the daily cash audit form listing sales
(vault cash) by POS station from the previous day. The opening mangers reconcile the daily cash
audit and POS sales summary report from the previous day. Discrepancies require a second count
by the individual that observed the first count. Final discrepancies are detailed on a cash audit form
and signed by both managers.
The original cash audit form stays in the vault with the daily cash. Copies of the new cash audit
form along with the sales summary report are forwarded to accounting. The assigned POS sales
person is responsible for closing the POS station, printing the end of day sales summary and
moving the cash drawer to the vault room for counting and verification.
Staff will be trained on the following policies and procedures:
• Cash will be kept out of view of general staff and public
• The counting of cash will be limited to designated, management office of the facility
• All currency counting and storage areas will be under overt video surveillance
• Management will ensure that all currency is placed in the safe as soon as possible
Business Hours of Operation
Retail Hours of operation will be as follows:
9am to 9pm Monday through Sunday
Visitors 9am to 5pm Monday through Sunday
Vendors 9am to 5pm Monday through Sunday.
Distribution Hours of operation will be as follows:
10am to 7pm Monday through Sunday
Visitors 9am to 5pm Monday through Sunday
Vendors 9am to 5pm Monday through Sunday.
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INVENTORY SECURITY
Transaction Procedures
Transaction of pickup of inventory is controlled via log sheets (see appendix). All inventory is
managed via secured servers and software. Management is in charge of all personnel handling
transactions on site.
Inventory Control or Tracking Plan
Storage Procedures: Storage is always recorded by a 24 hour surveillance system on site. Access
to any part of the facility is granted to authorized personnel only. Badges with proper ID/Pictures
will be granted to all personnel and are stored on a secured server outlining all access. Terminated
employees will be removed from the system immediately. Storage to all stock is controlled and
logged. All log sheets will be stored on -site for access.
Transportation, Tracking and Deliveries: All cannabis will be transported by a state licensed
distribution company.
Disposal Plan: Waste will be disposed of as prescribed by BCC. All personnel picking up disposal
will be logged in, please see the disposal plan attached.
Record -Keeping System: Record keeping will be hosted on a virtual server (Centrix IT). The
domain is controlled with a controlled server. All access is secured, and all approved personnel
must enter credentials to access any portal.
Secure Transport/Distribution of Cannabis
Distribution & Armored Vehicle Solutions
It is essential that marijuana distributors are equipped with exceptionally secure vaults to protect their
revenue and products. It is just as important that these assets are properly protected when they are
transported by vehicles.
Below are five guidelines for distribution
1. Drivers must carry the right licenses
Anyone transporting cannabis for sale must hold a distributor license or be an employee or contractor of a
licensed distributor.
If you're a person or a business that's paid to transport property — that now includes cannabis goods in
California — in their motor vehicle regardless of vehicle size, type, or weight, you must also have a motor
carrier permit. In other words, if you're transporting property and getting paid for it, then you're a "for -
hire" motor carrier.
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Standard Operating Procedures and Security Plan
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As a transporter, cannabis goods must only be accessible by the licensee, their employees, and
contractors. Cannabis goods are also only allowed to be transported inside of a vehicle or trailer and can't
be visible or identifiable from outside of the vehicle or trailer.
Any time left unattended, vehicles and trailers must be locked and secured. Let's say you stop to get gas
or take a bathroom break. Not only must the vehicle or trailer be locked, but the cannabis goods that are
being transported must be stored in a locked box, container or cage that is secured to the inside of the
vehicle or trailer. The locked container also must be separate from the body of the vehicle or trailer. So,
the glove compartment, center console, or spare tire storage is out of the question.
At a minimum, a distributor must also have a vehicle alarm system on all transport vehicles and trailers
transporting the cannabis goods. Motion detectors, pressure switches, duress, panic, and hold-up alarms
may also be used. If this sounds like you're only real option is hiring an armored car, you might be
surprised to know you have secure transport options.
Also, a distributor can't leave a vehicle or trailer containing cannabis goods unattended in a residential
area or parked overnight in a residential area.
