Perceived efficacy of responsible gambling strategies in Queensland hotels, casinos and licensed clubs

Southern Cross UniversityePublications@SCU

School of Commerce and Management

2003

Perceived efficacy of responsible gamblingstrategies in Queensland hotels, casinos andlicensed clubsHelen BreenSouthern Cross University, [email protected]

Jeremy BuultjensSouthern Cross University, [email protected]

Nerilee HingSouthern Cross University, [email protected]

ePublications@SCU is an electronic repository administered by Southern Cross University Library. Its goal is to capture and preserve the intellectualoutput of Southern Cross University authors and researchers, and to increase visibility and impact through open access to researchers around theworld. For further information please contact [email protected].

Suggested CitationBreen, H, Buultjens, J & Hing, N 2003, Perceived efficacy of responsible gambling strategies in Queensland hotels, casinos and licensed clubs,report to the Research and Community Engagement Division (formerly the Gambling Policy Directorate) of Queensland Treasury.

http://epubs.scu.edu.au

http://epubs.scu.edu.au/comm_pubs

mailto:[email protected]

centre for gambling education & research

The Perceived Efficacy of ResponsibleGambling Strategies in Queensland Hotels,

Casinos and Licensed Clubs

ByMs. Helen Breen, Dr. Jeremy Buultjens and Dr. Nerilee Hing

Centre for Gambling Education and ResearchSchool of Tourism and Hospitality Management

Southern Cross UniversityLismore NSW 2480

Final ReportFor the Research and Community Engagement Division

(formerly the Gambling Policy Directorate)of Queensland Treasury

August 2003Reviewed December 2003

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CONTENTS

EXECUTIVE SUMMARY 1

1 INTRODUCTION TO THE STUDY 10

1.1 Introduction 10

1.2 Aims and Objectives of the Study 11

1.3 Conclusion 11

2 BACKGROUND TO THE RESEARCH TOPIC 12

2.1 Introduction 12

2.2 Problem Gambling 12

2.3 Responsible Gambling 15

2.4 Responsible Gambling Codes of Practice 16

2.5 Development of the Queensland Responsible Gambling Code of Practice 19

2.6 Implementation of the Queensland Responsible Gambling Code of Practice 222.6.1 The Queensland Responsible Gambling Resource Manual 222.6.2 Training in Implementing the Code 232.6.3 Other Support and Involvement of the Industry Associations 252.6.4 Placement of Responsible Gambling Signage by the QOGR 26

2.7 Accountability and Review of the Queensland Responsible Gambling Code ofPractice 27

2.8 Evaluating the Queensland Responsible Gambling Code of Practice: ATheoretical Framework 29

2.9 Evaluating the Queensland Responsible Gambling Code of Practice: APractical Framework 33

3 RESEARCH METHODS 36

3.1 Introduction 363.2 Research Design 36

3.3 The Sample 37

3.4 Data Collection 38

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3.5 Data Analysis 41

3.6 Limitations of the Methodology 41

3.7 Conclusion 42

4 THE LONGREACH CASE STUDY 43

4.1 Introduction 43

4.2 Awareness of the Code in Longreach 43

4.3 Implementation of the Code in Longreach 444.3.1 Implementation: Provision of Information 484.3.2 Implementation: Interaction with Customers and Community 484.3.3 Implementation: Exclusion Provisions 494.3.4 Implementation: Physical Environments 504.3.5 Implementation: Financial Transactions 514.3.6 Implementation: Advertising 51

4.4 Perceived Adequacy of the Code in Longreach 514.4.1 Adequacy: Provision of Information 524.4.2 Adequacy: Interaction with Customers and Community 524.4.3 Adequacy: Exclusion Provisions 534.4.4 Adequacy: Physical Environments 534.4.5 Adequacy: Financial Transactions 534.4.6 Adequacy: Advertising 54

4.5 Facilitators and Impediments for the Code in Longreach 544.5.1 Facilitators 544.5.2 Impediments 54

4.6 Summary 554.6.1 Awareness and Implementation 554.6.2 Adequacy 56

5 THE TOWNSVILLE CASE STUDY 57

5.1 Introduction 57

5.2 Awareness of the Code in Townsville 58

5.3 Implementation of the Code in Townsville 605.3.1 Implementation: Provision of Information 645.3.2 Implementation: Interaction with Customers and Community 655.3.3 Implementation: Exclusion Provisions 675.3.4 Implementation: Physical Environments 695.3.5 Implementation: Financial Transactions 715.3.6 Implementation: Advertising 72

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5.4 Perceived Adequacy of the Code Townsville 735.4.1 Adequacy: Provision of Information 755.4.2 Adequacy: Interaction with Customers and Community 765.4.3 Adequacy: Exclusion Provisions 775.4.4 Adequacy: Physical Environments 795.4.5 Adequacy: Financial Transactions 815.4.6 Adequacy: Advertising 83

5.5 Facilitators and Impediments for the Code in Townsville 845.5.1 Facilitators 855.5.2 Impediments 86

5.6 Summary 895.6.1 Awareness and Implementation 895.6.2 Adequacy 905.6.3 Facilitators and Impediments 90

6 THE SOUTH EAST QUEENSLAND CASE STUDY 92

6.1 Introduction 92

6.2 Awareness of the Code in South-East Queensland 93

6.3 Implementation of the Code in South-East Queensland 946.3.1 Implementation: Provision of Information 986.3.2 Interaction with Customers and Community 996.3.3 Implementation: Exclusion Provisions 1016.3.4 Implementation: Physical Environments 1036.3.5 Implementation: Financial Transactions 1056.3.6 Implementation: Advertising 106

6.4 Adequacy of the Code in South-East Queensland 1086.4.1 Adequacy: Provision of Information 1106.4.2 Adequacy: Interaction with Customers and Community 1126.4.3 Adequacy: Exclusion Provisions 1136.4.4 Adequacy: Physical Environments 1156.4.5 Adequacy: Financial Transactions 1166.4.6 Adequacy: Advertising 118

6.5 Facilitators and Impediments for the Code in South-East Queensland 1206.5.1 Facilitators 1206.5.2 Impediments 122

6.6 Summary 1236.6.1 Awareness and Implementation 1236.6.2 Adequacy 1246.6.3 Facilitators and Impediments 126

7 CROSS-CASE ANALYSES OF THE THREE CASE STUDIES 127

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7.1 Introduction 127

7.2 Compliance with the Code 127

7.3 Regional Location and Compliance with the Code 129

7.4 Venue Size and Compliance with the Code 130

7.5 Venue Type and Compliance with the Code 132

7.6 Perceived Adequacy of the Code 134

7.7 Regional Location and the Perceived Adequacy of the Code 136

7.8 Venue Size and Perceived Adequacy of the Code 136

7.9 Venue Type and Perceived Adequacy of the Code 138

7.10 Conclusion 140

8 CONCLUSIONS 141

8.1 Introduction 141

8.2 Results for Research Objective 1 141




8.6 Conclusion 148

9 RECOMMENDATIONS 149

10 ACTIONS ALREADY UNDERTAKEN 152

10.1 Responsible Gambling Advisory Committee 152

10.2 Responsible Gambling Training 153

10.3 Need for Variations to Practices in the Code of Practice in ParticularCircumstances 154

10.4 Awareness and Education of the Code of Practice 154

11 REFERENCES 157

12 APPENDICES 160

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LIST OF TABLES & FIGURES

Table 2-1 Practices in the Queensland Responsible Gambling Code of Practice ............ 21

