THE GAMES RATING AUTHORITY
ANNUAL REPORT &
ACCOUNTS 2015
THE GAMES RATING AUTHORITY
ANNUAL REPORT &
ACCOUNTS 2015
Presented to Parliament pursuant to section 6 (2)
of the Video Recordings Act 1984
The Video Standards Council
Suite 4a, Salar House
61 Campfield Road,
St Albans, Herts
AL1 5HT
02037 718543
www.videostandards.org.uk
www.gamesratingauthority.org
[email protected]
© 2016 The Video Standards Council
CONTENTS
Page 1
From the Chair
Page 3
Moving Forward
Page 6
Video Game Classification in 2015
Page 12
The age rating process
Page 16
An overview of UK activities
Page 18
UK Public Attitudes Survey
Page 25
IARC (International Age Rating Coalition)
Page 26
VSC Board, panels and senior executives
Page 28
Statistics
APPENDIX
Page 29
Directors’ report & accounts 2015
The Video Standards Council was established in 1989 and fulfils two basic
roles:
It is a standards body for the video and video games industries and has a Code of
Practice designed to ensure that both industries show a duty of care in their dealings
with customers and the public generally. It provides its retailer members with a staff
training course dealing with age restricted videos, DVDs and video games.
It acts as an administrator of the PEGI system of age rating for video games. PEGI
is used in over 30 European countries.
In 2012 it was designated as the UK regulator responsible for the age rating of video
games supplied on physical media (using the PEGI system.) In fulfilling this role, it
uses the name Games Rating Authority (GRA.)
FROM THE CHAIR
The VSC has had another excellent year and has continued to work to increased
demand and deliver to exacting standards. The staff of the VSC are committed to an
ethos of continuous improvement and I am frequently impressed by their innovative
approach to the way the organisation adapts to an ever changing business
landscape.
There has been a considerable effort to promote greater awareness of the work of
the VSC and of the Games Rating Authority (GRA) which is a subsidiary company
of the VSC and which deals with the mandatory games rating process which forms
much of the work undertaken by the staff. The extensive development of the VSC
website in the past twelve months has been a significant highlight. The website has
undergone a complete change and now offers all users an opportunity to access a
wide range of information for all stakeholders in the world of video games. Not only
does the website provide vital help and information to those in the retail side of video
games, but it also provides guidance to parents and children about the content of
video games and explains the game rating process. The website is easy to access
and is very user friendly.
A notable feature of the new website is the amount of information available to parents
and teachers, and in particular an easy to follow guide for “parental control” on all
major electronic devices. Quite simply parents now have access to a wide choice of
information about video games providing them with the facility to make informed
choices about which games are suitable for different ages of children.
The VSC has placed a high priority on developing its relationship with those involved
in education and there has been a great deal of activity with universities and colleges,
as well as with Head Teachers and Local Authorities. This forms part of the
continuous work to promote awareness of the role and work of the VSC as well as
contributing to the wider effort on the subject of “Internet Safety” which is seen as so
crucially important.
The VSC continually monitors the landscape in which it operates in order that it may
adapt to any changes as they occur. This is both important and necessary in terms
of keeping the work of the VSC and GRA properly focussed but also essential in
terms of positioning itself in such a fast moving and dynamic environment. The Board
of the VSC will assist where possible.
In last year’s annual report specific mention was made about the development of the
International Age Rating Coalition (IARC) which provides a global age rating system
for games “Apps”. A fuller description of IARC is contained within this report but I
would like to express the appreciation of the Board of the VSC for the work our staff
carried out with their international counterparts. The development of IARC has seen
exceptional collaboration and cooperation in producing such an effective process.
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There are many organisations with whom the VSC work in such a constructive way.
In particular I would like to thank Jo Twist, Chief Executive Officer of UK Interactive
Entertainment which is the trade body representing the UK’s video games
publishers. The Board of the VSC are often hosted by UKIE in their London offices
for the purpose of holding our Board meetings and we are very grateful to them.
I would also like to thank Iain Muspratt (Vice Chair of the VSC) for his continuing
involvement and enthusiasm. His extensive knowledge of the video games industry
is of enormous value to all involved.
Tony Lake OBE QPM
Chair of the VSC
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MOVING FORWARD
2015 proved to be a busy year for the Video Standards Council, especially going
through the upheaval of an office move as we relocated to new premises in St
Albans. This was particularly challenging as we had to maintain the fast track
examination time period for PEGI video game ratings at the same time as settling
into new accommodation. Fortunately, the dedicated staff took this in their stride
and nobody experienced any delay.
The VSC and PEGI carried out research to assess United Kingdom public views on
certain aspects of the PEGI rating system used in the UK. More details are provided
later in this report, but one major finding seemed to indicate an anomaly that while
the ratings were recognised, known, understood and apparently trusted, PEGI the
organisation itself was not particularly well-known to UK consumers. This has led
the VSC to attempt a larger promotion of the PEGI system amongst the UK games
consumers.
We made a decision to change our VSC company logo so as to incorporate the use
of the term GRA. The Games Rating Authority (GRA) is a subsidiary company of
the Video Standards Council and is the name under which we carry out the
mandatory video games rating process for the UK. This was done in an effort to help
put across a message that the ratings seen in the UK are obligatory, binding and
carried out with legal authority; this is in addition to the core values of the VSC being
fair, appropriate and responsible.
This theme played a large part in our activities in trying to make consumers,
particularly parents, more aware of the PEGI rating system and the meaning of the
ratings in terms of game content. We have given presentations to schools and
colleges and have taken part in two-way, online discussions with school assemblies
using the ‘skype’ communication system. We are also currently developing
resources for teachers, designed for each of the educational key stages and working
with schools to form focus groups to help us perfect the resources and methods of
delivery.
Where possible we try to assist in promoting safety online for young people. To this
end we have given a presentation to a large conference organised by a local
authority and attended by a large number of delegates mostly involved either with
teaching or protecting young people. This has led to us providing more resources
for organisations concerned with online safety; not least our comprehensive guide to
the use of parental control on devices.
We have attended consumer video game exhibitions where we have provided
literature and information explaining the PEGI rating system and encouraging
parents to refuse access to games not suitable for their children. These have proved
successful and have led to more enquiries from teachers requesting further
information on the rating system.
In conjunction with UKIE, the UK video games publishers’ association, the VSC
provides advice, materials and financial support to an online presence through a
website www.askaboutgames.com. This website exists to promote family values in
gaming. It explains the rating system as well as providing content information for
specific games so as to help parents when making decisions regarding game
purchases.
It is also right to give as much information to younger people as we can as to why
games receive a certain rating and to this end we have extended our use of social
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media, Facebook and Twitter, in an attempt to attract the younger audience. This
has been showing some success with responses steering the type of material that
we produce.
The VSC website has been updated. This carries much information on the PEGI
rating system and includes extended consumer advice on specific game content
which shows the reasons for the rating that has been applied and is the only place
where this information is available. In addition, we have recently developed an app
which will make this information available on mobile devices and we are currently
working on methods to roll this out for the most effective consumer use at the point
of sale. We hope this will allow parents to find out, in quite some detail, the content
and appropriateness of a game before making a purchase.
We believe that the point of sale remains an important element in the protection of
children from inappropriate content. As well as providing industry guidelines and
point of sale signage, the VSC has continued to enhance its elearning programme
which provides training to retail staff on the legislation and responsibilities associated
with the sale of video and video game material. We have formed a partnership
arrangement with Trading Standards so as to gain assured advice when necessary
and to also obtain agreement and approval on the content of the elearning packages.
The VSC maintains the records in relation to the training so as to be able to prove
satisfactory completion where necessary. There are several thousand retail outlets
involved in the training system. Unfortunately, even though the training, when
carried out correctly, does provide the due diligence required of retailers, it has
proved very difficult to persuade major retailers to make use of the VSC training in
place of, or alongside, their own in-house training.
In the year under review the number of games examined by the VSC that eventually
received a 12, 16 or 18 age rating has risen slightly from the previous year. This
includes all games, those distributed digitally as well as those distributed on physical
media. Although the VSC has the legal ability and responsibility to refuse a
certificate for the release of any video game that might cause harm, or which
contains illegal material, no game has been considered to fall into this category.
