# Related-party governance memo

## Objective

Build a defensible related-party ledger and identify governance/document gaps after the NYSE uplisting.

## Publicly disclosed Glass House related-party categories

1. **Beach Front Property Management Inc.** — consulting agreement for M&A advisory and real-estate acquisition/financing services; majority-owned by an executive and certain board members.
2. **Jon A. Neu Insurance** — insurance brokerage services; majority-owned by Beach Front Property Management in public annual filing descriptions.
3. **5042 Real Estate Investment LLC** — partially owned by an executive/board member; leases property to a subsidiary; consolidated in 2025 according to public disclosures.
4. **3645 Long Beach LLC** — partially owned by an executive/board member; headquarters/lease relationship.
5. **Kazan Trust dated December 10, 2004** — trust relationship tied to real-estate leasing.
6. **Preferred equity holders** — certain executive officers/directors hold preferred equity interests in GH Group.

## Rosenwald / Dalton / Beach Front mapping

The public-source task is to determine whether Rosenwald Capital Management, Dalton Investments, Rosenwald Partners L.P., Beach Front I LLC, Beach Front Properties LLC, Beachfront-named entities, and family trusts/LPs are:

- Glass House shareholders or beneficial owners.
- Counterparties to leases, consulting, insurance, financing, or property transactions.
- DCC owners or financial-interest holders.
- Local cannabis permit applicants, owners, or control persons.
- Related parties under SEC/IFRS/Canadian disclosure rules.

No public final finding of illicit activity is established by this memo. The deliverable is a mapping and records-request schedule.

## Records to obtain

- Related-party policy and annual questionnaires.
- Audit committee/independent director approval minutes.
- Agreements, amendments, invoices, and payment ledgers.
- Lease appraisals, rent comps, broker files, insurance placement files.
- CA SOS registrations, statements of information, assumed names.
- County recorder/assessor deeds, leases, DOTs, UCC filings.
- SEC Forms 3/4/5, 13D/G, 13F, ADV, SEDAR/SEDI insider reports.
- DCC owner/FIH records and local cannabis ownership applications.