There is none. You are obviously told a rumor.
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You can buy club penguin membership codes from the shop but unless you win one in a competition there is no such thing as a free club penguin membership code.
A membership that is unused
Club Penguin has membership and at least half are members.
no
A Club Penguin gift code is a code that grants you access to the Club Penguin website. The codes will establish a membership for Club Penguin activities.