Figure 2-1: A Planning and Evaluation Cycle for Public Health Programs..................... 30

Figure 2-2: A Framework for Evaluating the Queensland Responsible Gambling Codeof Practice ............................................................................................................. 34

Table 3-1 Key Characteristics of Participating Venues .................................................. 40

Table 4-1 Implementation of the Code’s Elements in the Longreach Venues................. 45

Table 4-2 Perceived Adequacy of the Code’s Practice Areas for Longreach .................. 52

Table 5-1 Implementation of the Code’s Elements in the Townsville Venues ................ 61

Table 5-2 Perceived Adequacy of the Code’s Practice Areas for Townsville ................. 74

Table 6-1 Implementation of the Code’s Elements in the South-East QueenslandVenues .................................................................................................................. 95

Table 6-2 Perceived Adequacy of the Code’s Practice Areas for South-East QLD....... 109

Table 7.1 Regional Location and Compliance with the Code....................................... 128

Table 7.2 Venue Size and Compliance with the Code.................................................. 131

Table 7.3 Venue Type and Compliance with the Code ................................................ 133

Table 7.4 Regional Location and Perceived Adequacy of the Code ............................. 135

Table 7.5 Venue Size and Perceived Adequacy of the Code ........................................ 137

Table 7.6 Venue Type and Perceived Adequacy of the Code ....................................... 139

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EXECUTIVE SUMMARY

The Queensland Responsible Gambling Strategy (Queensland Treasury, 2002a) was

released on 27 February 2002 and encompassed a range of initiatives for achieving its‘overarching objective…to minimise the harmful impacts of problem gambling’. To

ensure that gambling environments are safe and supportive for consumers, the

Queensland Responsible Gambling Advisory Committee developed the voluntaryQueensland Responsible Gambling Code of Practice (Queensland Treasury, 2002b), the

subject of this research. In developing this Code, the Queensland ResponsibleGambling Advisory Committee undertook extensive community and industry

consultation and the Code was launched on 29 May 2002. It advocates that gambling

providers implement a range of responsible gambling practices in six broad areas.These comprise the provision of information, interaction with customers and the

community, exclusion provisions, physical environments, financial transactions, andadvertising. Through implementing these practices, the Code aims to minimise the

potential for harm associated with gambling and allow people to make informed

decisions about their gambling.

This study, funded by the Research and Community Engagement Division of

Queensland Treasury, was conducted with the aim of investigating the perceivedefficacy of these six broad responsible gambling practices in selected Queensland

hotels, casinos and clubs in three case study areas - Longreach, Townsville and south-

east Queensland. These areas were selected as representing remote, regional and urbanareas. More specifically, the project measured and compared gambling providers’

awareness and perceived adequacy of the provisions of the Code, and facilitators andimpediments to implementing the Code and to meeting its objectives. Four research

objectives were addressed in this study to achieve this aim:

1. To identify those elements of the Queensland Responsible Gambling Code of

Practice that are and are not being implemented in selected hotels, casinos and

licensed clubs;

2. To assess the perceptions of key staff in the selected venues of the adequacy of theCode to provide an indication of its potential effectiveness from a venue

perspective;

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3. To identify factors facilitating and impeding the implementation of the Code; and

4. To recommend a range of options to encourage further implementation of the Code.

The main data collection method involved qualitative, semi-structured interviews with

50 managers and staff in 30 venues with gambling facilities in Longreach, Townsvilleand south-east Queensland. A tick-box questionnaire instrument, based on the Code,

was used to record the implementation of the various practices in the Code, with further

details gathered through the interviews. These interviews also investigated theperceived adequacy of the Code, from the perspective of managers and key staff in

these organisations. On-site observation of responsible gambling practices was alsoconducted in each venue visited. Additionally, interviews were held with key industry

associations and some welfare agencies to gather additional information about the

implementation and performance of the Code to date.

Key results include:

ß Of the six practice areas outlined in the Queensland Responsible Gambling

Code of Practice, the practice area most commonly reported as being adhered towas advertising. Twenty venues or 66% of the venues visited, all based in

heavily populated locations, used advertising and promotions to attractcustomers. Managers and staff in these venues stated that their advertising was

responsible and adhered to all relevant aspects of the Code, suggesting a 100%

implementation rate with this practice area. However, there are two qualifiersthat should be noted. The first is that the researchers did not conduct an

independent evaluation of the advertising practices in the venues, but relied onself-reported data from the interviewees. A such, the researchers cannot verify

these self-reported levels of compliance with the advertising practices in the

Code. Second, a number of managers and staff stated that other venues were notbeing responsible in their advertising practices, with several examples cited.

Indeed, the researchers did encounter such breaches of the Code during theirfield work, including some by venues who participated in the study and who

nevertheless reported compliance with the Code’s advertising practices.

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ß The financial transactions practice area of the Code had an average 85%

implementation rate. Venues in south-east Queensland were much more likelyto have implemented all elements of the financial transactions practice area of

the Code than those in the other two regions.

ß The physical environments practice area had an average 80% implementation

rate. Practices in this area were widely adhered to by venues in Longreach,

compared to those in the other two locations.

ß The remaining three practices in the Code - provision of information, interaction

with customers and the community, and exclusion provisions - had lower levelsof implementation, between 60 and 63%. For each of these practices, venues in

south-east Queensland had the highest levels of implementation.

ß Implementation of all the Code’s practices was very high (97%) in the twocasinos in the sample. This compared to the overall implementation rates for

clubs of 74% and for hotels of 67%.

ß Venues with small gaming installations had a lower implementation rate of theCode’s practices than venues with large gaming installations. The former’s

adherence to the Code in the area of interaction with customers and thecommunity was particularly poor.

ß The aspect of the Code considered most adequate, with 80% agreement, was

based on physical environments. Interaction with customers and the communityand responsible advertising and promotions both received a 67% rate of

approval from managers and staff. Managers in 60% of the venues agreed thatfinancial rules and limits were adequate to promote responsible gambling, while

57% believe that exclusion provisions are appropriate. Respondents were

generally not convinced that the provision of information and signage wasadequate to support responsible gambling.

ß Based on regional differences, managers and staff in Longreach were lesspositive about the adequacy or potential effectiveness of most of the practices in

the Code. Managers and staff in Townsville were very positive about the

adequacy of their interaction with customers and support services networks. In

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south-east Queensland, the physical environment practice area was perceived as

the being the most potentially effective measure in the Code.

