PRIMARY SOURCE the operations manual
Every Bricks & Minifigs franchisee is required to put one sentence at the bottom of every email they send: that they independently own and operate their store. The requirement is set out in the manual the company gives them. So are the rules that follow. The same section names the only four ways an owner may contact the company, assigns the email address they must use, reserves the company’s right to read it, tells new owners they may not speak in the shared channels, forbids owners from discussing company policy with one another in public, and warns that not communicating quickly enough can be treated as abandoning the franchise. Those rules are set out below in the company’s own words.
A franchisor speaks in two registers. One is written to be read by people deciding whether to buy: the disclosure document, the brochure, the discovery-day deck. The other is written to be read only by the people who have already bought and must now obey it. The first has something to sell. The second has nothing to gain from flattery, because its audience is already inside and its purpose is to make them comply.
Where the two describe the same subject differently, the internal one is the better account of how the business actually runs. That is not a rule invented for this company. It is the reason a statement made against the speaker’s own interest carries weight that a promotional statement never does.
BAM values the two documents the same way. The disclosure is filed, indexed and public. The manual is not given to a franchisee at all. Item 11 of that same disclosure describes what the company does with it: “Loan to you during the term of the Franchise Agreement one copy of our confidential Pre-Opening and Operations Manuals.” It is lent, not transferred, and the disclosure calls it confidential. The manual enforces the point itself: it may not be shared with employees or anyone outside the company, sharing it is a breach of the confidentiality contract carrying “appropriate penalties,” and departing from any policy in it is a breach of the franchise agreement. No company protects its marketing that way. How the two documents are guarded is the company’s own assessment of which one describes the business.
What follows is that document, quoted rather than characterized.
CONFIRMED BAM’s own systems and its own court filing, each captured and cited
The manual is guarded on paper. Whether confidential material is guarded in practice is a different question, and there is a record of it.
BAM runs an online help desk for its franchisees at bamfran.freshdesk.com, and it requires no login. Its fifty-two articles are the operating instructions the company gives a store owner, including the point-of-sale system every store is required to buy and which vendors to use. This site captured them in full on July 23. The company’s own store-management system, which carries the franchise number, division, floor area, opening dates and internal record number for each of the 191 stores it tracks, is also reachable without a login, and was captured the same day.
The pattern reaches its court filings. Suing a California franchisee in January 2024, BAM filed a competitor’s marketing email and blacked out the sender. It covered three of the five fields on the page that identify anyone, precisely the three that name the forwarder, and left its own chief executive’s address in the clear. The boxes were painted over a picture of the email and the words underneath were never removed, so they remain in the document the company filed. The sender was BAM’s own chief technology officer.
So the company that treats its operations manual as confidential, lends rather than gives it, and makes sharing it a breach of contract, is the same company that leaves its operating instructions and its store database open to anyone who types the address, and files a redaction that can be read straight through. That gap is not an argument about the manual. It is the record on how this company handles the material it calls confidential.
It also leaves a question open. A company whose help desk, whose store database and whose own court filing have each turned out to be readable by anyone who looked is not a company whose confidential documents can be assumed to be anywhere in particular. Whether the operations manual is itself sitting somewhere publicly reachable is not established here. On this record it is not a question that answers itself.
The manual is the Franchisee Training & Operations Manual, edition V.10.6.24, the edition in force at the company’s 2024 fiscal year end. Its existence and its nineteen numbered sections are already a matter of public record: BAM filed the table of contents with federal and state regulators as Exhibit E to its 2025 disclosure document, which is the subject of a separate note published today. What follows is the document itself, at bamopsmanual.com.
Two provisions on the cover set the terms on which everything else rests:
“This training manual is intended for Franchise Owners ONLY and is not to be shared with employees or anyone outside of the company. Failure to do so will be considered a breach of our confidentiality contract and appropriate penalties will apply.”
“Failure to abide by all policies and specific guidelines and directives outlined herein or incorporated by reference, shall constitute a breach of the Franchise Agreement.”
Every policy in the manual is enforceable against the owner as a contractual default. Six pages later, section 1.7 sets out what the company owes in return:
“In no event shall Bricks and Minifigs Corporate accept any liability for injury, loss, or damage incurred by use of, or reliance on, the information in this manual. Further, we do not warrant the quality, accuracy or completeness of any information herein. Such information is provided ‘as is’ without guarantee of any kind … we reserve the right to revise its content at any time and without notice.”
The instrument binds one party and is disclaimed by the other. An owner defaults on the franchise agreement by departing from a document the company does not warrant to be accurate, and may rewrite without telling them.
Section 3 adds a third layer. A memo can displace the manual before the manual is updated:
“Any official memoranda or communications will be sent out amongst the stores, and any new standards or policies explained in those communications will then be the new standard for the brand moving forward. Those policies will override any currently existing policies in this manual, until this manual is updated and those policies are incorporated herein.”
So the binding rules are: a manual that can change silently, plus memoranda that override the manual, enforced against an owner who is in default if they fall out of step with either.
Section 3.1.1 assigns each store its email address and specifies what must appear beneath it:
“You must include in your email signature in each communication the following: ‘[your corporate entity or individual name] independently owns and operates this Bricks & Minifigs franchise.’”