2. Driving under the radar
If you're driving a vehicle that's being used to transport and deliver cannabis goods, it must have a Global
Positioning System (GPS) device so the geographical location of the delivery can be identified at all
times. This device must be owned by the licensee, active and inside the delivery vehicle at all times
during the delivery and used for delivery purposes only.
It's also illegal to take your cannabis across state lines, even if you're traveling to another state where
cannabis is legal.
3. Drivers must wear your ID badge
The licensee, anyone employed by the licensee or anyone acting on behalf of the licensee, must wear a
laminated or plastic -coated identification badge whenever they are transporting cannabis goods. The ID
badge must include the following:
• Licensee's "doing business as" name and license number
• Employee's first name
• Assigned employee number
• Color photograph of the employee
Also, it's important to know that while transporting cannabis goods, only a licensee or an employee of the
distributor, age 21 years or older, can be in the vehicle.
4. Driving under the influence
You can't get high just by transporting cannabis. However, it's important to mention that even though
you may just be "the middle man" so to speak as the transporter, and you don't personally consume
cannabis or cannabis goods, if you're under the influence of cannabis while operating a car, boat, or other
vehicle, a law enforcement officer can pull you over and conduct a sobriety test. If you drive while you're
high, you can get a DUI, as well as risk your life and the lives of those around you.
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Transporting cannabis products safely and legally is critical. With the new California regulations in place,
secure transport is crucial to stay compliant and avoid getting ticketed — or even worse — losing your
license.
5. Driver must limit/minimize stops on all routes
Managers must ensure their drivers have the most optimal route, the right fleet mix, and order sequences.
Distribution back -end software such as Locus may be used to ensure the following;
• Tracking delivery
• decrease in delivery time
• Decrease in fuel consumption
• Incorrect address mistakes
• Incorrect resource allocation
INFORMATION SYSTEMS SECURITY
Security of Data and Information Systems
All data will be kept on site at a secured office. All shipping and inventory matters will be
controlled via software on site, see software control section of manual.
PROTECTION OF GENERAL PUBLIC
Security Officers should not fire under conditions that would subject bystanders or hostages to
possible injury or death. Firing under such conditions is not justified unless failure to do so at the
time would create a substantial and imminent threat of serious bodily harm or death. Security
Officers must be sure of their target and surroundings.
Definitions
Ability: Subject has the capability, weapon, or means to carry out a threatened action of serious
bodily harm or death.
Opportunity: Subject must be in a position, reasonable distance, or proximity in which he or she
can effectively apply his or her ability to carry out the act or threat.
Imminent Threat: Immediacy or level of threat posed by a subject is a function of two factors:
(1) Method or means used by the subject to deliver force against an intended victim
(2) Time or distance necessary for the subject to deliver that force.
Another way of describing this factor is to refer to the subject's propensity for violence known to
the Security Officer. The Security Officer may base his or her assessment of the subject's
propensity for violence on the Security Officer's personal knowledge, information provided by
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other Security Officers, victim, client, or other reliable channels. As is often the case, however, an
Security Officer may not know anything about the subject. Time translates into the speed or
intensity with which a subject can deliver force or use a weapon against a Security Officer(s)
and/or citizen(s). Stated another way, the less time that a subject requires to deliver force, the faster
or more dangerous the subject becomes.
Conditions and Criteria for the Use of Deadly Force
To protect oneself or another person from what is reasonably believed to be an imminent threat of
serious bodily harm or death.
Criteria that must be present for an Security Officer to stop a subject's imminent threat using
deadly force are as follows:
• When the Security Officer reasonably believes, based upon facts obtained, that the subject
has the ability and opportunity to place the Security Officer or another person in imminent
threat of serious bodily harm or death; each of these elements is expressly linked to the
other.
• The objective principles of reasonableness, totality of the circumstances, mental
preparation, and factual articulation enable the Security Officer to make timely and
reasonable judgments that support the paramount consideration of safety for the Security
Officer and the public.
• The legal standard of reasonableness does not require personnel to select the least intrusive
alternative, exhaust all options, or use all feasible alternatives; only a legally reasonable
one. Security Officers will not use deadly force to protect themselves or others from bodily
injury assaults that are not likely to result in serious bodily harm or death.
