Operations Manual

Procedures for the organization, administration, command, and control of the compassion center or licensed cultivator (including but not limited to organizational chart, chain of command protocols, etc.).

Organizational Chart, Chain of Command Documents forthcoming pending advice from legal counsel.

Tracking System

South County Compassion’s Chief Operating Officer will oversee all aspects related to SCC’s use of any tracking system. SCC has opted to utilize LeafLogix Enterprise Resource Planner as our software vendor for purposes of point-of-sale tracking, inventory tracking, and all compliance related information.

The COO will work with department managers to ensure accurate, timely entry of all data into Leaf Logix. Each department manager, and all employees who will be responsible for data entry will be fully trained in appropriate areas of the software’s use by a representative of LeafLogix.

South County Compassion will ensure all employees are trained on the use of the medical marijuana program tracking system for all information related to the acquisition, propagation, cultivation, transfer, manufacturing, processing, testing, storage, destruction, wholesale and/or retail sale of all marijuana and medical marijuana products possessed by South County Compassion in accordance with the Act , which will be kept completely up-to-date in the Medical Marijuana Program Tracking System, including but not limited to:

1. Planting and propagation of plants; 2. Transition of immature to mature plants; 3. Harvest dates with yield documentation; 4. Destructions of immature plants, mature plants and medical marijuana products; 5. Transportation of immature plants, mature plants, and medical marijuana products; 6. Theft of immature plants, mature plants, and medical marijuana

products; 7. Adjustment of product quantities and/or weights; 8. Conversion of product types including waste documentation; 9. Required test results as reported by a cannabis testing laboratory; 10. Retail and wholesale transaction data; 11. Product compliance data; 12. A complete inventory including, but not limited to: a. Batches or lots of useable marijuana; b. Batches or lots of concentrates; c. Batches or lots of extracts; d. Batches or lots of marijuana infused products; e. Immature plants, f. Mature plants; g. Marijuana waste; and 13. Any other information or technical functions DBR deems appropriate

Upon completion of all training, each recipient will sign a statement attesting to receipt of the training and acknowledging the date, time and place he or she received said training, topics discussed, and the name and title of presenters in accordance with Section G.E.3 of the Regulation. Refer to Appendix E for a sample Training Attestation.

Please refer to Appendix A for marketing, training and compliance collateral provided by LeafLogix.

South County Compassion Tracking System Policy:

Upon direction by the DBR and in accordance with R.I. Gen. Laws §§ 21-28.6- 12(g)(3), and 21-28.6-16(d) South County Compassion will utilize the state approved Medical Marijuana Program Tracking System to document and monitor compliance with the Act and all regulations promulgated . South County Compassion will pay costs associated with use of the Medical Marijuana Program Tracking System. - All information related to the acquisition, propagation, cultivation, transfer, manufacturing, processing, testing, storage, destruction, wholesale and/or retail sale of all marijuana and medical marijuana products possessed by South County Compassion and/or distributed to registered cardholders in accordance with the Act will be kept completely up-to-date in Leaflogix, including but not limited to:

■ Planting and propagation of plants; ■ Transition of immature to mature plants; ■ Harvest dates with yield documentation; ■ Destructions of immature plants, mature plants and medical marijuana products; ● Transportation of immature plants, mature plants, and medical marijuana ● products; ● Theft of immature plants, mature plants, and medical marijuana products; ● Adjustment of product quantities and/or weights; ● Conversion of product types including waste documentation; ● Required test results as reported by a cannabis testing laboratory; ● Retail and wholesale transaction data; ● Product compliance data; ● A complete inventory including, but not limited to: - Batches or lots of useable marijuana; - Batches or lots of concentrates; -Batches or lots of extracts; - Batches or lots of marijuana infused products; -Immature plants, -Mature plants; -Marijuana waste; and Any other information or technical functions DBR deems appropriate.

Refer to Appendix A, Leaf Logix Informational Material

Dispensing and Sales Transactions Overview

South County Compassion’s Chief Operating Officer will implement policies and procedures to ensure all dispensing and sales transactions are to registered qualifying patients, primary caregivers, authorized purchasers and verified out-of-state patient cardholders. SCC’s Retail Manager will conduct monthly training of all SCC agents on intake policies and procedures. The Compliance Officer will be responsible for reviewing policies and procedures, training materials, and training attestation forms, ensuring that all materials comply with the regulations. Additionally, the Compliance Officer will audit all records related to dispensing and sales transactions on a monthly basis.

South County Compassion has developed a detailed patient intake procedure which

may be referred to in Appendix C. All patients, regardless of issuing authority of patient ID card will be required to complete all intake forms prior to utilizing SCC’s services.

South County Compassion Dispensing and Sales Transactions Policy:

South County Compassion’s sales to qualifying patients or authorized purchasers, are only permitted if those qualifying patients or authorized purchasers are registered and compliant with R.I. Gen. Laws Chapter 21-28.6 entitled, “The Edward O.Hawkins and Thomas C. Slater Medical Marijuana Act,” as amended and all regulation promulgated thereunder. Only marijuana products that have been designated as medical marijuana in accordance with § 1.7 of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation may be sold or distributed. For such sales, South County Compassion will be strictly bound by the dispensing limits set forth in R.I. Gen. Laws § 21-28.6-12(g).

Sales to Out-of-State Patients

South County Compassion may conduct sales to out-of-state patient cardholders in accordance with R.I. Gen. Laws § 21-28.6-4(o), provided the receiving or purchasing patient has a valid medical marijuana card, or its equivalent, which has been issued by the applicable regulating authority for the medical marijuana program of the issuing U.S. state/jurisdiction/territory. The patient must also possess and present valid government issued identification matching the name on their medical marijuana card.

Each patient verified pursuant to § 1.6.3(E)(2)(a) of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation, shall complete an intake form (upon a form acceptable to DBR) which includes at minimum the home state card registration number (or if the home state registration number is not available, a unique identifier assigned by South County Compassion).

South County Compassion will log and track all transactions with each out-of-state patient cardholder in the Medical Marijuana Program Tracking System according to the issuing state’s patient card registration number or the unique identifier assigned to that person by South County Compassion.

Out-of-state patient information shall be maintained confidentially in accordance with § 1.6.6(D)(2) of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation .

South County Compassion will provide each out-of-state patient cardholder with a notice regarding the requirements and prohibitions under the Act and any regulations promulgated thereunder that apply to dispensing and use of medical marijuana within the State of Rhode Island, including without limitation notice of medical marijuana dispensing and possession limits, prohibition of taking medical marijuana and medical marijuana products across state lines and

prohibition of smoking in public places.

Sales for delivery to a qualifying patient cardholder’s residence are deemed permitted provided that such sales comply with § 1.6.9 of this Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation

Reference Appendix C - Patient Intake Procedure

Limits for Usable Marijuana and Marijuana Product Equivalency Limits

South County Compassion will utilize an industry leading seed-to-sale software solution which allows for limit setting by administration on the backend. South County Compassion will set the purchase limits to the limits set by the Act, 2.5 ounces in any 15 day period. All products entered into the seed-to-sale system will be assigned a flower equivalent according to Part 1.14 of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation. Scanning of items will remove allotment from the individual patients’ limit accordingly. The seed-to-sale system will not allow a sale to be completed if the sale would be in excess of limits set in the system.

The following equivalency table will be used by South County Compassion to ascertain whether the amount of various forms of marijuana is compliant with the dried usable possession limits set forth in the Act and the DBR Regulations. “Single serving unit” as used in the below table means no more than 10 mg of THC per single serving unit.

Marijuana Flower Weight Equivalent Number of 10mgs of THC Single Serving Units

5 ounces 415 THC single serving units

2.5 ounces 125 THC single serving units

1 ounce 83 THC single serving units

.25 ounces 21 THC single serving units

1 gram 3 THC single serving units

Marijuana Flower Weight Equivalent grams of Concentrate

5 ounces 38.5 grams

2.5 ounces 19.25 grams

1 ounce 7.7 grams

.25 ounces 1.9 grams

1 gram 0.3 grams

Wet Flower Weight Dry Flower Weight (20% of Wet Flower Weight

50 ounces 10 ounces

37.5 ounces 7.5 ounces

25 ounces 5 ounces

12.5 ounces 2.5 ounces

Voluntary and Involuntary Recalls

DBR or DOH may require South County Compassion to recall any marijuana or marijuana product that it has sold or transferred upon a finding that circumstances exist that pose a risk to public health, safety and welfare.

a. The recall will be initiated by South County Compassion immediately as determined by their approved recall plan; and b. South County Compassion will comply with any additional instructions made by DBR.

A recall may be based on, without limitation, evidence that the marijuana,marijuana product, or medical marijuana product: a. Contains unauthorized pesticide(s);

b. Failed a mandatory test and was not mitigated pursuant to testing protocols; c. Is contaminated or otherwise unfit for human use, consumption or application; d. Is not properly packaged or labeled; e. Was not cultivated, processed or manufactured by a licensee or otherwise is not in accordance with the The Edward O. Hawkins and Thomas C. Slater Medical Marijuana Act, as amended, DBR regulations or DOH regulations; or f. Otherwise poses a threat to public health or safety as determined by DBR or DOH.

DBR may at any time require the destruction of medical marijuana product or marijuana product upon a finding that circumstances exist that pose a risk to public safety and health.

If DBR finds that a recall is required, DBR: a. Must notify the public and licensees of the recall; b. Must affect an administrative hold on all affected medical marijuana and/or medical marijuana products in the tracking system; c. May require South County Compassion to place all marijuana, marijuana product, medical marijuana and medical marijuana product in quarantine itself or with a third-party custodian at SCC’s expense. d. May require South County Compassion to notify all individuals to whom such medical marijuana or a medical marijuana product was sold; and e. May require that South County Compassion destroy the recalled product.

Refer to Appendix E: Recall Plan

Product Inspection, Quarantine Protocols and Procedure

South County Compassion takes care to ensure that all medical marijuana and medical marijuana product inventory is effectively and compliantly managed. SCC’s Inventory Manager will conduct training with all SCC agents on the inspection of cannabis products and identification of adulterants. SCC Inventory Specialists will be responsible for the inspection of products upon intake and monitoring of product quality and expiry dates throughout the batch’s life cycle. During the intake process, care will be exercised throughout visual inspection. All marijuana and marijuana products will be assigned an

expiry date in the Medical Marijuana Program Tracking System, which will be monitored daily to prevent selling of expired or outdated products. Additionally, throughout storage and sale, products will be visually inspected for signs of deterioration or aging.

Guidance for ensuring the prevention of the entrance of defective and/or contaminated cannabis flower or products/materials into South County Compassion facilities is as follows: a. Receipt procedures 1. All marijuana and marijuana products, upon entry to any SCC facility must be retained in the designated receiving area depending on the size and nature of the delivered item. 2. The employee(s) receiving the delivered item must confirm that the transportation manifest details match the delivery physically received. 3. The employee receiving the delivered item must notify the manager of the receiving department that the delivered items have been received. b. Inspection for defects 1. The employee receiving the delivered item must initiate a visual inspection of all surfaces of the package, container or material. 2. The employee receiving the delivered item must conduct a visual determination that the package, container or material is either damaged, or not, by inspecting all visible exterior surfaces of the package, including any and all tamper-evident seals. 3. If the delivered item has a noticeable area of damage, or if tamper-evident seals have been broken or tampering is suspected, the department manager must conduct an inspection of the delivered item to determine whether the item is usable or not. 4. if the delivered item is deemed ‘not usable’ a warning sticker will be placed on the item and the manufacturer/wholesaler will be notified of the pending return. 5. Product deemed ‘not usable’ will be segregated and stored in a container separate from usable marijuana and marijuana products and placed into quarantine in accordance with the Regulations. Inspection for contaminants SCC will assume that any package or container entering our facility from outside is contaminated to a certain degree, at least on the exterior surfaces of the package, given that sterility is not maintained during routine shipping practices.

