On the agenda: Flossmoor meeting — surveillance camera (Oct 15)

MEMORANDUM
TO:
FROM:
DATE:
RE:

CHAIR MITCHELL AND MEMBERS OF THE PLAN COMMISSION
SCOTT M. BUGNER – DIRECTOR OF BUILDING AND ZONING
OCTOBER 8, 2026
REGULAR OCTOBER MEETING

Please find enclosed the agenda and related materials for the regular October meeting of the
Flossmoor Plan Commission. The meeting will be held on Thursday, October 15th, beginning at
6:00 p.m. This meeting will be conducted in person at Village Hall.
There is one item on the agenda for your consideration.
• Consideration of a Special Use Permit – Aces Dispensary (3327 Vollmer Road)
Please telephone Jen Fisher at 957-4101 or e-mail her at [email protected] no later than
5:00 p.m. Wednesday, October 14, 2026 to confirm your attendance. As always, it is important
that we confirm as early as possible that a quorum will be available for the meeting.
If you have any questions or require additional information please do not hesitate to contact me
via email at [email protected]

PLAN COMMISSION
October 15, 2026
6:00 P.M.
FLOSSMOOR VILLAGE HALL
The October 15, 2026 meeting of the Flossmoor Plan Commission will be conducted in
person at Village Hall. Public participation will be permitted only in person during the
Public Comment portion of a public hearing. Members of the public may also comment by
email to [email protected] if received no later than 5:00 PM, Wednesday October 14,
2026.
AGENDA
1.

ROLL CALL

2.

APPROVAL OF THE MINUTES OF THE MEETING OF MAY 21, 2026

3.

CONSIDERATION OF A SPECIAL USE PERMIT FOR AN ADULT USE CANNABIS
DISPENSARY – Aces Dispensary (3327 Vollmer Road)

4.

OTHER BUSINESS
a. Findings and Recommendations – Aces Dispensary

5.

ADJOURNMENT

MEMORANDUM
To:
FROM:
DATE:
RE:

CHAIR MITCHELL AND MEMBERS OF THE PLAN COMMISSION
SCOTT M. BUGNER, DIRECTOR OF BUILDING AND ZONING
MAY 15, 2026
CONSIDERATION OF A SPECIAL USE PERMIT – ACES DISPENSARY – 3327 VOLLMER ROAD

The Village has received a request for approval of a special use permit for a proposed adult use
cannabis dispensary at 3327 Vollmer Road in the Flossmoor Commons shopping center which is in a
B3 – Planned Business Center District.
The facts of the matter are as follows:
Section 285-16-3 D. of the Flossmoor Zoning Ordinance permits Cannabis Dispensing Organizations
as a special use in accordance with Chapter 200, Article 6, of the Flossmoor Municipal Code and
subject to the following conditions:
1. Shall not be located within 1,000 feet of the lot line of any elementary, middle or high school.
2. Craft growers, cultivation centers, infuser facilities, processing facilities, and transportation facilities
shall be prohibited.
3. On-premises consumption of cannabis products is prohibited.
4. No images of cannabis or paraphernalia be displayed in windows, nor advertised by signs viewable
from building exterior.
5. No more than one cannabis dispensing organization shall be permitted within the Village at any time.
The petitioner indicates that Aces Dispensary would comply with all State of Illinois requirements as
well as the requirements and conditions set forth in the Village of Flossmoor Zoning and Municipal
Codes.
The proposed retail space at 3327 Vollmer Road is approximately 3,750 square feet in area including
the second-floor space which will accommodate an office, break room, IT closet and storage space.
Principal improvements to the space would include the installation of a comprehensive security system,
with interior and exterior surveillance cameras, motion and glass break protection, duress alarms, card
reader-controlled access systems and a reinforced vault to secure all cannabis inventory and currency.
The dispensary anticipates creating approximately 30 - 35 employment positions, full and part-time
combined when fully staffed. Proposed hours of operation would be 9:00 a.m. to 9:00 p.m. Monday
through Thursday, 9:00 a.am. to 10:00 p.m. Friday and Saturday, and 10:00 a.m. to 9:00 p.m. on
Sunday.
Aces Dispensary and its affiliate currently operate four dispensaries in Illinois, with locations in Darien,
Normal, Elgin and Plainfield. Aces Dispensary holds a Conditional Adult Use Dispensary License
issued by IDFPR for BLS Region 5 which authorizes them to secure a location and build out the
dispensary. Following completion of the build out, IDPFR would conduct a final inspection, with a full
operating license being issued only upon successful completion of that inspection. In addition, the Fire
Department, Police Department and Building Department would also conduct inspections prior to being
issued a certificate of occupancy.

To assist you in consideration of this matter please find attached the following materials:
•
•
•
•
•
•
•

Application for Land Use Review
Business Plan
Security Plan
Supplemental Information
Floor Plans
Sign Plan
Legal Notice

ALL APPLICANTS MUST ANSWER THE FOLLOWING QUESTIONS

□
□
□X
□
□
□
□

PLEASE INDICATE WHICH TYPE OF LAND USE REVIEW YOU ARE SEEKING:
Approval of a Plat of Subdivision, Resubdivision or Consolidation
Approval of a Request for Rezoning
Approval of a Special Use Permit
Approval of an Amendment to an existing Special Use Permit
Approval of a Site Plan (Non-Single Family Residential)
Approval of a Planned Unit Development
Approval of an Amendment to an approved Planned Unit Development

What is the current Zoning of the subject property (i.e., R-1 Single Family Residential)?

What is the current use of the subject property (i.e. vacant, improved with single family
home etc)?

This property is currently vacant. It was formerly occupied by a ReMax
real estate office and was most recently occupied by The Mommie
Experience, a selfie museum and event venue.

LAND USE REVIEW FEES
Approval of a Plat of Subdivision, Resubdivision or Consolidation
** $300.00**
Approval of a Request for Rezoning
** $300.00**
Approval of a Special Use Permit
** $300.00**
Approval of an Amendment to an existing Special Use Permit
** $300.00**
Approval of a Site Plan (Non-Single Family Residential)
** $300.00**
Approval of a Planned Unit Development
** $300.00**
Approval of an amendment to an approved Planned Unit
Development
** $300.00**
Approval of a Request for Annexation
** $300.00**
Approval of a Variation from the Subdivision Regulations
** $300.00**

Word:Plan Commission:Application for Land Use Review

OSIRIS HOLDINGS, LLC
d/b/a ACES DISPENSARY
BUSINESS PLAN
September 2026
Business Plan Introduction
We have carefully and deliberately planned every aspect of our adult use dispensary. This Business
Plan provides a comprehensive overview of our company, including key partnerships and
resources, construction and operational timelines with associated costs, anticipated staffing
requirements, and our plan to achieve profitability.
To provide a complete picture of our operational strategy, this plan also includes a brief financial
overview, including projected inventory volumes and storage management. Developed under the
guidance of cannabis professionals with a combined seven years of experience running
dispensaries in Illinois, this Business Plan reflects a holistic approach to the operations we intend
to undertake.
Our plan is deeply aligned with Illinois’ social equity framework, especially workforce-based
eligibility. From launch, we will employ more than 10 full-time employees, with a majority
qualifying as social equity staff, with a focus on residents of Disproportionately Impacted Areas
(DIAs) in the vicinity of our chosen location. This commitment ensures compliance with state law
and delivers direct economic benefit to the communities most affected by past cannabis policies.
Company Summary
Osiris Holdings, LLC, doing business as Aces Dispensary (“Aces Dispensary”), has as its mission
to become a premier adult use dispensary in Illinois, setting a standard for social equity, corporate
responsibility, and regulatory compliance. Founded by experienced cannabis operators who are
ready to take the reins and build their own business, our company combines industry expertise
with a commitment to creating a dispensary that truly embodies the social equity principles
intended by the Department.
Our guiding values, known as the Four Pillars, shape our daily operations and drive us toward this
mission:
●

Social Responsibility. We commit to acting in ways that benefit society and our
community, including prioritizing social equity in hiring and business practices.

●

Education. We strive to educate our customers and community on responsible cannabis
consumption, ensuring safe and informed use.

●

High Standards. We uphold the highest standards by consistently choosing quality
products, ethical business practices, and operational excellence.

●

Culture. We foster a workplace culture rooted in trust, respect, and compassion, creating
a supportive environment for our employees and customers alike.

With years of combined experience operating dispensaries in Illinois, our founders are uniquely
positioned to navigate the regulatory landscape, implement best practices, and launch a dispensary
that not only meets compliance standards but also serves as a model for equity, community impact,
and operational excellence. By leveraging our expertise, we aim to create a sustainable, profitable
business that benefits both our team and the communities we serve.
Key Partnerships
We have already established strong, trusted relationships with local cultivators and industry
partners. These connections provide a foundation for sourcing high-quality cannabis products and
allow us to collaborate effectively with growers, infusers, and other licensed businesses. In
addition, we are committed to prioritizing partnerships with social equity cultivators and infusers
wherever possible, supporting the Department’s goals for equitable participation in the cannabis
industry. Our objective is to develop a robust network of key partners to ensure a value-added,
customer-focused experience, offering a wide variety of products across all categories while
encouraging collaborative initiatives on product margins, marketing, and advertising that meet the
needs of our adult use customers.
Every cannabis product affects each purchaser differently, and each individual has unique
preferences for consuming their “cannabis” (410 ILCS 705/1-10, defining “Cannabis” to include
concentrates and cannabis-infused products). To meet these diverse needs, our dispensary will
offer a comprehensive selection of methods for adult use, including smoking and vaporized
products, concentrates, live resin, and cannabis-infused products such as topicals, edibles, and oral
or sublingual offerings. We will also offer several forms of paraphernalia for use by adult
purchasers. Our dispensary employees will receive thorough training on the expected effects and
safe use of each product type, enabling them to provide personalized consultations and guidance
tailored to each customer’s preferences.
All products will be sourced exclusively from Illinois-licensed craft growers, cultivation centers,
and infusers; we will not produce or manufacture cannabis in-house (410 ILCS 705/15-70(c),
(n)(1)). Cannabis-infused products will strictly adhere to the Department of Agriculture’s rules
governing maximum THC levels per serving and packaging (410 ILCS 705/55-5(f)), and all
products will feature primary packaging that clearly identifies our dispensary (410 ILCS 705/1570(b)). Product names will be distinctive, clearly differentiating types and strains, and we will
continuously evaluate and expand our offerings to provide the widest possible selection for adult
use purchasers.

We will not sell seeds or live plant material, consistent with Illinois law for adult use dispensaries
(410 ILCS 705/15-70(n)(16)). By fostering strong partnerships and carefully curating our product
selection, our dispensary will provide a safe, responsible, and highly tailored experience for every
customer.
Smoking and Vaporization Products
Our dispensary will offer a diverse selection of dried cannabis flower to meet the needs and
preferences of adult use purchasers. Available strains will vary in potency, ranging from lowstrength options with mild effects to high-strength varieties for immediate relief, all presented in
pristine, manicured, and clean flower in various sizes (410 ILCS 705/1-10, defining “Cannabis
flower”). Purchasers will be able to consume flower through traditional combustion methods, such
as flower or pre-rolls, or via vaporization using high-quality vaporizer pens available for purchase
at our dispensary.
Combustion, or smoking, remains a popular method due to its simplicity, affordability, and the
ability for users to precisely regulate dosage. The rapid onset of effects makes combustion an ideal
option for purchasers seeking immediate relief or specific therapeutic effects.
For those who prefer a cleaner alternative, we will offer a robust selection of vaporization products,
including preloaded cartridges, standard and disposable vaporizer pens, and compatible batteries.
Vaporization provides many of the same benefits as combustion, such as rapid onset, while
minimizing lung irritation and reducing odor generation. We will carefully vet all vaporization
suppliers to ensure that our customers receive only the safest, highest-quality products. Our team
is well-versed in public health concerns and stays informed about current issues related to vaping,
ensuring responsible product selection and guidance for our purchasers.
By offering both smoking and vaporization options, we aim to provide a safe, flexible, and
satisfying experience that accommodates a wide range of consumption preferences and promotes
responsible, informed use.
Topicals
Topicals utilize full-spectrum cannabis extracts to deliver cannabinoids through the skin, providing
targeted relief without producing the intoxicating effects often associated with other consumption
methods. Oils, creams, and other topical formulations are absorbed directly into the skin, making
them popular among purchasers seeking localized relief for muscle aches, soreness, or other
discomforts. Our dispensary will offer topicals in both high-CBD and high-THC formulas,
available in a variety of container sizes. Potential ingredients include cannabis extract, coconut oil,
beeswax, essential oils such as lavender, peppermint, or tea tree, vitamins, aloe vera gel, and cocoa
butter.

When developing our topical product lines, we will conduct a thorough analysis of the Illinois
cannabis market, as well as markets in other states, to identify gaps and address underserved
purchaser needs. Our goal is to provide a wide variety of high-quality, safe, and effective topical
products that meet diverse consumer preferences. Potential offerings may include creams, salves,
balms, sprays, lotions, bath salts, bath bombs, massage oils, and lip balms. By providing a broad
selection of topicals, we aim to enhance the purchaser experience, support responsible use, and
ensure our dispensary meets the varied needs of the adult use community.
Transdermal Patches
Similar to topicals, transdermal patches are applied directly to the skin, but they are designed to
deliver a specific dose of cannabinoids directly into the bloodstream. These medicated adhesive
patches provide a controlled, slow release of cannabinoids over an extended period, offering allday or all-night effects. This delivery method allows purchasers to enjoy the therapeutic benefits
of cannabis discreetly, without the need for repeated dosing throughout the day.
Transdermal patches are particularly valuable for purchasers seeking long-lasting, predictable
effects for conditions such as chronic pain, inflammation, or sleep support. By including
transdermal patches in our product offerings, our dispensary will provide a convenient, discreet,
and effective option for responsible adult use consumers, further enhancing the breadth and quality
of our product selection.
Edibles
Edibles are consumed orally, allowing cannabinoids to enter the bloodstream through digestion
and absorption in the intestines. This method provides longer-lasting effects compared to
inhalation and is ideal for purchasers seeking a healthier alternative to smoking, a more discreet
method of consumption, or a more controlled, enjoyable experience. Our dispensary plans to offer
a large and diverse selection of cannabis-infused edibles to meet the varied preferences and needs
of adult use purchasers in Illinois.
Potential offerings may include syrups, dissolvable powders, beverages, tea bags, baked goods
such as caramels, waffles, brownies, and cookies, infused oils including olive, coconut, or
avocado, and take-and-bake ingredients such as cookie dough, pizza sauce, and powdered
chocolate for home baking. We will also provide savory products like candied bacon, beef jerky,
and pork skins, as well as chocolates, pastilles, lollipops, granola bars, gum, taffies, mints, and
gummies. All edible products will be carefully selected to avoid packaging or shapes that could
appeal to children, ensuring responsible adult use.
By offering an extensive variety of edibles, our dispensary will provide purchasers with safe,
enjoyable, and discreet options that enhance the overall cannabis experience while adhering to
Illinois regulatory standards.

Oral and Sublingual Products
Tinctures. Our dispensary will offer cannabis in tincture form, a preferred method for purchasers
seeking a discreet and precise way to consume cannabinoids (410 ILCS 705/1-10, defining
“Tincture”). Tinctures are less viscous liquids intended for buccal (inside the cheek) or sublingual
(under the tongue) administration. Using a dropper allows for easy measurement and accurate
dosing, making tinctures ideal for purchasers who need fine control over dosage or prefer a lowerpotency option. Tinctures will be the only products at our dispensary containing alcohol, and all
containers will be limited to 100 milliliters to comply with state regulations (410 ILCS 705/1570(d)).
Lozenges. Lozenges are orally administered and designed to dissolve slowly in the mouth,
providing a continuous release of cannabinoids to the oral mucosa through sublingual absorption.
This method allows for relatively rapid effects while offering a controlled and discreet
consumption experience. We will offer lozenges in a variety of cannabinoid profiles, including
THC-only and CBD-only options, to meet diverse purchaser preferences.
Capsules, Pills, and Tablets. Capsules, pills, and tablets containing cannabis extracts provide a
familiar, traditional, and precise method of consumption. These products deliver activated
cannabinoids in specific doses and are easily consumable by any purchaser capable of swallowing
them. Many users prefer capsules for their convenience, portability, and predictable dosing.
Syringes. Syringes, like tinctures, are intended for buccal or sublingual use and contain a measured
amount of cannabis oil in a plastic plunger, with no needle involved. Syringes allow for rapid
consumption and precise dosing within seconds and can also be used to refill compatible vape
cartridges.
By offering a comprehensive selection of oral and sublingual products, our dispensary will provide
purchasers with precise, discreet, and flexible options for cannabis consumption, accommodating
a wide range of preferences while promoting safe and responsible use.
Concentrates
Shatter and Hash Oil. Shatter is a highly potent cannabis extract produced by using CO2 or
hydrocarbon solvents to concentrate cannabinoids and terpenes from plant material. Hash oil is a
similar concentrated form that delivers high cannabinoid content in a versatile product format,
providing purchasers with strong and reliable effects.
Wax. Cannabis wax can have a crumble or creamy “budder” consistency, depending on the plant
material used in extraction. During production, the concentrate is whipped to introduce oxygen,
resulting in a more user-friendly texture that is easier to handle and consume.

