Responsible GAMBLING – the government wants more…

The UK Government earlier in the year reduced the maximum bet on poker machines to address problem gambling. Culture Secretary Matt Hancock championed the change which limits bets to 2 pounds per spin, down from the previous limit of 100 pounds.

The Sydney Morning Herald recently reported – “Supermarket giant Woolworths' pokies business is facing heavy penalties or the cancellation of gaming licences after investigations uncovered evidence it has been providing patrons with free alcohol to keep them gambling longer.”  The headline for this article was - Woolworths branded nation's 'worst' pokies operator over free drink scandal.

There is no doubt the groundswell support for far more stringent responsible gambling practices is gaining momentum. Around the world we are starting to see a far more rigorous approach to responsible gambling, including the examples cited above in the UK plus changes in other jurisdictions such as Macau, British Columbia, Canada and New Zealand. In Japan, where the casino culture is relatively new, responsible gambling is being inbuilt into the system.

Queensland is not immune to this drive to improve the approach to responsible gaming. 

Current state of play

The Queensland responsible gambling Code of Practice provides a proactive whole-of-industry approach to the promotion of responsible gambling practices. It also encourages the continuation of best practice for gambling environments that minimise harm to individuals and to the broader community. 

The Code of Practice supports and progresses the State Government’s Queensland Responsible Gambling Strategy, which aims to balance the social and economic benefits and costs of gambling. The Code of Practice draws upon industry commitment to best practice in the provision of responsible gambling. 

What is responsible gambling? 

Responsible gambling is the provision of safe, socially responsible and supportive gambling environments where the potential for harm associated with gambling is minimised and people can make informed decisions about their participation in gambling. It occurs as a result of the collective actions and shared ownership of individuals, communities, the gambling industry and government. 

What is problem gambling? 

Problem gambling is characterised by difficulties in limiting money and/or time spent on gambling which leads to adverse consequences for the gambler, others, or for the community. 

Guiding principle - The Code of Practice is based on shared commitment by gambling industry providers to the guiding principle of ethical and responsible behaviour. This principle recognises the importance of customers’ wellbeing with a focus on minimising the potential harm of gambling. In addition, customers’ rights to privacy are respected. 

So, there’s the background and some context of industry’s role and the expectation of government. Sounds good doesn’t it? Easy? Fair? Pfft!

The reality of responsible gambling

Then of course there is the reality of implementing responsible gambling practice, which unfortunately sees operators tempted to stray from the recommended path and that is where the problems begin to fester.  Human nature – right? It takes just one operator to stray from their obligations, and before long all those around them in the local catchment are doing it as well.  The thinking by those that are followers is often stated as - “If I don’t do it, I can’t compete, and I’ll lose market share.”

The following was provided by a large Queensland club in recent correspondence to our Queensland the regulator, the Office of Liquor and Gaming Regulation (OLGR).  In my mind the management and board at this club are leaders, not followers, given they continue to challenge themselves, to ensure the social licence afforded them by way of being good custodians of gaming product is that the the provision of this gambling offer meets or exceeds public and government scrutiny!

“As we’ve mentioned recently our club has always been proud of its position towards harm minimisation and has equally always judged QLD as the leading state in regard to how the government manages poker machines. However, we’re all aware the community sentiment towards poker machine gambling has been on a downward slide for many years now.  This has been actively driven by an anti-gambling movement with their constant messaging starting to resonate with the general public.
Whilst this negative shift has been slow, we equally feel that our industry is slow at responding and more needs to be done by both industry and government to ensure our social licence can prosper into the future.

Our club became a member of NAGS three years ago and it’s been a very big eye opener.  It has exposed us to people and concepts that we would never meet in our normal Club circles.  Attending their conferences has shifted our view on harm minimisation, more so, it has shifted our ‘culture’ on harm minimisation.
We now know that more has to be done, with the first step being getting a greater understanding of the opportunity gap. We need to understand better ways to approach and deliver harm minimisation, and we need to reach out to the greater gambling community, so we can lift our benchmark and start actively rolling out programs so harms can be reduced to a target of zero.
Whilst practically, zero might not be achievable, for us it’s all about shifting the culture towards zero harms rather than thinking ‘some’ harms are acceptable.” 

Industry sustainability and responsible gambling practice

As many are aware, Clubs Queensland commissioned KPMG in late 2018 to conduct a broad analysis of the industry as a catalyst for change and more importantly sustainability. We recognized that it is time for our sector to be proactive and to collectively reset the path forward to secure the sector’s future, and the future of the communities we serve throughout Queensland.

The KPMG Report is therefore, in many ways an important tool for the government, the community club industry and our key stakeholders to focus on an appropriate and much needed ‘competitive’ (rules appropriate) course forward together.  

The report also conveys that industry sustainability requires “proactive implementation of initiatives and technology that minimises gambling related harm.”

Clubs Queensland is committed to exploring the practical and legislative basis for a better industry position on responsible gambling, recognising that there is an opportunity for community clubs to take a lead on this important issue.

