COMPLIANCE

Execution Compliance

BUNDLES

ILLINOIS

Yes: Cannot use the word “bundles”. Use “Box” or “BOGO”.

MASSACHUSETTS

Mes: Cannot say price

MED Yes: Just no prices

REC Yes: Cannot say “deal”, “discount” or “promotion” Cannot be offered as part of a contest

(Pricing in stores okay per risk analysis with Dan and Jennifer)

MARYLAND

Yes

NEW YORK

Yes: Cannot be tied to specific product. Only dollar amounts/ percentages off a total purchase is allowed.

Ex: Cannot do JH1 flower + Yellow 1:1 Capsules Can do mix and match of one category or mix and match of multiple categories

OHIO

Yes

PENNSYLVANIA

VERIVIP/LIVWELL REWARDS

ILLINOIS

Yes

MASSACHUSETTS

Med Only

MARYLAND

Yes

NEW YORK

Yes

OHIO

No

PENNSYLVANIA

Email Only

COLORADO

Yes

MICHIGAN

Yes

PRICING AND TRIGGER WORDS

ILLINOIS

Can use words like sale, promotion, gift box. Examples: Sale, % or $ off, promotion, discount, offers, specials

MASSACHUSETTS

No pricing in email. Can use “bundles”.

MED Discounts, coupons, promotions can be advertised to medical patients

REC Cannot use any promotional wording on emails, screens, print Can still be on Jane (Pricing in stores okay per risk analysis with Dan and Jennifer)

MARYLAND

Can use words like sale, promotion. Examples: Sale, % or $ off, promotion, discount, offers, specials, bundles

OHIO

Can use % or $ off. Can not use the word coupon or show any coupons. Can not say sale, promotion, specials, bundles. Examples: Reduced pricing % or $ off SKU or category Can use “reduced pricing,” “discount,” or “offers”

NEW YORK

Cannot promote a single sku or group. If promoting specific items needs to state ‘Staff Pick’. Can use sale, promotion, discount. Examples: Right: All Matter Oral Solutions - $XX Wrong: Blue 20:1 Oral Solutions - $XX

Right: Staff Pick 20/ct capsule - $XX Wrong: Blue 20:1 20/ct capsule - $XX

Right: Sale, % or $ off, promotion, discount, offers, specials, bundles

PENNSYLVANIA

Can use $ and % off in emails and texts. Can not use the word coupon or show any coupons. Can not say discount, deal, sale, special, promo. Can say: featured, reduced pricing, updated pricing, bundles, or staff picks

COUPONS

ILLINOIS

Yes

MASSACHUSETTS

MED Yes

REC No

MARYLAND

Yes

NEW YORK

Yes: Cannot be tied to specific product. Only dollar amounts/percentages off a total purchase is allowed.

OHIO

No: Cannot use word coupon or show coupon.

PENNSYLVANIA

No

DISCOUNTS

ILLINOIS

Yes

MASSACHUSETTS

Cannot list price MED - can list % off REC - No except for employees. “reduced prices” can only be communicated

MARYLAND

Yes

NEW YORK

Yes: Cannot be tied to specific product. Only dollar amounts/percentages off a total purchase is allowed.

OHIO

No: cannot sell or distribute clothing, apparel or wearable accessories (including stickers, according to OBOP), unless such sale or distribution is to an employee for purpose of identification while at the licensed facility. All swag must be approved for giveaway.

PENNSYLVANIA

Yes: Needs to be submitted to PA DOH

GIFT (CANNABIS)

ILLINOIS

Yes

MASSACHUSETTS

No

MARYLAND

Yes

NEW YORK

No

OHIO

No

PENNSYLVANIA

No

BUY X GET X FREE

ILLINOIS

No free cannabis BOGO is allowed for non-cannabis items

MASSACHUSETTS

No

MARYLAND

No

NEW YORK

No

OHIO

No

PENNSYLVANIA

No

PRICE SHOWN ON MARKETING MATERIALS

ILLINOIS

Yes

MASSACHUSETTS

No

MARYLAND

Yes

NEW YORK

Yes

OHIO

Yes

PENNSYLVANIA

Yes for emails, not for screens/ physical materials

DRAWING AND TICKETS

ILLINOIS

Cannot be referred to as “raffle” - use “drawing” / Tickets cannot say “raffle” Medical/Adult Use: We can offer a prize in a promotional offer such as “Stop by the dispensary on 4/20 to be entered into a drawing for a custom LivWell bike. No purchase required.”