ß Perceptions of the Code’s adequacy and potential effectiveness based on size of

gaming installation showed differences between venues with small and largegaming installations. Except for the practice area of physical layout and

environment, managers and staff with small gaming installations were less

favourable towards and optimistic about the Code than those with large gaminginstallations.

ß Based on type of venue, managers and staff in clubs were more positive aboutthe adequacy and potential effectiveness of all practices in the Code, except for

the exclusion provisions. Managers and staff in casinos were evenly divided in

their opinions about the adequacy and potential effectiveness of the practicesrelevant to provision of information, interaction with customers and the

community, and physical environments.

ß Facilitating factors assisting compliance with the Code included staff training,education and development in responsible gambling, industry association and

member commitment to the Code, understanding the philosophy underpinningthe Code, adequate support materials and resources, some practices with

legislative overlap, prior experience with responsible gambling in other state

systems, regular audits, and strong links with community support networks.

ß Impediments hindering compliance with the Code included high staff turnover,

low levels of staff training and education in responsible gambling, not being a

member of an industry association, managerial apathy, being in a remotelocation, being a busy owner-manager, and not receiving a copy of the Code andother responsible gambling materials.

ß Based on the research results, eighteen recommendations have been made to

improve the implementation and potential effectiveness of the Code, to inform

current policy, and to assist in later evaluations of the Code, including those

planned by Queensland Treasury (2003a) in its review of the Code over its first

five years of implementation.

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SECTION ONE

1 INTRODUCTION TO THE STUDY

1.1 Introduction

The Queensland Treasury released the Queensland Responsible Gambling Strategy

(2002a) on 27 February 2002. It encompassed several initiatives for achieving its

‘overarching objective…to minimise the harmful impacts of problem gambling’. To

ensure that gambling environments are safer and more supportive for consumers, which

is one objective of the Queensland Responsible Gambling Strategy (Queensland

Treasury, 2002a), the Queensland Responsible Gambling Advisory Committee

developed the Queensland Responsible Gambling Code of Practice (Queensland

Treasury, 2002b). Adherence to this code by gambling providers is voluntary. In

developing this Code, the Queensland Responsible Gambling Advisory Committee

undertook extensive community and industry consultation and the Code was launched

on 29 May 2002. It advocates that gambling providers implement a range of responsible

gambling practices in six broad areas. These comprise the provision of information,

interaction with customers and the community, exclusion provisions, physical

environments, financial transactions, and advertising. Through implementing a range of

measures in each of these practice areas, the Code aims to minimise the potential for

harm associated with gambling and allow people to make informed decisions about

their gambling.

This report documents the conduct and the findings of a research project commissioned

by the Gambling Research Panel of Queensland Treasury (now the Research and

Community Engagement Division). The study investigated the perceived efficacy of

responsible gambling strategies in selected Queensland hotels, casinos and licensed

clubs, from the perspective of venue management and staff. Empirical research was

conducted in three case study areas in Queensland - Longreach, Townsville and south-

east Queensland, to represent remote, regional and urban areas, respectively. Its primary

focus was on the responsible gambling practices contained in the voluntary Queensland

Responsible Gambling Code of Practice (Queensland Treasury, 2002b). The timeframe

for this research was August 2002 to July 2003.

This first section of the report articulates the specific aims and objectives of the study.

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1.2 Aims and Objectives of the Study

The aim of this study was to assess the perceived efficacy of the responsible gambling

practices contained in the Queensland Responsible Gambling Code of Practice in

selected Queensland hotels, casinos, and licensed clubs. Specifically, the project

measured and compared gambling operators’ awareness and perceived adequacy of the

provisions in the Code, and facilitators and impediments to implementing the Code and

to meeting its objectives. Four research objectives were addressed in this study to

achieve this aim:

1. To identify those elements of the Queensland Responsible Gambling Code of

Practice that are and are not being implemented in selected hotels, casinos and

licensed clubs;

2. To assess the perceptions of key staff in the selected venues of the adequacy of

the Code to provide an indication of its potential effectiveness from a venue

perspective;

3. To identify factors facilitating and impeding the implementation of the Code;

and

4. To recommend a range of options to encourage further implementation of the

Code.

1.3 Conclusion

Having introduced the study and identified its aims and objectives, Section Two of this

report explores the contextual background for this research into responsible gambling

practices in Queensland. Section Three then outlines the research methodologies used.

Sections Four, Five and Six each describe and analyse the results for the three

individual case studies, while Section Seven provides a cross-case analysis of the

findings for these three case study areas. Section Eight presents and explains the

research conclusions and Section Nine the recommendations. Section Ten lists the

references for literature cited in this report while Section Eleven contains the

appendices.

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SECTION TWO

2 BACKGROUND TO THE RESEARCH TOPIC

2.1 Introduction

This section of the report provides some contextual background to the research topic.Because codes of practice in responsible gambling are generally a response to concerns

about problem gambling, this concept is firstly outlined, along with some estimates of

its prevalence in Australia and Queensland. The concepts of responsible gambling andresponsible provision of gambling are illuminated, along with some challenges for

effective implementation of responsible gambling codes of conduct. Later discussionfocuses on the development, implementation and review processes for the Queensland

Responsible Gambling Code of Practice (Queensland Treasury, 2002b). The section

concludes by presenting theoretical and practical frameworks which have guided thisinvestigation into the efficacy of the Queensland Responsible Gambling Code of

Practice.

2.2 Problem Gambling

The provision of commercial gambling in Australia has developed into a major

industry, providing certain benefits for individuals, organisations, communities andgovernments. However, gambling does create social, health and welfare costs (Korn

and Shaffer, 1999) due mainly to problem gambling. There have been difficulties withdefining problem gambling and these differences in definition are important because

they impact on solutions provided to overcome the problem. The Productivity

Commission (1999) included a range of definitions of problem gambling that variouslyemphasised either symptoms (e.g. loss of control, chasing debts) or effects (e.g.

disruption and damage to personal, family or work life). One widely accepted definition

is that adopted by the Victorian Casino and Gaming Authority (VCGA). It states thatproblem gambling occurs ‘where a person’s gambling activity gives rise to harm to the

individual player, and/or to his or her family, and may extend into the community’(Australian Institute for Gambling Research, 1997).

A similar definition, one that also defines problem gambling according to its effects,

has been adopted by the Queensland Government (Queensland Treasury, 2002a,2002b):

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‘Problem gambling exists when gambling activity results in a range of adverse

consequences where:

• the safety and wellbeing of gambling customers and/or their families and friends

are placed at risk; and/or

• negative impacts extend to the broader community.’

As might be expected where definitional issues have existed, there are differing

estimates of the extent of gambling problems within the Australian community. Themost widely used estimates for Australia are those derived by the Productivity

Commission (1999). The Commission estimated that approximately 1 per cent of theadult Australian population (around 130,000 people) had ‘severe problems’ with

gambling, while an additional 1.1 per cent (160,000) had ‘moderate problems’, making

a pool of approximately 290,000 ‘problem gamblers’ or 2.1 per cent of adultAustralians (Productivity Commission, 1999). The Commission also found that

problem gamblers comprised 15 per cent of regular, non-lottery gamblers but accounted

for approximately 30 per cent of gambling industry revenue, losing on average around$12,000 per head, per year (Productivity Commission, 1999). The Commission applied

the Australian interpretation of the SOGS screening instrument and acknowledged thatthe resulting figures probably underestimate the extent of the problem (Productivity

Commission, 1999).

