RIW Adam R. Barnosky, Esq. Direct: 617.570.3519 E-mail: arb@riw.com

RUBERTO. ISRAEL & WEINER

VIA IN HAND DELIVERY Department of Public Health Medical Use of Marijuana Program RMD Applications 99 Chauncy Street, 11 'h Floor Boston, MA 02111

Re: Management Operations Profile Valley Green Grow, Ine.

Dear Sir/Madam:

August 7, 2017

~'

I write on behalf of Valley Green Grow, Inc. regarding its request to the Department of Public Health for Certificates of Registration to operate three (3) Registered Marijuana Dispensaries in the Commonwealth of Massachusetts. Pursuant to the Department of Public Health's Invitation to submit a Management and Operations Profile dated June 21, 2017, kindly find the follow documents enclosed:

1. Valley Green Grow, Inc., Management Operations Profile (1 of 3)

a. Remittance Form b. Management Operations Profile Application; c. Articles of Incorporation; d. Certificate of Good Standing from the Massachusetts Secretai.y of State;

Co1porate Bylaws; and e.

f. Bank Check payable to the Commonwealth ofNiassachttsetts for $30,000.00 g. Employment and Education Forms

(i) Chief Executive Officer: Jeffrey Goldstein (ii) Chief Financial Officer: Mark Frechette (iii) (iv) (v)

Chief Operating Officer: Thomas Regan Chief Cultivator: Hendrik Van Duijne Chief of Security Planning & Operations: John Garvin

2. Valley Green Grow, Inc., Management Operations Profile (2 of3)

a. Remittance Form b. Management Operations Profile Application; c. Articles of Incorporation; d. Certificate of Good Standing from the Massachusetts Secretaiy of State; e. Corporate Bylaws; and f. Bank Check payable to the Commonwealth of Massachusetts for $30,000.00 g. Employment and Education Forms

(00633793.DOC/1}

Ruberto, Israel & Weiner, P.C. 255 State Street, 7th Floor Boston, MA 02109 T: 617.742.4200 F: 617.742.2355 www.riw.com

Letter to Department of Public Health Medical Use of Marijuana Program August 7, 2017 Page Two

(i) Chief Executive Officer: Jeffrey Goldstein (ii) Chief Financial Officer: Mark Frechette (iii) Chief Operating Officer: Thomas Regan (iv) Chief Cultivator: Hendrik Van Duijne (v) Chief of Security Planning & Operations: John Garvin

3. Valley Green Grow, Inc., Management Operations Profile (3 of3)

a. Remittance Form b. Management Operations Profile Application; c. Articles of Incorporation; d. Certificate of Good Standing from the Massachusetts Secretary of State; e. Corporate Bylaws; and f. Bank Check payable to the Commonwealth of Massachusetts for $30,000.00 g. Employment and Education Forms

(i) Chief Executive Officer: Jeffrey Goldstein (ii) Chief Financial Officer: Mark Frechette (iii) Chief Operating Officer: Thomas Regan (iv) Chief Cultivator: Hendrik Van Duijne (v) Chief of Security Planning & Operations: John Ga1vin

4. Authorization Forms (in a sealed envelope)

a. Background Check Authorization Cover Sheet b. Bank Check Payable to Ct?ative Services, Inc. (Corporate Background Checks) c. Bank Check Payable to C!?ative Services, Inc. (Personal Background Checks) d. Chief Executive Officer Jeffrey Goldstein's Background Check Forms e. Chief Financial Officer Mark Frechette's Background Check Forms f. Chief Operating Officer Thomas Regan's Background Check Forms g. Chief Cultivation Officer Hendrik Van Duijne's Background Check Forms h. Chief of Security John Ga1vin's Background Check Forms

Thank you for your attention to this matter. Please be in touch if you have any questions on the enclosed applications or if any further information is required.

Enclosures cc: Valley Green Grow, Inc. (via Email)

(00633793.DOC/1)

Ve1y tiuly yours,

R//O, ISRAEL & WEINER, P.C.

~LA /\ ,/± 1 L

CHARLES D. BAKER Governor

KARYN E. POLITO Lieutenant Governor

INSTRUCTIONS

The Commonwealth of Massachusetts Executive Office of Health and Human Services

Department of Public Health Bureau of Health Care Safety and Quality

Medical Use of Marijuana Program 99 Chauncy Street, 11 1

h Floor, Boston, MA 02111

MARYLOU SUDOERS Secretary

MONICA BHAREL, MD, MPH Commissioner

Tel: 617-660-5370 www.mass.gov/medicalmarijuana

MANAGEMENT AND OPERATIONS PROFILE Request for a Certificate to Registration to

Operate a Registered Marijuaua Dispensary

This application form is to be completed by a non-profit corporation that wishes to apply for a Certificate of Registration to operate a Registered Marijuana Dispensary ("RMD") in Massachusetts, and has been invited by the Department of Public Health (the "Department") to submit a Management and Operations Profile.

Once invited by the Department to submit a Management and Operations Profile, the applicant must submit the Management and Operations Profile within 45 days from the date of the invitation letter, or the applicant must submit a new Application of Intent and fee.

If invited by the Department to submit a Management and Operations Profile for more than one proposed RMD, you must submit a separate Management and Operations Profile, attachments, and application fee for each proposed RMD. Please identify each application of multiple applications by designating it as Application I, 2 or 3 in the header of each application page. Please note that no executive, member, or any entity owned or controlled by such an executive or member, may directly o'r indirectly control more than three RMDs.

However, even if submitting a Management and Operations Profile for more than one RMD, an applicant need only submit one background check packet, including authorization forms for all required individuals, and fee associated with the background checks.

Unless indicated otherwise, all responses must be typed into the application forms. Handwritten responses will not be accepted. Please note that character limits include spaces.

Attachments should be labelled or marked so as to identify the question to which it relates.

Each submitted application must be a complete, collated response, printed single-sided, and secured with a binder clip (no ring binders, spiral binding, staples, or folders).

Valley Green Grow, Inc. Application _2_ of _3_ Applicant Non-Profit Corporation ______________ _

Mail or hand-deliver the Management and Operations Profile, with all required attachments, the $30,000 application fee, and completed Remittance Form to:

Department of Public Health Medical Use of Marijuana Program

RMD Applications 99 Chauncy Street, 11th Floor

Boston, MA 02111

All fees are non-refundable and non-transferable.

REVIEW

Applications are reviewed in the order they are received.

After a completed application packet and fee is received by the Department, the Department will review the information and will contact the applicant if clarifications/updates to the submitted application materials are needed. The Depattment will notify the applicant whether they have met the standards necessary to be invited to submit a Siting Profile.

Applicants must receive an invitation from the Department to submit a Siting Profile within 1 year of the date of submission of the Management and Operations Profile or the applicant must submit a new Application of Intent and fee in order to proceed in the application process.

PROVISIONAL CERTIFICATE OF REGISTRATION

Applicants must receive a Provisional Certificate of Registration from the Department within 1 year of the date of the invitation letter from the Department to submit a Siting Profile. If the applicant does not meet this deadline, the application will be considered to have expired. Should the applicant wish to proceed with obtaining a Certificate of Registration, a new application must be submitted, beginning with an Application of Intent, together with the associated fee.

REGULATIONS

For complete information regarding registration of an RMD, please refer to 105 CMR 725.100.

It is the applicant's t·esponsibility to ensure that all responses are consistent with the requirements of 105 CMR 725.000, et seq., and any requirements specified by the Depattment, as applicable.

PUBLIC RECORDS

Please note that all application responses, including all attachments, will be subject to release pursuant to a public records request, as redacted pursuant to the requirements at M.G.L. c. 4, § 7(26).

QUESTIONS

If additional infonnation is needed regarding the RMD application process, please contact the Medical Use of Marijuana Program at 617-660-5370 or RMDaprlication@state.ma.us.

/)J '

Information on this page has been reviewed by the applican~/ i./9/Wlfere provided by the applicant, is accurate and con1plete, as indicated by the initials of the authorized signatory here: _j /..;!__

J/ Manage1nent and Operations Profile - Page 2

Valley Green Grow, Inc. Application 2 of_3_ Applicant Non-Profit Corporation---------------

CHECKLIST

The forms and documents listed below must accompany each application, and be submitted as outlined above:

129A fully and properly completed Management and Operations Profile, signed by an authorized signatory of the applicant non-profit corporation (the "Corporation")

IKI A copy of the Corporation's Articles of Organization

IS1! A copy of the Corporation's Certificate of Good Standing from the Massachusetts Secretary of State. The Certificate of Good Standing must be dated no earlier than 90 days prior to the date the Management and Operations Profile is received by the Department.

5<I A copy of the Corporation's bylaws

~An Employment and Education form (use template provided) for each of the following individuals: The Corporation's Chief Executive Officer, Chief Operations Officer, Chief Financial Officer, individual/entity responsible for marijuana for medical use cultivation operations, and individual/entity responsible for the RMD security plan and security operations

,Pil A bank or cashier's check made payable to the Commonwealth of Massachusetts for $30,000

IXl A completed Remittance Form (use template provided)

Iii A sealed envelope with the name of the Corporation and marked "authorization forms," that contains the

background check authorization forms (use forms provided) and fee, for each of the following actors:

• Chief Executive Officer; Chief Operating Officer; Chief Financial Officer; individual/entity responsible for marijuana for medical use cultivation operations; individual/entity responsible for the RMD security plan and security operations; each member of the Board of Directors; each Member of the Corporation, if any; and each person and entity known to date that is committed to contributing 5% or more of initial capital to operate the proposed RMD. For entities contributing initial capital to operate the proposed RMD, authorizations forms must be completed and signed by the entity's Chief Executive Officer/Executive Director and President/Chair of the Board of Directors.

ii

.1!1 Information on t?i~ page has been re~iewed by the applicaf~tw~~re provided by the applicant, is accurate and complete, as md1cated by the m1l!als of the authonzed signatory here: ; f;

· Manage1nent and Operations Profile - Page 3

f / [i

Application 2 of 3 . . Valley Green Grow Inc. Applicant Non-Profit Corporat10n ________ ' _______ _

SECTION A. APPLICANT INFORMATION

Valley Green Grow, Inc. I.

2.

3.

4.

5.

6.

Legal name of Corporation

Jeffrey Goldstein

Name of Corporation's Chief Executive Officer 1600 Osgood Street North Andover, MA 01845

Address of Corporation (Street, City/Town, Zip Code) Michael D. Rosen, Esq. Ruberto, Israel & Weiner P.C., 255 State Street, 7th Fl., Boston, MA 02109

Applicant point of contact (name of person Department of Public Health should contact regarding this application)

(617) 742-4200

Applicant point of contact's telephone number mdr@riw.com

Applicant point of contact's e-mail address

7. Number of applications: How many Management and Operations Profiles do you intend to submit?

3

SECTION B. INCORPORATION

8. Attach a copy of the corporation's Articles of Organization, documenting that the applicant is a non­profit entity incorporated in Massachusetts.

9. Attach a copy of the corporation's Cettificate of Good Standing from the Massachusetts Secretaty of State. The Certificate of Good Standing must be dated no earlier than 90 days prior to the date the Management and Operations Profile is received by the Department.

10. Attach a copy of the corporation's bylaws.

11;! /// //

Infonnation on this page has been reviewed by the applica1~(;-/a,{c;14here provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here:-"'. · .. '/,i!-

/ t/ Manage1nent and Operations Profile -Page 4

Ir r

6172270178

Name Approved

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M R.A.

nc.

D D D D

MA SOC Filing Number: 201728484800 Date: 3/17/2017 2:47:00 PM

02:43:20p.m. 03-17-2017 2 /7

Filing F<e: $35.00

'Qebt Qt.ommontotaltb of 3JiaS"s-aebu.S'tttS' WllUam Francis Galvin

Secretary of the Commonwealth OneAshburton Place, Room 1717, Boston, Massachusous 02108-1512

Valley Green Grow, Inc.

•• ARTICLES OF ORGANIZATION

(General Lawi1, Chapter 180)

ARTICLE I 1bc cnct·namc of'thc cotpora.tlon h:

ARTICLE II 'Tho purpose of tho corporation k to cng;ge In the fullowing acrlvltl~<:

The oorporatlon Is organized for nonprom purposes Including, but not llmllad to, providing wellness seivlces and products to pallents suffering from debllltaUng medical conditions: adu.catlng patients and oommunlty stakeholders about wellness and public health; engaging In community activities related to wellness and public health: and conduct and support research and development In Iha fields of cannabis cultlvatlon; and to evaluate the rtsks and sustainable madlcel benefits of cannabis. As permitted by law, the corporation . may engage.In any and all activities In furtherance of, related to, or lnclderrtal to these purposes, the activities being lawful for a corporation formed under Chapter 160 of the General Laws of Massachusetts: · Any revenue from the corporation shall be used solely In compliance with applloable laws for non-profit corporations In Iha Commonwealth of Massachusetts.

