MANUFACTURERS OF END PRODUCTS

We will engage with you in a holistic manner so as to have a complete and detailed understanding of your business structure, processes, aims and future aspirations for your enterprise.

We will liaise with you in order to compile a comprehensive dossier which represents a complete record of your entire business and supply chain – absolutely everything from seed to shelf, from manufacture to marketing.

The Canna Consultants does not provide any legal advice or any legal services. We believe that such advice should only come from an identified, independent and professionally regulated individual. In this manner there is absolutely no question about who has provided legal advice, what legal advice they have provided (because it will always and only be in writing), all in a regulated relationship between you and a self-employed barrister in independent practice.

Acting as your intermediary, we will facilitate the instruction of a self-employed barrister in independent practice with expertise in regulatory issues. The barrister will be specially qualified to provide legal advice to receive their instructions directly from you, without the need for the instruction of a solicitor – saving you the dual costs usually associated with the instruction of a solicitor, and then a specialist independent barrister.

The Opinion provided will identify those aspects of your business which the independent, self-employed barrister believes comply with the UK regulatory requirements, plus those areas where there is a need for improvement before Regulatory Compliance would be achieved, all explained in an understandable format which you can thereafter use as a blueprint to work towards compliance.

The barrister will also be asked to comment upon aspects of the business which, while not in breach of any legal requirement, could be improved so as to bring the business up to what might be considered to be the “Best Regulatory Practice”.

Upon receipt of the Opinion from the independent, self-employed barrister, and in the event that it is necessary, The Canna Consultants will provide you with structured proposals for how Regulatory Compliance and Best Regulatory Practice could be achieved and the cost options of the same through the Achieving Regulatory Compliance (ARC) and Achieving Best Regulatory Practice (BRP) services.

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As a result of being involved with you in the compilation of the comprehensive dossier for the instruction of Counsel, which represents a complete record of your entire business and supply chain, including absolutely everything from seed to shelf and from manufacture to marketing, we are able to offer you an additional service through the General Business Health Review (GBHR).

In this review The Canna Consultants will provide an assessment of all aspects of the non-food/non-cannabinoid-centric side of the business. This review will not address legal regulatory or compliance matters – those will have been addressed by the Opinion from the independent, self-employed barrister.

The review will focus on the unregulated, non-legal aspects of your business which we feel could be improved in order to better position your enterprise within the marketplace, such as your:

• Merchant and monetisation structure;
• Online security and transactional safety;
• Branding and Brand protection; and,
• Trademark considerations.

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The Canna Consultants will work with you in order to assist in the implementation of new processes, structures or operational standards necessary in order to achieve compliance with any (compulsory) Regulatory Compliance requirements that were felt to be lacking, as identified by the independent, self-employed barrister in the written Opinion provided to you.

Once compliant, you will then be eligible for:

• The Canna Consultants’ continued Future Regulatory Liaison Service (FRL);
• Advancement to the Accelerated Membership Scheme (AMS);
• Advancement to the Retailers Placement Scheme (RPS);
• Advancement to the Manufacturers Placement Scheme (MPS).

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The Canna Consultants will work with you in order to assist in the implementation of new processes, structures or operational standards necessary in order to achieve compliance with any (voluntary) Best Regulatory Practice requirements that were felt to be lacking, as identified by the independent, self-employed barrister in the written Opinion provided to you.

Once compliant, you will then be eligible for:

• The Canna Consultants’ continued Future Regulatory Liaison Service (FRL);
• Advancement to the Accelerated Membership Scheme (AMS);
• Advancement to the Retailers Placement Scheme (RPS);
• Advancement to the Manufacturers Placement Scheme (MPS).

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For the duration of your subscription (via a monthly fee) you, as an FRL client, will receive liaison assistance in respect of any regulatory enforcement action or enquiry by the FSA, MHRA, Trading Standards or ASA.

If, during your subscription period, you are the subject of any regulatory enforcement action or enquiry The Canna Consultants will discuss with you the subject matter of the action/enquiry and agree with you how you would like to proceed.

In the first instance this is likely to be contacting the enforcement authority on your behalf and discussing with them their concerns and your position in respect of the matter, seeking to identify whether there is any means for a swift and simple resolution that is satisfactory to both parties.

In addition to any specific regulatory liaison, all subscribers to the FRL service will be notified of any changes to any applicable food/cannabidiol-centric (but not general business) regulations or their interpretation, and advised how to achieve compliance with those new changes.

The service is subject to a maximum number of hours engaged per calendar month and the applicable subscription is bespoke to each applicant because, firstly, no two product repertoires are the same and, secondly, different applicants will have differing appetites for the number of hours to be included within the subscription. However, as an FRL client you will receive a discount from our standard chargeable rate for instructed work which exceeds that included within their subscription.

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Due to our relationship with the Leading Trade Associations, if you achieve a Regulatory Compliance assessment with The Canna Consultants, you are eligible to receive expedited assessment for Membership of the Leading Trade Associations.

The Canna Consultants will deal with all aspects of the application process and undertake all facilitation and liaison with the Leading Trade Associations, allowing you to concentrate on your core business rather than accreditation administration.

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The Manufacturing Consistency Assessment Service is targeted for the benefit of wholesalers and retailers of Cannabinoid-containing products.

Under the Manufacturing Consistency Assessment Service The Canna Consultants will organise the testing of your existing product lines. The test results will be compared to the Certification that was provided at your point of purchase of the product line and a comparison will enable an assessment to be made as to the consistency between the two.

In the early life of a relationship it may be thought wise to undertake such testing on an annual basis in order to ensure that the maximum time period between evidence of consistency between the Manufacturer’s Certification and independent certification is 12 months. As a relationship matures and repeat consistency is established, we will discuss with you whether it is suitable to review the frequency period.

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