Medical Marijuana Dispensary Permit Application

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1 Department of Health Use Only # Received You may apply for one dispensary permit in this application for any of the medical marijuana regions listed below. A separate application must be submitted for each primary dispensary location sought by the applicant. Please see the Medical Marijuana Organization Permit Application Instructions for a table of the counties within each medical marijuana region and the counties in which you are eligible to locate your primary dispensary. Please check to indicate the medical marijuana region, and specify the county, for which you are applying for a dispensary permit: Northwest Northcentral Northeast Southwest Southcentral Southeast County 1 (Primary Dispensary Location): Centre County 2 (if applicable): County 3 (if applicable): 1 Updated February 1, 2017 See Guidance

2 Part A - Applicant Identification and Dispensary Information (Scoring Method: Pass/Fail) FOR THIS PART, THE APPLICANT IS REQUIRED TO PROVIDE BACKGROUND AND CONTACT INFORMATION FOR THE BUSINESS OR INDIVIDUAL APPLYING FOR A DISPENSARY PERMIT, THE PRIMARY DISPENSARY LOCATION, ALONG WITH ANY SECOND OR THIRD DISPENSARY LOCATIONS THAT ARE BEING SOUGHT UNDER THE APPLICATION. Section 1 Applicant Name, Address and Contact Information Business or Individual Name and Principal Address Business Name, as it appears on the applicant s certificate of incorporation, charter, bylaws, partnership agreement or other legal business formation documents: Aceso Agrologics, LLC Other trade names and DBA (doing business as) names: Business Address: 2041 Lawfer Avenue City: Allentown State: PA Zip Code: Phone: Fax: DOH REDACTION Primary Contact, or Registered Agent for this Application Name: Stevens & Lee, P.C. c/o Stephen F. Tuckey, Esquire Address: 17 N 2nd Street, 16 th Floor City: Harrisburg State: PA Zip Code: Phone: Fax: DOH REDACTION Section 2 Dispensary Information THE APPLICANT IS REQUIRED TO PROVIDE A PRIMARY DISPENSARY LOCATION. THE APPLICANT MAY INCLUDE A SECOND OR THIRD LOCATION UNDER THIS APPLICATION. A SECOND OR THIRD DISPENSARY MAY BE ADDED TO A DISPENSARY PERMIT AT A LATER DATE THROUGH THE FILING OF AN APPLICATION FOR ADDITIONAL DISPENSARY LOCATIONS. By checking Yes, you affirm that you possess the ability to obtain in an expeditious manner the right to use sufficient land, buildings and other premises and equipment to properly carry on the activity described in the medical marijuana dispensary permit application, and any proposed location for a dispensary. Yes No Primary Dispensary Location (please indicate dispensary name as you would like it to appear on the dispensary permit) Facility Name: Aceso Agrologics, LLC Dispensary Facility 2

3 Address: 2364 Commercial Blvd. City: State College State: PA Zip Code: County: Centre County Municipality: College Township PLEASE PROVIDE A DESCRIPTION OF THE PUBLIC ACCESS TO THE DISPENSARY LOCATION, INCLUDING ANY LOCAL PUBLIC TRANSPORTATION THAT MAY BE AVAILABLE: Aceso s dispensary is located at 2364 Commercial Blvd., College Township, Centre County, State College, Pennsylvania and is within the North-Central Region of the Pennsylvania Department of Health. Aceso s dispensary consists of an approximately 1,500 square feet space (the Dispensary ) within an approximately 6,000 square foot commercial building (the Building ) under lease from 2360 Commercial LP, the legal owner of the Building and property (the Building and the property collectively the Property ) at 2360 Commercial Blvd. (the Owner ). Aceso has a secured a purchase option to purchase the Property from the Owner. This will provide Aceso with the ability to expand operations throughout the Building and the Property, should it be necessary or required in the future. The Dispensary is located on Commercial Blvd., just off of E. College Ave (PA Rt 26), which is a feeder road into State College (only 2.6 miles to Penn State University). The Dispensary enjoys immediate proximity to restaurants, banking, grocery stores, hotels, housing, and has excellent road access to E. College Avenue (PA Route 26), PA Route 150, and Interstate Route 99. 3

4 Zoning The Dispensary is located in College Township s C-1 Zone (General Commercial District). Aceso received a zoning approval as a Medical Marijuana Dispensary in the form of a Certificate of Verification of Use on March 3, 2017 from College Township. (Please see Attachment C) Centre County Demographics According to the United States Census Bureau, as of July 1, 2016, Centre County, Pennsylvania had an estimated population of 160,580 people, a 4.3% increase from the April 1, 2010 figures. Aceso selected the Dispensary location because Centre County has the largest population within the Department of Health s North-Central Region (Region 4), and because the State College area has the largest population within Centre County. Public Access to the Dispensary The Dispensary is easily accessible by road and the Property has at least 23 on-site parking spaces (likely further expandable). By way of example of the ease of access to the Dispensary, the simple driving directions from Old Main of Penn State University (located in State College) to the Dispensary are: 1. Head northeast on PA-26 N/E College Ave toward Porter Rd for 2.3 miles 2. Turn left onto Gerald Street for 322 feet. 3. Turn left onto Commercial Blvd for.2 miles to arrive at Dispensary (on the right). Upon arrival, the Dispensary, the Property has 2 handicapped parking spaces and 26 regular parking spaces (likely expandable) and has additional room for overflow and surplus parking should it be needed with the possibility of space leasing from adjoining neighbors. Additionally, the Dispensary is safely bikeable for several residential communities in and around the Dispensary. Public Transportation Access The Dispensary is within close proximity to the largest population in the Department s North-Central Region and offers multiple public transportation options including public busing, cab service and Uber service. 1. Busing. The Centre Area Transportation Authority (CATA) provides public busing consisting of 23 different community bus routes which provide service between Downtown State College, the Penn State Campus, the borough of Bellefonte, the village of Pleasant Gap, suburban shopping centers, apartment complexes, residential areas, governmental offices, and many other special points of interest. The Dispensary is located within CATA s Northeast Service Area and offers bus routes with multiple timed stops and other stops within as close as 500 feet of the Dispensary. Approximately six CATA route stops are located within 1,000 feet (as the crow flies) of the Dispensary (Stops #114, 115, 116, 328, 330, 331, and 332). Additionally, Greyhound Buses offer services into State College for those traveling from farther areas. 4

5 2. Ride Sharing. CATA also provides a RideShare service, Vanpool, and Emergency Ride Home (ERH) program designed to assist long distance commuters find a shared ride with someone who travels at the same time to a relatively close destination. ERH provides emergency rides home for those with RideShare arrangements, removing the fear of being stranded. 3. Curb to Curb Transportation. CATA also provides CATARIDE, a curb-to-curb transportation for senior citizens and people whose disabilities prevent their use of the CATA bus system. 4. Taxi Service. Multiple taxi companies service the Dispensary, including the following: AA Transit Inc. (814) Centre County Taxi for Less (814) Taxi by Handy Delivery (814) Nittany Express Inc. (814) Train Service. The closest train service to the Dispensary is an Amtrak Station located at 150 Helen Street in Lewistown, Pennsylvania (approximately 30 miles away). 6. On Demand Rides. Uber offers UBERX and UBERXL (large vehicle) on demand transportation in the State College area, including to/from the Dispensary. Location and Transportation Summary Aceso is proud of the location it has selected for the Dispensary, as Aceso believes that it can provide the greatest access (transportation options) to the greatest population of potential Patients requiring Medical Marijuana. The Dispensary provides an ideal blend of location, ease of access, expansion capability (Aceso Property purchase option), and proper zoning (use as Medical Marijuana Dispensary approved 3/3/17 by College Township Zoning official). Second Dispensary Location Facility Name: Not Presently Applicabile - To Be Determined in Coooperation with the Department of Health Address: City: State: PA Zip Code: County: Municipality: PLEASE PROVIDE A DESCRIPTION OF THE PUBLIC ACCESS TO THE DISPENSARY LOCATION, INCLUDING ANY LOCAL PUBLIC TRANSPORTATION THAT MAY BE AVAILABLE: Please limit your response to no more than 5,000 words. Third Dispensary Location 5