In Queensland, the Queensland Household Gambling Survey (2001) used the CanadianProblem Gambling Index to estimate that 0.83 per cent of the Queensland adult

population, or 21,910 people, can be classified into the ‘problem gambling’ category,with a further 2.7 per cent (71,227 people) in the ‘moderate risk gambling’ group, 8.18

per cent (215,824 people) in the ‘low risk gambling’ category, 73.24 per cent

(1,933,565 people) in the ‘non-problem gambling’ group, with the remaining 15.06%(397,449 people) in the ‘non-gambling’ category. In this survey, the ‘problem

gambling’ category comprises ‘those who have experienced adverse consequences fromtheir gambling and may have lost control of their behaviour’ and whose ‘involvement in

gambling is likely to be heavy’. Respondents in the ‘moderate risk gambling’ group are

described as those who ‘may or may not have experienced adverse consequences fromgambling’ but who ‘may be at risk if they are heavily involved in gambling and if they

respond positively to three or four of the correlates of problem gambling’. These

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correlates comprise faulty cognition, remembering an early win or early loss, a family

history of alcohol, drug and gambling problems, using alcohol or drugs while gambling,the urge to drink, use drugs or gamble in response to a painful event in their lives, and

stress and depression. Interestingly, these descriptors for the ‘problem gambling’ and‘moderate risk gambling’ categories refer to a mixture of the effects, symptoms and risk

factors associated with problem gambling, which appears at odds with the ‘effects-only’

definition of problem gambling adopted by the Queensland Government (QueenslandTreasury, 2002a, 2002b).

While the number of problem gamblers indicated by these surveys represents a verysmall minority of the general population, problem gambling is considered by many to

be a serious public health issue requiring an appropriate response from industry,

governments, individuals, communities and other stakeholders. This is because theconsequences of problem gambling can be disastrous for the individual affected, as has

been well documented elsewhere (e.g. Walker, 1992; Dickerson, 1993; Lesieur, 1996;

Australian Institute for Gambling Research, 1997), and because they also impact onfamily and friends and may also require certain public and other services to deal with

their problems. For example, the Productivity Commission (1999) found that, for eachperson experiencing gambling problems, at least five others in the community (family,

friends and work colleagues) were likely to be affected, making the number of people

affected by problem gambling at least 1,450,000 nationally. From a public healthperspective, the costs associated with gambling problems include the more obvious,

such as treatment programs, impaired work performance, family breakdown andgambling related crime. They also include the opportunity costs of the time and money

spent gambling, by both ‘problem’ and ‘non-problem’ gamblers. These opportunity

costs may include time not spent in family interaction or at social events or other leisurepursuits (Walker, 1998), and money not directed to household items, family needs or

household savings (Livingstone, 1999).

In acknowledging the existence, extent and consequences of problem gambling, many

Australian governments and gambling providers have implemented various measures to

promote responsible gambling, a concept discussed below.

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2.3 Responsible Gambling

Despite being widely used, the terms ‘responsible gambling’ and ‘responsible provisionof gambling’ are still poorly defined. Dickerson (1998) noted that they are generally

used to refer to a collection of operator practices that aim to reduce harm. Suchpractices include those identified by the Productivity Commission (1999), including

information about the price and nature of gambling products, information about the

risks of problem gambling, controls on advertising, controls on the availability ofATMs and credit, and self-exclusion options. The introduction of such practices in

responsible gambling programs in Australia recognises that, as gambling is a legalisedactivity, with known risks, a duty of care accrues to legislators and providers to

minimise harm to the public (Michaleas, 2000). Moreover, most experts in Australia

have now rejected medical and addiction interpretations of problem gambling toredefine it as a social and public health issue. This has shifted responsibility for

addressing problem gambling from individual gamblers, to gambling providers and

regulators to enact structural changes for improved harm minimisation in gambling(Hing, 2000).

Harm minimisation aims to reduce the risk and severity of adverse consequencesassociated with using a product, without necessarily reducing that use per se (Plant,

Single and Stockwell, 1997:3-4). The aim is not to achieve some ideal usage level, but

to implement preventative measures that reduce the chances of adverse outcomes(Plant, Single and Stockwell, 1997:7). Further, The National Drug Strategy in Australia

(Ministerial Council on Drug Strategy, 1998) popularised a public health vocabularythat is now being applied to other areas, including problem gambling. Three key

approaches were emphasised - demand reduction, supply control, and harm

minimisation. While aspects of each of these approaches can be seen in variousmandatory and voluntary responses to problem gambling, most responsible gambling

programs and codes of practice in Australia focus on harm minimisation.

In addition to harm minimisation, responsible gambling also has been interpreted to

include informed consent, a key principle underpinning consumer protection. For

example, Dickerson (1998) suggests that by applying the principle of informed consent,responsible gambling needs to ensure that consumers are at least:

• informed about all the relevant processes involved in the form of gambling;

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• making a genuine choice, with other options available to them; and

• not making the decision to gamble under conditions of strong emotion or personalcrisis.

Responsible provision of gambling also implies that gambling is provided in a sociallyresponsible way, one which is responsive to community concerns and expectations. For

example, Hing (2003) has noted that responsible provision of gambling may be

interpreted as involving the provision of gambling in a manner that meets acommunity’s economic, legal, ethical and philanthropic expectations at any given point

in time. This interpretation draws on a seminal model of corporate social responsibility(Carroll, 1979; 1991) and helps to align responsible provision of gambling with more

generic concepts in the corporate social responsibility literature.

These three principles commonly associated with responsible gambling and responsibleprovision of gambling – harm minimisation, informed consent and social responsibility

and responsiveness – are recognised by the Queensland Government (2002a, 2002b),

which defines responsible gambling as:

‘occur(ring) in a regulated environment where the potential for harm associated with

gambling is minimised and people make informed decisions about their participation in

gambling. Responsible gambling occurs as a result of the collective actions and shared

ownership by individuals, communities, the gambling industry and Government to

achieve outcomes that are socially responsible and responsive to community concerns.’