Complaints about the PEGI rating system are generally received via one of three
routes: directly to the PEGI website complaint page, from the complaint page on the
VSC updated website and from the complaint and comment port operated by Ofcom.
The vast majority are made directly to PEGI although some more comments are now
being received through the VSC website. Some of the complaints have tended to
be about the age level of the rating and these, more often than not, contain
comments such as “Now my parents will not let me have it”. Perhaps this could be
considered as an endorsement that the system works?
All complaints directly to PEGI are answered either by the PEGI administrator (VSC
or our colleagues at NICAM in Holland) when it is a matter of providing information
to satisfy the enquirer, or referral to the PEGI complaints board for more serious
matters. The PEGI complaints board has not had to deal with any this year.
The enquiries received through the VSC website have tended to be more concerned
with the retail aspect of video games. Where possible the VSC has contacted the
retailer involved to try to resolve the issue, although in some cases the matter has
been referred to Trading Standards for them to determine any necessary action.
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The VSC has continued to be a part of and to financially support ‘Parentport’ the
complaint and comment portal operated by Ofcom. This has resulted in five
comments being received by the VSC over a three-year period.
Although we have not had to ‘ban’ any game this year we obviously maintain the
formal appeals panel that would be required to adjudicate on any appeal made
against a decision to do so. The panel, chaired by Baroness Kennedy QC and
comprising other members eminent in their field, requires reminders and updates on
matters relating to video games rating. This year, in the form of a mini table top
exercise, they were presented with a simulated scenario involving the refusal of a
UK certificate for a fictitious game. The panel then discussed the facts and related
issues before coming to a decision based on their discussions. In the discussion,
each panel member gave the rationale for their decision. It proved to be very
interesting and beneficial to the VSC executive, persons designated under the Act
and the panel members themselves. The discussions led to further thought and work
on refining the process to be used should a certificate ever be refused.
There have been significant changes in relation to IARC, the global rating system for
games and apps provided for mobile devices in which the VSC has played a major
role in its development. The system has been taken into use by Google, one of the
largest providers through their storefront. Other providers such as Nintendo and
Microsoft have also made a decision to use the IARC system which brings
standardised symbols to the online world.
Peter Darby
Director General
5
VIDEO GAMES CLASSIFICATION 2015
With the exception of one game (see below) there have been no notable video game
controversies this year and certainly none that have required intervention by the
GRA.
To help illustrate how classification decision making has been carried out during
2015 this section discusses a selection of games from across the age category range
to give a flavour of the kind of material we deal with on a daily basis. The games
noted below have been selected either because they feature unique gameplay
elements, or provide absorbing and enjoyable game-playing experiences.
HATOFUL BOYFRIEND: HOLIDAY STAR (PEGI 12)
This is a slightly odd Japanese, ‘dojin soft’ visual novel in which the player occupies
an alternative Earth populated and ruled by birds.
This title, Hatoful Boyfriend: Holiday Star, continues from its predecessor as a set of
episodic modules based around the holiday season. Unlike the first game (Hatoful
Boyfriend), Holiday Star is a mostly linear visual novel with more standalone
scenarios and fewer branching plotlines.
The game was initially rated PEGI 12 for ‘Horror’ in respect of a momentary scene
within the game in which a character displays suicidal tendencies.
The publisher provided video clips which show a character talking about wanting to
die, of having no friends and of being an underachiever. This short, isolated scene
attempts, perhaps, to reflect the sort of concerns experienced by Japanese high
school students. However, this depressing monologue is clearly tempered by the
fact that it is being spoken by an animated bird rather than a human being, albeit an
anthropomorphic one. The script and game were reviewed further in light of this
scene and whilst the game could have been accommodated at PEGI 7, these suicide
references were considered unhelpful and unsuitable to this age group and the PEGI
12 rating was confirmed.
AMONG THE SLEEP (PEGI 12)
“Among the Sleep” is a first-person horror-adventure in which the player takes on
the role of a two-year old toddler. The player can move the cursor to walk, run or
crawl around the environment. The player can interact and push objects or open
doors and windows. Problem-solving skills are also brought into play such as how
do you open a door handle that appears to be a lot higher than you can reach? In
which case the player will have to push and climb up chairs or other objects in order
to reach. On route, the player can also collect and store various items which can be
used later.
For most of the game, the player is accompanied by a sentient teddy bear named
“Teddy”. The player can hug Teddy who emits a warm glow that helps the player
navigate through darker environments whilst providing comfort in the dark, eerie
locations.
So far, so normal, but the makers have added an effective twist in the form of two
scary creatures: a feminine figure that haunts the first three levels, and a trench
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coat-wearing figure that haunts the final level. Whilst these monsters are unseen
their presence is indicated by the blurring of vision, grating sounds, and in the case
of the feminine figure, a slow lullaby (Troll mors Vaggsang, "Troll mother's Lullaby")
which is eerily hummed.
Unlike most other horror games, there is no way to fight the monsters and the toddler
character must either run away or hide underneath tables, beds or chairs until they
go away. If the player is not quick enough to evade the creatures a short video clip
plays showing the monsters taking hold of the child and resulting in a ‘game over’.
The almost wholly helpless nature of the character makes for a hair-raising and
chilling game-playing experience with many a ‘jump’ moment ready to send the
heart-rate soaring.
In terms of the PEGI criteria, the PEGI 7 rating allows for “Pictures or sounds likely
to be scary or frightening to young children.” However, a view was taken that
the game presented a much stronger experience given the almost relentless sense
of threat and fear throughout and was quite beyond what a young child or parent
should reasonably expect in a PEGI 7 game.
The PEGI 12 horror criteria offer a simple definition of such material: “Pictures or
sounds likely to be horrifying.” In the context of this game, ‘horrifying’ was
certainly more applicable than ‘scary or frightening’ and the game was finally rated
appropriately at PEGI 12.
STAR WARS BATTLEFRONT (PEGI 16)
With the much-anticipated release of the film, “STAR WARS: THE FORCE
AWAKENS”, it was inevitable that the game franchise was going to draw a large user
audience even though there is little narrative relationship between the film and the
game.
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The game features much in the way of combat using hand-held weapons or,
alternatively, taking control of aircraft or land-based mechs such as the AT-AT – a
four-legged combat walker. The violence, however, is relatively restrained and
wholly lacking in bloody or gory detail. This notwithstanding, the violence did meet
the PEGI realism criteria at 16 where depictions of “…realistic looking violence
towards human-like or animal-like characters” will engage that rating without the
requirement for blood or gore. Contributory factors include enemies falling down
limply when shot or struck, sometimes with a yell, and bodies remaining on the floor
for a short time before disappearing.
Additionally, Darth Vader and Emperor
Palpatine can also use their powers to choke or electrocute their enemies, causing
them to realistically struggle, writhe and yell in pain.
BLOODBORNE (PEGI 16)
The game takes place in the gothic, ruined city of Yharnam which is rumoured to
house a potent medical remedy. Over the years, the city has become a place of
pilgrimage for travellers seeking the remedy to cure their afflictions; the player takes
on the role as one of these travellers. Upon arriving in Yharnam, however, your
character discovers that the city is plagued with an endemic illness that has
malformed most of its denizens into bestial creatures. The player must navigate the
streets of Yharnam and overcome its violently deranged inhabitants and horrifying
monsters in order to survive and find the medical remedy.
The violence during the gameplay is somewhat mild with characters hacking,
slashing and shooting at each other with little physical response to these attacks.
However, copious blood effects are evident, though the game falls short of the kind
of decapitation and dismemberment elements that would have warranted a PEGI 18.
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HATRED (PEGI 18)
This game arrived with a fair amount of ‘baggage’ attached to it mainly because of
the notoriety it had generated via various online commentators, forums and the
popular press. The main charge made against the game was that it was a
gratuitously violent, race-hate inducing game designed to appeal to base instincts,
and one which should be banned immediately - these judgments mainly made on
the basis of a couple of minutes worth of YouTube video. As a result, the VSC
received a handful of emails from the public asking us to ban the game even though
it had yet to be submitted for a rating.
The game eventually became available to UK consumers though only as a digital
product sold through online platforms such as the US based ‘Steam’, and not through
UK retail stores. The game centres on an un-named psychotic killer whose stated
aim is to kill as many people as he can simply because he hates humanity. There is
no indication that the character is seeking to kill a particular racial group.
