1. INTRODUCTION
The purpose of this procedure is to outline the internal processes that CHRG follows to ensure best practice in the responsible conduct of gambling.
This Procedure is underpinned by CHRG’s Responsible Conduct of Gambling Policy and Responsible Gambling Management Manual.
2. RESTRICTED ACCESS TO GAMING AREAS
CHRG complies with section 52 of the Gaming Machines Act 2001 (NSW) which prohibits minors from being in a gaming area of a club.
CHRG displays the appropriate signage concerning persons under 18 outside of any gaming area.
If a person under 18 years of age is observed in a gaming area of CHRG staff are aware that the minor is to be removed immediately. If a person is suspected of being under 18 years of age, such person may be requested to produce documentary evidence of age.
CHRG will ensure that staff induction and training provide information about which areas of the club are age-restricted areas (including gaming areas) and the relevant procedure if a person suspected of being under 18 years of age is observed in these areas.
3. RESTRICTED ACCESS TO CASH
All Automatic Teller Machines (“ATMs”) are not visible whilst seated in the club’s gaming areas or are screened, where possible.
EFTPOS transactions can be conducted at Reception, and all Food and Beverage outlets.
Any cash dispensing facility installed in any part of the club is not capable of providing cash from a credit account.
No cash advances are provided to any patron.
All ATMs display the appropriate Liquor and Gaming NSW gambling notice which can be clearly seen while using the ATM.
4. PLAYER WELFARE
CHRG team members will perform a Player welfare check in the following circumstances:
- team members observe the Player is displaying strong indicators of problem gambling;
- a Family Member raises concerns about a Player’s gambling;
- a Player reaches any voluntary pre-commitment limit set.
- Staff observe a Player gambling for three (3) or more hours continuously.
The welfare check must include at least the following:
- Enquiring as to the Player’s welfare;
- In the event that the Player reports any level of distress or hardship:
a) offering the Player information about counselling and self-exclusion;
b) asking the Player to take a break from gambling for a period of not less than 24 hours (this break does not require the Player to cease using other Club facilities); and
c) making a record of the interaction in the Club’s Gambling Incident Register.
5. AML/CTF
CHRG must ban any persons suspected of money laundering and log a Suspicious Matter Report with Australian Transaction Reports & Analysis Centre (‘AUSTRAC’).
We have the following procedure in place when dealing with any persons suspected of money laundering:
- Members of the club suspected of money laundering:
remove the Player from the club;
take steps to ban the Player from the club for conduct unbecoming of a member; and
report the relevant details of that Player to AUSTRAC and NSW Police.
- Non-members of the club suspected of money laundering:
remove the Player from the club;
issue the Player a notice that they are no longer permitted to enter the club; and
report the relevant details of that Player to AUSTRAC and NSW Police.
For further information refer to the AML/CTF Policy, Program and Procedure
6. EXCLUSIONS
6.1.Self-Exclusion
A Patron may request to exclude themselves from a CHGR venue. Once excluded from one venue, they are excluded from all CHRG’s venues.
To facilitate this a Duty Manager will;
- Take the patron to the members rewards desk
- Utilise the MVSE system to register the patrons details
- Explain to the Patron the conditions of their exclusion
- Offer Counselling brochures and information
- Print off the MVSE deed and place in the gaming office file
The Member Co-ordinator will receive an email from MVSE and will;
- If member
Update membership record to “Self exclusion” type
Change tier to “No Tier”
Set to hold mail.
Update circle scan to flag as banned
- If not a member
Add patrons to membership as rate 65
Update circle scan to flag as banned
6.2.Partial Exclusion
As per Self exclusion process, except the patron is only excluded from gaming in all CHRG venues.
6.3.Family
Initiated Exclusion
CHRG offers family-initiated exclusions to allow a Family Member of a person to make an application to the Club’s gambling counselling service provider ClubSAFE to have that family member excluded from the gaming machine areas at all CHRG venues.
November2023
The application must provide to ClubSAFE: - provide the full name, address, date of birth and contact details of the Player to whom the application relates; - provide evidence that the family is being harmed by the Player’s gambling; - provide evidence that the Player has refused to undertake a self-exclusion; - be endorsed by a qualified gambling counsellor as being necessary to protect the family from experiencing serious gambling-related harm; and - seek an exclusion period of at least 12 months.
The ClubSAFE gambling counsellor will attempt to contact the Player to whom the application relates and provide them with an opportunity to provide a response to the application. 45
CHRG will respect the privacy of the Family Member making an exclusion application and will not disclose their identity to the Player to whom the application relates, without the Family Member’s consent.
A Player to whom a Family-Initiated Exclusion applies may appeal the decision to the Code Adjudication Panel at any time during the exclusion period.
CHRG will provide information about the Family-Initiated Exclusion Process to a Family Member that raises concerns about a Player’s gambling
6.4.Club Initiated Exclusion
CHRG may initiate a Multi-Venue Exclusion for a Player if it is of the opinion that it is necessary to prevent that Player from experiencing serious gambling-related harm.
CHRG will initiate a Multi-Venue Exclusion if a Player displays any of the following problem gambling behaviours:
- Seeking credit for gambling;
- Seeking to borrow money for gambling;
- Admitting to borrowing or stealing money to gamble;
- Leaving a minor unattended while playing gaming machines.
CHRG may change a gaming area only exclusion to an entire Club premises exclusion if a Player breaches or attempts to breach their exclusion on two or more occasions.
7. DOCUMENT HISTORY
Preparedby: Approvedby: Date: Version:Comments AndrewKelly Group Gaming, loyalty & Compliance Manager
Group CEO