1. All packages and containers may be treated with a spray disinfectant and sponge to remove any visible contamination depending on the destination of the item. Office supplies will be treated differently than sterile cotton swabs, for example. 2. Each package or container will have a predetermined destination within the facility and will be transported there after being treated. Materials or products destined to be brought in be removed from any exterior packaging and inspected again to ensure there is no contamination of the material or product. 3. Packages, containers or materials that contain holes, tears, or other damage permitting exposure to the exterior will be temporarily quarantined until a manager had an opportunity to examine the package to determine whether it is useable or should be returned. 4. All marijuana and marijuana products will undergo a thorough visual inspection for any signs of adulteration, such as pest activity, fungal or bacterial growth, etc. 5. SCC will adhere to all forthcoming testing regulations released by the OCR or DOH In the event that marijuana or marijuana product(s) are found to be outdated, damaged, deteriorated, mislabeled, or contaminated, SCC will immediately quarantine the marijuana or marijuana product(s) from other marijuana, and destroy the marijuana or marijuana product(s) in accordance with the Regulations.

Quarantine procedure: ● SCC will maintain an area for storage of quarantined medical marijuana or medical marijuana products, in a physically separate area clearly identified for such use ● Products may be deemed fit for quarantine and/or destruction should the product be found to be outdated, damaged, deteriorated, mislabeled, or contaminated. ● Quarantined products will be placed in sealed containers and clearly marked with labels that state “QUARANTINED - DO NOT SELL”. Quarantined products will be stored by either South County Compassion or with a third party custodian at SCC’s expense. ● Quarantined products will be held until further direction is given by DBR to either retest, remediate, or destroy the quarantined product(s).

South County Compassion Safe Disposal of Medical Marijuana Waste and Safe Destruction of Usable Medical Marijuana

South County Compassion’s Compliance Officer will ensure that the disposal of medical marijuana waste and destruction of usable medical marijuana are performed in compliance with the Regulations. Marijuana and marijuana product waste,including but not limited to, all liquid,

chemical, hazardous, pesticide, manufacturing solvent and chemical waste containing any traces of marijuana) will be stored, secured, and managed in accordance with all applicable federal, state, and local statutes, regulations, ordinances, or other legal requirements.

Prior to disposal, marijuana and marijuana product waste will be made unusable and any marijuana plant material made indistinguishable from other plant material. This will be accomplished by grinding and incorporating the marijuana plant waste with other non-consumable solid waste or other ground materials, so the resulting mixture is at least 50% non-marijuana waste by volume. Other methods to render marijuana waste unusable will be approved by DBR before implementing. Marijuana waste rendered unusable following an approved method may be delivered to a licensed solid waste disposal facility in Rhode Island for final disposition or disposed of in an alternative manner approved by DBR. C. Destruction of marijuana and marijuana materials other than waste generated in the regular course of processing and/or manufacturing (such as destruction of whole plants, wet, or usable marijuana that are found to be in excess of statutory possession limits or destruction of a contaminated batch of medical marijuana product) will be in a manner acceptable to DBR, which may include consultation with law enforcement.

Destruction of marijuana and marijuana materials upon revocation or abandonment of the license will be specifically governed by DBR order or agreement and/or coordinated efforts with law enforcement.

South County Compassion will maintain accurate and comprehensive records regarding waste material that accounts for, reconciles, and evidences all waste activity related to the disposal of marijuana and marijuana products (including any waste material produced through the trimming or pruning of a marijuana plant prior to harvest). DBR may mandate storage of any such records or summaries of such records to be through the Medical Marijuana Program Tracking System or any other electronic system DBR designates.

All actions in compliance with § 1.6.16 of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation must comply with any applicable DEM laws, regulations or policies.

Records retention policies

Personnel Records

● South County Compassion will maintain a personnel record for each employee, agent or volunteer for a period of at least one (1) year after termination of the individual’s affiliation SCC. Each personnel record will contain the following minimum documentation and information:

○ An application for employment or to volunteer or offers to provide services as an agent. ○ An employment or engagement description detailing duties, responsibilities, authority, qualifications and supervision. ○ If applicable, a copy of any employment or engagement contract, including salary or compensation terms, or for volunteers, volunteer agreement. ○ A record of any disciplinary action taken. ○ Documentation of all required training, which shall include a signed statement from the individual indicating the date, time and place he or she received said training, topics discussed, and the name and title of presenters. ○ South County Compassion will maintain a current list of all cardholders associated with SCC ● Additional Records to be Maintained ○ In addition to all other specific record-keeping requirements of the Act, the DBR Regulations, and the DOH Regulations, South County Compassion will maintain the following records for a minimum of five (5) years: ■ All contracts and purchase orders, including documentation of any cancelled contracts or purchased orders and any contracts and purchase orders voided by replacement contracts. ■ Invoices and any supporting documentation of all marijuana purchases, acquisitions, transfers, and payments. ■ Contracts pertaining to the security alarm and security camera systems. ■ Contracts with vendors, including any approved third-party testing providers. ■ All records normally retained for tax purposes. ■ Complaints. ■ Management contracts. ■ Compensation records and financial statements. ■ Nonprofit corporate records including, but not limited to articles of organization, bylaws, meeting agendas, minutes and corporate resolutions.

All records maintained by South County Compassion which pertain to one or more registered qualifying patients, registered primary caregivers or authorized purchasers will be:

● Considered confidential health care information under applicable Rhode Island

law; and ● Protected as health care information in accordance with the Federal Health Insurance Portability and Accountability Act of 1996, as amended.

Records Storage and Responsibility for Loss of Records and Data

○ Records pertaining to transactions occurring within the last six (6) months shall be stored on the licensed premises. Records dating further back may be stored off the premises with DBR’s approval. ○ South County Compassion will exercise due diligence and reasonable care in preserving and maintaining all required records to guard against loss of records and data, including cybersecurity of electronically-maintained records.

Ethics and Compliance policies.

See Appendix H - Ethics and Compliance Policy

Alcohol and drug free workplace policy

Drug and Alcohol Policy

The use of illegal drugs and alcohol misuse by employees are inconsistent with South County Compassion’s commitment to maintain a safe, healthy, and productive work environment and a drug-free workplace. Illegal drugs are controlled substances that are not being used or possessed under the supervision of a doctor or other licensed health care professional. Information about the dangers of drug abuse and alcohol misuse in the workplace, sources of help for drug and alcohol problems, this policy, and the consequences that may result from violations of this policy, is available from Human Resources.

Work Rules

South County Compassion prohibits:

The use, unauthorized distribution, unauthorized manufacture, unauthorized transfer, unauthorized sale, unauthorized purchase or unauthorized possession of any controlled substance, illegal drug, intoxicant, drug paraphernalia or alcohol, or the improper use of prescription medication while on South County Compassion premises or work sites, using South County Compassion property –

including SCC vehicles and private vehicles parked on South County Compassion premises or work sites – or at any time while conducting South County Compassion business (except alcohol available at South County Compassion-sponsored functions with the approval of Management)

Employees from reporting to work or performing their duties while under the influence of a controlled substance or alcohol, or while abusing prescription medication.

This policy does not prohibit employees from the lawful possession and responsible, safe use of prescribed medications. Employees have the responsibility to consult with their doctors or other licensed health care professionals about the effect of prescribed medications on their ability to perform their specific job duties in a safe manner, and to promptly disclose any work restrictions to their supervisors or Human Resources. Employees should not, however, disclose underlying medical conditions, impairments or disabilities to their supervisors or Human Resources unless specifically directed to do so by their doctors or other licensed health care professionals.

Voluntary Requests for Assistance

Employees with drug and alcohol problems are encouraged to seek help before they become subject to discipline for violating this or other South County Compassion policies. South County Compassion will support, assist, and accommodate such employees to the extent required by applicable law. Human Resources can assist employees in a confidential manner, by referring them to the Employee Assistance Program, providing them with information about other community resources for evaluation, counseling, and treatment and helping them utilize any available employee benefits. Employees will not be disciplined by the South County Compassion because they request assistance. Employees may not, however, escape discipline by requesting assistance after they violate the South County Compassion’s policies. In addition, employees who request assistance will not be excused from complying with the South County Compassion’s policies, including its standards for employee performance and conduct.

Consequences

Employees who violate this policy will be subject to appropriate disciplinary

action up to and including termination of employment. Depending on the circumstances, an employee’s return to work, reinstatement and/or continued employment may be conditioned on the employee’s successful participation in and/or completion of any and all evaluations, counseling, treatment, and rehabilitation programs, passing of return-to-duty and follow-up drug and alcohol tests, and/or other appropriate conditions as determined by the South County Compassion.

Testing

South County Compassion reserves the right to conduct reasonable suspicion and other drug and alcohol tests in accordance with the requirements of applicable law.

Reporting Convictions

Employees who are convicted of, plead guilty to (including a plea of nolo contendere or no contest), or are sentenced for a crime involving illegal drugs must report the conviction, plea or sentence to Management within five (5) days after such conviction, plea or sentence. If an employee who is convicted of, pleads guilty to or is sentenced for a crime involving illegal drugs performs work directly relating to the South County Compassion’s contracts, permits, or grants with a state or the federal government, the South County Compassion will report such conviction, plea or sentence to the appropriate agency within ten (10) days after it receives notice.

Employee Assistance Program

When there is reason to believe that an employee has a substance or alcohol abuse problem that interferes with his or her ability to perform the essential functions of the job, the South County Compassion may, at its discretion, refer the employee to the Employee Assistance Program for counseling or to a substance abuse rehabilitation facility, as appropriate. An employee’s refusal to comply with recommendations to seek assistance may be further grounds for disciplinary action, including termination of employment, consistent with applicable law.

Odor Control and Mitigation

All South County Compassion cultivation, manufacturing, packaging and any

other area(s) deemed necessary by DBR will have ventilation and filtration systems installed that prevent medical marijuana plant odors from exiting the interior of the structure to an extent that would significantly alter the environmental odor outside, while addressing the potential for mold.

The ventilation and filtration system, along with any plumbing improvements, shall be installed in compliance with all applicable codes and ordinances, including obtaining any necessary permits, and inspected by the municipality.

Measures to assure compliance with this section shall be documented in an odor control and mitigation plan acceptable to DBR.