The game is set in a contemporary, urban environment thus creating a readily
recognisable and realistic setting. The moody and menacing tone of the game is
established by the use of grainy, monochromatic graphics with most of the action
seen from an isometric perspective.
The killer is required to eliminate a certain number of human targets in each level
whilst collecting assorted weapons and ammunition. Most of the targets are
unarmed civilians, but others are also armed and can fire back. In addition, and just
like Grand Theft Auto, the police will appear at regular intervals to ‘take down’ the
killer. The ability to stave off police intervention is solely down to the player’s skill
and ability. The number of cops does increase regularly even in “easy” mode, so it
is not just a simple killing spree that has no consequences as has been suggested.
There are missions within each level such as attacking a police station, a
supermarket and a party. Successfully completing a mini-mission rewards the player
with a respawning point.
As is the case with similar games, there is a law of diminishing return at work since
the gameplay is relatively restricted in terms of what there is to do. As you progress
through the levels, you gain more weaponry, but face harder enemies ad infinitum,
lending a repetitive, somewhat monotonous feel to the game.
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One of the more gruesome elements of the game is the ‘execution’ option. If you
shoot and merely wound a target, you can walk up to them, press ‘Q’ on the keyboard
and the game will switch to a brief video clip where the killer is seen to draw a large
knife which is then stabbed, sometimes repeatedly, into the victim with bloody effect.
He can also stamp on the victim, rifle-butt them or summarily execute them. The
player has no control over which execution technique is used.
There is no doubting the fact that the game readily attains its PEGI 18 rating for
strong, bloody violence and the focus on killing defenceless civilians, but there are
many such ‘rampage’ games passed at ‘18’ from which “Hatred” has clearly drawn
inspiration. These include THE PUNISHER, STATE OF EMERGENCY and
POSTAL.
In the final analysis, the VSC came to the conclusion that “Hatred” was not so
particularly unique or different that any form of action against it was necessary other
than applying a PEGI 18 rating. Precedents had already been set by the
aforementioned games. More importantly, the charge laid against the game that it
was likely to encourage or incite racial hatred was simply not evident.
APB RELOADED (PEGI 18)
This is a third person crime game which gives the player the choice of playing either
as a criminal or a law enforcement officer. Irrespective of the choice made, the
system will issue missions to the player which can be accepted or refused. As a
criminal you are required to embark on various crime sprees with or against other
players.
Initially, the character will start off carrying one weapon only, but as the game
progresses better weapons become available. These are required to kill other
players who will invariably have better and powerful weapons. To purchase
weapons, the criminal character's notoriety needs to be increased and this is
achieved through completing the missions. Money is acquired through acts such as
breaking into vehicles and buildings which increases the amount of money the player
holds.
In criminal mode, the player can use an assortment of tools and implements to
commit break-ins, but these do not constitute readily imitable techniques.
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As a law enforcement officer (an enforcer) the player is tasked in much the same
way, the character is required to apprehend or shoot criminals. The enforcer can
also use a firearm to shoot defenceless characters. However, the game system will
deduct points for this behaviour.
All characters can utilise vehicles within the game to move from area to area, whilst
doing so it is possible to run down pedestrians. They either bounce off the bonnet of
the vehicle or are run over.
The game is somewhat derivative in that much of what it presents has already been
done in any number of crime-based video games. Nevertheless, the game attained
its PEGI 18 rating as the overall content included depictions of motiveless killings to
innocent victims, violence towards defenceless characters and a number of strong
sexual expletives.
FALLOUT 4 (PEGI 18)
This is another much-awaited game which is set in a post-apocalyptic New England
in the year 2287, some 200 years after a nuclear war which destroyed the USA. The
player emerges from an underground bunker and into this devastated world.
The game allows the player to wander across New England – his goal is to find his
missing son – and whilst doing so, he can collect items to build equipment and
weapons, construct buildings and create habitable areas for the remaining humans.
The game world is enormous and much of the player’s time is spent exploring
different towns and areas whilst scavenging for food, spare parts and equipment.
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Though this game does not contain full-on, continuous violence, there are times
when the player is forced to defend or attack against assorted enemies. Firearms,
explosives and melee weapons are available and this will invariably result in strong,
bloody violence. This is made more notable by the use of an electronic targeting
system that focuses in on and allows the player to aim at specific body parts. In
addition, the player can also attack defenceless victims whilst the game also features
occasional strong language. These elements in the game are issues which are setout in the PEGI criteria for ‘18’ and the game was accordingly rated thus.
THE AGE RATING PROCESS
HOW IS A VIDEO GAME GIVEN AN AGE RATING FOR THE UK?
The VSC has adopted the name Games Rating Authority in respect of its games
classification activities both as the UK regulator and the PEGI administrator.
The PEGI system is internet based and is designed to be used by games publishers
from all over the world. In order to enter the PEGI system the games publisher has
first to enter into an agreement with the Interactive Software Federation of Europe
(ISFE) and amongst other things contractually agree to comply with the PEGI Code
of Conduct. In order to submit a game for a PEGI age rating the publisher has then
to nominate at least one ‘coder’ who will be the person responsible for completing
the online submission process and who will be the main point of contact with the
PEGI administrators.
In order to submit a video game for a PEGI rating the coder is required to complete
an initial online assessment form (available for download from the VSC website).
The answers provided in the assessment form will elicit a provisional rating for the
video game. The questions, associated help pages and associated criteria have
been established and developed over the years with the advice and guidance of
family welfare and child safety experts. They have also been designed to
accommodate particular matters of concern in any one or more of the countries using
the PEGI system. For example, they accommodate the UK concerns about bad
language and the Greek concerns about gambling. The PEGI philosophy is one
where the concern of one country is shared by all countries.
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Under the PEGI rules there are significant penalties for deliberately failing to disclose
relevant content in a game or being negligent (a possible fine of up to €500,000).
The requirement to complete the initial assessment form illustrates the need for a
separate approach to age rating video games. For a film it is straightforward. A film
is linear. If the film is 90 minutes long it takes 90 minutes to see everything in it.
Video games are both interactive and not necessarily restricted to a set time limit.
Every time the game is played the experience is different and different things are
seen. A single act of violence or use of a sexual expletive in a film may only be seen
or heard once. In a video game it may be seen or heard many times over as the
player endeavours to progress through each level of the game. To see everything in
a video game and every combination of its component parts is all but impossible.
The assessment form is completed by the coder on behalf of the games publisher
who knows precisely what the game contains and where.
The completion and submission of the assessment form and the establishment of a
provisional rating is a starting point only. At this stage a PEGI rating has not been
given. The provisional rating simply serves to establish which of the PEGI
administrators will examine the game.
Games with a provisional 3 or 7 PEGI classification are examined by the Netherlands
Institute for the Classification of Audiovisual Media (NICAM) in Holland. Games with
a provisional 12, 16 or 18 PEGI classification are examined by the VSC. There are
arrangements between the VSC and NICAM to ensure that all video games
submitted at 3 or 7 and which are eventually classified at 12 and above are examined
by the VSC.
Under the Video Recordings Act 1984, video games on physical media (such as
discs) that are unsuitable for younger children must be classified before they can be
supplied in the UK. Thus the 12, 16 or 18 classifications on these games are legally
enforceable and selling or renting them to anyone not old enough is a criminal
offence. Games suitable for younger children are exempt from any legal
classification requirements and PEGI 3 or 7 classifications are advisory only.
THE CLASSIFICATION CRITERIA
For violent video games there are degrees of violence. Gross violence and such
things as torture, sadism, horrific depictions of death or injury, motiveless killing and
violence towards vulnerable people will attract a PEGI 18 classification.
For video games attracting PEGI 16 violence is permitted at levels which fall short of
the violence attracting the 18 classification such as realistic violence and sustained
depictions of death or injury to human characters
For video games attracting a PEGI 12 the level of violence falls even lower and
includes such things as violence to fantasy characters and unrealistic looking
violence.
A similar approach is adopted when dealing with the other main rating issues such
as drugs, sex and nudity, crime, and bad language.
If the use of illegal drugs is shown in a game it will attract a PEGI 16 and if the game
in any way glamorises the use of illegal drugs the rating will be raised to PEGI 18.
