Exhibit 19.1

Green Thumb Industries Inc.

POLICY ON INSIDER TRADING

Adopted Effective: February 21, 2024

The Board of Directors (the “Board”) of Green Thumb Industries Inc. (referred to herein, inclusive of its subsidiaries and affiliates, as the “Company”) has adopted this policy (this “Policy”) concerning the rules and procedures governing transactions in Securities (as defined below) by Covered Persons (as defined below).

“Company” shall have the meaning provided above.

“Covered Person” means all employees, officers, directors, agents, contractors, vendors and service providers of the Company and the Related Persons of each such individual. In addition, individuals outside of the Company can become temporary “insiders” who are treated as Covered Persons by having a special confidential relationship with the Company resulting in access to Material Nonpublic Information.

“Designated Insider” shall have the meaning set forth in Section G below.

“Material Nonpublic Information” also referred to as “Inside Information” has the meaning set forth in Section D below.

“Related Person” means, with reference to any person, (i) that person’s immediate family members, (ii) any person living in that person’s household, and (iii) any such person may own or control.

“Securities” means the equity securities (including, without limitation, subordinate voting shares, multiple voting shares and super voting shares) or debt securities, warrants, options, or preferred stock, of, or derivative securities relating to, a company.

“Tipping” means sharing Material Nonpublic Information with a third party, whether or not for compensation or an expectation of profit.

The Company’s reputation for integrity and high ethical standards in the conduct of its affairs is of paramount importance. To preserve this reputation, it is essential that when transacting in Securities, all Covered Persons conform to all applicable laws, including U.S. and Canadian securities laws, and that they avoid even the appearance of impropriety. All Covered Persons must familiarize themselves with this Policy and abide by it. Insider trading is strictly regulated by the corporate and securities laws in the United States and Canada, as well as any stock exchange on which the Securities of the Company are listed. Violations of this Policy may result in civil and criminal penalties under applicable securities laws and disciplinary action by the Company up to and including termination of employment or service.

The obligations of the Company’s General Counsel (or if such role is vacant, the applicable person fulfilling such responsibilities) hereunder may be delegated by the General Counsel to such other member(s) of the Legal Department as the General Counsel may determine from time to time.

Covered Persons may not, directly or indirectly, purchase or sell Securities of the Company while in possession of Material Nonpublic Information concerning the Company. Similarly, Covered Persons may not trade in the Securities of another company if they have obtained Material Nonpublic Information about that company in the course of or in connection with the Covered Person’s employment by or other service to the Company. In addition, Covered Persons are strictly prohibited from Tipping any other person or giving Material Nonpublic Information to another person.

Covered Persons are reminded that they may come into possession of Material Nonpublic Information in the ordinary course of their employment with or other service to the Company. Information that is not considered material to the Company may nevertheless be material to one of those other companies, and it is not permissible for Covered Persons to make use of Material Nonpublic Information gained in the course of their service to or employment with the Company for any reason outside of their scope of responsibilities to the Company.

“Material Nonpublic Information” or “Inside Information” is information that is both material and nonpublic. Whether information is material is difficult to evaluate in the abstract and typically is assessed with the benefit of hindsight. There always is information about the Company that is generally not known to the public. This information is “material” if it would likely to affect the stock price of the Company, or if a reasonable investor would consider it important in making an investment decision (i.e., whether to buy, hold, or sell Securities).

Examples of information, which if not publicly known, could be “Material Nonpublic Information” or “Inside Information” include:

· changes in capital structure including stock splits and stock dividends, or changes in our capital investment plans or corporate objectives;

· a major lawsuit, criminal indictment or governmental investigation;

· development of a significant new product process;

· significant labor disputes or disputes with major contractors or suppliers;

· a change in auditor, substantial changes in accounting methodologies or auditor notification that an issuer may no longer rely on an audit report;

· borrowing or receiving loans for a material amount of money or obtaining significant debt financing; a public or private sale of a material number of additional securities

· material changes or developments in products or contracts which could materially affect earnings upwards or downwards of the Company or its subsidiaries; and

· knowledge of material cybersecurity risks or incidents.

Material information about the Company should be considered nonpublic unless there is a certainty that it is publicly available. For example, Covered Persons should assume that the information is not public unless the information has been disclosed in a press release issued by the Company, in a public filing by the Company (such as a report filed on Form 10-K, Form 10-Q or Form 8-K) made with the U.S. Securities and Exchange Commission (“SEC”) or in materials provided to the Company’s shareholders (such as an annual report, investor letter, prospectus or proxy statement), or is available from the Company through a newswire service or daily newspaper of wide circulation, AND a sufficient amount of time has passed (generally, at least one full trading day on the Company’s primary securities exchange) so that the marketplace has had an opportunity to digest the information. Information about the Company and its Securities will continue to be considered nonpublic even if some information, such as rumors, speculation or similar reports from sources outside of the Company are the only source of publicity.

If you have questions or want clarification on whether particular information is material or nonpublic, please contact the General Counsel of the Company, its Chief Counsel – Securities & Governance or other designee of the General Counsel.

This Policy applies to any sale of stock as part of a broker-assisted cashless exercise of an option, the sale of Securities delivered to the option holder as a result of a “withhold to cover” transaction, or any other market transaction. However, this Policy does not apply to the exercise of options granted under the Company’s employee share and incentive plan, or to the exercise of a tax withholding right, under a “withhold to cover” method for the exercise of the applicable option, where that transaction does not involve the sale of securities on the open market, such as through a broker-assisted transaction.

Please contact the Green Thumb Equity Team ([email protected]) or the Chief Counsel – Securities & Governance, the General Counsel or the General Counsel’s designee if you have questions about whether it is possible to exercise options outside of the application of this Policy.