Refer to Appendix F - Odor Control and Mitigation Plan

Pesticides

South County Compassion’s Chief Operating Officer will implement policies and procedures related to the use of pesticides by any SCC agent or employee. SCC’s Compliance Officer will ensure all policies, procedures, trainings, and materials are in compliance with the Regulations. No pesticides will be purchased or used without explicit written approval by both SCC’s COO and Compliance Officer. SCC’s Head Grower will oversee the training of employees in the compliant application of pesticides. All employees receiving training surrounding the use or application of pesticides will be required to sign an attestation in line with SCC’s training policies and procedures. No employees will be given access to areas where pesticides are stored without proper training and documentation in accordance with this policy.

South County Compassion will maintain strict compliance with Policies and Procedures for pesticide use requirements for compassion centers promulgated by the Department of Business Regulation pursuant to R.I. Gen Laws 21-28-6-12(f)(11) and21-28.6-16(g).

South County Compassion’s cultivation processes will use best practices to limit contamination of medical marijuana and marijuana products, including but not limited to mold, mildew,fungus, bacterial diseases, rot, pests, pesticides, and any other contaminant identified as posing potential harm.

The use of pesticides on marijuana plants in Rhode Island by South County Compassion will not

be considered a violation of these regulations provided that the products satisfy all of the following criteria:

● The product must be a “minimum risk pesticide” under 40 C.F.R. §152.25(f), incorporated above at § 1.1.7(C) of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation ● The product must be labelled for use on all plants, other plants, bedding plants, unspecified plants, or unspecified crops. ● The label must not prohibit indoor or greenhouse use, as applicable. ● All active ingredients must be eligible for food use as determined by the federal Environmental Protection Agency’s list of (EPA) Active Ingredients Eligible for Minimum Risk Pesticide Products, incorporated above at § 1.1.7(D) of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation . https://www.epa.gov/sites/production/files/2015-12/documents/minrisk-active-ingredients -tolerances-2015-12-15.pdf ● All inert/other ingredients must be eligible for food use in accordance with EPA’s Inert Ingredients Eligible for FIFRA 25(b) Pesticide Products, incorporated above at § 1.1.7(E) of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation.https://www.epa.gov/sites/production/files/2016- 11/documents/minrisk_inert_ingredients_w_tolerances_2016-11-16.pdf. ● The product must be a currently registered pesticide product eligible for sale in Rhode Island as determined by DEM. To verify a product’s registration in Rhode Island, please consult the online National Pesticide Information Retrieval System through the Center for Environmental and Regulatory Information Systems. http://npirspublic.ceris.purdue.edu/state/state_menu.aspx?state=RI. ● The product must be used in accordance with any and all use instructions on the label.

No application of pesticides shall be made after the vegetative stage of growth of the cannabis plant. The vegetative stage of growth should be determined by visual buds or flower or by proxy of the plant receiving less than eighteen (18) hours of light in a twenty-four (24) hour period.

Pesticides will be identified, held, stored and disposed of in a manner that protects against contamination of medical marijuana and marijuana products and in a manner that is in accordance with any applicable local, state, or federal law, rule, regulation, or ordinance.

As a DBR record-keeping requirement, South County Compassion will keep detailed records of any pesticide products used and application regiments, including video recording during pesticide applications which must cease if there is a failure or disruption of the video surveillance system. This record-keeping requirement is independent of that required of commercial pesticide applicators by DEM and is intended to apply in addition to that

requirement, where relevant.

Outreach Activities

South County Compassion recognizes the importance of patient outreach and the pivotal role that it plays in patient education and the continued expansion of the medical marijuana program in Rhode Island. As such, SCC will maintain a public presence, performing outreach activities in the community on a regular basis. SCC’s Patient Services Manager will be responsible for identifying outreach opportunities, booking the outreach activities themselves, and ensuring proper representation on SCC’s behalf. SCC’s Compliance Officer will ensure that all patient outreach, activities, and materials are compliant with the Regulations.

SCC will provide each patient who visits the dispensary with a patient handbook, which will include information about the Program, legal limits in terms of possession and purchasing, information about SCC’s products and services, and a journal to allow patients to document their experience with SCC’s products.

South County Compassion Patient Outreach Policy:

South County Compassion’s outreach activities to registered qualifying patients, registered primary caregivers, and authorized purchasers will, at a minimum, include:

● Providing each new registered qualifying patient who visits South County Compassion with a frequently asked questions sheet that explains the limitations on the right to use medical marijuana under state law in accordance with R.I. Gen. Laws § 21-28.6-12(f)(9); ● Providing a list of ingestion options for usable marijuana; ● Providing applicable usage techniques and any corresponding safety information to registered qualifying patients; ● Communicating potential side effects; and ● Upon the request of DOH and/or DBR, e-mailing or otherwise disseminating information to SCC clients regarding changes in the medical marijuana program, or disseminating customer surveys.

Appendix G - Patient Handbook

Complaints

South County Compassion takes patient complaints - and customer satisfaction - seriously. SCC has standardized our complaint format, in order to offer options across multiple media and compile data in real-time for quick review. Our complaint forms will collect the following information:

Date of Purchase Product Name Product SKU/Package ID Details

Hard printed copies of our complaint form will be available at our sales counter for patients to access and return at their convenience. SCC will also store hard copies at the patient services desk for complaints received orally or via phone. In order to protect individual identities, SCC will provide a digital copy of the form on our website.

All data will be aggregated in a digital format and reviewed by SCC management weekly. All complaints will be responded to in a direct and timely manager by SCC management. In the event that a complaint could possibly merit a recall due to reasonable concern for public health and safety, the complaint may be taken to appropriate levels of management immediately on a case-by-case basis.

Safe Dispensing of Medical Marijuana

South County Compassion takes patient identification and validation seriously. Only patients, caregivers, and authorized purchasers who display a valid, unexpired, state-issued identification, as well as a valid medical marijuana license will be permitted into SCC’s facilities.

South County Compassion’s sales to qualifying patients, directly or through their caregivers or authorized purchasers, are only permitted if those qualifying patients, caregivers, or authorized purchasers are registered and compliant with R.I. Gen. Laws Chapter 21-28.6 entitled, “The Edward O.Hawkins and Thomas C. Slater Medical Marijuana Act,” as amended and all regulation promulgated thereunder. Only marijuana products that have been designated as medical marijuana in accordance with § 1.7 of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation may be sold or distributed. For such sales, South County Compassion will be strictly bound by the dispensing limits set forth in R.I. Gen. Laws § 21-28.6-12(g).

Sales to out-of-state patients

Reference Appendix C - Patient Intake Procedure

Packaging and Labeling

South County Compassion will maintain strict compliance with retail-ready marijuana product packaging and labeling requirements for compassion centers promulgated by the Department of Business Regulation pursuant to R.I. Gen Laws

21-28-6-12(f)(11) and21-28.6-16(g). It is South County Compassion’s responsibility to ensure all medical marijuana products are retail-ready prior to sale to a qualifying patient,registered primary caregiver or authorized purchaser.

SCC recognizes the importance of compliant, safe retail marijuana packaging. SCC’s Chief Operating Officer will be responsible for all functions related to packaging and labeling. SCC’s Compliance Officer will work in tandem with the COO to ensure that all requirements of the Regulations are adhered to. SCC’s Inventory Compliance Manager will ensure all retail-ready marijuana products received through wholesale purchasing meet all packaging and labeling requirements.

SCC’s Packaging and Labeling Manager will oversee the Packaging and Labeling Department, ensuring that all internally packaged retail-ready marijuana products meet all packaging and labeling requirements. Retail-ready marijuana products will be inspected prior to addition to SCC’s product menu. All SCC employees will be trained in packaging and labeling requirements prior to commencing regular duties, in line with SCC’s Training Procedures, outlined in Appendix D.

In the case that any retail-ready marijuana products are found to be out of compliance with the packaging and labeling requirements of the Regulations, SCC will immediately quarantine the entirety of the batch that is affected. If the affected batch was purchased from a Cultivator, SCC will either return the product to the Cultivator or remedy the packaging and labeling issues accordingly. If the affected batch is SCC in-house product, SCC will remedy the packaging and labeling issue prior to commencing retail sales of the batch. If any mislabeled or improperly packaged product is sold by SCC, SCC will immediately notify DBR through appropriate channels.

Packaging ● SCC will ensure all retail-ready medical marijuana products are in compliant packaging upon entering the compassion center retail sale space. ● Any packaging containing retail-ready medical marijuana will: 1. Be opaque, of a neutral color, and light resistant. Neutral colors include but are not limited to: black, white, gray, beige, brown, and tan. These colors will not include primary and secondary colors (exp. Red, orange, yellow, green,blue, or purple) or any variant of primary or secondary colors.

2. Fully enclose the product; 3. Protect the product from contamination 4. Not impact any toxic or deleterious substance to the medical marijuana product 5. Be Child Resistant as defined in 1.1 of Part 1- Rules and Regulation Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation. 6. Be able to be resealed in a Child Resistant manner unless the package contains a single-serving medical marijauan edible or ingestible pursuant to 1.5.2(D) and(E) of the Rules and Regulation Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation. ● Exit Package 1. Except for medical marijuana edibles and ingestibles, upon DBR approval, any other retail-ready medical marijuana product placed into a container that is not child-resistant will be placed into a child- resistant Exit Package at the point of sale. ● Additional Requirements for South County Compassion Retail-Ready Medical Marijuana Edibles 1. A single serving size will not exceed ten (10) milligrams of active THC. 2. When selling an individual single serving size unit, we will place the unit into a child-resistant container. 3. Multiple single serving units will be placed together into a single child resistant and resealable package only when the active THC per package does not exceed one hundred (100)mgs. 4. Multiple packages will be bundled and sold together only if: A. Total amount of THC per serving unit does not exceed ten (10) mgs. B. Total amount of THC per package does not exceed one hundred (100) mgs; and C. Total amount of THC per bundled package does not exceed the maximum amount a patient can possess pursuant to the Act and the equivalency table in 1.14 of Rules and Regulation Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation. 5. We will seal Medical Marijuana edibles in liquid form packaged as a singles serving size using a metal crown cork style bottle cap.

6. For Medical Marijuana Edibles in liquid form containing multiple serving units, the container will have a resealing cap or closure which maintains child resistance compliance.

7. Medical Marijuana Edibles in liquid form containing multiple serving units will include a measuring device such as a measuring cap, cup or dropper with the package containing the medical marijuana product.

E. Packaging Requirements for South County Compassion Medical Marijuana Ingestibles 1. When a single serving unit of a Medical Marijuana Ingestible is sold individually , it will be placed into a child resistant container. 2. Multiple single serving units placed together will be put into a single child resistant and resealable package. 3. Multiple packages to be bundled and sold together will have a total THC per bundled package that does not exceed the maximum amount a patient can possess pursuant to the Act and the equivalency table in 1.14 of the Rules and Regulation Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation. 4. For Medical Marijuana Ingestibles in liquid form packaged as a single serving unit, the container will be sealed using a metal crown cork style bottle cap. 5. For Medical Marijuana Ingestibles in liquid for with multiple serving units, the container will have a resealing cap or closure. 6. All Medical Marijuana ingestibles in liquid for with multiple serving units will include within the packaging : ● A measuring device such as a measuring cap, cup or dropper that is capable of dispensing a ten(10)mg serving unit ● A “Hash Mark” on the package will not be used as a measuring device Additional Packaging Requirements for Retail Ready Medical Concentrates for SCC ● Cartridges and any other devices, as determined by the DBR, shall receive a consumer testing certificate which is subject to DBR review. ● Electronic vaporization devices will have internal and external temperature controls to prevent combustion and have heating elements made of inert material. ● The total THC per package will not exceed 500 mgs.