MASSACHUSETTS

Cannot be referred to as “raffle” - use “drawing” / Tickets cannot say “raffle” MED Yes / REC No: Drawings must be entry for a chance to purchase the prize

MARYLAND

Cannot be referred to as “raffle” - use “drawing” / Tickets cannot say “raffle”

NEW YORK

Cannot be referred to as “raffle” - use “drawing” / Tickets cannot say “raffle” Cannot be tied to a purchase. Tickets must be available to anyone coming into dispensary

OHIO

Cannot be referred to as “raffle” - use “drawing” / Tickets cannot say “raffle” Items must be approved by BOP and cannot be cannabis

PENNSYLVANIA

Cannot be referred to as “raffle” - use “drawing” / Tickets cannot say “raffle” Items must be approved by DOH. Large prizes may not be approved due to concerns of being an inducement to purchase

STATE APPROVALS

ILLINOIS

No

MASSACHUSETTS

No

MARYLAND

No

NEW YORK

No

OHIO

Yes, takes about a month

PENNSYLVANIA

No for digital assets Yes for in-store material, takes about three weeks

ILLINOIS

CAN MATCH EMAIL CONTENT

A REMINDER THAT FOR SCREENS, THE DISCLAIMER IS NOT REQUIRED AND CAN BE REMOVED SHOULD YOU CHOOSE.

SCREENS/SELLSHEETS

For use only by adults 21 years of age or older or persons holding a patient registration card. There may be health risks associated with consumption of cannabis. Cannabis can impair concentration, coordination, and judgment. Do not operate a vehicle or machinery under the influence of cannabis. Use during pregnancy and breast-feeding may pose potential harm. Keep out of the reach of children. The impairment effects of edible cannabis may be delayed by two hours or more. Talk with your healthcare provider about any questions you may have regarding your cannabis use. The information and materials provided to you by PharmaCann should not be used as a substitute for the care and knowledge that your physician can provide. ©2022 PharmaCann. All rights reserved.

IN STORE SCREEN DISCLAIMER: Please consume responsibly. There may be health risks associated with the consumption of this product. This product may cause impairment and may be habit-forming. For use only by adults 21 years of age or older or persons holding a patient registration card. Keep out of the reach of children.

MASSACHUSETTS

CAN MATCH EMAIL CONTENT

If screen does NOT show product: Please consume responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product.

If screen shows product: Please Consume Responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product. This product has not been analyzed or approved by the Food and Drug Administration (FDA). There is limited information on the side effects of using this product, and there may be associated health risks. Marijuana use during pregnancy and breast-feeding may pose potential harms. It is against the law to drive or operate machinery when under the influence of this product. KEEP THIS PRODUCT AWAY FROM CHILDREN. There may be health risks associated with consumption of this product. Marijuana can impair concentration, coordination, and judgment. The impairment effects of edibles may be delayed by two hours or more. In case of accidental ingestion, contact poison control hotline at 1-800-222-1222 or 9-11. This product may be illegal outside of MA. ©2022 PharmaCann. All rights reserved.

MARYLAND

You must be 18 years or older to view this content. Cannabis use is only for certified patients. Always seek the advice of your physician or other qualified healthcare provider before starting any new treatment or discontinuing an existing treatment with medical cannabis. Talk with your healthcare provider about any questions you may have regarding your cannabis use. The information and materials provided to you by PharmaCann should not be used as a substitute for the care and knowledge that your physician can provide to you. There may be health risks associated with the consumption of medical cannabis, consult your physician. ©2022 PharmaCann. All rights reserved.

NEW YORK

Medical cannabis use is only for certified patients. Always seek the advice of your physician or other qualified healthcare provider before starting any new treatment or discontinuing an existing treatment with medical cannabis. Talk with your healthcare provider about any questions you may have regarding your cannabis use. The information and materials provided to you by PharmaCann should not be used as a substitute for the care and knowledge that your physician can provide to you. There may be health risks associated with the consumption of medical cannabis, consult your physician. ©2022 PharmaCann. All rights reserved.

OHIO

Always seek the advice of your physician or other qualified healthcare provider before starting any new treatment or discontinuing an existing treatment with medical marijuana. Talk with your healthcare provider about any questions you may have regarding your medical marijuana use. The information and materials provided to you by PharmaCann should not be used as a substitute for the care and knowledge that your physician can provide to you. There may be health risks associated with the consumption of medical marijuana, consult your physician. ©2022 PharmaCann Ohio. All rights reserved.