Justification for the Use of Lethal Force
Justification for the use of deadly force should be what reasonably appears to be facts known or
perceived at the time the Security Officer decided to shoot. Facts unknown to an Security Officer,
no matter how compelling, cannot be considered later to justify a shooting. Facts perceived by the
Security Officer are those imminent facts known in the here and now, when the Security Officer
makes his or her decision to shoot to stop the action or neutralize the situation.
Unnecessary Drawing of Firearms
Unnecessarily or prematurely drawing or exhibiting a firearm limits a security officer's
alternatives in controlling a situation, creates unnecessary anxiety on the part of citizens in the
immediate area, and may result in an unwarranted or negligent discharge of the firearm. Security
Officers shall not draw or exhibit firearms unless circumstances surrounding the incident create a
reasonable belief that it may be necessary to use that level of defense in conformance with this
policy.
Those Security Officers who unnecessarily or prematurely draw or exhibit a firearm could be
subject to revocation of their firearms qualification (FAQ) status, progressive disciplinary action
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up to and including termination of employment, and, in certain circumstances, criminal
prosecution and civil action.
Reporting the Use of a Firearm
Whenever a firearm is drawn to a show -of -force position or discharged, personnel must report the
incident to his or her immediate supervisor as quickly as possible. Documentation containing
factual articulation is required as to what level was used or exhibited.
An Incident Report (IR), in addition to a Use of Firearms Report, shall be accurately completed
and submitted to the Security Officer's supervisor for a review conducted by the local manager.
The IR should be completed within a reasonable time frame, based upon the totality of the incident
and operations policies and local procedures. Failing to report a firearm discharge or drawing a
firearm while on duty, other than during the uploading and downloading process, will be subject
to disciplinary action up to and including termination of employment of the responsible Security
Officer. A negligent discharge or any other firearm negligence will also be subject to disciplinary
action up to and including termination of employment of the responsible Security Officer. The
company takes firearm safety very seriously and maintains a zero -tolerance policy for negligence
with a deadly weapon. Strict firearm safety guidelines will always be followed and obeyed because
overall safety is paramount. Violations of firearm safety policies will be subject to disciplinary
action up to and including termination of employment.
General Use of Firearms
The following general procedures apply to all situations pertaining to firearms:
• Emergency Medical Services (EMS) notification
When a use -of -force incident occurs in response to a subject's actions, the Security Officer
will constantly assess the individual's medical condition, if feasible, until EMS or
equivalent arrives. Security Officers need to be aware of possible secondary threats that
may be posed to themselves or other individuals and react accordingly.
• Documentation of show -of -force or use -of -force incidents
An IR shall be completed to accurately describe and articulate all facts known to the
Security Officer at the time force was used or displayed. The Security Officer must submit
the completed IR and a Use of Firearms Report, if applicable, to his or her supervisor for
review and approval.
• Professional conduct
Armed Security Officers shall always conduct themselves in a professional manner and
shall remain aware of the possibility of facing a deadly force decision and, therefore, to
make a legally reasonable response to defend themselves or others as necessary.
Negligence
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An act of negligence is any unreasonable action taken by a security Security Officer that could or
does result in injury, property damage, loss of business or reputation, or loss of life. An act of
negligence may be considered as an omission or failure to act when the Security Officer should
have acted and that could or does result in the above consequences.
Reporting Acts of Negligence
No matter how serious the act of negligence or omission, failure to report will compound the
problem and the results. It shall be the responsibility of the security Security Officer involved in
any act of negligence or omission —either proven or by implication —to submit a complete, written
report and explanation to the site manager within a period of 24 hours from the time the situation
occurred.
City Notification
City city manager or their designee will be notified within twenty-four hours of discovering any
of the following:
• Significant discrepancies identified during inventory. The level of significance shall be
determined by the regulations promulgated by the city manager or their designee.
• Diversion, theft, loss, or any criminal activity involving the commercial cannabis business
or any agent or employee of the commercial cannabis business.