Labeling Requirements for SCC 1. Each package containing retail ready medical marijuana products at SCC will be labeled with all required information pursuant to 1.5 of Rules and Regulation Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation before being sold to a registered patient, registered primary caregiver or authorized purchaser. 2. Labeling text will be:

● No smaller than size 6 font, unless otherwise specified. ● In Times New Roman, Calibri, Arial, Helvetica or any other font determined by DBR to be easily read. ● In black or white, unless otherwise specified. ● Clearly written or printed in the English language. ● In addition to the required English label, SCC may include an additional, accurate foreign language translation on the label that otherwise complies with these rules. 3. All required information will be unobstructed and conspicuous. When multiple labels are affixed to the packages none of the information required will be obstructed. 4. Required information may be stated in a peel-back accordion, expandable, or extendable style so long as the label can be easily identified by a consumer as containing important information. 5. All packages containing retail-ready medical marijuana products will be clearly labeled with the following information: ● The business(s) or tradename(s) and licenses number(s) of the licensee(s) who produced the product; ● South County Compassion or any trade name developed and our license number of SCC. ● The unique identifier generated by the Medical Marijuana Program Tracking System; ● Total THC and Total CBD as provided by a licensed cannabis testing laboratory ; ● Upon request, SCC will disclose the name of the licensed cannabis testing lab that conducted the tests and provide the results of all required tests for any medical marijuana or medical marijuana product. ● A DBR- selected universal warning symbol will appear on the front or most predominantly displayed area of the package, no smaller than one inch (1)by one inch (1). ● Any Vape cartridges sole containing medical marijuana product will include the DBR-approved symbol in a manner that is clear and conspicuous; ● When applicable, the recommended expiration date, or “use by”date; ● Poison Control Contact Information :”American Association of Poison Control Center (800)222-1222” ● For smokable and vapable products; the net weight of the medical marijuana product prior to its placement in the package, using a standard of measure compatible with the tracking system. 6. Additional Labeling Requirements for Retail-Ready Marijuana Infused Products for SCC: A.The total contents of THC and CBD will be stated per serving unit in milligrams (mgs), and in font larger than size 6, bolded, underlined and in red, so as to stand from surrounding text to the customer;

B. Total contents of THC and CBD must be stated per package, in milligrams (mgs), in font larger than size 6, bolded, underlined and in red, so as to stand from surrounding text to the customer;

C. The serving size; and

D. The number of servings per package. 7. The following information may be placed on an insert but will accompany each retail-ready medical marijunana product sold: A. A complete list of all non organic pesticides, herbicides, and fertilizers that were used in the cultivation and production of the medical marijuana product; B. For medical marijuana infused products, the net weight of the medical mairjuana or medical marijuana product prior to its placement in a package,using a standard of measure compatible with the tracking system; C. For the medical marijuana products consisting in whole or impart of marijuana flower or trim, the date of the harvest batch; D. For medical marijuana products including concentrates and marijuana infused products that were manufactured, the date on which the manufacturing batch was created; E. For the processed medical marijuana products, the processing technique or solvent(s) used to produce the product; F. For processed medical marijuna products, a list of all chemicals, diluents, additives, ingredients and/or excipients used to produce the medical marijuana product or that were added to the medical marijuana product; G. For medical marijuana infused products, a list of all ingredients used to manufacture the marijuana infused product, including identification of any major allergens contained in the product in accordance with the Food Allergen Labeling and Consumer Protection Act of 2004, 21 U.S.C. § 343 (2010), specifically milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat and soybeans; H. For medical marijuana edibles and ingestibles, a nutritional fact panel in accordance with 21 C.F.R. Part 101, incorporated above at § 1.1.7(B) of compassion centers promulgated by the Department of Business Regulation pursuant to R.I. Gen Laws 21-28-6-12(f)(11) and21-28.6-16(g) I. For medical marijuana topicals, a list of all ingredients in descending order of predominance by weight or volume as applicable; and J. For medical marijuana topicals, the amount recommended for use at any one time.

Universal Symbol

As directed by DBR, unless deemed impracticable by DBR, each single a standardized serving unit of a medical marijuana infused product will be marked, stamped or otherwise imprinted with a DBR-selected universal symbol directly on at least one side of the medical marijuana infused product in a manner to cause the universal symbol to be distinguishable and easily recognizable. The universal symbol marking will:

1. Be centered either horizontally or vertically on each standardized serving

of marijuana; and

2. If only imprinted on one-side, the imprinted side must be the front or most

predominantly displayed area of medical marijuana infused product; and

3. If centered horizontally on a serving, the height and width of the universal

symbol shall be of a size that is at least 25% of the serving’s width, but not less than 1⁄4 inch by 1⁄4 inch; or

4. If centered vertically on a serving, the height and width of the universal

symbol will be of a size that is at least twenty-five percent (25%) of the serving’s height, but not less than 1⁄4 inch by 1⁄4 inch.

Unless determined by DBR to be impractical, the following categories of marijuana infused product are considered to be per se practicable to mark with the universal symbol: ● Chocolate; ● Soft confections; ● Hard confections or lozenges; ● Consolidated baked goods (e.g. cookie, brownie, cupcake, granola bar) ● Pressed pills and capsules.

WARNINGS ● We will maintain strict compliance with Warnings on all retail-ready medical marijuana (and products) requirements for compassion centers promulgated by the Department of

Business Regulation pursuant to R.I. Gen Laws 21-28-6-12(f)(11) and21-28.6-16(g). It is South County Compassions responsibility to ensure all retail ready medical marijauna products:

1. Be in the English language;

2. Be in Times New Roman, Calibri, Arial, Helvetica or any other font that

can be easily read;

3. Be in text no smaller than size 8 font and bolded;

4. Not be covered or obscured; and

5. Be displayed in a bright yellow box as to stand out from other labeling

requirements, unless otherwise stated.

The following warnings will be displayed on all medical marijuana products at SCC, when applicable; ● “Warning: For Medical use ONLY. This product contains marijuana. Store in a securely locked cabinet away from children.” ● “Warning: It is unlawful to transport this product outside of Rhode Island.” ● “Warning: For medical use by a registered patient only. Not for resale.”

For medical marijuana products intended to be smoked or vaporized: ● “Warning: Smoking and Vaping is hazardous to your health.” ● “Warning; Vaping can expose you to toxic chemicals that may lead to death”.

For all medical marijuana infused products, it must state in slightly larger

or bolded font as to stand out from surrounding text, with priority placement, ● “Effects of this product may be delayed by 3 or more hours.”

For all topical products, it must state: ● “For Topical Application – Do Not Eat or Smoke.”

-In addition to the warnings above, rotating warnings must accompany all retail- ready medical marijuana products at the point of sale.

Rotating warnings will: ● Be in the English language; ● Be in Times New Roman, Calibri, Arial, Helvetica or any other font that can be easily read; ● Be in text no smaller than size 10 font and bolded; and ● Not cover or obscure any required information pursuant to § 1.5 of Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation. ● Accompany all retail-ready medical marijuana products at the point of sale based on a rotating schedule as determined by DBR.

South County Compassion will post any additional warnings at the point of sale as determined by DBR.

See Appendix I - Examples of Proposed Packaging

SCC Protocols and Policies for Transportation of Medical Marijuana Product

South County Compassion intends to regularly transport medical marijuana products. SCC will transport medical marijuana while performing home delivery services, as well as in the process of obtaining wholesale products from Cultivators licensed by the Department of Business Regulation located within the state, or transporting products from SCC’s production facility. SCC recognizes the importance of safety and security throughout the transportation process, and has developed policies and procedures with these points in mind.

SCC’s Compliance Officer will oversee all aspects of transportation. SCC’s Chief Operating Officer will work in tandem with the Compliance Officer to ensure that all transports are handled in a safe and compliant manner. SCC’s Security Department will be responsible for arranging transports, staffing transportation vehicles, and performing transports. SCC will utilize a GPS tracking system and geofencing in order to prevent

our transportation vehicles from leaving the State of Rhode Island under any circumstances when there is medical marijuana product contained within the vehicle(s). SCC will utilize the medical marijuana tracking system, or an alternative approved by the Department of Business Regulation, to maintain orders, generate and track transportation manifests, and record and track all transactions.

● South County Compassion will maintain strict compliance with the Transportation of Medical Marijuana Products for compassion centers promulgated by the Department of Business Regulation pursuant to R.I. Gen Laws 21-28-6-12(f)(11) and21-28.6-16(g).

Authorized Transport Vehicle

1. SCC will ensure Authorized transports will be conducted in such a manner that marijuana and marijuana products are secured and safe at all times during transport.

2. SCC will ensure our “authorized transport vehicle” will be in compliance and at all times be meeting all the following criteria:

- The vehicle bears no markings that indicate that the vehicle is being used to transport marijuana nor indicates the name of the marijuana establishment licensee;

- The vehicle is equipped with a global positioning system monitoring device that is monitored by the originating marijuana establishment licensee during an authorized transport;

- The vehicle is equipped with an alarm system;

- The vehicle is equipped with functioning heating and air conditioning systems appropriate for maintaining correct temperatures for storage of marijuana products;

- Marijuana products will not be visible from outside the vehicle;

- Marijuana products will be stored and transported in a secure, locked storage compartment that is a part of the vehicle transporting the marijuana products. However, the trunk of a vehicle does not qualify as a “locked storage compartment.”

3. When transporting marijuana products, SCC will have no other products transported or stored in the same vehicle.

4. SCC will have a strict firearms policy, this will be included in our transportation SOPs, no firearms will be located within the vehicle or on the person of the authorized transport cardholder. 5. Any other security and safety requirements as determined by DBR.

Transport Manifests

SCC will create and maintain detailed transport manifests for all authorized transports, which DBR may require be generated through and/or maintained in the Medical Marijuana Program Tracking System.

The detailed transport manifest will be prepared by the originating marijuana establishment licensee and transmitted in advance to the receiving license. Mediflor partnering licensees will retain copies of detailed transport manifests as part of their record retention responsibilities.

The detailed transport manifest will include the following minimum information: ● Departure date and approximate time of departure. ● Names, location addresses, and registration/license numbers of the originating and receiving marijuana establishment facilities. ● Unique identifier generated by the Medical Marijuana Program Tracking System. ● Product names or descriptions. ● Quantities (by weight or unit) of each product to be delivered. ● Product name or descriptions and quantities (by weight or unit) of each product which was received by the marijuana establishment licensee. ● Arrival date and approximate time of arrival. ● Delivery vehicle make, model and license plate number. ● Names, registry identification card numbers, and signatures of the authorized transport cardholders.

Authorized Transportation Requirements 1. When SCC is the originating marijuana establishment licensee shall ensure that all delivery times and routes are randomized.

2. When SCC is the originating marijuana establishment licensee we will ensure that all transport routes remain within the state of Rhode Island.

3. SCC Authorized transports may only be made by authorized transport cardholders affiliated with the particular marijuana establishment licensee that is the source or recipient party to an authorized transaction.

