The PEGI Code of Conduct

The PEGI System is based on a Code of Conduct - a set of rules to which every publisher using the PEGI system is contractually committed. The Code deals with age labelling, promotion and marketing and reflects the video games industry’s commitment to provide information to the public in a responsible manner.

PEGI CODE OF CONDUCT

FOR THE VIDEO GAMES INDUSTRY IN EUROPE REGARDING AGE RATING LABELLING, PROMOTION AND ADVERTISING OF VIDEO GAMES AND MAINTENANCE OF SAFE ONLINE GAMEPLAY

Article 1: SCOPE     

1.1    This Code shall apply to all video game products including games which, in each case, are intended for play in territories where the PEGI System applies, are distributed electronically by whatever means or for retail sale on a physical carrier, by all publishers or other organisations that enter into an agreement with Video Games Europe to comply with this Code (“Members”).

1.2    The rules contained in this Code shall apply to the labelling of video game products, as well as to associated advertising, promotion, and distribution by any means.

1.3    All capitalised terms in this Code have the meanings given to them in the standard PEGI Agreement unless otherwise indicated in this Code.

Article 2: PURPOSE

This Code reflects the video games industry’s commitment to provide information to the public on the content of video game products in a responsible manner and also to ensure safe online and offline gameplay for all.

This Code:

2.1    is intended to provide players of all ages, parents, guardians, and educators with objective, intelligible and reliable information regarding the minimum age for which the content of a video game product is deemed suitable along with additional information on in-game features. The ratings implemented under the Code in no way relate to the difficulty of a video game product or the level of skill required to play it.

2.2    is intended to ensure that all advertising, marketing and promotion of video game products is conducted in a responsible manner.

2.3    reflects the video games industry’s commitment not to promote or distribute video game products likely to offend human decency.

2.4    reflects the video games industry’s commitment to provide a safe environment where people play video game products online.

Article 3: INSTRUMENTS

The following systems and bodies are responsible for meeting the objectives set out in Article 2:

3.1    The PEGI System operated by PEGI s.a. (see 3.2 below) and supported by the Administrator, grants licenses to use the PEGI Logos and Descriptors. PEGI retains the right to rescind or recall any Logo or Descriptor assigned to a product at all times.

3.2    PEGI S.A. (“PEGI”), a Belgian not for profit company with a social purpose and entrusted with the day-to-day management, supervision and development of the PEGI System.

3.3    The PEGI Management Board (“PMB”) consisting of a chairperson, the PEGI Director General, representatives from industry, the chairs of the PEGI Council and the Experts Group, is responsible for providing guidance to the PEGI S.A. Director General, who is in charge of the day-to-day management, the operation and development of the PEGI System.

3.4    The PEGI Council (“PC”) and PEGI Experts Group (“PEG”), which are independent committees including representatives from the main stakeholders (parents, consumers associations, child psychology experts, academics, media experts and the video games industry - see Article 12 below), which are responsible for advising the PMB on the Code of Conduct, and regular scrutiny of and regular adjustments to the Code of, to take account of social, political, legal and technological developments. The PEG is responsible for considering technical developments (in their respective fields) that may impact the PEGI System.

3.5    The PEGI Complaints Board (“PCB”) including in the same manner as the PC, representatives from chief stakeholders, (see Article 13 below), which is responsible for, inter alia, handling the following types of complaints:

- complaints about PEGI age ratings made by Signatories or consumers.
- complaints that promotional activities of any Signatory are not consistent with or appropriate for a video game’s age rating granted or likely to be granted to it under the PEGI System.

3.6    The PEGI Enforcement Committee (“PEC”) which includes, in the same manner as the PC, representatives from chief stakeholders which is responsible for implementing the recommendations of the PMB, and enforcing the rules and sanctions of this Code, including decisions of the PCB (see Article 14 below).

3.7    The PEGI Legal Committee (“PLC”) which is in charge of securing the ongoing coherence of the PEGI System with national legal frameworks.

Article 4: PEGI’s COMMITMENT TO THE CODE

PEGI hereby commits to:

4.1    ensure that the PEGI age classification procedure is operated as efficiently and transparently as possible by independent administrators and that the provisions to maintain a safe online gameplay environment are verified.

4.2    raise awareness and understanding of the Code and its purpose by participants in the industry, including Signatories, retailers and other stakeholders.