Distillate. Distillates are produced by heating and refining crude cannabis oil to concentrate
cannabinoids while removing plant solids. This process results in a potent, full-spectrum product
that delivers consistent effects and can be used in a variety of consumption methods, including
vaporization and infusion into edibles.
Isolate. Isolates take distillates a step further by separating individual cannabinoids or terpenes
into single-compound products. Isolates are particularly valuable for purchasers seeking precise,
targeted effects or for experimentation with specific cannabinoids such as THC, CBD, or
individual terpenes.
Live Resin. Live resin concentrates preserve the natural flavors, aromas, and effectiveness of
freshly harvested or immediately frozen cannabis. This extraction method maintains the plant’s
full terpene profile, often resulting in higher potency and enhanced flavor compared to traditional
concentrates.
Live Rosin. Live rosin is a solventless extract created using heat and pressure, and in some methods
water, to produce a high-quality concentrate. When produced from freshly harvested or frozen
cannabis, live rosin delivers potent effects with full flavor and aroma while avoiding the use of
chemical solvents.
Kief or Sugar. Kief consists of the cannabinoid-rich capitate glands separated from the flower and
sugar leaves of the cannabis plant, typically through sifting, tumbling, or agitation. Sugar is a
similar product often produced by agitating plant material in an ice bath and then straining and
drying. Both provide concentrated cannabinoids in a form that can be used alone or infused into
other products.
By offering a full range of concentrates and live resin products, our dispensary will provide adult
use purchasers with potent, flavorful, and high-quality options, catering to a range of preferences
while maintaining safe, responsible use standards.
Cannabis Paraphernalia
In addition to cannabis products, our dispensary will offer a variety of paraphernalia for adult use
purchasers. Under recent legislation, cannabis paraphernalia is defined as equipment, products, or
materials intended to be used for packaging, repackaging, storing, containing, concealing,
ingesting, or otherwise introducing cannabis into the human body (410 ILCS 705/1-10, SB1557
revisions).
Our paraphernalia offerings will include secure storage containers, grinders, vaporizers and
vaporizer batteries, a variety of pipes, rolling papers, filters, dab tools, rolling trays, and lighters.
We will continuously monitor purchaser demand and tailor our paraphernalia selections to meet
market preferences while prioritizing quality, safety, and compliance.

All paraphernalia products will fully comply with state and local regulations. Prior to introducing
any new items for sale, we will coordinate with the Department to ensure compliance with all
applicable laws and standards. By carefully curating our paraphernalia offerings, we aim to provide
adult use purchasers with safe, functional, and high-quality tools that enhance their cannabis
experience.
Other Products for Sale
In addition to cannabis products and paraphernalia, our dispensary will offer a variety of
miscellaneous products, including branded merchandise such as t-shirts, hats, bottles, stickers, tote
bags, and other items designed to engage and delight our adult use purchasers. We will
continuously evaluate market trends and purchaser feedback to adapt our offerings and explore
new, creative products that enhance the overall customer experience.
All miscellaneous products will strictly comply with applicable statutory and regulatory
requirements, including the Illinois Compiled Statutes and Department regulations regarding
advertising, marketing, and product safety. We will not sell any products containing alcohol,
except for tinctures, which will be limited to containers no larger than 100 milliliters to remain
fully compliant (410 ILCS 705/15-70(d)).
By offering thoughtfully curated non-cannabis products alongside our core dispensary items, we
aim to enhance the retail experience, build brand loyalty, and provide additional value to our adult
use purchasers while maintaining strict adherence to all regulatory standards.
Estimated Volume of Cannabis Planned to be Stored at Dispensary
A cornerstone of our operational strategy is ensuring a consistent and uninterrupted supply of highquality cannabis products to meet purchaser demand and build long-term trust and loyalty.
Purchasers will come to rely on our dispensary to have their preferred products in stock, and we
recognize that both undersupply and oversupply can be equally damaging. Undersupply risks
driving purchasers elsewhere and eroding brand trust, while oversupply may result in product
expiration, regulatory complications, and financial inefficiencies.
In alignment with the Department’s Advisory Notice, we have quantified our anticipated storage
levels using estimated retail value. Our demand analysis, based on historical sales data and trends
in comparable Illinois and national markets, indicates that by the end of the first year of operations
monthly demand will reach approximately 335 pounds of cannabis per dispensary license,
inclusive of cannabis flower and flower-equivalent oil-based products. We anticipate this demand
will grow gradually over the course of the first year as the dispensary establishes its customer base.
To responsibly meet this demand while maintaining compliance, we plan to begin with an initial
inventory valued at approximately $560,128, representing a two-week supply at projected initial

sales volumes. This inventory will be strategically diversified across product categories to provide
a wide selection for purchasers while ensuring effective inventory turnover.
Product Category

Inventory Quantity

Wholesale Cost

Retail Value

Dry Flower

49.1 lbs

$122,835

$294,804

Concentrates

1,286 grams

$32,160

$70,753

Vape Cartridges

2,144 units

$53,601

$117,922

Tinctures

354 units

$7,075

$17,688

Topicals

354 units

$7,075

$17,688

Capsules

295 units

$7,370

$17,688

Edibles

884 units

$7,075

$17,688

Transdermal Patches

468 units

$2,808

$5,896

$240,000

$560,128

Total Cannabis Products (two week supply)

The opening inventory shown above represents our position at launch. We anticipate that the
volume of cannabis held at the dispensary will increase over the course of the first year of
operations, in step with growth in customer demand, while continuing to represent an approximate
two-week supply at then-current sales volumes. Inventory levels will be reviewed continuously
through our point of sale and inventory management systems so that increases are driven by
demonstrated demand rather than by speculation. This balanced approach allows us to maintain
strong supply consistency, minimize waste, and remain fully aligned with all state regulations.
Corporate Organizational Structure
Aces Dispensary is wholly owned by Monsaur Othman, Founder and Owner, who holds 100
percent ownership of the company. Day-to-day operation of the dispensary will be led by our
General Manager, supported by designated Agents-in-Charge who are separately licensed and who
may act in the manager’s capacity whenever the General Manager is not on site.
Employee Training
Every staff member will participate in comprehensive foundational training as part of our
onboarding program, including review of the Employee Handbook, company policies, and
dispensary-specific procedures. Beyond this foundation, all employees will receive role-specific
training overseen by the Owner and the General Manager before undertaking any dispensing
responsibilities. Training will not be a one-time event; employees will receive continuing
education throughout their employment to ensure compliance, consistency, and excellent customer
service.

Dispensing education will be a central focus of training. Employees will be thoroughly trained on
the use of our point of sale system, including how to create purchaser profiles for our loyalty
program, navigate product look-up functions, ring up sales, properly log transactions, and
complete register reconciliation at the close of business. To ensure maximum proficiency, we will
partner with our point of sale software provider to deliver provider-led, hands-on training sessions.
In addition, training will cover our dispensing procedures, confidentiality obligations, purchaser
education responsibilities, and protocols for handling situations such as denial of sale. Security
training will also be a key component of our program, with our professional security provider
conducting structured sessions to ensure both staff and customer safety at all times.
We will comply with Illinois state regulations requiring all cannabis employees holding a
Dispensary Agent Badge to complete the Responsible Vendor Training Program each year through
a state-approved provider. Inclusive of the two-hour Responsible Vendor Training requirement,
we will ensure that all badge holders participate in a minimum of eight hours of annual training,
covering all elements required by state regulations. This commitment guarantees that our
employees remain fully informed, responsible, and compliant in their roles.
We are committed to creating a culture of accountability and professionalism. To that end, the
Owner will maintain detailed records of all staff training for at least three years after an employee’s
termination, in full compliance with state requirements. This structured and ongoing investment
in staff development ensures our dispensary operates with the highest levels of safety, compliance,
and customer care.
Startup Costs, Occupancy, and Staffing
Aces Dispensary is committed to bringing a high-functioning, fully compliant cannabis business
to the Village of Flossmoor. Opening a dispensary carries substantial cost. Expenses begin with
retrofitting the facility and implementing the rigorous security measures required by Illinois
cannabis regulations. Once construction is complete, additional resources are needed to stock the
vault with sufficient product, hire and train a qualified staff, and launch operations.
We have secured construction funding to build out our facility and have working capital in place
to support operations through the opening period and into stabilization. We are not seeking outside
financing in connection with this project, and we do not anticipate requiring additional external
support.
Our occupancy costs are fixed and known. Under our lease at 3327A West Vollmer Road, the
leased premises comprise approximately 3,750 square feet of net rentable area, held under an initial
five-year term with one five-year extension option. Base rent is set as follows:

Lease Year

Base Rent Per Month

Base Rent Per Year

Year 1

$6,250.00

$75,000.00

Year 2

$6,437.50

$77,250.00

Year 3

$6,630.62

$79,567.44

Year 4

$6,829.53

$81,954.36

Year 5

$7,034.42

$84,413.04

In addition to base rent, we pay our proportionate share of common area maintenance, insurance,
and real estate taxes as additional rent. Based on current estimates, additional rent is approximately
$1,293.75 per month for common area maintenance and insurance and approximately $1,509.98
per month for property taxes, bringing total estimated occupancy cost in the first lease year to
approximately $9,053.73 per month. A security deposit of $11,000 was paid at lease execution.
A significant portion of our operating budget will directly support employment. Our dispensary
expects to create approximately 31 positions, offering meaningful opportunities to residents of
Flossmoor and the surrounding communities. The positions will pay competitive wages and
include both leadership and entry-level opportunities, structured as follows:
●

One General Manager at $60,000 per year

●

One Assistant General Manager at $54,000 per year

●

Four Agent-in-Charge Supervisors at $45,000 per year each

●

Fifteen Budtenders at $17 per hour

●

Five Inventory Associates at $17 per hour

●

Five Front Desk Associates at $17 per hour

These roles will not only support the successful launch of the dispensary but also create long-term
economic value for the community. We anticipate reaching operational stability within the first
year and achieving profitability shortly thereafter, ensuring both business success and sustained
positive impact for Flossmoor and its residents.
Financial Plan
Our approach to financial modeling is rooted in conservative and disciplined assumptions, with
robust sensitivity analysis on all major inputs. When uncertain, we deliberately estimate expenses
on the higher end and revenues on the lower end. This ensures that our projections account for
volatility in the cannabis industry and safeguard against over-optimism.

We have developed multiple scenarios to evaluate the impact of varying purchaser adoption rates
and purchase volumes. In one conservative model, we assume only 50 percent of our anticipated
market share, which demonstrates our readiness to navigate a slower ramp-up period while still
maintaining solvency. Conversely, we also modeled a scenario in which market demand reaches
200 percent of anticipated sales, as rapid and overwhelming success can also create operational
and financial challenges. Across all modeled scenarios, our financial structure positions the
business to reach permanent cash-flow positivity within the first year of operations.
Banking and Financial Oversight
We have proactively engaged a variety of banking institutions to evaluate their willingness to
provide financial services to cannabis-related businesses. We are pleased with our current banking
solution and have already opened an account designated for business operations. Our leadership
team is well-prepared for the routine audits required by financial institutions.
Financial oversight will be managed at two levels. The Owner is responsible for high-level
oversight, compliance, and financial strategy. Our accountant and bookkeeper are responsible for
day-to-day transaction management, reporting, and reconciliations.
Together, they will ensure full compliance with 410 ILCS 705/15-75(d)(4) by filing the required
annual compilation report, including an income statement, balance sheet, profit and loss statement,
statement of cash flows, wholesale cost and sales, and any other documentation required by the
Department. Each report will include a review letter from a licensed Certified Public Accountant
affirming its accuracy.
Our team includes cannabis industry experts with proven experience securing banking
relationships in other states, providing us a significant advantage in navigating Illinois’ financial
landscape.
Legislative Context
We are also closely tracking state-level efforts to normalize cannabis banking. Illinois Senate Bill
2023, effective as of August 2019, amended the Illinois Banking Act and Credit Union Act to
prevent regulators from penalizing financial institutions for working with cannabis businesses.
This progress, along with federal momentum, increases our confidence in long-term banking
stability for the industry.
Merchant Services and Cash Handling
While our preference is to build direct banking relationships, we have also investigated third-party
merchant service providers. Should banking services be temporarily limited, we are prepared to
use a blended approach of third-party platforms and internal cash-handling standard operating
procedures to ensure seamless operations.

To facilitate safe and convenient financial transactions for purchasers, our dispensary will accept
cash and implement a cashless ATM point-of-banking system. From the customer’s perspective,
this functions like a PIN-based debit card transaction. Purchasers enter their PIN, select a
withdrawal amount in five dollar increments, and receive cash change back for any difference.
This system reduces the amount of physical cash required on site, mitigating risks of robbery while
increasing customer convenience.
Path to Profitability
Our financial model anticipates that, with prudent management of expenses and careful inventory
controls, the dispensary will reach its operational break-even point within the first 9 to 12 months
of operations. Thereafter, we expect steady profitability as brand awareness grows, local market
share strengthens, and operational efficiencies are realized.
Pricing Strategy and Considerations
Our pricing strategy is rooted in data, adaptability, and long-term competitiveness. To establish
our initial prices, we collected and analyzed data from the existing Illinois cannabis market as well
as from more mature adult use markets nationwide. This research allowed us to identify which
products are in the highest demand and to anticipate consumer preferences as the Illinois market
continues to evolve. Combined with our detailed financial planning, this ensures that we
understand our break-even points under best-case, worst-case, and most-likely market conditions.
As operations begin, our ongoing pricing decisions will be informed by several factors, including
the cost of purchasing products, changes in market supply, and competitive dynamics. We
anticipate that as more cultivation centers, craft growers, and infusers become licensed in the
future, wholesale prices will decline, particularly for cannabis flower. To prepare for this, our
financial models already account for steadily decreasing retail prices over time. At the same time,
as our customer base grows, we will be able to spread fixed costs across a larger output, allowing
us to preserve healthy margins even as we lower prices in response to market conditions. By
benchmarking against competitors and monitoring local demand, we will ensure that our prices
remain competitive while maintaining profitability.
Affordability and fairness are central to our approach. We recognize that consistent and reasonable
pricing is essential to building trust with our purchasers. To that end, we will continuously monitor
purchase data through our point of sale system, track product demand, and evaluate price elasticity
to understand how customers respond to changes in price. This data-driven approach will allow us
to fine-tune prices in a way that maximizes revenue while keeping our products accessible. We
will also stay ahead of industry trends, responding to evolving consumer preferences for categories
such as concentrates, infused beverages, or wellness-oriented products, and adjust pricing
accordingly to encourage trial and repeat purchases.

Ultimately, our strategy is designed to balance affordability with sustainability. By proactively
adapting to supply-side changes, competitive pressures, and customer demand, we will ensure that
our dispensary remains a trusted and reliable source of cannabis products in Illinois, fostering
loyalty while maintaining strong long-term financial health.
Business Plan Conclusion
This Business Plan demonstrates in detail how we will successfully manage our dispensary on
both a short-term and long-term basis. From revenue generation and cost control to differentiation
from competitors, to unwavering compliance with all state and local regulations, we have built a
strategy designed for resilience, scalability, and community impact. Our diverse product offerings,
comprehensive contingency planning, targeted marketing efforts, and premium customer service
will enable us to attract and retain a loyal purchaser base from across Illinois. We will leverage
our point of sale system to maintain detailed and accurate records of all sales transactions, ensuring
transparency and accountability. Compliance will be led by the Owner, working with the General
Manager to implement a robust compliance plan informed by lessons learned from other highly
regulated industries. Collectively, these measures will allow us to operate a dispensary that is not
only profitable, but also a model for operational excellence in Illinois’ adult use cannabis
marketplace.
Equally important, our business is rooted in values that extend beyond profitability. By aligning
every element of our operations, from hiring and training, to supplier partnerships, to community
reinvestment, with Illinois’ social equity goals, we will create real opportunities for individuals
and communities historically harmed by prohibition. A majority of our staff will be hired from
social equity populations, and we will invest in their success through professional training, living
wages, and career growth opportunities. In doing so, we will not only build a strong team but also
create a workplace culture rooted in equity, trust, and respect.
We believe this mission-driven approach positions our business for lasting success. It maximizes
our ability to deliver measurable, positive impact for the community of Flossmoor and the broader
Illinois market. Ultimately, our dispensary is designed to become more than just a retail location.
It will be a trusted community partner, a driver of economic opportunity, and a leader in advancing
social equity in the cannabis industry. With our experienced team, comprehensive planning, and
deep commitment to responsibility, we are confident that we will leave a lasting and positive
impression on Illinois’ cannabis marketplace.

