CORNERSTONE OPERATIONS MANUAL Trade Secrets Proprietary Information TABLE OF CONTENTS PAGE 1. Executive Summary 1 TRANSPARENCY AND OVERSIGHT 1 SAFE WORKING CONDITIONS 1 GOOD MANUFACTURING PRACTICE FACILITY DESIGN 1 REGULATORY COMPLIANCE 2 2. Personnel Plan: 3 EQUAL OPPORTUNITY EMPLOYER 3 CONFIDENTIAL INFORMATION 3 EMPLOYEE PRACTICES 3 LAW ENFORCEMENT/REGULATORY INTERACTION 4 EMPLOYEE BADGE 4 EMPLOYEE SAFETY 4 FACILITY SAFETY 5 EMPLOYEE RECORDS 5 EMPLOYEE HANDBOOK 5 EMPLOYEE TRAINING 5 2.10.1 Employee Training: Track and Trace Software 6 2.10.2 Employee Training: Transportation 6 2.10.3 Employee Training: Storage 6 2.10.4 Employee Training: Packaging Procedure 6 2.10.5 Employee Training: Disposal 6 2.10.6 Employee Training: Sanitation 6 3. Products and Inventory 8 CANNABIS AND CANNABIS PRODUCT STORAGE 8 CLEANING SUPPLIES STORAGE 9 PURCHASING OF PRODUCTS FROM OUTSIDE SUPPLIERS 9 OPERATIONAL ACTIVITES & PROHIBITIONS 9 3.4.1 Age Restrictions 9 3.4.2 Alcohol Use 9 3.4.3 Onsite Cannabis Consumption 9 3.4.4 Anti‐Loitering 9 3.4.5 No Visibility of Operations from the Street 10 3.4.6 Emergency Contact 10 3.4.7 Restricted Access 10 ODOR CONTROL 10 PACKAGING AND LABELING 10 DISPOSAL 12 NON‐CANNABIS WASTE MANAGEMENT 13 3.8.1 Recycling 13 3.8.2 General Waste 13 4. Track and Trace 14 INFORMATION SECURITY 14 RECORD RETENTION 14 DAILY OPERATIONS RECORDING AND TRACKING 14 PRODUCT INTAKE PROCEDURES 15 BI‐MONTHLY INVENTORIES 15 RETURNS AND DESTRUCTION 15 DISPOSAL / CANNABIS WASTE 15 5. Inventory Control Plan 17 DESIGNATED STAFF 17 6. Distribution Operations Plan 18 OVERVIEW 18 SUPPLIER AGREEMENTS 18 INVENTORY PRACTICES 18 TESTING 19 QUALITY ASSURANCE PRACTICES 20 INSURANCE REQUIREMENTS 20 TAX COLLECTION PRACTICES 20 6.7.1 Cultivation Taxes 21 7. Transportation Plan 22 OVERVIEW 22 LOCAL AND STATE REGULATIONS FOR TRANSPORTATION 22 TRANSPORTATION REQUIREMENTS 23 TRANSPORTATION VEHICLE REQUIREMENTS 24 TRANSPORTATION ROUTE PROCESS 24 SHIPMENT OF PRODUCTS 24 8. Manufacturing Operations 26 OPERATIONS 26 8.1.1 Packaging 26 8.1.2 Sanitation 26 8.1.3 Sanitary Conditions 26 8.1.4 Sanitary Facilities Conditions 26 8.1.5 Equipment and Utensil Requirements 27 8.1.6 Quality Control 27 9. Cultivation Operational Plan 29 PLANT PROCESS 29 HARVEST PROCESS 29 9.2.1 Designation and Handling of Scales and Weights 29 TRACK AND TRACE SPECIFICATIONS 35 9.3.1 Overview 35 1. Executive Summary This Operations Manual is intended to be an overview of the standard daily operation policies and procedures of CORNERSTONE’s Santa Cruz Micro‐Business. 1. TRANSPARENCY AND OVERSIGHT To ensure the transparency of the operations through documentation and strict operational measures, CORNERSTONE will enforce several policies regarding facility access, operational conformity, and the utilization of documentation for all interactions throughout the facility. CORNERSTONE will utilize GrowFlow (GrowFlow is a third party track and trace system that has an API for the State Metrc system) track and trace software and security protocols to help ensure that: CORNERSTONE or staff verify all shipments coming into the facility via GrowFlow; Bulk Cannabis products will only be sold to and purchased through other license holders; Except for security, suppliers, or city/state officials, the only other persons allowed on the property at any given time will be necessary staff. As required by SCMC Chapter 6.91, a copy of all records shall be kept on site including: The emergency contact person name and phone numbers; Full name, address and telephone number(s), city‐issued work permit and a fully legible copy of a government‐issued form of identification for each The full name, address, and telephone number(s) of the owner, landlord and/or lessee of the Property; employee engaged in the management and operations of the manufacturing facility; Job description and participation of each employee or contractor; The full name, date of birth, residential address, and telephone number(s) of each baseline employee and supervisor/manager; and All records described in this section shall be maintained for a period of not less than seven (7) years and will otherwise keep accurate records of all business activity and provide records for inspection consistent with Section 19327 of the California Business and Professions Code as well as any additional rules established by the licensing authority. 2. SAFE WORKING CONDITIONS CORNERSTONE will implement several policies and procedures necessary to ensure a safe working environment for all staff. CORNERSTONE’s staff will be trained to limit all access to the site to scheduled visitors. Access for visitors will be limited to the door on Ingall’s and no outside vehicles will be allowed through the vehicle gate other than staff. Emergency communication and alarm systems will also be a training requirement for all staff upon hiring. 