International learnings and where Clubs Queensland is ‘at’ in terms of responsible gambling and industry leadership

Given the Queensland government and most governments for that matter, are intent on ensuring Responsible Gambling practices are appropriate and effective and the comments in the KPMG report, I recently attended (for the first time) on behalf of Clubs Queensland, the 17th International Conference on GAMBLING and RISK TAKING in Las Vegas.

This conference is held once every three years, and this year approx. 600 delegates from 34 countries attended.  The event organisers received in excess of 500 research/presentation papers with the TOP 150 submissions then invited to present over the three days of the conference.  

In addition to the conference, whilst there I met with: 
  • Shelly White, CEO Responsible Gambling Council – Toronto Canada
  • Janine Robinson, Director, Centre for the Advancement of Best Practices from Responsible Gambling Council –  Toronto Canada
The Responsible Gambling Council has been doing work in Australia for a number of years including more recently working with ClubsNSW (plus some larger NSW clubs), Clubs in SA, the Northern Territory and Tasmania.  They have also done a considerable amount of work with the ALH pub group.

From their website – “Amongst other things, this group offers an ‘independent’ RG Audit process” which was worthy of further discussion and investigation.  

The concept of accreditation is fairly simple: compare a particular reality to a general standard to see where it stacks up. If it meets an established threshold, then it’s accredited. This process is familiar to most of us, whether from swimming lessons, or learning to play piano.

The reality of accreditation, of course, is much more complicated. What is the standard? Who sets it and how is it validated? What are the criteria for comparison? How is the process implemented? Who makes the final decision to grant accreditation? Once accredited, how long does it last? How do we maintain the program’s independence?

What is the standard for RG Check?            

For RG Check, the standard is the RG Index - 8 standards that define the problem gambling safety net for gaming venues. These are the core areas of gaming venue operations in which responsible gambling practices are embedded:
  1. corporate policies
  2. self-exclusion
  3. advertising and promotion
  4. informed decision making
  5. assisting patrons who may have problems with gambling
  6. access to money
  7. venue and game features
  8. employee training                    
In addition, the scoring assesses 47 criteria and 230 metrics, with applicants needing to achieve a minimum of 70% overall to pass.

As a consequence of my Las Vegas meeting with Janine Robinson from Responsible Gambling Council, she recently visited us in Brisbane as our guest.  At Clubs Queensland offices, she presented to both OLGR and the Office of Regulatory Policy, and separately to a group of larger SE Qld clubs.  The presentation was relevant, refreshing and provocative.  You could say this was another step towards more knowledge for both the industry and regulator as we work together seeking continued improvement in Responsible and Problem Gambling space. 

“Apparently the SA regulator is finding the system of benefit, even in terms of just getting more staff out on the floor and interacting with patrons (as they have to respond to alerts).” 

As part of my recent investigations I was also directed to the ARMS system in South Australia.  it appears that the ARMS system in pubs and clubs is not like the Canadian Tracy Schrans type monitoring system that looks at patterns of play, but this technology alerts management on 2 parameters - sessions that are over 3 hours or so or where turnover is greater than $20K. Apparently the SA regulator is finding the system of benefit, even in terms of just getting more staff out on the floor and interacting with patrons (as they have to respond to alerts).

Maybe this is the key?  OLGR has regularly shared their concern that staff are not interacting with members and guests in the gambling space enough, and significant improvement is required in this area operationally.  This leads me to question - do you really need AI software or a monitoring system that triggers a ‘must respond’ message to staff and management?

Genuinely, would it not be better to be accessing harm via interacting a number of times with a member or guest who is gambling over the period of their visit, thus mitigating the need to have a ‘one off’ conversation (at a prescribed 3 hour mark) around wellbeing, that can be difficult for all involved? Perhaps an ongoing interaction/assessment regime almost on the hour is part of the answer. 

This kind of interaction is not only good customer service but appropriately, it also allows staff to monitor all your patrons, and importantly make it easier to spot an issue before it becomes a problem.  It is all about good communication, good service and good outcomes.  

Further, how do we champion responsible gambling practice from the boardroom? Here’s a few challenge questions for your boards to consider for your governance and board reviews: do your staff have KPI’s around gambling patron’s interaction, do your board minutes report on gambling staff KPI’s and gambling member/guests’ interactions, etc?

The landscape at government level 

The Queensland government made an election pledge to Queenslanders that in this term of government ‘responsible gambling’ was to be reviewed.  As the next state election is in Oct 2020, not that far away really, it is a sure bet given the government’s undertaking you can expect change in the rigor and responsibilities of gambling operators.  

Noting this, it is always better to be a part of change in preference to it being thrust upon you.  Therefore, Clubs Queensland’s role on behalf of the community club sector is to ensure that we proactively contribute to this government review thus ensuring a sustainable and vibrant community club gambling industry.

Industry sustainability requires “proactive implementation of initiatives and technology that minimises gambling related harm.” 

Respectfully, your Community Clubs’ social licence is all about underpinning your role within Queensland communities, by way of what you do being appropriate, relevant and safe.  

We want members and guests (your patrons) to enjoy the facilities via a wholistic view that it is for life, as this approach not only assists in funding the club’s objects, but it also distinguishes the pedigree of your social licence.

Stay tuned, as more will be shared on this matter as potential outcomes and industry deliverables become clearer.