ACES DISPENSARY
SECURITY PLAN

Security Introduction
Protecting our community, neighborhood, staff, purchasers, facility, and inventory is our
foremost concern in operating a safe and responsible adult use dispensary. Our Security Plan
details the wide-ranging safety and security measures we will implement to prevent unauthorized
access to critical facility areas, minimize opportunity for theft or diversion of cannabis, and ensure
the safety of both employees and purchasers. 410 ILCS 705/15-100(c). We understand that the
security standards contained in the Illinois Compiled Statutes constitute only the minimum
requirements, and we aim to exceed these and any other standards the Illinois Department of
Financial and Professional Regulation (“the Department”) may mandate by rule in order to operate
one of the most secure cannabis facilities in the State of Illinois. 410 ILCS 705/15-100(j). In
addition to state requirements, our facility will also exceed compliance with any applicable local
security ordinances for cannabis dispensaries. 410 ILCS 705/15-100(f).
Protecting a facility that is open to entry by all members of the public aged 21+ presents a
unique security challenge. To address this challenge, we have adopted a multi-layered security
approach based on a “concentric circles of protection” theory. Concentric circles security relies on
multiple, layered barriers to prevent, deter, detect, delay, assess, and respond to threats. Located
at the center of the circles are our cash and cannabis inventory. Each layer of barriers is equipped
with defensive tools that reinforce other layers. For example, intrusion detection alarms on the
facility doors and windows (outer-most layer of security) can trigger a lockdown of the reinforced
vault room where inventory is kept (inner-most layer of security). Policies and procedures
reinforce each barrier and prevent development of human-induced vulnerabilities in physical
security systems. Annual audits of our security technology and monthly system maintenance will
keep our property and surrounding areas continually safe. Additionally, a culture of awareness will
help to foresee and prepare for potential attacks and to enhance tools and procedures after a security
breach. Together, these layers of security will deter and prevent unlawful entry into our dispensary
and theft or diversion of our cannabis inventory or related currency. 410 ILCS 705/15-100(a).
Pursuant to state law, we will submit any changes to our floor plan or to this Security Plan to
the Department for pre-approval. 410 ILCS 705/15-100(b). If the Department finds that any
additional security measures not described in this plan are necessary to protect our facility, staff,
and purchasers, we will diligently work with the Department to implement those measures as
rapidly and efficiently as possible. 410 ILCS 705/15-100(d). Any changes made to the floor plan,
security plan, or any other required submission to the municipality will also be subject to approval
by the municipality. Throughout this plan, any equipment, product, program, or system listed by
name is an example of an item that would meet the need identified, and each such reference should
be read as that item or similar. Our ultimate selection of products will be made during the final
stages of planning and design based on availability and suitability to this facility.
Security Team

Security Contractor(s)
We will contract with a qualified, Illinois-licensed security contractor for the installation and
maintenance of our surveillance and alarm systems, and with a licensed guard services provider
for on-site security personnel, as required by State of Illinois regulation. We will select these
vendors during the final stages of planning and design based on licensure, demonstrated experience
with cannabis facilities, and suitability for this location. Should a contractor cease to meet our
needs or fail to maintain good standing, we will assess and engage a replacement provider.

Security Team
Our dispensary is owned and overseen by a single owner (the “Owner”), who holds ultimate
accountability for compliance with this Security Plan. The majority of our security team will be
supplied through our licensed third party guard services contractor, as required by State of Illinois
regulation. Prior to opening, ownership will hire and designate a General Manager (“GM”) with
demonstrated experience in regulated retail operations, cannabis compliance, or physical security.
The GM will hold responsibility for the day-to-day operational and security functions described
throughout this plan, assisted by designated Agents-in-Charge (“AICs”), who are separately
licensed and who may act in the manager’s capacity whenever the GM is not on site.
Our security team holds responsibility for oversight of the day-to-day goings on at the facility.
Security personnel control and monitor the primary entrance, verify valid government issued
identification and age for every individual seeking entry, observe purchaser and visitor conduct
throughout operating hours, and conduct regular checks of the perimeter and surrounding grounds
to confirm that the area around the dispensary remains safe, free of loitering and visual obstruction,
and clear of any sign of trespass or tampering. Security personnel report any concern immediately
to the GM or a designated AIC.
Security at our facility is not the responsibility of any single individual. Every employee,
regardless of role, will complete our full security training curriculum before beginning work and
will be retrained on any revision to these procedures. That curriculum covers verification of
government issued identification and age at every point of entry, controlled and monitored access
at the facility entrance, limited and restricted access area protocols, recognition and reporting of
suspected diversion, and emergency response. This shared standard ensures that facility security
does not depend on the presence of any one person on any given shift.

Facility Security Features
The first layer of security at our facility begins with the perimeter. We will carefully plan our
exterior landscaping and lighting to maintain the area around the facility in ideal conditions for
video and visual surveillance. Our facility will be “enclosed” and remain locked at all times, with
tinted shatterproof films preventing unlawful entry through windows and our secure primary
entrance serving as the sole point of ingress and egress for visiting purchasers. 410 ILCS 705/1-10
(defining “Enclosed, locked facility”). To control and limit access within the facility, we will

designate areas of the facility as public, limited access areas (“LAAs”), and restricted access areas
(“RAAs”), and utilize locks controlled by an electronic keycard access system that will generate a
traceable record of all access attempts.
Perimeter Security
Video surveillance cameras will operate 24-hours-per-day, 7-days-per-week to record all
activity around the outside of our facility. Exterior cameras will be equipped with day/night autoswitching and infrared capabilities to enable continuous, clear video recording in all lighting
conditions. Exterior lighting will illuminate the perimeter sufficiently to facilitate effective video
surveillance, allow visual surveillance by security personnel, and enable employees and visitors to
safely navigate the area after sunset or before sunrise. 410 ILCS 705/15-100(c)(13). When making
decisions regarding lighting, such as types of lights, positioning, or brightness, we will consult
with local ordinances, neighbors, and surrounding businesses to ensure that the lighting will not
create a nuisance for our community. Our facility will be surrounded by exterior pole-mounted
and building-mounted lighting sufficient to illuminate the on-site parking area and all approaches
to the building, supplemented by existing street lighting on the adjacent public ways. We will
confirm final fixture type, placement, and light levels against the code of the municipality in which
the dispensary is located during the design phase.
Our security personnel will regularly patrol the perimeter of the facility to identify signs of
intrusion and to confirm that all perimeter security equipment is in good condition and functioning
properly. We will keep the immediate area surrounding the facility clean and clear of visual
obstructions, including bushes and trees. Keeping this area clear will allow for effective visual and
video surveillance, while also preventing intruders from using terrain and vegetation for
concealment. 410 ILCS 705/15-100(c)(14).
We will keep in mind security considerations throughout the construction/remodeling of our
facility. Windows and doors will be kept to a minimum number necessary for safe and efficient
facility operations. At a minimum, we will reinforce all windows with shatterproof security films
to limit visibility from the outside and prevent unlawful entry. 410 ILCS 705/15-100(h)(1)(ii). All
dispensing activities will occur indoors in access-controlled interior facility areas protected by
locked keycard access doors, and accessible only to authorized employees.
To enhance the safety of employees and visitors, our facility will feature on-site parking. Onsite parking will limit the safety and security risks created for visitors. On-site parking will make
it easier for purchasers with decreased mobility to move from their vehicles to the facility,
minimizing opportunities for injury, and will also keep all vehicles contained within the secured
facility perimeter, where they will be under constant video surveillance and visual observation by
security personnel.
All purchasers and other visitors will enter the facility through the designated primary entrance,
which we will clearly mark with signage to facilitate easy identification by visitors. The primary
entrance will be accessible through a security door of solid construction with internal hinges to
prevent tampering and a keycard access lock. All door locks will be remotely controllable from
inside the facility, enabling the reception employee to safely isolate and contain any potential
threats.

All employees will enter the facility via the designated employee entrance at the rear of the
dispensary, using their employee keycard to unlock the door and log their arrival at the facility.
This will create a readily accessible record of facility entry through electronically logged keycard
data and video surveillance. Employee keycards will be configured to limit access to other
entrances, further controlling movement of personnel around and within the facility.
We will also accept deliveries through our rear entrance, which enters into an RAA, and we
will never accept deliveries through the public entrance or LAA, unless explicitly permitted by the
Department. 410 ILCS 705/15-70(f). More information on our plans for receiving product
deliveries is included below.
Access Controls
Controlling access within the facility is vital to limiting opportunities for theft and diversion.
With all areas of the facility, regardless of classification, we will restrict access to individuals with
a legitimate purpose, such as employees fulfilling employment duties or purchasers making a
purchase, and will require all individuals to exit the dispensary once their business is complete.
410 ILCS 705/15-100(c)(2). To limit the number of individuals in the facility at any given time,
we have constructed procedures establishing maximum capacity for the waiting area and the sales
area, as well as limiting purchaser flow from the waiting area into the sales area based on the
number of sales associates available in the sales area. 410 ILCS 705/15-100(c)(3). Maximum
capacity in our waiting room is determined by purchaser comfort, Americans with Disabilities Act
(“ADA”) guidelines, the Illinois Environmental Barriers Act (“EBA”), and local building and fire
codes. Because we value a positive customer experience and want to closely monitor purchasers
in the LAA, we will allow only five purchasers to enter the sales floor for each sales associate in
the sales area.
Public Areas
The only areas of the facility that the public (non-purchasers) will be permitted to access are
the on-site parking areas, the lobby/waiting area, and, where the facility layout places a restroom
in the public area forward of the primary security door, that restroom. All other restrooms are
located at the rear of the facility within restricted access areas and are not accessible to purchasers
or other members of the public. These public access areas will be patrolled by a security guard,
ensuring that all areas of the facility are guarded during operating hours and easily reached by at
least one guard in mere moments. All other areas will be off limits to the public. Even in public
areas, security personnel will prohibit loitering and will require that all individuals in the area have
a legitimate purpose for being there, such as waiting for purchasers they are accompanying to
complete their visit or picking up/dropping off an employee. Even in public areas, security
personnel will prohibit minors under the age of 21 from entering or remaining in the dispensary,
and we will post signage on the exterior of the facility identifying that persons under 21 years of
age are not permitted on premises even in the waiting area. 410 ILCS 705/15-65(i)(1). We will
operate as an adult use dispensing organization and will not hold a medical cannabis dispensing
license at the time of licensure, and we will therefore not permit minor qualifying patients to enter
our facility. Should we subsequently obtain a medical cannabis dispensing license from the State
of Illinois and secure all required approvals from the municipality in which the dispensary is
located, we will serve qualifying patients and registered caregivers at that time, and we will submit

any resulting amendments to this Security Plan and our floor plan to the Department for preapproval.
Limited Access Areas
We will designate certain semi-public areas of the facility as LAAs. The LAA is a room, or
other area under the control of our dispensing organization, with access limited to purchasers, our
licensed owners and agents, or service professionals conducting business with the dispensing
organization. 410 ILCS 705/1-10. LAAs will be areas that require access by facility staff and
purchasers, such as the retail sales area. We will limit access to the sales area to dispensary
employees and purchasers who have provided valid government-issued identification
demonstrating they are age 21+.
All LAAs will remain securely locked using UL-listed commercial-grade, non-residential door
locks or electronic keycard access locks, maintaining a secure barrier between the facility entrance
and LAAs. 410 ILCS 705/15-100(c)(1). A solid wall with a keycard access-controlled door will
isolate our public waiting area/lobby from the LAA retail sales area.
Restricted Access Areas
We will classify all areas containing cannabis, cannabis infused products, cannabis waste, or
surveillance equipment or records as RAAs and identify them as such on our floor plan. 410 ILCS
705/15-100(g)(2). Importantly, we will designate and clearly mark the portion of the retail sales
area located behind the sales counter as an RAA and will only dispense cannabis from this RAA,
as required by law. 410 ILCS 705/15-100(c)(5). The sales counter will serve as a barrier between
the public access area and LAA, which will be a solid barrier that prevents an individual from
easily accessing the RAA. All counters separating the LAA from RAAs will be at least 48” in
height, except that spans of counters up to 36” in width (such as our ADA-accessible counter) may
be reduced to 36” in height. See IDFPR FAQs, published November 1, 2019.
In accordance with Drug Enforcement Administration (“DEA”) guidelines for facilities
containing controlled substances, we will limit access to RAAs to the minimum number of
personnel essential to facility operations. RAAs within the dispensary will be closed to the general
public and purchasers. Any visitors must have a legitimate purpose for their visit, such as
maintenance contractors or business guests, will be required to inform us of their intended
visitation time and date in advance, and will only be allowed to access areas related to their visit.
Visitors will be admitted only according to our visitor protocols, as described in this plan.
Authorized dispensary employees, authorized Department personnel, and any individuals
accompanying authorized Department personnel will be permitted to access RAAs without prior
notice and without regard to our Visitor Protocols. Management will provide on-duty law
enforcement, fire personnel, or emergency medical service professionals with unhindered access
to all RAAs in the event of an emergency requiring immediate action, including security threats,
fires, and medical emergencies.
To prevent unauthorized access from public areas and LAAs, RAAs will feature electronic
keycard locks with individualized access privileges for each employee. 410 ILCS 705/15100(g)(3). We will clearly identify entrances to RAAs with a minimum 12”x12” sign with at least

1” high font stating: “Do Not Enter – Restricted Access Area – Authorized Staff Only.” 410 ILCS
705/15-100(g)(1).
All dispensary employees will have access to all RAAs except for the reinforced vault room,
manager’s office, and security closet. Keycard locks with individualized access privileges will
restrict access to these three areas to authorized employees only, which may include the Owner,
the General Manager, and designated AICs. Prior to employees beginning work at the dispensary,
management will explain to employees that these three areas are off-limits without a higher
clearance, as well as the penalties for unauthorized entrance attempts. Management will investigate
any unauthorized access or access attempts and deal with them according to the procedures detailed
in this Security Plan. Penalties for unauthorized access may include immediate suspension of all
facility access privileges, termination of employment, and reporting of the employee to the
Department and state and local law enforcement.
Locks and Keycards
We will securely lock all dispensary doors, windows, and points of entry. All traditional facility
locks will be UL-listed commercial grade, nonresidential door locks with burglary resistant lock
cylinders designed to prevent lock-picking. We will institute strict policies prohibiting keys from
being left in locks, doors to LAAs and RAAs being left open, and keys or keycards being left in
areas where they could be accessible to unauthorized persons. 410 ILCS 705/15-100(c)(11). All
doors will be self-closing and self-locking. Certain doors may feature multi-point locking systems
that include bolts and mechanics that secure each door at multiple points around the door frame to
prevent doors from being pried open.
We will install electronic door locks and an electronic keycard-based controlled access system
to limit access to RAAs to authorized employees only. 410 ILCS 705/15-100(h)(1)(v). We will use
iCLASS SE Readers (or similar) for our keycard readers, along with ND Series Electrified
Cylindrical Locks and HES 5000 Electric Strikes (or similar) to limit access to RAAs.
Each employee will receive keycard access privileges limited to areas that they require access
to for their job purposes. Access to the manager’s officer and the reinforced vault room, where we
will store backstock cannabis inventory, will be restricted to management employees and above.
Access to the security closet will be limited to personnel essential for security operations. Keycards
will be linked to each individual employee and keycard readers will maintain a record of all
activities, including the date and time of entry and exit, the name of the individual, and any other
information that may be required by the Department by rule. Management will retain keycard
access records electronically on a server in our security closet for a period of at least three (3) years
and will be make these records available to the Department upon request. 410 ILCS 705/15110(a)(3). The accuracy of access records can be verified by our surveillance cameras, which will
record the individual entering the restricted area and the time of entrance in the event a keycard
was stolen or used under duress.
An online web portal will facilitate remote administration of access privileges and manual
lockdown of certain areas. Our Owner and General Manager will use this portal to deactivate any
lost or stolen keycards, or any keycards of facility personnel who are under investigation or have
had their employment suspended or terminated. In the event of a security threat, the remote access

system may be manually accessed to lockdown certain areas of the facility. The system will be
configured to automatically lockdown all RAAs in the event of a holdup, duress, or intrusion alarm.
In order to remain operational, all electronic and magnetic locks will not solely be controlled
by an electronic access panel and will additionally be connected to a backup uninterruptible power
supply capable of powering all facility locks for a period of at least four hours in the event of a
power failure. 410 ILCS 705/15-100(h)(6), (i)(7). Management and security staff will conduct
monthly inspections of all facility locks, including both traditional key locks and keycard locks, to
ensure all locks are in good condition and functioning properly, and will schedule or perform
necessary maintenance immediately to prevent lapses in security. 410 ILCS 705/15-100(c)(9).
Security Equipment
We will secure our facility with a state-of-the-art video surveillance system (“VSS”) and
intrusion detection alarm system. Our VSS will maintain constant video recording of all activities
at the facility, providing high-quality images suitable for facial recognition of all persons entering
and leaving the dispensary. If our VSS is ever inoperative, we will temporarily close our dispensary
and cease all operations until the equipment is repaired. 410 ILCS 705/15-70(n)(11). Alarm
systems will secure our dispensary against unauthorized access 24-hours-per-day, 7-days-perweek. Regular maintenance, inspections, and backup power systems will ensure that all security
equipment remains in good condition and operational without interruption. All equipment in this
plan listed by name remains an example of a product that would meet the need of this security
plan, as described in our Security Introduction.
Video Surveillance
Our VSS will provide constant monitoring of our entire dispensary. We will outfit the facility
premises with a VSS that consists of: high-definition video surveillance cameras; video monitors
for viewing of live surveillance footage and recordings; digital archiving devices, including a
VIVOTEK NR9681 Network Video Recorder (or similar); and, an imagePROGRAF PRO-1000
color printer (or similar) capable of generating still photos. Our surveillance systems will remain
in operation year-round—24 hours a day, 7 days a week.
Continuously operating surveillance cameras will cover all interior and exterior areas of the
property; installers will carefully angle cameras to provide an unobstructed view for clear and
certain facial recognition for identification of anyone entering or exiting the dispensary, and we
will install lighting sufficient to allow surveillance of interior and exterior areas of the property at
all times of night or day. 410 ILCS 705/15-100(i)(2), (3). To this end, surveillance cameras will
capture all activity occurring within 20 feet of all points of entry and exit. We will strategically
locate interior and exterior lighting to optimize lighting for surveillance. 410 ILCS 705/15100(c)(13). Security personnel will conduct regular verifications of lighting equipment to keep
interior and exterior lighting in good working order and to make sure that wattage is sufficient for
security cameras. 410 ILCS 705/15-70(k). During installation, we will calibrate and focus cameras
to maximize quality of recorded images.
Camera Features

Our VSS will provide a 24-hour live feed with motion-activated capabilities from all cameras.
Cameras will provide motion video and clear, color, still photo-generation from any live footage
or surveillance recording. 410 ILCS 705/15-100(i)(5). Our VSS will also provide direct feed and
login capabilities to the Department for real-time access/monitoring and reverse functionality via
a secure internet connection. 410 ILCS 705/15-100(i)(12).
We will use the following (or similar) cameras:
•
•
•
•

VIVOTEK FD8169A Fixed Dome: 2 MP, 30 fps @ 1920x1080, H.264, MJPEG
VIVOTEK FD8377-HTV and EHTV Fixed Dome: 4 MP, 30 fps @ 2688x1520, IP66
VIVOTEK CC9381-HV 180-degree Panoramic: 5 MP, 30 fps, 3DNR, 15m IR, IP66
VIVOTEK FE9182-H and FE9382-EHV Fisheye: 5 MP, 360-degree surround view, 20m
IT, IP66, and H.265

Cameras will be capable of recording at a minimum resolution of 600 lines per inch (analog)
or D1 (720 x 480) (IP) and a minimum light factor of 0.7 LUX. All electronic video surveillance
monitoring will record at least the equivalent of 8 frames per second and will be available as
recordings to the Department and the Department of State Police 24 hours a day via a secure webbased portal with reverse functionality. 410 ILCS 705/15-100(i)(12).
Surveillance cameras will also interface with our facility intrusion detection alarm system to
show live or recorded video automatically based on an alarm trigger and switch any camera in the
system to any monitor in the system automatically based on an alarm trigger.
Camera Locations
Installers will permanently mount cameras in fixed locations throughout the dispensary. We
will install all cameras in such a way that cameras’ lenses will not be obstructed or easily tampered
with or disabled, such as by placing cameras high enough to be out of reach without a ladder.
Cameras will produce recordings with sufficient resolution to facilitate clear and certain facial
recognition for all individuals entering the following areas, as well the license plates of vehicles
in the parking lot (410 ILCS 705/15-100(i)(2), (3)):
•
•
•
•
•
•
•

The exterior surrounding the dispensary storefront;
The dispensary parking lot;
All points of entry and exit, including the primary entrance;
The entrance to the reinforced vault room from inside and outside;
All safes, including the cash safe within the reinforced vault room;
The retail sales area, including all point of sale locations and cash registers; and,
All other areas where cannabis is stored, handled, dispensed, or destroyed.