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Sexual innuendo, images and descriptions as well as sexual posturing will attract a
PEGI 12. If the sex act is shown in a non-explicit manner or there is erotic or sexual
nudity the classification will rise to PEGI 16. If it does become explicit then it will go
to the PEGI 18 level.
If a game in any way glamorises crime it will attract a PEGI 16. A game containing
mild swearing will be given a PEGI 12 and the use of any sexual expletives will raise
this to PEGI 16.
It is useful to point out that once a single depiction of 18 level violence is identified
the video game concerned will never be classified at a rating lower than PEGI 18
regardless of any other content, A single depiction of violence in a game may be
seen many times over as the player may make many attempts to play through the
level of the game where the single depiction is.
EXAMINATION
The completed assessment forms for games given a provisional PEGI 12, 16 or 18
are submitted to the VSC, and subject to the PEGI fee being paid, the examination
process begins.
The game is allocated to a VSC examiner. Examiners have to be adept at playing
games and using the various games consoles, but they are essentially recruited for
their analytical skills. They have to be able to understand the criteria used at each of
the age levels and apply them to what they are seeing on the screen.
Before an examiner starts the examination the following must be supplied:
A copy of the completed game (including any additional material that will appear with
the retail version of the game).
Video footage giving an overview of the game and of sequences in the game
resulting in ‘yes’ answers in the assessment form.
Plus as much of the following as is available:
Storyline & manual
Any cheat codes, ‘God’ modes, walkthroughs and shortcuts.
Saved games at the beginning of sequences resulting in a ‘yes’ answer in the
assessment form.
Easy access to sequences resulting in a ‘yes’ answer.
Song lyrics and dialogue scripts.
If at any time the examiner wants more materials to be provided, the examination
stops until it is supplied.
The examiner then reviews the video footage supplied to ensure it is consistent with
the provisional rating. After that the examiner plays the game to the extent
necessary to establish that the supplied video footage is truly representative of the
game and that the game is unlikely to contain undisclosed pertinent content. The
examiner will then allocate an age rating to the game. If this is different to the
provisional rating the examiner will give the coder the opportunity to remove or alter
content giving rise to the different rating. If content is altered or removed, the
examiner will look at the amended version and allocate the appropriate rating.
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If the examiner comes across any particularly controversial content in a game, or
matters where there is any uncertainty as to the appropriate age rating there are
systems in place to refer such issues to senior VSC management
In practice nearly all differences between the rating given by the examiner and the
rating expected by the coder are resolved by the coder accepting advice from the
examiner in respect of necessary changes.
At the end of the examination a PEGI licence is issued specifying the classification
and content descriptors specified by the examiner. If the games publisher disagrees
with the classification given there is a formal PEGI appeals procedure available.
UK CERTIFICATES
The issuing of a PEGI licence for games rated 12, 16 and 18 does not give the games
publisher the ability to supply the game in the UK. It is at this point that the VSC
(operating as the Games Rating Authority) has to assume its position as the
designated authority. In this position it has to answer two basic questions:
Has the game been properly classified under the PEGI system?
Does the game contravene UK law?
The answer to the first question will of course be in the affirmative as the VSC itself
(as PEGI administrator) will have just rated the game using the PEGI system. In the
vast majority of cases the answer to the second question will be ‘no’. However, this
may not always be the case.
Before answering this question there are a number of UK statutes which have to be
considered dealing with such subjects as sexual content, pornographic images,
protection of children, cruelty to animals, private sexual recordings, obscenity and
tobacco advertising. Beyond this there is the Video Recordings Act which gives the
designated authority the ability to decline to grant a UK certificate (‘ban’ a game from
UK supply) upon the basis that the game contains significantly harmful content.
The process the VSC will follow upon initially considering a game should be ‘banned’
allows the game to be referred to an expert advisory panel. This panel (members
listed at page 25) will advise on all psychological, clinical, legal and research factors.
The designated persons (the VSC Chair and Vice-Chairs) will take this advice into
account when reaching a final decision on whether a UK certificate should be issued
or not. If they decide that a UK licence should not be issued, then the game is
effectively ‘banned’ from supply in the UK.
APPEALS
If a UK certificate is refused the games publisher concerned has a right to appeal
against this decision. In this respect, the VSC has established an independent
appeals panel and appeals procedure. The appeals panel comprises a Chair and a
team of members for the Chair to draw on to hear an appeal.
15
UK ACTIVITIES
INFORMATION
Websites
The VSC website has undergone a full redesign with the aim of making it more userfriendly and appealing to its target audiences. The website has always contained a
wealth of information for parents, retailers and game publishers, but this is now more
easily accessible with clearly defined areas. One of which is our new Parents section
where users can now view jargon-free parental control guides on all major devices
simply by clicking on the image of their console. It is also possible to view detailed
rating reports written by our examiners by searching for a game, allowing parents to
make more informed decisions.
www.videostandards.org.uk
The VSC fully supports the ‘ask-about-games’ website, a resource for parents
providing further information about video gaming. Featured here are two minute long
video game guide videos created in collaboration with ourselves that contain our
additional consumer information which explains to parents why each game got its
rating, alongside video clips taken from the game.
www.askaboutgames.com
The VSC continues to provide financial support for ‘Parentport’, an online portal
providing consumers with a one-stop-shop to direct their complaints or comments to
the relevant regulator. The site was established and is maintained by OFCOM.
Unfortunately, since its inception, this portal has resulted in only five minor
complaints/comments being received in respect of video games. The vast majority
of comments have been received via the PEGI website with, latterly, some being
received through the enhanced abilities built into the VSC website.
www.parentport.org.uk
Dealing with public complaints, queries and requests for information
Virtually all complaints, queries and requests for information are made directly online
to the PEGI public website.
www.pegi.info
These communications cover a plethora of topics but recent years would serve to
show that the volume of technical questions and comments on classifications is
decreasing and the volume of general requests for information about PEGI is
increasing.
Familiarity with the PEGI system has certainly increased over recent years.
However, the VSC recognises that there remains a great deal of work to be done in
terms of raising public awareness.
16
Although there is a centralised PEGI system for dealing with public complaints,
queries and requests for information the VSC does identify matters raised by UK
based members of the public. Where it concerns a UK specific matter then the VSC
deals with it. In any event all matters raised by the public are dealt with in a proper
and prompt manner.
TRAINING & EDUCATION
UK retailers
Since it was established in 1989 the VSC has provided its retailer members with staff
training guidelines designed to educate staff involved in the supply of video
entertainment about the law relating to age restricted videos and DVDs and the
consequences of supplying them to persons under the specified ages. The staff
training guidelines have now been amended to take into account age restricted video
games.
The VSC also provides its retailer members with other information and in store
display materials dealing with age restricted videos, DVDs and video games.
In addition, the VSC has established an online e-learning staff training programme
for its retailer members which now incorporates the new laws relating to age
restricted video games. The programme includes an exam designed to ensure that
members of staff have understood what their responsibilities are. The programme
produces an overview report for retailer members (both large and small) giving
details of each member of staff and their status so far as the course and taking the
exam are concerned. It provides retailer members with a very useful tool to ensure
that all members of staff have been properly trained.
In an effort to make our training more accessible to all of our members, the content
is now available across a range of formats, including DVDs, MS Powerpoint, and
PDF. When used as instructed, regardless of the format, the courses provide the
same high standard of training.
EDUCATION
Increasing UK public awareness of PEGI is and probably will remain at the top of the
VSC priority list for quite some time. Although awareness of PEGI has improved
greatly over recent years the VSC recognises that promoting PEGI ratings is
important to ensure that both parents and children understand why video games are
classified and the rationale behind these classifications.
In this respect the VSC has and will continue to identify opportunities to reach out,
not only to the public, but also to colleges, universities and other educational
establishments with a view to ensuring that the next generation of opinion formers
and parents are as knowledgeable and familiar with PEGI classifications as they are
with age restrictions for other media.
Within VSC resources we have already had a measure of success and have
conducted a number of presentations to educational establishments including the
Queen Mary University London, Stanmore College, Uxbridge College, Kidderminster
College and Lancaster and Morecombe College.
We have to acknowledge that this approach will be a gradual process since many
educational establishments do not always have space in their curricula to
17
accommodate us. In many cases we supply information and literature through our
websites.