4. When using one SCC authorized transport vehicle, the vehicle shall be operated/occupied by a minimum of two authorized transport cardholders and at least one such cardholder shall remain in the authorized transport vehicle at all times until the vehicle returns to the originating marijuana establishment licensee.

5. When two authorized transport vehicles, the authorized transport vehicles shall travel together at all times during the authorized transport and each vehicle shall be operated/occupied by at least one authorized transport cardholder. These vehicles shall not be left unattended for any period of time during any authorized transportation.

6. During all SCC authorized transports:

a. The authorized transport cardholders must have on their persons their compassion center registry identification cards and the detailed transport manifest; and

b. A copy of the detailed transport manifest shall also accompany the marijuana and marijuana products in the locked storage compartment of the authorized Mediflor transport vehicle.

7. Any and all SCC authorized transport vehicles carrying marijuana and marijuana products shall travel directly from the originating marijuana establishment licensee to the receiving marijuana establishment licensee.

8. In case of an emergency stop, SCC will immediately prepare a detailed written account that must be maintained describing the reason for the event, the duration, the location, any activities occurring during the stop, and any personnel exiting the vehicle during the stop.

9. Prior to leaving the originating marijuana establishment licensee for an

authorized transport to another marijuana establishment licensee, the originating marijuana establishment licensee must weigh, inventory, and account for on video all marijuana and marijuana product to be transported.

10. SCC will ensure authorized transports to and from a marijuana establishment licensee, the transport manifest will be accompanied by a copy of any contract/purchase order for which the transport is being made and documentation of the actual payment date, if prepaid.

11. SCC will ensure Upon arrival at the destination marijuana establishment licensee, the Receiving party shall confirm receipt of each item in the presence of the delivering authorized transport cardholder and then initial each received line item on both the originating licensee’s manifest and the receiving licensee’s manifest. The receiving party shall then immediately re-weigh, re-inventory, and account on video for all marijuana and marijuana product transported.

12. SCC will make certain Both the originating and recipient marijuana establishment licensees shall timely adjust their records to reflect in its records the completed authorized transport of marijuana, including logging such information in the Medical Marijuana Program Tracking System. All records and entries in the Medical vMarijuana Program Tracking System shall be easily reconciled by unique identifier, product name and quantity, with the applicable detailed transport manifest.

13. In the case that SCC finds any unusual discrepancies in the quantity described in the detailed transport manifest and the quantities received will be reported to DBR and municipal and/or state law enforcement within twenty-four (24) hours.

14. In the case of any vehicle accidents, diversions, or losses during authorized transports of marijuana SCC shall report to DBR and law enforcement as an “emergency event” pursuant to § 1.6.5(I) of requirements for compassion centers promulgated by the Department of Business Regulation pursuant to R.I. Gen Laws 21-28-6-12(f)(11) and21-28.6-16(g)

15. Transportation to or from a third-party testing provider shall be in accordance with the DOH Testing Regulations.

Patient feedback and product selection

SCC recognizes the importance of patient feedback in better serving patients’ needs. SCC will regularly elicit patients’ feedback in order to gain insight into market trends and opinions. SCC has set up a general email account to accept feedback, [email protected]

SCC believes it is sound business practice to take into account customer feedback when determining product selection. When making wholesale purchasing decisions, SCC will look at a variety of factors, including patient feedback and any historical complaints or adverse reports.

Other services to be provided - South County Compassion takes a holistic approach to care for its patient base. SCC recognizes that physical and mental health are as important as therapy with medical marijuana. SCC’s primary objective is to enhance the well being of its patients and its community, and plan to provide safe, effective medical marijuana while as well as an array of ancillary services to aid in accomplishing our objective. Additional services SCC intends to offer include, but are not limited to: Massage therapy, chiropractic discounts, patient support groups (Veteran, disabled, traumatic brain injury, cancer, epilepsy, etc.)

Advertising: South County Compassion recognizes the importance of taking care in advertising practices. SCC intends to take a strictly educational approach to all advertising activities. SCC’s Compliance Officer will oversee all activities related to advertising and marketing, and will ensure that all such activities are performed in accordance with the Regulations and any other official communications from the Department of Business Regulation, or Office of Cannabis Regulation. SCC’s Chief Operating Officer will work in tandem with the Compliance Officer in directing marketing and advertising activities.

SCC’s Marketing Manager will be responsible for designing all content related to SCC’s marketing and advertising initiatives. All such content will be inspected and approved for use by the Compliance Officer prior to distribution through any channels. SCC’s Compliance Officer will maintain records related to the approval of all such advertising or marketing activities. SCC has designed policies and procedures to ensure all advertising and marketing practices are performed in a compliant manner.

● South County Compassion will not advertise in a manner which is observed by or targets the general public. All advertising will be restricted to a registered patient audience. ● In the course of promoting SCC’s brand, medical marijuana or medical marijuana products, SCC will not advertise or cause any advertising or agent to advertise in a manner that: ○ Is attractive to persons under twenty-one (21) years of age; ○ Promotes non-medical use; ○ Promotes activity that is illegal under Rhode Island law; ○ Is contrary to or in direct violation of state or federal consumer protections; or ○ Otherwise presents a significant risk to public health and safety. ● Any advertising by or on behalf of South County Compassion will not: ● Contain statements that are deceptive, false or misleading; ● Display images or representations of marijuana plants, marijuana or marijuana products; ● Display the consumption, use or transfer of marijuana or marijuana products; ● Include claims related to potency (beyond listing of cannabinoid content); ● Include any prices or the term “sale,” “discount,” “coupon,” “special” or similar terms; ○ SCC’s website may include prices of product and reference to services offered for discounted products ○ Product Menus available to patients once in South County Compassion may show prices as well. ● Depict activities or persons in conditions under the influence of marijuana, including but not limited to operating a motorized vehicle, boat or machinery, or persons who are pregnant or breastfeeding; ● Contain any content that can reasonably be considered to target individuals under the age of twenty-one (21), including but not limited to ○ images of persons under twenty-one (21) years of age ○ cartoons, toys or similar images and items typically marketed towards persons under twenty-one (21) years of age or ○ references to products that are commonly associated with persons under twenty-one (21) years of age or marketed to persons under twenty-one (21) years of age; ○ contain any imitation of candy advertising ○ include the term “candy” or “candies” ● Encourage the transportation of marijuana or marijuana products across state lines or otherwise encourage illegal activity; ● Assert that marijuana or marijuana products are safe because they

are regulated by DBR or have been tested by a testing facility or otherwise make claims that any government agency endorses or supports marijuana; ● Make claims that marijuana has curative or therapeutic effects; ● Contain any health or physical benefit claims, including but not limited to health or physical benefit claims on labels or packaging; or ● Contain material that encourages excessive or rapid consumption. ● Make any deceptive, false or misleading assertions or statements on any informational material, any sign or any document provided to a patient, registered caregiver or authorized purchaser;

● South County Compassion will not: ○ Distribute handbills in public areas or on publicly owned property; ○ Advertise within the prohibited distance of one thousand (1,000) feet (or such greater distance if prescribed by the municipality in which the advertising is located) of the property line of an existing public or private school; ○ Advertise on television, radio, or print media; ○ Advertise in any manner that is viewable or can otherwise be perceived in a public space, including but not limited to billboards, bus wraps, benches, adopt a highway signs, or any format that may be viewable from roads or walkways; ○ Engage in advertising via marketing directed towards location-based devices or electronic devices, including but not limited to cellular phones, unless the marketing is a mobile device application targeted to a registered patient audience and not a public audience, and that is installed on the device by the owner of the device who is a registered patient and includes a permanent and easy opt-out feature; ○ Engage in any form of advertising which promotes application or enrollment into the program or the services of the practitioner or any other party which facilitates patient registration; or ○ Permit use of the South County Compassion’s trademarks, brands, names, locations or other distinguishing characteristics for third-party use on advertising in a manner that does not comply with § 1.10 of this Part or any other statute, rule or regulation. ● In the event a third party has used SCC’s brand, trademark, brand name, location or other distinguishing characteristics in an advertisement that does not comply with § 1.10 of this Part or any other statute, rule or regulation, SCC will immediately notify DBR and issue a cease-and-desist notice to such third party.

● Digital, Electronic and Web-based Advertising ○ In addition to complying with the advertisement criteria and prohibitions outlined above, while advertising on a digital, electronic or web-based platform, SCC will: ■ Utilize appropriate measures to ensure that individuals visiting the platform are over twenty-one (21) years of age and are authorized to use and/or purchase listed products. If appropriate measures to ensure that individuals visiting the platform are over twenty-one (21) years of age are not available, SCC will not advertise on such a platform. ■ Not utilize unsolicited pop-up or banner advertising on the platform other than on age-restricted websites for people twenty-one (21) years of age and over who consent to view marijuana-related material. ● Required Statements on all Advertising ○ South County Compassion include the following statements on all advertising regardless of the medium: ■ "For use only by qualified patients”; and ■ The license number of SCC.

Return Policy

SCC will accept medical marijuana product returns at its sole discretion, or at the direction of the Department of Business Regulation in the event of a product recall.

If the package’s tamper seal is intact, and the product is not expired or otherwise unfit for sale, a full refund will be issued and the product will be returned to inventory for resale.

If the package’s tamper seal is broken, and any amount of the product has been used, SCC’s Retail Manager or Supervisors may, at their discretion, issue a full or partial refund in the form of store credit. As a guideline, if less than ⅓ of the package has been used, some type of refund is likely in order. HFowever, if 90% of the package has been used, for instance, there is less reason for any amount to be refunded. In the case that a package is returned with its tamper seal broken, the product will be immediately quarantined in line with SCC’s quarantine procedure, and destroyed in accordance with SCC’s destruction procedure.

For each return, the patient will be required to fill out a Complaint Form, in line with our Complaint Procedure, in order for management to review weekly. Should the patient refuse to complete the form, the employee receiving the complaint will be responsible for ensuring necessary information is collected and aggregated according to SCC’s Complaint Policy. Should the employee receiving the complaint believe that it warrants

immediate escalation to management, the employee may seek approval from their direct supervisor to escalate immediately. In the case that SCC finds evidence that the complaint may warrant a recall, SCC will immediately quarantine the batch and notify DBR through appropriate channels.

Proposed Medical Marijuana Varieties and Product Types proposed to be Offered

South County Compassion will source medical marijuana and medical marijuana products primarily from the State’s 60+ licensed cultivators. Our team has strong, well-established relationships within the Cultivator market through years of experience in the RI medical marijuana industry.

SCC will aim to maintain a heavily diverse product menu, offering marijuana varieties and products to suit the needs of the state’s patients. SCC’s Chief Operating Officer will be responsible for SCC’s product menu offering, developing strong business relationships with the State’s cultivators and leading the way in terms of internal product development and product lines.