3. GOOD MANUFACTURING PRACTICE FACILITY DESIGN CORNERSTONE’s immediate priority for considering Good Manufacturing Practice guidelines is how the design of the facility’s interior is in relation to the overall processes of the operation. They are primarily focused on the flow of processes and control of potential contamination throughout the facility. The primary goal for these practices is that the facility is designed and constructed to facilitate ease of use for maintenance, operations, and compliance. 1 4. 5. REGULATORY COMPLIANCE CORNERSTONE will maintain the highest level of operational compliance ‐ both at the local level and in conjunction with the State licensing. When CORNERSTONE obtains it Administrative Use Permit and business license from the City of Santa Cruz, they will maintain compliance with local and state taxes as well as renewal of each license. CORNERSTONE will utilize GrowFlow immediately even though the State track and trace system is still non‐operational. 6. CORPORATE STRUCTURE CORNERSTONE will have a series of managers in key positions responsible for all functions of the operations. The operations manager will play the most significant role in oversight of day to day operations. The operations manager will be responsible for ensuring all aspect of the operations are flowing efficiently. They will be the direct point of contact for all other mangers, oversight of the GrowFlow and scheduling all operations. The logistics manager will be responsible for overseeing all transportation related functions, working directly with retailers, pick ups from other non‐retail businesses and order fulfillment. 2 2. Personnel Plan: 7. EQUAL OPPORTUNITY EMPLOYER It is the Company’s policy to extend “Equal Employment Opportunities” to all employees and all future applicants for employment. The internal policy is to employ and promote on the basis of ability, experience, and performance. CORNERSTONE will give preference to local candidates, to the extent permissible by California law. The Company does not discriminate against any person in recruitment, hiring, assignments, training, promotion, transfers, reassignments, lay‐offs, or compensation because of race, religion, color, sex, age, national origin, ancestry, sexual orientation, physical or mental disability, pregnancy, marital status, military veteran status or any other characteristic protected by applicable law. If any employees are caught violating this policy they will be subject to disciplinary action and/or termination. 8. CONFIDENTIAL INFORMATION As an employee of the Company, certain confidential information will be released including but not limited to methods of production, ratios of ingredients, customer information, process protocols and overall practices implemented by the Company. Under no circumstances shall the information be made public including confidential information regarding the Company’s business, products or internal operations. Upon accepting employment with the Company, the employees will sign a “Confidentiality, Trade Secrets, Non‐solicitation and Conflicts of Interest Agreement,” which generally provides requirements on how to not improperly disclose or use any confidential information, either during or after employment. 9. EMPLOYEE PRACTICES Employees must practice personal cleanliness including: Outer garments such as work shirts, pants and any uniforms must be clean and appropriate for the assigned tasks; Nails must be trimmed and clean; Work shoes must be clean and free of external debris or contaminants; when practical, employees should change into designated work shoes while in the facility; Store clothing or other personal belongings in areas separate from those where cannabis products are exposed or where equipment or utensils are washed; and Confining the following activities to areas separate from those where cannabis products may be exposed or where equipment or utensils are washed: eating food, chewing gum, drinking beverages, and/or using tobacco. Employees must demonstrate proper hand sanitation protocols including: Cleaning hands and exposed portions of his or her arms (or, as applicable surrogate prosthetic devices for hands and arms), during the following times and circumstances: – Immediately before working with usable cannabis or other cannabis products prior to packaging; – After touching bare human body parts other than clean hands; 3 – After using the toilet; – After coughing, sneezing, using a handkerchief or disposable tissue, using tobacco, eating or drinking; – After handling soiled equipment; – As often as necessary to remove soil and contamination and to prevent cross‐ contamination when changing tasks;