Advertising & Marketing Compliance

1. Purpose and Scope

This Advertising and Marketing Compliance Policy establishes the standards, procedures, and restrictions governing all advertising, marketing, and promotional activities conducted by Florent Labs, LLC. This policy ensures compliance with Massachusetts 935 CMR 500.105(4) and New Jersey N.J.A.C. 17:30-11.8, as well as applicable federal advertising standards.

This policy applies to all employees, contractors, marketing agencies, and any third parties authorized to create or distribute advertising or marketing materials on behalf of Florent Labs, LLC.

2. Required Elements in All Advertising

All advertising and marketing materials must include:

• Company name and applicable state license number(s)
• "Please Consume Responsibly" (required by Massachusetts 935 CMR 500.105(4)(a)(1))
• "21+ only" or equivalent age restriction statement (required by New Jersey N.J.A.C. 17:30-11.8)
• The Massachusetts health warning statement (935 CMR 500.105(4)(a)(5)) on all advertising distributed in Massachusetts
• The New Jersey health warning statement (N.J.A.C. 17:30-11.5) on all advertising distributed in New Jersey
• Universal THC symbol where product imagery is displayed

3. Prohibited Content

The following content is strictly prohibited in all advertising and marketing materials:

• Any content designed to appeal to individuals under 21 years of age, including cartoons, toys, animals, or characters popular with minors
• Images or depictions of persons under 21 years of age
• Images or depictions of cannabis consumption
• Health, medical, or therapeutic claims unless approved by the FDA (which currently has no approved cannabis products)
• False, deceptive, or misleading statements or claims
• Use of the word "organic" (cannabis cannot receive USDA organic certification due to federal illegality)
• Testimonials or endorsements by individuals under 21
• Unsolicited pop-up advertising on the internet (935 CMR 500.105(4)(a)(11))
• Content that promotes overconsumption or excessive use
• Claims of safety or lack of risk associated with cannabis use
• Comparisons to pharmaceutical or FDA-approved products

4. Placement Restrictions

4.1 Audience Composition

• Massachusetts: Advertising may not be placed in any medium where more than 30% of the audience is reasonably expected to be under 21 years of age (935 CMR 500.105(4)(b)(6))
• New Jersey: Advertising may not be placed in any medium where more than 15% of the audience is reasonably expected to be under 21 years of age (N.J.A.C. 17:30-11.8(a)(3))

Note: When advertising applies to both states, the more restrictive standard (NJ's 15%) must be followed.

4.2 Location Restrictions

• Massachusetts: No advertising within 500 feet of schools, playgrounds, child care facilities, or libraries
• New Jersey: No advertising within 200 feet of schools, playgrounds, child care facilities, or houses of worship
• No advertising on publicly owned or operated property, including public transit (both states)

4.3 Broadcast Restrictions

Television and radio advertising (if used) may only be broadcast during hours and on programs where audience data demonstrates compliance with the applicable audience composition requirements.

5. Digital and Social Media

• All digital platforms must include an age verification gate before displaying cannabis-related content
• Social media accounts must use available age-restriction settings to limit audience to 21+
• No paid social media advertising that cannot be age-restricted to 21+
• All digital advertising must comply with the platform's cannabis advertising policies
• No geotargeting to areas near schools, playgrounds, or other restricted locations

6. B2B Marketing

Marketing materials directed at licensed cannabis businesses (dispensaries, retailers, other manufacturers) are subject to the same regulatory requirements. Even B2B communications must:

• Refrain from making unsubstantiated claims
• Include required disclaimers and warnings
• Not contain prohibited content as described in Section 3
• Accurately represent product specifications, potency, and test results

7. Trade Show and Event Participation

Participation in trade shows, industry events, and sponsorships must comply with all applicable advertising restrictions. Branded merchandise and promotional items must not appeal to individuals under 21 and must comply with all labeling and warning requirements.

8. Record Retention

Copies of all advertising and marketing materials must be retained for a minimum of two (2) years in accordance with state regulatory recordkeeping requirements. These records must be made available to the CCC or CRC upon request.

Records shall include:

• The advertising or marketing material itself
• The medium in which it was placed
• The dates it was active or distributed
• Audience composition data supporting placement decisions
• Approval records (if pre-approval was required by a regulatory authority)

9. Approval Process

All advertising and marketing materials must be reviewed for regulatory compliance before publication or distribution. Materials must be submitted to the CCC or CRC for pre-approval if requested by either regulatory authority.

10. Violations and Corrective Action

Any advertising or marketing material found to violate this policy or applicable regulations must be immediately withdrawn. Violations will be documented, reported to management, and corrective action taken to prevent recurrence. Repeated violations may result in disciplinary action for responsible employees.

11. Contact Information

For questions about this policy, please contact: