Modern Slavery Act Statement


This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for Book Depot Inc. and its subsidiary Kidsbooks Publishing (including Out of the Box Publishing) (collectively, the "Group") for the financial year ending 2025.



Our Organization and Structure


Book Depot Inc. is a Canadian corporation headquartered in Thorold, Ontario, Canada. Through our subsidiary Kidsbooks Publishing, we operate Out of the Box Publishing, a UK-based children's book publisher. This creates a UK business presence that requires compliance with the Modern Slavery Act 2015.


The Group operates across multiple jurisdictions, including Canada, the United States, and the United Kingdom, in the book retail and publishing industry.



Our Business and Supply Chains


The Group's business includes:


  • Retail sale of bargain books and related products (Book Depot, Book Outlet)

  • Book subscription box services

  • Children's book publishing (Kidsbooks Publishing, Out of the Box Publishing)

  • Educational publishing (American Book Company)

  • Distribution of books, games, toys, puzzles, and reading accessories



Our supply chains include:


  • Publishers and book suppliers (domestic and international)

  • Printing and manufacturing partners across multiple countries

  • Paper and materials suppliers

  • Warehouse and logistics providers

  • Technology and service providers

  • Packaging and promotional material suppliers


We recognize that our international supply chain, particularly printing and manufacturing operations, presents potential risks related to modern slavery and human trafficking.



Our Policies on Slavery and Human Trafficking


The Group is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have zero tolerance for slavery and human trafficking.


We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.



Our Standards and Expectations for Suppliers


We expect all those in our supply chain and contractors to:


  • Comply with all applicable laws, regulations, and industry standards relating to slavery, servitude, forced or compulsory labour, and human trafficking

  • Provide workers with freely chosen employment

  • Not use child labour, forced labour, bonded labour, or involuntary labour of any kind

  • Provide safe and healthy working conditions

  • Treat workers with dignity and respect

  • Pay fair wages that meet or exceed legal minimum requirements

  • Respect workers' rights to freedom of association and collective bargaining

  • Maintain accurate employment records

  • Provide reasonable working hours



Due Diligence Processes


The Group undertakes due diligence when considering new suppliers and regularly reviews existing suppliers. Our due diligence processes include:


Risk Assessment


  • Conducting supply chain mapping to identify higher-risk categories (e.g., printing, manufacturing, raw materials)

  • Assessing geographic risk based on known prevalence of modern slavery

  • Evaluating sector-specific risks in the publishing and retail supply chain



Supplier Evaluation and Engagement


  • Evaluating potential suppliers' commitment to ethical business practices and labour standards

  • Requiring suppliers to complete self-assessment questionnaires regarding their labour practices

  • Prioritizing engagement with key strategic suppliers to communicate our expectations



Contractual Provisions


  • Implementing a risk-based due diligence framework that includes requiring contractual warranties of compliance with all applicable anti-slavery and forced labour laws

  • Reserving contractual rights to conduct independent audits of higher-risk suppliers

  • Including provisions allowing termination for non-compliance with modern slavery standards



Monitoring and Verification


  • Conducting risk-based assessments of supplier compliance

  • Investigating concerns or allegations related to modern slavery

  • Working with industry partners and third-party organizations to enhance monitoring capabilities



Supplier Accountability


We include provisions in our supplier contracts that require compliance with applicable laws relating to slavery and human trafficking. We reserve the right to:


  • Request evidence of compliance with our standards

  • Conduct audits or inspections of supplier facilities

  • Terminate our relationship with any supplier found to be involved in modern slavery or human trafficking practices



Training and Awareness


We are committed to building awareness of modern slavery and human trafficking risks within our organization. We provide training to relevant employees involved in:


  • Procurement and supply chain management

  • Compliance and legal functions

  • Publishing operations at Out of the Box Publishing and Kidsbooks Publishing



Training covers:


  • Understanding modern slavery and human trafficking indicators and red flags

  • Our policies and expectations

  • Due diligence processes and risk assessment

  • Reporting mechanisms for concerns



Effectiveness and Performance Indicators


We assess the effectiveness of our actions to address modern slavery and human trafficking through:


  • Supply Chain Transparency:

    Percentage of key suppliers that have completed our ethical labour practices assessment

  • Contractual Coverage:

    Percentage of supplier agreements that include modern slavery provisions

  • Training Metrics:

    Number and percentage of relevant employees who have completed modern slavery awareness training

  • Risk Assessment Coverage:

    Proportion of supply chain spend covered by risk assessment processes

  • Issue Resolution:

    Documentation of any concerns raised and corrective actions taken



Remediation and Corrective Action


If we identify potential modern slavery or human trafficking in our supply chains, we are committed to:


  • Investigating the matter thoroughly and promptly

  • Requiring immediate corrective action from the supplier

  • Working with the supplier to implement sustainable remediation measures

  • Ensuring any remediation protects the interests of affected workers

  • Terminating the relationship if the supplier fails to adequately address the issue

  • Reporting to appropriate authorities as required by law



Continuous Improvement


We recognize that preventing modern slavery and human trafficking is an ongoing effort. We are committed to:


  • Continuously improving our due diligence processes and risk assessment methodologies

  • Engaging with industry peers, civil society organizations, and stakeholders on best practices

  • Expanding our training and awareness programs

  • Enhancing our supply chain transparency

  • Strengthening our monitoring and verification mechanisms

  • Updating this statement annually to reflect our progress