".

6172270178 02:43:31 p.m. 03-17-2017

ARTICLEIII A corporndon may have one or more classes of members. Iflr does, the di:sJgnadon of :iUch classes, the mQJlner of dec:tion or appointments, the durnrlon of membeahlp and the qualification and rlgh,., including voting rlgho, of the members of eacli clau, may beset fotth ln the by-laws of the corporation or may be.'" forth below:

Mey be sat fo!1h In Bylaws.

ARTICLEN **Other lawful provision$, lf :mri for the conduct and regulatlon of the businen and affii.lrs of th-e corporaclon, for lrs voluntary dlnolutlon1 or fur Um.itlng1 defining, or rcgu)adng the powetS of the cor:pGratlollJ or ofltJ dlrcctots or members, or of any class of members, arc as fotlows:

Saa Attached.

ARTICLEV The by-Jaws of the corpora don have been duly adopted and the lnltlal dln:crors, pmldent, tn:aslltc! and clerk or other pn:sldlng, financial or recording oflken, whos~ name.i: are set out on the followJng page, have been duly elected.

317

6172270178 02:43:39 p.rn. 03-17-2017

ARTICLE VI The c!fectlve datc ofo!Jll!l117atlon of the tvrporndnn shall be the date llJ>pmvd and.filed by the Smcwy of the Commonwdch. lfa /aterelfcctlve date ls d..IIcd, specllY such date which shall not h• more dum thlny ~I after the date of filing.

ARTICLE VII 'Ihc information contained 1n .Article VII ls not a. pmnMent part of the Artldu of Organlzatlon,

a. The litrett address (pDst office boxei arc not act(!prable) of the princlpaJ office of the corpotatlon in MttJiathusatt is:

1600 Osgood Street, North Andover, MA 01646

b. The name, residential address and post office address of each director and officer of the c:orpotatlon ls as follows:

President:

Treasurer:

Clerk:

Directors: (or ofliccro having th• power.of dimmn)

NAME [See AltachnienlJ

RESIDENTIAL ADDRESS

c, '!he fiscal Y"" of the corporation shall end on the last day of the monch of: December

d. The name and buslni:ss address of the resident aient, if any, of the corporatlon ls:

NA

POST OFPICEADDRBSS

IIWc, che bdow signed lncorporator(s), do hereby ccrrlfy under the pains and penalties of pcrjucy chat I/we have not been con~lctcd of any alines relating to alcohol or gaming within chc past o:n l""'· I/We do hcr<by lurcher certify that m the b"t of my/our knowledge the 11.bovc--namcd officers have noi been slmllarly convicted. If 10 convicted, cxph11n.

IN WITNESS WliEREOF AND UNDER THE PAINS AND PENALTIES OF PERJURY, I/we, whose algnaturo{s) appw bdow" lncorporator(s) and whose name(•) and busino" or "'81dcntlal addrds(es) art el.ar/y typtd or prlntedbeneath e,P. slgnatUr<, do hereby wocl· ate with the Intend n · rml s corporation under che provblon.s of General Lawi, Chapter 180 and do hereby sign theseArtlcles of Organhadon as Is .15fu._day of March , 20,..J1L.L7 __

1600 Osgood Street, North Andover, MA 01846

Notti Jf llll a/sdngtorporallon II it#lnglU ltim11'ortt10r; 'Jl}ll in lht tz4lltutm• oftk RJ'1'orlftlo"' lbd lt#tl orotlitr Juriullakm whm ltWIU lnzorpamtnl. Jhttutm~ o/fA, pm on ril"lngon 61/J11!f af WJ &f11POn1tiori itfU/ th~ tltk hU1bt bo1"s ar at/Jtr IU'th11rlty h, whlr:b 111tb mtlon. U Mfan.

417

6172270178

Valley Green Grow, Inc. Articles of Organization Article IV: Other Provisions

02:43:52 p.m. 03-17-2017

The corporation is organized exclusively for nonprofit purposes lllld shall be operated in in accordllllce with the laws of the Commonwealth of Massachusetts. · Except to tlte extent. prohibited under M.G.L. Chapter 180, the coi:poration shall have the same powers as business corporations under M.G.L. Chapter 156B. Those powers include, but are not limited to: (1) to be a partner in any business venture which the corpo!ation would have the power to conduct on its own; (2) to make contracts of guaranty and suretyship, whether or not in furtherance of the corporation's purposes; (3) to borrow or lend money; and (4) to sell, convey, lease, exchange, transfer or otherwise dispose of, or mortgage, pledge, encumber or create a security interest in all or any ofits property, or any interest. therein. ·

In the event of dissolution of the corporation, the board of directors shall, after paying or making provisions for the payment of all of the liabilities of the corporation, dispose of all the assets of the corporation, as the board of directors shall· determine, in accordance with the statutes of the Commonwealth of Massachusetts.

No officer or director of the corporation shall be personally liable to the corporation for monetary damages for or arising out of a breach of fiduciary duty as an officer or director notwithstanding any provildon of fuw imposing such liability, provided, however, that the foregoing shall not eliminate or limit the liability of an officer or director to the extent that such . liability is imposed by applicable Jaw (i) for a breach of the officer's or director's duty of!oyalty to the corporation or its members, (ii) for acts or omissions not in good faith or which involve intentional misconduct or a knowing violation· of Massachusetts law, or (iii) for any transaction from which the officer or director derived ail improper personal benefit.

The corporation shall, to the extent legally permissible, indemnify each person who may serve or who has served at any time as an officer or director of the corporation against all expenses and liabilities, including, without limitation, counsel fees, judgments, fines, ,excise taxes, penalties and settlement payments, reasonably incurred by or imposed upon such person in connection with any threatened, pending or completed action, suit or proceeding in which he or 'she may become involved by reason of bis or her service in such capacity; provided that no indemnification shall be proVided for any such person with respect to any matter as to which he or she shall have been finally adjudicated in any proceedjng not to have acted in good faith in the reasonable belief that such action was in the best interests of the corporation; and further provider that any compromise or settlement payment shall be approved by a majority vote of the quorum of directors who are not at that time parties too the proceeding.

{OOS9070l.00or/4)

5 /7

6172270178

Valley Green Grow, Inc. Articles of Organization Article VII: Officers and Directors

Officeg

Jeffrey Goldstein, President 1600 Osgood Sti:eet North Andover, MA 01845

Jeffrey Goldstein, Secretary 1600 Osgood Street North Andover, MA 01845

Jeffrey Goldstein, Treasurer 1600 Osgood Street North Andover, MA 01845

Directors

Jeffrey Goldstein 1600 Osgood Street North Andover, MA 01845

(OOS90703,DOCJ(/4)

02:44: 19 p.m. 03-17-2017 717

6172270178 02:44:11 p.m. 03-17-2017

The indemnification provided hereunder shall inure to the benefit of the heirs, executors and administrators of persons entitled to indemnification hereunder. The right of indemnification under this Article shall be in addition to and not exclnsive of all other rights to which any such person may be entitled.

This· Article constitutes a contract between the corporation and the indemnified officers and directors. No amendment or repeal of the provisions of this Article which adversely affects the right of an indemnified officer or director under this Article shall apply to such officer or . director with reSPect to those acts or omissions which occurred at any time prior to such amendment or repeal.

(00580703,00CX/4}

6/7

MA SOC Filing Number: 201728484800 Date: 3/17/2017 2:47:00 PM

THE COMMONWEALTH OF MASSACHUSETTS

I hereby certify that, upon examination of this document, duly submitted to me, it appears

that the provisions of the General Laws relative to corporations have been complied with,

and I hereby approve said articles; and the filing fee having been paid, said articles are

deemed to have been filed with me on:

March 17, 2017 02:47 PM

WILLIAM FRANCIS GALVIN

Secretary of the Commonwealth

William Ftancis Galvin Secretary of the Commonwealth

~ <Jomnwmoeafth·[!/' .A!A&Sac~ , fecret:o y (!/th& Oom.1n/H?f,(J£a!th

Jtate SfOtto.e, [i]oJ:to11, Jf£usachtto.ett& 02/SS

Date: July 26, 2017

To Whom It May Concern :

I hereby ce1iify that according to the records of this office,

VALLEY GREEN GROW, INC.

is a domestic corporation organized on March 17, 2017

I further ce1iify that there are no proceedings presently pending under the Massachusetts Gen-

era! Laws Chapter 180 section 26 A, for revocation of the charter of said corporation; that the

State Secretary has not received notice of dissolution of the corporation pursuant to Massachu-

setts General Laws, Chapter 180, Section 11, 11 A, or 11 B; that said corporation has filed all

annual repmis, and paid all fees with respect to such repo1is, and so far as appears of record said

corporation has legal existence and is in good standing with this office.

In testimony of which,

I have hereunto affixed the

Great Seal of the Commonwealth

on the date first above written.

///~~~ Secretary of the Commonwealth

Certificate Number: 17070438190

Verify this Ce1tificate at: http://corp.sec.state.111a.us/CorpWeb/Ce1tificates/Verify.aspx

Processed by:

BYLAWS

of

VALLEY GREEN GROW, INC.

March 17, 2017

ARTICLE I

General Provisions

Section 1.1 Name. The name of this corporation is Valley Green Grow, Inc. and shall herein be referred to as "the corporation."

Section 1.2 Offices. The principal business office of the corporation shall be at 1600 Osgood Street, North Andover, Massachusetts 01845. The corporation may also have offices at such other places as the corporation may require.

Section 1.3 Fiscal Year. The fiscal year of the corporation shall begin on January 1 and.end on the following December 31 of each year.

Section 1.4 Membership. The Member(s) of the corporation are those persons listed in the List of Members appended hereto. The Charter Member(s) are those persons who were members at the time of incorporation of the corporation. The Members shall have such powers as provided by law, the Articles of Organization, or these By-laws. The Member(s) may act by meeting or written consent. Additional persons may be elected to membership by the Member(s). A person elected a Member shall remain a Member until his or her death, resignation or removal. A Member other than the Charter Member may be removed by a majority vote of the directors.

ARTICLE2

Statement of Purposes

The corporation is organized for nonprofit purposes including, but not limited to, providing wellness services to patients suffering from debilitating medical conditions; educating patients and community stakeholders about wellness and public health; and engaging in community activities related to wellness and public health. As permitted by law, the corporation may engage in any and all activities in furtherance of, related to, or incidental to these purposes, the activities being lawful for a corporation formed under Chapter 180 of the General Laws of Massachusetts. All Registered Medical Dispensaries (RMDs) related to the corporation shall at all times operate on a non-profit basis and shall ensure that any revenue from the corporation's RMD(s) shall be used solely in in accordance with the laws governing non-profit corporations in the Commonwealth of Massachusetts ..

{00590795.DOCXII l}

ARTICLE3

Board of Directors

Section 3.1 Authority. The business and affairs of the corporation shall be controlled and governed by the board of directors, which shall, unless otherwise stated herein, have the right to exercise all powers of the corporation as permitted by law.

Section 3.2 Composition. Except as otherwise provided by law, (a) the number of directors; and (b) manner by which new directors are nominated and appointed; shall be determined by the Charter Member, or in the event of the death, incapacity, or resignation of the Charter Member, then by the Manager of Emerald Ventures, LLC.

Section 3.3 Terms of Office. Except as provided herein, the board of directors shall determine the length and number of terms to be served by directors.

Section 3.4 Meetings. The board of directors shall hold annual meetings each year and may select the time and place for annual and other meetings of the board. Other meetings of the board of directors may be called by the president or by a majority of the directors then in office by delivering notice in writing, of the date, time, place, and purpose of such meeting, to all directors at least three (3) days in advance of such meeting.

Section 3.5 Quorum and Voting. A majority of the board of directors shall constitute a quorum for the transaction of business at any meeting of the board. At any meeting of the board of directors at which a quorum is present, a majority of those directors present shall decide any matter, unless a different vote is specified by law, the Articles of Organization, or these bylaws.