The declaration of independence is itself a corporate requirement, written by the company, mandated in the company’s manual, in language the company supplies. The same section continues:
“Be mindful that you have no expectation of privacy in your (store) business email accounts. We are authorized to access and search the email accounts and their contents, although we do not anticipate doing so except possibly in extreme circumstances.”
An independent operator, on an address the company assigns, in an account the company may read, signing every message with a sentence the company drafted.
Section 3.0 opens by naming “the only approved methods to communicate with Corporate”: email, Slack, phone, scheduled video conference. It closes by attaching a consequence to silence:
“Failure to communicate in an appropriate and timely manner with the BAM Franchising Inc., especially on matters relating to the performance of your store, may be considered an abandonment of franchise and may result in termination of your franchise agreement and all associated rights. Choosing to ignore communications, or failure to adhere to communicated directives may also result in termination.”
Section 3.2 governs what owners may say to each other. New franchisees are observers:
“As a forming store, you may only observe on the general channels (please don’t comment or give advice unless you receive permission first) until you are actually open for business.”
Owners who are open for business face a different limit. Section 3.2.1.1 is headed “Slack Policy Discussions”:
“Slack shall not be used as a forum to discuss franchise wide policy. …
a. Any franchise directed policy discussions will be removed from public threads.
b. If you have a franchise directed policy matter to discuss, you are to use any of the appropriate communications channels (private store channels, phone, email, text, etc.) to reach out to Corporate members to open a dialogue.
c. If Corporate decides to open a public discussion on policy – feel free to participate.”
The manual states the design plainly two paragraphs later. Discussion of policy is not prohibited, it is redirected:
“This does not mean we wish to hinder the flow of ideas and discussion related to policy – just direct it to flow upwards.”
Alongside it, section 3.2.1.2 tells owners the shared channels are not “a place to air personal grievances, or sway opinions,” and section 3.2.1.4 reserves the remedy: “Any communications Corporate deems inappropriate are subject to deletion.”
Read together, section 3 describes a communications system the company builds, assigns, may read, and moderates, in which the one subject franchisees may not discuss collectively is the terms of the franchise itself. Grievances go up a private channel, one owner at a time. Whether policy is ever discussed among owners in the open is a decision reserved to the company.
Section 2 sets out the model in the company’s own framing. The second of its four pillars:
“Central to our brand’s uniqueness is the buy-sell-trade model. Unlike traditional toy retailers, we provide customers the opportunity to trade their new and used Bulk, Lego sets and Minifigures for cash or store credit. … this aspect of your business is the heart and soul of what makes Bricks & Minifigs unique.”
Section 1 is candid about what that means in practice, and section 1.7 is candid about who carries the regulatory weight of it. The manual advises that “each state or city may have its own laws or regulations regarding various rules, permits and pawn licenses in force for buying or selling used products of any kind,” and that the owner “may have to check your city, state, or country laws to ensure you are in compliance.” The disclosure document introduces the same subject to prospective buyers differently. Item 1 says that “generally, there are no government regulations that apply specifically to operating a re-sale store specializing in LEGO® brand products,” before listing categories of general law that do apply, second hand and re-sale store laws among them. The duty is described to buyers in the general register and to owners in the specific one. In both places it belongs to the franchisee, and in the manual it arrives inside the same section that disclaims all liability for the answer.
The cover, section 1 (Introduction), section 2 (The BAM Difference) and section 3 (System and Brand Communications) are reproduced as printed. Two categories are removed and marked in place: addresses for the company’s internal systems, and email addresses belonging to named individuals. Departmental addresses are left intact, because the company publishes them itself on its own login-free help desk, which this site captured in full on July 23.
Nothing above depends on a document the reader cannot check. The manual pages are at bamopsmanual.com, the disclosure document is a public regulatory filing, and the help desk is open. Related material is on the disclosure, the store, and the connection board.
In fairness. A franchise system may set operating standards, and moderating a workspace it administers is ordinary in itself. None of the provisions quoted here is alleged to be unlawful, and each is reproduced rather than summarized so a reader can weigh it without taking this site’s word for it. BAM Franchising has not responded to these points.
Primary sources. All manual quotations are from the Bricks & Minifigs Franchisee Training & Operations Manual, edition V.10.6.24, published as printed: the cover and sections 1.7, 2.2, and 3.0, 3.1.1, 3.2 and 3.2.1. The confidentiality-practice section rests on three findings already documented here, the support portal, the store map and the redacted exhibit. The manual’s table of contents is a public filing, Exhibit E to the Bricks & Minifigs 2025 Franchise Disclosure Document (state filing 33584-202504-15), the source of the Item 1 and Item 11 passages quoted above. Every allegation referenced elsewhere on this site remains unadjudicated and every person and entity retains the presumption of innocence.
The BAM Map is independent reporting on matters of public concern. Nothing here is a finding of any person’s guilt; the criminal charges referenced are unadjudicated and every defendant is presumed innocent. Sources are linked so readers can check the record. · Home · Map · The law · Bodycam