6 Facility Name: Not Presently Applicabile - To Be Determined in Coooperation with the Department of Health Address: City: State: PA Zip Code: County: Municipality: PLEASE PROVIDE A DESCRIPTION OF THE PUBLIC ACCESS TO THE DISPENSARY LOCATION, INCLUDING ANY LOCAL PUBLIC TRANSPORTATION THAT MAY BE AVAILABLE: Please limit your response to no more than 5,000 words. Part B Diversity Plan (Scoring Method: 100 Points) IN ACCORDANCE WITH SECTION 615 OF THE ACT (35 P.S ), AN APPLICANT SHALL INCLUDE WITH ITS APPLICATION A DIVERSITY PLAN THAT PROMOTES AND ENSURES THE INVOLVEMENT OF DIVERSE PARTICIPANTS AND DIVERSE GROUPS IN OWNERSHIP, MANAGEMENT, EMPLOYMENT, AND CONTRACTING OPPORTUNITIES. DIVERSE PARTICIPANTS INCLUDE A PERSON, INCLUDING A NATURAL PERSON; INDIVIDUALS FROM DIVERSE RACIAL, ETHNIC AND CULTURAL BACKGROUNDS AND COMMUNITIES; WOMEN; VETERANS; INDIVIDUALS WITH DISABILITIES; CORPORATION; PARTNERSHIP; ASSOCIATION; TRUST OR OTHER ENTITY; OR ANY COMBINATION THEREOF, WHO ARE SEEKING A PERMIT ISSUED BY THE DEPARTMENT OF HEALTH TO GROW AND PROCESS OR DISPENSE MEDICAL MARIJUANA. DIVERSE GROUPS INCLUDE THE FOLLOWING BUSINESSES THAT HAVE BEEN CERTIFIED BY A THIRD-PARTY CERTIFYING ORGANIZATION: A DISADVANTAGED BUSINESS, MINORITY-OWNED BUSINESS, AND WOMEN-OWNED BUSINESS AS THOSE TERMS ARE DEFINED IN 74 PA. C.S. 303(B); AND A SERVICE-DISABLED VETERAN-OWNED SMALL BUSINESS OR VETERAN-OWNED SMALL BUSINESS AS THOSE TERMS ARE DEFINED IN 51 PA. C.S Section 3 Diversity Plan By checking Yes, the applicant affirms that it has a diversity plan that establishes a goal of opportunity and access in employment and contracting by the medical marijuana organization. The applicant also affirms that it will make a good faith effort to meet the diversity goals outlined in the diversity plan. Changes to the diversity plan must be approved by the Department of Health in writing. The applicant further agrees to report participation level and involvement of Diverse Participants and Diverse Groups in the form and frequency required by the Department, and to provide any other information the Department deems appropriate regarding ownership, management, employment, and contracting opportunities by Diverse Participants and Diverse Groups. Yes No DIVERSITY PLAN IN NARRATIVE FORM BELOW, DESCRIBE A PLAN THAT ESTABLISHES A GOAL OF DIVERSITY IN OWNERSHIP, MANAGEMENT, 6

7 EMPLOYMENT AND CONTRACTING TO ENSURE THAT DIVERSE PARTICIPANTS AND DIVERSE GROUPS ARE ACCORDED EQUALITY OF OPPORTUNITY. TO THE EXTENT AVAILABLE, INCLUDE THE FOLLOWING: 1. The diversity status of the Principals, Operators, Financial Backers, and Employees of the Medical Marijuana Organization. 2. An official affirmative action plan for the Medical Marijuana Organization. 3. Internal diversity goals adopted by the Medical Marijuana Organization. 4. A plan for diversity-oriented outreach or events the Medical Marijuana Organization will conduct during the term of the permit. 5. Contracts with diverse groups and the expected percentage and dollar amount of revenues that will be paid to the diverse groups. 6. Any materials from the Medical Marijuana Organization s mentoring, training, or professional development programs for diverse groups. 7. Any other information that demonstrates the Medical Marijuana Organization s commitment to diversity practices. 8. A workforce utilization report including the following information for each job category within the Medical Marijuana Organization: a. The total number of persons employed in each job category, b. The total number of men employed in each job category, c. The total number of women employed in each job category, d. The total number of veterans in each job category, e. The total number of service-disabled veterans in each job category, and f. The total number of members of each racial minority employed in each job category. 9. A narrative description of your ability to record and report on the components of the diversity plan. For purposes of this Section, Diverse Participants include a person, including a natural person, individuals from diverse racial, ethnic and cultural backgrounds and communities, women, veterans, individuals with disabilities, corporation partnership, association, trust or other entity or any combination thereof who are seeking a permit issued by the Department of Health to grow and process or dispense Medical Marijuana. For purposes of this Section, Diverse Groups include the following businesses that have been certified by a Third-Party Certifying Organization: a Disadvantaged Business, Minority-Owned Business, and Woman-Owned Business as those terms are defined in 74 PA. C.S. 303(B); and a Service-Disabled Veteran-Owned Small Business or Veteran- Owned Small Business as those terms are defined in 51 PA.C.S (CONFIDENTIAL) 7

8 Diversity Status of Aceso s Principals, Operators, Financial Backers and Employees (CONFIDENTIAL) 8

9 DIVERSITY PLAN (Affirmative Action Plan) Aceso s Diversity Plan is grounded upon a simple policy. Obviously when seeking new employees, operators, suppliers and contractors the most highly-qualified applicant should be sought and selected. That said, in recognition of the importance of diversity and being aware of the benefits provided by a diverse workforce (as well as a diverse operator, contractor and supplier base), Aceso will maintain a constant awareness around issues of diversity when making selections between new employees, operators, suppliers and contractors, and, all other things being equal, shall weigh its ultimate selection in favor of any candidate which will enrich the diversity of Aceso s environment. Aceso is committed to the principle of winning through diversity and inclusion at all levels ownership, participation and operations and contracting. Aceso recognizes that attracting a diverse pool of talented people and retaining them in positions at all levels of the company is essential to our success. In addition, Aceso believes that it must be able to contract for goods and services with diverse vendors and suppliers in order to be successful. Each component of this Diversity Plan is designed to enable Aceso to reach its goal of being an exemplary model as a Pennsylvania Medical Marijuana Organization. Diversity Goals Aceso s has two simple universal diversity goals: 1. To create, honor, and follow its Diversity and Inclusion Mission Statement; and 2. To uniformly adopt within its internal culture an awareness and understanding that Diversity and Inclusion is a mission without end and a constant evolution in recognition that a diverse and inclusive work environment will ultimately produce a stronger, healthier, richer climate for all. DIVERSITY AND INCLUSION MISSION STATEMENT The following mission statement summarizes Aceso s commitment to diversity. It will be posted in prominent places throughout the facility. It communicates the foundation of our diversity and inclusion mission to Team Members, business partners and our community: Aceso is devoted to building and nurturing a diverse and inclusive environment, and is committed to equal opportunity employment and participation by all team members in all employment classifications throughout the organization. This commitment to equal opportunities and diversity also applies to our vendors, suppliers and independent contractors. 9

10 PRINCIPLES AND VALUES We are committed to recruiting, employing, training and advancing talented people of any race, color, national origin, ancestry, sex, sexual orientation, sexual identity and expression, marital status, family status, lifestyle, age, culture, religion, military and veteran status, citizenship, or disability. We actively search for a diverse pool of candidates to provide us with a depth of talent, skills and potential to meet our goals in all employment levels of our operation. We celebrate our diversified employee base and appreciate its cooperative power as a means to meet our business goals. We are committed to offer opportunities to diverse vendors, suppliers, contractors and other service providers from throughout our County and surrounding counties to enhance the participation of such groups in the success of our facility. We require that our contractors and vendors practice equal opportunity policies when they deal with others who provide goods or services to us. Aceso believes that when we partner with diverse persons and businesses, there are limitless opportunities to share knowledge and expertise, and to ultimately assist each other to grow and succeed. LEADING TO WIN A strategic plan must be driven from the highest levels of a company if the plan is to succeed. At Aceso the ultimate responsibility for winning through diversity lies with the Chief Diversity Officer. Aceso has reached an agreement with a consultant to our Board to advise on areas of diversity and helping to ensure compliance with our Diversity Plan. The Chief Diversity Officer is responsible at the Aceso Board level, for strategic planning and evaluation of each department s success in the implementation of the Diversity Plan. Aceso will also have a designated diversity director ( DD or Diversity Director ) who will provide reports to the Chief Operating Officer and operates with the authority of the Chief Operating Officer to monitor the Diversity Plan and other related initiatives. The DD will be chosen annually from the members of the Diversity Task Force. The Diversity Task Force shall be comprised of the Chief Executive Officer, the Chief Operating Officer, the Chief Financial Officer, and the Human Relations Officer. The Task Force will meet with the management team on a quarterly basis to ensure that Aceso meets the commitments of this Diversity Plan. ORGANIZED TO WIN The Diversity Director, together with the Diversity Task Force, shall serve as the monitor for accountability for Team Members involvement in fulfilling the company s Diversity Plan. The Diversity Task Force The Diversity Director and Task Force duties shall include: 10

11 Developing policy statements and diversity programs to effectuate the Diversity and Inclusion Plan. Developing and executing internal and external communication including the dissemination of the Diversity and Inclusion Mission Statement throughout Aceso as well as to business partners, prospective Team Members, current Team Members, contractors and vendors. Identifying opportunities for improvement. Assisting management in implementation of Aceso Diversity Plan and in arriving at solutions to any perceived impediments. Designing and reporting information that will: Measure the effectiveness of the Diversity Plan; Identify areas with opportunities for improvement; Determine the degree to which objectives have been attained; Provide all required statistical reports and documentation to the Pennsylvania Department of Health (the Department ) as required. Serving as liaison between Aceso and the Department of Health, Human Relations Commission, and law enforcement agencies, local organizations concerned with employment opportunities for minorities and women, community action groups and community service programs and historically disadvantaged groups. Performing periodic reviews of hires, promotions, terminations, job classifications, management and supervisory practices, work assignments, training, upward mobility programs, and other terms and conditions of employment as necessary, to ensure adherence to, and conformity with, the goals of the Diversity Plan. Ensuring that the Diversity and Inclusion Mission Statement is identified and posted in Team Member areas. Keeping Aceso management and supervisors informed of the latest developments pertaining to diversity and monitoring best practices in diversity among Medical Marijuana Organizations with guidance from the Pennsylvania Department of Health and the Pennsylvania Human Relations Commission. Assisting the purchasing department in fulfilling the goal of creating participation opportunities for diverse groups in the supply of goods and services to the facility. Assisting the purchasing department in the development of a diverse vendor and supplier database in order to better ensure participation Diverse Participants and Diverse Groups. Developing Winning Managers and Supervisors All Aceso managers and supervisors are responsible for implementation of the Diversity Plan and the goal of winning through diversity. These managers and supervisors include the Chief Financial Officer, the Chief Operating Officer, the Human Relations Officer, the Sales Manager, the Master Grower, the Production Manager, the Cultivation Manager, the Extraction and the Concentrates Production Manager. The responsibilities of these managers and supervisors include: Assisting in the identification of opportunities for improvement and the establishment of unit diversity objectives, which will be developed and reviewed on an ongoing basis. Requiring all Team Members to participate in our Aceso University Program. Requiring fair treatment of all Team Members and discouraging the harassment, intimidation or coercion of any Team Member. 11