Section 3.6 Meetings by Remote Communication. One or more directors may attend any annual, regular, special, or committee meeting of the board through telephonic, electronic, or other means of communication by which all directors have the ability to fully and equally participate in all discussions and voting on a substantially simultaneous basis. Such participation shall constitute presence in person at such meeting.

Section 3. 7 Action Without a Meeting. Any action required or permitted to be taken at any board meeting may be taken without a meeting if a consent in writing, setting forth the action to be taken, shall be signed by all of the directors with respect to such subject matter. Such consent, which may be signed in counterparts, shall have the same force and effect as a vote of the board of directors.

Section 3.8 Waiver of Notice for Meetings. Whenever any notice of a meeting is required to be given to any director under the Articles of Organization, these bylaws, or the laws of Massachusetts, a waiver of notice in writing signed by the director, whether before or after the time of the meeting, shall be equivalent to the giving of such notice.

(00590795.DOCX/l l)

Section 3.9 Committees. The board of directors may create such standing and special committees as it determines to be in the best interest of the corporation. The board of directors shall determine the duties, powers, and composition of such committees, except that the board shall not delegate to such committees those powers which by law may not be delegated. Each such committee shall submit to the board of directors at such meetings as the board may designate, a report of the actions and recommendations of such committees for consideration and approval by the board of directors. Any committee may be te1minated at any time by the board of directors

Section 3.10 Compensation. Directors as such shall not receive any salaries for their services on the board, but directors shall not be precluded from serving the corporation in any other capacity and receiving reasonable compensation.

Section 3.11 Resignation. Any director may resign by delivering a written resignation to the corporation at its principal office or to the president or clerk. Such resignation shall be effective upon receipt unless it is specified to be effective at some later time.

Section 3.12 Removal. Except as provided herein, any director may be removed, with or without assignment of cause by a vote of the majority of the entire board of directors at any meeting of the board of directors or by the Charter Member, or in the event of the death, incapacity; or resignation of the Charter Member, then by the Manager of Emerald Ventures, LLC. No member of the board shall be removed from office unless the notice of the meeting at which removal is to be considered states such purpose and opportunity to be heard at such meeting is given to the director whose removal is sought. Notwithstanding the notice provision of Section 3.4 above, written notice shall be delivered to all directors at least fourteen (14) days in advance of a meeting at which removal is sought. Founding director Jeffrey Goldstein shall be a director in perpetuity and may only be removed for Cause upon a unanimous vote of the disinterested directors. For the purpose of this Section "Cause" shall mean if any director: (1) fails to qualify as a dispensary agent as determined by the Massachusetts Department of Public Health ("DPH"); (2) is found unsuitable or unqualified to sit as director of a registered marijuana dispensary as determined by DPH pursuant to written notice to the non-profit; (3) engages in any negligent, reckless, or intentional action or inaction that causes substantial financial or reputational injury to the non-profit, or jeopardizes the non-profits ability to receive or a renew a marijuana dispensary permit, as determined in a written opinion of the non-profit's legal counsel; or ( 4) or disability of the director such that the director cannot perform the director's duties for a period equal to ninety (90) days in any three hundred sixty-five (365) day period.

Section 3.13 Vacancies. Any vacancy occurring in the board of directors shall be filled in accordance with Section 3 .2. A director elected to fill a vacancy shall be elected for the unexpired term of his or her predecessor in office.

ARTICLE4

Officers

(00590795.DOCX/l l}

Section 4.1 Officers. The officers of the corporation shall be a president, a treasurer, and a clerk of the board of directors and such other officers as may be elected in accordance with the provisions of this Article.

Section 4.2 Election. The officers of the corporation shall be elected annually by the board of directors at the annual meeting. Each officer shall hold office until a successor shall have been elected and qualified.

Section 4.3 Vacancies. A vacancy in any office because of death, resignation, disqualification, or otherwise may be filled by the board of directors for the unexpired portion of the term.

Section 4.4 Removal. Any officer may be removed, with or without assignment of cause, by a vote of a majority of the entire board of directors at any meeting of the board of directors. No officer shall be removed from office unless the notice of the meeting at which removal is to be considered states such purpose and opportunity to be heard at such meeting is given to the officer whose removal is sought. Notwithstanding the notice provision of Section 3.4 above, written notice shall be delivered to all directors at least fourteen (14) days in advance of a meeting at which removal is sought

Section 4.5 President. The president shall preside at all meetings of the board of directors. The president, or other proper officer or agent of the corporation authorized by the board of directors, may sign any deeds, mortgages, bonds, contracts, or other instruments which the board of directors has authorized to be executed. The president shall perform all duties incident to the office of president and such other duties as may be prescribed by the board of directors from time to time.

Section 4.7 Treasurer. The treasurer, or other proper officer or agent of the corporation authorized by the board of directors, shall have charge and custody of and be responsible for all funds and securities of the corporation; receive and give receipt for moneys due and payable to the corporation from any source whatsoever, and deposit all such moneys in the name of the corporation in such banks, trust companies, or other depositories as shall be selected by the board of directors; and in general perform all of the duties incident to the office of treasurer and such others as may from time to time be assigned by the board of directors.

Section 4.8 Clerk. The clerk shall keep the minutes of the meetings of the board of directors in one or more books provided for that purpose; ensure that all notices are given in accordance with the provisions of these bylaws; be custodian of the corporate records; and in general perform all such duties as may from time to time be assigned by the board of directors.

ARTICLES

Corporate Transactions

Section 5.1 Contracts. The board of directors may authorize any officer or officers, agent or agents of the corporation in addition to the officers so authorized by these bylaws, to

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enter into any contract or execute and deliver any instrument in the name of and on behalf of the corporation, and such authority may be general or confined by specific instances.

Section 5.2 Indebtedness. All checks, drafts, or orders for the payment of money, notes, or other evidence of indebtedness issued in the name of the corporation, shall be signed by the president or treasurer, or such other officer or agent of the corporation as from time to time may be determined by the board of directors. In the absence of such determination of the board, such instruments shall be signed by the president or treasurer of the corporation.

Section 5.3 Deposits. All funds of the corporation shall be deposited from time to time to the credit of the corporation in such banks, trust companies, brokerages, or other depositories as the board of directors shall select.

ARTICLE6

Books and Records

The corporation shall keep at the principal office of the corporation correct and complete books and records of account; minutes of the proceedings of board of directors; and a register of the names and addresses of the directors of the corporation. All books, and records of the corporation may be inspected by any director, or agent or attorney thereof, for any proper purpose ,at any reasonable time.

ARTICLE7

Restrictions on Activities

No part of the net earnings of the corporation shall inure to the benefit of, or be distributable to its directors, officers, or other private persons, except that the corporation shall be authorized and empowered to pay reasonable compensation for services rendered and to make payments and distributions in furtherance of the purposes of the corporation.

ARTICLES

Dissolution

In the event of dissolution of the corporation, the board of directors shall, after paying or making provisions for the payment of all of the liabilities of the corporation, dispose of all the assets of the corporation as the board of directors shall determine, in accordance with the statutes of the Commonwealth of Massachusetts.

ARTICLE9

Conflicts of Interest

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Whenever a director or officer has a financial or personal interest in any matter corning before the board of directors, the affected person shall fully disclose the nature of the interest and take any other such actions as required by applicable law or pursuant to this Article 9. No director may receive compensation or other benefits for serving as an officer or employee of the company unless the terms and conditions of such compensation and/or benefits have been reviewed and approved by two (2) disinterested board members. The minutes of meetings at which such votes are taken shall record such disclosure, abstention and rationale for approval. This Article may be further defined by the directors in pursuant to a written policy incorporated herein.

ARTICLE 10

Personal Liability

No officer or director of the corporation shall be personally liable to the corporation for monetary damages for or arising out of a breach of fiduciary duty as an officer or director notwithstanding any provision oflaw imposing such liability; provided, however, that the foregoing shall not eliminate or limit the liability of an officer or director to the extent that such liability is imposed by applicable law (i) for a breach of the officer's or director's duty ofloyalty to the corporation or its members, (ii) for acts or omissions not in good faith or which involve intentional misconduct or a knowing violation of Massachusetts law, or (iii) for any transaction from which the officer or director derived an improper personal benefit.

ARTICLE 11

Indemnification

The corporation shall, to the extent legally permissible, indemnify each person who may serve or who has served at any time as an officer or director of the corporation against all expenses and liabilities, including, without limitation, counsel fees, judgments, fines, excise taxes, penalties and settlement payments, reasonably incurred by or imposed upon such person in connection with any threatened, pending or completed action, suit or proceeding in which he or she may become involved by reason of his or her service in such capacity; provided that no indenrnification shall be provided for any such person with respect to any matter as to which he or she shall have been finally adjudicated in any proceeding not to have acted in good faith in the reasonable belief that such action was in the best interests of the corporation; and further provided that any compromise or settlement payment shall be approved by a majority vote of a quorum of directors who are not at that time parties to the proceeding.

The indenmification provided hereunder shall inure to the benefit of the heirs, executors and administrators of persons entitled to indemnification hereunder. The right of indemnification under this Article shall be in addition to and not exclusive of all other rights to which any person may be entitled.

This Article constitutes a contract between the corporation and the indemnified officers and directors. No amendment or repeal of the provisions of this Article which adversely affects

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the right of an indemnified officer or director under this Article shall apply to such officer or director with respect to those acts or omissions which occurred at any time prior to such amendment or repeal.

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ARTICLE 12

Amendments to Bylaws; Conversion

These bylaws may be amended or repealed by a majority vote of the entire board of directors, provided however that amendment or repeal of Sections 3 .12 and this Section 12, must also be approved by founding director, Jeffrey Goldstein, or in the event of the death, incapacity, removal or resignation of Jeffrey Goldstein, then by the Manager of Emerald Ventures, LLC.

To the extent allowed by the Commonwealth of Massachusetts General Laws (the "General Laws"), the corporation shall be entitled to convert into a domestic business corporation or a domestic other entity, or any other such domestic business entity as permitted by the General Laws, by adopting a plan of entity conversion in accordance the General Laws. Unless otherwise provided by the General Laws, authority to elect such conversion shall be vested in the Charter Member.

ARTICLE13

Policies

The Board of Directors _may adopt and amend policies that shall be incorporated into these By­Laws. The following policies have beeil adopted and incorporated herein:

Appendix 1: Document Retention and Destruction Policy Appendix 2: Comprehensive Information Security Policy

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LIST OF MEMBER(S)

The Member(s) of the corporation are:

Jeffrey Goldstein, Charter Member

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Appendix I

VALLEY GREEN GROW, INC. DOCUMENT RETENTION AND DESTRUCTION POLICY

This document retention policy ("Policy") sets forth the Valley Green Grow, Inc.'s ("VGG") policies and procedures for the management of documents (as defined below).

VGG takes seriously its obligations to preserve information relating to litigation, audits, and investigations. The information listed in the retention schedule below is intended as a guideline and may not contain all the records VGG may be required to keep in the future.

From time to time, V GG may suspend the destruction of records due to pending, threatened, or otherwise reasonably foreseeable litigation, audits, government investigations, or similar proceedings.

I. DEFINITIONS

A. "Document" means any document, communication, memorandum, report, record, data compilation or other similar item generated, received, transmitted or maintained by the VGG or its employees, for or on behalf of VGG. This definition applies regardless of the format, storage method, or medium used to store the item, including any paper, chart, card, book, photograph, microfilm, microfiche, magnetic media, daily planner, electronic calendar, computer tape, floppy disk, zip drive, computer hard drive, e-mail, electronic image or CD-ROM, and any copy, back-up or printout thereof (including informational, working and personal copies).

B. "Retention Schedule" means the document included herein, which sets forth time periods for the retention of Documents, and any subsequent versions thereof.

C. "Record Retention Coordinator" refers to the person serving in the position of Treasurer.

D. "Disposal Suspension Notice" means a notice prepared by the Treasurer, directing that disposal of Documents relating to a particular matter should be suspended.

II. OBJECTIVES

The objectives of this Policy are:

A. To establish a consistent policy for managing, retaining, storing and disposing of Documents, regardless of the media in which they are stored;

B. To ensure the preservation of Documents relevant to any pending, threatened, reasonably foreseeable or contemplated legal action or proceeding or government investigation;

C. To ensure that Documents required for VGG's operations are maintained in an efficient manner so they can be readily accessed when necessary;

D. To comply with applicable legal requirements for retaining Documents; and

E. To ensure an appropriate and orderly Document disposal process.

III.POLICY

The general policy of V GG is to retain for an appropriate time all Documents that are needed to operate VGG or required by law to be retained. Documents should be retained or routinely disposed of in accordance with the time periods indicated in the Retention Schedule. These time periods apply to all Documents regardless of how or· where they are maintained. The time periods listed in the Retention Schedule do not apply, however, if the Record Retention Coordinator has issued a Document Disposal Suspension Notice requiring certain Documents or categories of Documents to be retained. This Policy will be consistently and uniformly applied throughout VGG.