• The loss or unauthorized alteration of records related to cannabis, customers or employees
or agents of the commercial cannabis business.
• Any other breach of security
Negligence with a Firearm
Any security Security Officer found to be negligent with a firearm will be immediately relieved of
duty, not reassigned until a hearing has taken place with the local site manager and will have his
or her FAQ status revoked for a minimum period of 90 days with no maximum. Further, the
negligent security Security Officer may be subject to termination. Any security Security Officer
found to be negligent with other personal equipment will be relieved of duty for a minimum of
three days and will not be allowedto carry such equipment until the Security Manager is satisfied
that another act of negligence will not occur.
Negligence in Judgment or Action
Any security Security Officer, who fails to act, acts in a negligent manner, or is proven to be
intentionally derelict in the discharge of his or her responsibilities, will be required to submit to
the site manager a written explanation of his or her actions. The site manager may relieve the
Security Officer of duty for up to three days. If the situation is sufficiently serious, the Security
Officer may be terminated.
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Negligence Resulting in Death
Any Security Officer, whose negligence is found to result in injury or death to another person, will
be immediately terminated and may be subject to prosecution and criminal charges.
Discipline, Grievances, and Chain of Command.
To best maintain uniformity and consistency throughout the organization, it is necessary that
procedures be established to fairly enforce company policies, that personnel know and understand
the penalties for infractions, and that there is a procedure for airing grievances, so personnel have
a fair recourse to appeal.
The Company's policies are designed in the best interest of the company and the general Public,
with maximum consideration given to the Security Officers, who must live by those policies. The
policies are intended to be fair. However, in those circumstances in which personnel feel that the
policies are not fair, or if they have other grievances about the organization or their supervisors, it
is essential that a channel be available to voice those grievances. Further, no Security Officer shall
be threatened or penalized in any way by supervisory personnel for acting to air such grievances.
Infractions and Disciplinary Actions
Any Security Officer, who has committed a violation or infraction of the policies contained herein,
is subject to disciplinary action. Disciplinary action may vary from a written warning to
termination of employment. The degree of action will vary with the extent of the violation.
Chain of Command
In all disciplinary actions and in hearing of all grievances, the chain of command will be followed.
No Security Officer may be disciplined except by a ranking Security Officer, who is in the chain
of command directly above that Security Officer. Similarly, when Security Officers have
grievances, those grievances must be presented to supervisors directly above the Security Officers.
Grievance Procedure
All company supervisory personnel have the responsibility to hear the grievances of those for
whom they are responsible. Security Officers, who have grievances, must submit their grievances,
in writing, to their immediate supervisors; Security Officer Feedback forms are available for this
purpose. Written grievances shall include the nature of the complaint and a statement describing
the action the Security Officer would like to see taken. The immediate supervisor is responsible
for providing a written response to the grievance.
If the immediate supervisor is unable to resolve the issue, the Security Officer may appeal the
grievance, in writing, with the supervisor's response in writing to the next Security Officer in the
Chain of Command. The appeal may be continued up to and including the regional manager, if the
grievance is not resolved. In all circumstances, the final determination of the regional manager is
final and binding. Grievances of a harassment nature must be reported to the Field Operations
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Manager. If the Security Officer's local command staff is part of the problem, the grievance should
be reported directly to the Security Manager.
Signage
Signage requirement. The medical cannabis facility must comply with the following signage
requirements.
• A sign shall be posted in a conspicuous place near each point of public access which shall
be not less than twelve (12) inches wide and twelve (12) inches long, composed of letters
not less than one inch in height, stating "All Activities Monitored by Video Camera."
• Limited access areas shall be clearly identified by the posting of a sign which shall be not
less than twelve (12) inches wide and twelve (12) inches long, composed of letters not less
than a half inch in height, which shall state, "Limited Access Area —Authorized Personnel
Only."
• In addition to the requirements set forth in the zoning ordinance and applicable CUP,
signage shall be limited to the business name and address with no logos, advertising,
banners, green crosses, or similar insignia.
• Permits and original copy of the National City Business business license(s), alarm permit
and any other permits.
