ClubsACT Gambling Harm Prevention Strategy 2020-2023

ClubsACT

GAMBLING HARM

PREVENTION STRATEGY

2020 - 2023

ClubsACT • CLUBSACT.COM.AU • (02) 6273 4694 • INFO@CLUBSACT.COM.AU

ClubsACT

CONTENTS

ClubsACT GAMBLING HARM PREVENTION STRATEGY

FORWARD FROM CLUBSACT PRESIDENT

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RESPONSIBLE GAMBLING BEHAVIOURS

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ABOUT GAMBLING HARM PREVENTION

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WHAT WE DO EVERYDAY

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POLICIES AND PROCEDURES

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EDUCATION

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COMMUNITY AWARENESS

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INFORMED CHOICE

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EFFECTIVE IN VENUE STRATEGIES

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Transparency of Information

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Availability of Information

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Prohibition on Gambling by Minors/ Persons Under 18 Years 6 ENGAGEMENT

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RESPONSIBLE ADVERTISING AND COMMUNICATION

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Responsible Gambling Information Online 7 RESPONSIBLE GAMING PROMOTIONS

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KEEPING RELEVANT

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SUPPORT

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OUR STAFF

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CLUBS GAMBLING CONTACT OFFICERS (GCOS)

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SELF-EXCLUSION PROGRAMS

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RECORDING GAMBLING HARM

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EFFECTIVE ENVIRONMENTS

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Staff Support

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Counselling Services

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Gambling Counselling

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Financial Counselling

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Current Relationship Counselling 11 COMPLIANCE

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REPORTING 12 STRATEGIES FOR 2020-2023

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ClubsACT and ACT Gambling Counselling Support Service

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Gambling Intervention Officer

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Gambling Contact Officer Training

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Pastoral Care

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Venue-based voluntary pre-commitment to the Clubs industry

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Gambling Area Exclusion

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Early Intervention Education

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Enhance Responsible Gambling Tools

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Research and Education 16 What we have achieved

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What we will do

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ClubsACT GAMBLING HARM PREVENTION STRATEGY

The clubs of the ACT are community based organisations established by local Canberrans who banded together by a common purpose – to serve the communities in which they operate.

In 1973 the ACT Government gave the privilege of operating poker machines to our community clubs and nearly five decades later poker machine revenue accounts for 60 per cent of total club revenue, underpins over 1700 jobs, enables the payment of $73 million in taxes to Governments, and an annual social contribution of $37 million into our community.

Gambling provides recreational, social and economic benefits to individuals and the communityi.

ClubsACT recognise that despite most people using poker machines as a source of fun and entertainment, there remains a small number of people who, through their gambling behaviour, can cause significant harm to themselves, their families and friends.

It is the responsibility of the ACT government, the club industry and individuals to minimise the harm from gambling.

ClubsACT takes that responsibility seriously and I am pleased to present the ClubsACT Gambling Harm Prevention Strategy 2020-2023. This strategy outlines our member club’s commitments to creating a safer and more responsible club gambling environment.

Kim Marshall President- ClubsACT OCTOBER 2020

i

Australasian Gaming Council,

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RESPONSIBLE GAMBLING BEHAVIOURS

SETTING AFFORDABLE LIMITS

BALANCING GAMBLING WITH OTHER ACTIVITIES

USING HELP AND SUPPORT IF NEEDED

RESPONSIBLE GAMBLING BEHAVIOURS

GAMBLING FOR ENTERTAINMENT

UNDERSTANDING HOW GAMBLING WORKS

SETTING AFFORDABLE LIMITS Source: Hing, N, Russell, A & Hronis, A 2016, Behavioural Indicators of Responsible Gambling Consumption, Victorian Responsible Gambling Foundation, Melbourne.

ClubsACT

ClubsACT GAMBLING HARM PREVENTION STRATEGY

CLUBSACT GAMBLING HARM PREVENTION STRATEGY Harm prevention aims to address gambling harm issues through the implementation of numerous strategies and procedures. The aim of gambling harm prevention strategies is to prevent and reduce gambling harm in our community.

ClubsACT Harm Prevention Strategy sets out the policies describing the current initiatives and support services and our future strategies that will continue to prevent and reduce gambling harm in our community.