Documents that are reasonably likely to be relevant to any pending, threatened, reasonably foreseeable or contemplated (i) legal action or proceeding (e.g., a civil lawsuit), . or (ii) govermnent investigation (e.g., an IRS audit), should not under any circumstances, be altered, mutilated, concealed, deleted, destroyed or otherwise disposed of without the specific authorization of the Record Retention Coordinator. Under the circumstances described above, routine Document disposal must be suspended pending authorization by the Record Retention Coordinator to resume it.

IV. RESPONSIBILITIES

Employees

Every employee is required to manage Documents in their possession or control in accordance with this Policy.

Records Retention Coordinator

The responsibilities of the Records Retention Coordinator include:

A. Assuming overall responsibility for VGG's compliance with the Retention Schedule;

B. Communicating the requirements of this Policy to all employees;

C. Interpreting for employees the provisions of this Policy or the Retention Schedule as they may apply to specific situations and consulting with the Record Retention Coordinator regarding those interpretations, as needed;

D. Training employees to implement this Policy;

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E. Supervising the implementation of and ensuring compliance with this Policy;

F. Notifying employees of, and monitoring their compliance with, any Document Disposal Suspension Notice; and

G. Providing notice to all employees of exceptions or modifications to the Retention Schedule.

H. Modifying or amending the Retention Schedule.

V. lf\1PLEMENTATION

A. The Record Retention Coordinator will, when necessary, provide notice to the appropriate persons in the company that they need to identify Documents that have exceeded their retention period and should be disposed.

B. Document Storage. Documents that are being retained should be stored in a secure storage area that is reasonably safeguarded against theft, inappropriate access, misuse and damage (including events such as fire and flood).

C. Document Disposal. Docµments requiring routine disposal pursuant to the Retention Schedule are to be handled in the following manner:

1. Each employee will identify Documents m their possession that have exceeded the required retention period;

2. Each employee will confirm that none of the identified Documents should be retained pursuant to any Document Disposal Suspension Notice;

3. Each employee will approve and prepare for disposal all Documents that have exceeded the required retention period and are not required to be retained under any Document Disposal Suspension Notice;

4. Hard copy Documents will be disposed of by shredding or burning such that no Document disposed of remains intact; and

5. Electronic Documents will be disposed of by the information technology service that supports the firm pursuant to a data disposal program.

If an employee is uncertain whether a particular Document should be retained or disposed of, he or she should promptly seek advice from the Record Retention Coordinator.

D. Email. The cost of indiscriminately retaining e-mail can be significant. Accordingly, employees will store e-mails they are required to retain in accordance with this Policy either in the form of a paper document or in a separate electronic folder in the employee's e-mail system. The printed or stored e-mail will be subject to the retention periods listed in the Retention Schedule. E-mail not stored to a separate

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electronic folder and all back-up e-mail will be routinely disposed of six months after the date on the e-mail.

E. Disposal Suspension Notices. When appropriate, the Record Retention Coordinator will issue a Document Disposal Suspension Notice ("Suspension Notice") related to Documents that must be retained because they are reasonably likely to be relevant to a pending, threatened, reasonably foreseeable or contemplated legal action or proceeding or govermnent investigation. The Record Retention Coordinator will communicate the Suspension Notice to all employees. When a Suspension Notice is issued, routine disposal of Documents covered by such Notice must be suspended immediately and such Documents must be promptly forwarded to the Record Retention Coordinator. If a Document covered by a Suspension Notice cannot be forwarded because it is required for VGG's operations, the head of the Department retaining such Document must notify the Record Retention Coordinator of the existence of the Document and the reason it cannot be forwarded.

F. Training. All employees will be periodically trained and kept current in all aspects of their Document management responsibilities. The Record Retention Coordinator will be responsible for informing employees of the policies and procedures contained herein and ensuring that each employee receives the appropriate training to ensure compliance.

G. Questions. Questions regarding this Policy or the Retention Schedule should be referred to the Record Retention Coordinator who will seek advice from the Record Retention Coordinator, as needed. Employees are required to report any instances of non-compliance with this Policy to the Record Retention Coordinator.

VI. PROCEDURE FOR AMENDING THE DOCUMENT RETENTION SCHEDULE

In the event of any change in the Retention Schedule, the Record Retention Coordinator will be responsible for notifying employees of the changes and supplying them with a new Retention Schedule.

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VALLEY GREEN GROW, INC. DOCUMENT RETENTION SCHEDULE

Contracts, A2reements, Etc. Cancelled checks for taxes, purchases of property, special Permanently contracts, etc. should be filed with papers pertaining to the transaction Contracts ' 10 years after expiration Correspondence (general) 3 years Deeds, mortgages and bills of sale Permanently Leases 10 years Loans Permanently

Financial Records Accident reports/claims (property insurance) - settled cases 7 years Accounts receivable & payable ledgers & schedules 7 years Annual Reports Permanently Auditors' reports/work papers Permanently Authorization and appropriations for expenditures 3 years Bank reconciliations/statements 7 years Bank deposit slips 3 years Billing statements 7 years Budgets 3 years Cancelled checks (general) 7 years Cash disbursement journals Permanently Cash receipts journals Permanently Correspondence (routine) 3 years Financial Statements (annual) Permanently General Ledger Permanently Income tax returns, supporting worksheets and cancelled checks Permanently for payments (fed, state and local) Insurance policies ( cmTent & expired) Pennanently Invoices from vendors 7 years Petty cash vouchers 3 years Property records, including cost, depreciation reserves, Permanently depreciation schedules, blueprints and plans Purchase orders 7 years Sales and use tax returns 10 years Sales records 7 years

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VALLEY GREEN GROW, INC. DOCUMENT RETENTION SCHEDULE

Human Resources!Pavroll Records Accident reports/claims (liability insurance) - settled cases 7 years Continuing education documents & faculty evaluations 2 years Correspondence (general) 3 years Employee pavroll records (W-2, W-4, annual earnings, etc.) 7 years Defined contribution and tax deferred annuity plan documents Permanentlv Emolovee retirement records Permanentlv Emoloyee contracts 10 years Occupational injury and illness records (workers comp) 5 years Payroll tax returns 4 years Personnel records (terminated) 7 years Time sheets/cards 7 years

Institutional Records Articles of Incorporation Permanently Shareholder Meeting Minutes Permanently By-Laws Permanently

Lef!a[ Documentation Pertaininf! to Ooeration of VGG Claims and litigation files 10 years Copyright, patent, license and trademark registrations Permanently Correspondence (legal and important matters) Permanently

Client Intef!rated Medical Records 20 Years

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Appendix 2

VALLEY GREEN GROW, INC. COMPREHENSIVE INFORMATION SECURITY POLICY

I. OBJECTIVE

Valley Green Grow Inc. (hereinafter "VGG") has developed and implemented this Written Information Security Policy ("Policy") to comply with the Massachusetts Standards for the Protection of Personal Information of Residents of the Commonwealth, 201 CMR 17.00. This Policy sets out the company's polices and procedures regarding the protection of personal information. Employees are required to read, be familiar with and follow the policies and procedures outlined in this Policy.

The purpose of this Policy is to create and maintain a secure environment for the storage of personal information and to establish safeguards that are appropriate for (a) the size, scope and type of business operated by VGG (b) the amount ofresources available to implement the Plan; (c) the amount of stored data and (d) the need for security and confidentiality of personal information as defined below. A primary goal for this Policy is to make sure that everyone who handles confidential personal information applies reasonable safeguards to protect that information from unauthorized access. This Policy is to be interpreted and implemented in tandem with VGG's Document Retention Policy.

II. PERSONAL INFORMATION

A. Definition

For purposes of this Policy:

"Personal Information" means a person's first and last name or first initial and last name in combination with any one or more of the following:

• Social Security number,

• Driver's license number,

• State-issued identification card number, or

• Financial account number or credit or debit card number, with or without any required security code, access code, personal identification number or password that would permit access to a financial account,

provided, however, that "Personal Information" shall not include information that is lawfully obtained from publicly available information, or from federal, state or local government records lawfully made available to the general public.

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B. Limiting the Collection and Keeping of and Access to Personal Information

It is the policy ofVGG to:

• limit the amount of Personal Information collected - collecting only the Personal Information that is reasonably necessary to accomplish the purpose for which it is collected;

• limit the time such information is retained - keeping it only for as long as is it reasonably needed to accomplish the purpose for which it was collected, unless VGG is legally required to keep it for a longer period; and

• limit access to the information - allowing access only by those persons who are reasonably required to know the information in order for VGG to accomplish the purpose for which the information was collected or to comply with VGG legal requirements.

C. Handling, Storage and Disposal of Personal Information

To reduce the risk of disclosure of Personal Information:

• Visitors shall not be permitted to visit unescorted any area of V GG where Personal Infotmation is kept.

• Employees are prohibited from leaving open records containing Personal Information unattended on their desks.

• At the end of the work day, and as appropriate during the work day, all records containing Personal Information shall be stored in secure storage areas.

• Upon disposal, paper documents containing Personal Information shall be redacted, or shredded so that personal data cannot practicably be read or reconstructed.

• Personal Information may not be transmitted through a public network unless the network is encrypted (i.e. e-mail containing personal information may only be sent on an encrypted network).

• If Personal Information is stored on a laptop or other portable device, such device must be encrypted. Do not keep personal information on your lap top or other portable device unless know that such device is encrypted.

• Upon disposal, electronic media and other non-paper media containing Personal Information shall be destroyed or erased so that Personal Information cannot practicably be read or reconstructed.

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III. RISK ASSESSMENT AND IMPLEMENTATION OF SAFEGUARDS

A. Program Administrator

The Treasurer ofVGG will be responsible for overseeing, implementing, and administering this Policy ("Program Administrator"). The Program Administrator will train staff, as necessary, to effectively implement the Policy, and may designate any one or more employees to perform or assist in the performance of the responsibilities described in this Policy. As used throughout the rest of this Policy, the term "Program Administrator" means "the Program Administrator and his or her designee(s)."

B. Assessment of Personal Information

The Program Administrator will periodically undertake to identify and assess the reasonably foreseeable internal and external risks to the security, confidentiality, and/or integrity of any electronic, paper or other records that contain personal information. The Program Administrator will do this at least annually or whenever there is a material change in business practices that may reasonably implicate the security or integrity ofrecords containing personal information.

This assessment will include but not necessarily be limited to:

• identifying the paper, electronic and other records, computing systems, and storage media, including laptops and portable devices, that V GG uses to store personal information;

• identifying what Personal Information is collected, kept and used, and for what purposes;

• identifying which employees have access to Personal Information and for what purposes; and

• assessing the internal and external risks to the security of that information.·

Based upon this assessment, the Program Administrator will evaluate and where necessary improve the effectiveness ofVGG safeguards for limiting the internal and external risks to the security of that information, including but not limited to:

• developing and implementing security policies and procedures;

e periodic training of relevant employees (including temporary employees and contractors) with respect VGG information security policies and procedures;

• ensuring employee awareness of and compliance with this Program and Policy and any other policies and procedures concerning the protection of Personal Information, including but not limited to periodic distribution of this Program and Policy and other relevant policies and procedures;

• implementing means for detecting and preventing security system failures; and

• encouraging timely reporting of information security failures or risks.

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The Program Administrator will work with those offices or employees responsible for collecting and keeping Personal Information to develop and implement any specific rules or procedures necessary to implement this policy.

IV. TERMINATED EMPLOYEES

Immediately upon the termination of a person's employment with VGG, the Company will:

• obtain from the person all Personal Information in their possession, including all such information contained in any computer electronic files or devices, and

• terminate the person's physical and electronic access to any records containing personal information, including but not limited to deactivating any of the person's computer passwords and user names.

V. THIRD-PARTY SERVICE PROVIDERS

VGG will take reasonable steps to verify that all third-party service providers with access to Personal Information have the capacity to and will protect such information, including but not limited to having reasonable policies and procedures in place that are designed to detect, prevent, and mitigate Identity Theft. It will:

• select and retain only service providers that are capable of maintaining reasonable and appropriate safeguards for personal information;

• contractually require service providers to maintain such safeguards; and

• prior to permitting any third-party service provider access to personal information, obtain from the service provider a written certification that the service provider has a written, comprehensive information security program that is in compliance with the provisions of all applicable federal and state laws as they may be amended from time to time.

