# Glass House Brands (GLAS) — Related-Party Transaction & Entity Network Ledger
**Research Date:** July 9, 2026
**Sources:** SEC EDGAR filings (6-K, 20-F), SEDAR+, Glass House Brands website filings, Wikipedia, Grokipedia, SEC AIF

> **⚠ VERIFICATION STATUS (updated 2026-07-09):** See **`glas_verification_and_actions.md`** for the verification pass. Corrections affecting this file: founders' voting power is **~76% non-diluted / ~64.6% diluted** per the FY2025 AIF (not 77.3% / 65.5%; the 77.46% figure is GLAS's control of *MPB Acquisition Corp.*, a different metric). The Beach Front / Rosenwald link is documented as **Rosenwald Capital Management, Inc. being a co-manager of Beach Front Properties LLC (with Kyle Kazan)** — not "director of Beach Front." **5042 Real Estate Investment LLC** and **2000 De La Vina LLC** are GLAS corporate/subsidiary vehicles (managers GH RE Manager LLC → GHB Usub, and GH Group Inc.), **not** insider landlords. Jon A. Neu Insurance's parent is named inconsistently across filings (Beach Front Property Management Inc. vs. Beach Front Properties LLC).

---

## EXECUTIVE SUMMARY

Glass House Brands Inc. (NYSE: GLAS) has an extensive network of related-party transactions primarily involving real estate leases, consulting agreements, insurance brokerage, and preferred equity arrangements. The vast majority of these transactions flow through entities controlled by **Kyle Kazan** (Co-Founder, Chairman & CEO) and **James B. Rosenwald III** (Co-Founder of Dalton Investments and Beach Front Properties), who together with their family members form the "Company Founders" group holding ~76% of voting power (~64.6% diluted) via Multiple Voting Shares.

The related-party ecosystem includes at least **8 distinct real estate entities**, a property management/consulting company, an insurance brokerage, a family trust, and investment firms — all connected to Glass House insiders.

---

## KEY INSIDERS

### Kyle D. Kazan — Co-Founder, Chairman & CEO
- **Role at GLAS:** Chairman & CEO since June 2021 (previously CEO of GH Group since 2018)
- **Background:** Former Torrance PD officer (1995-1999), real estate investor since 1991
- **Founder of:** Beach Front Property Management, Inc. (1999–present); Beach Front Properties, LLC (co-founded 1997 with Rosenwald)
- **Other roles:** Director of Dalton High Yield Mortgage Fund (since 2012); Director of Kings Bay Investment Company, Ltd. (since 2013)
- **Related entities controlled/owned:** Beach Front Property Management Inc. (founder/chairman), Beach Front Properties LLC (co-founder/managing member), Kazan Trust (trustee), and partial ownership of multiple real estate LLCs
- **Source:** SEC AIF (Exhibit 99.3, FY2024); Wikipedia (Kyle Kazan); GLAS Board of Directors page

### James B. Rosenwald III — Co-Founder of Beach Front Properties / Dalton Investments
- **Role at GLAS:** Not a director or officer of GLAS directly, but is a "Company Founder" holding Multiple Voting Shares
- **Background:** Co-founder & CIO of Dalton Investments LLC (1999–present); Chairman & CEO of Rosenwald Capital Management, Inc. (since 1984); Managing Member of Beach Front Properties, LLC (since 1997); Director of Beach Front Property Management, Inc. (since 2010)
- **Education:** A.B. Economics, Vassar College (1980); MBA, NYU Stern (1984); CFA (1987)
- **Dalton Investments AUM:** ~$5.4 billion (as of June 2025)
- **Rosenwald Capital Management:** Holds majority ownership in Dalton Investments
- **Family connections:** Father of James Rosenwald IV and Jocelyn Rosenwald (both GLAS Company Founders); spouse of Laura Parker Rosenwald (also a Company Founder)
- **Source:** Grokipedia (James B. Rosenwald); SEC AIF; Spokeo public records; Nippon Active Value Fund prospectus