ABOUT GAMBLING HARM PREVENTION Gambling is a recreational pursuit enjoyed by millions of Australians. For the overwhelming majority, gambling is a source of entertainment and enjoyment. The club industry is aware that excessive gambling can cause significant harm for some individuals and society more broadly.

The ACT Government has adopted a comprehensive regulatory regime for gambling harm prevention, and as a result, the rate of gambling harm in the ACT is amongst the lowest in Australia.

ClubsACT’s approach to preventing harm is to provide responsible gambling services; create safe environments where people can make informed choices about their gambling; and be supportive in their decisions not to gamble.

WHAT WE DO EVERYDAY ClubsACT member club’s commitment to gambling harm prevention can be summarised as:

• Policies and Procedures that promote responsible gambling best practices; • Informed Choices that will facilitate informed decision-making about gambling;

• Proactively engage with members and their guests to identify problems; • Support within a public health approach, such as counselling and pastoral care services;

• Compliance with legislation and best practice guidelines.

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POLICIES AND PROCEDURES Responsible gambling is the provision and use of gambling products in a manner that is safe and enjoyable, while also preventing gambling harm.

ClubsACT will continue to issue clear guidance on responsible gambling best practices.

ClubsACT best practice policies and guidelines encompass the following:

• • • • • •

Self-Exclusion; Third-Party Exclusion Policy - Family Member Intervention; Partial Self- Exclusion; Staff Gambling Policy; Guidelines for Member Clubs on the appropriate use of EFTPOS facilities in venues; Guidelines for Member Clubs on establishing a re-admittance plan for patrons who have previously identified, or been identified, as excluded members.

ClubsACT have established a Gambling Harm Prevention Advisory Group modelled on NSW Liquor Accords, to develop, implement and oversee gambling harm prevention strategies across Clubs in the ACT. Examples of strategies are:

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Undertaking a comprehensive review of Responsible Service of Gaming and Gambling

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Improving the early identification of “at risk” members. For example, clubs consider

•

Strengthening the exclusion process.

Contact Officer (GCO) training; introducing a gambling related question on membership forms;

ClubsACT will continue to work collaboratively with the ACT Gambling and Racing Commission’s (The Commission) to implement of their Strategy for gambling harm prevention in the ACT. GARC ACT Gambling and Racing Commission gamblingandracing.act.gov.au

EDUCATION ClubsACT commits to making available to all its associated member club Directors, senior managers and staff:

• • • •

Opportunities to improve knowledge and professional development; A relevant and easily accessible Resource Library; Information on the National Association of Gambling Studies annual conference; Information from the 2019 ACT Gambling Survey.

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COMMUNITY AWARENESS Gambling Harm Awareness Week (the Week) is a national initiative that involves a unique partnership between local governments, the gaming industry and community groups. The Week recognises that those who provide gambling products, consumers, and the broader community all share responsibility for promoting and encouraging gambling harm prevention.

We will support the Commission through engaging with our local communities and promoting gambling harm prevention messaging. During the Week, clubs will actively participate in the Gambling Harm Awareness Conference and promote awareness through use of preventing gambling harm collateral such as “Gambling Harm we don’t play it down” messaging.

INFORMED CHOICE ClubsACT supports improvement to the information available to consumers to facilitate more informed decision-making regarding gambling purchases.

ClubsACT will provide improved access to information about Electronic Gaming Machines (EGM’s) and the risk of gambling, through digital technologies and social media. The aim is to increase accessibility to consumer information, which has typically been confined to physical brochures located in venues. ClubsACT is working with other jurisdictions, researchers and suppliers to develop relevant digital content and will encourage clubs to utilise their digital distribution channels to inform members.

EFFECTIVE IN VENUE STRATEGIES TRANSPARENCY OF INFORMATION The rules of all EGM’s are available at all venues upon request. Player Information Displays on EGM’s provide further information including the odds of winning.

AVAILABILITY OF INFORMATION All clubs make available a comprehensive range of gaming harm prevention information to members and extensively advertise services and information availability, such as the Vikings Group best practice gaming harm prevention program “Play Within Your Limits”.

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Lifeline information, counselling services detail and support contact numbers are displayed throughout venues and in places such as:

• • • • • • • •

On gaming machines; At ATMs; On relevant advertising material; Internal advertising televisions; In customer bathrooms; In Club News Magazines; At cashier desks; At gaming floor entrances.