4.3    implement and maintain the appropriate structures and resources to operate the PEGI System, to carry out the tasks of interpreting and updating this Code, to settle disputes, and where appropriate, to conduct studies and write reports about the PEGI system, content classification, and minor protection in video games.

4.4    promote general public awareness of the PEGI System and its Code of Conduct, in cooperation with national video games industry trade associations and other stakeholders.

4.5    support initiatives that aim to enhance the awareness of teachers, educators and other professionals of the PEGI system and its Code of Conduct in order to support them in promoting safe and responsible gameplay.

Article 5: GENERAL OBLIGATIONS OF SIGNATORIES

Signatories shall:

5.1    provide all appropriate information to the PMB, PC and PEG and abide in good faith by all decisions of the PMB, PCB and PEC.

5.2    assist PEGI in delivering on its own commitments as stated in Article 4 above including endorsing and publicising the Code where necessary.

5.3    support the promotion of general public awareness of the availability of parental control tools and the importance of safe and responsible gameplay.

5.4    take account of children’s perspectives, needs, interests and rights when designing and evaluating new products and services intended for children.

5.5    inform Retailers directly and/or require distributors and wholesalers of their video game products to inform retailers that all employees, when engaged in face-to-face transactions with customers, must comply with the PEGI Retail Code (see Annex B) and, in particular, shall not sell any video game products to those customers in contravention of the specified PEGI age rating. 

Article 6: LEGAL AND REGULATORY ENVIRONMENT

Signatories shall ensure that the content, distribution by any means, marketing and advertising of the video game products covered by this Code comply at all times with existing and future laws and regulations at EU and national level. The obligation to abide by this Code applies only as far as it does not lead to any infringement of existing or future national mandatory (governmental) rating and labelling system applicable to video games made available by physical or electronic means.

This Code of Conduct complements existing international, European and national regulations and enforcement mechanisms. It was drafted with special consideration and respect for the Rights of the Child, as set forth in the United Nations Convention, and for the responsibilities and duties of parents and guardians to provide, in a manner consistent with the evolving capacities of the child, appropriate direction and guidance in the exercise of these rights by the child.

Article 7: PEGI SYSTEM FOR AGE RATINGS

The main features of the PEGI System are described as follows. 

7.1    Prior to the release of a video game, Signatories shall, for each video game product and format thereof, complete an Assessment File.

7.2    The Assessment File will generate an age rating Logo and the Descriptors indicating the reasons for classification of the Product in a specific age category.

7.3    The PEGI System age rating categories are: 3, 7, 12, 16, and 18.

7.4    The Administrator shall review the Assessment File according to the following rules:

7.4.1    The Administrator shall review all video game products in full before deciding whether to approve the age rating by granting a licence to use the Logo and Descriptors except in the case of video game products subject to the IARC classification procedure where age ratings can be verified by the Administrator after the Product is made available to the public.

7.4.2    In the event that the Administrator determines an age rating that is different from the one determined by the submitting Signatory, an explanation for the variation shall be provided by the Administrator. If the Signatory does not agree with the recommendation, it may appeal to the PCB, which will make the final decision as to the appropriate age rating recommendation.

7.4.3    To conclude this process, the Signatory will receive a license to reproduce the age rating Logo and Descriptors on the video game product packaging or in a place which is immediately visible to consumers where delivery is made via electronic means.

Article 8: IN-GAME MONETISATION

8.1    PEGI signatories offering in-game purchase options in video game products shall ensure that these offers are made in a fair and transparent manner and in compliance with applicable laws and regulations.

8.2    Signatories shall accurately inform consumers about the presence of in-game purchase offers, by displaying the PEGI in-game purchases content descriptor (and where applicable, the “includes paid random items” notice) at the point of purchase or download, in accordance with the templates set out in the Labelling and Advertising Guidelines (Art. 10-11).

8.3    When random items (like loot boxes, card packs or prize wheels) are available for purchase (directly or indirectly through premium in-game currency), Signatories shall:

8.3.1    clearly inform consumers prior to acquisition about the probability of receiving each item or category of items. This shall be done in an easily understandable and accessible way;

8.3.2    ensure that probabilities are transparent and equivalent for all players, that random items are distributed without any disadvantageous manipulation based on unfair processing of personal data, and in compliance with applicable data protection and privacy laws;

8.3.3    ensure and emphasise that paying for random items is never essential to the gameplay. 