### Jocelyn Rosenwald — Director
- **Role at GLAS:** Director since June 2021; Chair of Audit Committee; member of Product Expansion Committee
- **Background:** Licensed California real estate broker; began career at Beach Front Properties LLC in 2013 managing $500M portfolio; Board member of Dalton Investments LLC (~$6B AUM)
- **Relationship to James Rosenwald III:** Family member (daughter, per public records)
- **Source:** SEC AIF; GLAS Board of Directors page; Spokeo

### Other "Company Founders" (Multiple Voting Share holders)
Per the FY2024 AIF, the "Company Founders" are collectively:
1. **Kyle Kazan**
2. **Graham Farrar** (Co-Founder, President & Director)
3. **James Rosenwald III** (and IV)
4. **Laura Parker Rosenwald** (spouse of James III)
5. **Jocelyn Rosenwald** (daughter of James III)
6. **Kris Hulgreen** (executive at Beach Front Property Management)

These founders hold **~76% of voting power** on a non-diluted basis (~64.6% diluted) through Multiple Voting Shares (50 votes per share vs. 1 vote per Equity Share). *(Per the FY2025 AIF, dated March 24, 2026, as of December 31, 2025. The previously-cited "77.3%" was a conflation with GLAS's ~77.46% control of MPB Acquisition Corp.)*
- **Source:** SEC AIF (Exhibit 99.3, FY2024), page 45

### Original "GH Group Founders" (pre-IPO)
Per the April 2021 transaction documents, the original GH Group Founders were:
1. Kyle Kazan
2. Graham Farrar
3. Jamie (James) Rosenwald
4. Benjamin Persky (son of Steve Persky, Dalton Investments co-founder)
5. Kris Hulgreen
6. Steven Persky (Dalton Investments co-founder)
7. Hans Tiedemann
- **Source:** SEC 6-K filing, Exhibit 99.70 (April 2021)

---

## RELATED-PARTY ENTITY LEDGER

### 1. Beach Front Property Management, Inc. (BFPM)

| Field | Details |
|-------|---------|
| **Ownership Structure** | Majority-owned by Kyle Kazan (founder/chairman); James Rosenwald III is a Director (since 2010); Kris Hulgreen is an executive |
| **Relationship to GLAS Insiders** | Founded by Kyle Kazan (GLAS Chairman/CEO) in 1999; James Rosenwald III (GLAS Company Founder) serves as Director |
| **Nature of Transactions** | Consulting agreement with GLAS dated September 28, 2020 — provides M&A advisory and real estate acquisition/financing services |
| **Dollar Amounts** | Monthly consulting fee: ~$11,000 (increased from ~$10,860 in earlier years). Q1 2026: $53,000; Q1 2025: $35,000. H1 2025: $70,000 |
| **Address** | 1212 Long Beach Blvd, Long Beach, CA 90813 |
| **DRE License** | #01254940, #01254939 |
| **Disclosure Source** | SEC 6-K (Q1 2026 Financial Statements, Note 18); SEC 6-K (Q2 2023, Note 19); SEC 6-K (Q2 2025 MD&A); GLAS AIF FY2024 |

### 2. Beach Front Properties, LLC

| Field | Details |
|-------|---------|
| **Ownership Structure** | Co-founded 1997 by Kyle Kazan and James B. Rosenwald III; both serve as Managing Members |
| **Relationship to GLAS Insiders** | Co-owned by Kyle Kazan (GLAS CEO) and James Rosenwald III (GLAS Company Founder); Jocelyn Rosenwald (GLAS Director) is Managing Director with $1B+ AUM |
| **Nature of Transactions** | Majority owner of Jon A. Neu Insurance (insurance brokerage entity that serves GLAS). The entity itself is described as having ~$5B+ AUM (per GLAS board bio of Kazan) |
| **Dollar Amounts** | No direct transactions with GLAS disclosed; transactions flow through subsidiary Jon A. Neu Insurance and BFPM |
| **Disclosure Source** | SEC 6-K (Q1 2026 Financial Statements, Note 18 — Jon A. Neu Insurance section); GLAS Board of Directors page; Wikipedia (Kyle Kazan); Grokipedia (James B. Rosenwald) |