12 Recruiting Practices Pennsylvania Department of Health Requiring all Team Members, to participate in company-provided training programs that can assist in their advancement. Disciplining or terminating employees who fail to adhere to the Diversity Plan. Promoting and fostering a collaborative work environment that celebrates and respects diversity. Ensuring all employees comply with and adhere to the Diversity Plan Maintain all Diversity Plan (and related) documentation for review by the Department. WINNING PROGRAMS: DIVERSE TEAM MEMBERS AT ALL LEVELS OF THE COMPANY Aceso is committed to recruiting, retaining, and developing the best employees regardless of race, color religion, sex, age, disability or national origin. Aceso complies with the Equal Employment Opportunity Act and will employ policies consistent with that Act that apply to all employment practices including recruitment, hiring, evaluation, promotion, transfer, discipline, and termination, as well as forms of employee compensation. Furthermore, Aceso will implement a number of concrete steps to ensure that the Diversity Plan is followed in the recruitment of team members at Aceso: The Human Relations Officer will notify all Managers on a regular basis of all open positions. A list of job openings will be distributed on a regular basis to recruitment sources with the ability to reach disadvantaged persons, community action agencies, and minority sources. A list of job openings will be distributed on a regular basis to local colleges, universities, community colleges, trade schools and other organizations that are involved in higher education. Aceso will also have an informational employment section on its website explaining our Diversity Mission Statement and list available job openings, and when possible links to community action agencies with which Aceso has partnered. Available positions at Aceso will be posted on our Company web-site with a brief description and minimum requirements so that all qualified internal Team Members and qualified external applicants will have an opportunity to apply. When advertising for employment opportunities, Aceso will advertise using typical advertising means and will include advertising in minority publications in Lycoming County and surrounding counties, and other publications designed to reach a diverse pool of applicants. The Diversity Director will take appropriate measures to identify and coordinate recruitment efforts with employment sources serving disadvantaged and minority persons. The Human Relations Officer in collaboration with the Diversity Director and Task Force will review and implement on a regular basis additional ways to improve the pool of diverse candidates for all openings. Job Postings All positions will be posted for a minimum of three (3) days and maintained on the Careers section of the Aceso website and/or other areas of the operation. 12

13 Applicant Referral Process All applicants, internal and external, shall be referred to the Human Relations Officer. The Human Relations Officer will identify all qualified internal applicants for positions and refer them to Department Managers for consideration. The Human Relations Officer will identify all qualified external applicants for position openings, once the position has been posted on the company website for a minimum of three (3) days. All qualified applicants will be refereed to Department Managers to be interviewed. College Recruitment The Human Relations Officer will issue notices to career service departments of colleges and universities on a local, state and national level, informing them of our Diversity and Inclusion Mission Statement and initiatives to promote a diverse workforce and will inform them of Aceso s interest in interviewing students and graduates whose educational training and background have prepared them for opportunities within our industry who are members of groups which have been historically disadvantaged. Career Fairs The Human Relations Officer and/or the Diversity Director and Task Force members or their representatives shall attend career fairs in which minorities and females traditionally participate and distribute information which describes the job opportunities available and company sponsored training programs. Leadership Development - Aceso University (CONFIDENTIAL) Aceso University: Diversity Awareness Training for Team Members (CONFIDENTIAL) 13

14 Complaint Resolution Process Aceso will encourage fair treatment of all Team Members and discourages the harassment, intimidation or coercion of any Team Member. The following process to resolve discrimination and harassment complaints will be as follows: If an individual feels that he or she has been a victim of harassment or discrimination in any form by a manager, supervisor, co-worker, customer, client, or any other person in connection with their employment, they should notify their supervisor of the alleged incident or problem immediately. If the complaint involves the team member s direct supervisor or someone in the team member s direct line of supervision they should contact the Human Relations Officer. If an employee is uncomfortable with discussing this matter with the designated manager and/or supervisor or is not satisfied with the action taken by their designated manager and/or supervisor they may select to bypass these individuals, and notify the Human Relations Officer immediately. Supervisors and managers should take each complaint of harassment/discrimination seriously and should not make judgments or opinions as to the validity of the complaint. Each complaint brought to the attention of a supervisor/manager must be reported to the Human 14

15 Relations Officer immediately. All allegations will be investigated by the Human Relations Officer in a timely and confidential manner. They will take appropriate corrective action when warranted. Any team member, who is found, as a result of the investigation, to have engaged in harassment or discrimination is in violation of this policy, will be subject to appropriate disciplinary action, up to and including termination of employment. Retaliation in any form against any team member who exercises his or her rights to make a complaint is strictly prohibited, and will itself be cause for appropriate disciplinary action up to and including termination of employment. WINNING PROGRAMS: DIVERSE SUPPLIERS AND VENDORS Third Party Contracts With Diverse Groups Aceso has committed to utilize a Certified Third Party Minority Owned Business as its electricity supplier. Aceso projects to spend at least $10,000 on electricity consumption. This amount represents 0.5% of Aceso s total annual operational expenses. In addition to this commitment, Aceso will continue to seek and develop contracts with Diverse Participants and Diverse Groups. (See Aceso Agrologics LLC_ _Dispensary_Liberty Power Letter of Intent.pdf) The Chief Operating Officer and the Diversity Director will share the responsibility for identifying and encouraging the participation of minority, disadvantaged, veteran, and women-owned business. The Diversity Director and the Chief Operating Officer will encourage representation and participation of diverse groups in the ownership and operation of businesses that will serve Aceso and provide goods and services to the facility. We are committed to procuring goods, products, and services from a diversified pool of vendors and professional service providers. Our strategy is to work with a broad range of suppliers that are competitive in quality, service, and price. All suppliers are encouraged to support diversity efforts through the use of second-tier supplier programs. Aceso will take the following actions: The Diversity Director and Chief Operating Officer will utilize the list of the minority and women s business enterprises that are pre- qualified by the Bureau of Minority and Women s Business Enterprises of the Pennsylvania Department of General Services Bureau of Diversity, Inclusion & Small Business Opportunities (BDISBO) to seek goods and services from diverse vendors. Aceso will partner with local organizations within its operational area. Aceso will provide a link on the company s website to assist local organizations within the local area, and will include itemized procurement needs and provide informational assistance, such as certification requirements and certification bodies, for all vendors. Aceso will make available on its website information describing procurement needs, processes and general contract information. Aceso will participate in industry-wide events to find qualified Diverse Participants and Diverse Groups with whom to conduct business. Aceso s purchasing personnel (Chief Operating Officer) will help qualified vendors and 15

16 suppliers (as defined by the Pennsylvania Department of General Services), where necessary, by providing pertinent information and feedback so that they can compete effectively on price, service and product quality. Aceso s Diversity Director shall work with the Chief Financial Officer to track dollar volume and performance of suppliers and vendors and provide reports/data to monitor compliance with the Diversity Plan. Aceso through the Diversity Director will collect data and issue reports needed for periodic diversity reporting, including participation reports as defined and required by the Department. The Chief Operating Officer and the Diversity Director will work to develop a Diverse Groups and Diverse Participants network and on the implementation of the Diversity Plan. Aceso purchasing personnel and internal end-users will be trained on supplier diversity policies and procedures and compliance requirements. The Chief Operating Officer will actively solicit and secure services with Diverse Participants and Diverse Groups. The Diversity Director will network with ethnic chambers of commerce and civic organizations to help recruit qualified vendors. The Diversity Director will utilize niche media to help attract qualified vendors. WINNERS NEVER QUIT: AUDIT AND REPORTING SYSTEM At Aceso we knew that we were aiming high when we set Winning through Diversity as our goal. And we know that winners cannot sit back and hope to achieve their goals. Consequently, our plan for winning includes self-scrutiny because winning means always setting the bar ever higher. Internal Progress Reports The Diversity Director and the Diversity Plan Task Force shall monitor company progress to carry out the Diversity Plan. The Diversity Task Force shall receive employment and procurement activity reports for each department and Diverse Participants and Diverse Groups participation reports, at a minimum on a quarterly basis. These reports shall be used to compile a periodic progress report to be submitted to the Diversity Plan Task Force for review and comments. The Diversity Plan Task Force shall assist department managers and supervisors and project site managers by recommending specific actions. Report of Participation As often as required or requested by the Department, Aceso shall file reports with the Department which sets forth the Company s performance in fulfilling the goals of this Diversity Plan. The report shall contain, for each job category within the Company all of the following: The total number of persons employed in each job category. The total number of men employed in each job category. The total number of women employed in each job category. The total number of Veterans employed in each job category. 16

