PRIMARY SOURCEthe Bricks & Minifigs operations manual, published at bamopsmanual.com, and BAM’s own filed financial statements
Section 9 of the Bricks & Minifigs operations manual is titled “The Daily Store Operations,” and most of it is exactly that: turn on the lights, unlock the door, keep the hand soap above half full, count the register, take out the trash so it does not “create a stench in the store.” It is the most ordinary chapter in the book. It is also where the franchisor keeps the two things a genuinely independent owner would keep for themselves: the store’s voice to the public, and the store’s money. The sections are published in full.
An earlier chapter makes every franchisee end every email with a sentence declaring they independently own and operate their store; the onboarding chapter has the company build the store’s Facebook, Instagram and website and withhold the ability to post until the company certifies it. Section 9 is what happens for the rest of the store’s life. Every store social account, on every platform, “must invite and maintain a corporate administrator from the Franchisor,” and “failure to do this will be considered a violation of your franchise agreement and may result in the termination of your franchise.” Read that plainly: an owner can lose the entire business they bought over whether the franchisor holds administrator rights on a Facebook page.
The control does not stop at access. The franchisor “reserves the right to delete, remove, hide, or otherwise alter posts, comments, and/or other social media activities, and maintains complete control over the Bricks & Minifigs brand and its messaging,” and the manual closes the only exit: “Stores are not allowed to create their own websites.” So the store every owner must, on every email, declare they independently own and operate has no channel to the public the franchisor does not build, administer, or forbid. The Customer Service chapter already gave the company a way to end a franchise over customer complaints it counts at its “sole discretion”; this is another, in the chapter about turning on the lights. The independence is the sentence they sign. The control is the chapter they follow.
The store map showed every franchisee must buy the point-of-sale system the company specifies. Section 9 puts the money on top of it and admits of no exception. As a matter of “your franchise agreement, you are required to use only franchise approved POS systems”; since 2020 “the Heartland Retail POS system is the only approved POS system”; and, for payments, “all stores are required to use Heartland Retail as the merchant processor, and for the universal gift card system. There are no exceptions to this policy unless expressly provided by the Franchise in writing.” Every card a customer swipes and every gift card a customer buys, in every store in the country, runs down one company-designated rail. It is the same design as the fee collection the financial chapter mandates, where the company takes its money by exclusive monthly debit and “any deviation” is a breach.
A single, system-wide flow of card transactions is precisely the thing a rebate is paid on, and the company’s own filings show it has taken exactly that. BAM’s 2023 disclosure document states that “in the past” it received rebates from its designated merchant processor, “of around 15% to 30% of the merchant processor’s net revenue based on the total number of open and active merchant accounts in our franchise system,” and that “since switching merchant processors, we no longer receive these payments.” It is the same reserved-rebate pattern the approved vendor list showed on construction and fixtures, where the company keeps supplier rebates “without obligation to share or remit any portion” to the franchisee who paid. The company does not merely choose the road every store must drive; on its own record, for a time, it collected on the traffic.
The gift-card half of that mandate has a number too, and it is in BAM’s own audited financial statements. The gift-card liability, the balance of what customers have prepaid and not yet spent, grew from $146,338 at the end of fiscal 2022 to $417,367, then to $673,228 at the end of fiscal 2024. The same audited statements, given an unqualified opinion, report total stockholders’ equity that year of negative $492,495. By the company’s own numbers, the money customers have prepaid into the gift-card system Section 9 makes mandatory is larger than the company’s entire net worth is negative. Every one of those dollars sits inside a single pooled system the franchisor controls the rail for and the owner may not opt out of.
One stretch of the routine is worth reading against the chapter two sections earlier. The bathroom checklist tells owners to stock diapers in “sizes 1-4,” a changing table, feminine products, and a step stool for the sink, the last one called for, in the manual’s words, because “we will have a lot of children in our stores”. The customer chapter already established, in the company’s own words, what those children are for: they are “the conduit to the parents” the store buys its LEGO from, the child a staffer is coached to win over to reach the adult beside them. Section 9 is where the same premise appears in the plumbing. The store is built for children because the manual, elsewhere, is built to buy from the adults beside them.
The upward-facing design the communications chapter set up, where discussion is engineered to “flow upwards,” runs through the daily routine too. The manual recommends an inventory chat in part for “allowing you to monitor employee purchasing decisions,” has each store post its net sales publicly every night, and instructs that the register “should balance every night. You shouldn’t be over or short, ever.” Advice, when it faces the customer; a standing record of every person’s conduct, when it faces the staff and the owner.
The pattern is the chapter’s own summary. What faces the customer is help: welcome the people waiting in their cars, answer the phone, refill the soap. What faces the owner is control: keep the company on your accounts or lose the store, run every dollar through the company’s rail, do not build your own website. Daily Store Operations is, like the chapters before it, two documents in one binding.
The fair counterpoint. None of this is unusual on its own and none of it is unlawful. Franchises routinely require brand-consistent social media, administrator access to protect a trademark, a single point-of-sale platform, and one payment processor and gift-card system, and there are ordinary brand and accounting reasons for each. Disclosing supplier rebates and later switching processors is what the disclosure rules are for, not a violation of them; unspent gift-card balances are a normal liability in any retailer that sells them, and a negative book equity is not the same as insolvency. Requiring diapers and a changing table is a store trying to be welcoming. Every provision and every figure quoted here is taken from the company’s own manual, as published on bamopsmanual.com, or its own filed statements, so a reader can weigh them against the store the same company requires every owner to declare, on every email, that they independently own and operate. Nothing here is a finding of law.
Sources. Bricks & Minifigs Franchisee Training & Operations Manual, V.10.6.24, Section 9 (“The Daily Store Operations”), pages 81–101, published in full at bamopsmanual.com/09a-daily-open and /09b-daily-systems: the social-media provisions are section 9.4.5, the point-of-sale and merchant-processing provisions sections 9.6 and 9.7, the bathroom checklist 9.11, the internal-messaging and cash provisions 9.1.3 and 9.8, each quoted from the published pages. The merchant-processor rebate language is quoted from BAM Franchising’s 2023 Franchise Disclosure Document (Item 8); the “without obligation to share or remit” supplier-rebate clause is from the franchise agreement, both walked in the approved vendor list. The gift-card liability series (fiscal 2022 through 2024) and the negative stockholders’ equity are from the audited financial statements filed as an exhibit to the disclosure document. The mandated email declaration that a store “independently owns and operates this Bricks & Minifigs franchise” and the “flow upwards” communications design are in Sections 1–3; the onboarding social-media build and exclusive ACH fee collection in Sections 4–5; the required point-of-sale system in the store map; the discretionary termination-for-complaints in Section 6; and the customer chapter’s treatment of children in Sections 7–8.
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