8.4    PEGI signatories shall ensure that their policies prohibit that items acquired in-game can be transferred into monetary value for use in unlawful gambling or betting activities. These policies should include clear wording on the enforcement of potential penalties such as suspending or banning players in the case of illegal trading.

8.5    Signatories shall provide transparency in transactions, so that:

8.5.1    where players can buy in-game currency for in-game purchases, the cost of this currency is always clear and unambiguous. Players/account holders should always receive a receipt or an invoice in their account when making purchases related to the gameplay with real money, such as buying in-game currency. This information can also be communicated by parental control tools or other transaction reports.

8.5.2    Where a player may use purchased in-game currency to acquire content, the value of that content should be clear to consumers, for example by including a clear statement of the cost of the content in such in-game currency and easy access to information on how much of the in-game currency the player currently holds and/or the storefront area where this in-game currency can be purchased with real-world prices displayed.

Article 9: STANDARDS FOR SAFE ONLINE GAMEPLAY

9.1    Rated Content: As described in Articles 1.4 and 2.1, video game products offering Online Gameplay Environments operated by Signatories will be appropriately rated under the PEGI System. This does not include content generated by players (so-called user-generated content) and communication between players, to which the following safety provisions apply:

9.2    Community Standards: Signatories shall ensure that their terms of service with players in Online Gameplay Environments incorporate certain provisions in easily understandable language that are usually included under the heading of so-called ‘Community Standards’. These provisions shall:

9.2.1    prohibit players from introducing content or indulging in online behaviour which is illegal and/or harmful. Such provisions shall describe the consequences of any breach of their terms. 
Examples of such content or behaviour can be: abusive, bullying, corrupting, defamatory, degrading, fraudulent, harassing, insulting, obscene, offensive, racist, sexist, threatening content, or content that incites violence, terrorism, hatred or self-harm, or that might impair the physical, mental or moral development of players.
9.2.2    ensure that all reasonably practicable precautions are taken to ensure that Online Gameplay Environments that allow text, voice, video chat, or image sharing protect children from access to age-inappropriate content introduced by other players.

9.3    Notice and Action and Removal of Content: Signatories shall ensure that Online Gameplay Environments are kept free of content and behaviour described in Article 9.2.1 or of content and behaviour that otherwise breaches their terms and conditions, rules and community guidelines. Specifically, Signatories shall:

9.3.1    act expeditiously to remove or to disable access to any user-generated content that falls within Article 9.2 above;

9.3.2    ensure that appropriate notice mechanisms are in place to allow players and others to notify them of the presence on their Online Gameplay Environments of content considered to fall within Article 9.2 above. Signatories shall ensure that these mechanisms are easy to access, user-friendly and allow for the submission of notices exclusively by electronic means;

9.3.3    ensure that they have procedures in place to review notifications of user-generated content which falls within or is suspected of falling within Article 9.2;

9.3.4    in accordance with EU and national legislation, Signatories shall process notices received, and take their decisions in respect of the content to which the notices relate in a timely, diligent and objective manner.

9.4    Other Operators: Signatories shall use their best endeavours to ensure that operators of Online Gameplay Environments offered by video game products published by the Signatory and which are authorised by, but not under their control, abide by these rules and/or subsequently become Signatories themselves. Signatories shall ensure that they display to players of such video game products the terms which expressly prohibit the content and conduct as described in Article 9.2.1, and that they inform them about the consequences if the terms are not respected.

9.5    Safety Warnings: Signatories shall advise players in Online Gameplay Environments under their control of the desirability of taking regular breaks from gameplay.

9.6    Education: Signatories are encouraged to provide regular training to their staff on the rhetoric and tactics used to promote content prohibited under this Agreement in Online Gameplay Environments that allow user-generated content. The sharing of best practices with other entities is encouraged.

9.7    Privacy: Any Signatory engaging in the online collection of personal information from players shall maintain an effective and coherent Privacy Policy fully in accordance with all applicable European Union and national data protection laws.

9.8    Clear Language: Where an Online Gameplay Environment is explicitly targeting children of a literate age, any privacy-related information and communication, in particular those related to the mechanisms allowing to report prohibited content or behaviour, should be conveyed in clear and plain language or in a medium that such children can easily understand.

Article 10: LABELLING

10.1    The PEGI Logo and Descriptors shall appear on or in connection with the video game product in a size that permits the message to be legible and clearly visible to the consumer at the point of sale, in accordance with the templates set out in the Labelling and Advertising Guidelines that are made available and regularly updated by PEGI.