### 3. Jon A. Neu Insurance

| Field | Details |
|-------|---------|
| **Ownership Structure** | Majority owned by Beach Front Properties LLC (per Q1 2026 filing); described as "majority owned by Beach Front Property Management Inc." in FY2025 audited financial statements |
| **Relationship to GLAS Insiders** | Indirectly controlled by Kyle Kazan and James Rosenwald III through Beach Front entities |
| **Nature of Transactions** | Provides insurance brokerage services to Glass House Brands |
| **Dollar Amounts** | Q1 2026: ~$82,000; Q1 2025: ~$150,000 in insurance brokerage expense |
| **Note on Ownership Discrepancy** | Q1 2026 6-K states "majority owned by Beach Front Properties LLC"; FY2025 audited FS state "majority owned by Beach Front Property Management Inc." — possible cross-ownership or filing inconsistency |
| **Disclosure Source** | SEC 6-K (March 31, 2026, Note 18); FY2025 Annual Audited Financial Statements; SEDAR+ filing (May 2026) |

### 4. 5042 Real Estate Investment, LLC

| Field | Details |
|-------|---------|
| **Ownership Structure** | Partially owned by an executive and board member of the Company (not further specified in filings) |
| **Relationship to GLAS Insiders** | Owned by GLAS insider(s); GLAS became the manager of the LLC (per 2022 audited FS) |
| **Nature of Transactions** | Owns an undivided tenancy-in-common (TIC) interest in a property leased to a GLAS subsidiary |
| **Lease Terms** | 10-year lease commencing August 2022; initial annual base rent: $222,000, increasing 3% per annum |
| **Dollar Amounts** | Q1 2026 rent: $61,000; Q1 2025 rent: $55,000 |
| **Property** | Likely Lompoc, CA area (associated with Lompoc TIC, LLC in filings) |
| **Disclosure Source** | SEC 6-K (March 31, 2026, Note 18); SEC 6-K (Q2 2023, Note 19); FY2025 Annual Audited FS; 2022 Amended Audited FS |

### 5. 3645 Long Beach LLC

| Field | Details |
|-------|---------|
| **Ownership Structure** | Partially owned by an executive and board member of the Company |
| **Relationship to GLAS Insiders** | Owned by GLAS insider(s) — likely Kyle Kazan (address matches GLAS HQ) |
| **Nature of Transactions** | Five-year lease with a GLAS subsidiary for GLAS headquarters at 3645 Long Beach Boulevard, Long Beach, CA 90807 |
| **Lease Terms** | Original lease commenced December 2019; initial annual base rent $64,477, increasing to $69,352 for year two, then 5% per annum. **Renewed** for five years starting January 1, 2025 at base rent of $93,000, increasing annually by greater of 3% or CPI (capped at 5%) |
| **Dollar Amounts** | Q1 2026 rent: $37,000; Q1 2025 rent: $20,000. H1 2025 rent: $40,000. H1 2023 rent: $38,230 |
| **Disclosure Source** | SEC 6-K (March 31, 2026, Note 18); SEC 6-K (Q2 2023, Note 19); SEC 6-K (Q2 2025 MD&A); 2022 Amended Audited FS |

### 6. 2000 De La Vina LLC

| Field | Details |
|-------|---------|
| **Ownership Structure** | Partially owned by executives and board members of the Company (plural — multiple insiders) |
| **Relationship to GLAS Insiders** | Owned by multiple GLAS insiders |
| **Nature of Transactions** | Two leases with GLAS subsidiaries for property in Santa Barbara, CA |
| **Lease Terms** | Both leases commenced July 2022, 10-year terms. Lease 1: initial annual base rent $60,000, increasing 3% annually. Lease 2: initial annual base rent $180,000, increasing 3% annually |
| **Status** | Lease 1 terminated in 2025 in connection with sale of underlying property; GLAS entered negotiated termination payment agreement |
| **Dollar Amounts** | Q1 2026 rent: $49,000; Q1 2025 rent: $60,000. Q1 2026 termination payment: $27,000 |
| **Entity Status (2022 FS)** | Listed as a non-controlling interest entity: "2000 De La Vina LLC, Santa Barbara, CA, Real Estate" — GLAS held 0% ownership, 100% non-controlling interest (per 2022 Amended Audited FS entity table) |
| **Disclosure Source** | SEC 6-K (March 31, 2026, Note 18); SEC 6-K (Q2 2023, Note 19); 2022 Amended Audited FS |