VI. COMPUTER SYSTEM SECURITY REQUIREMENTS

The Program Administrator will establish and maintain a security system covering VGG computers, including any wireless system, which at a minimum will have the following elements:

• Secure user authentication protocols including:

o control of user IDs and other identifiers;

o a reasonably secure method of assigning and selecting passwords, or use of unique identifier technologies, such as biometrics or token devices;

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o control of data security passwords to ensure that such passwords are kept in a location and/or format that does not compromise the security of the data they protect;

o restricting access to active users and active user accounts only; and

o blocking access to user identification after multiple unsuccessful attempts to gain access or the limitation placed on access for the particular system

• Secure access control measures that:

o restrict access to records and files containing Personal Information to those who need such information to perform their job duties; and

o assign unique identifications plus passwords, which are not vendor supplied default passwords, to each person with computer access, that are reasonably designed to maintain the integrity of the security of the access controls

e Encryption, to the extent technically feasible, of:

o all transmitted records and files containing Personal Information that will travel across public networks,

o all Personal Information that will be transmitted wirelessly, and

o all Personal Information stored on laptops or other portable devices.

• Reasonable monitoring of systems for unauthorized use of or access to Personal Information.

• For files containing Personal Information on a system that is connected to the Internet, reasonably up-to-date firewall protection and operating system security patches, which are reasonably designed to maintain the integrity of the personal information.

• Reasonably up-to-date versions of system security agent software, which must include malware protection and reasonably up-to-date patches and virus definitions, or a version of such software which can be supported with up-to-date patches and virus definitions and which is set to receive the most current security updates on a regular basis.

• Education and training of employees where appropriate on the proper use of the computer security system and the importance of Personal Information security.

VII. MONITORING, UPGRADING AND REPORTING

The Program Administrator will conduct regular monitoring to ensure that the VGG Policy is operating in a manner reasonably sufficient to prevent unauthorized access to or unauthorized use of Personal Information and will upgrade information safeguards as necessary to limit risks. The Program Administrator will also update this Policy periodically to reflect any changes with respect to the risks of Identity Theft.

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VIII. REPORTING AND RESPONDING TO SECURITY BREACHES

All employees are required to report to the Program Administrator any material risk to or breach of the security of Personal Information maintained by VGG. The Program Administrator will:

• undertake any action necessary to respond to the risk or breach;

• conduct a post-incident review of the events and all actions taken, if any, to make changes in business practices relating to protection of personal information; and

• document any such post-incident review and all responsive actions taken in counection with any incident involving a breach of security.

XI. VIOLATIONS AND DISCIPLINE

Any employee who violates this Policy or any security policies or procedures adopted in accordance with this Policy will be subject to disciplinary action, which may include termination of employment.

XII. QUESTIONS '

Any questions about this Policy or the subjects addressed in this Policy should be directed to the Program Administrator.

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Application _2_ of_3 __ Valley Green Grow, Inc.

Applicant Non-Profit Corporation----------------

SECTION C. NON-PROFIT COMPLIANCE

Answer each of the questions below to explain how the Corporation will remain in compliance with the non­profit requirements of Ch. 369 of the Acts of 2012, the regulations at I 05 CMR 725.000, and "Guidance for Registered Marijuana Dispensaries Regarding Non-Profit Compliance." Please refer to the "Guidance for Registered Marijuana Dispensaries Regarding Non-Profit Compliance" document in completing this form.

11. Please identify any management company that the applicant intends to utilize and summarize the terms of any agreement or contract, executed or proposed, with the management company.

Valley Green Grow, Inc. (the "Corporation") intends to enter into a management services contract with Emerald Ventures, LLC, a Massachusetts limited liability company (the "Management Company") under common control with the Corporation. The management services contract will address the provision of administrative services and oversight of security and cultivation functions for the Corporation. Fees will be commensurate with others providing similar services in the marijuana dispensaty indusl!y and will be in compliance with 105 CMR 725. l OO(A)(l). The Corporation will be free to terminate the services of the Management Company at its discretion.

In addition to the Management Company, the Corporation intends to enter into an agreement with an affiliated property holding and management company, 1600 Osgood Street, LLC, a Massachusetts limited liability company (the "Propetty Company") from which the Corporation will lease its cultivation facilities. The lease shall be in compliance with 105 CMR 725.IOO(A)(l) and provide for payment of monthly rent.

The applicant understands that it is responsible to provide copies of all of the agreements referenced above to the Department of Public Health, along with an independent legal opinion regarding compliance with 105 CMR 725.lOO(A)(l) and Department of Public Health's Guidance for Registered Marijuana Dispensaries Regarding Non-Profit Compliance

/ I

Information on this page has been reviewed by the applicaf;~d'Wh1re provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: fllbL

;/ Management and Operations Profile -Page 5 :1

l

Application 2 of_3_ Applicant Non-Profit Corporation Valley Green Grow, Inc.

12. Please identify any agreements or contracts, executed or proposed, in which the applicant will engage in a Related Party Transaction and summarize the terms of each such agreement.

The Management Company is owned, in part, by Jeffrey Goldstein, the CEO, President, Treasurer, Secretary, and Director of the Corporation. The management team will overlap with that of the Corporation. The contract with the Management Company will contain terms that are fair to the Corporation, commensurate with terms that would be included in an arms-length transaction, and will comply with 105 CMR 725.lOO(A)(l). Any increase in fees owed to the Management Company will be reviewed by independent members of the Corporation's Board.

The Property Company is owned, in part, by Jeffrey Goldstein and will engage a management team that overlaps the management of the Corporation. The rent paid to the Property Company will be reviewed by the Board to ensure fairness and that such rent corresponds to fair market value for rental property similarly situated, taking into account appropriate premiums for the rental of facilities for the cultivation and sale of medical marijuana, and for providing property management.

Initial funding for the Corporation will be loaned to the Corporation by Jeffrey Goldstein, and will be supported by promissory notes issued by the Corporation. Such notes shall have commercially reasonable terms, including interest rates that confmm with Massachusetts usury laws, and will be in compliance with 105 CMR 725.lOO(A)(l).

The applicant understands that it is responsible to provide copies of all of the documents referenced above to the Depatiment of Public Health, along with an independent legal opinion regarding compliance with 105 CMR 725. l OO(A)(l) and Depatiment of Public Health's Guidance for Registered Marijuana Dispensaries Regarding Non-Profit Compliance

. 4/ Information on this page has been reviewed by the applica~.,{~Ai'~here provided by the applicant, is accurate and con1plete, as indicated by the initials of the authorized signatory here: I (

v; Manage1nent and Operations Profile - Page 6

/ .. /

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

13. Please identify whether any members of the Board of Directors are also serving as employees of the proposed RMD and, if so, their title and role with the proposed RMD.

The following member of the Board of Directors of the Corporation will serve as an officer/employee with the corresponding titles:

Jeffrey Goldstein - President, Chief Executive Officer, Treasurer, and Secretary

Each employee of Valley Green Grow, Inc., including those employee(s) who serve on the Corporation's Board of Directors, will be compensated at commercially reasonable rates for the medical marijuana industry given such employee's expertise and experience in the field. All executive employee salaries will be approved by independent members of the Board of Directors of the Corporation (not including such employee) and will be reviewed periodically.

!l

Information on this page has been reviewed by the applicanJn~whet'e provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: ff"/

, i Manage1nent and Operations Profile - Page 7

/

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

14. Please identify whether any members of the Board of Directors are serving as officials, executives, corporate members or board members for any management company, investor or other third patty proposed to contract or otherwise conduct business with the proposed RMD.

Jeffrey Goldstein, a member of the Corporation's Board of Directors, is the manager and one of several members of the Management Company, which is discussed in Valley Green Grow, Inc.'s response to Question 11.

Jeffrey Goldstein is also the manager and one of several members of the Property Company referenced in Valley Green Grow, lnc.'s response to Question 11.

As discussed in Valley Green Grow, Inc.'s response to Question 12, Jeffrey Goldstein will provide funding for the establishment of the Corporation's operations in Massachusetts.

;J

!/f I ; ; /

Information on this page has been reviewed by the applican;t.,'.-fand wh~re provided by the applicant, is accurate and con1plete, as indicated by the initials of the authorized signatory here: J,µ

/ L/' Manage1nent and Operations Profile - Page 8 ! I 1

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

15. Please identify any contract or agreement, executed or proposed, under which a percentage or po1tion of the applicant's revenue will be distributed to a third patty and summarize the terms of any such agreement or contract.

Va11ey Green Grow, Inc. anticipates entering into a Host Community Agreement with the Town of N01th Andover, the terms of which may include a percentage or po1tion of the applicant's revenue. Valley Green Grow, Inc. sha11 timely supply any such agreement to the Depattment of Health promptly upon execution thereof.

AB other fees to be paid to third patties will be based upon a fixed-fee or cost-plus basis in accordance with M.G.L.c. 180 and 105 CMR 725.lOO(A).

The applicant agrees and attests that it will operate in compliance with all applicable state laws and regulations, including, but uot limited to, laws regarding child support and taxation, as well as the "Guidance for R.~yrtered Marijuana Dispensaries Regar/ling Non-Profit Compliance."

;J~ I / ?Cl;~ ( .... / (l /7, j./·1 !14/'--~-"- /;JI; . ~~v~!~~/-·~·~~~~~~~~

Sig fe cif'Authorized Signatory Date Signed

/ /Jeffrey Goldstein CEO, Pres., Treas., Sec., Director

Print Name of Authorized Signatory Title of Authorized Signatory j

Information on this page has been reviewed by the applican filtnd )'I here provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: \-/

Manage1nent and Operations Profile - Page 9

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

SECTION D: EXPERIENCE

16. Attach an Employment and Education form (use template provided) for each of the following individuals: The Corporation's Chief Executive Officer, Chief Operations Officer, Chief Financial Officer, individual/entity responsible for marijuana for medical use cultivation operations, and individual/entity responsible for the RMD security plan and security operations.

17. Describe the experience, and length of experience, of the Corporation's Chief Executive Officer, Chief Operations Officer, and Chief Financial Officer with running a non-profit organization or business.

Dr. Jeffery Goldstein has over twenty (20) years experience in working for a non-profit. Prior to his work at the Cannabis Research Center at Sheba Medical Center, Dr. Goldstein was the Medical Director of Radiation Oncology, Lowell General Hospital, a non-profit organization based in Lowell, Mass. His was employed with Lowell General Hospital for twenty-one (21) years, from 1991-2012. In addition, Dr. Goldstein was an Assistant Clinical Professor of Radiation Oncology, New England Medical Center, Tufts University School of Medicine for twenty (20) years, from 1993-2013.

Mark Frechette (Chief Financial Officer) has approximately twelve (12) years of non-profit experience as a Finance Committee and Board of Directors Consultant to the YMCA of Nashua, New Hampshire. During his time as a Consultant, Mr. Frechette reviewed the non-profit's monthly operating results, helped construct the capital and operating budget, constructed the investment policy and created a product profitability process. Mr. Frechette was actively engaged in all financial facets of the non-profit during his time with the organization.

Tom Regan (Chief Operation Officer) has over fifteen (15) years business experience, working as a Director of Supply Chain Operations for Cisco Systems and, most recently, as the President of Winkanda, LLC ( dba Mindful), a cannabis operation in Colorado. Mr. Regan is the executive responsible for Mindful's day-to-day operation of cannabis grow/cultivation, retail, extraction, wholesale sales, and legal compliance, in addition to setting strategy for the company's business development.

Infonnation on this page has been reviewed by the applicaV--qt, !ri~d }'\ihere provided by the applicant, is accurate and con1plete, as indicated by the initials of the authorized signatory here: _// I./

/ Management and Operations Profile - Page I 0 ti

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

18. Describe the experience, and length of experience, of the Corporation's Chief Executive Officer, Chief Operations Officer, and Chief Financial Officer with providing health care services.

