Forced Labour and Child Labour in Supply Chains Report


This report is made pursuant to Canada's Fighting Against Forced Labour and Child Labour in Supply Chains Act (the "Act"). This report outlines the steps Book Depot Inc. ("Book Depot") has taken during the financial year ending 2026 to prevent and reduce the risk that forced labour or child labour is used at any step of the production of goods by Book Depot or of goods imported into Canada by Book Depot.


1. Structure, Activities, and Supply Chains


Our Organization


Book Depot Inc. is a Canadian corporation headquartered in Thorold, Ontario, Canada. We operate a family of brands in the book retail and publishing industry across Canada and the United States.



Our Brands and Activities


  • Book Depot and Book Outlet:

    Retail sale of bargain books, book subscription box services, and related products including games, toys, puzzles, and reading accessories

  • American Book Company:

    Educational materials and publishing

  • Kidsbooks Publishing:

    Children's book publishing, including the recent acquisition of Out of the Box Publishing, a UK-based publisher



Our Supply Chains


Our supply chains include entities located in Canada, the United States, the United Kingdom, and other international jurisdictions. Key supply chain components include:


  • Publishers and book suppliers (domestic and international)

  • Printing and manufacturing partners

  • Paper and materials suppliers

  • Warehouse and logistics providers

  • Technology and service providers

  • Packaging and promotional material suppliers


As an importer and distributor of books and related products, we recognize that our international supply chain presents potential risks related to forced labour and child labour, particularly in regions with weaker labour protections.



2. Policies and Due Diligence Processes


Our Commitment


Book Depot has zero tolerance for forced labour and child labour in our operations and supply chains. We are committed to conducting business ethically and responsibly.



Policies


We have implemented the following policies related to forced labour and child labour:


  • Code of Business Conduct:

    Establishes our commitment to ethical business practices and respect for human rights

  • Supplier Standards:

    Requires suppliers to comply with all applicable labour laws and prohibits the use of forced labour, child labour, or any form of modern slavery

  • Procurement Policy:

    Incorporates human rights considerations into supplier selection and evaluation



Due Diligence Processes


Our due diligence processes to identify and address forced labour and child labour risks include:


  • Risk Assessment:

    We conduct risk assessments of our supply chain based on geographic location, industry sector, and type of products sourced

  • Supplier Evaluation:

    We evaluate potential suppliers' commitment to ethical labour practices before entering into business relationships

  • Contractual Requirements: We include contractual provisions requiring suppliers to:

    • Comply with all applicable laws relating to forced labour and child labour

    • Warrant that they do not use forced labour or child labour

    • Permit audits and provide information upon request

  • Supplier Communication:

    We communicate our expectations regarding forced labour and child labour to our suppliers

  • Monitoring:

    We monitor supplier compliance through various means, including questionnaires and risk-based assessments



3. Risk Identification and Management


Parts of Business and Supply Chains at Risk


Through our risk assessment process, we have identified the following areas as potentially higher risk for forced labour or child labour:


  • International printing and manufacturing of books and related products, particularly in jurisdictions with documented labour rights concerns

  • Raw materials sourcing (paper, textiles, plastics) from regions with higher prevalence of labour exploitation

  • Complex, multi-tier supply chains where visibility into lower-tier suppliers is limited



Steps Taken to Assess and Manage Risk


During the reporting period, we have taken the following steps:


  • Conducted a mapping exercise to identify higher-risk suppliers and geographies

  • Implemented a supplier self-assessment questionnaire to gather information about labour practices

  • Prioritized direct engagement with key suppliers to discuss our expectations

  • Enhanced contractual terms with major suppliers to include specific prohibitions on forced labour and child labour

  • Reserved the right to conduct audits of higher-risk suppliers



4. Remediation Measures


Forced Labour or Child Labour Identified


During the reporting period, we did not identify any instances of forced labour or child labour in our operations or supply chains.


Should we identify forced labour or child labour, our remediation process would include:


  • Immediate engagement with the supplier to understand the situation

  • Requiring the supplier to take corrective action within a specified timeframe

  • Providing support for remediation where appropriate

  • Terminating the relationship if the supplier fails to remediate or if the violation is severe

  • Reporting to appropriate authorities as required by law



5. Remediation of Loss of Income


We have not identified any loss of income to vulnerable families resulting from measures taken to eliminate forced labour or child labour during the reporting period.


Should such situations arise, we are committed to working with affected suppliers and other stakeholders to address income loss in a manner that does not increase vulnerability, such as:


  • Supporting transition to alternative, legitimate employment

  • Ensuring any remediation does not result in children being placed in worse situations

  • Working with local organizations and experts to design appropriate responses



6. Training


Training Provided


During the reporting period, we have provided training on forced labour and child labour to employees involved in:


  • Procurement and supply chain management

  • Compliance and legal functions

  • Senior management



Training topics include:


  • Understanding forced labour and child labour indicators

  • Assessing supply chain risks

  • Our policies and due diligence processes

  • Reporting mechanisms for concerns


We are committed to expanding our training program to additional employees in future reporting periods.

7. Assessing Effectiveness


We assess the effectiveness of our actions to prevent and reduce risks of forced labour and child labour through the following measures:


  • Supplier Engagement:

    Tracking the number and percentage of key suppliers that have completed our self-assessment questionnaire and acknowledged our supplier standards

  • Contractual Coverage:

    Monitoring the percentage of supplier contracts that include forced labour and child labour provisions

  • Training Completion:

    Tracking completion rates for training programs

  • Risk Assessment Reviews:

    Conducting periodic reviews of our supply chain risk assessment and updating it based on new information

  • Incident Tracking:

    Maintaining records of any concerns raised and actions taken



Performance Indicators


  • Number of suppliers assessed for forced labour and child labour risks: [INSERT NUMBER]

  • Percentage of key suppliers with contractual provisions addressing forced labour and child labour: [INSERT PERCENTAGE]

  • Number of employees trained on forced labour and child labour: [INSERT NUMBER]

  • Number of supplier audits conducted: [INSERT NUMBER]


We recognize that assessing effectiveness is an ongoing process, and we are committed to refining our metrics and processes in future reporting periods.