Staff will verify camera coverage by walking through the facility while carrying an empty box.
If at any point the box, or the individual carrying, it is not visible on any surveillance camera, the
GM will address this deficiency by adjusting or relocating cameras, or by contracting for
installation of additional cameras. For all cameras aimed at point of sale stations, the GM will

carefully finetune the positioning of the cameras to capture the dispensing agent, the purchaser,
the sale itself, and the computer monitors used for the sale. 410 ILCS 705/15-100(i)(10).
Surveillance Recordings
The heart of our VSS will be our VIVOTEK NR9681 Network Video Recorder (or similar),
which features H.265 video coding, 64 channels, Dual LAN, local display capabilities, and 80TB
of storage space. Seagate Skyhawk hard drives (or similar) will provide additional storage
capabilities.
The VSS will be able to export still images in industry-standard formats and save exported
video in an industry-standard format that can be played on a standard computer operating system.
410 ILCS 705/15-100(i)(5). Our surveillance system will allow footage to be exported in formats
including .mpeg, .jpg, .bmp, and .gif, with at least 1280x720 resolution or greater and a frame rate
of 8 FPS or greater. 410 ILCS 705/15-100(i)(8), (12). Surveillance footage will also be exportable
in a proprietary format, ensuring authentication of footage and that no alteration of footage has
occurred. 410 ILCS 705/15-100(i)(8). Recordings will include an embedded visual date and time
stamp, which will be synchronized with the National Institute of Standards and Technology and
placed so as not to significantly obscure the picture. 410 ILCS 705/15-100(i)(6).
The surveillance system will display a live view from the video server to Samsung S32D850T
Business Monitors (or similar) contained in the security closet. All monitors will be at least 32
inches or greater. 410 ILCS 705/15-100(i)(1). Monitors will also be capable of at least 2560x1440p
resolution. Upon recognition of an alarm, the system will be able to switch and display views from
any camera that is associated with the alarm point. Camera feeds will traverse the IP network from
the camera source to the server utilizing Motion JPEG (MJPEG) or MPEG-4/H.264/Advanced
Video Coding codec technology. In event of a failure of the VSS, monitors will provide security
staff with an audible and visual notification of the failure. 410 ILCS 705/15-100(i)(11). Further
information on failure of security systems is addressed below.
We will secure VSS equipment and recordings in a locked security closet to protect security
recordings from theft, loss, destruction, corruption, or alterations. 410 ILCS 705/15-100(h)(2). The
security closet will be located within an RAA, with access limited to persons who are essential to
surveillance operations, law enforcement, security system service personnel, and the Department.
410 ILCS 705/15-100(h)(3). Within the security closet, we will securely locate our video storage
servers in a lockable RackSolutions Model 151 Server Cabinet Enclosure (or similar) for added
security. Our GM will maintain a current list of all authorized dispensing organization agents and
service personnel with access to surveillance equipment and will make this list available to the
Department upon request. 410 ILCS 705/15-100(h)(3). Our security software will log all access of
surveillance records automatically. The Department will have full access to our VSS, and our
recordings will be accessible through a secure internet portal or from computers at our dispensary,
making them easy to obtain upon request. 410 ILCS 705/15-100(i)(4).
We will keep all surveillance recordings for a minimum of 90 days. 410 ILCS 705/15-100(i)(4).
If we become aware of any loss or theft of cannabis, or are notified of any pending criminal, civil,
or administrative investigation, or other legal proceeding for which surveillance recordings may
contain relevant information, we will preserve our recordings indefinitely until we receive

notification from the Department that we may dispose of the recordings. 410 ILCS 705/15100(i)(4). To comply with Department regulations, our security staff will erase or destroy
recordings after completion of the retention period and prior to disposal. 410 ILCS 705/15100(i)(8). The VSS will log erased recordings (time, date, and responsible staff) prior to disposal
to prevent fraud or the creation of copies of sensitive materials. 410 ILCS 705/15-100(i)(4).
Alarm System
We will outfit our building with intrusion detection technology, including a commercial-grade
professionally monitored security alarm system installed by an Illinois-licensed private alarm
contractor agency. 410 ILCS 705/15-100(h)(1).
We will configure our intrusion alarm to directly or indirectly notify, by the most efficient
means available, the Public Safety Answering Point for the law enforcement agency having
primary jurisdiction in the area where our dispensary is located. 410 ILCS 705/15-100(h)(1)(iv).
Upon request, we will make available to the Department all information related to the alarm
system, monitoring, and alarm activity.
Various alarm devices, including motion sensors, glass break sensors, and door contacts, will
secure our dispensary. To ensure that the facility will be kept secure in event of a system failure,
we will utilize an electrical support backup system. If power to the primary alarm is compromised,
the backup system will take over to guarantee that the facility remains protected. These systems
will maintain operation of our security alarm system and all devices 24-hours-per-day, 7-days-perweek, including during any unexpected power outages. 410 ILCS 705/15-100(c)(10).
Alarm Types
Our alarm systems will feature multiple different types of alarms for use under different
emergency circumstances, including a duress/holdup alarm and a panic alarm. 410 ILCS 705/15100(h)(1)(iv). The alarm systems will be connected to the facility fire detection system to facilitate
warnings for any emergencies. All audible alarms will feature different and distinct alert sounds
for each alarm type, and management will train employees on how to handle each alarm.
Duress alarms will be a silent alarm generated by manual activation of a device to signal that
an employee is in danger and requires immediate law enforcement response. We will install duress
alarms inconspicuously throughout the facility, such that employees can activate them without
alerting a potentially hostile intruder that they are doing so. Our duress alarms will use United
Security Products HUB Series Hold Up Buttons (or similar), which are UL listed, feature an
impact-resistant housing, and have a 10+ year battery life.
Panic alarms will be an audible alarm generated by manual activation of a device to signal an
emergency requiring law enforcement response. We will install panic alarms inconspicuously (but
easily accessed by employees) throughout the interior and exterior of the facility, such that
employees can activate them and generate an immediate audible alarm throughout the facility. We
will use AVTECH Panic Buttons (or similar), which feature large red and orange buttons
connected to speakers for an audible alarm.
Alarm Features

Our alarm technology will provide UL-listed full premises burglary protection with a dualpath communication system: a continuously polled IP off-premises connection and a backup
cellular transmitter if IP should fail. These systems will provide continuous monitoring of facility
entry points and all RAAs and LAAs, utilizing alarm contacts on all points of entry and glass break
protection on all windows. 410 ILCS 705/15-100(h)(1)(i). Alarms will generate distinct alert
sounds for each alarm or alarm type, allowing staff to easily distinguish between alarms.
Monitoring systems will feature an administration option that requires an AIC or a manager to
enter a response to an alarm before allowing them to clear it from the alarm view window, ensuring
that all alarm activations are properly addressed, and any response measures are documented.
We will use a Honeywell VISTA-21iP Control Panel (or similar) as our alarm panel to integrate
intrusion detection, video surveillance, and access control functions, providing a fully-integrated
security solution for our dispensary. Throughout the facility, Honeywell 6160 Alpha Display
Keypads (or similar) will allow for alarm system control. Alarms will interact with the VSS to
provide live video from each camera associated with an alarm. They will also interact with the
keycard system by: notifying security personnel when doors to LAAs or RAAs have been left
open; displaying when staff use a keycard to open a door or if a keycard was used but the door was
not opened; and, providing a “watch” function that allows normal access control, but will highlight
the access-grant event at the system monitor for keycards specifically configured to be watched
(e.g., for an employee under suspicion).
Alarm Coverage
Alarms will provide full coverage of our facility to detect any unauthorized entry attempt.
Intrusion sensors will include: Honeywell 968XTP High Security Switches (door/gate
pressure/contact switches) (or similar) on all entry points (a perimeter alarm), which use balanced
magnetic contacts and internal circuitry with surge protection to prevent defeat; Fire Burglary
Instruments 2200 & 2100 Glass Break Detectors (or similar) on all windows, which detect acoustic
shockwaves caused by breakage, even through curtains, drapes, and blinds; Honeywell IS3000
DT8000 Series Wiredpir and Dual Tec Motion Detectors (or similar) throughout the facility using
passive infrared, with adjustable sensitivity and wall-to-wall coverage; heat/smoke detectors; and,
environmental sensors. 410 ILCS 705/15-100(h)(1)(i). These systems will provide complete
coverage of our facility, including:
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•
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•
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All entrances and exits (410 ILCS 705/15-100(h)(1)(i));
Rooms with exterior windows;
Rooms with exterior walls;
Roof hatches;
Skylights;
The cash safe; and,
Storage rooms, including the reinforced vault room and any cabinets or safes used to
store cannabis.

Failure Prevention
Regular maintenance, testing, and inspections will prevent deterioration or failure of our
alarms, VSS, and keycard access control systems. 410 ILCS 705/15-100(c)(9). In the event of a

loss of connection to the electrical grid or any other failure in the alarm or VSS, an automatic
failure notification system will immediately notify the Owner, the GM, and other designated
dispensing organization agents via an audible, text, or visual notification within five minutes of
the failure. 410 ILCS 705/15-100(h)(1)(iii), (i)(11). An uninterruptible power supply battery
backup will provide emergency backup power for at least four hours in event of a facility power
failure, allowing all security systems, including cameras and video surveillance system, to remain
operational and preventing any facility locks from being automatically released. 410 ILCS 705/15100(i)(7), (9).
To guarantee that all facility security systems are properly installed, we will contract with
reputable, qualified, and licensed vendors to install all keycard access controls, alarms, and VSS.
Qualified technicians and our GM will conduct maintenance, testing, and inspections of all security
equipment, including the VSS and alarms, no more than one month from the previous inspection
to ensure all security systems remain functional. 410 ILCS 705/15-100(h)(4). We will maintain
security documentation in an auditable physical or electronic form in a locked cabinet in the
security closet or on a server located in the security closet. Documentation contents will include
all security maintenance inspections and tests conducted, as well as any servicing, modification,
or upgrades performed on the security alarm system or surveillance cameras.
Alarm Maintenance
Our Owner and GM will create protocols for testing and maintenance of security alarm
systems, including dates for regularly scheduled maintenance and inspections. Our GM or a
designated AIC will conduct tests of all alarms at least every 30 days and will contract a qualified,
Illinois-licensed alarm vendor, for annual comprehensive inspections of the facility alarm system.
If any defects are present in testing and inspections, the GM will immediately schedule
maintenance and implement additional safeguards to prevent any lapses in security, as well as
alerting law enforcement. The GM will maintain results of all security system tests and inspections
electronically on a protected server in the security closet or off-site for as long as our facility
remains in operation. We will also maintain documentation in an auditable form for all
maintenance inspections and tests, and any servicing, modification, or upgrades performed on the
security alarm system.
VSS Maintenance
The GM, designated AICs, and security personnel will maintain the VSS system daily to
identify any camera failures or other potential issues. 410 ILCS 705/15-100(h)(2). Maintenance
will include daily checking of the surveillance feeds from all cameras using a monitor in the
security closet and weekly visual inspections of all facility surveillance cameras for signs of wear
and tear, misalignment or tampering, or other potential failure points. The GM, designated AICs,
and security personnel will identify and electronically record any abnormalities. They will report
abnormalities immediately to the GM and the Owner, who will schedule maintenance and repairs
within 24 hours of receiving the report. The GM will maintain an electronic record of any
abnormalities identified in their monitoring activities. A qualified contracted vendor will conduct
an annual inspection of all facility surveillance systems to identify and repair any undiscovered or
emerging issues. We will maintain a record of any repair or replacement of components of the
VSS, including the nature of the issue, time and date of the failure, the time and date of the repair,

and the identity of the technician who conducted the repair. We will retain surveillance system
inspection and repair records electronically on a protected server in the security closet or off-site
for at least three (3) years. 410 ILCS 705/15-110(a)(3).
Cannabis Storage
Pursuant to state law, we will store all of our cannabis inventory on-site at our dispensary in
RAAs. 410 ILCS 705/15-80(a). We will not store any cannabis at our dispensary during initial
construction/renovations. If further renovations are necessary once our dispensary becomes
operational, we will securely store all cannabis inventory in the reinforced vault room, which is an
RAA, to prevent theft or diversion during the renovations. 410 ILCS 705/15-100(b).
Retail Employee Area
For display, purchaser education, and daily sales purposes, we will maintain a limited quantity
of cannabis inventory behind the counter (the “retail employee area,” an RAA) within the retail
sales area (an LAA) during our hours of operation. Staff will keep this cannabis in locked display
cabinets or other secure containers accessible only to authorized employees from behind the sales
counter. 410 ILCS 705/15-100(c)(5). We will designate the area behind the sales counter as an
RAA and post signage identifying it as such. Only employees will be permitted behind the sales
counter; at no time will any purchasers be permitted behind the sales counter for any reason. At
the beginning of each business day and throughout the day as needed, an AIC will retrieve cannabis
from the reinforced vault room to replenish depleted sales area inventory. At closing time, an AIC
will transfer all cannabis in the sales area onto a rolling cart, which the AIC will then secure in the
reinforced vault room for overnight storage. 410 ILCS 705/15-100(c)(6).
Reinforced Vault Room
We will store the bulk of our cannabis inventory in our secure reinforced vault room, which
will be an RAA off-limits to purchasers and accessible only by authorized dispensary staff
members. 410 ILCS 705/15-100(c)(6). During open hours, we will keep cannabis back-stock
inventory securely stored in the vault. During closed hours, we will securely store all of our
cannabis inventory (active- and back-stock) in the vault. The vault room will contain organized
product storage areas (shelves, containers, etc.), a product refrigerator, our cash safe, and our
cannabis waste and recall/quarantine area.
The vault room will be centrally located within the facility and will not be adjacent to any
exterior walls. We will construct the vault room to comply with DEA storage requirements in 21
C.F.R. § 1301.72 for Schedule I controlled substances, including: walls, floors, and ceilings
constructed on at least 8 inches of reinforced concrete or other substantial masonry, reinforced
horizontally and vertically with steel rods; and, a door and frame rated for 30 man-minutes against
surreptitious entry, 10 man-minutes against forced entry, 20 man-hours against lock manipulation,
and 20 man-hours against radiological techniques. 21 C.F.R. § 1301.72(a)(3).
We anticipate using a Roland Ultra-Security Modular Vault System (or similar), which features
an ultra-high strength concrete core with formed steel panels. For the vault door, we anticipate
using a Roland Ultra-Security Vault Door (international TL-30 BL) (or similar), which includes
1.5” diameter, high tensile steel bolts, a 2-hour fire rating, steel matrix construction, built-in alarm