Dr. Jeffery Goldstein (Chief Executive Officer) came to the Merrimack Valley after completing his fellowship training at MD Anderson Cancer Center. Dr. Goldstein was the Medical Director of Radiation Oncology, Lowell General Hospital, Lowell, Mass from 1991-2012 and Assistant Clinical Professor of Radiation Oncology, New England Medical Center, Tufts University School of Medicine 1993-2013. Dr. Goldstein assumed the position of residency director at Sheba Medical Center in 2013 where he has been providing clinical care, teaching residents and conducting retrospective and prospective clinical research. Dr. Goldstein's primary research interest was development of methods to reduce tumor motion when patients with breast, lung and upper GI tumors receive radiation treatments. Dr. Goldstein's group has presented their findings at numerous scientific meetings and published their initial work in leading radiation oncology publications. Under his leadership, several patents have been submitted by Sheba Medical Center to use their device in patients receiving radiations treatment. Dr. Goldstein has accepted the position of Vice­Chairman of the Cannabis Research Center, Sheba Medical Center, Israel and is working closely to establish collaborations for medical research between Israel and Massachusetts.

Mark Frechette (Chief Financial Officer) has been the Chief Financial Officer of Winkanda, LLC (dba Mindful) since 2014. Mindful is one of the largest cannabis companies in the United States, with six (6) dispensaries, which includes a significant medicinal marijuana operating, servicing health care needs for patients throughout Colorado.

Tom Regan (Chief Operating Officer) has been the President ofWinkanda, LLC (dba Mindful) since 2014. Mindful is one of the largest cannabis companies in the United States, with six (6) dispensaries, which includes a significant medicinal marijuana operating, servicing health care needs for patients throughout Colorado.

Information on this page has been reviewed by the applic~l~~,~/where provided by the applicant, is accurate and con1plete, as indicated by the initials of the authorized signatory here:,,:%"' .. ,~/_'./_' _

// Management and Operations Profile - Page 11 ;)' f

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

19. Describe the experience, and length of experience, of the Corporation's Chief Executive Officer, Chief Operations Officer, and Chief Financial Officer with providing services for marijuana for medical purposes.

Dr. Jeffery Goldstein (Chief Executive Officer) is the Vice-Chairman of the Cannabis Research Center at Sheba Medical Center in Israel and is working closely to establish collaborations for medical research between Israel and Massachusetts.

Mark Frechette (Chief Financial Officer) has been the Chief Financial Officer ofWinkanda, LLC (dba Mindful) since 2014. Mindful is one of the largest cannabis companies in the United States, with six (6) dispensaries, which includes a significant medicinal marijuana operation. Mindful has one of the largest marijuana extraction facilities in the United States. Mr. Frechette helped guide mindful from $6M to $18M in gross revenue in three (3) years and helped establish one of the largest concentrates and infused product operations in Colorado.

Tom Regan (Chief Operation Officer) has been the President of Winkanda, LLC ( dba Mindful) since 2014. Mindful is one of the largest cannabis companies in the United States, with six (6) dispensaries, which includes a significant medicinal marijuana operation. Mindful has one of the largest marijuana extraction facilities in the United States. Mr. Regan is the executive responsible for Mindful's day-to-day operation of cannabis grow/cultivation, retail, extraction, wholesale sales, and legal compliance, in addition to setting strategy for the company's business development. Mr. Regan is tasked with P&L responsibility for two (2) major brands (Mindful and TR Extracts). Mr. Regan has launched several new products and new product development at Mindful, and has been in charge of operations for medicinal cannabis use.

// I! I

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Infonnation on this page has been reviewed by the applicaU~<'.aod where provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: -1k;/.1/

1 .. ' Manage111ent and Operations Profile - Page l 2 [

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

20. Describe the experience, and length of experience, of the Corporation's individual/entity responsible for marijuana for medical use cultivation operations and individual/entity responsible for the RMD security plan and security operations with providing services for marijuana for medical purposes.

Harry von Duijne (Chief Cultivation Officer) has spent his life working in greenhouse horticulture, first in a family greenhouse business growing a variety of agricultural products, and later as an Operational Manager and Chief Cultivation Officer at various large-scale greenhouse horticulture operations in the Switzerland and the Netherlands. Most recently, Mr. von Duijne was the Chief Grower at Bedrocan Medicinal Cannabis Center, which produces medicinal-grade cannabis under contract for the Dutch Ministry of Health. Under the Ministry's medicinal cannabis program, standardized herbal cannabis is available in Dutch pharmacies on prescription. The Ministry also exports cannabis for medicinal use to Australia, Denmark, Germany, Finland, Israel, Italy, Macedonia, Austria, Poland and the Czech Republic, and to approved researchers around the world. Mr. von Duijne's experience and Bedrocan include:

- Creation and implementation ofGMP, GAP, LEAN, 5-S, KP!s, Quality Management System procedures and Standard Operating Procedures. - Improving the facility, systems, design, logistics and waste management. - Interfacing, as part of ongoing crop management/project oversight, to insure increased crop growth, streamline systems to improve productivity, yields and quality. - Assisting to lower overall cost of production, while increasing yields. - Trouble shooting and consultations in (standard) growth methods, cultivation planning, Integrated (biological) Pest Management (!PM). - Experimentation and implementation of large scale production methods in cannabis. - Responsible for training and education (new-)growers. - Overseeing a team of licensed employees charged with producing the highest grade of independent laboratory tested medical cannabis. - Responsible for experimental plants and backup plants. - Creating and implementing eight Individualized Work Plans for fieldwork; data collection; documentation; data interpretation and systems analysis.

John Garvin (Chief Security Officer) has over thirty (30) years experience as Detective Lieutenant and Commanding Officer with the Massachusetts State Police, along with other experience which is transferable to the medical cannabis industry. Mr. Garvin has a Masters Degree in Criminal Law from Western New England University. Since 2008, Mr. Garvin has operated Jack Garvin Investigations, a private investigations firm licensed with the Commonwealth of Massachusetts. Mr. Garvin's transferable skill set includes, but is not limited to: identifying risk; maintaining logs (written and/or computerized) of activities occurring during the shift (e.g., accidents, significant incidents) to maintain a record; coordinating use communications equipment (e.g., radio, computer, telephone) to exchange information relative to official duties; transporting evidence to various locations (e.g., lab, co mt), maintaining an unbroken chain of custody; protect a crime scene from contamination by controlling access to the scene and erecting physical barriers to preserve the evidence of a crime; and identifying and collect evidence to preserve that evidence for use in an investigation.

/l /! ~nf~rmation on t?i~ page has been re:iewe? by the applicapf~/?h~/\\fhere provided by the applicant, is accurate and con1plete, as 111d1cated by the 1111ttals of the authorized signatory here:. ,,y.1 c./

/ / Manage1nent and Operations Profile~ Page 13 'I I v

Valley Green Grow, Inc.

Applicant Non-Profit Corporation-------------

SECTION D. EMPLOYMENT AND EDUCATION FORM

This Employment and Education form must be completed and signed by each of the following individuals: The Corporation's Chief Executive Officer, Chief Operations Officer, Chief Financial Officer, individual/entity responsible for marijuana for medical use cultivation operations, and individual/entity responsible for the RMD security plan and security operations. Submit one Employment and Education form for each of the above individuals when submitting a Management and Operations Profile to the Department of Public Health.

Name

I Jeffrey Goldstein

Residential Address

Title (at applicant non-profit corporation)

CEO, President, Treasurer, Secretary, & Director

Name of Applicant Non-Profit Corporation

I Valley Green Grow, Inc.

Highest Education Attained - Institution, Degree, and Year

M.D., University of Miami School of Medicine (1984)

Management and Operations Profile - Employment and Education Form - Page l

Valley Green Grow, Inc.

Applicant Non-Profit Corporation ____________ _

Past 10 Years of Employment by Employer, Title and Time Period. List chronologically, beginning with most recent employment. Add more forms if space is needed for additional employment history entries.

Emnlover Title Time Period Sheba Medical Center Vice-Chairman, Cannabis Research Center 2017 - Present Tel Hashoner, Israel (virtual)

Sheba Medical Center Attending Radiation Oncologist 2013-2017 Tel Hashoner, Israel Director, Residency Training

Lowell General Hospital Director, Department of Radiation Medicine 1991 -2012 Lowell, MA

Holy Family Hospital Attending Radiation Oncologist 1991 - 2006 Methuen, MA

Signed under the paif/and penalties ofpe1jmy, I agree and attest that all information inclu'.\"d in this form is complete

and accur/;f-~ i! IJ} g/" 4 01'7 Si? rf t 'e di vi dual Dak$igned

Management and Operations Profile- Employment and Education Form - Page 2

Applicant Non-Profit Corporation Valley Green Grow, Inc.

SECTION D. EMPLOYMENT AND EDUCATION FORM

This Employment and Education form must be completed and signed by each of the following individuals: The Corporation's Chief Executive Officer, Chief Operations Officer, Chief Financial Officer, individual/entity responsible for marijuana for medical use cultivation operations, and individual/entity responsible for the RMD security plan and security operations. Submit one Employment and Education form for each of the above individuals when submitting a Management and Operations Profile to the Department of Public Health.

Name

Mark Frechette

Residential Address

Title (at applicant non-profit corporation)

CFO

Name of Applicant Non-Profit Corporation

I Valley Green Grow, Inc.

Highest Education Attained - Institution, Degree, and Year

University of California at Berkeley, MBA, 1983

Management and Operations Profile- Employment and Education Form M Page 1

Applicant Non-Profit Corporation Valley Green Grow, Inc.

Past 10 Years of Employment by Employer, Title and Time Period. List chronologically, beginning with most recent employment. Add more forms if space is needed for additional employment history entries.

Emnlover Title Time Period

Winkanda CFO 2014-2017

Arte! CFO 2013-2014

Brookstone Finance Manager 2011-2012

Harvard Pilgrin1 Director 2011

Sleepnet CFO 2010

Source Electronics CFO 1996-2009

Signed under the pains and penalties of perjury, I agree and attest that all information included in this form is complete and accurate.

ignature of the Individual Date Signed

Management and Operations Profile- Employment and Education Fotm ~ Page 2

Past 10 Years of Employment by Employer, Title and Time Period. List chronologically, beginning with most recent employment. Acid more forms if space is needed for additional employment history entries.

~- -Employer Title Time Period -----

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5/eepfl)ef C-F/J ;J-610

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Signed under the pains and penalties ofpe1jury, I agree and attest that all information included in this form is complete

~-Signature of the Individual

Managc1ncnt and Operations Profile - E1nploy111cnt and Education Fonn - Page 2

Applicant Non-Profit Corporation Valley Green Grow, Inc.

SECTION D. EMPLOYMENT AND EDUCATION FORM

This Employment and Education form must be completed and signed by each of the following individuals: The Corporation's Chief Executive Officer, Chief Operations Officer, Chief Financial Officer, individual/entity responsible for marijuana for medical use cultivation operations, and individual/entity responsible for the RMD security plan and security operations. Submit one Employment and Education form for each of the above individuals when submitting a Management and Operations Profile to the Department of Public Health.

Name

I Thomas G. Regan

Residential Address

Title (at applicant non-profit corporation)

I Chief Operating Officer

Name of Applicant Non-Profit Corporation

I Valley Green Grow, Inc.

Highest Education Attained - Institution, Degree, and Year

Boston College, Masters Business Administration 1996

Management and Operations Profile-Employment and Education Form~ Page 1

Applicant Non-Profit Corporation Valley Green Grow, Inc.

Past 10 Years of Employment by Employer, Title and Time Period. List chronologically, beginning with most recent employment. Add more forms if space is needed for additional employment history entries.

Emnlover Title Time Period

Winkanda (Mindful) President September 2014-Present

T3 Interactive CTO, Founder March 2012-September 2014

Cisco Systems Director January 2000-November 2013

Signed under the pains and penalties of perjury, I agree and attest that all information included in this form is complete and accurate.

ff'• 'G•V./fr-'f2.6 f'4G>f,_ A-Tr4GU&.,:;, ")

Signature of the Individual Date Signed

Management and Operations Profile- Employment and Education Form~ Page 2

Applicant Non-Profit Cotporation

Past 10 Years of Employment by Employer, Title and Time Period. List chronologically, beginning with most recent employment. Add more forms if space is needed for additional employment history entries,

Emnlover Title Time Period

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Ts J:NTf(LACt-1 V (i er o .> fuv....v o <VfL J/~o I;).. - Cf/7-tJI'-/

c 1>co sy~5 DJ(l.UTO(L t/2-ooo - 11/2()13

Signed under the pain~d penalties of perjury, 1 agree and attest that all information included in this fom1 is complete an c rate. / /

6- ii-)1-Date Signed

Manage1nent and Operations Profile - Employ1uenl and Education Fonn - Page 2

Applicant Non-Profit Corporation Valley Green Grow, Inc.

