Sunoco RAMS Compliance Department One Meridian Blvd. Suite 2A01 Wyomissing, PA 19610 ramscompliance@sunocoinc.com Fax #: 877-306-1931 Main Phone: 610-988-2619

Overview Opening/Closing Locations Temp/Partial Temp Close Locations Licenses/Permits Violations Database Maintenance Reporting

Opening/Closing Locations Ground-ups, Acquisitions Assign Co-Op Numbers Co-Op Profile Order starting supplies Opening Procedures Closing Dealer, Distributor, Board-Up, or Permanently closed Closing Procedures All licenses should be returned to RAMS (unless authorized) Note: New Coop numbers must be requested by the Division Operations Manager via email. We never reuse a Co-op number, even if the site used to be a Coop and then was sold or permanently closed and is then reopened as a Coop. Opening and closing procedures are available on the portal. You can also call Compliance for an emailed copy. This is a great tool to use as a checklist when going through the process of opening or closing a site. An example of a license that would not be returned to compliance when a location closes in NY Liquor. Start up supplies: Start up forms – Corporate Express Grab & Go bucket and First aid kit – Hagemeyer Add the store to the office max account Labor law posters

Notifications of Temp/Partial Temp Close Locations Temp Close: Store & Pumps are closed Partial Temp: Store or Pumps are closed At least 2 weeks notice from AOM of dates Temp Close Profile (for rebuilds or remodels) store closings Email is sent out to National Vendors & Selected Sunoco Staff Payroll Efficiency Forecasting Updates CAO: Computer Assistance Ordering When a site temp closes for a long period of time for a raze and rebuild, new pumps and\or store upgrade, we need a temp close profile completed by the area manager. This is available through the Compliance Department at RAMS. This enables us verify that the stores licensing needs have not changed. The importance of notifying Compliance in advance of a temp close or partial temp close is critical. This saves the helpdesk time tracking down why a store is not sending payroll, can prevent unneeded fuel deliveries, notifies the national vendors such as Waste Management to proactively contact the area manager about service changes or possible right sizing issues. Temp close profile should be returned 60 days prior to reopen. Things like new food permits can take 30-60 days to complete.

Licensing Apply for new licenses Renewals Licensing, Inspection, and Violations Policies & Procedures (OP-0410-06-10 ) Research & implement new regulations i.e. PA Food Employee Certification Licensing Management (database) to track the licenses more efficiently. All renewals and new licenses must be applied for by the RAMS Compliance Department. If a store receives something and is unsure what it is, they should fax it to us for review. All inspections and violations must be paid for in the RAMS Compliance Department. Please see Licensing, Inspection and Violations Policies & Procedures available on the Portal and by contacting RAMS Compliance. As for research and new regulations, this is done at times when issues arise and all involved are unclear on the rules and\or laws. If a site would like to go from 18 hours to 24-hours, please contact RAMS Compliance to verify that there are no local or county issues. When putting up new signage, please notify RAMS Compliance. Many jurisdictions are now requiring licenses for this or not permitting new signage.

Types of Licenses Food Stamp Program Alcohol/Liquor Tobacco/Cigarette Business Lottery ATF Tax Stamp Vendor Motor Fuel Alarm Sign Food Health Drug & Device Weights & Measures Scanning Logo Occupational Sell of Soft Drinks This is a good time to mention seasonal items or last minute service offerings. If a store only has iced cappuccino in the summer, we need to know that. If the store stops by the local bakery gets a couple dozen fresh bagels, donuts, pastry or Faschnachts to sell at the store, we need to know ahead of time. For many towns\counties\states, this is against the food licensing guidelines. We can be cited and fined for this type of activity. If the store received a notice from the town or county about a new ordinance for such things as recycling, grease traps, wastewater etc. it should be faxed to Compliance. We can coordinate with our Philadelphia office or Exton office on these types of things and save the store and area manager time.

Environmental Compliance Located at 1735 Market St. Kathy McCaney - Permits and Tank Registrations - 215-246-8513 Anna Morley - Compliance Testing of UST and Stage 2 System - 215-977- 3205 Sandy Carl - Site inspections and Violations - 215-977-6801 Bryan Giran - Inventory Control and Leak Detection (Southern States) - 215-977-6580 Fred Smith - Inventory Control and Leak Detection (Northern States ) - 215-977-6212 Fire Inspections\violations Underground Storage Tank Registration (UST)\Crompco Stage II Vapor Recovery Reports Air Pollution Veeder Root Environmental Compliance Reports/Inspections can be faxed to: 866-903-4195. If unsure which department to send it to, please forward to RAMS Compliance and we will forward it to the appropriate party.