PENNSYLVANIA

Always seek the advice of your physician or other qualified healthcare provider before starting any new treatment or discontinuing an existing treatment with medical marijuana. Talk with your healthcare provider about any questions you may have regarding your medical marijuana use. The information and materials provided to you by PharmaCann should not be used as a substitute for the care and knowledge that your physician can provide to you. There may be health risks associated with the consumption of medical marijuana, consult your physician. ©2022 PharmaCann Penn. All rights reserved.

COLORADO

NONE

MICHIGAN

©2022 LivWell Enlightened Health. All Rights Reserved. While supplies last. For use by individuals ages 21+, registered qualified patients ages 18+ and registered primary caregivers. Keep out of reach of children. It is illegal to drive a motor vehicle while under the influence of marihuana. National Poison Control Center 1-800-222-1222.

ILLINOIS

NONE REQUIRED

MASSACHUSETTS

If the advertisement is just for LivWell and not about a cannabis product you must include “Please Consume Responsibly” and at least 2 of these 5 statements verbatim under 935 CMR 500.105(4)(a)7 : “This product may cause impairment and may be habit forming.”; “Marijuana can impair concentration, coordination and judgment. Do not operate a vehicle or machinery under the influence of this drug.”; “There may be health risks associated with consumption of this product.”; “For use only by adults 21 years of age or older. Keep out of the reach of children.”; or “Marijuana should not be used by women who are pregnant or breastfeeding.”

matter. SPECIFIC EMAILS

If the advertisement features cannabis or cannabis products you must include 2 of the 5 statements listed above and this full statement verbatim under 935 CMR 500.105(4)(a)8: Please consume responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product. This product has not been analyzed or approved by the Food and Drug Administration (FDA). There is limited information on the side effects of using this product, and there may be associated health risks. Marijuana use during pregnancy and breast-feeding may pose potential harms. It is against the law to drive or operate machinery when under the influence of this product. KEEP THIS PRODUCT AWAY FROM CHILDREN. There may be health risks associated with consumption of this product. Marijuana can impair concentration, coordination, and judgment. The impairment effects of Edibles may be delayed by two hours or more. In case of accidental ingestion, contact poison control hotline 1-800-222-1222 or 9-1-1. This product may be illegal outside of MA.

MARYLAND

You must be at least 18 years old to view the content. Medical cannabis is for use by certified patients only.

NEW YORK

Medical Cannabis use is only for certified patients. Always seek the advice of your physician or other qualified healthcare provider before starting any new treatment or discontinuing an existing treatment with medical cannabis. Talk with your healthcare provider about any questions you may have regarding your cannabis use. The information and materials provided to you by PharmaCann should not be used as a substitute for the care and knowledge that your physician can provide to you. There may be health risks associated with the consumption of medical cannabis, consult your physician. ©2021 PharmaCann. All rights reserved.

OHIO

Always seek the advice of your physician or other qualified healthcare provider before starting any new treatment or discontinuing an existing treatment with medical cannabis. Talk with your healthcare provider about any questions you may have regarding your cannabis use. The information and materials provided to you by LivWell should not be used as a substitute for the care and knowledge that your physician can provide to you. There may be health risks associated with the consumption of medical cannabis; consult your physician. ©2021 PharmaCann Ohio. All rights reserved.

PENNSYLVANIA

Always seek the advice of your physician or other qualified healthcare provider before starting any new treatment or discontinuing an existing treatment with medical marijuana. Talk with your healthcare provider about any questions you may have regarding your medical marijuana use. The information and materials provided to you by PharmaCann should not be used as a substitute for the care and knowledge that your physician can provide to you. There may be health risks associated with the consumption of medical marijuana, consult your physician. ©2021 PharmaCann Penn. All rights reserved.

ALL PHARMACANN LEGACY STATES (IL, MA, MD, NY, OH, PA)

ALL EMAIL DISCLAIMERS SHOULD BE IN THE FOOTER OF THE EMAIL

NON-VERIVIP EMAIL DISCLAIMER

While supplies last. There may be health risks associated with the consumption of this product. This product may cause impairment and may be habit-forming. Please consume responsibly. For use only by adults 21 years of age or older or persons holding a patient registration card in Illinois and Massachusetts. Cannabis use is for certified patients only in Maryland, New York, Pennsylvania, and Ohio. Keep out of the reach of children. Please click on the disclaimer link listed below for your state’s specific disclaimers.