2.4 Responsible Gambling Codes of Practice

Many jurisdictions, gambling industry sectors and gambling providers have introducedresponsible gambling programs and codes of conduct in recent years. A comprehensive

audit of responsible gambling codes of practice in Australia was conducted in early

2001 (Hing, Dickerson and Mackellar, 2001) for the Australian Gaming Council toinform the Council’s development of a national framework for the responsible delivery

and service of gaming. As well as identifying a range of mandatory measures inresponsible gambling, the audit also identified and examined 30 voluntary responsible

gambling codes operating in Australia at that time. The researchers found that a wide

range of responsible gambling practices are promoted by these voluntary measures to

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extend upon the mandatory measures in responsible gambling. However, given the

diverse frameworks underpinning these voluntary initiatives, the practices they includeand the ways they have been implemented vary significantly, with a wide variety of

stewardship processes in place to facilitate their implementation. Further, theresearchers found that no programs had mechanisms for independent monitoring of

program implementation or for assessing compliance levels, while only a small

minority had processes for periodic review. Further, no programs had been evaluated interms of their effectiveness in addressing problem gambling or in promoting

responsible gambling. Despite the diversity of strategies found by the researchers, therewere sufficient common themes amongst the codes examined to highlight the following

deficiencies:

ß definitions of key elements, such as responsible gaming, problem gambling orinformed consent were rarely given or integrated into strategies;

ß the codes failed to draw upon existing literature on harm minimisation as it

relates to other leisure/pleasure products that impinge on public health, such asalcohol and cigarettes;

ß the codes failed to develop strategies based on established principles or causalthemes in the research literature such as the links between continuous forms of

gambling, regularity of gambling and those players ‘at risk’;

ß although almost all jurisdictions in Australia are attempting to develop harmminimisation strategies, there has been no research collaboration even though

the very different prevalence levels of problem gambling across states provide anatural ‘experiment’;

ß with very few exceptions, there has been no independent evaluation of

strategies;

ß the existing range of strategies, perhaps with the exception of some self-

exclusion procedures, avoid targeting those most at risk and avoid the use ofadvertising of a similar power and sophistication to that employed in marketing

the gambling products themselves.

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In addition to the extremely difficult challenges of identifying measures that are

effective in addressing problem gambling and in promoting responsible gambling,responsible gambling codes of practice also face the challenge of being embraced and

effectively implemented, particularly where such codes are voluntary and self-governing, as is the case in Queensland. In comparing existing responsible gambling

codes with codes developed for other industries, Doherty (1999) suggested that, to be

effective, responsible gambling codes require the following types of support to optimisetheir implementation and compliance rates:

ß Explicit industry commitment - with clear objectives, expectations andgroundrules;

ß Involvement of front-line staff - with appropriate, regular training given to

the gambling sector’s highly casualised workforce;

ß A sound institutional base for developing and implementing the code -

including enforcement and compliance;

ß Clear and relevant incentives for voluntary compliance - and clear negativeconsequences for failure to comply;

ß Community confidence - gained through open processes in development andimplementation, and transparency in operation;

ß Regular flow of information - about how the code is working and the

response to it;

ß Extensive publicity - both for the code and for its complaints measures; and

ß Regular reviews - to ensure the code is meeting community expectations.

A lack of mechanisms for reporting, evaluation and compliance was noted in the

responsible gambling codes in existence at the time of Doherty’s research (1999). This

view was supported by the findings of the Productivity Commission (1999) and ofHing, Dickerson and Mackellar (2001) in the aforementioned audit. Given this

deficiency, it is instructive to assess the extent to which the voluntary Queensland

Responsible Gambling Code of Practice (2002b) has been embraced by gambling

19

providers. To contextualise this assessment, some background on the development,

implementation and review mechanisms of this Code is provided below.

2.5 Development of the Queensland Responsible Gambling Code of Practice

Prior to June 2002, the Queensland Acts and associated regulations relating to gamblingoperations in casinos, clubs and hotels went little beyond the usual minimum

requirements relating to minors, staff gambling, credit betting and exclusion provisions.

A $5 maximum bet on gaming machines and limits on machine numbers (280 perregistered club and 35 per hotel) were included. The legislation also provided for

imposed exclusion from playing gaming machines for one month where there arereasonable grounds for a licensee to believe that the peace and happiness of a person’s

family were endangered due to excessive playing.

The Policy Direction for Gambling in Queensland (Queensland Government, 2000)highlighted the need for a unified strategy to address social concerns related to the rapid

expansion of gambling. The policy emphasised better responsiveness to community

concerns, including in the area of responsible gambling. Accordingly, the Queensland

Responsible Gambling Strategy (Queensland Treasury, 2002a) was released on 27

February 2002 and encompassed a range of initiatives for achieving its ‘overarchingobjective…to minimise the harmful impacts of problem gambling’. Six priority action

areas were identified as:

1. Enhancing responsible gambling policies and programs through research;

2. Increasing community knowledge and awareness of the impacts of gambling;

3. Reducing risk factors for problem gambling through early intervention;

4. Developing a statewide system of problem gambling treatment and support services;

5. Ensuring gambling environments are safer and more supportive for consumers; and

6. Promoting partnerships to address statewide and local gambling issues andconcerns.

To address the fifth priority area above, the Queensland Responsible GamblingAdvisory Committee developed the Queensland Responsible Gambling Code of

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Practice, the subject of this research. The Queensland Responsible Gambling Advisory

Committee had its genesis as the Problem Gambling Advisory Committee, formed inAugust 1996, ‘with the aim of providing a community, industry and government forum

to monitor the impact of problem gambling in Queensland’ (Queensland ResponsibleGambling Advisory Committee, 2001). It is a tripartite alliance of community, industry

and government which has advised the Queensland Government on projects including

the Gambling Help-Line Pilot Project, the Queensland Review of Gaming, and thedevelopment of responsible gambling curriculum modules for secondary school

students (Queensland Responsible Gambling Advisory Committee, 2001).

In developing the Queensland Responsible Gambling Code of Practice (Queensland

Treasury, 2002b), the Responsible Gambling Advisory Committee undertook extensive

community and industry consultation, with a draft released for public consultation

between December 2000 and March 2001. Following further refinements, the Code was

launched on 29 May 2002. It commits gambling providers to a range of practices in six

broad areas, as shown in Table 2.1.

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Table 2-1 Practices in the Queensland Responsible Gambling Code of Practice

22

2.6 Implementation of the Queensland Responsible Gambling Code of Practice

As noted earlier, the Queensland Responsible Gambling Code of Practice was launchedin late May 2002. While the Code is voluntary, Queensland Treasury estimated that

almost 3,800 gambling providers across the state would be implementing it(Queensland Responsible Gambling Advisory Committee, 2002). Various measures

have been adopted to encourage venues to implement the Code. The major ones

comprise developing and distributing the Queensland Responsible Gambling Resource

Manual, provision of training in implementing the Code, support and involvement of

the industry associations and the casinos, and placement of responsible gamblingsignage in venues by the Queensland Office of Gaming Regulation (QOGR). These

measures have relied in large part on the active involvement of the industry associations

for the club and hotel industries and of casino management in Queensland. In order toclarify the nature of this involvement, the researchers interviewed the CEO from Clubs

QLD, Ms Penny Wilson, the Development and Training Manager from the Queensland

Hotels Association (QHA), Mr Geoff Parker, and Ms Mary Marquass, ResponsibleGambling Liaison Manager from Conrad Jupiters Casino in February 2003. The

discussion which follows incorporates these interview findings.