In 2015 we also attended EGX, the video games show at the NEC in Birmingham,
which was attended by 75,000 members of the public where we had experts on hand
to explain the PEGI ratings to parents and young people.
UK PUBLIC ATTITUDES SURVEY
Analysis of Results of PEGI Sensibilities Report 2014
Ipsos MediaCT were commissioned to conduct a study in Great Britain to explore
consumer opinions in relation to the PEGI video game rating system. The intention
of the study was to explore how the PEGI age ratings for video games related to
consumer expectations.
The study was broken into three sections. The first looked at a comparison between
ratings for video and tv content and ratings for video games. The second section
examined attitudes towards sexual, flirtatious or provocative language, dressing or
behaviour and the third section explored the type of video game content thought
most important to control.
The approach was to ask about each of the content type starting with video games
given a PEGI age rating 18. If the respondent agreed with the content being allowed
at 18 they were then asked if it should be allowed at 16. This was repeated for each
age group until the respondent disagreed at which point the study moved to the next
question.
The respondents were asked which age group they were from, their gender, whether
they were video game players, whether they were parents, the age group of their
children and whether their children played video games.
Our analysis attempts to look at the correlation between the responses in the study
and the ratings supplied by the PEGI criteria.
The study began by asking a general question to probe views on ratings for different
media.
Question (general)
In the UK, movies, TV content (on DVDs/Blu-rays) and video games are all given an
age rating classification to provide a reliable indication of the suitability of content for
different age groups.
In general, do you think the age rating classifications applied in the UK are too strict,
not strict enough or about right for the following? The respondent was invited to give
an opinion on whether each of the movies, DVD/Blu ray and video games receive a
rating which is a) too strict, b) not strict enough, c) about right or d) does not know.
The responses showed that for movie and for DVD/Blu-ray content a majority (55%)
thought the ratings were ‘about right’. However, for video game content only 29%
thought the ratings ‘about right’ with 41% believing they were not strict enough. The
vast majority of these were female and respondents from the older age group (3564 years). Of the parents, 52% with children who played video games thought the
ratings ‘about right’, a figure which dropped to 20% of those
18
parents of children who did not play video games. 25% of the total responses were
in fact ‘Don’t know’.
Analysis:
PEGI is an age rating system designed to primarily provide information to help
parents make purchasing decisions relating to video games for their children. The
fact that 52% of parents with game playing children stated that they thought the
ratings about right would tend to indicate that it is achieving this aim.
Question 1a
Before today, have you heard of an age rating system for video games?
This was followed by
Question 1b
Before today, have you heard of an age rating system for video games called PEGI
(Pan European Games Information)?
70% of all respondents were aware of the existence of a rating system designed for
video games. However, only 21% overall knew about PEGI and surprisingly only
39% of gamers were aware.
Analysis:
The indication is that most people know that games are rated but do not know who
rates them.
Although PEGI has existed in the UK since 2003 the legal rating of video games was
historically associated with the BBFC. This changed in 2012 when PEGI became
the mandatory system. The Video Standards Council, PEGI and Ukie are carrying
out awareness programmes in an attempt to make the public more aware of the
PEGI system but this is probably an area where time will help. As gamers grow older
there will be more parents aware of the system.
Most of the awareness campaigns have been aimed at parents but the lack of
knowledge of PEGI by gamers possibly indicates that they are just looking at the age
without taking in who the body responsible for applying it is. PEGI insistence on
PEGI ratings being promoted during video game advertising, alongside promotions
by ‘askaboutgames.com’, should certainly help in this area. Perhaps the most
important aspect is that the majority of people know that games are rated and that
the video games industry is not a free for all, the understanding about those
responsible for the ratings can follow.
The next questions dealt with the actual content of video games.
Question 2a
Which, if any, of the following do you think should NOT BE ALLOWED within a video
game for those aged 18 or over? Please select as many or as few as apply.
1. Bad language
2. Depictions of, or material which may encourage discrimination (such as
race, gender, religion, sexual orientation or disability)
3. Use of tobacco or alcohol
4. Use of illegal drugs
5. Sounds or pictures that are likely to scare or frighten young children
6. Encouragement or teaching of gambling
7. Moderate nudity
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8. Violence (fantasy/non-realistic, strong/realistic)
9. The ability for players to connect online with people they may not know in
real life
10. The ability for players to pay online to access extra features/content
11. All of these should be allowed
12. Don’t know
The same question was repeated for each of the PEGI age groups with those points
already answered as ‘should not be allowed’ omitted from the list. The results were
then listed by content.
Bad Language:
Language was split into two, one dealing with strong bad language (sexual
expletives) and the other dealing with mild bad language.
79% of respondents thought that strong bad language should not be allowed for
videogames rated 12 whilst 74% thought that mild bad language should not be
allowed in videogames rated 7.
Analysis:
The responses are firmly in line with the current PEGI criteria dealing with language.
It is interesting to note that 25% of respondents thought that strong bad language
should not even be allowed at 18 and 9% thought that mild bad language should not
be allowed at 18. These responses indicate that although PEGI appears to be
getting it right the issue of language remains a concern.
Material which may encourage discrimination:
44% of all respondents believe that such content should not be allowed in
videogames rated 18 and this rises to 62% for those rated 16 with further increases
at lower ages. Amongst female respondents the figure is 51% at 18 rising to 70%
for videogames rated 16.
Analysis:
The question deals with depictions of encouragement, or material that may
encourage discrimination and not merely the showing of discrimination. The basis
for the discrimination was given as race, gender, religion, sexual orientation or
disability. The PEGI criteria will currently rate this type of material at 18. It should
be noted that material that encourages discrimination is very likely to be illegal in
most of the PEGI territories and therefore the video game would not be released
even with an 18 rating. It does however, clearly show that there is concern about
discrimination by a large majority.
Use of tobacco or alcohol:
The question only asked whether the use of alcohol or tobacco should not be allowed
and did not deal with encouragement of such use. 72% of respondents thought that
the use of alcohol or tobacco should not be allowed in videogames rated 12 and this
dropped to 42% for those rated 16.
Analysis:
This result is in line with the PEGI criteria except that PEGI examines the area a little
bit more finely and restricts anything that might in any way encourage the use of
alcohol or tobacco to age 16 and does not restrict depictions that are merely of a
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character seen smoking or drinking. Not surprisingly, parents of young teenagers
appeared to be more sensitive to this issue.
Use of illegal drugs:
67% thought that the use of illegal drugs should not be allowed in videogames rated
16 or over. This only dropped to 43% for videogames rated 18.
Analysis:
This question was similar to the question relating to alcohol and tobacco and did not
differentiate between the use of drugs and the encouragement of use. In the case
of illegal drugs PEGI actually restricts both the use of and the encouragement but
does this in different age groups with depictions of any use of an illegal drug rated
at 16. Anything that may encourage the use of illegal drugs attracts an 18 age rating.
The higher rating also captures those video games that may make activities such as
drug trafficking attractive even though no actual drug use is shown. Again, not
surprisingly, parents of young children and teenagers are particularly sensitive. It is
of interest to note that that this group of respondents also include those video games
aimed at older age groups within the issue.
Sounds or pictures likely to scare or frighten young children:
72% of respondents thought that this material should not be allowed for videogames
rated 7 with 47% believing that it should not be allowed in videogames rated 12.
Whether material is scary is subjective and very broad a further question was asked
which omitted the limitation of ‘to be likely to scare young children’. This gave
responses showing that 69% believed it should not be allowed in those rated 12.
Analysis:
Sounds or pictures likely to scare or frighten young children has always received a
rating of 7. However, recent changes to the PEGI criteria introduced a category
relating to sounds or pictures likely to be horrifying which produces a rating of 12.
This newer criterion would appear to equate to the ‘frightening’ element of the
question asked and it deals with the removal of the limitation ‘to only frighten young
children’ in the first question.
Encouragement or teaching of gambling:
Over half of the respondents believe that content that encourages or teaches
gambling should not be allowed in videogames rated 18 with the majority of these
being female. This figure rises to 75% for those who would not allow it in videogames
rated 12. The figures are very similar when comparing the views of gamers with
those of non-gamers.
Analysis:
Until a few years ago PEGI did not attach any age rating to this type of content.