A brief description of SCC’s intended product offering is included below:

● Raw Cannabis Flower - Prepackaged raw cannabis flower, or “bud.” Dried flower which may be smoked or vaporized ○ Sativa - Sativa is a primary marijuana strain type known to be energizing and cerebral. Sativa strains are ideal for activities during the daytime that require physical activity or a high level of social interaction. In terms of effects, sativa strains provide a high for your mind, jumpstarting creativity, focus and mental energy. ○ Indica - Indica is a primary marijuana strain type known to be calming and relaxing. Indica strains are ideal for activities during the evening that require little to no physical activity or social interaction. In terms of effects, indica strains provide a high for your mind and body, creating a sedated and sleepy state of mind. ○ Hybrid - Hybrids are a primary marijuana strain type that live between indicas and sativas. Hybrid strains are classified by their ability to produce a unique balance of indica and sativa effects. Hybrids can be both energizing and relaxing, depending on their specific strain lineage. ○ CBD Rich - The many benefits of CBD hemp flower that people have reported include relaxation, improved clear-mindedness, and more. It has been known to

provide a relaxing and “chill” experience without the more intense and intoxicating effects associated with its sister plant, marijuana. ● Prerolled joints - dried flower rolled in papers with or without a support/mouthpiece, or “crutch” ● Kief - mechanically separated extract from the cannabis plant. Kief is produced when dry flower is passed over a micron screen of an appropriate size. It is most often smoked, used to “top off” a bowl of flower or rolled into a joint. ● Bubble Hash - mechanically separated extract from the cannabis plant. Bubble hash is produced using ice and water to freeze trichomes (reinous glands containing cannabinoids) contained in material which can then be separated from plant material through agitation. Following filtration, the hash is collected and dried, and is most often smoked in a pipe or rolled into a joint. ● Live Rosin - Live rosin is resin extracted from flower, kief, or bubble hash that is “pressed” using heat and pressure to remove the essential oils contained within trichomes. The product is most often “dabbed” or vaporized. ● CO2 Shatter - CO2 shatter is extract that is produced utilizing supercritical fluid extraction using carbon dioxide. The oil is treated similarly to how hydrocarbon-extracted concentrates are treated, resulting in a product that is very tacky to the touch and extremely potent. ● Rick Simpson Oil (RSO) - A cannabis concentrate used for many different medical benefits, including relieving cancer symptoms. It has a thick, syrupy consistency and can be applied as a topical or ingested in food or drinks. ● Vape Cartridges - A vape cart is a glass cartridge pre-filled with a gram or half-gram of cannabis oil. This oil contain various combinations of cannabinoids and terpenes extracted from cannabis. ● Edibles - foods infused with activated cannabinoids. ○ Lozenges ○ Chocolates ○ Chews ○ Beverages

Pricing

South County Compassion plans to maintain a pricing plan that strikes a balance between patient access and affordability and viability from a business standpoint.

SCC intends to utilize tiered pricing for most products. SCC will utilize a scoring system in order to assign a tier designation to each batch of medical marijuana or medical marijuana product prior to sale.

SCC will provide separate pricing structures for wholesale versus in-house produced products. SCC assumes the majority of its products will come from the Cultivator market in the State. SCC intends to fully support the State’s cultivators, and will purchase wholesale products whenever market conditions permit. SCC will aim to maintain a minimum of 50% gross margin on all wholesale products. Refer to Appendix L, Proposed Pricing Grid. This grid is current as of SCC’s application for licensure, given current market conditions in the State.

South County Compassion’s Executive Leadership Team will periodically analyze pricing, and may alter pricing structures or tiers from time to time. When analyzing pricing, SCC will take into consideration recent average wholesale prices, changing production costs, market trends, patient feedback, internal recommendations, etc. Due to fluid and uncertain market conditions, SCC reserves the right to change pricing at any time, without notice.

Discounting South County Compassion recognizes that patients in the State come from all walks of life, social classes, and income levels. As such, SCC intends to adopt programs to offer discounted or free medical marijuana or medical marijuana products to patients who meet certain qualifying criteria. All patients will receive materials on discount qualification as part of their patient education materials (see Patient Handbook). Covid19

South County Compassion’s COO will ensure strict compliance with all recommended or mandatory state and federal protocols, requirements and guidance with respect to the COVID-19 health pandemic. Providing a safe and sanitary environment for both employees and patients is SCCs top priority on a daily basis. The COO will conduct daily review of current and/or any new guidance provided by but not limited to; ● The DBR ● The Occupational Safety and Health Administration (OSHA) ● Commerce RIs website and;

● The Governors Executive Orders SCCs COO will work with the Compliance Officer and Department Managers to formulate detailed plan of action including notification to the Department, if anyone at your facility were to get sick or be required to quarantine due to COVID-19 exposure.

Notification to DBR of an Inventory Discrepancy South County Compassion will perform inventory reconciliations on a continual basis. These inventory reconciliations, in essence, will match up physical, on-hand inventory counts with stated values recorded in the Medical Marijuana Tracking System. In the event that during any inventory reconciliation, South County Compassion discovers a verified, unexplainable inventory discrepancy, SCC will immediately launch an internal investigation and promptly notify the Department of Business Regulation/Office of Cannabis Regulation of the inventory discrepancy’s discovery.

The internal investigation will be launched and managed by SCC’s Compliance Officer, with the support of SCC’s Chief Operating Officer. All investigations surrounding inventory discrepancies will be executed in a prompt manner. SCC recognizes that any opportunities for diversion warrant top priority status. SCC will open and maintain communication with the DBR/OCR throughout the investigation process, and will update DBR/OCR with any findings. At the conclusion of the investigation, the Compliance Officer will compile a review of the investigation and findings and submit the review to DBR/OCR.

Emergency Alternative Tracking Procedures South County Compassion understands that the accurate, real-time tracking of all cannabis products is requisite to a transparent, compliant operation. In the event that South County Compassion is unable to access the Medical Marijuana Program Tracking system, SCC will employ alternative measures to ensure all information required by regulation is recorded in real-time. SCC’s Chief Operating Officer will be responsible for overseeing adherence to procedures in the event that SCC is unable to access the Tracking System.

SCC will use Google Sheets in order to organize and track all plants, medical marijuana, and medical marijuana products, and a random number generator to generate a unique identifier for each marijuana unit/product. Once the unique identifier is generated, it will be recorded in Google Sheets along with information regarding the unit/product. SCC will use Microsoft Word

and existing label printing hardware to print labels, and securely attach the labels to each unit/product. Copies of all inventory-related Google Sheets will be printed at the end of each business day that SCC is unable to access the Tracking System. Throughout the duration that SCC is unable to access the Tracking System, SCC will:

a. Immediately conduct an initial comprehensive inventory of all medical marijuana, including usable marijuana available for dispensing and/or sale, marijuana plants and seedlings, unusable marijuana, and wet marijuana, at each authorized location on the date the compassion center first dispenses, or the licensed cultivator first cultivates medical marijuana or as of another date certain set by DBR.

b. Conduct daily subsequent comprehensive inventories.

c. Conduct a monthly inventory review of stored, usable marijuana, seedlings, plants, and wet marijuana.

Appendices

Appendix A: Leaf Logix Informational Material

Appendix B: Patient Intake Form

Appendix C: Patient Intake Standard Operating Procedures

Intake Procedures:

o South County Compassion’s sales to qualifying patients, directly or through their caregivers or authorized purchasers, will only be permitted if those qualifying

patients, caregivers, or authorized purchasers are registered and compliant with the The Edward O. Hawkins and Thomas C. Slater Medical Marijuana Act and all regulations promulgated thereunder. Only marijuana products that have been designated as medical marijuana in accordance with § 1.7 of the Rules and Regulations Related to the Medical Marijuana Program Administered by the Office of Cannabis Regulation at the Department of Business Regulation will be sold or distributed by SCC. For such sales, South County Compassion Center shall be strictly bound by the dispensing limits of R.I. Gen. Laws § 21-28.6-12(g). o Intake SOP: ▪ In-state Patients: ● Patient enters man trap/vestibule, approaches intake service window ● Patient Intake agent requests medical marijuana card and state-issued identification - both are required, every time, for entry ● Patient Intake agent verifies validity of state-issued ID, such that: o Name on state-issued identification matches name on medical marijuana card o Photo generally matches physical appearance of individual, using physical characteristics that don’t change over time, such as nose, spacing of eyes, ears, etc.) o ID is not expired o Patient Intake agents will then validate the patient’s ID using a digital identification scanning and verification system which fully integrates with our point of sale system. ▪ Collateral on the scanning system - need to get info from Leaf Logix ● Patient Intake agent confirms whether patient is registered in SCC point-of-sale system and has completed all required forms and received required materials ● If yes, patient is checked in and allowed access to dispensary waiting area by way of access controlled entrance door, controlled by Patient Intake agent ● If patient is not registered in Leaf Logix point-of-sale, patient intake packet is provided to patient o In-state patient: ▪ Intake form ▪ Summary of rules and regulations of facility

▪ Patient confidentiality packet ▪ Patient education materials - Patient Handbook ● Out-Of-State Patients: o Patient enters man trap/vestibule, approaches intake service window o Patient Intake agent requests medical marijuana card and state-issued identification - both are required, every time, for entry o Patient Intake agent verifies validity of state-issued ID, such that: ▪ Name on state-issued identification matches name on medical marijuana card ▪ Photo generally matches physical appearance of individual, using physical characteristics that don’t change over time, such as nose, spacing of eyes, ears, etc.) ▪ ID is not expired ▪ Patient Intake agents will then validate the patient’s ID using a digital identification scanning and verification system which fully integrates with our point of sale system. ● Collateral on the scanning system - need to get info from Leaf Logix o Patient Intake agent verifies validity of out-of-state Medical Marijuana ID ▪ Utilizing reasonable means available, Patient Services representative confirms validity of out-of-state Medical Marijauna IDs through verification means, if available (website portals, etc.) o Patient Intake agent confirms whether patient is registered in SCC point-of-sale system and has completed all required forms and received required materials o If yes, patient is checked in and allowed access to dispensary waiting area by way of access controlled entrance door, controlled by Patient Intake agent o If patient is not registered in Leaf Logix point-of-sale, patient intake packet is provided to patient ▪ Patient Intake Packet (Out-of-State) ● Intake form ● Summary of rules and regulations of facility ● Patient confidentiality packet ● Patient education materials - Patient Handbook ● ***Include in patient handbook?*** South County Compassion will provide each out-of-state patient cardholder with a notice regarding the requirements and prohibitions under the The Edward

O. Hawkins and Thomas C. Slater Medical Marijuana Act, as amended and any regulations promulgated thereunder that apply to dispensing and use of medical marijuana within the State of Rhode Island, including without limitation notice of medical marijuana dispensing and possession limits, prohibition of taking medical marijuana and medical marijuana products across state lines and prohibition of smoking in public places.

Appendix D: Training Procedures

South County Compassion takes employee training seriously. Not only does proper training insure continued licensure of SCC’s facilities, but also ensures protection of public health and safety as a whole. As such, SCC will develop a comprehensive training curriculum to cover all aspects of SCC’s operation as well as state and federal laws and regulations. SCC will certify internal trainers, specifically those who have displayed a deep understanding of all required training materials and content. SCC’s internal trainers will hold classroom-style training sessions with SCC’s employees, upon hiring and on a continual basis. The classroom-style training sessions will cover specific aspects related to cannabis law, regulation, operations, detection and prevention of diversion, cannabis and cannabinoids, market trends, professional conduct, ethics and product knowledge. Participants in these sessions will be required to successfully complete an assessment which adequately addresses the material covered in each specific section. Upon successful completion of each assessment, the employee will complete a training attestation form which will then be added to the employee’s personnel file per (REFERENCE).