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23 BACKER, OPERATOR AND EMPLOYEE. Pennsylvania Department of Health 1. Title: Chief Executive Officer (CEO) Role: The CEO will be responsible for the hiring, firing, professional development, and supervision of the management team of Aceso (with the help of the Hiring Committee and other Aceso Committees) and will report to the principals of Aceso. Supervisor: Principals of Aceso. Supervision of: Chief Operating Officer, Chief Financial Officer, Human Relations Officer Duties and Responsibilities: Overall management and supervision of Aceso. Supervision of Management Team of Aceso. Liaison between Management Team and Principals of Aceso. Long Term Business Plan and Strategy Developing high quality business strategies and plans ensuring their alignment with short-term and long-term objectives Leading and motivating subordinates to advance employee engagement develop a high performing managerial team Overseeing all operations and business activities to ensure they produce the desired results and are consistent with the overall strategy and mission 2. Title: Chief Operating Officer (COO) Role: The COO will be responsible for overall supervision of the Dispensary operations and for the supervision of all Aceso employees. The COO will be responsible to negotiate and manage procurement activities, and is ultimately responsible for compliance (which is directly supervised by the Dispensary Compliance Officer) with all Federal, State, and Local rules and regulations, and handle public relations and community affairs. The COO will report to the CEO. Supervisor: Chief Executive Officer Supervision of: Staff Medical Professional, Inventory Control Manager, Dispensary Compliance Manager, Maintenance and Security Manager. Duties and Responsibilities: Overall management and supervision of Aceso Operations. Supervision of all Dispensary Operations. Design and implement business strategies, plans and procedures Set comprehensive goals for performance and growth 23

24 Establish policies that promote company culture and vision Oversee operations of the company Lead employees to encourage maximum performance and dedication Evaluate performance by analyzing and interpreting data and metrics Write and submit reports to the CEO in all matters of importance Assist CEO in fundraising ventures Participate in expansion activities (investments, acquisitions, corporate alliances etc.) Manage relationships with partners/vendors Overall conditions on the site or in the facility and correction of any conditions which could compromise the operations of Aceso. 3. Title: Chief Financial Officer (CFO) Role: The CFO will be responsible for the oversight of all financial affairs of Aceso and for the preparation and provision of all financial reporting to Management and to all Federal, State, and Local authorities. The CFO will be responsible for tracking and depositing income receipts, and for making payment of all expenses and obligations of Aceso. The CFO will work in conjunction with the HRO (see below) to fund payroll and employee benefits administration. Supervisor: Chief Executive Officer Supervision of: None. Duties and Responsibilities: Driving the company s financial planning Performing risk management by analyzing the organization s liabilities and investments Deciding on investment strategies by considering cash and liquidity risks Maintaining and Supervising financial reporting, bookkeeping, and financial recordkeeping 4. Title: Human Relations Officer (HRO) Role: The HRO will be responsible for the management of all Aceso employees and to ensure adherence with best employment practices. The HRO will work with the CFO on the coordination of payroll and employee benefits. The HRO will also act as the Chief Diversity Director for Aceso and will work as a liaison between Aceso Employees and outside third party contractors (e.g.: Security, Inventory Management, Facility Maintenance, etc.) to ensure full awareness of Aceso policies and procedures and consistent implementation thereof. 24

25 Supervisor: Chief Executive Officer Supervision of: None. Pennsylvania Department of Health Duties and Responsibilities: Developing and implementing HR strategies and initiatives aligned with the overall business strategy Bridging management and employee relations by addressing demands, grievances or other issues Managing the recruitment and selection process Chief Diversity Officer and implementation and review of Aceso s Diversity Policy Strategic Planning Driving Sales and Cost Controls Inventory Controls Financial Planning and Strategy 5. Title: Chief Medical Officer Role: Responsible for keeping the Company informed and updated from a medical professional perspective. Supervisor: Chief Executive Officer and Board of Aceso Supervision of: None - Advisory Duties and Responsibilities: Staying updated and current on the state of the art in research and advancements in the use and administration of medical marijuana. Advising Aceso Management and Board of medical news impacting the administration of medical marijuana. Monitoring the clinical success of the medical marijuana program in Pennsylvania and reporting findings to Aceso Management and Board. Providing Advisory Support to the Staff Medical Professional 6. Title: Chief Diversity Officer Role: Responsible for reviewing, monitoring, and advising management on diversity and compliance with the letter and spirit of Aceso s Diversity Policy. Supervisor: Chief Executive Officer and Board of Aceso Supervision of: None - Advisory 25

26 Duties and Responsibilities: Staying updated and current on the diversity rules and regulations and best practices in the implementation of diversity policy. Advising Aceso Management and Board of Aceso s diversity performance and compliance with the Diversity Plan. Communicate and coordinate with Aceso s Diversity Director (Human Relations Officer) regarding Aceso s diversity performance and compliance with the Diversity Plan. 7. Title: Staff Medical Professional (SMP) Role: There will be one Staff Medical Professional responsible for all daily operations and maintenance of the Dispensary. Supervisor: Chief Operating Officer Supervision of: Retail Associates, Patient Services Agent Duties and Responsibilities: Manage day to day operations of the Dispensary. Be responsible for implementing policies with the Dispensary. Responsible for supervision and training of all employees. Provide mandatory training for new employees. Work with Retail Associates, Patient Services Agent, and Inventory Control Manager to ensure smooth and proper operation of the Dispensary and proper care of Patients and Caregivers. Serve as Aceso s Recall Coordinator Access to, and responsibility for all Medical Marijuana Products at all times. Responsible to ensure Aceso s compliance with (Limitations on Dispensing). Model the importance of continuing training and education and promote the virtues of Aceso University (Aceso s own training and continuing education program) to all employees. Ensure the utilization of industry best practices. Monitors Aceso s compliance with the Diversity Policy and works with the Human Relations Officer (also the Diversity Director) on the Diversity Committee to continue working with, and fostering relationships with Diverse Participants and Diverse Groups. Acts as Aceso s Recall Coordinator responsible to properly determine voluntary recalls and to properly manage and coordinate and communicate mandatory recall procedures. Ensure Aceso s Dispensary compliance with HIPPA confidentiality standards. B. PLEASE DESCRIBE THE EMPLOYEE QUALIFICATIONS OF EACH PRINCIPAL AND EMPLOYEE. 26

27 All principals and employees of Aceso, including, but not limited to those listed below shall, and shall be required to take and successfully complete the 2 hour training program under the Act and Regulations, in addition to the Qualifications, Training, Licensing, and Experience set forth below: 1. Title: Chief Executive Officer (CEO) Necessary Qualifications: The CEO should be experienced in running and managing business operations. The best CEO is aware of his/her own skillsets but is also equally aware of his/her limitations (when to seek outside help and resources). Furthermore, ethical integrity and moral grounding is essential attributes of a good CEO as the CEO tends to set the tone for the entire organization. The CEO must be 21 years old or older, of strong moral character and reputation, and pass a background test (no convictions of any felony or criminal offence relating to the sale or possession of illegal drugs, narcotics or controlled substances). Required Education/Training/Licensing (if any): Bachelor s degree. Graduate degree preferred. Required Experience (if any): At least 10 years of business management and operational experience. Name of Candidate: (CONFIDENTIAL) 27

28 2. Title: Chief Operating Officer (COO) Necessary Qualifications: The COO should be experienced in managing people in the operations of a business. The best COO has experience in the SPECIFIC business in which the company operates (medical marijuana). The COO must be over 21 years old or older, of strong moral character and reputation, and pass a background test (no convictions of any felony or criminal offence relating to the sale or possession of illegal drugs, narcotics or controlled substances). Required Education/Training/Licensing (if any): Bachelor s degree. Required Experience (if any): Minimum of 5 years of experience in management operations in legal medical marijuana field. Name of Candidate: (CONFIDENTIAL) 28

29 3. Title: Chief Financial Officer (CFO) Necessary Qualifications: The CFO should be experienced in finance, bookkeeping, and accounting. The CFO must be over 21 years old or older, of strong moral character and reputation, and pass a background test (no convictions of any felony or criminal offence relating to the sale or possession of illegal drugs, narcotics or controlled substances). Required Education/Training/Licensing (if any): Preferred Bachelor of Arts or Bachelor of Science. Required Experience (if any): Preferred CFO experience. Preferred Certified Public Accountant. Name of Candidate: No Candidate Selected. 4. Title: Human Resources Officer (HRO) Necessary Qualifications: The HRO should be experienced in human resource operations. The HRO must be over 21 years old or older, of strong moral character and reputation, and pass a background test (no convictions of any felony or criminal offence relating to the sale or possession of illegal drugs, narcotics or controlled substances). Required Education/Training/Licensing (if any): Preferred Bachelor of Arts or Bachelor of Science. Required Experience (if any): Preferred HRO experience. Name of Candidate: No Candidate Selected. 5. Title: Chief Medical Officer (CMO) Necessary Qualifications: The CMO should have a medical degree be experienced in operation of medically-related business operations. The CMO must be 21 years old or older, of strong moral character and reputation, and pass a background test (no convictions of any felony or criminal offence relating to the sale or possession of illegal drugs, narcotics or controlled substances). Required Education/Training/Licensing (if any): Medical Degree. Required Experience (if any): Preferred experience in operation of medically-related business operations. Name of Candidate: (CONFIDENTIAL) 29