However, due to problems in Greece relating to some hand held devices being used
by young people to play gambling content, possibly being illegal, PEGI raised the
age to 18. After some considerable time, this was reduced to 12. It must be pointed
out that none of the content allowed within the PEGI criteria refers to real gambling,
it only deals with content that allows the player to play games for fun but which still
teach the rules, etc. of the gambling game. Any content that allowed the real
exchange of money would not be rated by PEGI and would be governed by
legislation dealing with gambling.
21
Moderate nudity / Realistic depiction of sexual activity / Full nudity:
59% of respondents believe that moderate nudity should not be permitted in
videogames rated 12 with 11% believing that it should not be allowed in those rated
18. For the realistic depiction of sexual activity and full nudity, 34% believe that it
should not be allowed in videogames rated 18.
Analysis:
The only type of nudity permitted by PEGI below the age of 16 is nudity in a totally
non-erotic manner. This covers those depictions of natural nudity where there are
no sexual connotations. Although nudity is permitted at the 16 age group realistic
depictions of sexual activity with visible genitals is rated at age 18. In line with UK
video ratings, any content that is pornographic would receive an R18 rating and could
only be sold in licensed sex shops in the UK. Taking all of this into account would
indicate that PEGI ratings are broadly in line with consumer expectations.
Violence (fantasy / non-realistic) and strong realistic violence:
64% of respondents believe that fantasy or non-realistic violence should not be
allowed within videogames rated 12. 23% believe that it should not be allowed for
those rated 18 and over. With strong or realistic violence this figure rose to 63%
believing that it should not be allowed in those rated 16 and 39% believing it should
not be allowed for videogames rated 18 and over.
Analysis:
The responses for this topic are not consistent with the PEGI rating criteria.
Violence is a very difficult area to cover in this type of research as it is very subjective
and really requires some visual content to effectively pose the question. The majority
of respondents stated that fantasy violence should not be allowed in videogames
rated 16 but this content includes cartoon type depictions typically enjoyed in film or
DVD by young children. The same respondents have also stated that they believe
film and DVD ratings to be about right. This topic is probably worthwhile investigating
more finely at some later date so as to look at types of violence in a more granular
manner.
The next two questions dealt with online contact and in game / online additional
payments. These topics are not strictly part of the PEGI rating process, however,
they do form part of the information that is supplied to consumers.
The ability for players to connect online with people they may not know in real life:
60% or more of respondents would not allow this in videogames rated 12 whilst 15%
would not allow it in those rated 18.
The ability for players to pay online to access extra features/content:
The responses for this were very similar to the online contact questions although the
percentage not allowing it in those rated 18 dropped to 11%.
Analysis:
Although this is not part of the age rating process PEGI realises that it is information
that consumers want and forms part of the consumer information that is displayed
on the packaging. These are matters that are the responsibility of the individual
publishers who are the only ones able to place age restriction on either online contact
or the purchase of add-ons. Many already have this in place.
22
There appears to be some concern within the UK regarding the ‘sexualisation of
children’ and the next section of the research examined some thoughts about this
area within video games.
Use of mild sexual or flirtatious language:
62% believe that this should not be allowed in videogames rated 12 with 22%
thinking that it should not be available in those rated 16. Of the parents interviewed
the percentage contained within the overall figures above was higher for those with
children that do not play video games than for those that do.
Characters dressing in a sexual or provocative way:
69% of respondents felt that this should not be allowed in videogames rated 12 with
17% believing it should not be allowed in those rated 18.
Characters behaving in a sexual or flirtatious way:
68% of respondents thought this should be not be allowed in videogames rated 12.
Analysis:
The responses to all of these three questions show broadly similar percentages. All
of them are covered to a certain extent by the PEGI criteria which restricts any
language or depictions that amount to sexual innuendo to the 12 age category.
Depiction of younger characters behaving in an adult way:
58% of respondents believe that this content should not be allowed in videogames
rated 16 with the figure rising to 64% amongst female respondents.
Analysis:
This is a topic not specifically covered by the PEGI criteria although the behaviour
itself could trigger an age rating.
Of all of the questions dealing with sexualisation in any form the last question was
the only one to refer to younger characters carrying out the activity where responses
showed that 44% would not allow it for videogames rated 18. Although the term
‘adult way’ was not defined the results would tend to support the belief that feelings
amongst the UK population are against any form of sexualisation of children.
Depictions that might cause offence in terms of.. (Race, gender, religion, sexual
orientation or disability)
Although the question was asked separately for each of the categories the results
were broadly similar across them all.
Over 50% of respondents (with the exception of ‘gender’ where it was 47%) in each
case stated that the material should not be allowed in videogames rated 16 years
and in excess of 40% (with the exception of ‘gender’ where it was 36%) believing it
should not be allowed in videogames rated 18.
Analysis :
This type of content is different from that covered by the 18 rating which deals with
encouraging discrimination. This content deals with the lower category of causing
offence by means of discrimination. Currently PEGI treats it as offensive language
and rates it at 12.
23
The results show quite clearly that there is a strong belief that when the ‘offence
caused’ is in connection with any form of discrimination the rating should be higher
than that given for merely causing offence.
In the next part of the survey, the respondents were given a list of the broad topics
covered by the PEGI criteria and asked to state which of them was most important
overall and should be controlled by PEGI. The results showed the top four
categories to be violence, drugs, discrimination and sex.
Analysis:
This question was introduced with a view to identifying important areas that could
form the basis of future research. Violence is clearly a priority with the other three
categories prompting a similar response to each other.
Recommendations
Although a majority of parents with children who play videos games thought the
ratings were ‘about right’ there can be no sense of complacency and the findings will
be used as part of the ongoing process of considering further changes and
refinements to the PEGI criteria. Efforts must also continue to raise public awareness
of the PEGI system.
Violence is clearly an issue but the research was not able to be more granular as it
was text based and therefore not so capable of dealing with specific types of
violence. Violence should be made a specific topic in future research and should
deal in more detail with the various levels of violence contained in video games, if
possible using pictorial methods in the questioning.
The encouragement of gambling also raises issues and should be examined in more
detail in future research. This also would benefit from visual depictions of what the
typical game contains rather than a textual version merely stating that a game
encourages gambling.
The PEGI experts group, consisting of psychologists and industry members have
been tasked with examining three areas:
i. Should offensive language and/or depictions that are based upon
discrimination be placed into a specific category and rated at a higher
level than generic offensive language?
ii. Should any form of sexualisation of children be dealt with as a specific
PEGI category and which age rating would be most appropriate?
iii. Should the rating for depictions likely to be scary to young children be
raised to age 12? Alternatively, should the question be posed again but
include depictions instead of only text in the question.
The VSC is also a member of the experts group and will take part in the creation of
any new rating criteria considered necessary.
24
THE INTERNATIONAL AGE RATING COALITION
Over the past few years the VSC on behalf of PEGI, has been heavily involved in
the development of a global rating system for apps in collaboration with the other
major rating authorities around the globe, together forming The International Age
Rating Coalition (IARC).
The system assigns age ratings, content descriptors and interactive elements for
digitally-delivered games and apps. The fundamental goal is to enable digital
consumers, especially parents, to have broad access to established, credible and
locally-relevant ratings for interactive entertainment products, regardless of the
device on which they consume them.
In April 2015 the IARC system was implemented on the Google Play Store, the
primary source of Android based apps. This means that all apps and games on this
storefront now display PEGI ratings for users in the UK and across Europe. This
was a major step forward for the IARC system which beforehand was limited to the
Firefox marketplace. In addition to this towards the end of the year Microsoft signed
up to the system, implementing IARC on their PC and mobile storefronts.
Benefits of IARC
Storefronts and platforms are able to forego administering their own rating systems
in favour of using established standards while complying with the content
classification requirements that are legally mandated in certain countries.
Developers are relieved of having to go through multiple processes for obtaining
ratings for the different territories and storefronts in which they wish to make their
games available. And consumers are presented with a consistently applied set of
familiar and trusted ratings that reflect their local, distinct sensibilities about content
and age appropriateness.
25
VSC BOARD, PANELS & SENIOR EXECUTIVES
VSC BOARD
Tony Lake OBE QPM (Chair)
Former Chief Constable of Lincolnshire Police.
