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Submission to the Standing Committee on Justice Policy
Bill 158, Film Classification Act, 2004
Commitment to Parents

Canadian retailers are in agreement with the Ontario government regarding the policy issue of preventing the sale or rental of adult material to children and are committed to assisting parents in making informed entertainment choices for their families regarding the purchase or rental of interactive video and computer games. We share a common objective with provincial governments across Canada — supporting parents in protecting their children.

That is why, at the behest of our members, Retail Council of Canada (RCC) launched a national rollout of Commitment to Parents in October 2004. RCC was pleased to work together with Ontario's Minister of Consumer and Business Services to launch Commitment to Parents last fall. We applaud the Minister for his leadership in actively supporting this significant initiative.

The Commitment to Parents initiative limits the sale or rental of mature or adult oriented video games to children through a system of video game ratings on the packaging and point-of-purchase controls. This is a highly successful voluntary program of self-regulation that began in British Columbia in 2001.

The Commitment to Parents program evolved out of the collaborative efforts of Retail Council of Canada, the Entertainment Software Association of Canada (formerly the Canadian Interactive Digital Software Association — CIDSA), the Entertainment Software Ratings Board (ESRB), and the Government of British Columbia.

Participating retailers in Ontario and across Canada check age identification to ensure "Mature" rated video games are not sold or rented to customers under the age of 17. Working closely with the Entertainment Software Ratings Board, retailers also work to educate parents on the need to pay close attention to the games their children are playing and how the ESRB ratings system can assist them in that regard. Retail Council of Canada consulted extensively with government officials in Ontario, as well as in other jurisdictions, in order to create this comprehensive national program.

Under this approach, the video gaming industry will continue to ensure that all of its products are properly rated by the Entertainment Software Rating Board, the North America-wide agency established in 1994 to develop the standardized rating system. The rating system consists of six symbols prominently displayed on game boxes to tell parents what age the game is appropriate for. Also appearing on each box are descriptions of content elements.

The national Commitment to Parents program also ensures that the ESRB ratings are easily recognized and well understood through "OK to Play" marketing materials. Participating retailers are currently distributing this educational material in order to raise awareness and provide parents with detailed information regarding the ESRB rating system. The video gaming industry, along with major retailers, are working together to make sure that the games purchased or rented by minors are appropriate to their age.

The Commitment to Parents program also includes a consumer redress mechanism should a retailer fail to adhere to the national code. The Consumer Complaint process establishes that a retailer that sells or rents an AO or M rated video game to a minor will, at a minimum, provide the consumer with a full refund on the cost of purchase or a free rental on another video or computer game. For further information, the full version of the Commitment to Parents National Retailer Code is included with the submission. (See Annex 1)

Commitment to Parents is an extension of retailers' commitment to customer service, and will help make parents in Ontario and Canada better equipped to decide what is appropriate for their children. With the growth of the Internet and other non-traditional forms of retail, parents must be more vigilant than ever in ensuring the games their children play are appropriate to their age.

Educating parents must be an important part of this process. As part of the program, the industry and retailers launched a public awareness campaign to educate and inform parents about the rating system. The "OK to Play" campaign includes point-of-purchase displays, informational brochures and rating cards for parents. (See Annex 2) It is our hope that by taking these actions, retailers in Ontario and across Canada can support parents in protecting their children.

In this instance we all share the same goal: To support and empower parents ... to ensure they have the information and tools they need to make their decisions about what is appropriate video and computer game programming for their children.

We start with the premise that the best control of entertainment is parental control and there is no better place than a retail store for parents to control the content of the video and computer games to which their children have access.

Above all else, Commitment to Parents is about retailers helping parents making more informed entertainment choices for their families through a parental empowerment program that combines ratings education with voluntary ratings enforcement.