10.2    Article 10.1 shall apply to all types of distribution of video game products to the public: sale, rental, lending or cloud by digital retail platforms as well as sale, rental or lending by physical retailers.

10.3    Signatories shall ensure that the PEGI Logo and Descriptors are used in accordance with any national legal requirements and that, in particular, they are not used in countries where the Product is prohibited or subject to compulsory content classification.

10.4    Signatories shall use their best efforts to encourage online service providers carrying, featuring or advertising their video game products, but not under the Signatory’s control, to display the age ratings and descriptors for those products within those online services, in accordance with the PEGI Labelling and Advertising Guidelines.

Article 11: ADVERTISING AND PROMOTION

11.1    Promotional materials shall follow the PEGI Labelling and Advertising Guidelines including as to the display of the age rating of the product.

11.2    The design, broadcasting and targeting of print, tv and on-line advertising of video game products shall also comply with laws and regulations.

11.3 More generally, the following principles shall apply:

i. All advertisements shall accurately reflect both the nature and content of the video game product publicized and the rating associated with it. Advertisements should not mislead consumers as to the video game product’s true character.

ii Advertisements shall not use the PEGI age rating for other purposes than informing consumers about the age suitability of a game.

iii. All advertisements shall be created with a sense of responsibility towards the public.

iv. No advertisement should contain content that is likely to cause serious or widespread offence to the average consumer targeted.

v. Signatories shall not specifically target advertising for video game products rated 16 or 18 to consumers for whom the product is not rated as appropriate.

vi. Signatories shall ensure that ancillary or separate products that are being sold or promoted in association with a core video game product contain content that is appropriate for the audience for which the core product is intended.

vii. Signatories shall not enter into promotion of video game products rated 16 or 18 with another company’s brands, products, or events, if it is reasonable to believe that such company’s products, brands or events will reach consumers for whom the video game product is not rated as appropriate.

viii. Signatories shall inform the public by means of a general statement of the existence of sponsorship(s) and/or the existence of product placement(s) associated with any video game product. Use of a trademark or brand solely to provide authenticity to the video game product environment shall not be held to constitute either product placement or sponsorship provided that those with a right to use such mark or brand do not receive payment in exchange for such use.

Article 12: PEGI COUNCIL, LEGAL COMMITTEE AND EXPERTS GROUP

The PEGI Council (“PC”) and PEGI Experts Group (“PEG”) and PEGI Legal Committee (“PLC”) shall ensure that the Code evolves in line with all relevant social, political, legal and technological developments.

The PC comprises:

• national representatives from the counties that use the PEGI System,
• representatives from PEGI and the Administrators,
• other members as deemed appropriate by agreement between the PMB and the PC.

The PEG comprises:

• academic professionals in the fields of (child) psychology, media, sociology and minor protection law,
• content classification and age rating experts,
• videogame industry experts,
• parents and consumer organisation representatives,
• other experts in their field as considered appropriate and necessary.

The PLC comprises:

• lawyers expert in European minor protection laws,
• videogame industry experts,
• academics,
• other experts in their field as considered appropriate and necessary.

Article 13: COMPLAINTS BOARD

The PEGI Complaints Board (“PCB”) is responsible for: 

• handling possible rating conflicts between Signatories and the PEGI System
• processing age rating complaints by consumers.
• handling possible complaints about the consistency of advertising, marketing and promotional activities of any Signatory with the age rating finally attributed or likely to be attributed under the PEGI System;

The PCB will draw on similar expertise to the PC and PEG.

Article 14 ENFORCEMENT COMMITTEE

Compliance with this Code, the provision of advice to Signatories and the PEGI Administrator and the imposition of sanctions on Signatories infringing the Code, shall be entrusted to the PEGI Enforcement Committee (“PEC”) which shall be made up an equal number of carefully selected representatives of the industry and PC members, as nominated by the PMB.

Article 15: INFRINGEMENT, CORRECTIVE ACTION, SANCTIONS AND ARBITRATION

15.1 In addition to infringements identified by third parties or the Administrator, the PEC and the PCB shall jointly identify and document any possible wrongful application and/or breaches of the Code. Reasonable, non-arbitrary discretion will be used in examining all relevant facts to enable a determination of appropriate sanctions.

