NABCA 19 TH ANNUAL LEGAL SYMPOSIUM ON ALCOHOL BEVERAGE LAW & REGULATION Erin L. Neff Senior Attorney Litigation and Regulatory Law Department March 6, National Retailer Perspectives

Over 7,800 retail drugstore locations 2011 sales were $72 billion Over 247,000 employees 6.1 million customers served daily A typical store: Total size: 14,500 square feet Sales area: 11,000 square feet Items for sale: 18,000 Employees: Annual sales: $9 million 2

Getting Back Into the Business... Walgreen Co. was once one of the largest retailers of alcoholic beverages in the nation before phasing the offering out in the 1990s. Walgreen Co. made a decision in 2009 to pursue alcoholic beverage licenses in 39 states, Puerto Rico and Washington DC. We took lessons learned from past experiences and combined them with today’s technology to create new tools to further compliance, licensing and training. An alcohol team was assembled with representatives from every major corporate department including Legal, Government Relations, Store Operations, Compliance, Merchandising, License Administration, Loss Prevention, Internal Audit, IT and Learning Services to name a few. By the end of 2011, we held more than 5,500 licenses. 3

Challenges 4 Coordination of Corporate Departments Licensing Compliance Marketing Regulation and Government Affairs

Coordination of Corporate Departments 5 Single Point of Contact (SPOC) Clearly Defined Roles (and knowing when to go beyond them…) Compilation of Data

Licensing Application and Renewal Process Nuances Corporate Officer and Board Member Information and Fingerprints Hearings 6

Compliance Training and Policies Enforcement Citations and Compliance Hearings 7

Marketing Weekly Circulars Promotions Online Advertising and Web Pickup 8

Regulations and Government Affairs Meshing Modern Technology with Regulations Expectations of Regulators Managing Network of Outside Counsel 9

NABCA 19 TH ANNUAL LEGAL SYMPOSIUM ON ALCOHOL BEVERAGE LAW & REGULATION Erin L. Neff Senior Attorney Litigation and Regulatory Law Department March 6, National Retailer Perspectives