2.7 The Queensland Responsible Gambling Resource Manual

The Queensland Responsible Gambling Resource Manual supports the Code and was

developed in collaboration with gambling industry sectors. It is maintained by theGambling Policy Directorate (now the Research and Community Engagement Division)

of Queensland Treasury with advice from the Queensland Responsible GamblingAdvisory Committee. The aim of the Resource Manual is to assist gambling providers

to implement the Code of Practice. It includes guidance for gambling providers to

develop and implement their responsible gambling policy, examples of practices thatconform to industry best practice, and an outline of responsible gambling strategies

specific to each industry sector and based upon the Code’s practices (QueenslandTreasury, 2002b).

Once the Queensland Responsible Gambling Code of Practice was launched, Clubs

QLD was given responsibility for sending out the Queensland Responsible Gambling

Resource Manual to all clubs in Queensland, even those which are not members of the

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association. Clubs QLD has around 520 members, which represent about 75 per cent of

clubs who ‘could be members’ (that is, those with gaming machines). Ms Wilsonindicated that Clubs QLD personally delivered some of the Resource Manuals, while

the remainder were mailed out.

Similarly, the QHA has taken responsibility for distributing the Resource Manual to

Queensland hotels. It has done this by distributing the Manual at training workshops, by

delivering the Manual to some hotels en route to training workshops, and by sending itout to the remaining hotels, including both members and non-members of the

association. About 70-75 per cent of the 1,230 hotels in Queensland are members ofQHA (although only about 750 have gaming machines), with membership ‘probably

more concentrated in coastal areas’.

2.8 Training in Implementing the Code

Additionally, the Code is supported by industry training provided by various registered

training providers in Queensland. One training provider is Clubs QLD which offers

training in responsible gambling to all clubs, including non-members. It commencedthis training in May 2002 to coincide with the launch of the Code, and has provided

training to gaming managers and staff, but not club directors, although the importanceof responsible gambling is ‘emphasised to directors in the liabilities training provided to

them by the association’. Clubs QLD notifies all Queensland clubs of its training

sessions through flyers and its newsletters. At the time of the interview (13 February2003), Clubs QLD ‘definitely hadn’t trained all clubs as yet’, but it intended to target

club managers who had not done the course by making personal contact with them andto ‘couple training opportunities with zone meetings’. The training is designed as a

‘one-off’ session lasting 2.5 to 4 hours, and Ms Wilson’s impression was that

‘operational staff were generally positive about the Code’. The location of trainingsessions depends on potential demand, with visits to major centres like Cairns,

Townsville and Mt Isa occurring ‘a couple of times a year’. Less frequent visits aremade to smaller centres. However, Ms Wilson indicated that Clubs QLD would provide

training ‘anywhere where there are sufficient numbers’. Further, Ms Wilson

acknowledged that the turnover of gaming staff is such that Clubs QLD needs to keepoffering training, so it may ‘therefore do the circuit (around the state) once per year’. In

contrast, the turnover of club managers ‘varies, but they often stay within the industry’.

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Clubs QLD started charging $30 per participant for a training session, but now charges

$60-$70 ‘to cover costs’.

Another training provider is the QHA. It held its first responsible gambling workshop in

April 2002, the first of 31 planned workshops to be conducted in three stages of trainingprovision. Stage One attempted to provide training in all main centres based on the

‘spread of hotels with gaming machines’. Stage Two has concentrated on large centres

on the Queensland coast. Stage Three had not been implemented at the time of theinterview (13 February 2003). The QHA training workshops are of three hours duration

and were designed as a ‘one-off’ session for Stages One and Two. However, StageThree will ‘take it a bit further’, incorporating ‘any issues arising from the Queensland

Responsible Gambling Advisory Committee’s working parties examining self-exclusion

and advertising and promotions’. Mr Parker felt that the workshops are ‘most effective’,with ‘a high implementation rate (of the Code) after workshop attendance’. The QHA

advertises its training workshops via notices sent to all hotels which are on the QOGR

mailing list, although Mr Parker acknowledged that, for some hotels, this list mayidentify only the hotel owner and not the manager. The QHA also ‘signals in its

newsletters that if people can’t make it to a regional workshop, then they can ring theQHA who will try to arrange a workshop, even for non-members’. Mr Parker indicated

that the training workshops are ‘nearly at an end’ as they are now ‘struggling to get

many attendees’. Ongoing training will therefore be through information and discussionin the association’s newsletters and through the AHA Review, a publication distributed

to all hotels. Additionally, the QHA has a responsible gambling section on its website.

Conrad Jupiters, which operates three casinos (Gold Coast, Brisbane and Townsville),

conducts its own in-house training in responsible gambling. At the time of the interview

(February 2003), it had conducted 77 training sessions involving 1,100 staff. While only740 of these employees were directly involved with the provision of gambling products,

the training was also delivered to all staff, including supervisors and managers acrossthe business. This training comprised a single session of four hours. Annual refresher

courses are being introduced in 2004.

In addition to Clubs QLD and the QHA, other registered training providers offerresponsible gambling training in Queensland. These include QLD TAFE (but only as

part of a longer course, such as a Certificate Two) and the Currumbin College of

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Hospitality. However, the number of responsible gambling training providers is

relatively few in Queensland as responsible gambling certificates are not required bylaw, and so demand is more limited than in NSW, for example, where such training is

mandatory for staff working in gaming areas.

2.9 Other Support and Involvement of the Industry Associations

In general, Clubs QLD, the QHA and Conrad Jupiters appear to have made a major

contribution to facilitating the development and implementation of the Code.

Clubs QLD is a member of the Queensland Responsible Gambling Advisory Committee

and had input into the development of the Code via extensive consultation and theassociation’s existing Responsible Gaming Policy (1999) and Advertising and

Promotions Code of Ethics (1999). Along with its role in distributing the Resource

Manual and training provision, the association helps to publicise the Code throughnewsletters and zone meetings, it distributes Gamblers’ Help-Line brochures and signs

at training meetings, invites the welfare sector to its zone meetings, and conducts

responsible gambling sessions at tradeshows and conferences. Despite these initiatives,Ms Wilson acknowledged that some barriers to compliance with the Code were

‘apathy’, ‘denial’ (‘only a small club, therefore we have no problem gamblers’), thatsome clubs are not members of Clubs QLD, and intense competition (‘if one venue is

doing the right thing and another is not, then the latter could have an advantage, for

example, by conducting more aggressive advertising’). However, she also noted that animportant incentive for compliance with the Code is that ‘if clubs and pubs don’t

embrace this, then something less palatable may be imposed through legislation’.