### 7. Kazan Trust (dated December 10, 2004)

| Field | Details |
|-------|---------|
| **Ownership Structure** | A trust of which the trustee is an executive and board member of the Company |
| **Relationship to GLAS Insiders** | Trustee is Kyle Kazan (GLAS Chairman/CEO). The trust is dated December 10, 2004 |
| **Beneficiaries** | Not specifically disclosed in SEC filings. Kyle Kazan's wife is Diane Kazan (per Wikipedia). The trust likely benefits Kazan family members |
| **Nature of Transactions** | In August 2022, the Kazan Trust acquired partial ownership of a real estate entity that entered into a 10-year lease with a GLAS subsidiary |
| **Lease Terms** | Lease commenced July 2022; initial annual base rent: $36,489, increasing 3% per annum thereafter |
| **Dollar Amounts** | Q1 2026 rent: $10,000; Q1 2025 rent: $9,000. H1 2025 rent: $18,000. H1 2023 rent: $18,245 |
| **Disclosure Source** | SEC 6-K (March 31, 2026, Note 18); SEC 6-K (Q2 2023, Note 19); SEC 6-K (Q2 2025 MD&A); 2022 Amended Audited FS; GLAS Q2 2023 filing (tm2322983d1_ex99-1.htm) |

---

## ADDITIONAL RELATED-PARTY ENTITIES (Disclosed in GLAS Filings)

### 8. Neo Street Partners LLC

| Field | Details |
|-------|---------|
| **Ownership Structure** | Partially owned by an executive and board member of the Company |
| **Nature of Transactions** | Five-year lease with GLAS subsidiary (CA Manufacturing Solutions LLC) for property in Lompoc, CA |
| **Lease Terms** | Commenced October 2018; initial annual base rent $213,049, increasing to $243,491 for years 2-5. Renewed for one year starting October 2024 |
| **Key Event** | On August 18, 2025 (per Q1 2026 filing) / April 15, 2025 (per Q2 2025 MD&A), GLAS acquired the remaining 76% undivided ownership interest in the Lompoc property, eliminating future related-party rent |
| **Dollar Amounts** | Q1 2026 rent: $0 (property acquired); Q1 2025 rent: $93,000. Q2 2025 rent: $94,000. Historical annual: ~$243,491 |
| **Disclosure Source** | SEC 6-K (March 31, 2026, Note 18); SEC 6-K (Q2 2023, Note 19); SEC 6-K (Q2 2025 MD&A); GLAS AIF FY2024 (Material Contracts) |

### 9. Isla Vista GHG LLC

| Field | Details |
|-------|---------|
| **Ownership Structure** | Partially owned by executives and board members of the Company (plural) |
| **Nature of Transactions** | Ten-year lease with GLAS subsidiary for retail cannabis location in Isla Vista, CA |
| **Lease Terms** | Initial monthly rent $5,000 starting April 19, 2022 until Commencement Date; then $144,000 annual base rent increasing 3% per annum |
| **Dollar Amounts** | Q1 2026 rent: $39,000; Q1 2025 rent: $36,000. H1 2025: $72,000 |
| **Disclosure Source** | SEC 6-K (March 31, 2026, Note 18); SEC 6-K (Q2 2023, Note 19); SEC 6-K (Q2 2025 MD&A) |

---

## INVESTMENT FIRM ENTITIES

### 10. Rosenwald Capital Management, Inc.

| Field | Details |
|-------|---------|
| **Ownership Structure** | Registered investment advisor since 1984. James B. Rosenwald III serves as Chairman & CEO. Holds **majority ownership** in Dalton Investments LLC |
| **Relationship to GLAS Insiders** | Controlled by James B. Rosenwald III, a GLAS Company Founder holding Multiple Voting Shares |
| **Nature of Transactions with GLAS** | No direct transactions disclosed in GLAS financial statements. However, both Rosenwald Capital Management and Dalton Investments are disclosed as **shareholders of Glass House Brands** (per Japanese regulatory filing) |
| **RIA Registration** | CRD #801-112520 |
| **AUM (Dalton)** | ~$5.4 billion (as of June 2025) |
| **Disclosure Source** | Grokipedia; RIAbase; Japanese securities disclosure (Yahoo Finance Japan, Aug 2025); Nippon Active Value Fund prospectus; KCERA Board agenda (Sept 2023 — "Rosenwald owns 51% of Dalton Investments through Rosenwald Capital Management") |