30 6. Title: Chief Diversity Officer (CDO) Necessary Qualifications: The CDO should be a female or a member of a minority group or historically disadvantaged group. The CDO must be 21 years old or older, of strong moral character and reputation, and pass a background test (no convictions of any felony or criminal offence relating to the sale or possession of illegal drugs, narcotics or controlled substances). Required Education/Training/Licensing (if any): None required. Required Experience (if any): Preferred experience in staffing and participation in groups advising organizations on issues of diversity. Name of Candidate: No candidate selected. 7. Title: Staff Medical Professional (SMP) Necessary Qualifications: The SMP must be a physician or a pharmacist (Aceso will originally only have one facility and this facility will be staffed by a physician or a pharmacist). The SMP should have experience running or managing a business and managing people within that business. The SMP must be over 21 years old or older, of strong moral character and reputation, and pass a background test (no convictions of any felony or criminal offence relating to the sale or possession of illegal drugs, narcotics or controlled substances). Required Education/Training/Licensing (if any): Doctor of Pharmacy (Pharm D); Medical Doctor, Doctor of Osteopathic Medicine (physician or pharmacist). Completion of four-hour training course developed by the Department prior to assuming any duties at the Dispensary. Required Experience (if any): Business Management Experience (at least 5 years). Name of Candidate: No Candidate Selected. 8. Title: Inventory Control Manager 30

31 Necessary Qualifications: Good organizational skills. The Inventory Manager must be 21 years old or older, of strong moral character and reputation, and pass a background test (no convictions of any felony or criminal offence relating to the sale or possession of illegal drugs, narcotics or controlled substances). Required Education/Training/Licensing (if any): Bachelor of Science preferred. Required Experience (if any): Preferred experience with inventory control software and specifically industry-based seed-to-sale software. Name of Candidate: No Candidate Selected. C. PLEASE DESCRIBE THE STEPS THE APPLICANT WILL TAKE TO ASSURE THAT EACH PRINCIPAL AND EMPLOYEE WILL MEET THE TWO-HOUR TRAINING REQUIREMENT UNDER THE ACT AND REGULATIONS. 1. All principals are required by Company Resolution to comply with the 2 hour training requirement and to otherwise comply with the Act and all Regulations thereunder. 2. All employees are required as a condition of their employment with Aceso to comply with the 2 hour training requirement and to otherwise comply with the Act and all Regulations thereunder. 3. Aceso has an appointed Compliance Officer tasked with ensuring that Aceso remains in compliance with the Act and all Regulations thereunder. 4. Upon being issued a permit by the Department, Aceso s Compliance Officer will begin to coordinate and schedule participation by all Aceso Principals and Employees and contractors with the 2 hour training requirement. 5. Aceso s Dispensary Compliance Officer and Human Relations Officer shall jointly maintain a list of all Aceso Principals and Employees and employees of contractors along with dates of completion of the 2 hour training and copies of any official certificates of completion received from the Department or its approved training agent. 6. Aceso s stated policies in its posted employee material, employee manuals, and employment contracts shall require compliance with the 2 hour training requirement and compliance with the Act and all Regulations in order to maintain employment 7. Each of Aceso s principals will certify to the Board that at all times they remain in compliance with the 2 hour training requirement and compliance with the Act and all Regulations in order to maintain ownership in Aceso. 31

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33 INSPECTION/SERVICING/ALTERATION PROTOCOLS. Pennsylvania Department of Health (CONFIDENTIAL) 33

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44 The date and approximate time of arrival. The transport vehicle s make, model, and license plate number. The identification number of each member of the delivery team accompanying the transport. When a delivery team delivers medical marijuana to multiple medical marijuana organizations, the transport manifest must correctly reflect the specific medical marijuana in transit; each recipient will also provide the dispensary with a printed receipt for the medical marijuana received. All medical marijuana being transported must be packaged in shipping containers and labeled in accordance with and (relating to packaging and labeling of medical marijuana; and labels and safety inserts). Separate copies of the transport manifest will be provided to each recipient receiving the medical marijuana product described in the transport manifest. To maintain confidentiality, a dispensary may prepare separate manifests for each recipient. The applicant acknowledges that, upon request, a copy of the printed transport manifest, and any printed receipts for medical marijuana being transported, will be provided to the Department or its authorized agents, law enforcement, or other Federal, State, or local government officials if necessary to perform the government officials functions and duties. PLEASE PROVIDE AN EXPLANATION OF ANY RESPONSES ABOVE THAT WERE ANSWERED AS A NO AND HOW YOU WILL MEET THESE REQUIREMENTS BY THE TIME THE DEPARTMENT DETERMINES YOU TO BE OPERATIONAL UNDER THE ACT AND REGULATIONS: NOT APPLICABLE C. PLEASE DESCRIBE YOUR PLAN REGARDING THE TRANSPORTATION OF MEDICAL MARIJUANA AND MEDICAL MARIJUANA PRODUCTS. FOR EXAMPLE, EXPLAIN WHETHER YOU PLAN TO MAINTAIN YOUR OWN TRANSPORTATION OPERATION AS PART OF THE FACILITY OPERATION, OR WHETHER YOU WILL USE A THIRD-PARTY CONTRACTOR. IF YOU CHOOSE TO USE YOUR OWN TRANSPORTATION OPERATION, PLEASE PROVIDE THE NUMBER AND TYPE OF VEHICLES THAT WILL BE USED TO TRANSPORT MEDICAL MARIJUANA AND MEDICAL MARIJUANA PRODUCTS, THE TRAINING THAT WILL BE PROVIDED TO EMPLOYEES THAT WILL TRANSPORT MEDICAL MARIJUANA AND MEDICAL MARIJUANA PRODUCTS, AND ANY ADDITIONAL MEASURES YOU WILL TAKE TO PREVENT DIVERSION DURING TRANSPORT. IF YOU WILL BE USING A THIRD-PARTY 44

45 DOH REDACTION

46 DOH REDACTION

47 Security Training Specifics (CONFIDENTIAL) DOH REDACTION 47

48 DOH REDACTION DOH REDACTION 48

49 DOH REDACTION DOH REDACTION a Diversion Prevention Measures During Transportation (CONFIDENTIAL) 49

50 Qualified Third Party Deliveries (CONFIDENTIAL) Summary of Transportation Procedure: Medical marijuana and medical marijuana products may only be transported within the Commonwealth 50

51 DOH REDACTION Pennsylvania Department of Health Summary of Shipment Delivery (Outgoing) (CONFIDENTIAL)

52 Summary of Shipment Delivery (Incoming) (CONFIDENTIAL)

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56 DOH REDACTION Pennsylvania Department of Health Overall Interior Security for Medical Marijuana Product Storage (CONFIDENTIAL) 56

57 1. Storage of Medical Marijuana Products (CONFIDENTIAL) 57

58 2. Storage of Restricted Waste (CONFIDENTIAL) Pennsylvania Department of Health. 3. Storage of Cash and Negotiable Instruments (Cash) (CONFIDENTIAL) 58

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60 package attractive to children. Pennsylvania Department of Health PLEASE PROVIDE AN EXPLANATION OF ANY RESPONSES ABOVE THAT WERE ANSWERED AS A NO AND HOW YOU WILL MEET THESE REQUIREMENTS BY THE TIME THE DEPARTMENT DETERMINES YOU TO BE OPERATIONAL UNDER THE ACT AND REGULATIONS: NOT APPLICABLE B. PLEASE DESCRIBE YOUR PROCESS FOR CREATING AND MONITORING THE LABELING USED FOR MEDICAL MARIJUANA PRODUCTS: DOH REDACTION 60

61 DOH REDACTION Pennsylvania Department of Health Product Labeling (CONFIDENTIAL) 61

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63 5. 6. Product Packaging (CONFIDENTIAL)

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65 of the inventory findings, and the employee identification numbers and titles or positions of the individuals who conducted the inventory. PLEASE PROVIDE AN EXPLANATION OF ANY RESPONSES ABOVE THAT WERE ANSWERED AS A NO AND HOW YOU WILL MEET THESE REQUIREMENTS BY THE TIME THE DEPARTMENT DETERMINES YOU TO BE OPERATIONAL UNDER THE ACT AND REGULATIONS: NOT APPLICABLE C. PLEASE DESCRIBE YOUR APPROACH REGARDING THE IMPLEMENTATION OF AN INVENTORY MANAGEMENT PROCESS. THIS APPROACH MUST ALSO INCLUDE A PROCESS THAT PROVIDES FOR THE RECALL OF MEDICAL MARIJUANA PRODUCTS AND THE MANAGEMENT OF MEDICAL MARIJUANA PRODUCT RETURNS FROM YOU TO THE ORIGINATING GROWER/PROCESSOR: (CONFIDENTIAL) 65

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70 3. 4. Section 15 Diversion Prevention A. PLEASE PROVIDE A SUMMARY OF THE PROCEDURES THAT YOU WILL IMPLEMENT AT EACH PROPOSED FACILITY FOR THE PREVENTION OF THE UNLAWFUL DIVERSION OF MEDICAL MARIJUANA AND MEDICAL MARIJUANA PRODUCTS, ALONG WITH THE PROCESS THAT WILL BE FOLLOWED WHEN EVIDENCE OF THEFT/DIVERSION IS IDENTIFIED: (CONFIDENTIAL) 70