SECTION D. EMPLOYMENT AND EDUCATION FORM

This Employment and Education form must be completed and signed by each of the following individuals: The Corporation's Chief Executive Officer, Chief Operations Officer, Chief Financial Officer, individual/entity responsible for marijuana for medical use cultivation operations, and individual/entity responsible for the RMD security plan and security operations. Submit one Employment and Education form for each of the above individuals when submitting a Management and Operations Profile to the Department of Public Health.

Name

j Casper, Hendrik van Duijne

Residential Address

Title (at applicant non-profit corporation)

I Chief Cultivation Officer

Name of Applicant Non-Profit Corporation

I Valley Green Grow, Inc.

Highest Education Attained - Institution, Degree, and Year

RMLTS - Ryks Middelbare Land en Tuinbouw School A Degree(= highest) 1989-1994

Management and Operations Profile- Employment and Education Form - Page I

Applicant Non-Profit Corporation Valley Green Grow, Inc.

Past 10 Years of Employment by Employer, Title and Time Period. List chronologically, beginning with most recent employment. Add more forms if space is needed for additional employment history entries.

Emnlover Title Time Period

BedrocanNL Chief Grower & Team leader cultivation June 2014-February 2017 Dutch licensed Medical Cannibis department Producer, Veendam, Netherlands

Lamprecht pflanzen AG Chief Grower & Chief Cultivation Officer March 2013-August 2013 Horben-Illnau, Switzerland

Smit nursery BY Chief Grower & Facility Manager January 2012-March 2013 Sappermeer, Netherlands

Duijn-pol nursery CEO August 1998-August 2011 Klazienaveen, Netherlands

Signed under the pains and penalties of perjury, I agree and attest that all information included in this form is complete and accurate. ·

[s;.6N,'1f "/l 6. f' A,;; 6. /,1 ff A Uf t'-1:> ']

Signature of the Individual Date Signed

Management and Operations Profile - Employment and Education Form - Page 2

Applicant Non-Profile Corporation ValleyGtwiGtowlno

Past IO Years of Employment by Employer, TJi!e and ThrePeriod. List chronologically,~ with most recent employment. Add more fCJmsifspace irne<rled for ailitkmlemploymenthistncy entries.

Employer Title Time Period

Bedrocan NL Chief Grower June 2014 - February 2017 &

Dutch licensed Medical Cannabis Producer. Veendam, Netherlands

Team leader cultivation department

Lamprecht pflanzen AG Chief Grower &

March 2013 - August 2013

Harben- Illnau, Switzerland. Chief Cultivation Officer

Smit nursery BY Chief Grower January 2012 - March 2013 &

Sappermeer, Netherlands. Facility manager

Duijn-pol nursery CEO

Klazienaveen, Netherlands August 1998 - August 2011

Signed under the pains and penalties of perjury, I agree and attest that all information incltdrl in 1his form is complete and

accurate.

Signature ofthe Individual Date Signe

Jyw'LC

J,/AL; '') '2"''1'

- l.l - L..ol(

Management and qx,raioosl'iolile- Employment and Eill::3icn Form - Page 2

Applicant Non-Profit Corporation Valley Green Grow, Inc.

SECTION D. EMPLOYMENT AND EDUCATION FORM

This Employment and Education form must be completed and signed by each of the following individuals: The Corporation's Chief Executive Officer, Chief Operations Officer, Chief Financial Officer, individual/entity responsible for marijuana for medical use cultivation operations, and individual/entity responsible for the RMD security plan and security operations. Submit one Employment and Education form for each of the above individuals when submitting a Management and Operations Profile to the Department of Public Health.

Name

John E, Garvin

Residential Address

Title (at applicant non-profit corporation)

I Chief Security Officer

Name of Applicant Non-Profit Corporation

I Valley Green Grow, Inc.

Highest Education Attained - Institution, Degree, and Year

Western New England University Masters (criminal law) 1998

Management and Operations Profile- Employment and Education Form - Page I

Applicant Non-Profit Corporation Valley Green Grow, Inc.

Past 10 Years of Employment by Employer, Title and Time Period. List chronologically, beginning with most recent employment. Add more forms if space is needed for additional employment history entries.

Emnlover Title Time Pel'iod

Self employed Owner (licensed by Commonwealth of January 2008 - present Jack Garvin Investigations Massachusetts)

Massachusetts State Police Detective Lieutenant June 1974-December 2007 Commanding Officer Certification Unit among others

Signed under the pains and penalties of perjury, I agree and attest that all information included in this form is complete and accurate.

Signature of the Individual Date Signed

Management and Operations Profile - Employment and Education Form ~Page 2

Applicant Non-Profit Corporation Utt•g_f:i:.'-"-- C',c~ __£;_,,,~­Past 10 Years of Employment by Employer, Title and Time Period. List chronologically, beginning with most 1·ccent employment. Adel more forms If space is needed for additional employment history entries.

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r-------·-·--------;--------------+--------------·-----

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Signed under the pains and penalties of pe~jury, 1 agree and attest that all information included in this form is complete and acct ·ate.

0 '/ y-1"/ e of the Individual Date Signed

Managetncnt and Operalions Profile - E1nploy1nent and Education Fonn ~ Page 2

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

SECTION E: OPERATIONS

21. Provide a summary of the RMD's operating procedures for the cultivation of marijuana for medical use.

Valley Green Grow Inc. is proposing a single cultivation center to grow multiple medical cannabis strains for licensed patients at its three proposed RMD locations. All operations will take place designated, locked, authorized access areas that are monitored by surveillance camera system in accordance with 105 CRM 725.11 O(D)(I)( d)-(i).

All phases of cultivation take place in separated grow roo1ns to 1nini1nize cross conta1nination of plant pathogens. These protective rooms are high locked, controlled (HVAC syste1ns); authorized accessed, clitnate controlled environ1nental rooms. according to the highest Hygienic require1nents, User require1nents specifications, SOP's and GMP standards, all which is necessary to grow standardized medical cannabis.

Cultivators will 1naintain a clean environ1nent in all grow roon1s and wear re1novable protective suits and head coverings to limit exposure to potential contatninants. The incoming ventilation air from outside will be filtered and highly controlled with cooling and heating systems. Rooms will be over-pressured to keep contan1ination outside. All air exhausted fro1n the building will be carbon filtered and/or treated with ozone to eliminate any "tell-tale" odors from escaping the building

Valley Green Grow, Inc. will not utilize pesticides and will control pests with natural ene1nies. Pests, diseases and infections will be prevented by preventive ineasures. Best practices, filters, disinfection, cleaning cycles and personal protection will be tnaintained to ensure that 1nolds, fungus, bacterial diseases, rot, pests, non-organic pesticides, inildew, and any other conta1ninant posing potential hann are elituinated.

All plants will be grown hydroponically in rockwool, an inert, PH and EC neutral medium. Reverse osmoses filtration and/or UV-disinfection will be e1nployed to strip the water used of any minerals, salts and potential chemical conta111inants. This allows for baseline of near zero pp1n (parts per 1nillion) allowing precise control of the nutrients that the plants receive throughout all stages of the plants life cycle. Approved nutrients will be used in the appropriate strengths and fotmulas for each phase of life.

Grow roo1ns will utilize High Pressure Sodiu1n and/or LED fixtures to replicate the natural light of the sun. Carbon Dioxide (C02) enrichment will be employed to increase photosynthesis and improve yield.

Strains selection will be based on the input from our R&D, cultivation and 1nanage1nent tea1ns, whose work in other licensed dispensaries throughout the world offers validated experience with plant species that are effective for specific 1nedical conditions, R&D strain collection and genetics backup will take place in separated quarantine grow rootns to avoid conta1nination.

Cultivation will be overseen by Chief Cultivation Officer Hany von Duijne. Mr Hany von Duijne will oversee a team of licensed employees charged with producing the highest grade of independent laboratory tested medical cannabis. Mr von Duijne's large-scale, state licensed 1nedical cannabis dispensa1y cultivation experience in the Netherlands ensures sea1nless integration of operating procedures at the proposed Valley Green Grow Inc. Facility.

Information on this page has been reviewed by the applican/~ ')'Mre provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: __,_. f.lf[ L // .

/ .- Manage1nent and Operations Profile- Page 14

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

22. Describe the types and forms of Marijuana Infused Products ("MIPs") that the RMD intends to produce, if any.

Valley Green Grow, Inc. intents to produce a comprehensive variety ofMIP's offering licensed patients a wide variety of administration and ingestion options. These products will be manufactured in accordance with state regulation and follow "Good Manufacturing Practices for Food"and state requirements for food handlers and sanitary requirements. The proposed MIP product line includes:

• D1y concentrates (compressed cannabis plant resin including hashish) • Freeze Drying Bud (Freeze d1ying uses sublimation to remove the moisture from the bud. It preserves the terpenes, which will preserve flavor and aroma). • Oils (extracted cannabinoids in liquid form. Including hash oil, "ready-dose" infusions, Phoenix tears) • Tinctures and Sprays (flavored sub lingual drops of extracted cannabinoids in liquid form) • Capsules (extracted cannabis infused into natural oil) • Sublingual Dissolving Strips (cannabis infused, dissolved under the tongue) • Topical (applied to skin as analgesic or anti-inflammatory remedy) • Personal Vaporizer Ca1tridges /Cups/Pads (dose-specific, concentrate-base liquid for non­smokable ingestion) • Cosmetics (extracted cannabis infused in creams, and liquid pe1fumes ). • Maintenance- Cleaning products (extracted cannabis compounds as terpenes) • Edible Food Products or Cmmabis as Ingredients (chocolates, cookies, caramels, lozenges, chewables)

/} /

iJ/i / ~nf?rmation on t~1i7 page has been re~iewe? by the applic~~'.t[ji1td where provided by the applicant, is accurate and complete, as 1nd1cated by the 1111t1als of the authonzed signatory here: fif

//"/H,-z.-- Managetnent and Operations Profile - Page 15 jl!

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

23. Provide a summary of the RMD's methods of producing MIPs, if the RMD intends to produce MIPs.

Production of edible MIP's will take place within the Valley Green Grow, Inc facility at 1600 Osgood Street, North Andover, Massachusetts. All production will meet the standards set fotth in 105 CMR 725.105. The MIP product line will include a collection of precision-dosed, medically familiar methods of administration. All products will be produced with ingredients of the highest purity with careful attention to milligram specificity. MIP's produced for edible consumption will be contained in opaque packaging and labeling pursuant to the state regulation. No MIP's will be produced to resemble commercially available food or candy products. Storage of all MIP's will be in secure, climate controlled rooms in the cultivation facility and RMD.

Valley Green Grow, Inc. will follow a four-step process for MIP production: extraction, independent laboratory validation, product creation, and final product validation. The RMD will utilize extraction processes that include water, ethanol, butane, propane or C02. Extractions utilizing solvents will be heat and vacuum purged to ensure the removal of any residual solvent. Independent laboratory testing will be conducted on all extractions so that residual solvent levels are less than 100 ppm.

Once laborat01y testing is validated, the product line will be created using a variety of methods (carrier oil infusion, baking, etc.). Finally, all finished MIP's will undergo a final product validation to ensure quality along with additional laboratory analysis to ensure potency and consistency of each product.

11 //,<X

Information on this page has been reviewed by the applic·a·b.#./ang/where provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: ;. / //

f/1/ l,/ Manage1nent and Operations Profile - Page 16 '

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

29.Provide a summary of the RMD's operating procedures for quality control and testing of product for potential contaminants.

Valley Green Grow, Inc. 1s RMD procedures for quality and testing of product for potential contaminants shall, at all tin1es, co1nply \Vith the provisions of 105 CMR 725.105(C)(2), which shall include, but not be limited to the follo\ving procedures:

All test results must reference the corresponding batch of final product. Pesticide residue testing inust include analysis for the presence of chlorinated hydrocarbons, organophosphates, carban1ates and pyrcthroids, neonicotinoids, acaricides, fungicides, bactericides, at a n1inimum. Testing should also include any 1naterials not listed above but used by producer and 1neet all local and state testing requirements. A sample of usable cannabis will be considered to test positive for presence of pesticides if the level exceeds 0. 1 ppn1 of any tnaterial. All strains 1nust be tested in all production cycles. Sa1npling must be done for all production cycles. Testing should include comprehensive profiles that detail levels of THC, THC-A, THCV, CBD, CBDV, CBD-A, CBN and terpenoid profile as applicable to the product specification.