### 11. Dalton Investments LLC

| Field | Details |
|-------|---------|
| **Ownership Structure** | Co-founded 1999 by James B. Rosenwald III, Steven D. Persky, and Gifford Combs in Santa Monica, CA. Majority-owned by Rosenwald Capital Management (51% per KCERA board agenda) |
| **Relationship to GLAS Insiders** | Co-founded by James B. Rosenwald III (GLAS Company Founder). Jocelyn Rosenwald (GLAS Director) serves on the Board of Dalton Investments. Kyle Kazan (GLAS CEO) co-managed the Dalton Distressed Mortgage Fund with Steve Persky since 1997, and has been Director of Dalton High Yield Mortgage Fund since 2012 |
| **Nature of Transactions with GLAS** | No direct operating transactions disclosed. Dalton Investments and Rosenwald Capital Management are **shareholders** of Glass House Brands |
| **AUM** | ~$5.4 billion (June 2025); ~$4.2 billion (December 2024) |
| **Disclosure Source** | Grokipedia; Wikipedia (Kyle Kazan); GLAS Board of Directors page; Japanese securities disclosure; KCERA Board agenda |

### 12. Rosenwald Partners L.P.

| Field | Details |
|-------|---------|
| **Ownership Structure** | Limited Partnership associated with the Rosenwald family |
| **Relationship to GLAS Insiders** | Connected to James B. Rosenwald III (GLAS Company Founder) |
| **Nature of Transactions** | A Japanese tender offer document (Mita Securities, January 2023) references "Rosenwald Partners LP" and "Kings Bay Investment Company Ltd." in connection with borrowing/lending arrangements. The document also references Rosenwald's role at Beach Front Property Management (Director since 2015) |
| **Dollar Amounts** | Not specifically disclosed in GLAS filings |
| **Note** | This entity does NOT appear directly in Glass House Brands' SEC/SEDAR+ related-party transaction disclosures. It appears in Japanese regulatory filings related to Rosenwald's broader investment activities |
| **Disclosure Source** | Japanese tender offer prospectus (Mita Securities, January 10, 2023); SEC 20-F filing references to Kings Bay transactions |

---

## FAMILY TRUSTS & LIMITED PARTNERSHIPS

### 13. Preferred Mezzanine Equity Transactions (GH Group Preferred Shares)

| Field | Details |
|-------|---------|
| **Nature** | Certain executive officers and directors of GLAS hold preferred equity interests in GH Group, Inc. (a consolidated subsidiary) |
| **Instruments** | Series B, C, D, and E Preferred Stock in GH Group, Inc. |
| **Transactions** | Related-party holders receive preferred dividends on a pro rata basis per contractual terms |
| **Dollar Amounts** | Q1 2026 preferred dividends to related-party holders: ~$0.5 million; Q1 2025: ~$0.3 million |
| **Terms** | All issuances, conversions, redemptions, and dividend payments completed on same terms as non-related-party preferred stockholders. "No preferential rights or special arrangements were provided to related-party holders" |
| **Disclosure Source** | SEC 6-K (March 31, 2026, Note 18 — Preferred Mezzanine Equity Transactions) |