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76 Section 16 Sanitation and Safety A. PLEASE PROVIDE A SUMMARY OF THE INTENDED SANITATION AND SAFETY MEASURES TO BE IMPLEMENTED AT EACH PROPOSED FACILITY LISTED IN THE PERMIT APPLICATION. THESE MEASURES SHOULD COVER, BUT ARE NOT BE LIMITED TO, THE FOLLOWING: A WRITTEN PROCESS FOR CONTAMINATION PREVENTION, PEST PROTECTION PROCEDURES, MEDICAL MARIJUANA PRODUCT HANDLER RESTRICTIONS, AND HAND-WASHING FACILITIES. For purposes of this section and application, seeds, immature medical marijuana plants, medical marijuana plants, and medical marijuana products will be collectively referred to as Medical Marijuana Material, or MMM. Any and all expired, damaged, deteriorated, mislabeled, contaminated, recalled, or otherwise compromised (containers or packages opened or breached) MMM will be collectively referred to as Restricted Waste. While it anticipated that the Aceso Dispensary will only be handling finished Medical Marijuana Product, the more-broad MMM is often used to indicate that the controls are in place regardless of the form of marijuana being addressed. A neat, clean, safe workplace is essential to an efficient, productive, rewarding environment. This section outlines the procedures and protocol utilized by Aceso to ensure a safe and clean work 76

77 environment for employees and contractors so that Aceso can focus its efforts on the growth and processing of consistently high quality medical marijuana for the benefit of qualified patients. GENERAL SANITATION AND SAFETY Aceso s Dispensary will maintain its facility in a sanitary condition to limit the potential for contamination or adulteration of the medical marijuana store in or dispensed at the facility. The following will apply: 1. Trash will be properly removed. 2. Floors, walls, and ceilings will be kept in good repair. 3. Adequate protection against pests will be provided by the use of integrated pest management practices and techniques that identify and manage pest problems and the regular disposal of trash to prevent infestation. 4. Toxic cleaning compounds, sanitizing agents, solvents and pesticide chemicals must be labeled and stored in a manner that prevents contamination of medical marijuana and in a manner that otherwise complies with other applicable laws and regulations. Aceso s employees working in direct contact with medical marijuana is subject to restrictions on food handlers in (relating to restrictions on food handlers). An employee will otherwise conform to sanitary practices while on duty, including the following: 1. Maintaining adequate personal hygiene. 2. Washing hands thoroughly in an adequate hand-washing area before starting work and at any time when hands may have become soiled or contaminated and at all times before dispensing medical marijuana to a patient or caregiver. Aceso will provide its employees and visitors with adequate and convenient hand-washing facilities furnished with running water at a temperature suitable for sanitizing hands. The following will apply: 1. Hand-washing facilities must be located where good sanitary practices require employees to wash and sanitize hands. 2. Effective nontoxic sanitizing cleansers and sanitary towel service or suitable hand-drying devices will be provided. Aceso will provide its employees and visitors with adequate, readily accessible lavatories that are maintained in a sanitary condition and in good repair. Aceso will comply with all other applicable State and local building code requirements. Handwashing Facilities: All Aceso employees and visitors will have access to, and require employees to wash hands in multiple 77

78 and convenient hand washing facilities (located in the Men s Restroom, the Women s Restroom and in the Break Room) providing running water at a temperature suitable for sanitizing hands and nontoxic sanitizing cleansers and sanitary drying devices. Aceso bathroom facilities will be readily accessible and maintained in a neat, clean, sanitary condition cleaned daily as an accessory duty of a Retail Associate willing to handle as part of their daily routine. Aceso s water supply is provided by public water supply and is adequate for its operations. Aceso s facility will be in compliance with all State and local building code requirements. The construction and design of the entire facility, including equipment, fixtures, and shelving will take into consideration materials and surfaces which will facilitate the maintenance of a clean and sterile environment. The facility is designed for a smooth work flow so that the movement of materials through the facility can be done in a systematic and efficient manner. The Product Safe (for storage of bulk medical marijuana product inventory) separately stores products from any Restricted Waste or quarantined medical marijuana product which is separately stored in the Restricted Waste Safe. Inspection Schedules (CONFIDENTIAL) Handler Restrictions and Sanitation Procedures Handler restrictions and sanitation procedures include: 78

79 All handlers of MMM and all Aceso employees will be over 18 years old and will have completed the State mandatory 2 hour training as well as Aceso s training on its Standard Operating Procedures (which will be prepared and finalized for review by the Department prior to operation). All Aceso employees working in direct contact with medical marijuana will maintain personal hygiene, wear proper clothing (see below for cultivation and lab clothing), wear gloves, and wash hands thoroughly before beginning work and at all other times when hands become soiled or contaminated in accordance with restrictions on food handlers (per 28 Pa. Code ). All Sales Associates, Delivery Team Members, the Patient Services Agent, the Staff Medical Professional, and the Inventory Control Manager will be responsible for keeping their respective workspaces neat and clean on a daily basis. All Sales Associates, the Patient Services Agent, the Staff Medical Professional, and the Inventory Control Manager will dress neatly and professionally in a uniform designated by Aceso and maintain a neat, clean, professional appearance. (Delivery Team Members clothing will not indicate any association with medical marijuana). All Sales Associates, Delivery Team Members, the Patient Services Agent, the Staff Medical Professional, and the Inventory Control Manager will wear their Aceso-provided identifications at all times while in the Dispensary. The overall Dispensary will be cleaned nightly at the end of each operational day by an Aceso employee (a Retail Agent handling this added role under the supervision of the Staff Medical Professional). Cleaning will include all bathrooms, hallway, and common area floors. Garbage (non Restricted Waste) will be removed daily from the inside common areas and taken to the exterior trash area by the above-referenced employee(s). All Restricted Waste will be properly documented on the inventory management system and neatly stored in the Restricted Waste Safe in the Inventory Room by the Inventory Control Manager until it is properly disposed of in accordance with Aceso s Restricted Waste disposal program (returned to the supplying grower/processor). Pest Protection Procedures (CONFIDENTIAL) 79

80 Sanitation: Maintaining a clean and sterile environment is the most important phase of the IPM program. The above-referenced maintenance and sanitation procedures will be the first step in ensuring a neat, clean, sterile environment. Monitoring: IPM requires a thorough and daily assessment of the facility. All employees, under the supervision of the Staff Medical Professional, will play a part in monitoring conditions and reporting any pests for treatment. Identification of Pest Problems: Visual inspections (by all Aceso employees and under the daily supervision of the Staff Medical Professional) are the primary method for determining if pest problems exist in the Dispensary. Any pests or evidence of pests will be identified and called to the attention of the Staff Medical Professional. Control Methods: Should any pests be identified by employee observation or by the quarterly professional pest control provider, the Staff Medical Professional will coordinate and schedule the appropriate treatment with the professional pest control provider. Evaluation: All aspects of the IPM Program will be thoroughly documented, including frequency, rates, methodology and time/date when applied (per ). Records will be completed within 24 hours of the completion of each application and will be maintained in Aceso s records for at least 4 years. A record will be made immediately available to the Department or its authorized agents and medical personnel or first responders in an emergency. All records will be available for inspection by the Department of Health and the Department of Agriculture upon request and will include: 1. The date of application. For a pesticide requiring re-entry time, the date of application must also include the hour completed. 2. The place of application. 3. The size of the area treated. 4. The product name of every pesticide used. 5. The United States Environmental Protection Agency product registration number. This requirement is unnecessary for products exempted under section 25 of the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C.A. 136w). 6. The total amount of pesticide used in pounds, ounces, gallons or liters applied to a treated area. 7. The dosage or rate of application of every pesticide used. 8. If applicable, the employee identification numbers of the individuals involved in making the pesticide and the permit or certification number of the individuals making or supervising the application. 80

81 9. Copies of pesticide labels and Safety Data Sheets for the pesticides used at the facility. CONTAMINATION PREVENTION Aceso is very aware that its facility will be producing products for human consumption. Thus, Aceso s protocols will require careful and intentional storage and inventory management of all chemicals and substances so as to ensure that the Finished Medical Marijuana Product meets the highest levels of sanitation and purity for human consumption purposes and to minimize chances of contamination. Specific storage requirements are: Storage of Cleaning and Janitorial Products Responsibility: The Maintenance and Security Manager and the Inventory Control Manager will be responsible for the storage and inventory of cleaning supplies, facility cleaning agents, and janitorial supplies and products (collectively Janitorial Supplies). Access: Access to Janitorial Supplies will be limited to the Maintenance and Security Manager and the Inventory Control Manager and the Aceso employees (added duties of specific Retail Associates) assigned to facility cleaning. Janitorial Supplies will be stored and neatly labeled and shelved in a locked utility closet in a manner that will prevent contamination of medical marijuana and in an manner that otherwise complies with other applicable laws and regulations. Storage Specifications: All Janitorial Supplies will be safely and neatly stored in a locked utility closet in tightly closed containers consistent with the storage label on such products (if applicable) and consistent with The Inventory Control Manager will be responsible to maintain log sheets and inventory of all Janitorial Supplies. Proper eye protection, gloves, skin protection (clothing) will also be required during the use of Janitorial Supplies, per labeling on such products. Proper fire extinguishers will be mounted and installed in the facility and a centralized, monitored smoke and fire detection equipment will be utilized and maintained. SUMMARY Aceso s above-referenced sanitation and safety procedures will minimize the risk of contamination of MMM from pests and disease, and any other impurities which would render the Finished Medical Marijuana Product unfit for human consumption. Only after following all of the above safety protocols and methodical processing procedures, will a Medical Marijuana Products be made available for sale to patients and caregivers. Section 17 Recordkeeping A. PLEASE PROVIDE A SUMMARY OF YOUR RECORDKEEPING PLAN AT EACH PROPOSED FACILITY LISTED IN THE PERMIT 81