contacts, and a 37x80” clear vestibule opening. The vault door will be UL Listed Class 1
(minimum) with at least a one-half hour burglary rating, and will feature an ADA-compliant
lockable day-gate.
The vault room will remain locked unless access is required, and if needed, a self-closing and
self-locking day-gate will offer easier access during operating hours, while keeping the vault room
secured against unauthorized entry. 21 C.F.R. § 1301.72(a)(3)(iii). During times when staff require
repeated access to the vault, the day-gate will allow staff to leave the main vault room door open
and use the day-gate for easier access, while still preventing unauthorized entry. The day-gate will
remain locked at all times except for the actual time necessary for staff to access stored inventory.
Electronic keycard access locks will keep the reinforced vault room securely locked at all times
that the vault room door is closed. 410 ILCS 705/15-100(c)(7). We will train all employees with
vault room access privileges to always keep the vault room door or day-gate closed. The GM will
maintain a list of all employees with vault room access privileges, and our keycard-based access
control system will prevent unauthorized entry into the vault room and log every access or
attempted access, including the date and time of entry and exit, and the name of the individual.
410 ILCS 705/15-100(c)(8). If maintenance personnel, business guests, or other visitors require
access to storage areas, they will be required to be accompanied by an AIC with vault room access.
We will maintain a written record of any such access, including the identity and purpose of the
visitor and the identity of the accompanying AIC. 21 C.F.R. § 1301.72(d).
The interior and exterior of the vault room will be under constant video surveillance from
multiple angles. Contact switches on the vault room door will trigger an alarm condition in event
of unauthorized entry and will alert management whenever the vault door or day-gate is opened.
21 C.F.R. § 1301.72(a)(3)(v). Manual alarm activation buttons will be located inside and outside
of the vault to allow staff to activate a holdup alarm in event of a robbery. Any alarm activation
will trigger an automatic notification system, which will alert management and local or state law
enforcement of a breach of security or a power failure. To combat drilling, the interior of the vault
room will feature a sound detection alarm system that will trigger an alarm condition if noise is
detected inside the vault room. The vault room door will also be equipped with heat sensors to
detect any attempted intrusion using plasma cutters, thermal lances, or acetylene torches. 21 C.F.R.
§ 1301.72(a)(3)(vi). The vault room will also feature adequate lighting and temperature controls
to preserve our cannabis inventory, including ventilation, temperature, and humidity controls. 410
ILCS 705/15-80(c).
We will not be sharing vault space with any other licensed cannabis organization. If this
changes in the future, we will inform the Department and maintain compliance with all
requirements for shared storage under the Illinois Compiled Statutes and any rules promulgated
by the Department. Compliance measures will include separate vault rooms for each licensee,
unless each licensee using the vault room shares at least 50% ownership. 410 ILCS 705/15-100(e).
Storage of Cannabis Waste and Recalled Products
We will store cannabis waste awaiting disposal and recalled, defective, and unsellable products
in a designated area within the reinforced vault room. 410 ILCS 705/15-100(c)(4). Once identified,
we will clearly mark waste and unusable products, place them in the pre-determined area for this

type of inventory, and make them clearly distinguishable from sellable products to ensure that
defective products will never be returned to regular inventory or dispensed to purchasers. We will
wrap defective products in yellow tape and utilize brightly colored sticker alerts that clearly read
in bold lettering: “QUARANTINED - NOT FOR SALE,” or a similar warning clearly identifying
the product’s status (e.g., “Returned Product” or “Recalled Product”) and ineligibility for sale.
Diversion and Theft Prevention Procedures
We will compile and implement unauthorized access response, inventory, investigative, and
employment procedures to prevent diversion or theft of our cannabis. Security of RAAs and LAAs
is a major operational concern, and detailed procedures for responding to security breaches or
unauthorized accesses of these areas are a vital part of our plan to prevent diversion or theft of
cannabis inventory or currency. We have constructed comprehensive procedures for conducting
inventories, investigating diversion, and reporting security incidents to the Department and local
law enforcement. We will maintain good relationships and open lines of communication with the
Department and local law enforcement, ensuring that we will abide by all Department rules
regarding communication and incident reporting.
Hiring and training trustworthy employees while maintaining effective surveillance and
oversight to identify and preempt potential diversion is essential to preventing diversion and theft.
We will implement a zero-tolerance policy towards diversion of cannabis or unlawful use of
cannabis products. Before beginning work, management will thoroughly train all employees on
this policy and all anti-diversion procedures, including inventory audits and mandatory bag checks
by a manager or security guard prior to exiting the facility.
Unauthorized Access of RAAs or LAAs
To ensure effective response to any security breaches, we have constructed response policies
for unauthorized accesses of RAAs and LAAs. In the event of an unauthorized access of an RAA
or LAA, management will immediately begin an investigation into the security breach. Our GM
will notify the Department within 24 hours of any breach of security or criminal activity. If
diversion is suspected to have occurred, we will immediately commence an investigation pursuant
to the “Diversion Investigations” protocols in this Security Plan.
If an employee without authorization attempts to access the vault room, manager’s office, or
security closet, our keycard access system will log the access attempt, and a member of
management will begin an investigation (e.g., watching surveillance footage and interviewing the
employee and witnesses) to identify why the employee attempted to access the area, if the attempt
was successful, and if any diversion has occurred. If the access attempt was accidental, a manager
will re-train the employee on access privileges to ensure that no further mistakes occur. If
investigation reveals that the access attempt was intentional, we will immediately terminate the
employee and report them to the Department and applicable law enforcement.
We will also implement policies for investigation of suspected misconduct by management. If
a manager is suspected of accessing an RAA or LAA without a valid purpose or without
authorization, the Owner will immediately initiate an investigation to determine the manager’s
motivations and whether any diversion has occurred.

During an investigation into an employee or manager’s unauthorized access, we will suspend
the employee or manager’s keycard access privileges and will instruct them not to return to the
dispensary without express permission until the investigation is concluded.
If a visitor attempts to access any area of the facility for which they do not have access or
attempts to access any area of the facility without an employee escort, the visitor will be
immediately escorted out of the facility. If the visitor refuses to leave, we will immediately contact
local law enforcement to remove the individual and will report the incident to the Department.
Following removal of any visitor, a member of our security team will consult the Visitor Log to
identify the visitor and add their name to our No Entry/Do-Not-Serve list and company security
records to prevent them from being allowed to enter the dispensary in the future. We will notify
the Department of all visitor-related incidents and will provide the identity and purported purpose
of the visitor. We will also notify law enforcement if necessary.
We will immediately report to the Department and local law enforcement any trespassing on
our property or unlawful entry into our dispensary. If a trespasser manages to enter the facility,
employees will avoid the individual and shelter-in-place by remaining where they are, locking any
entrances, activating the silent alarm, and contacting 911. In event of an armed robbery, employees
will follow the procedures outlined in this Security Plan. Management will conduct a
diversion/theft investigation after any facility interior trespassing event to determine how the
unauthorized individual gained access to the facility and whether any diversion or theft has
occurred.
Inventories
We will use our electronic point-of-sale system (“POS”) to ensure accountability of all
inventory and traceability of all employee actions by logging all employee interactions with
cannabis inventory. Management will supervise employee interactions with cannabis inventory
and will regularly access the POS to confirm that all interactions are being properly logged.
Inventory data will include details on each sales transaction recorded at the time of sale, and each
day’s beginning inventory, acquisitions, sales, disposals, and ending inventory. 410 ILCS 705/1575(b)(1).
An AIC will conduct daily inventory audits and reconciliations of inventory to identify
discrepancies and possible internal diversion. 410 ILCS 705/15-75(d). These audits will include
complete daily inventories within the vault room and in the retail employee area of all cannabis
and cannabis infused products at our dispensary. The AIC conducting the audit will document all
inventories, including: date; detailed inventory results; name, signature, and title of individuals
who performed the inventory; and, an attestation by the AIC, who led the inventory, certifying the
accuracy of the inventory. An AIC will immediately report any discrepancies or suspected
diversion to the GM, who will begin an investigation in accordance with the “Diversion
Investigations” protocols below and notify the Department and law enforcement as necessary.
Diversion Investigations
To prevent our cannabis inventory from entering the grey market through diversion, we will
implement comprehensive investigation and reporting protocols for suspected diversion. Any

discrepancy in weekly inventories, abnormality in random inventory audits, reporting by
employees of suspicious activity, or any security breach or unauthorized access of an RAA will
trigger an investigation. An AIC will lead all investigations and work with the General Manager
and the Owner to identify and prevent diversion. Following any investigations, our management
will conduct an assessment to determine whether any additional safeguards are necessary to
prevent subsequent security breaches. 410 ILCS 705/15-100(c)(15). We will also seek feedback
from the Department and implement any additional safeguards we or the Department deem
necessary. 410 ILCS 705/15-100(c)(16).
If any of our employees are arrested for illicit use, possession, or distribution of cannabis, the
AIC will immediately begin a diversion investigation by auditing the employee’s transactions and
handling of cannabis to determine if any diversion has occurred. We will suspend facility access
privileges for any employee under investigation and will instruct the employee not to report to
work until the investigation has been completed. In accordance with our zero-tolerance diversion
policy, we will terminate the employment of any employee confirmed to have been involved in
perpetrating or supporting diversion and will report the incident to the Department and law
enforcement.
We will begin any diversion investigation with a transfer of all currency and cannabis
inventory to the secure vault room for an immediate audit. 410 ILCS 705/15-100(c)(15). This will
help our management assess exactly how much cannabis and which specific products are missing
from inventory. Once missing products have been identified, the AIC will consult the POS to
determine the last location of those products, when the products were last inventoried, and which
employees were the last to have contact with the products. This will narrow the timeframe in which
the products could have gone missing and approximate the time and location from which the
products went missing. The AIC will then review video surveillance and the keycard access log to
determine which employees may be involved and assess whether any criminal activity has
occurred.
Notifications & Reporting
Our Owner and GM will construct guidelines and procedures for communication with
regulatory bodies, law enforcement, and other licensed cannabis organizations. Management will
implement and train staff on these guidelines prior to our dispensary beginning operations. We
will develop procedures for notification of the Department and law enforcement in accordance
with the reporting requirements in 410 ILCS 705/ and any applicable administrative rules.
Procedures will include when notification is required, who is required to be notified, how
notification is to occur, what timeframe notification will occur within, and who is responsible for
performing the notification. A designated member of management will notify the Department, the
Department of State Police, and local law enforcement within 24 hours of first discovering any
diversion, theft, criminal activity, or suspected criminal activity. 410 ILCS 705/15-75(d)(3).
We will instruct our employees to immediately contact 911 in event of an emergency. In the
event of any criminal activity, staff will contact law enforcement having jurisdiction over the area
to report that a crime has been committed. We will keep lists of emergency phone numbers by all
landline telephones. We will designate a member of management responsible for immediate
notification of local law enforcement and notification of the Department within 24 hours becoming

aware of any alarm activation, event requiring response by public safety personnel, breach of
security; or, failure of the security alarm system due to a loss of electrical support or mechanical
malfunction that is expected to last longer than 24 hours. All notifications will include details on
the reported incident and any corrective measures taken. We will maintain records of all
notifications in an auditable form for at least three (3) years after providing the notification. 410
ILCS 705/15-110(a)(3).
Law Enforcement Liaison
To maintain open lines of communication with local law enforcement and enhance the security
of our operations, we will designate our General Manager as our law enforcement liaison. The
liaison will be responsible for reaching out to and developing relationships with local law
enforcement, as well as discussing our security measures and emergency response plans. We will
use feedback from these interactions with law enforcement to enhance our policies and procedures
and make our dispensary even safer and more secure. In the absence of the General Manager, the
Owner or a designated AIC will act as the law enforcement liaison.
Employee Procedures
Our ownership and management team understands the critical role of employee theft reduction
measures for the safety of our community, employees, and purchasers. Our plan for reducing
employee theft includes: stringent employee hiring practices; conducting in-depth employee
background checks; comprehensive anti-diversion training and procedures; building a culture of
transparency and teamwork; and, establishing and maintaining an anonymous employee tip line
for reporting workplace theft.
Hiring and Termination
Prevention of diversion begins with hiring only trustworthy managers and employees. We will
implement strict hiring procedures to avoid hiring any potential troublemakers. Prior to hiring, we
will conduct a criminal background check on all employment candidates. We will not hire any
candidates under the age of twenty-one years, who have had any disqualifying conviction, or who
have had any convictions for any offenses that call the candidate’s integrity into question. At the
same time we will continue to encourage employment of Social Equity Applicants (“SEAs”),
second chance candidates, and support community programs with prisoner re-entry candidates.
As specified in DEA guidelines, we will require all candidates to report all criminal convictions
that have occurred in the past two (2) years. Candidates who hide or falsify information will be
permanently disqualified from future employment. We will aim to hire individuals negatively
impacted by cannabis prohibition and will not discriminate against candidates convicted of a Minor
Cannabis Offense, so long as they disclose their conviction to the extent permitted by law.
In accordance with DEA recommendations, we will continue to monitor employees after they
have been hired. We will instruct employees to be on the lookout for troubled co-workers, and the
Owner will develop a confidential reporting process. We will perform additional screening
whenever an employee is promoted or has his or her access privileges increased. We may also
perform new background checks periodically to ensure that our employees remain eligible to hold
a Dispensing Organization Agent Identification Card.

We will notify the Department following the termination or separation of any employee or
ending of any relationship between our company and any principal officer. Upon termination/ or
separation of an employee, we will require the former employee to return their dispensing
organization agent identification card and will revoke all their access permissions to the dispensary
and the POS. 410 ILCS 705/15-40(d). We will then document the reason for the separation or
termination and will submit a copy of this documentation to the Department, along with the
Dispensing Organization Agent Identification Card of the terminated employee.
Dispensing Organization Agent Identification Cards (defined in 410 ILCS 705/1-10)
In accordance with 410 ILCS 705/15-40, we will require all employees to obtain a dispensing
organization agent identification card from the Department prior to beginning work at our facility.
Before hiring any employee, we will verify that the prospective employee meets all criteria
necessary to obtain an identification card. We will never hire any employee who is unable to obtain
an identification card.
Every employee must display his or her Dispensing Organization Agent Identification Card at
all times while in the dispensary. 410 ILCS 705/15-40(b). If an employee reports to work without
his or her identification card, we will not allow the employee to enter the facility. We will establish
procedures for employees to report lost or stolen identification cards, which will include immediate
notification of the Department of State Police and the Department. 410 ILCS 705/15-40(f). In
accordance with state law, we will require all employees to return their identification card to us
immediately upon termination. 410 ILCS 705/15-40(d).
Employee Diversion Prevention Training
Employee onboarding training will include instruction on our policies regarding diversion
prevention, including our zero-tolerance policy toward diversion of cannabis or theft of currency.
The employee handbook will detail these policies, and we will require all employees to read and
sign the handbook to confirm their understanding of, and agreement to, all diversion prevention
policies. Employees must read and sign the handbook and complete all diversion prevention
training prior to beginning work at the dispensary.
Part of employee diversion training will involve instruction on how to identify diversion,
including signs of possible diversion, suspicious activities, and discrepancies in inventory records.
Company policy will require employees to report any suspected diversion or suspicious activities
to a member of management, who will then initiate an investigation in accordance with our
“Diversion Investigations” procedures in this Security Plan. To encourage reporting, we will
implement an anonymous reporting system that will allow employees to report potential diversion
without disclosing their identity.
Anti-Pilferage Procedures
All dispensing activities will occur indoors and within view of surveillance cameras. We will
only permit employees to use clear drinking receptacles, such as clear plastic bottles, so that
cannabis or currency may not be hidden within them. We will prohibit employees from carrying
bags or backpacks into LAAs or RAAs; employees must secure any bags or backpacks in the
employee storage lockers located inside the dispensary, directly next to the rear employee entrance.

At the end of every workday, a member of management will search all employee bags or backpacks
under view of a surveillance camera prior to allowing employees to depart. All employees will
agree to this search when signing the employee handbook.
Whenever possible, employees will work in groups of at least two in order to monitor one
another’s activities. To limit opportunities for internal diversion, the Owner and General Manager
will arrange shifts so that an AIC is always present at the facility during operating hours and so
that no non-management employee is ever left alone at the facility.
Prohibited Behaviors
We will explicitly prohibit the use, possession, solicitation for, or sale of narcotics, illegal
drugs, alcohol, prescription medication without a prescription, or personal cannabis of any kind on
our premises or while performing a work assignment. We may ask staff to submit to a drug and/or
alcohol test at any time, which employees will agree to when signing the employee handbook, and
we will immediately terminate any staff member that violates our drug policy.
Loitering Prevention
In addition to the previously mentioned security measures that prevent unauthorized entries, the
facility will be equipped with an extensive video-monitoring and recording system. All staff
members will be trained in security measures, including the prevention of loitering. If someone
who is not a staff member remains on the premises without engaging in permitted activity, a staff
member will promptly call the police.
Before the facility opens for business, we will install exterior lighting with the purpose of deterring
loitering, vandalism, and other criminal activity. Furthermore, we will post a sign near the entrance
of the dispensary that can be easily read within five feet. This sign will state:
According to State law:
1. The sale, dispensing, and consumption of alcoholic beverages are not allowed on this
property. (This prohibition includes the interior of this facility and its parking area.)
2. Loitering is prohibited on this property. (This activity is not allowed inside the facility, in
the parking lot, or within 100 feet of the premises.)
Violators of either of these laws will be prosecuted.
Additionally, we will post a sign inside the facility, which states:
This dispensary is registered in accordance with the laws of the municipality in which it is located
and the State of Illinois. As such, the resale of cannabis bought at this facility is a direct violation
of both municipal and State laws.
If loitering becomes an ongoing issue despite these preemptive measures we will hire additional
security detail. This detail will regularly patrol the premises and stand guard at the entrance.