### 14. Kings Bay Investment Company, Ltd. (KBIC) / Kings Bay Capital Management Ltd.

| Field | Details |
|-------|---------|
| **Ownership Structure** | Cayman Islands company. Kyle Kazan has been a Director since 2013 (per Wikipedia). James Rosenwald III has been a Director since 1998 (per Grokipedia) |
| **Relationship to GLAS Insiders** | Both Kyle Kazan (GLAS CEO) and James Rosenwald III (GLAS Company Founder) are Directors |
| **Nature of Transactions** | Historical lending: KBIC held a "Kings Bay Note" that was assigned to Kings Bay Capital Management Ltd. On June 29, 2021 (GLAS go-public date), all principal and accrued interest under the Kings Bay Note was converted into Preferred Shares of GH Group |
| **Dollar Amounts** | Specific amounts not detailed in the available extracts, but the note was convertible into GH Group equity and was settled as part of the SPAC transaction |
| **Disclosure Source** | SEC 20-F; 2022 Amended Audited FS; GH Group Q1 2021 Financial Statements |

---

## SUMMARY OF RELATED-PARTY TRANSACTION TYPES

### A. Real Estate Leases (Ongoing)
GLAS leases at least **6 properties** from related-party entities controlled by its insiders:

| Entity | Property Location | Annual Base Rent (Initial) | Q1 2026 Rent | Status |
|--------|------------------|--------------------------|-------------|--------|
| Neo Street Partners LLC | Lompoc, CA | $213,049 → $243,491 | $0 (acquired Aug 2025) | **Acquired** by GLAS |
| 3645 Long Beach LLC | Long Beach, CA (HQ) | $64,477 → $93,000 (renewed) | $37,000 | Active (renewed 2025) |
| Isla Vista GHG LLC | Isla Vista, CA (retail) | $144,000 | $39,000 | Active |
| Kazan Trust | Undisclosed | $36,489 | $10,000 | Active |
| 2000 De La Vina LLC | Santa Barbara, CA | $60,000 + $180,000 (two leases) | $49,000 + $27,000 termination | Lease 1 terminated; Lease 2 active |
| 5042 Real Estate Investment, LLC | Lompoc area (TIC) | $222,000 | $61,000 | Active |

### B. Consulting Agreement (Ongoing)
- **Counterparty:** Beach Front Property Management Inc.
- **Services:** M&A advisory, real estate acquisition/financing
- **Monthly Fee:** ~$11,000 (up from ~$10,860)
- **Q1 2026:** $53,000; **Q1 2025:** $35,000

### C. Insurance Brokerage (Ongoing)
- **Counterparty:** Jon A. Neu Insurance (majority owned by Beach Front Properties LLC / Beach Front Property Management Inc.)
- **Q1 2026:** ~$82,000; **Q1 2025:** ~$150,000

### D. Preferred Equity Dividends (Ongoing)
- **Counterparty:** Certain executive officers and directors holding GH Group preferred stock
- **Q1 2026:** ~$500,000; **Q1 2025:** ~$300,000

---

## KEY FINDINGS & ANALYSIS

### 1. Insider Control Concentration
The "Company Founders" (Kazan, Farrar, Rosenwald III & IV, Laura Parker Rosenwald, Jocelyn Rosenwald, Kris Hulgreen) collectively hold **~76% of voting power** (~64.6% diluted) through Multiple Voting Shares (50:1 voting ratio). This means all related-party transactions are effectively self-approved.

### 2. Jon A. Neu — Identity
"Jon A. Neu Insurance" is not a person but an **entity** (an insurance brokerage). The entity is majority-owned by Beach Front Properties LLC (or Beach Front Property Management Inc. — filings are inconsistent). No public information was found identifying a specific individual named "Jon A. Neu" — it appears to be the named entity/brand of the insurance brokerage. No SEC filing or public record identifies Jon A. Neu as a director, officer, or specific insider of Glass House Brands.

### 3. Who Is Behind Rosenwald Capital Management and Rosenwald Partners?
- **Rosenwald Capital Management, Inc.** is controlled by **James B. Rosenwald III** (Chairman & CEO since 1984). It holds 51% majority ownership of Dalton Investments LLC.
- **Rosenwald Partners L.P.** is a limited partnership associated with the Rosenwald family, referenced in Japanese regulatory filings in connection with lending arrangements with Kings Bay Investment Company. It does not appear directly in GLAS related-party disclosures.