82 APPLICATION. THIS PLAN SHOULD COVER, BUT IS NOT LIMITED TO, RECORDS OF INVENTORY AND ALL DISPENSING TRANSACTIONS: For purposes of this section and application, seeds, immature medical marijuana plants, medical marijuana plants, and medical marijuana products will be collectively referred to as Medical Marijuana Material, or MMM. Any and all expired, damaged, deteriorated, mislabeled, contaminated, recalled, or otherwise compromised (containers or packages opened or breached) MMM will be collectively referred to as Restricted Waste. While it anticipated that the Aceso Dispensary will only be handling finished Medical Marijuana Product, the more-broad MMM is often used to indicate that the controls are in place regardless of the form of marijuana being addressed. Finished Medical Marijuana Product is what will ultimately be dispensed to serve the medical needs of Patients under the Pennsylvania Medical Marijuana Program. Aceso is highly aware of the highest levels of scrutiny that any new State program is under and the many complex interests which must be served in the process. This is particularly true in the case of medical marijuana. As an integral part of this Program, Aceso is committed to maintaining model-level standards of performance to set the bar for others to follow, and to ensure the success of Pennsylvania s Medical Marijuana Program under the supervision of the Department of Health. Critical to this success is the ability for the Department of Health to have full access to Aceso s complete, accurate, thorough, safely-maintained records of operation. Accordingly, Aceso will fully track, log, document and record such complete records for Department review and inspection in areas including, but not limited to: MMM inventory at the Dispensary or within the custody of any employee or individual within the control of Aceso (documenting seed-to-sale cycle as tracked in Aceso s Inventory Management System (IMS)) Standard Operating Procedures pest treatment, facility maintenance (inspections and calibrations), equipment maintenance (inspections and calibrations), alarm, security and surveillance, sanitation and cleaning, supplies inventory, employees (employee files and training records), transportation of MMM (and Transportation Manifests), complaints and recalls, security breaches, thefts or MMM diversion quality control (including improvements made to Standard Operating Processes), and financial records (sales, income, and expenses). All of the above-referenced information and data will be collectively referred to as RR (required records). 82

83 Records Keeping and Retention (CONFIDENTIAL) Pennsylvania Department of Health Inventory Records (CONFIDENTIAL) 83

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85 Diversion Prevention Records (CONFIDENTIAL) 85

86 Aceso Protocol Upon Discovery of Theft or Diversion (CONFIDENTIAL) Complaints about Medical Marijuana Upon becoming aware of any complaint made by a patient, caregiver, or practitioner who reports an adverse event from using medical marijuana dispensed from Aceso, Aceso s Inventory Control Manager will immediately notify the Department and the grower/processor. At this point, it is up to the grower/processor to investigate and either resolve the complaint by either determining no further action is required (within 24 hours), issuing a voluntary recall, or complying with a mandatory recall. Out of caution, the Aceso Dispensary will quarantine and set aside all affected medical marijuana pending such determination. Pending determination, the Inventory Control Manager will isolate and separately label (labeled PENDING POSSIBLE RECALL - DO NOT SELL ), collectively package, and separately store the affected medical marijuana in the Product Safe. Grower/Processor as follows: 1. Grower/Processor will immediately investigate the complaint to determine whether a voluntary or mandatory recall is required. 2. If Grower/Processor determines no further action is required, it will notify the Department of 86

87 its decision and, within 24 hours, submit a written report stating its rationale for not taking further action. 3. If Grower/Processor determines a voluntary recall is required, it will notify the Department at the time it begins the recall. The Grower/Processor may also initiate a voluntary recall at any other time on its own initiative, and will notify the Department at the time any recall is begun. 4. If Grower/Processor discovers a condition relating to the medical marijuana grown or processed at its facility poses a risk to public health and safety, it will: Immediately notify the Department by phone, secure, isolate, and prevent the distribution of the medical marijuana that may have been affected by the condition and remains in its possession. Grower/Processor will not dispose of or destroy any affected medical marijuana prior to notifying the Department and coordinating the disposal with the Department. The Aceso Dispensary will work with, and cooperate with any Grower/Processors in coordinating any voluntary and mandatory recalls will coordinate the return of the recalled medical marijuana with the Grower/Processor. Medical Marijuana Product Returns Aceso will maintain all records relating to medical marijuana complaints and medical marijuana product returns. Aceso s Dispensary will comply with (Complaints about or Recall of Medical Marijuana) and all other Regulations and Department requirements. Aceso s Recall Coordinator is responsible for developing, refining and maintaining Aceso s Recall Plan protocols. The Recall Plan will include a process for coordinating the return of recalled medical marijuana with the grower/processor. Aceso understands that the complaint and/or possible recall process is based upon clear and quick communication between the patients, caregivers, practitioners, the Aceso Dispensary, grower/processors, and the Department. Aceso will do its best to cooperate with this communication process and, upon discovery of any concerns with medical marijuana, to help identify and isolate (quarantine) affected medical marijuana, and to coordinate the return of the same (if recall is determined) to the grower/processor for proper storage and ultimate proper disposition. Employee Recordkeeping (CONFIDENTIAL) Equipment Maintenance Records Included in RR will be records pertaining to all facility operational equipment, including safes, HVAC, door and window hardware, interior electrical and lighting, and the security system and surveillance equipment (as addressed in Section 10). These records will be maintained by the Maintenance and 87

88 Security Manager electronically all as part of a backed-up and secure information network of the operations of Aceso to be used for operational reviews and improvements, as well as for the inspection and evaluation by the Department and its authorized agents. Facility Maintenance Included in RR will be records pertaining to the structure, roof, windows, doors (and hardware), plumbing, electrical equipment, driving and parking surfaces, sidewalks, and exterior fencing and gates. These records will be maintained by the Maintenance and Security Manager electronically all as part of a backed-up and secure information network of the operations of Aceso to be used for operational reviews and improvements, as well as for the inspection and evaluation by the Department and its authorized agents. Financial (CONFIDENTIAL) Security and Surveillance (CONFIDENTIAL) 88

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90 PA Department of Revenue Tax number (if applicant is currently doing business in Pennsylvania): PA Workers Compensation Policy Number (if applicant is currently doing business in Pennsylvania): The applicant affirms that workers compensation insurance will be obtained by the time the Department determines you to be operational under the Act and regulations. Yes No SECTION 19 BUSINESS HISTORY AND CAPACITY TO OPERATE DESCRIBE YOUR BUSINESS HISTORY AND YOUR ABILITY AND PLAN TO MAINTAIN A SUCCESSFUL AND FINANCIALLY SUSTAINABLE OPERATION: (CONFIDENTIAL) 90

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104 SECTION 22 CAPITAL REQUIREMENTS Pennsylvania Department of Health PROVIDE A SUMMARY OF YOUR AVAILABLE CAPITAL AND AN ESTIMATED SPENDING PLAN TO BE USED FOR YOU TO BECOME OPERATIONAL WITHIN SIX MONTHS FROM THE DATE OF ISSUANCE OF THE PERMIT: (CONFIDENTIAL)

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109 Part F Community Impact (Scoring Method: 100 Points) SECTION 23 COMMUNITY IMPACT PLEASE BE ADVISED, INDICATION OF SUPPORT FROM PUBLIC OFFICIALS WILL NOT BE CONSIDERED WHEN EVALUATING THIS SECTION. PROVIDE A SUMMARY OF HOW THE APPLICANT INTENDS TO HAVE A POSITIVE IMPACT ON THE COMMUNITY WHERE ITS OPERATIONS ARE PROPOSED TO BE LOCATED: For purposes of this section and application, seeds, immature medical marijuana plants, medical marijuana plants, and medical marijuana products will be collectively referred to as Medical Marijuana Material, or MMM. Any and all expired, damaged, deteriorated, mislabeled, contaminated, recalled, or otherwise compromised (containers or packages opened or breached) MMM will be collectively referred to as Restricted Waste. While it anticipated that the Aceso Dispensary will only be handling finished Medical Marijuana Product, the more-broad MMM is often used to indicate that the controls are in place regardless of the form of marijuana being addressed. For purposes of this Section, Diverse Participants include a person, including a natural person, individuals from diverse racial, ethnic and cultural backgrounds and communities, women, veterans, individuals with disabilities, corporation partnership, association, trust or other entity or any combination thereof who are seeking a permit issued by the Department of Health to grow and process or dispense Medical Marijuana. For purposes of this Section, Diverse Groups include the following businesses that have been certified by a Third-Party Certifying Organization: a Disadvantaged Business, Minority-Owned Business, and Woman-Owned Business as those terms are defined in 74 PA. C.S. 303(B); and a Service-Disabled Veteran-Owned Small Business or Veteran-Owned Small Business as those terms are defined in 51 PA.C.S Location of Facilities Aceso s dispensary is located at 2364 Commercial Blvd., College Township, Centre County, State College, Pennsylvania and is within the North-Central Region of the Pennsylvania Department of Health. Aceso s dispensary consists of an approximately 1,500 square feet space (the Dispensary ) within an approximately 6,000 square foot commercial building (the Building ) under lease from 2360 Commercial LP, the legal owner of the Building and property (the Building and the property collectively the Property ) at 2360 Commercial Blvd. (the Owner ). Aceso has a secured a purchase option to purchase the Property from the Owner. This will provide Aceso with the ability to expand operations throughout the Building and the Property, should it be necessary or required in the future. 109