15.2 The PEC and PCB may suggest corrective action commensurate to the violation, to be implemented immediately. This corrective action may include:

• re-labelling of packaging,
• revocation and removal of the Logos and Descriptors, 
• recall of inaccurately labelled product.
• modification of advertisements both on and offline.

15.3     Failure to abide by the terms of this Code, including the failure to institute the corrective action referred to at 15.2. above will expose offenders to the imposition of sanctions by the PEC as set out in Annex A including, but not limited to, the following:

• temporary suspension of product from the PEGI System,
• mandatory modification of any associated advertisements both on and off-line,
• disqualification of product from the PEGI System for a set period,
• fines of up to € 500,000 per violation depending on the gravity thereof and the failure to take appropriate remedial action.

         Violations warranting these sanctions include

• presenting misleading or incomplete material to support the original application for a PEGI rating license,
• failure to submit changes, updates, or modifications that affect the ability of the Signatory to comply with its obligations under the Codes in a timely fashion,
• self-application or flawed display of  the Logos and Descriptors by a Signatory,
• unlicensed or inappropriate display of the PEGI Online Logo.
• inappropriately targeted marketing,
• more generally, all steps or omissions that fail to show a sense of responsibility towards the general public. In this regard the deliberate failure by a Signatory to disclose relevant content which is discovered after Logos and Descriptors have been assigned shall be material grounds for consideration of high level sanctions by the PEC.
• those steps and omissions set out in Annex A.

15.4 The PEC shall be able to take into account on the application of a Signatory, or otherwise, any or all extenuating circumstances justifying moderation of any sanction to be applied.

15.5 Any PEC decision imposing a sanction on a Signatory can be referred by that Signatory, within thirty days of the date of the PEC decision, to final and binding arbitration by CEPANI, the Belgian Centre for Arbitration. Arbitration shall be the sole method available to challenge any decision of the PEC. Imposition of any sanction shall await the decision of CEPANI.

15.6 PEGI shall create, maintain, and update on a regular basis a publicly accessible database containing all decisions regarding enforcement of the Code. The said database shall be designed to be easily accessible by users, allowing for browsing of decisions and sanctions and shall include filters for dates of decisions, subjects and other relevant parameters. Signatories recognise the essential role this database plays, and solely reserve the right to request their anonymity in the entry that is publicly available.

ANNEX A

BREACHES OF THE CODE OF CONDUCT AND RELATED SANCTIONS

LEVEL I. VERY SERIOUS 

Failure to Disclose Significant Content

This can be defined as a deliberate failure to disclose, or gross negligence* leading to a failure to disclose significant aspects of a product which would have led to the assignment of a higher age rating to that product than the rating actually assigned to and displayed on the product under the PEGI rating process and the targeting of advertising for a product at consumers, especially children, for whom the product is not rated as appropriate.

The fact that this behaviour causes significant damage both to the integrity of the PEGI System and the public’s use of or trust in the system is reflected in the sanctions set out below.

SANCTIONS

First Breach: 100,000 to 250,000 Euro Fine 
Second Breach: 250,000 to 500,000 Euro Fine 
Third Breach: 500,000 Euro Fine

Additionally, a period of disqualification from the PEGI System may also be imposed the duration of which will depend on the severity of the breach.

In all the above cases the PEC may also elect to impose sanctions including the removal of the product from the market in order to resticker all existing product in line with the appropriate age rating.

* In case of doubt ‘gross negligence’ will not be held to have taken place;

1. where a genuine mistake has been made by the person assessing the content of a product and/or
2. where there was a subsequent genuine attempt made by that person to correct the assessment as soon as possible after becoming aware of the mistake

LEVEL II. SERIOUS

These include the following:

• Negligence leading to a failure to disclose significant aspects of a product which would have lead to the assignment of a higher age rating to that product than the rating actually displayed on the product when sold to the public. ‘Negligence’ will be held to exist where the content has been assessed but, through error or omission, content significant to the rating assigned has not been taken into account.
• Failure to comply with a sanction imposed by the PEC
• Failure to respond to an inquiry by the Administrator or the PEC
• Failure to submit changes, updates, or modifications that materially concern the age rating assigned to a product and are made after the product has received that rating.
• Using PEGI logo or content descriptors which have not been assigned by the Administrator by way of licence.
• Failure to display a PEGI age rating or display of an incorrect PEGI rating
• Failure to display a PEGI content descriptor or the display of incorrect content descriptor
• Using advertising which is inconsistent with a PEGI rating (not ‘very’ serious) or which exploits a PEGI rating by, for example, drawing attention to an 18 rating as a device to encourage sales of the product concerned.
• Using advertising which is offensive or which otherwise does not reflect a sense of responsibility towards the public or to the PEGI System.