Iain Muspratt (Vice-Chair)
Chartered Accountant. Past Chairman of the British Video Association and member
of the British Screen Advisory Council.
Kim Bayley (Entertainment Retailers Association)
ERA is the trade association representing retailers of music, video, DVDs and video
games.
Liz Bales (British Video Association)
The BVA is the trade body representing the interests of publishers and rights owners
of video entertainment.
Dr Jo Twist (Association for UK Interactive Entertainment)
UKIE is the trade association representing the video games and interactive
entertainment industries.
Mary MacLeod OBE
Independent family policy adviser and a leading voice on children and family welfare.
A Trustee of the Internet Watch Foundation.
Chris Atkinson
Child protection background and has worked in the children’s charity sector for most
of her career including 16 years at the NSPCC.
Harry Marsh MBE
Freelance consultant in the UK voluntary sector; advising a wide range of charities
and charitable trusts on governance, strategy, project management, diversity and
fund raising.
Paul Bennun
Senior communications strategist. A wide-ranging history of successfully
implementing communications and marketing strategies, with substantial retail and
video gaming experience.
Charles Webster
Over 40 years’ experience in marketing and product development in the home
entertainment industry.
APPEALS PANEL
Baroness Kennedy of the Shaws QC (Chair)
Leading barrister and expert in human rights law, civil liberties and constitutional
issues.
26
Prof. Barry Everitt
Provost of the Gates Cambridge Trust and Director of Research, University of
Cambridge. Professor of Behavioural Neuroscience and a former Master of
Downing College.
Anthony Lilley OBE
Member of the Content Board of Ofcom. Award winning media producer with
experience in the commercial and public sectors.
Judge Kyrie James
Chair, Member of the International Association of Women Judges; Associate Rapporteur for the UK Rapporteur’s Working Party on Vulnerable Persons of the
International Association of Refugee Law Judges; legal chair to Mayor's Office for
Policing and Crime.
John Grieve CBE QPM
Former New Scotland Yard detective. He teaches at Portsmouth and London
Metropolitan universities.
EXPERT ADVISORY PANEL
Geoffrey Robertson QC
Leading media lawyer and ‘distinguished jurist’ member of the United Nations Justice
Council.
Prof. Tanya Byron
Consultant clinical psychologist specialising in child and adolescent mental health.
Dr. Guy Cumberbatch
Chartered psychologist and Director of The Communications Research Group in
Birmingham.
SENIOR EXECUTIVES
Peter Darby (Director General)
Former senior police officer having served 34 years with the Metropolitan Police
Service. Joined the VSC in 2003.
Laurie Hall (Director of Business Affairs)
Qualified solicitor with many years’ experience in the music, video and video games
industries.
Full profiles for all of the above are available on the VSC website.
27
STATISTICS
UK ONLY
UK certificates issued by the VSC (for 12, 16 and 18 classifications) and total
video games (unique titles) rated for the UK under PEGI for the year to 31 st
December 2015
Age classification
UK certificates
12
239
16
145
18
173
TOTAL
557
Note:
For a video game supplied in the UK for a number of different games consoles (e.g.
Xbox, PlayStation, and Wii) a separate UK certificate is issued for each version of
the game.
ALL PEGI TERRITORIES
Overall PEGI ratings by age for the calendar year 2015
These figures include online ratings
Age classifications
Percentage
3
428
23%
7
486
26%
12
503
27%
16
241
13%
18
208
11%
TOTAL
1866
Complaints and enquiries made to PEGI public website for 2015
71
8
539
27
145
159
92
192
1233
Complaints related to rating delivered
Complaints concerning advertising
Requests for information on PEGI
Comments on PEGI System
Questions and comments on ratings
Complaints via pegionline.eu
Other
Technical difficulties
Total
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APPENDIX
Company Registration No: 02402805 (England & Wales)
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMITED BY GUARANTEE)
DIRECTORS' REPORT & FINANCIAL STATEMENTS
YEAR ENDED 31ST DECEMBER, 2015
29
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMITED BY GUARANTEE)
REPORT OF THE DIRECTORS
The directors present their annual report together with the audited financial
statements of the company for the year ended 31st December, 2015.
PRINCIPAL ACTIVITY
The principal activity of the company during the year was the administering of the
statutory rating system for video games within the United Kingdom and the voluntary
rating system for video games for the remainder of Europe.
DIRECTORS
The directors who have served during the year were: J.A. Lake (Chair)
I.D. Muspratt (Vice-Chair)
C. Webster
The UK Interactive Entertainment Association
Entertainment Retailers Association
British Video Association
C.M. Atkinson
M. Macleod
H. Marsh
P. Bennun
Auditors
A resolution in accordance with Section 385, Companies Act 1985, for the reappointment of Newton & Garner Ltd., as auditors of the company is to be proposed at
the forthcoming Annual General Meeting.
30
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMITED BY GUARANTEE)
REPORT OF THE DIRECTORS
STATEMENT OF DIRECTORS’ RESPONSIBILITY
The directors are responsible for preparing the Directors’ Report and the
financial statements in accordance with applicable law and regulations.
Company law requires the directors to prepare financial statements for each
financial year. Under that law the directors have elected to prepare the
financial statements in accordance with United Kingdom Generally Accepted
Accounting Practice (United Kingdom Accounting Standards and applicable law).
Under company law the directors must not approve the financial statements unless
they are satisfied that they give a true and fair view of the state of affairs
of the company and of the profit or loss of the company for that period.
In preparing these financial statements, the directors are required to:(i)
Select suitable accounting policies and apply them consistently.
(ii)
Make judgements and estimates that are reasonable and prudent.
(iii) Prepare the financial statements on the going concern basis unless it
is inappropriate to presume that the company will continue in business.
The directors are responsible for keeping adequate accounting records that are
sufficient to show and explain the company’s transactions and disclose with
reasonable accuracy at any time the financial position of the company and enable
them to ensure that the financial statements comply with the Companies Act 2006.
They are also responsible for safeguarding the assets of the company and hence
for taking reasonable steps for the prevention and detection of fraud and other
irregularities.
STATEMENT OF DISCLOSURE TO AUDITORS
So far as the directors are aware, there is no relevant audit information of which
the company’s auditors are unaware.
Additionally, the directors have taken all the necessary steps that they ought to
have taken as directors in order to make themselves aware of all relevant audit
information and to establish that the company’s auditors are aware of that
information.
This report has been prepared in accordance with the special provisions
relating to small companies within Part 15 of the Companies Act 2006.
Approved by the Board on 13th April 2016 and signed on its behalf
L.J. Hall
- SECRETARY
31
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMITED BY GUARANTEE)
YEAR ENDED 31ST DECEMBER, 2015
INDEPENDENT AUDITORS’ REPORT TO THE MEMBERS OF THE VIDEO STANDARDS COUNCIL
We have audited the financial statements of The Video Standards Council for the
year ended 31st December 2015, set out on pages 4 to 9. The financial reporting
framework that has been applied in their preparation is applicable law, and the
Financial Reporting Standard for Smaller Entities (effective January 2015)(United
Kingdom Generally Accepted Accounting Practice applicable to Smaller Entities).
This report is made solely to the company’s members, as a body, in accordance with
Chapter 3 of Part 16 of the Companies Act 2006. Our audit work has been undertaken
so that we might state to the company’s members those matters we are required to
state to them in an auditors’ report and for no other purpose. To the fullest
extent permitted by law, we do not accept or assume responsibility to anyone other
than the company and the company’s members as a body, for our audit work, for this
report, or for the opinions we have formed.
Respective responsibilities of directors and auditors
As explained more fully in the Directors’ Responsibilities Statement set out on
page 2, the directors are responsible for the preparation of the financial
statements and for being satisfied that they give a true and fair view. Our
responsibility is to audit and express an opinion on the financial statements in
accordance with applicable law and International Standards on Auditing (UK and
Ireland). Those standards require us to comply with the Auditing Practices
Board’s Ethical Standards for Auditors.
Scope of the audit of the financial statements
An audit involves obtaining evidence about the amounts and disclosures in the
financial statements sufficient to give reasonable assurance that the financial
statements are free from material misstatement, whether caused by fraud or error.