PROHIBITION ON GAMBLING BY MINORS/PERSONS UNDER 18 YEARS

Venues advertise on all gaming floor entry points the following detailed warning message:

“WARNING – GAMING AREA. PERSONS UNDER THE AGE OF 18 YEARS ARE NOT PERMITTED IN THE GAMING AREA. IF YOU HAVE A GAMBLING PROBLEM – CONTACT THIS VENUE ABOUT AVAILABLE HELP.”

Clubs staff heavily monitor to ensure that no person under the age of 18 is permitted to enter the gaming floor. If any doubt exists, appropriate identification is requested. If appropriate identification cannot be provided, the member is refused entry into the area.

Any parent or guardian bringing a child to a venue is made aware by signage and staff that children are not permitted on the gaming floor. Members are reminded that children are never to be left unattended. In the venue, if a child is unattended, the parent or guardian may be asked to leave the venue.

ENGAGEMENT A key advantage of the club environment is the ability for staff to oversee member behaviour and offer support to people showing signs of distress.

Research has found strong associations between gambling harm and other mental health issues, such as loneliness, grief, anxiety and depression. These comorbid mental health conditions are often the precursors to gambling harm.

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ClubsACT GAMBLING HARM PREVENTION STRATEGY

Preventative measures undertaken include:

• • •

Welfare Checking; Providing and using Customer Complaints; Role of GCO’s.

RESPONSIBLE ADVERTISING AND COMMUNICATION All external marketing from ClubsACT member clubs seek to portray clubs as a social outlet that offer many facilities and activities, including gaming as a member entertainment option.

Promotional material whether gaming related or not, is never sent to a member who is listed on our exclusion register as either Self-Excluded and Venue Excluded Members.

Gambling advertising and promotions are delivered to members, other than excluded members, in a responsible manner and on balance, encourage responsible gambling. When assessing gambling advertising and promotions, consideration is always given to the content and the potential impact the content may have on people experiencing gambling harm.

Factors such as the target audience selection, themes, imagery and the message is always considered for potential harm. Clubs do not publish any form of advertising that:

• • • •

Encourages anyone to contravene a gaming law;

• • •

Suggests that gambling is a form of financial investment;

Shows people under 25 years old gambling; Encourages people under 18 years old to gamble, or targets them; Expresses false or misleading information, particularly about the chances of winning or the expected return to a gambler;

Suggests that skill can influence games that are games of chance; Shows or promotes the consumption of alcohol while gambling.

RESPONSIBLE GAMBLING INFORMATION ONLINE Member clubs utilise online communications to deliver responsible gambling information via websites including referral details for gambling harm services. This information is intended to ensure that members who wish to assess information at home are easily able to do so and ensures members are directed to support services.

Online newsletters are optional to all members. Email marketing is not automatic, with members having the option to choose to opt-in to receive email communication from their club. If a member does select to receive emails, they are also given the option to opt-out at any given time.

The opt-out option is clearly communicated in all emails and is an extremely simple process.

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RESPONSIBLE GAMING PROMOTIONS Member clubs do not conduct gaming promotions that requires or encourages:

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People to gamble at the venue for a minimum period of time to qualify for

• •

Conduct a promotion where entry is solely through gaming;

•

Conduct a promotion or offer an inducement that encourages people to

• •

Induce people to gamble by offering free or discounted alcohol;

rewards;

Conduct a promotion for or including gambling at the venue that includes an offer of free or discounted alcohol; increase their intensity of betting at the venue;

Induce people to gamble by offering cash or free discounted gambling credits.

KEEPING RELEVANT ClubsACT members use various tools and resources to engage with stakeholders in order to prevent, reduce and minimise gambling harm. This includes:

• Working with independent researchers into gambling harm prevention; • Using evidence to test and introduce new gambling harm prevention measures;

• Working with high risk gamblers to improve intervention and harm minimisation strategies; and

• Educating club directors and staff on the benefits of gambling harm prevention approaches.

SUPPORT ClubsACT members encourage people to seek support while continuing to foster greater collaboration between clubs and counselling services, acknowledging that face-to-face counselling is highly effective in treating gambling harms.

OUR STAFF Clubs have dedicated gaming personnel including Customer Service Attendees, Supervisors and Duty Managers, who are assigned to all venue gaming floors. These staff members are quickly identifiable to our members and develop consistent relationships with regular visitors. This assists them in the provision of a responsible environment as they can quickly identify instances of out of character behaviour and address matters without confrontation.