### 4. The Kazan Trust
The Kazan Trust dated December 10, 2004 is a trust of which **Kyle Kazan** is the trustee. Kazan is GLAS's Chairman and CEO. Beneficiaries are not specifically disclosed in SEC filings, but Kyle Kazan's wife is Diane Kazan (per Wikipedia), and the trust likely benefits family members. The trust acquired partial ownership of a real estate entity in August 2022 that leases property to a GLAS subsidiary.

### 5. Dalton Investments' Relationship to Glass House
Dalton Investments is co-founded by James B. Rosenwald III (GLAS Company Founder) and Steven D. Persky. Kyle Kazan (GLAS CEO) co-managed the Dalton Distressed Mortgage Fund with Persky since 1997. Jocelyn Rosenwald (GLAS Director) sits on Dalton's board. Dalton Investments and Rosenwald Capital Management are **shareholders** of Glass House Brands. However, no direct operating related-party transactions between Dalton and GLAS are disclosed in financial statement footnotes.

### 6. Are These Entities Controlled by GLAS Directors/Officers/Family?
**Yes — virtually all of them:**
- Beach Front Property Management Inc. → controlled by Kyle Kazan (GLAS CEO); James Rosenwald III (Founder) is Director
- Beach Front Properties LLC → co-owned by Kazan and Rosenwald III
- Jon A. Neu Insurance → majority-owned by Beach Front entities
- 3645 Long Beach LLC → partially owned by an executive/board member (Kazan)
- Neo Street Partners LLC → partially owned by an executive/board member
- Isla Vista GHG LLC → partially owned by executives and board members
- 2000 De La Vina LLC → partially owned by executives and board members
- 5042 Real Estate Investment, LLC → partially owned by an executive/board member
- Kazan Trust → trustee is Kyle Kazan (GLAS CEO)
- Rosenwald Capital Management → controlled by James Rosenwald III (GLAS Founder)
- Dalton Investments → majority-owned by Rosenwald Capital Management

### 7. Entity Network Map
```
Kyle Kazan (GLAS CEO)          James B. Rosenwald III (GLAS Founder)
       │                              │
       ├── Beach Front Property       ├── Rosenwald Capital Management
       │   Management Inc.            │   (51% owner of Dalton Investments)
       │   (Founder/Chairman)         │
       │                              ├── Dalton Investments LLC
       ├── Beach Front Properties     │   (Co-founder/CIO, ~$5.4B AUM)
       │   LLC (Co-founder 1997)      │
       │         │                    ├── Beach Front Properties LLC
       │    ┌────┴────┐               │   (Managing Member since 1997)
       │    │         │               │
       │    ▼         ▼               ├── Beach Front Property Mgmt Inc.
       │  Jon A.   [Other real       │   (Director since 2010)
       │  Neu      estate LLCs]      │
       │  Insurance                   │
       │                              │
       ├── Kazan Trust (Dec 10, 2004)  ├── Rosenwald Partners L.P.
       │   (Trustee)                   ├── Kings Bay Investment Co.
       │                              │   (Director since 1998)
       │                              │
       │                    ┌─────────┴─────────┐
       │                    │                   │
       │              James Rosenwald IV   Jocelyn Rosenwald
       │              (GLAS Founder)       (GLAS Director,
       │                                   Audit Committee Chair,
       │                                   Dalton Investments Board)
       │
       └── Multiple Voting Shares (50:1 voting ratio)
           → ~76% of GLAS voting power (~64.6% diluted) held by
             all Company Founders collectively
```