How many licenses do our 581 stores have? 5,039 15 states (PA, RI, WV, MA, NY, NH, ME, NJ, FL, SC, TN, NC, OH, VA, DE) Federal, State, County and Local levels Approximate cost of our renewals in 2006 is $1,246,502. In 2005, our renewal cost was $834,177 and we had more stores. Our licensing database has enabled us to track the licenses more efficiently. We were able to catch renewals that had been done at the store in the past.

Violations Underage Sales of Alcohol/Tobacco False Alarm Notifications Alcohol or Tobacco Internal Incident Report must be completed and sent to RAMS Compliance. False Alarm Notifications Trash Food/Health Inspection Reports Scanning Sign LP Gas Weights & Measures Zoning Internal form. On all violations (whether there is a fine or not) the Division Manager is copied. On all tobacco violations the tobacco category manager and Sunoco legal is copied. On all liquor violations Sunoco legal is copied. On all food related violations, the category manager is copied. All violations must be paid from Compliance. All inspection reports must be faxed to Compliance. These are passed on to the Area Manager. If there are violations or critical violations, the division manager is copied. Instances where once a violation is corrected, we have to notify the agency in writing how the violation was corrected and why we allowed it to happen, the store manager or area manger is to convey this information to RAMS Compliance so that we can send the reply via FedEx on letterhead. Examples would be Erie County, NY Weights & Measures notes on an inspection that fill port covers need to painted or TN Food critical food violation notices. A monthly violation report is sent to the division managers as well as other key personnel.

SNAP – Food Stamp Program Review requirements before requesting\complete survey 148 Coop’s on SNAP and we are adding 13 more Florida stores 4-6 week period to process application Sheryl Hess, V.P. signs off on the application Fines run up to $10,000 for each illegal transaction x 3 times dollar 6 months to reapply if the site is not approved Call Retail Compliance if EBT machine stops working EBT machine be removed machine can be removed If you have less than $100.00 in redemption activity for more than one USDA conducts routine checks (mystery shop)

What must you sell on a regular bases to qualify?

Database Maintenance Station Master TPX (Customer Master) PDI (RMS) Changes AOM DOM DQA Open/Close Locations Store address (i.e. 911 changes or PO Box) Fax and Phone number Please make sure that all address changes are sent to RAMS Compliance via email ASAP. We update many computer systems with this information and may potentially affect the licenses. This is happening often right now.

Each Coop’s licenses are tracked by State (includes Federal such as Food Stamps and ATF Licenses), county, or local level using Station Master.

When a renewal arrives, the date it arrived is entered into the database. The database tracks when the renewal is due and when the license expires. The database tracks check request date, date the payment\renewal was mailed and the date we sent the new license out to the store. There is also a place for important notes about each license.

Each month we run a renewal report Each month we run a renewal report. This lists all renewals due for that month. If the renewal is not received within 30 days of the renewal date, we call the agency.

We can provide a store or area manager with a list of licenses the store should have displayed. The store manager or area manager can call and request this type of report for any location at any time. Once a year, usually in the first quarter, we send each area manager a report for each of their locations. This allows them to proactively check to make sure all locations have the licenses posted that are required. We keep copies of all licenses in Compliance and we can provide a copy anytime. Some licenses, such as liquor, have to be originals. If the store has lost one of these, we have to order a duplicate and there is usually a fee charged by the licensing agency for this. An example would be NY liquor license. We have to have a police report and a $5.00 fee to obtain a dup.

We are able to use Microsoft Access to create custom reports.

We added a category field for all licenses We added a category field for all licenses. This enable us to track the cost per category. We also have a field to track where the new license is sent (RAMS, MBC, STORE) and who is responsible for the renewal (RAMS or MBC).

In 2006, Compliance & Admin reviewed every Coop file (yes, all 5,039 of them!) to ensure we have copies of all of our licenses. In the event the store misplaces one, we can fax them a copy. During the review process, we discovered that numerous renewals were being handled at store level. We are now doing them in house thus making our tracking more accurate. Result? The Station Master Licensing module has enabled Compliance to have 100% on- time renewals!