This email was sent by PharmaCann Ohio, LLC, PharmaCann of New York, LLC, PharmaCannis Massachusetts, Inc., PharmaCann of MD, LLC, PharmaCann Penn, LLC, PharmaCann Inc., and Midwest Compassion Center.

PharmaCann Inc. 190 S. LaSalle, 29th Fl, Chicago, IL 60603

Unsubscribe | Disclaimers (https://www.LivWell.com/email-disclaimers) | Terms of Use (https://www.LivWell.com/termsuse) | Locations (https://www.LivWell.com/LivWell-dispensary-locations)

VERIVIP EMAIL DISCLAIMER

Points are non-transferable and can be redeemed only by the customer or patient associated with VeriVIP. Points must be redeemed in a single transaction. If the entire redemption amount is not used, the unused points cannot be credited to another VeriVIP account, redeemed for cash, or used as a merchandise credit. Points will not be refunded with returns. Points must be redeemed within 12 months of your last transaction. You must have a minimum of 200 points to redeem rewards. Massachusetts recreational customers are not eligible to earn points. For more information regarding the VeriVIP rewards program, please visit https://www.LivWell.com/verivip. There may be health risks associated with the consumption of this product. This product may cause impairment and may be habit-forming. Please consume responsibly. For use only by adults 21 years of age or older or persons holding a patient registration card in Illinois and Massachusetts. Cannabis use is for qualifying patients only in Maryland, New York, Pennsylvania, and Ohio. Keep out of the reach of children. Please click on the disclaimer link listed below for your state’s specific disclaimers.

This email was sent by PharmaCann Ohio, LLC, PharmaCann of New York, LLC, PharmaCannis Massachusetts, Inc., PharmaCann of MD, LLC, PharmaCann Penn, LLC, PharmaCann Inc., and Midwest Compassion Center.

Pharmacann Inc. 190 South Lasalle Floor 29, Chicago, IL 60603

Unsubscribe | Disclaimers (https://www.LivWell.com/email-disclaimers) | Terms of Use (https://www.LivWell.com/termsuse) | Locations (https://www.LivWell.com/LivWell-dispensary-locations)

NEW YORK EMAIL DISCLAIMER

Add to universal disclaimer: Orders must be picked up or delivered during the promotional period to receive reduced pricing. While supplies last.

ILLINOIS

N/A

MASSACHUSETTS

If NOT showing product: Please consume responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product.

If showing product: Please consume responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product. This product has not been analyzed or approved by the Food and Drug Administration (FDA). There is limited information on the side effects of using this product, and there may be associated health risks. Marijuana use during pregnancy and breast-feeding may pose potential harms. It is against the law to drive or operate machinery when under the influence of this product. KEEP THIS PRODUCT AWAY FROM CHILDREN. There may be health risks associated with consumption of this product. Marijuana can impair concentration, coordination, and judgment. The impairment effects of Edibles may be delayed by two hours or more. In case of accidental ingestion, contact poison control hotline 1-800-222-1222 or 9-1-1. This product may be illegal outside of MA

MARYLAND

All images in texts must state: Cannabis use is only for certified patients.

NEW YORK

N/A

OHIO

N/A

PENNSYLVANIA

N/A

BLOGS

Worded for recreational use General information, no specific state callouts (no specific locations, no products exclusive to certain states) No health claims, keep content factual May need to add disclaimers if showing product images (can show bud) Can show product images, can’t show people smoking, nothing cartoony or anything considered appealing to children If NOT showing/discussing product Please consume responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product.

If showing product/ STANDARD blog: Recreational Cannabis is not available in all states. Cannabis is for medical use only and may only be used by certified patients in Maryland, New York, and Pennsylvania. State laws impact what dispensaries can and can’t sell to recreational customers and medical marijuana patients. Not every type of product, consumption method, dosage form, or potency mentioned on this blog will be permitted in all locations.