Employee Records
Our Owner will maintain personnel records for all employees for at least three (3) years after
termination. 410 ILCS 705/15-110(a). Records will include: application materials; copies of
dispensing organization agent identification card and driver’s license or state-issued photo
identification card; documentation of agreement to comply with the laws of the State of Illinois
pertaining to the adult use cannabis program; verification of references; background checks; job
description or employment contract; all required training and a signed statement of the individual
indicating the date, time, and place he or she received said training and the topics discussed,
including the name and title of presenters; performance evaluations; disciplinary action; drug tests;
and, termination of employment. We will store records in an RAA and will restrict access to the
Owner, managers, and the Department.
As a best practice, in addition to entering all hires and terminations into the electronic database,
we will maintain a physical roster of current employees and their access privileges at the facility,
which will be available to the Department upon request. We will provide all prospective employees
with a notice of intent to hire form and will also send a notice of separation to the Department
when any employee ceases to work for us.
The Owner will also create and maintain an up-to-date organizational chart that includes:
name, address, and date of birth for each principal officer, employee, and any other individual
associated with the business.
Agent and Purchaser Safety and Security Procedures
Maintaining the safety and security of our staff, visitors, and facility is our foremost priority.
To this end, we have constructed procedures for: opening and closing the dispensary; receiving
deliveries; security guard activities; receiving purchasers and non-purchaser visitors; fire and
natural disaster safety; and, responding to suspicious individuals, robberies, and workplace
violence.
Opening and closing procedures
We will employ security guards to provide on-site facility security during our hours of
operation. At the facility opening time, the security guard on duty, accompanied by an AIC, will
perform an exterior walkthrough to look for signs of trespassing or anything out of the ordinary.
They will then unlock the employee entrance and conduct a similar inspection of the facility
interior. Once these inspections are complete, the security guard will wait near the employee
entrance to greet and check-in employees and visitors.
At the facility closing time, an AIC and a security guard will conduct another walkthrough of
the facility interior to verify that all doors and windows are secure and locked. A security guard or
manager will then wait near the primary entrance to perform checks of employee backpacks or
bags as employees exit the facility. No employee will be permitted to leave the facility until his or
her baggage has been inspected by a manager or security guard. Once all employees have exited
the facility building, a security guard will activate the facility alarm and exit and lock the facility.
Deliveries

We will accept product deliveries as necessary at our location at the rear dispensary entrance,
which is located in an RAA. 410 ILCS 705/15-70(f). This location will not be accessible to
purchasers or other unauthorized persons, will be under camera surveillance, and cannot be opened
without an employee keycard.
Only our designated AICs will accept deliveries and will record them in the POS immediately.
The receiving manager will count delivered products and give the delivery personnel an itemized
receipt to prevent personnel product diversion, theft, or loss. Delivery personnel must present valid
identification prior to delivering products or entering the facility. Our personnel will follow
company protocols during deliveries, ensuring that: a complete perimeter check has been done
prior to opening the rear receiving doors, and that no onlookers or possible robbers are present;
products are secured in opaque containers with no indication of contents; and, the transport
manifest matches products delivered (including name, strain, weight, and identification numbers),
ordered, and verified by us prior to delivery personnel departure. 410 ILCS 705/15-75(c).
Security Guards
In addition to the VSS, alarm system, and trained employees, our security guards will be the
first line of security. A licensed security guard will be on the premises at all times during operating
hours, stationed to control and monitor the primary entrance and conducting regular checks of the
interior and the surrounding property. During special events, promotional days, or any other period
when purchaser traffic is expected to be especially high, we will schedule one or more additional
guards. All security guards will be thoroughly trained in hazard, robbery, and emergency situations
to protect the facility and community. All security guards will be properly licensed by state and
local authorities and possess any necessary valid identification whenever they are on the premises.
As with all other staff, we will only hire security guards who are at least 21 years of age. We will
hire additional security guards as needed or required according to future Department regulations.
All security guards will wear shirts with “Security” on the front and back in a noticeable color
so as to be easily identified in case of a robbery, burglary, diversionary event, or other unexpected
hazard. Security guards will always comply with the security plan, will be trained in de-escalation
techniques, and will follow company, Department, and State of Illinois protocols to ensure facility
safety.
Security guards will have a variety of responsibilities, including: opening/closing the facility
each day with the help of managers; ensuring all entering individuals have valid identification, a
dispensing organization agent identification card, or regulatory agency identification; maintaining
a vigilant and pleasant visage; reporting possible security risks to the GM, a designated AIC, or
the Owner immediately; carefully observing staff, purchaser, and visitor actions; and, ensuring the
safety of the premises.
Security guards will only allow purchasers who have valid, government-issued identification
demonstrating their age (21+) to enter the dispensary, and will ensure that purchasers do not
consume products on the outside grounds of the dispensary. As part of their daily duties, security
guards will retrieve the visitors’ log at the start of business and return it at the end of the day,
ensuring all visitors sign in and out. Security guards will respond to suspicious or emergency
situations and coordinate with law enforcement to write incident reports, including an accurate

daily activity log with time, location, and detailed descriptions of security issues. Other daily
procedures will be dictated by the General Manager once the facility is licensed and will be
followed closely by security guards.
Visitor Protocols
Purchaser Reception Protocols
The dispensary may only operate from 6:00 a.m. to 10:00 p.m. local time. 410 ILCS 705/1570(j). Our normal business hours will be Monday through Thursday from 9:00 a.m. to 9:00 p.m.,
Friday and Saturday from 9:00 a.m. to 10:00 p.m., and Sunday from 10:00 a.m. to 9:00 p.m. We
will only allow purchasers to enter during these hours. We will place a sign showing the
dispensary’s business hours at the primary entrance in a location easily visible to visitors outside
of the facility and will also post up-to-date business hours and information on facility closures
(such as for holidays or maintenance activities) on our website.
We will not allow any consumption, use, sales, or dispensing of tobacco or alcohol on or
around the dispensary, and our dispensary will not sell any alcohol products except as allowed by
law. 410 ILCS 705/15-70(d). Signage on the exterior of the premises and inside the waiting and
point of sale areas will inform purchasers that consumption or use of tobacco, alcohol, or cannabis
is prohibited while on facility property. Additional signage on the exterior of our dispensary will
notify purchasers that minors under age 21 are not permitted on the premises, even in the waiting
area. 410 ILCS 705/15-65(i)(1).
Purchasers will enter the dispensary through the primary entrance, which opens into the
waiting area/lobby. This entrance will have a security guard stationed at the door to check
identification cards and ensure only public 21 years of age enter. The primary entrance will remain
securely locked outside of business hours. A staff member will be responsible for granting
purchasers access to the facility, greeting all purchasers, and inquiring about the purpose for their
visit. If the visitor is an adult use purchaser seeking access to the sales area, a staff member will
require the purchaser to provide a government-issued photo identification to confirm the visitors’
age is 21+ and will scan the identification to confirm it is valid. 410 ILCS 705/15-85(a)(1).
As with the rest of the dispensary, we will monitor access to the waiting area, and only persons
with a legitimate reason to be in the waiting area, such as purchasers awaiting access to the sales
area and individuals accompanying them (who must also be over the age of 21), will be permitted
to remain in the waiting area. We will not store, transfer, or display any cannabis in the waiting
area. Purchasers will remain in the waiting area until an employee unlocks the door to allow them
into the point of sale area. Locked doors and solid walls will provide full containment of visitors
in the waiting area at all times, providing a barrier between the facility entrance and LAAs by
preventing purchasers from entering LAAs without being granted access by an employee. 410
ILCS 705/15-100(c)(1).
The retail sales area, an LAA, will be a different room and will be physically separated from
the waiting area by a wall and an access-controlled door, which will prevent entry into the point
of sale area by unauthorized individuals. The retail sales area will also be closed to the public, and
only staff and purchasers aged 21+ will be permitted to enter. Purchasers in the retail sales area

will remain in view of employees and multiple video surveillance cameras throughout their visit.
Purchasers will never be permitted behind the sales counter, which we will designate as an RAA.
We will not permit any purchasers to remain in the retail sales area after their business has been
completed. Once their business is completed, staff will require purchasers to return to the waiting
area and depart through the primary entrance.
Pursuant to state law, we will not provide any cannabis via a drive-through or any vending
machines. 410 ILCS 705/15-70(n)(7), (8). All cannabis dispensing activities will occur within the
enclosed point of sale area and out of public view, and never via delivery to residences or any other
locations. 410 ILCS 705/15-70(n)(9).
Non-Purchaser Visitor Protocols
In addition to purchaser reception procedures, we have also constructed procedures for
receiving non-purchaser visitors, including contractors, business guests, and other visitors not
explicitly authorized by law or the Department to enter. The restrictions in this section will not
apply to the Department, any Department designees or personnel accompanying Department
personnel, or any on-duty emergency response personnel responding to an emergency at the
facility. Management will always provide immediate, unrestricted access to the dispensary for any
Department-authorized individuals, including inspectors.
All non-purchaser visitors will enter the facility via the primary entrance, which opens into the
waiting area. When non-purchaser visitors arrive in the waiting area, they will be greeted by a
manager or reception employee. Before allowing non-purchaser visitors to enter the facility, staff
will require non-purchaser visitors to provide valid government-issued photo identification to
confirm their identity and age. We will prohibit persons who do not provide sufficient
identification from accessing the facility. Staff will prepare temporary visitor ID badges that nonpurchaser visitors must always display on their person while in the facility and will record on a
physical Visitors Log (which we will retain for three (3) years):
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Visitors’ names;
Reasons for visitation;
Time visitors enters the facility;
Visitors’ temporary visitor ID badge numbers; and,
Time visitors leaves the facility.

Once checked in, non-purchaser visitors will remain in the waiting area until an employee
arrives to accompany them. Prior to entering the remainder of the facility, an employee will brief
non-purchaser visitors on the rules of conduct for their visit, including prohibited behaviors such
as unauthorized photography and physical contact with cannabis. We will prohibit non-purchaser
visitors from bringing food, drinks, bags, or backpacks into the facility, unless necessary for their
job, such as a repairman, in which case staff will require the visitor to consent to a thorough search
of the bag when entering and leaving the facility. Staff will instruct non-purchaser visitors to
always keep their visitor badge on their person and clearly visible. If a non-purchaser visitor
violates the rules of conduct, staff will immediately escort them out of the facility and place their
name and information on our No Entry/Do-Not-Serve List.

Non-purchaser visitors will remain in the visitor waiting area until a designated staff member
arrives to accompany them on their visit. At least one staff member will continuously escort nonpurchaser visitors throughout the facility. Non-purchaser visitors will always remain within
physical sight of escorting staff and will be recorded by the facility’s video surveillance. Nonpurchaser visitors will only be permitted in areas where they must be for their identified purpose.
Posted signage will clearly indicate which areas of the facility are RAAs and LAAs. All visitors
and staff will adhere to the posted signage and remain only in approved areas.
Once the visitors’ business is concluded, the escorting staff member will return them to the
visitor waiting area. Visitors will be required to return their visitor badge prior to departure. The
escorting staff member will sign the Visitors Log after each entry to confirm that each visitor has
returned their badge and will record the time that each visitor leaves the facility.
Emergency Response Team
Our highest priority in operations is the safety of all personnel and purchasers at our dispensary.
Pursuant to guidelines from OSHA, we will establish an Emergency Response Team (“ERT”)
composed of the Owner, the General Manager, and all designated Agents-in-Charge. The ERT
will: conduct research and compile our emergency and safety procedures, including general
emergency response plans, a fire plan, and procedures for security breach and armed robbery
response; train employees on these policies; and, supervise evacuations and other emergency
response activities. All employees will complete comprehensive safety training prior to beginning
work at our dispensary. This training will include instruction on the facility’s Emergency Action
Plan (“EAP”), which we will construct to comply with all applicable regulations from the
Department and the federal Occupational Safety and Health Administration (“OSHA”).
The ERT will construct policies for responding to various emergencies, including: fire,
tornados, flooding, armed robbery, workplace violence, and health/medical emergencies. These
policies will be based on expert guidelines from government agencies such as OSHA and
professional associations. The ERT will meet at least every six months to: assess policies; identify
gaps or inadequacies; and, update and improve policies. To keep personnel safe during dangerous
and severe weather events, such as tornados, the ERT will designate an area of the facility for use
as a shelter. The ERT will also designate shelter areas for incidents such as criminal activity,
chemical spills, or other environmental disasters.
Employee Safety and Security Training
Prior to beginning work, management will train all employees on all emergency plans. All
employees will complete training on the types of emergencies that may occur in the facility and
the proper response procedures for each emergency. Management will teach employees the
function and elements of our emergency plans, including types of emergencies, reporting
procedures, alarm systems, and evacuation plans. Employee training will cover: individual roles
and responsibilities; threats, hazards, and protective actions; notification, warning,
communications and reporting procedures; evacuation and shelter procedures; basic first-aid; and,
hierarchy and accountability during an emergency. In addition to regularly scheduled trainings,
staff will conduct retraining whenever emergency plans are revised or updated, when facility

layout or evacuation routes are altered, or when new equipment or hazards are introduced into the
workplace.
Employees will also complete thorough training on our fire safety plans. We will regularly
conduct fire and other emergency drills to ensure that employees are familiar with procedures and
functionality of any emergency equipment, such as fire extinguishers and fire alarm activation
mechanisms.
Before beginning work, all employees will receive instruction from a member of management
on the proper equipping, usage, and maintenance of any Personal Protective Equipment (“PPE”)
necessary for their job. The member of management will also inform employees of all applicable
policies and procedures and any state or federal rules for PPE.
Supervisors will provide each employee with information on whom to contact in the event of
an emergency. The ERT will compile and post a list of managers and employees with their
emergency responsibilities at regular intervals throughout the facility. In accordance with OSHA
guidelines, this list will include names, titles, and contact info for all responsible individuals.
Emergency Action and Fire Prevention Plans
In compliance with OSHA requirements in Title 29 of the Code of Federal Regulations, our
ERT will draft an EAP and a Fire Prevention Plan (“FPP”).
The facility’s EAP will include:
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Procedures for responding to and reporting fires, armed robbery, workplace violence and
other emergencies;
Emergency escape procedures and employee route assignments, including floorplans,
workplace maps, and designation of safe/shelter areas;
Procedures to account for all workers following an evacuation or shelter-in-place event;
and,
Designated managers and employees, along with their responsibilities in the event of an
emergency.

Pursuant to OSHA recommendations, the EAP will designate a member of management, an
AIC if possible, as a Coordinator and identify certain employees as Evacuation Wardens. The
Coordinator will be responsible for implementing emergency procedures in event of an emergency,
supervising emergency response efforts, and ensuring that first responders are directed to the scene
of the emergency. The Coordinator will be assisted by Evacuation Wardens, employees
responsible for directly supervising designated groups of employees in emergency response. Per
OSHA guidelines, there will be one Evacuation Warden designated for every twenty employees.
Our FPP will include all information required by OSHA regulations. We will employ active
fire protection measures, including placement of fire extinguishers in key locations and installing
a fire sprinkler system with facility-wide coverage. The FPP will consider all possible electrical,
fire, or other hazards that may be presented by our electronics and other equipment. Where
necessary, we will implement passive fire protection measures as well.

Fires and Natural Emergencies
Management will create detailed procedures for staff at the dispensary to follow in event of
local, state, or national emergencies, including natural disasters that affect the security or operation
of our dispensary. 410 ILCS 705/15-65(a)(2).
Detection equipment, including a professionally monitored fire alarm, will be present
throughout the facility to alert building occupants of fire or other emergency conditions
necessitating evacuation. A qualified alarm technician will test all detection equipment at least
every 30 days, and we will keep all equipment in good working order. We will strategically
position fire alarms to be visible, audible, or otherwise perceivable by everyone in the facility and
from any location in the facility. A fire sprinkler system will provide coverage throughout the
facility to immediately begin suppression of any detected fire.
Interior lighting will be sufficient to allow for safe navigation and evacuation of the dispensary
by employees and visitors. Illuminated exit signs will clearly mark all exits. The ERT will place
copies of the fire evacuation plan, including evacuation routes, throughout the facility to ensure
that personnel can always find a path out of the facility. We may install single-motion egress doors
at emergency exits to allow for more efficient evacuation in the event of a power failure. Singlemotion operation allows doors to be unlocked and opened only in one direction, with a single
motion and without use of keys or tools. These doors will automatically unlock when pushed open
and are only possible to open from the inside of the facility.
Sanitation staff will make safety data sheets (“SDSs”) available at entrances so firefighters can
have easy access to chemical information during emergencies. SDSs will detail every
commercially available substance onsite (i.e., cleaning chemicals), and all containers for water
will bear a clearly visible “H2O” label.
Severe weather emergencies may result in damages to the power supply of the facility. In the
case of an extended power outage, we will activate a backup generator, which will have sufficient
power to continue surveillance and door-locking technologies. The generator will remain in use
until power can be restored. During a power outage, all staff will safely exit the facility and return
only when management permits reentry.
Suspicious Individuals and Violent Incidents
While our facility incorporates many different security features, even the best features cannot
be one hundred percent effective at preventing a security breach. Therefore, the ERT’s emergency
plans will include procedures for employees to follow in the event of a security breach, armed
robbery, or violent event. We have based these procedures on guidelines from local law
enforcement, OSHA, the Federal Bureau of Investigation, Department of Homeland Security, and
professional organizations. Other items that the ERT will consider in crafting policies include local
law enforcement capabilities, frequency of patrol, and response time. The ERT will also develop
any additional procedures as required by the Department in response to any special security
concerns. 410 ILCS 705/15-100(c)(16).
Suspicious Individuals

We will instruct our employees on the following procedures for responding to suspicious
individuals and attempted or successful unauthorized entry to the facility:
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Remain aware of your surroundings, particularly when traveling from the parking area to
the entrance of the facility. Transitional spaces such as parking lots present a prime
opportunity for criminals to ambush you and force you to allow them to enter the facility.
Trust your instincts when encountering any suspicious individuals on or around company
property. If possible, lock the primary entrance to prevent any suspicious individuals
from entering the facility.
If a potential threat is present outside of the facility, inform other employees and visitors
of the threat, remain indoors, verify that all facility entrances are locked, and stay away
from doors and windows.
If possible, do not allow the individual to access the inside of the facility. Allowing a
threatening individual to enter the facility will create enormous danger to the safety of
everyone in the facility.
If a suspicious individual enters the facility, contact security personnel immediately. If
the individual is presenting a threat, keep your distance from them. If the individual has a
weapon or attempts to harm anyone, implement armed robbery or active harmer policies
as applicable and detailed below.
Call 911 or contact law enforcement immediately in response to a potential threat or
suspicious individual. Even if it turns out that there is no threat, it is better to be safe than
sorry. Try to provide a description of the individual and his or her behavior if you can
safely do so. Make note of the following: physical characteristics, including sex, race,
height, weight, and build; appearance, including clothing type and color; and, any
weapons or possible weapons.