ClubsACT

ClubsACT GAMBLING HARM PREVENTION STRATEGY

Venue Managers in conjunction with their Executive Managers, monitor gambling incidents to identify trends that may lead to gambling harm are not occurring.

CLUBS GAMBLING CONTACT OFFICERS (GCOS) Across all ClubsACT members, there are trained GCO’s operating within venues. The GCO’s act as the main point of contact for members concerning gambling issues.

SELF-EXCLUSION PROGRAMS The self-exclusion program enables members to exclude themselves from venues. Self-exclusion is a concrete tool for members that feel their gambling is becoming a problem. A self-exclusion from gambling is an agreement between the member and the Clubs to prevent the member from gambling at venues. Members are always guided through the process of signing a deed of selfexclusion, nominating the venue/s they will be excluded from and agreeing that they will not enter the venue. The self-exclusion catalogue is available to all staff. Member details are always treated with strict adherence to privacy guidelines.

RECORDING GAMBLING HARM A record of gambling harm incidents is kept at all venues and lists anyone who shows signs of having a gambling issue. The record includes the date and nature of the gambling incident, the name and address of the member (if known), or a description of the person involved.

All licenced Clubs in the ACT participate in the Australian Capital Territory Gambling Exclusion Database. This facility allows for members who self-exclude from venues to have their details made available to any or all ACT gaming venues at the time of completing their documentation.

This information is uploaded to the Commission hosted secure website, where their details remain safe yet their wishes are communicated to all licensed operators quickly. The record also includes details of any action taken by the Club in relation to the member.

EFFECTIVE ENVIRONMENTS Several features exist within Club gaming areas which are aimed to encourage responsible gambling. These include (but are not limited to):

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Clocks are displayed on individual EGMs so that customers can be aware of the passage of time. Staff will mention the time when making announcements about entertainment activities occurring in the venue;

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Adequate lighting is provided in all gaming areas;

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All Clubs are committed to the responsible service of alcohol and will not knowingly allow

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ATM withdrawal restrictions in accordance with relevant legislation. $250 daily ATM

a person, who is in a state of intoxication, to gamble; withdrawal limits, per card for a rolling 24 hour period. ATM and EFTPOS facilities are located outside the gaming areas;

• •

Only one EFTPOS facility in a venue allows cash out;

•

Members are encouraged to take regular breaks from gambling. This encouragement

A staff member trained in the responsible provision of gambling services is involved in all stages of the cash withdrawal transaction; may take various forms including:

> announcing a draw, including those relating to a trade promotion; > announcement of any entertainment occurring; > verbal encouragement by staff for customers to take refreshment breaks; > lounge facilities, available throughout the Venues; •

Several restrictions apply to financial transactions. These restrictions include matters

•

Member winnings from a gaming machine can be paid by cheque or EFT if the winnings

such as cheque cashing, payment of winnings and identification requirements; are more than $300 and the patron has requested the winnings be paid by cheque or electronic funds transfer;

•

EFTPOS is only to be used to access cash from savings or cheque (not credit) accounts

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Operators do not allow members to cash a cheque within a gaming area or allow

and is limited to cash withdrawals of $200 per transaction; members to buy back or redeem a previously cashed personal cheque. Cashing personal cheques is limited to 1 cheque to the value of $100 unless the patron has made previous arrangements;

•

Relevant staff will be instructed to offer members, who have received large payouts, the

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Operators comply with the Gambling and Racing Control - Code of Practice to not

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Service of alcohol is restricted within the gaming area. Venue staff do not serve alcohol

opportunity to ‘cool-off’ by taking payment in part or full by cheque; encourage a person to gamble beyond their means; to a member when they are playing a gaming machine or sitting/standing by a gaming machine;

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All gaming machines at venues are non-operational between 4am – 9am.

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ClubsACT GAMBLING HARM PREVENTION STRATEGY

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STAFF SUPPORT Promoting gambling harm prevention awareness and setting the right behaviours among employees is an important component of ClubsACT’s Gambling Harm Prevention Program.

Staff are not excluded from gambling issues and therefore our members ensure employees and their families have access to programs such as Employee Assistance Programs to discuss any actual or potential issues they may be experiencing.

