Diversion of cannabis to individuals not qualified under regulations to purchase or possess it would expose a company to legal risk and undermine its credibility with the community in which it operates (check out our “Detecting and Preventing Diversion” training).
Below are a few strategies that cannabis business operations can employ to prevent diversion.
- Appropriate security and access control measures should be implemented in any area of a facility that may contain cannabis. For example, security cameras should be installed in rooms where cannabis will be cultivated, received, examined, stored, processed, or otherwise handled.
- Cannabis and cannabis products should be tracked from cultivation through the sale and weighed at regular intervals or when appropriate based on changes in custody or form.
- Operations should maintain controlled-access areas to ensure that only authorized employees handle any cannabis on-site. Comprehensive records of employee activity within controlled-access areas should be maintained to prevent diversion and facilitate the identification of any employee who may attempt to illegally divert cannabis.
- Staff should be informed of the business operator’s commitment to legal compliance and non-diversion and warned of the consequences (ex. termination, prosecution) of violating laws and established policies and procedures.
- Post your written non-diversion policy in a prominent location where all employees will see it (ex. a staff break room).
- Refuse to do business with people or with other operations that are known to divert cannabis.
Providing Sufficient Security
Keeping the customers and the communities they serve safe should be cannabis operations’ top priority. To ensure safety, well-run facilities adopt a security plan consisting of a set of practices and strategies that work together to maintain safety and community standards.
An operation’s security plan may involve the following elements:
- Employing trained professional unarmed security personnel.
- Restricting access to the facility to authorized persons.
- Using appropriate security technology and equipment to monitor and secure the facility (video surveillance, panic buttons, safes, locking doors, etc).
- Maintaining communication with local law enforcement.
- Training dispensary staff to prevent and respond to emergencies.
- Educating staff and members as to their rights and responsibilities under the law.
Steps should be taken to ensure that all financial transactions remain secure. Protect credit card information, and provide customers with a secure area to make payments. Most retail businesses do cash drops throughout the day, removing excess money from the cash register and securing it in a safe away from where it is collected.
Risk can be further managed by making bank deposits on a schedule that varies to ensure that no one will become familiar with the deposit schedule. Cash should always be removed from buildings and transported discreetly (ex. in a purse or backpack, tucked under a coat, etc). Businesses may also be able to minimize risk by accepting credit card payments in lieu of cash.
Keeping a minimal amount of inventory on hand is also a good precaution. Products not displayed for purchase or being packaged should be stored in a locked safe. The combination should be carefully guarded to prevent unauthorized access. However, there should always be at least one (1) person on site who can open the safe.
This will facilitate smooth operations and may be imperative for preventing trouble in the event of an armed robbery. Alternatively, facilities may opt for a time-lock safe, which will only open after a predetermined amount of time. Time-lock safes are common tools for stopping or preventing robberies.
Develop Security Culture
In this context, “security culture” refers to a shared set of customs among members of a community that is subject to police surveillance. The culture is developed as the following of security protocols is internalized, becoming second nature.
For example, learning and putting into practice the principle that sensitive information should only be disclosed on a need-to-know basis until that becomes one’s default behavior promotes security both by reducing the risk that sensitive information will fall into the wrong hands and by reducing the number of people with knowledge of the sensitive information that law enforcement officers could attempt to turn.
It is impossible to overstate the importance of developing solidarity and a “security culture” within the cannabis community given their role in keeping members of the community safer. Law enforcement agents frequently aim to turn people against each other and disrupt the community. Additionally, it’s important to note that the inappropriate sharing of sensitive information in social settings can increase the risk of robbery.
For example, if some dispensary employees head to a bar after work in clothing that identifies their employer and one casually remarks to the other over drinks that the dispensary’s cash will be transferred to the bank at noon the following day, any would-be robbers within earshot would know when and where to find what could conceivably be a very valuable target.
Members of the cannabis community mustn’t gossip, brag, or ask about compromising or unnecessary information about cannabis operations and their activities. Although such behavior may be entertaining, it increases one’s risk of arrest and robbery. Before discussing personal involvement in cannabis operations, one must consider whether the other person or people party to the conversation would repeat what they are told to anyone else, either voluntarily or under police coercion, and whether that information could be used in criminal proceedings.
One must also consider whether one would want the other parties in the conversation to have to perjure themselves if called upon to testify, which would expose them to serious risk. Members of the community who are careless in their handling of sensitive information should be spoken to about the importance of maintaining a culture of security.
Those who continue to gossip, brag, or seek unnecessary information about sensitive topics after repeated corrective talks are grave risks at best. The possibility that they may be law enforcement officers attempting to gather intelligence or entrap others should not be discounted.
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