110 The Dispensary is located on Commercial Blvd., just off of E. College Ave (PA Route 26), which is a feeder road into State College (only 2.6 miles to Penn State University). The Dispensary enjoys immediate proximity to restaurants, banking, grocery stores, hotels, housing, and has excellent road access to E. College Avenue (PA Route 26), PA Route 150, and Interstate Route 99 Community Impact 1. Employment Impact Aceso expects to employ approximately 13 people. The average annual salary of Aceso employees at the Dispensary is expected to be approximately $101,000 plus an average of approximately $14,000 per employee in benefits (health insurance and 401k matching). Thus the expected total average employee annual salary plus benefits should exceed $115,000 at the Facility, which is over twice the average median household income in the Centre County area between 2011 and 2015 per the United States Census. Of the 13 Aceso employees, approximately 7 will be management-level employees including the Chief Executive Officer, the Chief Financial Officer, the Chief Operating Officer, the Human Relations Officer, the Inventory Control Manager, the Staff Medical Professional, and the Maintenance and Security Manager. Aceso s Human Relations Officer (HRO) will be primarily responsible for employee recruitment. Primary 110

111 recruitment resources for the HRO will include college recruitment and career fairs. State College is home to the main campus of the Pennsylvania State University and also to South Hills School of Business and Technology, which will serve as key recruitment locations for Aceso s HRO. Aceso will develop relationships with the respective offices of career development and placement in each of these organizations in order to create a symbiotic relationship of connecting the school s qualified candidates with Aceso s job opportunity positions. The HRO will also connect with and work with local area trade organizations, local government community and economic development organizations (e.g.: Chamber of Business and Industry of Centre County and the Bellefonte Intervalley Area Chamber of Commerce) to similarly communicate regarding Aceso job opportunities as well as to connect on areas where Aceso can continue increase its community involvement. Leadership Development - Aceso University (CONFIDENTIAL) 111

112 Contractor and Commerce Impact Pennsylvania Department of Health Aceso expects to hire and retain contractors to perform many services and to supply products necessary to support Aceso s substantial operations. Aceso expects it will utilize over $450,000 per year on service contractors and over $150,000 in initial fit out expense. Aceso s Chief Operating Officer, Inventory Control Manager, and Staff Medical Professional (the Purchasing Team) will work to procure service and supply contracts with a focus in and around the local community. Aceso s Purchasing Team will seek to associate with contractors, suppliers, and service providers who act responsibly, professionally, and share in Aceso s goals and values. The Purchasing Team will seek to work with as many local firms in this process as possible. Furthermore, as part of the contracting process, the Purchasing Team will seek to associate with Diverse Participants and Diverse Groups in furtherance and advancement of Aceso s Diversity Plan. As of 2012, the Centre County area had 3,436 women-owned firms, 749 minority-owned firms, and 1,055 veteran-owned firms per the United States Census. Aceso strongly believes that the more ties and relationships Aceso builds locally, the stronger the local bonds will grow to become. Aceso will have an annual total payroll in excess of $1,300,000. Furthermore, Aceso will engage a significant volume of contractors, suppliers and service providers, expected to collectively total over $451,000 annually. Collectively, over $2,000,000 annually will be added largely to the local community in and around the State College area and surrounding community in Centre County. All expenses incurred by Aceso will tend to create an economic multiplier effect, as each dollar spent by Aceso (on Employees, local contractors, local suppliers, and local service providers) is an extra dollar available (to that Employee, local contractor, or local supplier) to spend on other things. Aceso strongly believes that this added economic activity (and its resultant multiplier effect) will be a tremendous short term and long term benefit to Armstrong Township, the State College area, and Centre County. Initial Economic Impact Aceso s Facility will require approximately as much as $150,000 worth of renovations and improvements to its College Township location. Aceso s Chief Operating Officer will work to source local contractors and suppliers for as much of this work as is practicable. These fit-out expenses, spent locally will also provide the same multiplier effect referenced above). Tax Benefits As a contributing community member in College Township, the State College area, Centre County, and Pennsylvania, Aceso s activities will generate tax revenues for the respective taxing authorities. Aceso will ensure that all of its tax obligations (duties, in Aceso s opinion) are paid fully, timely and responsibly. Aceso fully understands that, as a member of the local community (and of the County and State), that Aceso will also participate in a role as a consumer of government goods and services and that these benefits come at a cost. Accordingly, Aceso will fully, timely, and responsibly honor all of its tax commitments (including, but not limited to, Wage and Unemployment Compensation Taxes, Sales and Use Taxes (on goods and services purchase by Aceso), and local property and income taxes). Community Charitable Causes 112

113 The finished Medical Marijuana Product is what will ultimately be dispensed to serve the medical needs of Patients under the Pennsylvania Medical Marijuana Program. Aceso is highly aware of the highest levels of scrutiny that any new State program is under and the many complex interests which must be served in the process. This is particularly true in the case of medical marijuana. As an integral part of this Program, Aceso is committed to maintaining model-level standards of performance to set the bar for others to follow, and to ensure the success of Pennsylvania s Medical Marijuana Program under the supervision of the Department of Health. Aceso recognizes and understands that it represents a new and different type of organization in College Township, the State College area, and Centre County. Furthermore, Aceso s operation as a dispensary of Medical Marijuana is completely new to Pennsylvania and its local communities. Aceso believes that this newness creates a unique and compelling opportunity for Aceso to demonstrate its intentions to integrate smoothly and cooperatively into the community and to provide meaningful and mutuallybeneficial results. As previously mentioned, Aceso is also applying for a Grower/Processor permit for a location in Armstrong Township, Lycoming County (also in the Department s North-Central Region). As part of Aceso s community impact in the North-Central Region, Aceso connected with, and feels strongly about doing something to help the opioid epidemic gripping the Lycoming County area where Aceso s proposed grower/processor facility is located. Lycoming County and the Williamsport area (including Armstrong Township) has struggled, and continues to struggle with epidemic levels of opioid addiction, opioid abuse, and opioid overdoses. These problems have impacted and run across all racial, gender, ethnic, religious, and socio-economic groups. According to the National Institute on Drug Abuse in 2014, it was estimated that 2.1 million people suffer from substance abuse disorders relating to prescription opioid pain relievers and 476,000 addicted to heroin. While opioid addiction and abuse is certainly not isolated (as it is occurring across Pennsylvania and nationally as well), Lycoming County and the Williamsport area is particularly hard-hit. By December 5, 2016, the Lycoming County Coroner recorded (and confirmed) 28 drug deaths for 2016, 23 of which were related to opiates and 16 involving heroin. According to Project Bald Eagle, a regional coalition working to prevent the growing opioid and heroin epidemic in multiple counties in northern central Pennsylvania, one in four families in Lycoming County is directly dealing with opioid addiction. According to the National Institute on Drug abuse, nearly half of those addicted to heroin abused prescription medications before beginning to use heroin. Since many frequently-prescribed pain medications are opioid-based (and highly addictive) it follows that when prescriptions run out, users resort to cheap, illegal alternatives such as heroin. Aceso believes that the legalization of Medical Marijuana in Pennsylvania will offer the Pennsylvania medical community with a superior alternative for pain treatment (and other State approved treatments) which will reduce the prescribing of opioid-based medications, and thus serve to stem the growing opioid addiction epidemic. 1. Project Bald Eagle - Charitable Contribution Aceso s Chief Executive Officer (CEO) has reviewed Project Bald Eagle s Mission Statement ( Project Bald 113

114 Eagle is a 501(c) 3 non-profit organization that is leading coalition efforts to stem the tide of the heroin epidemic through Education, Prevention, Treatment, Enforcement and Data Monitoring ), researched the local opioid epidemic, and spoken and corresponded with the Executive Director of Project Bald Eagle. Project Bald Eagle is a community-wide coalition that aggressively develops and supports efforts aimed at reducing prescription drug and & heroin abuse. Aceso believes that the Pennsylvania Medical Marijuana Program is innately aligned with Project Bald Eagle s mission. Furthermore, Aceso strongly believes in Project Bald Eagle s mission and purpose. Aceso s expressed its intention of opening a Medical Marijuana Grower/Processor facility in Armstrong Township, Lycoming County and Aceso offered to contribute 2% of its annual operating Dispensary profits towards Project Bald Eagle should Aceso be successful in obtaining its permit with the Department. Project Bald Eagle s Executive Director indicated that he would work to formalize a relationship in conjunction with Project Bald Eagle s Board of Directors. 2. D.A.R.E. - Charitable Contribution To supplement Aceso s commitment to helping to stem the tide of the local opioid epidemic Aceso also wishes to directly provide an, education-based drug awareness program tailored towards teaching younger people. D.A.R.E. is a national organization and its mission is Teaching students good decisionmaking skills to help those lead safe and healthy lives. Aceso s CEO is working to provide funding towards a Lycoming County D.A.R.E. officer to further D.A.R.E. s goal towards its mission for students in Lycoming County. Aceso intends to contribute 2% of its annual operating Dispensary profits towards D.A.R.E. (or alternatively towards a program tailored in cooperation with the Lycoming County Sheriff s Department) in order to educate and help local students learn good decision-making skills (which includes avoiding dangerous drugs) in another effort to ultimately help reduce the local area s opioid epidemic. Community Impact Summary Aceso is fully convinced that its participation in the community will lead to a symbiotic and mutuallybeneficial relationship for all. In addition to providing an expected 13 jobs at more than double the area household median, providing over $451,000 in contractor and service and supply spending, and generating federal, State, and local tax revenues, Aceso is putting its best foot forward by offering to contribute a total of 4% of its annual profits towards local charitable and beneficial causes tailored specifically to our intended new home. We are hopeful that our Application we will ultimately prove worthy of the Department s trust in Aceso becoming an important part of Pennsylvania s Medical Marijuana Program. 114

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