Preventing gambling harm is also a paramount undertaking for our employees as they build relationships with members. In addition to providing practical support, the culture of our organisations is one of nurture where all staff are comfortable in seeking advice or support both internally or externally.

COUNSELLING SERVICES ACT GAMBLING AND RACING COMMISSION PUBLISH UP TO DATE INFORMATION ON ALL GAMBLING AND FINANCIAL COUNSELLING AND SELF-EXCLUSION SUPPORT SERVICES: www.gamblingandracing.act.gov.au

CURRENT RELATIONSHIP COUNSELLING Relationships Australia has dedicated resources specialising in this area that are promoted in venues.

Information about these resources are available to all members, with contact directly through www. relationships.org.au The resources provide:

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Face-to-face counselling services for people with a gambling problem and/or partners and

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Assistance in overcoming a gambling problem, like exploring the extent and nature of the

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Controlling gambling behaviour through strategies that minimise the harm resulting from

relatives impacted by problem gambling behaviour; gambling behaviour and the factors which trigger the behaviour or encourage its continuation; gambling and strategies to avoid relapse into uncontrolled gambling behaviour;

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Financial counselling, to address debts, cope with creditors, and reorganise financial

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Counselling to address the underlying issues linked to gambling and the impact of

affairs generally; gambling on relationships and family life and steps to relieve that impact.

COMPLIANCE Compliance is a cornerstone of any successful gambling harm minimisation program. ClubsACT currently provide a key service with training on important compliance obligations such as antimoney laundering and counter-terrorism financing (AML/CTF) in conjunction with AUSTRAC and ACT Policing.

REPORTING ClubsACT members will ensure adherence to the Online Exclusion Database, Gambling Incident Register and following legislation:

• • •

Gaming Machine Act 2004; Gaming Machine Regulation 2004; Gambling and Racing Control (Code of Practice) Regulation 2002.

IMPROVED BOARD GOVERNANCE ClubsACT acknowledges there is a need for a more consistent level of understanding of nonexecutive responsibilities and obligations for clubs in the ACT. To address this ClubsACT will facilitate a training program for club directors and senior management that will cover key elements such as understanding the ACT legislative framework specifically gaming machine regulations and harm prevention measures; what is good corporate governance; financial, risk and audit management.

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ClubsACT GAMBLING HARM PREVENTION STRATEGY

STRATEGIES FOR 2020-2023 In continuing its commitment to reducing gambling harm, ClubsACT will undertake the following initiatives.

CLUBSACT AND ACT GAMBLING COUNSELLING AND SUPPORT SERVICE Re-establish direct engagement with ACT Gambling Counselling Support Service, the Commission’s service provider of professional gambling counselling and support services for people experiencing problems with gambling, which is funded through the Gambling Harm Prevention and Mitigation Fund. The initiatives will include:

• •

Standardised Club Induction Program; GCO Communication Network- establish an on line communication tool for Gambling Contact Officers across the ACT. The network will be established through Facebook and will be closed to GCO’s or Club staff only.

ACT GAMBLING INTERVENTION OFFICER PROGRAM ClubsACT will continue its discussion with government on the development and implementation of a Gambling Intervention Officer Program (GIOP). This program would include a government appointed ‘independent role’ tasked with the responsibility for providing advice to ClubsACT on its harm prevention strategies, including reviewing the exclusion process for all forms of gambling across the ACT.

ADVANCED GAMBLING CONTACT OFFICER TRAINING ClubsACT will initiate a program of advanced Gambling Contact Officer (GCO) training (available every six months) as a member service.

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PASTORAL CARE The ClubsACT Pastoral Care program will be a preventative initiative of ClubsACT and the identified best in field provider who will provide pastoral care and support to club members supporting their overall mental health and wellbeing, in conjunction with the University of Sydney Gambling Research and Treatment Clinic’s Advanced Responsible Conduct of Gambling staff training programs. This will be done by:

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Working with the Commission on the design and implementation of a legislated family

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With the Pastoral Care provider, conduct Mental Health and Wellbeing training sessions

intervention scheme; for staff, consisting of numerous modules which cover harm minimisation measures and tactics;

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In conjunction with the Pastoral Care provider, host a Mental Health and Wellbeing public

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Work with the Pastoral Care provider to distribute National Toolkits containing

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Develop and work within a 360-degree framework to provide ClubsACT member

event, annually during the Gambling Harm Awareness Week; information on issues including gambling, substance addiction, anxiety and depression; Executives with advice and recommendations regarding harm minimisation and mental health and wellbeing.