This includes an assessment of: whether the accounting policies are appropriate to
the company’s circumstances and have been consistently applied and adequately
disclosed; the reasonableness of significant accounting estimates made by the
directors; and the overall presentation of the financial statements. In addition,
we read all the financial and non-financial information in the Annual Report to
identify material inconsistencies with, the audited financial statements and to
identify any information that is apparently materially incorrect based on, or
materially inconsistent with the knowledge acquired by us in the course of
performing the audit. If we become aware of any apparent material misstatements or
inconsistencies, we consider the implications for our report.
Opinion on financial statements
In our opinion the financial statements:

give a true and fair view of the state of the company’s affairs as at
31st December, 2015 and of its surplus for the year then ended;

have been properly prepared in accordance with United Kingdom Generally
Accepted Accounting Practice applicable to Smaller Entities; and

have been prepared in accordance with the requirements of the Companies Act
2006.
32
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMTED BY GUARANTEE)
YEAR ENDED 31ST DECEMBER, 2015
INDEPENDENT AUDITORS’ REPORT TO THE MEMBERS OF THE VIDEO STANDARDS COUNCIL
Opinion on other matter prescribed by the Companies Act 2006
In our opinion the information given in the Directors’ Report for the financial
year for which the financial statements are prepared is consistent with the
financial statements.
Matters on which we are required to report by exception
We have nothing to report in respect of the following matters where the Companies
Act 2006 requires us to report to you if, in our opinion:

adequate accounting records have not been kept, or returns adequate for our
audit have not been received from branches not visited by us; or

the financial statements are not in agreement with the accounting records and
returns; or

certain disclosures of directors’ remuneration specified by law are not made;
or

we have not received all of the information and explanations we require for our
auditor; or

the directors were not entitled to prepare the financial statements in
accordance with the small companies regime and take advantage of the small
companies’ exemption in preparing the directors’ report and from preparing a
strategic report.
Robert Knight FCCA ATII
Senior Statutory Auditor
For and on behalf of Newton & Garner Ltd.
Chartered Accountants
Statutory Auditor
33
DATE: 25th April 2016
BUILDING 2,
30 FRIERN PARK,
NORTH FINCHLEY,
LONDON, N12 9DA
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMITED BY GUARANTEE)
INCOME AND EXPENDITURE ACCOUNT
YEAR ENDED 31ST DECEMBER, 2015
Notes
2015
2014
2
618,620
618,487
3
165
------618,785
148
------618,635
593,686
-------
537,297
-------
SUBSCRIPTIONS AND FEES
Fees receivable
INVESTMENT INCOME
Interest receivable
EXPENDITURE
Administrative expenditure
SURPLUS FOR THE YEAR
BEFORE TAXATION
4
25,098
Tax on surplus
5
5,837
-------
16,396
------
10
£19,261
======
£64,942
======
SURPLUS FOR THE YEAR
AFTER TAXATION
34
81,338
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMITED BY GUARANTEE)
BALANCE SHEET
AS AT 31ST DECEMBER, 2015
Notes
2015
2014
FIXED ASSETS
Tangible assets
6
-
-
CURRENT ASSETS
Debtors
Cash at bank and in hand
7
16,270
357,469
------373,739
20,649
337,109
------357,758
Amounts falling due within one year 8
34,801
-------
38,081
-------
CREDITORS
NET CURRENT ASSETS
TOTAL ASSETS LESS CURRENT LIABILITIES
338,938
------£338,938
=======
319,677
------£319,677
=======
£338,938
=======
£319,677
=======
RESERVES
Income & expenditure account
10
These financial statements have been prepared in accordance with the provisions
applicable to companies subject to the small companies regime and the
Financial Reporting Standard for Smaller Entities (effective January 2015).
Approved by the board on 13th April 2016 and signed on its behalf
J.A. Lake
- DIRECTOR
I.D. Muspratt
- DIRECTOR
Company Registration No. 02402805
35
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS
1. ACCOUNTING POLICIES
The following accounting policies have been applied consistently in dealing with
items which are considered to be material in relation to the company's accounts:Accounting convention
The accounts have been prepared under the historical cost convention and in
accordance with the Financial Reporting Standard for Smaller Entities
(effective January 2015).
Compliance with accounting standards
The financial statements are prepared in accordance with applicable United Kingdom
Accounting Standards (United Kingdom Generally Accepted Accounting Practice),
which have been applied consistently (except as otherwise stated).
Tangible fixed assets and depreciation
Tangible fixed assets are stated at cost less depreciation.
Depreciation is provided to write off the cost of office equipment in full, when
acquired.
Pensions
The company operates a defined contribution (salary sacrifice) scheme. The pension
charge represents the amounts payable by the company to the fund in respect of the
year.
2. VOLUNTARY INCOME
Fees receivable represents the invoiced amounts of services provided during the
year, excluding value added tax.
2015
2014
£165
===
£148
===
6,222
43,625
1,200
======
4,149
52,028
1,200
======
3. Investment income
Other interest
4. SURPLUS FOR THE YEAR BEFORE TAXATION
Surplus is stated after charging:Depreciation
Directors' remuneration
Auditors' remuneration
36
THE VIDEO STANDARDS COUNCIL
(A C0MPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS
2015
2014
5. TAXATION ON INCOME
U.K. Corporation tax at 20% (2014 – 20%)
£5,837
=====
£16,396
======
6. TANGIBLE FIXED ASSETS
COST
Office equipment
2014
£49,164
======
ACCUMULATED DEPRECIATION
Office equipment
2014
£49,164
======
NET BOOK VALUE
Office equipment
Additions
Disposals
£6,222
=====
===
Charge
for year
Disposals
£6,222
=====
===
2015
£55,386
======
2015
£55,386
======
2014
2015
===
===
2015
2014
8,978
7,292
-----£16,270
======
12,399
8,250
-----£20,649
======
17,337
14,964
2,500
-----£34,801
======
26,456
4,625
7,000
-----£38,081
======
7. DEBTORS
Prepayments
Other debtors
8. CREDITORS: AMOUNTS FALLING DUE WITHIN ONE YEAR
Taxation & social security
Fees received in advance
Accruals
37
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMITED BY GUARANTEE)
NOTES TO THE FINANCIAL STATEMENTS
9. PENSIONS
The company operates a defined contribution (salary sacrifice) scheme. Assets of
the scheme are held separately from those of the company in independently
administered funds.
Contributions payable by the company for the year
2015
2014
£31,223
======
£25,293
=======
319,677
19,261
------£338,938
=======
254,735
64,942
------£319,677
=======
10. RESERVES
Income & Expenditure account
Balance at 1st January, 2015
Surplus for the year
Balance at 31st December, 2015
11. Company limited by guarantee
The company is limited by guarantee of members and does not have a share capital.
12. Related party transactions
During the year the company paid £15,450 (2014 - £15,000) to IDM & CO, Chartered
Accountants (formerly Iain D. Muspratt Chartered Accountant) in respect of his
services provided by I D Muspratt as a director of the company.
13. Control
The company is under the control of its members.
38
THE VIDEO STANDARDS COUNCIL
(A COMPANY LIMITED BY GUARANTEE)
INCOME & EXPENDITURE ACCOUNT
YEAR ENDED 31ST DECEMBER, 2015
Fees receivable
Interest receivable
2015
2014
618,620
165
------618,785
618,487
148
------618,635
LESS EXPENSES INCURRED
Rent
Marketing & promotion
Consultancy fees
Directors' remuneration
Salaries, pension & national insurance
Insurance
Light and heat
Cleaning
Telephone
Postage & stationery
Travelling, entertaining & accommodation
Legal & professional fees
Audit & accountancy fees
Computer, repairs, maintenance & upgrades
Depreciation
Sundry expenses
38,706
28,647
20,000
43,625
401,124
5,747
616
900
8,745
2,677
13,505
2,666
10,000
6,790
6,222
3,716
-------
44,390
19,446
17,332
52,028
354,144
6,060
3,401
4,132
9,174
900
10,000
8,508
4,149
3,633
------593,686
------£25,099
=======
SURPLUS FOR THE YEAR BEFORE TAXATION
39
537,297
------£81,338
=======
The Video Standards Council
Suite 4a, Salar House
61 Campfield Road,
St Albans, Herts
AL1 5HT
02037 718543