SANCTIONS

First Breach: 5,000 to 20,000 Euro Fine 
Second Breach: 20,000 to 50,000 Euro Fine 
Third Breach: 75,000 Euro Fine

In all the above cases the PEC may also elect to impose sanctions either of removal of the product from the market or restickering or relabelling of all existing product in line with the appropriate age rating.

LEVEL III ADMINISTRATIVE/OPERATIONAL

• Failure to display correct PEGI rating on Demo or Trailer
• Wilful failure to submit complete and accurate submission materials, when discovered before release of the product.
• Negligent supply of incomplete, inaccurate or inconsistent content in submission materials leading to rating errors which are discovered before release of the product.

SANCTIONS

First Breach: up to 5,000 Euro Fine 
Second Breach: 5,000 to 7,500 Euro Fine
Third Breach: 10,000 Euro Fine and/or a period of disqualification from the PEGI Rating System depending on the severity of the breach

ALL LEVELS - RETRAINING OF CODERS

In all levels and cases of breaches of the Code of Conduct the imposition of a sanction requiring the retraining by the Administrator of all PEGI Coders employed by that company shall be at the discretion of the PEC. 

ALL LEVELS – SYSTEMATIC SCREENING OF FUTURE PRODUCT

In all levels and cases of breaches of the Code of Conduct the PEC may require systematic screening of product to be released in the future for a period to be determined and also the payment of any additional costs caused by this measure.

ALL LEVELS - BREACHES AND TIME LIMITS

In the case of sanctions to be applied the following Time Limits shall be held relevant in determining whether a company under sanction shall be considered by the PEC to be of past good conduct;

LEVEL I 
All breaches shall stay on a company’s PEGI record for a period of three years from the date that the related sanctions were imposed
LEVEL II
All breaches shall stay on a company’s PEGI record for a period of two years from the date that the related sanctions were imposed
LEVEL III
All breaches shall stay on a company’s PEGI record for a period of one year from the date that the related sanctions were imposed

After the expiration of the appropriate time limits as set out above the PEGI record of the offending company shall be considered free of any breach of Code of Conduct. However the PEC when considering sanctions for a breach at any one Level shall be entitled to take into account other breaches at all other Levels and can impose any discretionary penalties available under the Code for breaches at the Level under consideration.

ALL LEVELS - PUBLICATION OF DECISIONS

The PEC reserves the right to publicise details of all and any sanctions imposed for breaches of the Code of Conduct.

ANNEX B

PEGI RETAIL CODE

The Code applies to retailers in the European Economic Area territories and in Switzerland who have signed this Code and covers computer and video products that have been rated under the Pan European Game Information (PEGI) rating system. Retailers adopting this Code must use best efforts to comply with the policies outlined below when engaged in face to face transactions with customers.

Each signatory of this Code agrees to:

1. Train all appropriate managers, clerks and/or other employees so that they are familiar with the PEGI age ratings system and the policies adopted in this Code;
2. Display in a conspicuous location where product is displayed signage describing the PEGI age rating system;
3. Treat the PEGI age recommendations as mandatory and use reasonable endeavours to ensure that computer and video  games are not supplied to persons below the specified age;
4. Assess existing internal policies, practices and procedures on ratings education and policy enforcement and make improvements where necessary to maintain compliance with the Code;
5. Clearly and conspicuously display rating symbols and, where feasible, content descriptors, in all advertising, marketing and promotion of games;
6. Where practical, endeavour to keep a refusals record when sales of PEGI labelled products are refused to customers of inappropriate age;
7. Respond to customer complaints about non-compliance with the Code and keep a record of such complaints;
8. Advise customers to submit a complaint at the PEGI website (www.pegi.info) when a complaint cannot be resolved at the store level;
9. Regularly share information on best practices to further develop and improve compliance with this Code;
10. Accept that, if a Signatory has failed to fulfil the letter and spirit of the Code, PEGI may provide notice to the Signatory summarizing the deficiency and provide a period of 30 days to improve, after which time PEGI may determine that the Signatory has not made sufficient improvement and exclude him from the Code;
11. Be entitled to terminate its participation in the Code at its sole discretion by providing written notice of such termination to PEGI.