In accordance with R.I. Gen. Laws §§ 21-28.6-12(f)(14) and 21-28.6-16(b), South County Compassion will develop, implement and maintain on the premises an on-site training curriculum, or enter into contractual relationships with outside resources capable of meeting employee, agent and, if applicable, volunteer training needs. Each employee, agent or volunteer, at the time of his or her initial appointment and every year thereafter, shall receive, at a minimum, training in the following:

● Federal and state marijuana laws and regulations ● Detection and prevention of diversion of medical marijuana and medical marijuana products.

● Professional conduct, ethics, and state and federal laws regarding patient confidentiality; ● Informational developments in the field of medical use of marijuana; and ● Policies and procedures for dispensing to and transactions with out-of-state patient cardholders. ● The proper use of security measures and controls that have been adopted. ● Training on use of the Medical Marijuana Program Tracking System and any other tracking systems used by the compassion center for persons responsible for using the system. ● Specific procedural instructions for responding to an emergency, including but not limited to; robbery or violent accident, crime prevention, and personal safety techniques. ● The health, safety, and sanitation standards put in place by the Company in accordance with Section I.6 of the Regulation. ● Confidentiality and all other provisions of HAR §11-850 and chapter 329D, HRS ● that apply to the individual’s scope of employment.

Upon completion of each training indicated above, each recipient will sign a statement attesting to receipt of the training and acknowledging the date, time and place he or she received said training, topics discussed, and the name and title of presenters in accordance with Section G.E.3 of the Regulation. Refer to Appendix 1 for a sample Training Attestation.

Appendix 1: Training Attestation Form

Training Module/Class: Trainer (Name/Title): Date of Attendance:

I confirm that I attended the training class listed above. I listened, read, and understood the training, and I understand that as an employee, it is my responsibility to abide by Mediflor’s policy and procedures, in accordance with the training. If I have questions about the training, materials presented or Mediflor’s policy and procedures, I understand it is my responsibility to seek clarification from the Trainer and/or my direct supervisor.

Employee Signature______

Date______Print name______

Appendix E - Recall Plan o Procedure: ▪ Recall procedure A recall may be initiated based upon any SCC representative discovering, without limitation, evidence that marijuana, marijuana product, or medical marijuana product: a. Contains unauthorized pesticide(s); b. Failed a mandatory test and was not mitigated pursuant to testing protocols; c. Is contaminated or otherwise unfit for human use, consumption or application; d. Is not properly packaged or labeled; e. Was not cultivated, processed or manufactured by a licensee or otherwise is not in accordance with the Act, DBR regulations or DOH regulations; or f. Otherwise poses a threat to public health or safety as determined by DBR or DOH. Upon discovery of any of the above criteria, or any other criteria which an SCC representative discovers that they believe may warrant a product recall: 1. The SCC representative will immediately notify their direct supervisor, who will communicate with SCC management to determine whether a recall is warranted. 2. Should a recall be warranted, SCC management will immediately notify DBR of their intent to recall product, along with an explanation as to the criteria for which the recall was warranted. 3. Concurrently, SCC will cease retail sale of any potentially affected product(s), and physically consolidate and move any existing on-hand inventory to a secured storage location specified for quarantine. Quarantined product will be clearly marked with a label that states “Quarantined - Do Not Sell” 4. SCC will then query the seed-to-sale tracking system to identify all customers who purchased the recalled batch of product(s). 5. Patients will be contacted via their preferred contact method (phone or email), specified on their patient intake form. 6. Recalled product, upon return to SCC, will be placed into quarantine in accordance with the regulations until a determination is made on the fate

of the quarantined product (transfer to testing facility, remediation, destruction in accordance with the regulations, etc.)

Appendix F - Odor Control and Mitigation Plan South County Compassion recognizes the importance of being a good neighbor in its community. As such, SCC intends to implement the following plan in order to control any and all cannabis odors and to prevent the odors from becoming a burden on the surrounding areas. 1) All of SCC’s cultivation, manufacturing, and retail areas will be outfit with appropriate equipment to control and mitigate cannabis odors. Mitigation efforts may include activated carbon “scrubbing,” Ozone generation, or any combination thereof. 2) The ventilation and filtration systems shall be installed in compliance with all applicable local codes and ordinances, including obtaining any necessary permits, and will be inspected by the municipality. 3) All ingresses/egresses to SCC facilities will remain positively pressurized with filtered air, in order to prevent the escaping of odors into the environment. 4) SCC management and staff will regularly monitor the areas surrounding SCC facilities for any sign of cannabis odor. 5) Any reports or complaints of odor from the neighborhood or community will trigger immediate internal diagnostic tests of systems related to odor control and mitigation, including, but not limited to, ventilation and filtration equipment. 6) Should odors persist, SCC management will take additional measures in order to control and mitigate the odors, such as swapping of carbon filters or supplementing additional filtration or ozone generation.

Appendix G - Patient Handbook

Templates - https://www.greengold.group/docs/Green-Gold-handbook.pdf https://s3.amazonaws.com/netacare-lt/wp-content/uploads/2020/03/31164954/NET A20_Patient-Handbook.pdf

Appendix H- Ethics and Compliance Policy Responsibility for Ethics & Regulatory Compliance

Purpose

All persons associated with SCC including owners, officers, administrators, employees and contractors are required to adhere to the most recent version of the Rules and Regulations Related to the Medical Marijuana Program and the Edward O. Hawkins and Thomas C. Slater Medical Marijuana Act, administered by the Office of Cannabis Regulation at the Department of Business Regulation.

Responsibilities

The Chief Compliance Officer (CCO) is responsible for establishing SOPs related to regulatory compliance. The Human Resources Director will manage and oversee all training required by the SOPs. Managers and supervisors are required to ensure SOPs are adhered to by all employees and contractors at all times. All employees and contractors are responsible for strict adherence to SOPs and reporting any compliance questions or issues to their supervisor.

Policies and Procedures

Regulatory Compliance

1. The CCO will develop and maintain all SOPs necessary for compliance with applicable Regulations and laws. 2. The CCO will update SOPs as often as necessary to maintain compliance with the most recent version of the Regulation for the cultivation, manufacture, supply, and distribution of medical marijuana. 3. The CCO will establish all employee and contractor training requirements necessary to properly implement the SOPs. The Human Resources Director will oversee the provision of all training required.

4. All SOPs developed by the CCO must be approved by the Chief Executive Officer (CEO) prior to distribution and implementation. 5. The CCO will distribute all revisions and additions to SOPs to the necessary stakeholders. 6. All persons associated with SCC are required to maintain compliance with SOPs and report any non-compliant activities or concerns regarding compliance to a manager or supervisor as soon as possible. 7. SCC will ensure compliance with applicable laws and regulations relating to the accounting and taxation of medical marijuana. SCC has retained Restivo Monacelli LLP for all accounting related matters including ensuring appropriate bookkeeping, taxation and filing of required statements and forms.

Ethics

Management has the responsibility for demonstrating, through their actions, the importance of ethical behavior. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. In particular, the following define SCC’s mission as it relates to promoting an ethical workplace.

● Respect for others – no tolerance workplace in relation to sexual harassment, violence or discrimination of any kind. These behaviors will result in immediate termination. ● Integrity – no tolerance for deceitful or petty conduct including stealing, bribery or any other unlawful behavior most importantly in relation to the Rules and Regulations Related to the Medical Marijuana Program and the Edward O. Hawkins and Thomas C. Slater Medical Marijuana Act ● Conflict of Interest – involuntary conflicts of interest will be investigated as soon as they are presented and necessary actions will be taken to remedy. If a known conflict of interest was entered into in order to create an advantage, actions will be taken that may result in termination. ● Lawfulness – All parties involved with SCC will comply with the Rules and Regulations Related to the Medical Marijuana Program and the Edward O. Hawkins and Thomas C. Slater Medical Marijuana Act. Any voluntary disobedience of the regulation or act will result in punishment that may result in termination. All parties involved with SCC are required to follow all applicable laws regarding fraud, bribery, corruption and any kind of assault is a given. SCC will follow laws on child labor and avoid doing business with unlawful organizations. ● All parties involved with SCC must pay particular attention to: ● Patient confidentiality - to not disclose or expose personal information ● Data protection – to ensure all proprietary and sensitive information is not disclosed to unauthorized parties Preservation of the Public Welfare

All persons associated with SCC are required to take all necessary measures to ensure the public welfare including:

1. Maintenance of controls to prevent diversion of medical marijuana products to persons or entities that are not authorized to possess such products; 2. Provision of an adequate and uninterrupted supply of medical cannabis products to meet legitimate demand; 3. Strict compliance with applicable federal and local laws; 4. Promotion of new medical cannabis formulations and product development and techniques for cultivation, manufacture and production; 5. Control of associated persons in regards to criminal backgrounds; 6. Utilization of resources experienced in the cultivation, manufacture, production, distribution and testing of controlled substances; and 7. Controls against any activity that may violate health or public welfare priorities.

Appendix I- Example of packaging Appendix J - Perimeter Lighting Plan Appendix K - Security Plan App

Section 8 – Procedures for Safely Dispensing Medical Marijuana to Registered Qualifying Patients or Their Other Registered Primary Caregiver

Procedures for safely dispensing medical marijuana only to registered qualifying patients, registered primary caregivers, and authorized purchasers, including procedures for verifying authenticity of registry identification cards and other forms of identification.

Security- External security, lighting, cameras, hourly security rounds (perimeter checks, etc.), regular monitoring of parking lot.

SCC will remain in strict compliance with all security requirements per the Rules and Regulations Related to the Medical Marijuana Program. The SCC Chief Security Officer is responsible for ensuring the security of the facility for patients to be able to safely purchase medical marijuana. Specifically, SCC through the Chief Security Officer, will ensure the following: ● The outside perimeter of SCC will be well lit at all times to ensure safety for all personnel, patients, and visitors, as well as to provide for proper visualization for the security system. Please refer to Appendix J attached within for the specific perimeter lighting plan to be in place. ● The video surveillance system utilized at SCC will at a minimum comply with all requirements per the Rules and Regulations Related to the Medical Marijuana Program.

The surveillance system will be operational 24/7 365 days a year, and will monitor the exterior of the building, including the parking lot, and all areas of the interior excluding lavatories. The video surveillance system will provide a continuous live feed, with remote access available to the DBR. System will provide for clear resolution picture to allow for proper identification of all individuals inside or outside the facility. All video surveillance will be archived and maintained in original condition for a period of at least sixty days. Hourly perimeter security sweeps will be performed by SCC security personnel during operational hours to ensure no threats to SCC staff, patients or visitors. More detailed information can be found in SCCs Security Plan. ● South County Compassion’s Compliance Officer will oversee all activities related to the secured, segregated storage of medical marijuana and medical marijuana products. All medical marijuana and marijuana products will be kept in secured, segregated storage areas outside of business hours or when the product is not available for retail sales. Our retail vault room, located behind the sales counter in a limited access area at our dispensary, will act as our secured and segregated storage for all packaged, retail-ready medical marijuana and medical marijuana products. Our cultivation and product manufacturing vault room, located on the second floor of our cultivation facility, will act as our secured and segregated storage for all bulk product and works-in-process. The vault rooms will be secured by commercial grade locking mechanisms, and access will be limited to only those persons who require such access in performing regular duties or meeting specific responsibilities. A list of all persons with access to SCC’s vault rooms will be maintained and kept on applicable premises for review. These lists will be reviewed periodically by SCC’s Compliance Officer to ensure only those who require access are allowed access. Our vault room doors will be access controlled either by RFID fob or biometric (fingerprint) scanning. The access control system will maintain a log of all employees who have accessed the vaults along with a timestamp of the access for auditing purposes. All non-retail-ready products will be stored in the dispensary vault until the product is deemed retail-ready. All marijuana and marijuana products will be stored in separate, sealable containers, separated by Package ID number or Product Batch. Refer to Appendix N - Building Layouts

Intake Procedure - process of id check, first time patient(patient info, education)

Proper intake procedures for returning and new patients will additionally ensure SCC can safely dispense medical marijuana to registered, qualified, and educated patients. ● New patients will enter the facility and approach the Security desk and where he/she will be asked to present his/her patient registration card, or have his/her unique identification verified by the Patient Intake Agent. This information will be logged and time stamped and archived in accordance with the regulation. All patients will be advised of the rules while in the Dispensary.