---

## SOURCES CITED

1. **SEC 6-K filing, March 31, 2026** (Q1 2026 Financial Statements, Note 18 — Related Party Transactions): https://www.sec.gov/Archives/edgar/data/1848731/000184873126000025/glas-20260331xexx991.htm
2. **SEC 6-K filing, June 30, 2025** (Q2 2025 MD&A): https://www.sec.gov/Archives/edgar/data/1848731/000184873125000028/glas-20250630xexx992.htm
3. **SEC 6-K filing, June 30, 2023** (Q2 2023 Financial Statements, Note 19): https://www.sec.gov/Archives/edgar/data/1848731/000110465923091504/tm2322983d1_ex99-1.htm
4. **SEC AIF (Exhibit 99.3, FY2024)** — Annual Information Form dated March 25, 2025: https://www.sec.gov/Archives/edgar/data/1848731/000184873125000007/glas-20241231xex993.htm
5. **SEC 6-K filing, April 8, 2021** (Transaction Summary, Exhibit 99.70): https://www.sec.gov/Archives/edgar/data/1848731/000110465921125828/tm2129199d3_ex99-70.htm
6. **Glass House Brands FY2025 Annual Audited Financial Statements** (PDF): https://glasshousebrands.com/wp-content/uploads/2026/03/2025-GHBI-Annual-audited-financial-statements.pdf
7. **Glass House Brands FY2022 Amended & Restated Audited FS** (PDF): https://glasshousebrands.com/wp-content/uploads/2024/04/2022-Glass-House-Brands-Inc.-Audited-FS-amended-and-restated.pdf
8. **Glass House Brands Q1 2025 MD&A** (PDF): https://glasshousebrands.com/wp-content/uploads/2025/05/Q1-2025-GHBI-Interim-MDA.pdf
9. **Glass House Brands FY2024 Annual MD&A** (PDF): https://glasshousebrands.com/wp-content/uploads/2025/03/2024-GHBI-Annual-MDA.pdf
10. **Glass House Brands Board of Directors page**: https://glasshousebrands.com/about/board-of-directors/
11. **Wikipedia — Kyle Kazan**: https://en.wikipedia.org/wiki/Kyle_Kazan
12. **Grokipedia — James B. Rosenwald**: https://grokipedia.com/page/james_b_rosenwald
13. **Japanese tender offer prospectus** (Mita Securities, January 10, 2023): https://mitasec.com/mita_cms/wp-content/uploads/2023/01/manual20230110.pdf
14. **Japanese securities disclosure** (Yahoo Finance Japan, August 2025): https://finance-frontend-pc-dist.west.edge.storage-yahoo.jp/disclosure/20250825/20250825546831.pdf
15. **KCERA Board Agenda** (September 2023): https://www.kcera.org/files/fb16a6150/23-09-13+BOR+Agenda.pdf
16. **Nippon Active Value Fund Prospectus**: https://www.nipponactivevaluefund.com/wp-content/uploads/2021/09/Prospectus.pdf
17. **RIAbase — Rosenwald Capital Management**: https://www.riabase.com/Sitemap
18. **Spokeo — James Rosenwald** (public records): https://www.spokeo.com/James-Rosenwald/California
19. **Stock Titan — Q1 2026 6-K Summary**: https://www.stocktitan.net/sec-filings/GHBWF/6-k-glass-house-brands-inc-current-report-foreign-issuer-bce517d54f25.html
20. **SEDAR+ filing** (May 2026): https://newsfile.futunn.com/public/NN-PersistNoticeAttachment/7781/20260514/SEDAR_PLUS/CSA_SEDAR_PLUS_NOTICE_RECORD_ID_2406768.pdf

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## NOTES ON LIMITATIONS

1. **Beneficial ownership percentages** of the real estate LLCs (3645 Long Beach, 2000 De La Vina, 5042 Real Estate, Neo Street Partners, Isla Vista GHG) are described only as "partially owned by an executive and board member" or "partially owned by executives and board members" in SEC filings. GLAS does not disclose specific ownership percentages or which specific insiders own interests in each entity.

2. **Jon A. Neu** — Despite extensive searching, no public record identifies a specific individual by this name connected to Glass House or Beach Front. The entity name may be a legacy business name or named after a person not publicly profiled.

3. **Rosenwald Partners L.P.** — This entity does not appear in GLAS's SEC/SEDAR+ related-party transaction disclosures. Its connection to GLAS is indirect, through James Rosenwald III's broader investment network as documented in Japanese regulatory filings.

4. **Kazan Trust beneficiaries** — Not disclosed in SEC filings. The trust is described only as "a trust of which the trustee is an executive and board member of the Company."

5. **California Secretary of State** business entity records were not directly accessible during this research. Entity formation dates, registered agents, and ownership details could potentially be obtained from the California Secretary of State business search at https://businesssearch.sos.ca.gov for additional verification.