There should be no trading in any interest or position relating to the future price of the Company’s Securities, including:

All Covered Persons must limit transactions in the Company’s Securities to periods when they can reasonably be satisfied that there are no pending material nonpublic developments that might have a bearing on the market price of such Securities. In addition to this general probation that applies to all Covered Persons, additional restrictions apply on certain Company insiders who routinely have access to Material Nonpublic Information, specifically including:

(collectively referred to as the “Designated Insiders”). A current list of the Designated Insiders shall be maintained by the Chief Administrative Officer or that person’s designee.

Purchases and sales of Securities of the Company by Designated Insiders, and each Designated Insider’s Related Persons, will not be permitted at the following times, when Material Nonpublic Information is deemed reasonably likely to exist:

Hardship Exceptions. Designated Insiders in limited, special circumstances, including an unexpected and urgent need to sell Company Securities in order to generate cash, may, in appropriate circumstances, be permitted to sell Company stock even during the blackout period. Hardship exceptions may be granted only by the General Counsel and must be requested at least two (2) business days in advance of the proposed trade. Under no circumstances will a hardship exception be granted to a Covered Person who possesses Material Nonpublic Information. Please contact the Chief Counsel – Securities & Governance for more information.

From time to time, an event may occur that is material to the Company and is known by only a few directors, executives or employees. So long as the event remains material and non-public, directors, executive officers, and such other persons as are designated by the General Counsel or the General Counsel’s designee may not trade in the Company’s Securities (an “Event-Specific Blackout”). The existence of an Event- Specific Blackout will not be announced, other than to those who are aware of the event giving rise to the blackout. If, however, a person whose trades are subject to the prior notice procedures described below desires to trade in the Company’s Securities during an Event-Specific Blackout, the General Counsel or the General Counsel’s designee will inform the requestor of the existence of a blackout period without disclosing the reason for the blackout. Any person made aware of the existence of an Event-Specific Blackout must not disclose the existence of the blackout to any other person. Covered Persons are prohibited from trading while in possession of Material Nonpublic Information, regardless of whether they have been designated by the General Counsel or the General Counsel’s designee as being subject to an Event-Specific Blackout.

From time to time, the Company may be involved in transactions or other events with other publicly traded companies, and the transaction, while not material to the Company, may be material to the counterparty(ies). In such an event, the General Counsel or the General Counsel’s designee may impose an

Event-Specific Blackout period on the Covered Persons involved with this event or transaction solely with respect to that other company(ies) by notice to the affected Covered Persons.

Note that the mere existence of a blackout period may be considered Material Nonpublic Information.

To help prevent inadvertent violations of applicable securities laws and to avoid even the appearance of trading while in possession of Material Nonpublic Information, all individuals subject to Section 16 of the Exchange Act (i.e., Directors and Section 16 Executive Officers), and others as designated by the General Counsel of the Company from time to time, (collectively, the “Pre-Clearance Group”) may not engage in any transaction in the Company’s Securities (including a gift, contribution to a trust, or similar transfer) without first providing the Executive Vice President – Capital Markets and the Chief Counsel – Securities & Governance (together, the “Pre-Clearance Officers”) with at least 48 hours prior notice of the proposed transaction and receiving pre-clearance to proceed. The Pre-Clearance Officers (or, if one of them wishes to trade or is otherwise unavailable, then the General Counsel and/or the President shall replace such individual, as appropriate). The Pre-Clearance Officers will determine whether the transaction may proceed and if so, assist in complying with the SEC and Canadian reporting requirements, as applicable. The General Counsel or the designee thereof will maintain a list of the members of the Pre-Clearance Group and notify such individuals of their Pre-Clearance obligations. Pre-clearance shall be granted for a reasonable, limited period, generally no longer than five trading days from the date pre-clearance is granted. Pre-clearance may be requested again during an open trading window if the transaction is not completed within the applicable pre-clearance period.

These pre-clearance procedures apply to trades by partnerships, trusts, corporations, brokerage accounts or other vehicles over which members of the Pre-Clearance Group have investment control or influence, as well as the Related Persons of any member of the Pre-Clearance group. The Pre-Clearance Officers have the right to prohibit any trade for which pre-clearance is required.

Transactions under Company Plans. The pre-clearance procedures described above also apply to certain transactions under the Company’s employee stock purchase and incentive plans. The pre-clearance procedures do not apply to mandatory sell-to-cover transactions to satisfy tax withholding requirements which are not initiated by the holder of such Securities, but do apply, however, to any sale of stock as part of a broker-assisted cashless exercise of an option, or any other market sale for the purposes of generating the cash needed to pay the exercise price of an award. Pre-clearance must be in writing (which may be via e-mail or other electronic communication).

Designated Insiders and/or members of the Pre-Clearance Group may establish a trading plan under SEC Rule 10b5-1 only after first obtaining written pre-clearance for the plan from the General Counsel or the General Counsel’s designee. To obtain pre-clearance, a proposed Rule 10b5-1 Trading Plan must:

If, upon the termination of a Covered Person’s service as a director, officer, employee or other agent of the Company, the Covered Person possesses Material Nonpublic Information, unless otherwise pre-cleared by the General Counsel or the General Counsel’s designee, such Covered Person may not trade in the Company’s Securities until that information has become public or is no longer material. In all other respects, the procedures set forth in this Policy will cease to apply to the terminated Covered Person’s transactions in Company Securities upon the expiration of any applicable blackout period in effect at the time of the termination of service.

If you have any questions about this Policy or its application to any proposed transaction, you may obtain additional guidance from the General Counsel, the Chief Counsel – Securities & Governance or the General Counsel’s designee.