VENUE-BASED VOLUNTARY PRE-COMMITMENT TO THE CLUBS INDUSTRY Currently, the University of Sydney Gambling Treatment and Research Clinic is developing and trialling a website enabling gamblers to self-exclude from “anywhere at any time”. This initiative builds on the ClubsNSW multi-venue self-exclusion program that enable gamblers to self-exclude online.

GAMBLING AREA EXCLUSION Using technology such as biometric facial recognition to enable members to self- exclude from club’s gaming areas and allow access to member entertainment areas of venues.

EARLY INTERVENTION EDUCATION Investigate working with suitably qualified individuals and organisations to facilitate appropriate outreach and gambling harm awareness sessions among groups that have been identified as highrisk for developing harm from gambling. These include local primary and high schools, prisons and indigenous communities. These sessions would be designed to raise awareness about the risks of gambling harm and support services that are available.

ClubsACT

ClubsACT GAMBLING HARM PREVENTION STRATEGY

ENHANCE RESPONSIBLE GAMBLING TOOLS The availability of responsible gambling tools has increased in recent times with the release of various gambling expenditure calculators and tracking tools. There is also ongoing research into incorporating responsible gambling tools into gaming machine designs.

Deakin University is developing two online courses providing digital education and research on responsible gambling and prevention of harm. University of Sydney Gambling Treatment and Research Clinic is conducting a trial comparing face to face with online gambling treatment.

ClubsACT supports increasing the availability of cost-effective responsible gambling tools. This includes tools that can assist club staff in performing responsible conduct of gambling duties.

ClubsACT is also committed to working with gaming machine suppliers and researchers to improve access to responsible gambling tools on gaming machines.

In addition, ClubsACT will continue to support the roll-out of venue-based voluntary precommitment.

Online self-help and brief intervention services typically have fewer barriers to access and can be provided at a relatively low-cost. Some of the potential tools include:

• • • • •

On-line screening and automated feedback; On-line gambling budgeting tools; Interactive self-directed CBT online programs; SMS motivational messages; Access to counsellors via email, or online chat (research evaluating the efficacy of these services is an emerging field, but early results show great promise).

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RESEARCH AND EDUCATION Improving gambling harm prevention knowledge base is critical to the development of cost-effective policy. ClubsACT continues to encourage and support high-quality independent research on gambling harm minimisation with a focus on research that can help improve industry practices. We will use evidence to test and introduce innovation in gambling harm prevention best practice for venues.

• • •

Research reports published with meaningful recommendations for the club industry; A more informed and evidence-based approach to gambling policy formulation; Initiate Gambling Harm Prevention educational events for club directors and staff.

ClubsACT is committed to providing club staff with new advanced training developed by the University of Sydney. The training will provide club staff with the skills and confidence to interact with patrons that are displaying signs indicative of gambling harm. Furthermore, ClubsACT will work with the Commission to further educate club directors and staff on the benefits of a public health approach by providing key learning opportunities.

ClubsACT will work to increase in the number of clubs that have a gambling harm prevention page on their website with direct links to Gambling Help Online.

ClubsACT

ClubsACT GAMBLING HARM PREVENTION STRATEGY

WHAT WE HAVE ACHIEVED: ✔

Strictly adheres to strong procedures and practises that promote responsible gambling

✔ ✔ ✔ ✔ ✔ ✔ ✔

Proactively engages with members and their guests to identify problems

best practices

Provides timely communication, education and training Provides self-exclusion options Actively supports the ACT Gambling and Racing Commission Provides support to our staff, members and guests Rigorously complies with legislation and best practice guidelines Meet all state and federal government regulatory reporting requirements

WHAT WE WILL DO: F Strengthen our partnership with ACT Gambling Counselling and Support Service F Implement the ACT Gambling Intervention Officer Program F Implement the Advanced Gambling Contact Officer Training Program F Implement Board Governance Training F Initiate the ClubsACT Pastoral Care Program F Implement the Gambling Area Exclusion Initiative F Implement Early Intervention Education and Outreach Program F Initiate Responsible Gaming Tools

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