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VIREO HEALTH INTERNATIONAL, INC. ANNUAL INFORMATION FORM for the Year Ended December 31, 2019 Dated November 23, 2020

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VIREO HEALTH INTERNATIONAL, INC. ANNUAL INFORMATION FORM for the Year Ended December 31, 2019 Dated November 23, 2020 VIREO HEALTH INTERNATIONAL, INC. ANNUAL INFORMATION FORM For the year ended December 31, 2019 Dated November 23, 2020 Marijuana is illegal under U.S. federal law and enforcement of relevant laws is a significant risk. See “Risk Factors”. TABLE OF CONTENTS GENERAL ................................................................................................................................ 3 CAUTIONARY NOTE REGARDING FORWARD-LOOKING STATEMENTS ........................... 3 CORPORATE STRUCTURE .................................................................................................... 6 GENERAL DEVELOPMENT OF THE BUSINESS .................................................................... 7 DESCRIPTION OF THE BUSINESS .......................................................................................10 REGULATORY OVERVIEW....................................................................................................18 RISK FACTORS ......................................................................................................................37 DESCRIPTION OF THE SECURITIES ....................................................................................76 MARKET FOR SECURITIES ...................................................................................................86 DIRECTORS AND OFFICERS ................................................................................................87 PROMOTERS .........................................................................................................................96 LEGAL PROCEEDINGS AND REGULATORY ACTIONS .......................................................96 INTEREST OF MANAGEMENT AND OTHERS IN MATERIAL TRANSACTIONS ..................98 AUDITORS, TRANSFER AGENTS AND REGISTRARS .........................................................98 MATERIAL CONTRACTS .......................................................................................................98 INTEREST OF EXPERTS .......................................................................................................99 OTHER MATERIAL FACTS ....................................................................................................99 ADDITIONAL INFORMATION .................................................................................................99 APPENDIX “A” – GLOSSARY ............................................................................................... A-1 - 3 - GENERAL In this annual information form (“AIF” or “Annual Information Form”), unless the context otherwise requires, the “Company” or “Vireo” refers to Vireo Health International, Inc. together with its wholly-owned subsidiaries. This AIF applies to the business activities and operations of the Company for the year ended December 31, 2019. Unless otherwise indicated, the information in this AIF is given as of the date hereof. Unless otherwise indicated, all references to “$” or “US$” in this AIF refer to United States dollars and all references to “C$” in this AIF refer to Canadian dollars. This AIF includes market and industry data that obtained from third-party sources, including industry publications. The Company believes that the industry data is accurate and that its estimates and assumptions are reasonable, but there is no assurance as to the accuracy or completeness of this data. Third party sources generally state that the information contained therein has been obtained from sources believed to be reliable, but there is no assurance as to the accuracy or completeness of included information. Although the data is believed to be reliable, the Company has not independently verified any of the data from third-party sources referred to in this AIF or ascertained the underlying economic assumptions relied upon by such sources. CAUTIONARY NOTE REGARDING FORWARD-LOOKING STATEMENTS The information provided in this AIF, including information incorporated by reference, may contain “forward-looking statements” about the Company. In addition, the Company may make or approve certain statements in future filings with Canadian securities regulatory authorities, in press releases, or in oral or written presentations by representatives of the Company that are not statements of historical fact and may also constitute forward-looking statements. All statements, other than statements of historical fact, made by the Company that address activities, events or developments that the Company expects or anticipates will or may occur in the future are forward- looking statements, including, but not limited to, statements preceded by, followed by or that include words such as “may”, “will”, “would”, “could”, “should”, “believes”, “estimates”, “projects”, “potential”, “expects”, “plans”, “intends”, “anticipates”, “targeted”, “continues”, “forecasts”, “designed”, “goal”, or the negative of those words or other similar or comparable words. Forward-looking statements may relate to future financial conditions, results of operations, plans, objectives, performance or business developments. These statements speak only as at the date they are made and are based on information currently available and on the then current expectations of the party making the statement and assumptions concerning future events, which are subject to a number of known and unknown risks, uncertainties and other factors that may cause actual results, performance or achievements to be materially different from that which was expressed or implied by such forward-looking statements, including, but not limited to, the following risks and uncertainties: Marijuana remains illegal under U.S. federal law, and enforcement of U.S. cannabis laws could change. There is a substantial risk of regulatory or political change. The Company may be subject to action by the U.S. federal government through various - 4 - government agencies for participation in the cannabis industry. U.S. state and local regulation of cannabis is uncertain and changing. State regulatory agencies may require the Company to post bonds or significant fees. The Company may be subject to heightened scrutiny by United States and Canadian authorities. The Company may face state limitations on ownership of cannabis licenses. The Company may become subject to FDA or ATF regulation. Cannabis businesses are subject to applicable anti-money laundering laws and regulations and have restricted access to banking and other financial services. The Company operates in a highly regulated sector and may not always succeed in complying fully with applicable regulatory requirements in all jurisdictions where the Company carries on business. Because cannabis is illegal under U.S. federal law, the Company may be unable to access to U.S. bankruptcy protections in the event of its bankruptcy or a bankruptcy in an entity in which the Company invests. Because the Company’s contracts involve cannabis and related activities, which are not legal under U.S. federal law, the Company may face difficulties in enforcing its contracts. Because cannabis is illegal under U.S. federal law, cannabis businesses may be subject to civil asset forfeiture. The Company may not be able to secure its payment and other contractual rights with liens on the inventory or licenses of its clients and contracting parties under applicable state laws. The Company may not be able to secure its payment and other contractual rights with liens on the inventory or licenses of its clients and contracting parties under applicable state laws. Because marijuana is illegal under U.S. federal law, marijuana businesses may be subject to civil asset forfeiture. The Company may be subject to constraints on and differences in marketing its products under varying state laws. The results of future clinical research may be unfavorable to cannabis, which may have a material, adverse effect on the demand for the Company’s products. Inconsistent public opinion and perception of the medical recreational use cannabis industry hinders market growth and state adoption. Investors in the Company who are not U.S. citizens may be denied entry into the United States. As a cannabis business, the Company is subject to unfavorable tax treatment under the Code. - 5 - If the Company’s operations are found to be in violation of applicable money laundering legislation and its revenues are viewed as proceeds of crime, the Company may be unable to effect distributions or repatriate funds to Canada. The Company incurred net losses in the three months ended March 31, 2020 and fiscal years 2019 and 2018 with net cash used in operating activities and cannot provide assurance as to when or if the Company will become profitable and generate cash in its operating activities. The Company anticipates requiring substantial additional financing to operate its business and the Company may face difficulties acquiring additional financing on terms acceptable to it or at all. The Company is a holding company and its earnings are dependent on the earnings and distributions of its subsidiaries. The Company’s subsidiaries may not be able to obtain necessary permits and authorizations. Disparate state-by-state regulatory landscapes and the constraints related to holding cannabis licenses in various states results in operational and legal structures for realizing the benefit from cannabis licenses that could result in materially detrimental consequences to the Company. The success of the Company’s business depends, in part, on its ability to successfully integrate
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