○ First time patients will be required to follow SCC’s intake procedures as set forth in Appendix C: Patient Intake Standard Operating Procedures, including new patient registration procedures such as completion of the intake form. ● We will provide safety related pamphlets to support, inform and instruct patients as to the proper administration techniques and the risks and side effects associated with use of medical marijuana. Information will be provided describing proper dosage and different delivery systems. Patients will be presented with facts regarding substance abuse signs and symptoms, as well as contact information for substance abuse treatment programs and hotlines. Patients will be instructed that qualifying patients may not distribute cannabis to any other individual, and that they must return any unused, contaminated, or excess product to the Retail Dispensing Location from which it was purchased for destruction.

Product Safety - It is central to our mission that we provide the highest quality medicine and deliver it as safely as possible to our patients. Our medicine will be grown in accordance with organic practices and will be tested for impurities and natural parasites. In addition, we will implement procedures for ensuring exact dose administration. This will be accomplished through the following measures.

● Cultivating and manufacturing practices: SCC will cultivate and manufacture all medical marijuana products in accordance with the Regulations Related to the Medical Marijuana Program. We will utilize only organic nutrients, pesticides, herbicides and wetting agents that have undergone OMRI certification, when available. ● Product Testing: All cultivated and manufactured medical marijuana products will be tested by a third party laboratory in accordance with the Regulations Related to the Medical Marijuana Program. Through this testing practice, SCC can be assured that the product can safely be sold to medical marijuana patients or if the product needs to be quarantined. ● Sanitation Measures: SCC’s facility will be sanitized daily in accordance with the Regulations Related to the Medical Marijuana Program. ○ All areas accessed by patients will be monitored throughout the day to ensure walkways are clear and clean to ensure safe passage through the facility. This includes monitoring any spills on the floor, and all counters are regularly cleaned. ○ Ventilation will be regularly monitored and cleaned to ensure circulated air is properly cleaned. This will not only provide a clean environment for SCC staff and all patient visitors, but also is imperative to maintain the medical marijuana in its purest form in the facility. All staff will be required to regularly wash their hands. ○ All SCC employees are advised to remain home from work if he/she is feeling sick. Employees should contact his/her supervisor as soon as possible to report any illness, and follow protocol as advised by an applicable health professional for time to remain out of work to prevent illness spread. Further information about

employee health and safety can be found in the Employee Handbook - attached as Appendix to the Application. ■ Covid-19: Masks will be worn at all times by SCC staff, and hand sanitizer will be available at all entryways, and on the counters. Social distancing will be required inside and outside the facility for any patients waiting in lines. The number of patients let into the facility check in area and the service counter area will be limited to provide for proper social distancing. All patients will be required to wear masks when waiting in line, and when entering the facility. Any staff who exhibits Covid-19 symptoms will be required to stay home, and seek appropriate medical attention- including a Covid-19 test, or self-quarantine. Any patient who is experiencing Covid-19 symptoms should not enter the facility - consistent with the RI DOH guidelines.SCC will monitor the RI DOH website for updates to guidelines and will comply with all measures.

Point of sale - packaging(warnings), limits, patient education at budtender level,

● Packaging: For those products not produced by SCC, the COO will ensure the packaging meets the requirements of the Regulations Related to the Medical Marijuana Program. SCC will comply with the industry standard to label medical marijuana packaging with THC and CBD dosages. ● Limits: SCC has a responsibility to ensure patients are not over prescribed medical marijuana. As part of the patient intake procedure, all patient purchases will be logged so that the file can be referenced to ensure he/she remains within SCC’s authorized limits. These limits can be found in Appendix C along with more detailed information on patient purchase limits. ● Patient Education - Budtender level: SCC budtenders will be adequately trained to be able to provide proper customer service to educate patients on the products, usage, and side-effects. Additionally, we will provide safety related pamphlets, as described in this operations manual, that will support, inform and instruct patients as to the proper administration techniques and the risks and side effects associated. Patients will be able to depart SCC having their questions answered and feel properly informed on usage, limits, and side-effects. HIPAA- All employees of SCC shall be familiar with the guidelines of the Health Insurance Portability and Accountability Act (HIPAA) and all Rhode Island health care information law, including the Confidentiality of Health Care Communications and Information Act

To satisfy our obligation to maintain the highest level of privacy, we will develop an in-house Privacy Pamphlet based on Rhode Island law and the HIPAA instruction course HIPAA: Privacy Essentials for the Physician’s Office. This course is a free on-line HIPPA training

curriculum provided by the Ohio University College of Osteopathic Medicine in conjunction with the OHIC Insurance Company. All SCC staff will be required to take this course upon hiring in order to be fully educated on HIPPA requirements and to ensure patient confidentiality.

Our measures are as follows:

When a new patient visits SCC for the first time, the intake agent will ask he/she to sign the required HIPAA / Confidentiality Statement. They may, at that time, ask us to remove all but their I.D. from our records. SCC will provide patients the option to select which identifiable information we capture and maintain. SCC will protect all identifying patient information and may not use or disclose any individual patient's health information except for helping them secure an appropriate medicine, for payment purposes, or regular dispensary operations. Any additional uses of a patient's health care information would require an advanced authorization by the patient.

Our HIPAA/Confidentiality Statement will inform patients of SCC’s video surveillance practices and general information and privacy practices. Any and all practices will be fully compliant with State and Federal information and privacy laws.

Because of the sensitive nature of our business and for protection of our patients’ healthcare information, SCC stresses a culture of strict privacy. To most effectively address our patients’ privacy, SCC will establish the below practices to address the following privacy matters:

● Appoint a Privacy Officer or assign privacy officer duties to a specific staff member. ● Appoint a HIPAA IT Computer Security Officer. This individual's main responsibility will be to ensure SCC’s computer systems are sufficiently protected from external threats and provides proper controls to prohibit internal threats such as usernames/passwords, multi-factor authentication, etc. ● Ensure that all employees complete the HIPAA class, and maintain documentation of completion. ● SCC will require HIPAA/Confidentiality statements to be completed by all Subcontractors and Business Associates. ● Develop a notice of privacy, including an acknowledgement form. ● Define who can access and who cannot access protected health information (PHI). ● Establish a procedure to allow patients to amend their medical records

● Create a procedure to document all non-authorized disclosures outside of payment, compassion center operations. ● Develop audit trails to provide patients with a listing of all who accessed or received information from their records. ● Establish a protocol that states release of only the minimum information necessary - where applicable. ● Review information security including passwords and access to information. Also, require that passwords are regularly changed. ● Regularly review local, state and federal laws for changes to privacy requirements and ensure SCC privacy-related policies, forms, and procedures remain in compliance. ● Establish a privacy complaint policy and protocol. ● Institute a policy allowing patients to access their medical records. ● Train all employees on protocols and policies with regard to HIPAA. ● Monitor compliance and take corrective action when needed. ● Document all training and maintain record in the employee’s HR file. In addition to the above, the following procedures will be vigilantly monitored among all personnel.

● If necessary to distribute personal access information, staff will be required to send username and password and URL in multiple e-mails. ● Usernames and password information is prohibited from being maintained on any SCC desktop. SCC will look into the possibility of enrolling all applicable staff in a cloud software username and password manager system that will provide significant security to access information. ● Require all staff to change passwords every 60-90 days. ● All staff will not allow any internet browser to remember passwords. ● If purchasing a product and using a secure web form, it is okay to submit your SCC e-mail account – otherwise, staff are prohibited from using his/her company e-mail address outside of SCC related business. ● If posting a company sponsored event (ie: educational seminar) or something online that requests a reply for the general public, create a random e-mail address that will forward to your SCC e-mail.

Appendix L - Proposed Pricing Grid

Flower - WS 1g 3.5g 7g 14g 28g Tier 1 14 47 90 175 340

Tier 2 12.5 42 80 155 300 Tier 3 11 37 70 135 260

Flower - SCC 1g 3.5g 7g 14g 28g Tier 1 13 44 80 155 300 Tier 2 11.5 39 70 135 260 Tier 3 10 34 60 115 220

Prerolls - WS 1 4 7 14 28 Tier 1 13 51 88 170 330 Tier 2 11.5 45 78 150 290 Tier 3 10 42 68 130 250

Prerolls - SCC 1 4 7 14 28 Tier 1 12 49 78 150 290 Tier 2 10.5 43 68 130 250 Tier 3 9 40 58 110 210

Concentrates - WS 0.5g 1g CO2 Oil $35.00 $60.00 RSO - $45.00 Rosin $50.00 $90.00

Concentrates - SCC 0.5g 1g CO2 Oil $30.00 $50.00 RSO - $40.00 Rosin $45.00 $80.00

Extracts - WS 0.5g 1g Kief 35 Bubble Hash 30 50

Extracts - SCC 0.5g 1g Kief 30 Bubble Hash 25 40

Edibles - WS Per mg All $0.20

Edibles - SCC Per mg All $0.18

Appendix M Traffic Study Traffic and mitigation of community impact South County Compassion is committed to being a good neighbor in the community. SCC recognizes that traffic, odors, light pollution, noise pollution, and litter may have potentially negative impacts on South Kingstown and the surrounding communities. SCC has taken appropriate steps to ensure that any and all negative impacts on the community are appropriately mitigated. Bryant and Associates Engineering, on behalf of South County Compassion, completed a traffic study in the area of 703 Kingstown Road, South Kingstown in July of 2020. The findings of the study were presented to and approved by the town of South Kingstown throughout the local permitting process for the property. During this process, SCC has committed to working with the South Kingstown Police Department in mitigating any potential negative impacts that traffic may have on the surrounding area, including but not limited to providing financial compensation to the department in the event that traffic details are necessary. South County Compassion is cognizant of the fact that medical marijuana packaging litter is a real issue communities face where medical marijuana dispensaries operate. As such, SCC is committing 200 hours a year of labor to roadside, park, and beach cleanups. Reference Appendix __ Odor Control and Mitigation Plan Light Pollution - Refer to Appendix P - Lighting plans and equipment specs Appendix N Building Layouts

Appendix O Incident Report

Date of Incident Time of Incident Reported By: Details of Incident: Reviewed By: Submitted to DBR on:

Filed: