April 18, 2023 Kellie Rivera Columbia Care New Jersey, LLC 1560

CANNABIS REGULATORY COMMISSION

P.O. BOX 216

TRENTON, N.J. 08625-0216

DIANNA HOUENOU, Chair

SAMUEL DELGADO, Vice Chair

KRISTA NASH, Commissioner

MARIA DEL CID-KOSSO, Commissioner

CHARLES BARKER, Commissioner

JEFF BROWN, Executive Director

PHILLIP D. MURPHY

Governor

SHEILA Y. OLIVER

Lt. Governor

April 18, 2023

Kellie Rivera

Columbia Care New Jersey, LLC

1560 North West Boulevard

Vineland, NJ 08360

Re: FINAL AGENCY DECISION

Acceptance of Expanded Alternative Treatment Center’s (“Expanded ATC”)

Renewal Application to Operate in Personal-Use Cannabis Market

Dear Kellie Rivera:

Congratulations! The New Jersey Cannabis Regulatory Commission (“NJ-CRC” or

“Commission”) has approved your request for license renewal(s) to operate as an Expanded

Alternative Treatment Center. The above-listed entity will be permitted to engage in adult,

personal-use cannabis activities in New Jersey under the following licenses and at the following

locations for an additional year:

1. Class 1 Cannabis Cultivator (Tier III), 1560 North West Boulevard, Vineland, New Jersey,

Expiration April 17, 2024;

2. Class 2 Cannabis Manufacturer, 1560 North West Boulevard, Vineland, New Jersey,

Expiration April 17, 2024;

3. Class 5 Cannabis Retailer, 1062 North Delsea Drive, Vineland, New Jersey, Expiration

April 20, 2024;

4. Class 5 Cannabis Retailer, 1692 Clements Bridge Road, Deptford Park, New Jersey,

Expiration April 20, 2024.

This letter serves as written notice that the above-listed ATC has submitted complete, accurate,

and verifiable information, and the NJ-CRC has approved the expanded ATC to operate in the

adult personal-use market for an additional year. Details on the Commission’s review of materials,

terms and conditions of Commission approval, and next steps are provided below. Please read the

following information carefully; failure to satisfy any requirement may result in penalties levied

against the expanded ATC, including fines and license suspension, revocation, or renewal denial.

NJ-CRC Review of Renewal Application Materials

Pursuant to N.J.A.C. 17:30-9.4(m)(3), not fewer than 90 days prior to the date on which the

expanded ATC’s cannabis business license is set to expire after its first year of operations, in order

to renew its cannabis business license pursuant to N.J.A.C. 17:30-7.16, an expanded ATC shall:

(1) Certify to the Commission as to the continued material accuracy of the expanded ATC’s

previously approved ATC license application and its compliance with the provisions of the

Act regarding its operations concerning cannabis or cannabis items; and

(2) Submit a new written approval from the municipality in which the expanded ATC is

located, approving the continued operations as a cannabis business.

Additionally, an expanded ATC must pay the requisite renewal fees for each requested license

under N.J.A.C. 17:30-7.17.

Terms and Conditions of NJ-CRC Approval

The Commission’s approval provided herein is based and conditioned on the information provided

in the entity’s certification materials. It is your responsibility to ensure the entity understands and

complies with all applicable regulations, regardless of whether they are expressly mentioned in

this letter. Furthermore, because the approval is conditioned on evidence that the entity’s adult-

use cannabis activities will not negatively impact patient access to medicinal cannabis, the

Commission’s acceptance of the entity’s certification materials is subject to the terms and

conditions explained below regarding patient access, medicinal cannabis inventory, social equity,

labor, and product testing.

Adherence to the entity’s plans submitted to the Commission and the terms and conditions below

is an ongoing requirement for licensure as an Expanded Alternative Treatment Center. Failure to

adhere to the conditions and commitments in the entity’s certification materials, or failure to satisfy

any required terms and conditions set forth below, may result in adverse action taken against the

expanded ATC, including suspension or revocation of any issued permit or license. The NJ-CRC

is authorized to take these enforcement actions pursuant to N.J.A.C. 17:30-20.5.

Plans for Patient Access

The expanded ATC must satisfy all of the following conditions:

• Have business operating hours include at least 14 patient-only hours spread over at least

three (3) days per week, including at least one (1) weekend day. Patient-only hours should

be held at different times throughout the week to accommodate patients and designated

caregivers with different schedules;

• Provide exclusive parking options for patients and designated caregivers at all times;

• Designate points-of-sale that will be available for use exclusively by patients and

designated caregivers at all times. All points-of-sale shall be available for patient use at

any time. If patients are experiencing a wait time in excess of five (5) minutes, other points-

of-sale must be made available to serve patients to reduce the wait time before serving

personal-use cannabis purchasers;

• Provide express access to the ATC to minimize the wait time for patients and designated

caregivers;

• Provide patients and designated caregivers with the exclusive ability to reserve products

ahead of time so that they can be assured their order will be filled when going to the ATC;

• Provide a patient access telephone line staffed by ATC employees during all business hours

to assist patients and designated caregivers trying to access the ATC;

• Within 30 days of being issued the above-listed licenses, hold at least two (2) virtual town

halls with registered patients and caregivers to provide information on the ATC’s patient

access plan. Each virtual town hall must be conducted in a manner that complies with any

applicable patient privacy laws and regulations; and

• Provide the NJ-CRC with weekly reports on patient access. Weekly reports must include,

at a minimum, the following information:

o Average wait times for patients

o Number of patients served

o Medicinal Cannabis Product Dispensed

o Medicinal Cannabis Product on-hand (packaged)

o Medicinal Cannabis Product on-hand (bulk)

Additionally, the NJ-CRC encourages, but is not requiring, each expanded ATC to provide

exclusive home delivery for patients and online ordering and exclusive express curbside pick-up

for patients.

The expanded ATC must cooperate with the NJ-CRC by providing weekly reports on the entity’s

efforts to maintain patient access to medicinal cannabis.

Plans for Ensuring Adequate Medicinal Cannabis Inventory

The expanded ATC must maintain a “Minimum Adequate Supply” of medicinal cannabis for

patients, plus a “Reasonable Minimum Reserve.”

A Minimum Adequate Supply shall be calculated by determining the average purchases of

packaged products by patients in the preceding three (3) months at the ATC. The “Minimum

Adequate Supply” should be adjusted up to account for new patient enrollment, should the ATC

experience an increase in the number of patients enrolled at the ATC month over month.

Minimum Adequate Supply = [(current patients enrolled at the ATC) ÷ (patients enrolled

at the ATC 3 months prior)] × (Average amount of medical cannabis purchased over the

preceding three (3) months at the ATC)

A Reasonable Minimum Reserve shall be a three-month reserve calculated by determining the

average amount of medical cannabis purchased over the last three (3) months and multiplying it

by three (3). To meet the Reasonable Minimum Reserve, the ATC may include packaged and bulk

product. The ATC may also include flower that is drying or curing, and the raw materials for

manufacturing medicinal cannabis products.

Reasonable Minimum Reserve = [Minimum Adequate Supply] × 3

The expanded ATC must cooperate with the NJ-CRC by providing weekly reports on medicinal

product availability and inventory levels.

Plans for Social Equity

The expanded ATC must satisfy all of the following conditions:

• In accordance with N.J.A.C. 17:30-9.4(e), make a good faith effort to employ individuals

who either:

(1) have past marijuana- or hashish-related convictions, or

(2) at the time of employment, have lived in an Economically Disadvantaged Area for

five (5) of the last ten (10) years and in the preceding tax year made 80% or less of

the median house-hold family income.

Any such efforts shall be conducted in compliance with P.L. 2014, c.32, P.L. 2019, c.199,

and any other applicable employment or labor laws and regulations.

• Submit progress reports that include specifics on the good faith efforts being made to

ensure the expanded ATC’s social equity plans as presented in the entity’s certifications to

the NJ-CRC are being achieved. These progress reports should be prepared in accordance

with guidance from the Commission’s Office of Diversity and Inclusion.

The Commission may request additional information from the expanded ATC to help it determine

if efforts are being made in good faith.

Labor Peace and Collective Bargaining

If a majority of the expanded ATC’s employees express interest in a particular bona fide labor

organization, as defined under N.J.S.A. 24:6I-1 through 56, the expanded ATC shall make a good

faith effort to negotiate and execute a labor peace agreement with that bona fide labor organization.

Labor peace agreements provide the NJ-CRC with the assurance that, should an entity be licensed,

its operations will not be shut down due to labor-dispute or labor-related work stoppages.

After entering into a labor peace agreement, if a majority of the expanded ATC’s employees

support joining a particular bona fide labor organization, then the expanded ATC shall, within 200

days of executing a labor peace agreement, make a good faith effort to enter into a collective

bargaining agreement.

Failure of an expanded ATC to abide by its executed labor peace and collective bargaining

agreements may result in adverse action against the entity, including possible suspension or

revocation of an ATC’s license or permit or denial of any permit or license renewal.

Laboratory Testing

The expanded ATC is required to utilize a Commission-licensed testing laboratory to test cannabis

items pursuant to the Commission’s regulations.

Next Steps

By accepting this provisional award for license renewal, the expanded ATC is agreeing to be

subject to the terms and conditions stated in this letter, as well as any requirements in applicable

regulation. Before the license is renewed, he expanded ATC must submit payment for the

associated renewal licensing fee under N.J.A.C. 17:30-7.17 for each license. Accordingly,

payment in the amount of $50,000 is due and owed before the entity can continue to engage in any

activities associated with the adult-use cannabis market for an additional year. The breakdown of

fees is as follows:

• Class 1 Cannabis Cultivator (Tier II), 1560 North West Boulevard, Vineland, New Jersey,

Expiration April 17, 2024: $10,000

• Class 2 Cannabis Manufacturer, (up to 10,000 sq. Ft.) 1560 North West Boulevard,

Vineland, New Jersey, Expiration April 17, 2024: $20,000

• Class 5 Cannabis Retailer, 1062 North Delsea Drive, Vineland, New Jersey, Expiration

April 20, 2024: $10,000

• Class 5 Cannabis Retailer, 1692 Clements Bridge Road, Deptford Park, New Jersey,

Expiration April 20, 2024: $10,000

The NJ-CRC will email you an invoice that must be paid online using the Commission’s licensing

portal. If payment is not received within thirty (30) days of accepting this award, the NJ-CRC will

email a final notice regarding the unpaid invoice. Failure to pay the required fees within sixty (60)

days of accepting this award will result in the award automatically being rescinded and the entity’s

license renewal being rejected in the online licensing portal.

Congratulations once again on your successful request and thank you for your continued interest

in working with the NJ-CRC to establish a safe and equitable cannabis industry for the state of

New Jersey. Should you have any questions regarding this correspondence, please submit your

inquiry to the NJ-CRC Licensing inbox at [email protected].

Sincerely,

Dianna Houenou

Chairperson

New Jersey Cannabis Regulatory Commission