Armed Robbery
We will instruct our employees on the following procedures for responding to armed robberies:
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Remain calm and avoid any action that might incite the robber to act violently. The
robber may be nervous or agitated, and further excitement may cause the robber to panic
or harm someone.
Activate the facility holdup/duress alarm as you see the robber leaving, or earlier if you
can do so safety. Remain alert for opportunities to activate the alarm. The sooner the
alarm is sounded, the sooner police can respond. Do not let the robber see you activate
the alarm, as this may incite them to violence. Do not attempt to activate the alarm unless
you are absolutely sure you can do so safely and without being noticed by the robber.
Always obey any commands given by a robber if he/she has managed to enter the facility,
has a hostage, or is otherwise presenting an immediate threat to the life of a person. If a
robber has a hostage and is demanding access to the facility, always comply. None of the
company’s property is more valuable than the life of a person.
During or after a robbery, employees who are not aware of the incident should be notified
to stay away until police arrive and declare that the area is safe.
Call 911 or contact law enforcement immediately in response to a robbery. Try to provide
a description of the individual and his or her behavior if you can safely do so. Make note

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of the following: physical characteristics, including sex, race, height, weight, and build;
appearance, including clothing type and color; and, any weapons or possible weapons.
After a robbery, close and secure all areas where the robber was present. This will help to
preserve evidence, such as fingerprints, DNA, or fibers that the robber may have left
behind. Also make note of and leave in place any visible evidence left by the robber, such
as notes or dropped items. Do not allow any purchasers or staff who were present during
the robbery to leave until police have arrived, as they may be needed as witnesses. Each
employee should write his or her own description of the robber or threatening person and
the event and should provide this description to police when they arrive.

A member of management will report any armed robbery or other trespassing events to the
Department and local law enforcement as soon as possible, and never later than 24 hours after the
event. If diversion or theft of our cannabis inventory is suspected to have occurred, the GM will
immediately begin an investigation, including a full inventory audit. Any staff member involved
would be provided access to a counselor to discuss any trauma.
Active Harmer and Workplace Violence
Prevention of workplace violence begins by creating a welcoming and respectful work
environment where all employees feel comfortable. Part of our HR policies will include zerotolerance for violent or aggressive behavior or threats, discriminatory conduct, or sexual or other
harassment. We will encourage employees to accept individual differences, develop effective lines
of communication with each other and with supervisors, and to view themselves and every coworker as a vital part of a united team.
Nonetheless, workplace violence is an unfortunate reality of today’s society. To address this
threat, we have constructed procedures for response to workplace violence or active harmer
incidents:
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Workplace violence is relatively rare, however, keep in mind that violence, no matter
how rare, can potentially occur anywhere. Develop a response plan ahead of time to help
yourself feel better prepared and to enable a rapid and efficacious response in case the
unthinkable ever does occur.
Be aware of your environment. Know where the entrances and exits are. Notice when
something unusual is occurring and trust your gut when you feel that something is wrong.
Be alert for warning signs in fellow employees, including unusual or erratic behavior.
Communicate any violence, aggression, or threats of violence or aggression to a
supervising employee or manager. Everything should be reported, no matter how small,
because even small acts may be warning signs of larger harm to come.
Active harmer incidents create chaos and confusion. Expect a confusing environment.
React with a simple plan that maximizes potential for safety.
Survivors of shooting incidents often mistake gunfire for other benign sounds, such as
firecrackers, which can delay incident response and put lives at risk. If a gunfire-like
sound is occurring in a location where such sound is out of place, do not assume that the
source is something harmless.
If you are in a hallway, run to the nearest room or exit. Avoid doorways or dead ends
where you could be trapped.

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The best option in an active harmer situation is to run. Get to a safe place away from
where the violence is occurring. Call 911 and provide a location and description of the
perpetrator, if possible. If you can safely do so, warn others about the threat and prevent
them from entering the area where the perpetrator is.
The next best option is to hide. If you cannot safely get away from where the violence is
occurring, shelter in place by locking and barricading all entrances. Turn off the lights,
silence cell phones, spread people throughout the room, and inspect the area for potential
improvised weapons. If it is possible to do so safely, activate an alarm to alert law
enforcement. Remain quiet and calm, hide behind large, heavy objects, and stay away
from any doors or windows.
If no other options are available, the only way to survive may be to fight. Look around
for potential weapons and construct a plan of attack with other people around you. Use
improvised weapons, throw items to distract the perpetrator, and consider a plan to tackle
and restrain the perpetrator until help arrives. If you must fight, you need to remain
committed to that action until help arrives. Remember, a large group of people with
improvised weapons can easily overwhelm a single perpetrator in close quarters, but all
members of the group must remain committed to their action. Half-hearted resistance will
have the same result as no resistance.
Law enforcement will arrive at the scene with weapons drawn and may not know who the
perpetrator is or where he is located. Put down any objects that you may have in your
hands and keep your hands visible. Do not make any sudden movements, such as
reaching out towards officers. Obey all commands and understand that the first priority of
law enforcement is to stop the perpetrator, not to evacuate bystanders or render aid to
injured people.
If possible, provide information about the perpetrator to responding law enforcement or a
911 dispatcher. Valuable information includes: location and physical description of the
perpetrator, number of perpetrators, types of weapons involved, and number of potential
victims.
The company will make available counseling for those employees who may need it.
Cybersecurity Procedures

Protection of electronic data and digital infrastructure is a vital and often overlooked aspect of
security for any business. Our cybersecurity plans begin with minimizing the amount of purchaser
data we will be retaining and limiting opportunities for security breaches to occur. Per state law,
we will scan the government-issued identification of every purchaser who enters the dispensary in
order to verify their age and the validity of their identification. 410 ILCS 705/10-20(a). We will
retain some of this information, such as addresses, for use in event of a product recall. Additionally,
we may voluntarily collect and store purchaser names, email addresses, and phone numbers for
use in our loyalty program. We will not collect or store any purchaser payment information, such
as credit card numbers or bank account details. If we elect to offer non-cash payment options, we
will contract with a third-party payment processor to facilitate these transactions without our
dispensary retaining any purchaser data.
While we will only be retaining a small amount of purchaser data, protecting our cyber
infrastructure is nonetheless a vital part of keeping our dispensary secure. When creating policies

for the security of our computers and data, we have consulted regulations found in Title 45 of the
Code of Federal Regulations, including the Health Insurance Portability and Accountability Act
(“HIPAA”) and the Health Information Technology for Economic and Clinical Health Act
(“HITECH”). We will also adopt best practices for cybersecurity used by HIPAA-compliant
medical facilities to prevent unauthorized access or theft of our data, a set of practices that we are
adept with, as we are experienced in health information technology.
Employee Training and Security Policies
We will document all cybersecurity policies and employee trainings. Management will
thoroughly train all employees on our cybersecurity procedures prior to them beginning work at
the facility. We will also contract with a professional IT security company to revise policies and
procedures, test cybersecurity measures, and provide additional training for staff. Employee
training will include: recognizing phishing emails; creating and maintaining strong passwords;
avoiding dangerous websites or applications; and, many other company cybersecurity policies. At
a minimum, all staff will undergo annual retraining on cybersecurity best practices. We and our
cybersecurity professionals will also provide staff with notices of emerging cybersecurity threats,
such as new phishing scams or software vulnerabilities.
We will implement a policy prohibiting the sharing of employee-specific computer access
credentials. 410 ILCS 705/15-100(c)(12). Passwords will remain confidential and will not be
shared amongst employees. Passwords must be at least 12 characters, will be required to pass a
strength check, and will be changed every 90 days. Where feasible, systems will also use multifactor authentication measures to offer further user verification. Employees will always lock their
computer screen when away from their workstation. Other policies will include instruction for
employees to never open or click on unsolicited email attachments. We will mandate usage of
strong spam filters to prevent phishing emails from reaching employees.
Employees will also complete training on accessing records in our POS. This training will
include use of these systems and our policies against tampering with electronic records, including
penalties for any records tampering, which will include termination of employment and reporting
of any incidents to the Department and law enforcement. In addition to our policies against
tampering, our inventory and sales software will log all modifications to electronic records,
including what was changed and which user changed it, providing further protection against theft
or diversion facilitated or hidden by electronic records tampering. 410 ILCS 705/15-100(h)(5).
Technical Security Measures
The GM will keep all computer systems updated with the latest operating system, software,
and firmware updates to patch potential system vulnerabilities. The Owner and GM will create and
maintain plans for upgrading all system software and hardware. The GM will enable automatic
system updates on all computer systems, and systems will be routinely inspected to ensure that
they are running the latest and most secure updates. We will designate a member of management
to conduct regular inspections of the information technology market to identify promising new
security products and newly emerging cybersecurity threats.

An enterprise-grade router equipped with a commercial security firewall and virtual private
networking will provide capability for remote access through a secure, encrypted internet pathway.
Any individual devices, such laptops or tablets, will feature internal firewalls to provide further
security. To prevent introducing compromised devices onto our network, we will prohibit
employees, purchasers, and other visitors from connecting personal devices to our network.
Business-quality managed switches capable of Virtual LAN tagging will provide additional
traceability and security for all network activities.
Network management software will allow facility managers to monitor all network traffic to
detect non-permitted network access or violations of network usage policies by employees.
Through close management of network activity, management can identify potential insider
security threats, such as unauthorized access/attempted access of confidential data or connection
of unauthorized outside devices to the network.
HIPAA-compliant Microsoft Office 365 software (or similar) will provide secure facility
communication. All computers connected to our network will use firewalls and high-quality antivirus/malware software. Physical hardware encryption measures such as Bitlocker (or similar) will
prevent theft of data in event of a physical computer theft or physical hard drive access. We will
encrypt all sensitive data stored on our servers using 256-bit encryption to prevent unauthorized
access. We will regularly backup all data to secure off-site servers to avoid data loss in event of a
system failure, ransomware attack, fire, or other disaster at the facility. All backups will also be
encrypted and password-protected to prevent unauthorized access or theft.
These cybersecurity measures, along with access controls on facility doors and user account
access privilege restrictions, will limit access to electronic facility records to employees
necessitating such access for their job functions. By limiting the number of personnel who may
access and modify electronic records, we will reduce opportunities for electronic records
tampering.
Incident Response
Management will work with cybersecurity contractors to create plans for responding to
incidents. In response to a security breach, we will conduct the following procedures:
•
•
•
•

•

Assess the nature and scope of the incident to determine if the breach was a malicious
attack or a technical glitch.
Determine the source of the breach, such as a specific phishing email, downloaded
application, or outside attack.
Identify and document the extent of the damage. Immediately make a forensic image (an
exact copy of a hard disk) of any affected devices. This copy may be used for later analysis
and may possibly serve as evidence at trial.
Implement measures to minimize damage. Contain the attack and prevent it from
spreading, such as by stopping ongoing network traffic caused by the attacker and
disconnecting affected devices from the network. Maintain detailed records of all steps
taken.
Notify all relevant personnel, including management, IT personnel, security, law
enforcement, the Department, and any affected purchasers.

Data Breach Notifications
We will follow all applicable laws for notifications following a breach of security, including
the Illinois Personal Information Protection Act (815 ILCS 530). For the purposes of data breach
notifications, our procedures will define “breach of security” as any unauthorized access to data
containing unencrypted personal information that compromises the security, confidentiality, or
integrity of personal information. We will use the definition of “personal information” from the
Personal Information Protection Act: (a) a username and password that would allow access to an
online account, or (b) an individual’s first name or first initial and last name linked with any one
of more of the following (in unencrypted form): (1) social security number; (2) driver’s license,
state identification card, or cannabis registry card number; or (3) bank account, credit card, or debit
card number, access code, or password that could permit access to an individual’s financial
account(s); (4) medical information; (5) health insurance information; or, (6) unique biometric
information. 815 ILCS 530/5.
In event of a data breach, we will provide written notice to all potentially affected individuals
within 48 hours of discovering a breach, unless otherwise directed by law enforcement or the
Department. Notice will primarily be electronic notice consistent with the provisions of Section
101 of the federal Electronic Signatures in Global and National Commerce Act (15 U.S.C. s.7001).
Otherwise, notice will be substitute notice in the form of regular U.S. mail and/or e-mails to all
affected parties, conspicuous posting on our website, and notification to the Department and statewide media.
Cannabis Currency Handling
To create a safe working environment and ensure the safety of purchasers, surrounding
businesses, and the residents of Illinois, we have constructed a cash management plan that will
include cash counting and reconciliation procedures, cash storage, cash transport, banking cash
deposits, and employee cash management training. This cash management plan provides steps
that sales associates and management will follow for handling cash and a change fund. Our
policies will ensure that each sales transaction is accounted for and no unlawful sales
transactions or diversions take place.
Our AICs and management will maintain detailed cash management records to ensure the
accuracy of sales records. We will enlist a third-party accounting firm to perform an independent
audit and review of the books at least annually. This reviewer will ensure protocols are effective
and in line with industry best practices. We will keep records of personnel, training, security,
bank statements, sales, invoices, receipts, tax records, and records required by state tax regulators
in a locked storage area and electronic files accessible by the Department for at least three (3)
years. 410 ILCS 705/15-110(a)(7). For business records, including records of assets and
liabilities, audits, monetary transactions, journals, ledgers, and supporting documents, including
agreements, checks, invoices, receipts, and vouchers, we will maintain a record for at least five
(5) years. 410 ILCS 705/15-65(a)(6).
Employee Cash Management Training

Prior to engaging in any activities involving cash handling, employees will complete our cash
management training curriculum. This will include: processing transactions; purchase verification;
quantity and label checks; payment collection and change making; receipt generation and package
verification; and, exit bag use.
Cash Counting & Reconciliation Procedures
Sales associates and security guards will complete training in cash counting and reconciliation
procedures prior to our facility commencing operations. Sales associates will start the day with
tills containing ten-dollar bills, five-dollar bills, and one-dollar bills, totaling $300. Tills will be
removed from the cash storage safe by a manager and placed into each till by sales associates.
Whenever possible, a security guard will ideally be present during this operation. Managers will
provide oversight of cash counting and reconciliation procedures during operating hours to
eliminate employee diversion or cash theft.
To minimize burglary, theft, or diversion, sales associates will remove cash from the till on a
consistent, periodic basis throughout the day, each time leaving $300 remaining for the purposes
of making change. An AIC will place the excess cash in our cash safe in the reinforced vault room,
which is an RAA. A sales floor transaction log and video surveillance will monitor cash
transactions. If an investigation is necessary, management will access surveillance video camera
footage. Sales associates will count cash in tills at the end of each day with manager oversight, and
in full view of a surveillance camera, and will tally all cash on an end of day cash reconciliation
sheet. A manager will then place the cash register tills in the safe, ideally with the assistance of a
security guard. These procedures will guarantee that all currency is securely stored in the cash safe
inside the reinforced vault room, an RAA, at the end of each business day. 410 ILCS 705/15100(c)(6).
Change Fund & Petty Cash
Maintaining the change fund and petty cash will be the responsibility of the sales associates,
who will: maintain currency and coin quantities necessary for operation; store cash in the safe
when not in use; keep the change fund separate from petty cash; and, reconcile change funds
regularly with the GM on the last day of each month. The GM will be responsible for: conducting
surprise cash counts of the fund each quarter/month; completing cash verification within 30 days
of the required reporting date with the Owner’s signature; ensuring that the correct change fund is
in the possession of the sales associate; and, maintaining a verification form in the safe files for
five (5) years
Cash Storage
We will maintain a cash safe in the reinforced vault room to store all cash not needed for sales
transactions. 410 ILCS 705/15-100(c)(6). Access to the cash safe will be restricted to managers
and employees whose job functions necessitate access. A keycard-based access control system will
prevent unauthorized entry into the cash safe and log every access or attempted access, including
the date and time of entry and exit and the name of the individual.
We will purchase our cash safe from an established, reputable company, and safe installation
will be performed by qualified professionals. Cash safe features include: door and frame unit

designed for resistance to surreptitious entry, forced entry, lock manipulation, and radiological
techniques; connection to the facility alarm system; contact switches on the safe door; and, other
devices, such as ultrasonic equipment, designed to detect illegal entry. The cash safe will remain
under constant video surveillance and will contain alarm contact switches on the door that will
trigger an alarm in the event of unauthorized entry and alert management whenever the safe door
is opened. Manual alarm activation buttons will be located inside and outside of the cash safe to
allow facility personnel to activate a holdup alarm in event of a robbery.
The cash safe will be of sufficient size to comfortably store the cash drawers from our registers.
As part of our dispensary closing procedures, an AIC will remove the drawers from the registers
and secure them inside the cash safe. This will prevent theft of our currency by securing all
currency inside an RAA while the dispensary is closed overnight. 410 ILCS 705/15-100(c)(6).
Armored Car Pick-up of Cash Deposits
We will contract with an Illinois-licensed armored car/truck service to provide cash
transportation services. On a regular basis, cash transport will take place using armored cars/trucks
to transport cash from our dispensary. We will contract with cash transporters who use Bank
Secrecy Act and Anti-Money Laundering compliance programs to report criminal investigations
and enforce recordkeeping and reporting requirements to create a financial trail for the Department
and local, state, and federal law enforcement agencies.
Armored cars/trucks will be equipped with safety and security technologies that may include
a starter interrupt system with a key fob, geo fence, and time window to prevent theft of or
unauthorized starting of the car/truck. Armored cars/trucks will be equipped with customized alert
systems that contact the transportation company and law enforcement automatically in case of an
accident or security breach. Cash transporters will immediately alert the Department, state and
local law enforcement, and our company management should any diversion or theft attempt be
made on the vehicle.
Security Conclusion
We endeavor to construct and operate an adult use dispensing organization that will set the
standard for security in this emerging industry. To accomplish this goal, we have adopted standard
operating procedures and best practices from other high-security industries, including controlledsubstance pharmaceutical distributors and HIPAA-regulated medical practitioners. Security
systems at our facility will detect and prevent unauthorized entry to the facility, provide for
constant monitoring and surveillance of the facility, and secure all cash and cannabis inventory.
Management will train all employees thoroughly on our safety and security procedures, which we
have developed using guidelines from public safety officials, law enforcement agencies, and
professional security organizations. Carefully crafted diversion prevention and investigation
procedures will deter, detect, and prevent diversion. These security measures will work together
to create an adult use dispensing organization with world-class security that provides a safe
workplace for employees, prevents cannabis inventory from entering the black market, and
protects the health and safety of our community and the people of Illinois.

