C060762/0164007/1313270.4
Policy on the Sale of M-rated Video and PC Games
GameStop is dedicated to addressing consumer concerns regarding the content of certain video
and PC games. The company prohibits the sale of M-rated (as defined by the Entertainment
Software Rating Board (ESRB)) video games to customers under the age of 17 years old. The
policy requires employees to ask for identification of any customer purchasing an M-rated game
that appears to be under the age of 25 years old. All store employees are trained regarding these
procedures and the store manager, as well as the employee, must sign an acknowledgement that
the employee has reviewed and been trained on the company’s policy. Failure to follow the
company’s policy results in a “first and final” warning. If the employee is caught violating the
policy after such warning, the employee is subject to disciplinary action, which may include
termination of employment.
To promote compliance with the company’s policy, the company has developed a point-of-sale
register prompt reminding the employee of the age requirement for purchase. The prompt
requires the cashier to confirm the age of the customer before selling an M-rated video or PC
game and, for ease of reference, provides the employee with the exact date which the customer’s
birth date must be prior to in order to purchase the M-rated video or PC game. Monthly emails
are also sent to stores reminding them of the importance of compliance with the company’s
policy.
GameStop also believes that the best way to ensure that M-rated video games are not sold to
minors is to educate its customers on the ESRB rating system. To this end, GameStop features
numerous signs posting the rating system in each section of its stores and at the sales counter and
also includes ESRB information prominently displayed in the majority of its monthly shopping
catalogs. These measures serve to educate the company’s customers on the ESRB program and
reinforce the company’s dedication to the rating system. In addition, GameStop does not carry
adult-only games.
For products rated by the ESRB, GameStop also conspicuously displays on its websites a graphic
image of the product’s ESRB rating on each product detail page. Product pages also include
descriptions next to the rating containing more specific detail on the rating.
The company also has in place a secret shopper program to verify store compliance. These
random checks, conducted throughout the company’s store base multiple times each year, allow
the company to take appropriate action to correct problems immediately, if any are found.
Through these policies, GameStop is dedicated to ensuring that M-rated video and PC games are
not sold to minors.