Adequate signage will be posted internally and externally at thecannabisfacility regarding:
• Minimum cash amounts kept on hand
• No Loitering
• Video Surveillance
• Age Verification
• Cannabis purchasing limits
• Warnings of Cannabis use during pregnancy & breast feeding
• Armed Security working on the premises
• Excise and Sales Tax rates
• Illegal to consume Cannabis in public
• Illegal to travel outside the state or board an airplane with Cannabis
• Illegal to operate a motor vehicle under the influence of Cannabis
• Educational Notices
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APPENDIX A
Visitor Log
Store this log in a secured near deliver access point
Security Guard on Duty
Date Time Company Name Verified ID check Signature
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APPENDIX B
Keycard Access Agreement
Store this log in a secured near deliver access point
Date.
Time
Employee. Signature Security officer Signature
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tIite'
Security & Surveillance
PERIMETER SECURITY DESIGN
Perimeter Security poses one of the biggest challenges at this site. Controlled access at the gate
coupled with perimeter security are two points that must be addressed in order to assure security
success.
Ingress/Egress:
To control access to the cannabis site , a single point of entry is placed at the site. All
employees, visitors, vendors, city and state officials/inspectors and other personnel can enter the
main grounds. All personnel must be checked in at the gate. Security cameras will be placed at
the main gate for all activities. All personnel will have a badge that can grant access to the gate.
All non -employees must check in with proper identification. Name/ID/and vehicle plates must be
recorded on a separate log sheet to be stored. Visitors must identify his or her employer and a
placard/card must be placed on the dash for proper identification. All vehicles must park in either
employee or visitor parking spaces and their permit/placard must be displayedat all times. No
long-term parking is granted for extra security. Security guards must maintain perimeter security
(see guard perimeter security procedures in SOP).
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Standard Operating Procedures and Security Plan
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Perimeter Security:
Furnish and install 10 point to point laser beams with 500' max each. All Optex beams are to be
pole mounted with dual laser design to minimize false alarms. All units are to be powered and
armed 24 hours per day with reporting to the security building. Triggers will trigger local sirens
and visual notification at each corner of property.
Photoelectric Detectors Improved with OPTEX Innovation to Provide Advanced Performance in
Outdoor Detection. OPTEX Photoelectric Detectors with Innovative Features for Easy Installation
Provide Stable Performance against False Alarms for More Effective Outdoor Detection and Non
Security Applications. The OPTEX AX-100/200 Photoelectric Detector Series is the next step in
Outdoor Detection and will satisfy all the needs of both users and installers. OPTEX unique
technology and design provide a wide range of functions that greatly simplify installation and
maintain reliable performance even in many adverse weather or environmental conditions.
See cut -sheet.
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Standard Operating Procedures and Security Plan
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Perimeter Security Layout
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Standard Operating Procedures and Security Plan
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Photoelectric detector Smart Line. aeries
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• Current draw 420.M4m -) IPer 1 unit)
• Thermo switch 60'C 1140'F)
DIMENSIONS
.Jest nvnron
Standard Operating Procedures and Security Plan
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
Burglary Alarm system
Designed and submitted by: Martin Samo
The medical cannabis facility shall have an audible interior and exterior security alarm system installed on all
perimeter entry points and perimeter windows, operated, and monitored by a security company licensed by the
department of consumer affairs, bureau of security and investigative services, and approved by the city. "Perimeter
entry points" includes, regardless of size, all doors, windows, hatches and/or points at which systems (such as
HVAC systems) enter a structure
Intrusion and Motion Detection
There will be two (2) redundant alarm systems. The alarm systems must be wired with door contacts, motion
sensors, sirens, keypad and duress/hold-up switches. The alarm panel must be placed in a secure office or
dedicated closet/cabinet. The Alarm system will detect movement in all required areas within the premise when it is
vacant using motion detectors placed throughout the facility.
Burglary Alarm System
A centrally monitored alarm system shall be installed with motion sensors and strikes on all exterior doors as well
as the safe/vault room and will always be maintained and monitored. The system will detect unauthorized entrance
at all potential entry or exit points of the premises. In the event of an intrusion, the alarm system will notify the
central dispatch center that will immediately get in contact with its authorized assignee. If the authorized assignee
can't be reached, local police will be notified and dispatched.