The QHA is also a member of the Queensland Responsible Gambling Advisory

Committee and was responsible for developing the hotel section of the Resource

Manual in consultation with QHA members and other stakeholders, from large hotelconsortia to small owner-operators. It also drew on other responsible gambling codes of

practice, particularly the one already developed by the Australian Liquor andHospitality Group. Along with distributing the Resource Manual and providing training

workshops, the QHA helps to publicise the Code through its newsletters. However, Mr

Parker of the QHA acknowledged some barriers to compliance with the Code amongstQueensland hotels. These include the difficulty in attracting non-association members

26

to training workshops (with about 90 per cent of workshop attendees being members),

that ‘smaller operators west of the divide may think that they don’t have problemgamblers’, that hotel managers in remote areas may feel that they do not need formal

procedures, preferring instead to ‘approach problem gamblers and generally look outfor patrons’, and the ‘general busy-ness of small owner-operators who are juggling

multiple roles’. Additionally, the QHA was grappling with the ‘tyranny of distance’ in

providing training workshops in remote areas which requires ‘lots of dollars, resourcesand people’. Mr Parker also noted that hotels with small gaming installations had not

reached a ‘critical mass of machines where it was worth having gaming machinepromotions’ or had a large enough installation for ‘significant financial gain’ and so

responsible conduct of gambling was ‘not considered an issue’. He also pointed out that

small gaming machine installations in hotels ‘tend to be all in one room which is visiblefrom the bar’, so that responsible gambling measures were sometimes considered

unnecessary. However, the association appeared proactive in trying to optimise

compliance to the Code. Mr Parker noted that the QHA had responded to the results ofthe QOGR’s Responsible Gambling Practices Survey (Queensland Treasury, 2003b)

(see Section 2.7) by telephoning non-complying hotels to offer advice and assistance.

Conrad Jupiters also is a member of the Queensland Responsible Gambling Advisory

Committee and had substantial input into the development of the Code. Jupiters’ Vice-

President at the time of this study, Mr Grant Bowie, represented the casino group on theQueensland Responsible Gambling Advisory Committee, and was active in publicising

and promoting the Code via conferences and other outlets. Jupiters also hasmanagement representation on the various working parties formed by the Queensland

Responsible Gambling Advisory Committee, and on the National Advisory Body on

Gambling, the National Association for Gambling Studies, and the Australian Casinoand Responsible Gambling Taskforce.

2.10 Placement of Responsible Gambling Signage by the QOGR

One requirement of the Queensland Responsible Gambling Code of Practice is the

placement of signage in gaming venues. Hotels and clubs are required to display four

types of signage:

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ß Are you gambling with more than your money? These signs and take-away

cards provide information on the potential risks of gambling and where to gethelp for problem gambling.

ß An information display board which alerts customers to information availableon request (including a responsible gambling policy, a player information guide,

exclusion procedures, complaints resolution mechanisms and financial

transactions policy).

ß A responsible gambling mission statement.

ß Odds of winning major prizes.

To assist in implementing these requirements of the Code, Queensland Treasury paid

for an initial supply and installation of responsible gambling signs and takeaway cards

in all gambling venues in Queensland. The signs installed comprise the ‘Are you

gambling with more than your money?’ posters and takeaway cards and an information

display board with information about a venue’s responsible gaming policies. Additional

posters for cashier areas and a second print run of takeaway cards is also being provided

free of charge, after which the venues are responsible for purchasing replacements signs

and cards (QOGR, 2002)

2.11 Accountability and Review of the Queensland Responsible Gambling Code ofPractice

The Queensland Responsible Gambling Code of Practice has been described as ‘aliving document’ that ‘will be reviewed periodically’ (Queensland Responsible

Gambling Advisory Committee, 2002). The Code states a commitment to regularindependent monitoring and evaluation for its effectiveness (Queensland Treasury,

2002b).

The Review will occur in three phases with the focus for each phase changing, inrecognition that activities outlined in the Queensland Responsible Gambling Code of

Practice and the Responsible Gambling Resource Manual will take time to implement

and for results to be achieved (Queensland Treasury, 2003). The three phases are:

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1. Implementation (one year) to review the effectiveness of the implementation of the

Code of Practice and make any final modifications to the text.

2. Cultural Shift (three years) to review the level of cultural shift towards establishing

responsible gambling as a basic feature of running a gambling business.

3. Sustainability (five years) to examine the sustainability of the Code of Practice in

achieving best practice in responsible gambling and contributing to minimisation of

harm from problem gambling.

At the time of this research, only Phase One of the review had commenced. Its primary

objectives are to:

ß evaluate the effectiveness of implementation of the Code of Practice;

ß evaluate progress towards achieving the outcomes stated in the Code of Practice

and effectiveness of the practices;

ß identify new practices that have been developed in response to innovative best

practice within the industry;

ß identify amendments required to the Code of Practice and the ResponsibleGambling Resource Manual; and

ß identify where minimum standards may be recommended and, where appropriate,codified into legislation.

(Queensland Treasury, 2003a).

The major tool for collecting data for Phase One is the Responsible Gambling Practices

Survey which commenced on 1 October 2002 for clubs and hotels (Queensland

Treasury, 2002b), although at the time of this research, the findings of this survey hadnot been released. The process used for conducting the self-audit surveys in hotels and

clubs was as follows:

ß The Responsible Gambling Practices Surveys were sent to venues up to three weeksprior to a QOGR gaming machine audit, with the survey then collected by gaming

inspectors on audit day.

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ß The Responsible Gambling Officer in QOGR could later contact a venue to clarify

information in the survey, if necessary.

ß Letters were sent to the venues providing advice on their level of commitment to the

Code of Practice. If there were areas requiring attention, the venue was providedwith information on actions which need to be taken. These venues were invited to

address the areas requiring attention and provide details to the Responsible

Gambling Officer at the QOGR. This allowed for a reassessment of the venue'slevel of responsible gambling achievements.

(Queensland Treasury, 2003b).

While the Responsible Gambling Practices Survey and the current research project have

some overlap, there are important differences. The Responsible Gambling Practices

Survey will provide mainly quantitative data from a census of gambling providers inQueensland. In contrast, the current research aims to provide in-depth qualitative data

from a much smaller sample of clubs, hotels and casinos, to illuminate any issues and

challenges facing the venues, management and staff during program implementation.Another important difference is that the current research is an independent evaluation,

unlike the self-audit process of the Responsible Gambling Practices Survey. As such,the two research projects will complement, rather than duplicate, each other.

The preceding discussion has outlined the development and implementation of the

Queensland Responsible Gambling Code of Practice (Queensland Treasury, 2002b).The remainder of this section of the report draws on some theoretical concepts relating

to the evaluation of public health programs to guide the primary research conducted inthis study and reported later in this document.

2.12 Evaluating the Queensland Responsible Gambling Code of Practice: ATheoretical Framework

To guide this investigation into the perceived efficacy of responsible gambling

strategies in Queensland hotels, casinos and licensed clubs, the public health literatureon program evaluation was reviewed to locate an appropriate theoretical framework.

Many such frameworks view the planning and evaluation of public health programs as a

cyclic activity with ongoing reviews enabling continuous improvement of that program.

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The framework used to guide this investigation is shown in Figure 2.1. It identifies

eight stages in planning and evaluating a health program, from needs assessmentthrough to outcome evaluation, with that last stage then providing a feedback loop into

the first.