ACES DISPENSARY
Special Use Permit Application
Supplemental Information

Introduction
Aces Dispensary and its affiliate High Haven Dispensary collectively operate four adult use
dispensaries in Illinois, located in Darien, Normal, Elgin, and Plainfield. All four are currently
operating and are led by Monsaur Othman, who is the sole owner of Aces Dispensary and the
majority owner of High Haven Dispensary. The proposed Flossmoor location would be the fifth.
Our dispensaries are distinctive within the Illinois industry for our focus on customer service, our
highly trained staff, and our high-end speakeasy theme decor concept. In each location the front
waiting area is designed and finished as an entirely different kind of business, including a gas
station, a Chinese restaurant, a record store, and a casino, with the licensed dispensary beyond it.
The concept gives customers a distinctive and memorable retail experience and has become the
signature of our stores. It carries an incidental benefit for the surrounding community as well, in
that the customer-facing portion of the store presents as an ordinary neighborhood retail space
rather than drawing attention to itself. For the Flossmoor location we propose a botanical and
garden store theme, reflected in the reception area shown on the attached floor plan.
The concept is a matter of interior design rather than concealment. The business will be identified
by name on its exterior signage, and no images of cannabis or paraphernalia will appear in any
window or on any sign viewable from the building exterior, consistent with § 285-16-3D(5). Our
proposed signage is described in the attached Sign Plan.
Number of Employees
When fully staffed, the Flossmoor dispensary will employ approximately 30 to 35 people. All
employees will be at least twenty-one years of age and will hold a credential issued by the Illinois
Department of Financial and Professional Regulation before beginning work at the facility. Staff
will hold a Dispensing Organization Agent Identification Card, and management personnel will
hold an Agent-in-Charge Identification Card. An Agent-in-Charge will be on site at all times that
the dispensary is in operation.
Licensing Information
Aces Dispensary holds a Conditional Adult Use Dispensing Organization License issued by the
Illinois Department of Financial and Professional Regulation for BLS Region 5, ChicagoNaperville-Elgin. The conditional license authorizes the applicant to secure a location and build
out the dispensary. Once the facility is complete and customer ready, the Department will conduct

a final inspection of the premises. The full operating license is issued only upon successful
completion of that inspection. No cannabis will be brought to the site and no sales will take place
before the operating license has been issued.
Hours of Operation
The dispensary will be open to purchasers Monday through Thursday from 9:00 a.m. to 9:00 p.m.,
Friday and Saturday from 9:00 a.m. to 10:00 p.m., and Sunday from 10:00 a.m. to 9:00 p.m. These
hours fall within the limits established by § 200-6-3B of the Flossmoor Municipal Code and by
410 ILCS 705/15-70(j), which permit dispensary operation between 6:00 a.m. and 10:00 p.m.
Related Entities and Preliminary Drawings
The floor plans and security floor plan submitted with this application carry the title block of High
Haven Dispensary. High Haven and Aces Dispensary are related companies. The sole owner of
Aces Dispensary is also the majority owner of High Haven, and the drawings were prepared under
the High Haven title block prior to the formation of the applicant entity. The applicant for this
special use permit is Aces Dispensary.
These drawings are preliminary. Room layouts, fixture locations, and security device placement
are subject to refinement during final design and permitting. Any change to the floor plan or to the
Security Plan will be submitted to the Village for approval, as well as to the Illinois Department
of Financial and Professional Regulation as required under 410 ILCS 705/15-100(b).
Legal Description of the Subject Property
Lots 2 and 3 (except that part of Lot 3 falling within Kedzie Avenue) in Flossmoor Commons,
being a subdivision of that part of the South 1/2 of the Southeast 1/4 (except the North 60 acres)
of Section 11, Township 35 North, Range 13, East of the Third Principal Meridian, lying East of
the East line of Governor’s Highway, as recorded February 27, 1929 as Document 10294759
(excepting therefrom the South 50.00 feet taken for Vollmer Road, as recorded January 18, 1935
as Document 11549019), all in Cook County, Illinois.
Additional Information
We are happy to answer any question that would assist the Village in its review of this application.
If any additional document or information would be helpful, whether in advance of the Plan
Commission hearing or following it, please contact us and we will provide it as promptly as
possible.

95'-6"
16'-11"

47'-1"

15'-0"

26'-0"

6'-0"

8'-0"

5'-0"

7'-4"

safe

HALL

existing
counter

10'-0"

5'-0"

EXISTING
RESTROOMS

25'-6"

6'-0"

counter

counter

closet under
stair

stair

UP

11'-0"

VAULT

RECEPTION

SALES

ADA

pass-thru
boxes (4)

sales counter

counter

(4) POS

37'-7"

RECEIVING

9'-0"

6'-6"

16'-11"
(6) 2'X6'X10' rolling
product shelves

VAULT = 482 SQFT
SALES = 663 SQFT
RECEPTION = 624 SQFT
OFFICE = 150 SQFT
CONSULT = 48 SQFT
BREAK ROOM = 188 SQFT
TOTAL = 3,750 SQFT

FIRST FLOOR
PLAN VIEW
N
- 9'-7 1/2" EXISTING CEILING HIEGHT TO 2X4 TILES (SOME REPLACEMENT REQUIRED)
- RECEPTION AREA TO BE OF A FLOWER SHOP THEME
- 480 sqft UNUSED STORAGE SPACE UPSTAIRS

23'-2"

HIGH HAVEN
DISPENSARY
3327 VOLLMER RD
FLOSMOOR, ILLINOIS
9/02/2026

25'-0"

6'-10"

receiving counter

19'-8"
2'-0"

CLOSETS

13'-0"

OFFICE

HIGH HAVEN
DISPENSARY
3327 VOLLMER RD
FLOSMOOR, ILLINOIS

11'-9"

hatch to
storefront glass
and aluminum

2'-0"

STOREFRONT

9/02/2026
2'-0"

DN

- 480 sqft UNUSED STORAGE SPACE on second floor

15'-1"

I.T. CLOSET

stair

6'-7"

50'-7"

BREAK
ROOM

9'-9"

SECOND FLOOR
PLAN VIEW
N

10'-0"

STORAGE

11'-9 1/2"

STORAGE

95'-6"
16'-11"

47'-1"

15'-0"

pass-thru
boxes (4)

counter

VAULT

PB
PB

WAP

counter

existing
counter

DC

UP

PB
PB

MD

9'-0"

16'-11"
(6) 2'X6'X10' rolling
product shelves

GB

DC

RECEPTION
11'-0"

LPR

MD

MD

closet under
stair

DC

WAP

MD

CR

stair

RECEIVING

PB

CR

(4) POS

alarm
panel

SALES
sales counter

MD receiving counter

PB/DR

counter

DC

ADA

WAP

CR

alarm
panel

VAULT = 482 SQFT
SALES = 663 SQFT
RECEPTION = 624 SQFT
OFFICE = 150 SQFT
CONSULT = 48 SQFT
BREAK ROOM = 188 SQFT
TOTAL = 3,750 SQFT

FIRST FLOOR
- 19 total cameras - 3) fish eye camera, 4) 360 degree cameras, 2) 180 degree exterior cameras, 2)
license plate readers, 1) dual view camera, 7) single view cameras
-5 total motion detectors, 1 glass break detector, 6 push button duress alarms, 1 push button door
release, 6 door contactors, 4 card readers, 2 alarm panels, 3 wireless access point, 8 data connections.

SECURITY
FIRST FLOOR
PLAN VIEW
N

6'-6"

- 9'-7 1/2" EXISTING CEILING HIEGHT TO 2X4 TILES (SOME REPLACEMENT REQUIRED)
- RECEPTION AREA TO BE OF A FLOWER SHOP THEME
- 480 sqft UNUSED STORAGE SPACE UPSTAIRS

23'-2"

HIGH HAVEN
DISPENSARY
3327 VOLLMER RD
FLOSMOOR, ILLINOIS
9/02/2026

LPR

25'-0"

37'-7"

HALL

8'-0"

5'-0"

7'-4"

6'-10"

DC

PB

DC

safe

CR

26'-0"

6'-0"

10'-0"

5'-0"

EXISTING
RESTROOMS

25'-6"

6'-0"

SECOND FLOOR
- 7 total cameras - 4) fish eye camera, 3) single view cameras

19'-8"

-3 total motion detectors, 1 glass break detector, 1 push button duress alarms, 5 door contactors, 2 card
readers, 1 wireless access point, 4 data connections.

2'-0"

11'-9 1/2"

STORAGE

SECURITY
SECOND FLOOR
PLAN VIEW
N

DC

CLOSETS

13'-0"

MD
DC

- 480 sqft UNUSED STORAGE SPACE on second floor

15'-1"

BREAK
ROOM

50'-7"

DC

WAP

I.T. CLOSET

stair

CR

DC

9'-9"

OFFICE

PB

2'-0"

MD

MD

hatch to
storefront glass
and aluminum
DC

STOREFRONT GB

3327 VOLLMER RD
FLOSMOOR, ILLINOIS

11'-9"

DN

HIGH HAVEN
DISPENSARY

CR

9/02/2026
2'-0"

6'-7"

10'-0"

STORAGE

ACES DISPENSARY
Proposed Sign Plan
Flossmoor Commons
Village of Flossmoor, Illinois
Overview
Aces Dispensary ("Aces") is a proposed new lessee within Flossmoor Commons, a multi-tenant
shopping center located in the Village of Flossmoor, Illinois. This document sets out our proposed
approach to exterior signage in support of our application for a special use permit.
This plan is a proposal only. No signage has been designed to final specification, fabricated,
ordered, or installed, and no sign permit application has been submitted to the Village. Final
dimensions, materials, illumination method, and placement will be established during the final
design and planning stages and will be submitted to the Village for review and permitting before
any sign is fabricated or installed.
Coordination with Center Ownership
While navigating the final design and planning stages, we will work directly with the ownership
of Flossmoor Commons to ensure that all exterior signage is the correct size, material, and location.
That coordination will confirm that our signage conforms to the terms of our lease agreement, to
the established sign criteria for the center, and to the proportionate wall sign allowance attributable
to our storefront under § 285-22-9A(2) of the Flossmoor Zoning Code, which apportions the
building total among tenants according to each tenant’s share of the front face of the principal
building.
We will also coordinate with center ownership on the design and materials of our signage so that
it complements the signage of neighboring businesses and preserves the unified appearance of the
center, consistent with the intent of § 285-16-6 governing planned business centers. We will not
fabricate or install any signage until that coordination is complete, the design has been approved
by center ownership, and a sign permit has been issued by the Village under § 285-22-2.
Village Regulations Considered
In preparing this plan we have reviewed and taken into consideration the Village of Flossmoor
sign regulations at Chapter 285, Article XXII; the cannabis dispensing organization conditions at
§ 285-16-3D; the planned business center sign provisions at § 285-16-6F; and the cannabis
advertising restrictions at § 200-6-3C of the Flossmoor Municipal Code. Our proposed signage
will comply with each of the following:
●

Signage will be limited to identification of the business by name and logo, consistent
with § 285-16-6F, which limits signs other than directional signs to advertising the name
of the store.

●

No images of cannabis or paraphernalia will be displayed in any window or advertised by
any sign viewable from the building exterior, as required by § 285-16-3D(5).

●

Total wall sign area will not exceed one tenth of the area of the front face of the principal
building, subject to the 100 square foot building maximum and to our proportionate
tenant share, per § 285-22-9A(1) and (2).

●

No sign will be placed on the roof or in the airspace over the roof, and no sign will
project above the roofline or parapet wall line of the building, per § 285-22-9E and §
285-16-6F.

●

No sign will project more than twelve inches from the building wall, per § 285-22-3D
and § 285-22-9A(3).

●

Signage will be illuminated only by internal or indirect means of an intensity that
prevents excessive glare, with no exposed neon and no flashing, rotating, moving, or
animated elements, per § 285-22-9A(5) and § 285-22-3C.

●

Permanent window signage will be counted against our total allowable sign area, and any
temporary window signage will be limited to twenty percent of the glass area, per § 28522-9G.

●

Signage required to be posted by State law will be limited in content and size to what that
law requires, consistent with the exemption at § 285-22-2C.

●

All signage will be maintained in structurally sound and good condition, per § 285-223K.

We understand that no sign may be painted, constructed, erected, remodeled, relocated, or
expanded until a sign permit is obtained in accordance with § 285-22-2 and Section 35 of the
Building Code, and we will apply for that permit in the ordinary course once the design is final.
Proposed Signage
We anticipate a single front wall sign consisting of dimensional channel letters spelling the
business name, accompanied by our logo, mounted flat to the storefront fascia below the parapet
line. Neighboring businesses with permanent signage at the center use front lit acrylic sign faces,
and we intend to follow that convention so that our storefront reads as part of the center rather than
apart from it. Final letter height, overall sign width, face material, and mounting method will be
set in coordination with center ownership and will be sized to our permitted allowance.
Should center ownership permit and the Village allow, we would also seek a tenant panel on the
existing multi-tenant ground sign serving Flossmoor Commons, ordered to match the style,
proportion, and material of the panels already present. We understand that under § 285-22-9D a
ground sign may be permitted for a multiple-occupancy retail building in addition to permitted
wall signage, and that the existing center ground sign is under the control of center ownership.
Any panel would identify the business by name and logo only.
The specific equipment, fabrication vendor, and materials named or depicted anywhere in this plan
are examples of items that would meet the need identified, and each such reference should be read
as that item or similar. Final selections will be made during the final stages of planning and design
based on availability, suitability to this facility, and the requirements of center ownership and the
Village.

Brand Identity
Our logo consists of a stylized letter "A" with an abstract crescent element, presented in metallic
gold on a dark field, together with the "ACES" wordmark set in a serif typeface. The mark contains
no depiction of cannabis, no cannabis leaf or plant imagery, and no depiction of paraphernalia of
any kind, and is therefore suitable for exterior display and window display under § 285-16-3D(5).

Aces Dispensary logo, proposed for use on exterior signage.

Representative Existing Signage
The photographs below show the exterior signage at our existing dispensary in Plainfield, Illinois.
They are included to illustrate the general character, quality, and materials of our signage program.
They are representative examples only and do not depict the signage proposed for the Flossmoor
Commons location, which will be a wall sign scaled to our storefront and designed to match the
sign criteria of the center.

Existing Aces Dispensary location, Plainfield, Illinois. Representative example only.

Existing wall signage detail, Plainfield, Illinois. Representative example only.

Window Signage and Exterior Lighting
We anticipate displaying a small illuminated "OPEN" sign in the storefront glazing, together with
a posting of our hours of operation. Under § 285-22-9G, permanent window signs are permitted
and are counted against the total allowable sign area for the premises, and we will account for them
in that calculation. Any illuminated window signage will be of steady, constant illumination. We
will not display any flashing, chasing, animated, or moving-light signage, consistent with § 28522-3C. Where § 285-22-3B applies, illuminated signage visible from an adjacent residential
district will not be illuminated between 11:00 p.m. and 7:00 a.m.; our proposed hours of operation
end no later than 10:00 p.m. in any event. Signage that we are required by State law to post,
including our hours of operation and notice that persons under twenty-one years of age are not
permitted on the premises, will be limited in content and size to what the applicable law requires,
consistent with the exemption at § 285-22-2C. No window signage of any kind will contain an
image of cannabis or paraphernalia, as required by § 285-16-3D(5).
The linear accent lighting visible along the parapet of our Plainfield building is not part of the
signage proposed here. Any exterior building lighting at Flossmoor Commons will be developed
with center ownership and will be placed, designed, and used so that neither direct nor reflected
light adversely affects surrounding property or creates a traffic hazard, consistent with § 285-166G. We will not display pennants, streamers, or strings of lights as signage except as may be
permitted for a temporary grand opening display under § 285-22-9M.
Summary
The signage proposed in this plan is limited to identification of the business by name and logo, is
scaled to the proportionate allowance for our storefront, is free of any cannabis or paraphernalia
imagery, and will be developed in coordination with the ownership of Flossmoor Commons and
permitted by the Village before installation. We welcome the opportunity to revise this plan in
response to any comment from Village staff, the Plan Commission, or the Board of Trustees.