ACCESSIBILITY STATEMENT

Book Depot Inc. ("Book Depot," "we," "us," or "our") is committed to ensuring digital accessibility for people with disabilities. We are continually working to improve the accessibility and usability of our website to provide equal access to all of our users.

Compliance with Ontario Law

As a company headquartered in Ontario, Book Depot Inc. is committed to meeting its obligations under the Accessibility for Ontarians with Disabilities Act (AODA). We have developed a multi-year accessibility plan that outlines our strategy to prevent and remove barriers to accessibility. This plan is available upon request. We will file accessibility compliance reports as required by the AODA.

Our Commitment

We strive to ensure that our website is accessible to people with disabilities, including those who use assistive technologies such as screen readers, screen magnifiers, speech recognition software, and alternative input devices.

Conformance Standards

Our goal is to align our website with the principles of the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA, which are internationally recognized standards for web accessibility. These guidelines explain how to make web content more accessible for people with disabilities and more user-friendly for everyone.

Measures to Support Accessibility

Book Depot takes the following measures to ensure accessibility of our website:

  • Include accessibility as part of our mission statement and company values

  • Provide ongoing accessibility training for our staff

  • Assign clear accessibility goals and responsibilities

  • Employ formal accessibility quality assurance methods

  • Conduct ongoing accessibility testing and monitoring

Accessibility Features

We have incorporated a number of accessibility features into our website design, such as keyboard navigation support and providing text alternatives for non-text content, to improve the user experience for all visitors. Our ongoing efforts focus on:

  • Clear and consistent navigation structure

  • Sufficient color contrast

  • Readable and understandable content

  • Resizable text without loss of functionality

  • Descriptive page titles and headings

Feedback

We welcome your feedback on our accessibility efforts. You may also request a copy of our multi-year accessibility plan in an accessible format. If you encounter accessibility barriers or have suggestions for improvement, please contact us using the information at the end of this page. We aim to respond to accessibility feedback within 5 business days.

Third-Party Content

While we strive to ensure our website is accessible, we link to third-party websites (including our brand websites and our career portal hosted by ADP Workforce) that are beyond our control. We cannot guarantee the accessibility of content on external sites. Each of these sites maintains its own accessibility policies and practices.

Ongoing Efforts

Accessibility is an ongoing effort. We are continually seeking solutions to improve the accessibility of our website and bring it into compliance with accessibility standards. We review and update this Accessibility Statement as we make improvements.


EQUAL EMPLOYMENT OPPORTUNITY STATEMENT

Book Depot Inc. ("Book Depot") is an equal opportunity employer committed to creating and maintaining an inclusive and diverse workplace. We are dedicated to providing equal employment opportunities to all employees and applicants for employment.

Our Commitment

This commitment means we provide equal opportunity without regard to any characteristic protected by applicable law. These protections vary by jurisdiction and include, but are not limited to, the following:

In Canada: Race, national or ethnic origin, colour, religion, age, sex, sexual orientation, gender identity or expression, marital status, family status, genetic characteristics, disability, and conviction for an offence for which a pardon has been granted or a record suspended, as protected under the Canadian Human Rights Act. In Ontario, protections also include citizenship, ethnic origin, ancestry, place of origin, creed, family status, and record of offences, as defined by the Ontario Human Rights Code.

In the United States: Race, color, religion, sex (including pregnancy, sexual orientation, and gender identity), national origin, age (40 or older), disability, and genetic information, as protected by federal laws including Title VII of the Civil Rights Act, the Americans with Disabilities Act (ADA), and the Age Discrimination in Employment Act (ADEA). Protections may be broader under applicable state and local laws.

This policy applies to all terms and conditions of employment, including but not limited to:

  • Recruiting and hiring

  • Compensation and benefits

  • Professional development and training

  • Promotions and transfers

  • Social and recreational programs

  • Layoffs and terminations

  • Disciplinary actions

  • All other employment-related activities

Non-Discrimination and Harassment

Book Depot prohibits discrimination and harassment of any kind. We are committed to providing a work environment free from harassment, intimidation, and coercion. All employees, applicants, contractors, and visitors have the right to be treated with dignity and respect.

Any employee found to have engaged in discriminatory or harassing conduct will be subject to appropriate disciplinary action, up to and including termination of employment.

Reasonable Accommodations

Book Depot is committed to engaging in a collaborative and interactive process to provide reasonable accommodations for disabilities and religious beliefs/practices to qualified individuals, unless doing so would impose an undue hardship on the business.

To initiate a request for accommodation, employees or applicants should contact our Human Resources department or Compliance Officer. We are committed to working with individuals to identify effective accommodations that enable them to perform the essential functions of their position or to participate fully in the application process.

Compliance with Laws

Book Depot complies with all applicable employment laws, including but not limited to:

Canada:

  • Canadian Human Rights Act

  • Employment Equity Act

  • Ontario Human Rights Code

  • Accessibility for Ontarians with Disabilities Act (AODA)

  • Provincial employment standards legislation

United States:

  • Title VII of the Civil Rights Act of 1964

  • Americans with Disabilities Act (ADA)

  • Age Discrimination in Employment Act (ADEA)

  • Equal Pay Act

  • Genetic Information Nondiscrimination Act (GINA)

  • State and local fair employment practice laws

Reporting Concerns

Employees or applicants who believe they have been discriminated against or harassed, or who have witnessed such conduct, are encouraged to report it immediately using the contact information at the end of this page.

Book Depot prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports.

Career Opportunities

Employment opportunities at Book Depot are posted through our career portal. All applicants are evaluated based on their qualifications and ability to perform the essential functions of the position, with or without reasonable accommodation.

This policy reflects Book Depot's commitment to equal employment opportunity and is applied consistently across all of our brands and operating companies, including Book Depot, Book Outlet, American Book Company, and Kidsbooks Publishing.


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.


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 [INSERT DATE].

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


Contact Information

If you have any questions regarding these policies or your other interactions with Book Depot Inc. please contact us at:

Email: [email protected]

Phone: 800-801-7193

Mail: Book Depot, Attn: Compliance 67 Front Street North Thorold, Ontario Canada, L2V 1X3