Duress Codes and Panic Procedures
All employees will be assigned a 4 digit "duress" code. In the event of an emergency, such as a threat of violence,
robbery, or employee being coerced into "disarming" the alarm system by an intruder, by entering the duress code,
the alarm system will trigger a "silent" alarm that will dispatch police. Panic buttons can bring 24/7 help in the event
of an emergency, as they enable you to remotely send emergency signals to an alarm system, even if you can't
physically access the control panel. These consist of a single, small button designed to remotely trigger an alarm
and are strategically placed in a discreet and hidden location throughout the facility that, when triggered by staff,
automatically alerts police to an emergency. On duty police in the area will be dispatched to your location
immediately. Triggering a panic button can either sound an "audible" alarm or a "silent" alarm which will depend on
the potential risk scenario at hand.
DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
Access Control System:
Designed and submitted by: Martin Samo
Key Cards/Access Control Locks
All key orders should be properly authorized by an authorized employee, in addition to the key holder, before
issuing. The issuance of keys and/or access control cards to employees will be recorded on a security access log
(Appendix A). Each key will have its own appropriate level of access which will determine which areas of the facility
the employee has permission to enter, access to safes or vaults, and what data can be accessed within the
computer system. The appropriate level key shall be issued lo each individual granting only the appropriate level of
access and shall not be issued by request, but by need. Extra keys and access cards are to be stored in a vault or
safe in the Office. All employees issued a key or access control card will sign a Key/Key Card User Agreement
attesting to their understanding of the procedures (Appendix B). The paper version of the security access log will be
stored in a locked location when not in use. Commercial -grade locks. Note that all points of ingress and egress to
this medical cannabis facility shall ensure the use of commercial -grade, nonresidential door locks and window
locks.
Facility Access by Site Visitors
All vendors, contractors, and visitors must obtain permission to enter the facility 24 hours prior to arrival, and only
authorized visitors will be permitted access to the site. The identity of all visitors must be verified against
government issued identification before they are granted access to the facility and the identification must be verified
electronically or directly by staff security. Upon arrival, all visitors will be issued an identification badge and will
always be escorted by a designated employee.
Visitors and vendors must always be accompanied by an authorized employee when in the facility or when
accessing secure internal locations. The site shall maintain a visitor log documenting all visitors and vendors and
must be retained for a period of no less than 12 months.
No visitors shall be allowed access to storage areas without prior leadership approval, a government issued ID, and
an authorized escort. Visitor Identification Badges Short-term guests, vendors, observers, or other visitors will be
issued a temporary visitor badge approved for use by the facility and will always be escorted. The visitor ID cards
shall be retrieved and secured at the end of the temporary worker's shift. Once the temporary worker or contractor
has completed their assignment, the ID card shall be retrieved and returned lo the Human Resources.
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DocuSign Envelope ID: D1 D5340C-722C-4576-8A3D-8822710C2865
CONCEPT SURVEILLANCE
Designed and submitted by: Martin Samo
SURVAILLANCE MASTER -PLAN
The documents contained in this report will act as the foundation for BJSD's security master -plan that will address
the current and future strategic and physical security characteristics of the synagogue and its community. Its goals
are listed below:
1. Prevent loss of life and minimize injury
2. Protect critical assets
3. Prevent loss of operation
4. Deter criminals and terrorist from acting
5. Reduce liability
6. Enhance long term security for people and assets
Exterior Security Cameras
General notes:
1. Vandal dome style turret w/night vision
2. Cameras capable of 100' plus view w13.66mm lens
3. Rear parking lot building mounted Exterior type
4. Exterior Cameras to be 4MP resolution
Interior Security Cameras
General notes:
1. Vandal dome style w/night vision
2. Cameras capable of 100' plus view w13.66mm, 2.8mm or 12mm lenses
3. Interior Cameras to be 4MP or greater resolution
All cameras to be minimum 1280*720 Pixel resolution
All surveillance storage shall be TCP (transmission control protocol) capable of remote access through Internet.