If FOOD/recipe blog: Recreational Cannabis is not available in all states. Cannabis is for medical use only and may only be used by certified patients in Maryland, New York, and Pennsylvania. State laws impact what dispensaries can and can’t sell to recreational customers and medical marijuana patients. Not every type of product, consumption method, dosage form, or potency mentioned on this blog will be permitted in all locations. You assume full responsibility for using your best judgment when cooking with raw ingredients such as beef, poultry, or eggs, and seeking information from an official food safety authority if you are unsure. You must also take care to not physically injure yourself by coming into contact with hot surfaces, sharp blades, and other kitchen hazards. It is your responsibility to review all listed ingredients in a recipe before cooking to ensure that none of the ingredients may cause a potential adverse reaction to anyone eating the food based on recipes featured in this blog post. This includes allergies, pregnancy-related diet restrictions, etc. Please consult with your medical professional before using any recipe if you have concerns about how you may individually react to the use of any particular recipe or ingredient. By voluntarily creating and using any recipe provided here, you assume the risk of any potential injury that may result. All information provided regarding nutrition in this post is intended to be used for informational purposes only. Content related to nutrition is not medical advice nor is it intended to replace medical advice. This post is not intended to diagnose, prescribe, or treat any disease, condition, illness, or injury. Before beginning any diet program, modifying your diet, or making changes to the diet of a child in your care, including following the nutrition

information available in this post, you should seek advice from a licensed professional.The Food and Drug Administration has not evaluated the statements contained in any information on this Website. Individual results may vary. We are not responsible for any liability, loss, or damage, caused or alleged to be caused directly or indirectly as a result of the use, application, or interpretation of the nutrition information available in this post. The author disclaims liability for incidental or consequential damages and assumes no responsibility or liability for any loss or damage suffered by any person as a result of use of the information provided in this blog post. The author assumes or undertakes no liability for any loss or damage suffered as a result of the use of any information found on this Website. From time to time, this Website will publish content with recipes. All such recipes have been tried and used successfully, but results may vary from person to person. Consult your medical professional before using any recipe if you have concerns about how you may individually react to the use of any particular recipe or ingredient. By voluntarily creating and using any recipe provided here, you assume the risk of any potential injury that may result.

If Health claim/medical blog: This content is not intended as medical advice. The information provided is meant to encourage cannabis education, not replace direct patient-healthcare professional relationships. Always consult your primary care physician or other healthcare provider prior to using cannabis products for treatment of a medical condition. Any statements contained herein have not been evaluated by the Food and Drug Administration. Products referenced are not intended to diagnose, treat, cure, or prevent any disease. Products are only available where consumption of cannabis is legal.

If MA specific only: Please consume responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product. This product has not been analyzed or approved by the Food and Drug

ALL STATES

Trigger words on social

Cannabis, THC, CBD, Marijuana

Pricing on social

Cannot talk about pricing, sales, deals, promotions. You cannot advertise an illegal substance for sale

ILLINOIS

No disclaimers needed Yes, you can show product Yes, you can suggest recreational use

MASSACHUSETTS

Does not feature product: Please Please Consume Responsibly. Marijuana can impair concentration, coordination and judgment. Do not operate a vehicle or machinery while under the influence of this drug. Marijuana should not be used by women who are pregnant or breastfeeding.

When there is a product: Please Consume Responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product. Please visit LivWell.com/regulations for regulations and additional information.

Yes, you can show product Yes, you can suggest recreational use

MARYLAND

You must be at least 18 years old to view this content. “In Maryland, medical cannabis is for use by certified patients only

Yes, you can show product No, you cannot suggest recreational use

NEW YORK

No disclaimers needed Yes, you can show product No, you cannot suggest recreational use

OHIO

No social media posts, unless we create a template No, you cannot show product No, you cannot suggest recreational use

PENNSYLVANIA

No disclaimers needed Yes, you can show product No, you cannot suggest recreational use

ILLINOIS

No disclaimers needed

MASSACHUSETTS

Does not feature product: Please Please Consume Responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product.

If screen shows product: Please consume responsibly. This product may cause impairment and may be habit forming. There may be health risks associated with consumption of this product.

This product has not been analyzed or approved by the Food and Drug Administration (FDA). There is limited information on the side effects of using this product, and there may be associated health risks. Marijuana use during pregnancy and breast-feeding may pose potential harms. It is against the law to drive or operate machinery when under the influence of this product. KEEP THIS PRODUCT AWAY FROM CHILDREN. There may be health risks associated with consumption of this product. Marijuana can impair concentration, coordination, and judgment. The impairment effects of Edibles may be delayed by two hours or more. In case of accidental ingestion, contact poison control hotline 1-800-222-1222 or 9-1-1. This product may be illegal outside of MA.

MARYLAND

You must be at least 18+ to view the content. Cannabis use is only for certified patients.

NEW YORK

No disclaimers needed

OHIO

No disclaimers needed

PENNSYLVANIA

No disclaimers needed

CONTACT INFORMATION:

Heather Shevitz

Creative Director

heather.shevitz@pharmacann.com