- Test results tnust be retained for all ra\V cannabis and cannabis-derived products for three years. - Documented results can be frotn supplier analysis or tests perfonned for the operation by a

certified lab.

All products tnus_t have unique coding or nutnber to facilitate traceability in and out of the facility and for the purposes of linking the proper product testing results to the product.

All products with pending tests 1nust be segregated, marked "quarantined" and held in a secure location until test results are received. 011ly an authorized worker can release quarantined product and the release 1nust be docu1nented.

Operation shall designate a qualified staffme1nber to review each test result against the product specification, and if the product nieets all specifications and other requiren1ents, release the batch of product to the next step in the process.

- The product specification identifies all safety and quality requirements including quality and strain standards that must be met before product is released for sale or consu1nption, - Products that do not meet specifications are labeled and segregated and processed as rejected material. - The operation shall docutnent and retain all test results analysis reports for two years,

Producer must establish a detailed action plan to dispose of all products that do not 1neet established quality, strain or safety standards.

- Rejected 1naterial must be labeled and segregated until dispositioned, - The plan 1nust define processes for disposition of all rejected product and ho\v to account for this product in all harvest-related records. - Rejected product must be disposed so the waste is rendered unusable. A sample of product fron1 each production batch must be collected and stored appropriately per label instructions. An organized storage area and reference syste1n should be in place for all sainples.

Producer must retain all samples in storage for one year past the product expiration date or related quality control

date. Any san1ple involved in a pending claim or legal dispute shall not be destroyed.

All procedures not listed herein will comply with all applicable state and local regulations. This answer can be

supplemented on request with additional information not contained herein due to space constraints.

_// /

// /f / Information on this page has been reviewed by the applicah{,.i~tjd where provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: //// i /

rfj'., / V Management and Operations Profile- Page 22

I

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

30. Provide a summary of the RMD's operating procedures for maintaining confidentiality ofregistered qualifying patients, personal caregivers, and dispensary agents, as required by law.

Valley Green Grow, Inc. will conform with all state and federal Jaws pe1taining to patient confidentiality and patient privacy.

All RMD employees will be trained in the protection and treatment of patient, caregiver and dispensary agent pdvacy per the federal and state (and HIPP A) laws. Patient records will be available upon request.

Records for patients, caregiver, and dispensary agents will be stored in locked, li1nited access areas in the RMD.

Valley Green Grow, Inc. will utilize electronic record keeping and ensure that safeguards are in place, with regular software updates, to ensure cotnpliance with HIP AA guidelines.

All systems accessed by dispensaiy agents will be password protected. A 1·ecord will be kept of all logins and records created or edited during that login tin1e. Any hard copy information not stored in a locked cabinet as detailed above will be shredded and disposed of in a secure recepacle.

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~nf~nnation on t?i~ ~age has been re;iewe? by the applicanl l9d1

where provided by the applicant, is accurate and con1plete, as 1nd1cated by the 1111ttals of the authonzed signatory here: /i,l~

, , · Management and Operations Prnfile - Page 23 /:'

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

31. Provide a summary of the RMD's personnel policies.

Valley Green Grow is com111itted to providing a safe workplace for all e1nployees while 1naintaining compliance with federal, state and local employn1ent regulations and rules.

Valley Green Grow provides the following for all employees:

Equal Employn1ent Opportunity, competitive wages, disability accomn1odations, e111ployee benefits, paid tilne off including holidays, training in workplace ethics. All e111ployees will be afforded the opportunity for advance1nent and on the job/on-line;classroon1 based training.

All employees of Valley Green Grow, Inc. shall receive a detailed Employee Handbook, which shall include, but not be lin1ited to, policies regarding alcohol, s1noke, and drug-free workplace; irn111ediate dis111isal for e1nployees who dive1t n1arijuana or engage in unsafe practices; safety and security policies; con1pliance with FMLA, COBRA, EEO, Non Discrimination, Anti-Harrasment, ERISA, HIPPA; email policy, compliance with applicable Code of Mass. Regulations; business and working hours; wages and benefits; en1ploy1nent categories; perfonnance reviews; disciplary procedures; CORI checks, an1ong others.

All Valley Green Grow, Inc. employees will have extensive training.

Valley Green Grow will comply with applicable state and federal requirements for workplace posting.

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Information on this page has been reviewed by the applica91/~6d~here provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: If( v

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Management and Operations Profile - Page 24

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

33. Provide a summary of the RMD's operating procedures for record keeping.

Valley Green Grow, Inc.'s operating procedures security 1neasures, e1nployee security policies, storage of 1narijuana, record keeping and inventory protocols, plans for staffing and quality control, emergency procedures, drugwfree \Vorkplace policies, patient education, pricing standards, production and distribution policies and procedures as required by 105 CMR 725.105(A).

Valley Green Grow, Inc. shall maintain inventory records as required by 105 CMR 725.105(G), and seed-to-sale tracking records for all marijuana and MIPs as required in 105 CMR 725.105(G)(5).

Valley Green Grow, Inc. shall 1naintain personnel records, job descriptions, a personnel record for each dispensary agent that includes a copy of the dispensary agent application, performance evaluations, documentation of all required training and verification of reference, a staffing plan, policies and procedures, and all CORl reports obtained in accordance with 105 CMR 725.030(C). Waste disposal records as required by I 05 CMR 725.l 05(J) (5).

Valley Green Grow, Inc. shall 1naintain purchases, denials of sale and any delivery options using an encrypted, secure electronic patient database that is strictly controlled and continually backed up. Information held by a RMD about registered qualifying patients, personal caregivers, and dispensary agents is confidential and shall not be disclosed without the written consent of the individual to whon1 the infonnation applies, or as required under law or pursuant to an order fro1n a court of competent jurisdiction.

/J ///

Information on this page has been reviewed by the applica~~ an.~Hvhere provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: // ! .. /

/( c· Management and Operations Profile - Page 26

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

34. Provide a summary of the RMD's plans for providing patient education.

Valley Green Grow, Inc. will ensure the availability of an adequate supply of up-to-date educational materials. These materials will be available in languages accessible to all patients the RMD se!'Ves, as well as for the visually and hearing-impaired. These materials will be made available for inspection by DPH upon request. Further, Valley Green Grow, Inc. will provide patient education through the following means:

• Retail Associate product and patient training • In-store retail education printed material • Vendor infonnation days • Website/on-line education 111aterial • Published material by Valley Green Grow • Educational consun1ption 1naterial: flower, edible, vape, topical educational 1naterial and associate

consulting • Explanation of the co1npounds of Cannabis • Explanation of the effects ofco1npounds of Cannabis • In store strea111ing video • Private patient consultation center at retail locations

11 /h i/il ,

Infonnation on this page has been reviewed by the applica <~laqd''\¥here provided by the applicant, is accurate and con1plete, as indicated by the initials of the authorized signatory here: L./-

Manage1nent and Operations Profile - Page 27

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

36. Provide a summary of the RMD's policies and procedures for the provision of marijuana for medical use to registered qualifying patients with verified financial hardship without charge or at less than the market price.

Valley Green Grow will have policies and procedures for the provision of 1narijuana to registered qualifying patients with verified :financial hardship without charge or at less than the 1narket price, as required by 105 CMR 725.IOO(A)(6). All qualified patients with proven financial hardship will be extended financial support in the fonn ofa discounted price fro1n the market or retail price structure. There will be limits to the quantity of product that can be purchased and it is expected that this will be up to a 25o/o discount on all 1 ounce purchases. Special case patients with severe de1nonstrated financial hardship will be addressed on a case-by-case basis, but will not be denied 111edicine.

;_:r,, ./ Information on this page has been reviewed by the applic(\.'~{bd·W'here provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: /;

fl Management and Operations Profile - Page 29

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

37. Provide a summary of the training(s) that the RMD intends to provide to Dispensary Agents.

Valley Green Grow, Inc. will provide general and occupation~specific training to all its employees. General training will include, but not be excluded to: Company benefits, Equal Opportunity, Time-keeping and pay practices, Cotnpany Standard Operating Process, Workplace Safety, OSHA training, E1nergency training, Employee Conduct. Each employee will be trained in the state regulations/laws regarding n1arijuana as set f01th in 105 CMR 725.105(H). All employees will also go through special Compliance training stressing the security and handling of marijuana. At a 1ninin1u1n staff 'viii receive 8 hours of ongoing training each year, but generally many tnore training periods and continuing education will be provided by the company.

An Employee Handbook will be issued and reviewed with each employee and will cover these subjects and more. Each employee will be required to attend e1nployee handbook review sessions and sign and acknowledgment of understanding of employee handbook.

Occupation-specific training will cover job specific training in areas such as inventory management, con1pliance, retail, patient advocacy, cultivation, serve safe, transport, waste disposal and 1nanage1nent of waste products, cleanliness and Good Manufacturing Practices.

r) ;f Infonnation on this page has been reviewed by the applic~··'~ f d W,hll'I;~ provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: // / /'/

/j, Manage1nent and Operations Profile- Page 30 ' /"

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

38. Will the Corporation provide worker's compensation coverage to the RMD's Dispensary Agents?

Yes Ill No D

39. Will the Corporation obtain professional and commercial insurance coverage?

Yes Ill No D

40. Describe the Corporation's plan to obtain liability insurance or place in escrow the required amount to be expended for coverage of liabilities.

Valley Green Grow, Inc. has discussed with insurers options for obtaining and maintaining general and product liability insurance in compliance with 735.105(Q). Specifically, the company has confirmed the availability of policies including: general liability insurance for no less than $1,000,000 per occurrence and $2,000,000 in aggregate, annually, and product liability insurance coverage for no less than $1,000,000 per occurrence and $2,000,000 in aggregate. annually, with a liability policy deductible of less than $5,000 per occurrence.

/l .. / !nf?rmation on t~1i~ page has been re;iewe~ by the applic~~~~·~~d/~here provided by the applicant, is accurate and con1plete, as 1nd1cated by the 1111t1als of the authorized signatory here: 11.:?/;

/(/fl Manage1nent and Operations Profile - Page 31

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

SECTION F. CAPITAL CONTRIBUTORS

List all persons and entities known to date that are committed to contributing 5% or more of initial capital to operate the proposed RMD. For eritities contributing initial capital to operate the proposed RMD, list the entity's Chief Executive Officer/Executive Director and President/Chair of the Board of Directors.

Attach additional tables if needed.

Individual Name Amount of Initial Capital Percentage of Initial

Committed Canital Committed

Jeffery Goldstein $ 1,300,000.00 100%

$

$

$

$

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lnfonnation on this page has been reviewed by the applican,~1t\fid"\vhere provided by the applicant, is accurate and con1plete, as indicated by the initials of the authorized signatory here: _jj'//

// Manage1nent and Operations Profile-Page 32

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Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

Amouut of Initial Percentage of Entity Name Leadership Names Capital Initial Capital

Committed Committed Entity CEO/ED:

Entity President/Chair: $

Entity CEO/ED:

Entity President/Chair: $

Entity CEO/ED:

Entity President/Chair: $

Entity CEO/ED:

Entity President/Chair: $

Entity CEO/ED:

Entity President/Chair: $

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Infonnation on this page has been reviewed by the applica.n.Nf d-where provided by the applicant, is accurate and complete, as indicated by the initials of the authorized signatory here: / ·

/ Management and Operations Profile - Page 33

Application 2 of 3 Applicant Non-Profit Corporation Valley Green Grow, Inc.

ATTESTATIONS

Signed under the pains and penalties of petjury, I, the authorized signatory of the non-profit applicant corporation, agree and attest that all information included in this application is complete and accurate and that I have an ongoing obligation to submit updated information to the Department if the information presented within this application has changed.

Signatun(ofl,Xuthorized Signatory

Jeffrey Goldstein

Print Name of Authorized Signatory

CEO, President, Treasurer, Secretary, Director

Title of Authorized Signatory

I hereby attest that if the corporation is allowed to proceed to submit a Siting Profile, the corporation is prepared to comply with all Siting frofile requirements.

~ if!l~ --, Sif':;t~~16f Authorized Signatory

I (

Jeffrey Goldstein

Print Name of Authorized Signatory

CEO, President, Treasurer, Secretary, Director

Title of Authorized Signatory

ate' Sigiied

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Infor1nation on this page has been reviewed by the applicanl:./.Ji' ~~ )YI{{i: provided by the applicant, is accurate and co1nplete, as indicated by the initials of the authorized signatory here: !/v

Manage1nent and Operations Profile - Page 34

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