Figure 2-1: A Planning and Evaluation Cycle for Public Health Programs

Source: Hawe, Degeling and Hall, (1990:78).

Each of the stages depicted in Figure 2.1 is explained briefly below to illuminate wherethe current research project fits into this planning and evaluation cycle.

1. Needs assessment. Needs assessments are conducted to gain a comprehensivepicture of the health problems, or a particular health problem, in a community. As

such, they should guide choices and decisions about the types of health

interventions to be planned and implemented. Ideally, these choices and decisionsare guided by extensive consultation with relevant stakeholders and wide

31

canvassing of data sources and opinions. The aim is to specify the magnitude of the

problem and details of the target group(s) experiencing the problem, and to collectadditional data about factors that contribute to the health problem that may become

the focus of subsequent intervention.

2. Program planning. Program planning aims to devise a health program, within the

resources available, that is appropriate to the health problem and the identified

target group(s) and which will have the best chance of bringing about the desiredchange. Ideally, it involves specifying the program goals (desired change in the

health problem, e.g. a reduction in problem gambling in the community), theprogram objectives (desired change in the target group or groups, e.g. for more

individuals to gamble more responsibly), the program’s sub-objectives (desired

change in factors that are contributing to risk factors associated with the healthproblem, e.g. to minimise the likelihood of people losing track of time while

gambling), and the program’s strategy objectives (what the program will provide

and deliver, e.g. provision of training and support materials for all gambling venuesand managers). These goals, objectives, sub-objectives and strategy objectives

should be the standards against which the program is later evaluated.

3. Program implementation. This step involves implementing all the activities of the

program. Typical activities comprise advertising the program, distributing program

materials, training program participants, and providing administrative support tooptimise the likelihood that the activities of the program are implemented.

4. Process evaluation. Process evaluation aims to measure the activities of theprogram, the program quality and who it is reaching. It should logically precede

impact and outcome evaluation because, unless a program is getting to the right

people, is being implemented in the right way and participants are satisfied with it,then the program is unlikely to have the desired impacts and outcomes. Process

evaluation measures the success of the program in achieving its strategy objectives,that is, its success in providing and delivering what was planned. The main

questions to be addressed in process evaluation are: 1) is the program and all its

components reaching the target group(s)?; 2) are participants satisfied with theprogram?; 3) are all activities of the program being implemented?; and 4) are all the

materials and components of the program of good quality? It is this step in the

32

planning and evaluation cycle - process evaluation - that the current research

focuses on.

5. Program redesign and reimplementation. Information gathered from the process

evaluation is used in this stage to redesign the program to address any identifieddeficiencies, with the adjusted program then implemented. These adjustments are

then evaluated in a continuation of process evaluation until the program reaches an

optimum and stable form.

6. Evaluability assessment. This is the process of ensuring that the program is in such

a state that its impacts and outcomes can be evaluated meaningfully and usefully.Otherwise, there is a risk of designing an impact or outcome evaluation that collects

inappropriate information or that is conducted prematurely, before the program is

likely to work. For a program to be able to be adequately evaluated, there must be 1)a clearly defined fit between program activities and program goals; 2) proper

implementation of the program; 3) agreement on what evaluation questions should

be addressed; and 4) agreement on how the evaluation should be conducted andwhat should be measured.

7. Impact evaluation. Impact evaluation focuses on assessing the immediate effects ofthe program and usually corresponds with measuring whether the program is

meeting its objectives and sub-objectives. Thus, it assesses whether the program has

brought about the desired change in the behaviour of the target group or groups andwhether it has achieved the desired reduction of contributing risk factors associated

with the health problem.

8. Outcome evaluation. Outcome evaluation focuses on measuring the longer-term

effects of the program and usually corresponds with evaluating the success of the

program in meeting its goals relating to a desired change in the health problem (e.g.a reduction in problem gambling in the community). (Hawe, Degeling and Hall,

1990).

In summary, the planning and evaluation cycle involves three types of evaluation –

process, impact and outcome – that, in sequence, test the causal chain of events that has

been postulated by the health program under examination (Hawe, Degeling and Hall,1990:103). This postulated chain of events is that implementing the program (achieving

33

its strategy objectives) will reduce the risk factors associated with the health problem

(achieving its program sub-objectives), which in turn will achieve the desiredbehavioural change in the target group (achieving its program objectives), which will

ultimately bring about a reduction in the health problem (achieving its program goal).

Having outlined where the current research fits into a theoretical framework of public

health program planning and evaluation, the framework’s practical application to the

Queensland Responsible Gambling Code of Practice (Queensland Treasury, 2002b) isconsidered next.

2.13 Evaluating the Queensland Responsible Gambling Code of Practice: APractical Framework

At the time of this research, the development of the program under investigation, the

Queensland Responsible Gambling Code of Practice (Queensland Treasury, 2002b),had proceeded through the first three stages of the cycle shown in Figure 2.1 – needs

assessment, program planning and program implementation. As such, evaluation of the

Code is the next necessary step if the Code is to meet its commitment to independentmonitoring, evaluation and review (Queensland Treasury, 2002b). Thus, it is instructive

to consider the types of evaluation to which the Code may be subjected in order todelineate more clearly the type of evaluation undertaken in this research project. Figure

2.2 depicts the three types of evaluation which may be conducted for the Code and how

they relate to the Code’s goals, objectives, strategy objectives and strategy activities.However, it should be noted that the Code does not make all of these explicit, and so the

researchers have drawn on various statements and desired outcomes identified in theCode to compile Figure 2.2.

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Figure 2-2: A Framework for Evaluating the Queensland Responsible GamblingCode of Practice

Program GoalsTo promote responsible gambling, that is, gambling that ‘occurs

in a regulated environment where the potential for harmassociated with gambling is minimised and people make

informed decisions about their participation in gambling’.

Program Objectives• Individuals, communities, the gambling industry and the

Government have a shared understanding of responsiblegambling practices.

• Individuals, communities, the gambling industry and theGovernment have an understanding of their rights andresponsibilities in relation to responsible gambling practices.

• The gambling industry provides safe and supportiveenvironments for the delivery of gambling products andservices.

• Customers make informed decisions about their gamblingpractices.

• Harm from gambling to individuals and the broadercommunity is minimised.

• People adversely affected by gambling have access to timelyand appropriate assistance and information.

Strategy ObjectivesTo implement and achieve whole-of-industry voluntary

compliance with the QLD Responsible Gambling Code ofPractice and provide assistance for this via mechanisms such asthe QLD Responsible Gambling Resource Manual and training.

Strategy ActivitiesGambling providers to implement and adhere to responsiblegambling practices in:• Provision of information• Interaction with customers and community• Exclusion provisions• Physical environments• Financial transactions• Advertising and promotion

OutcomeEvaluation

ImpactEvaluation

ProcessEvaluation

ASPECTS OF THE PROGRAM APPROPRIATETYPE OF

EVALUATION

Source: adapted from Hawe, Degeling and Hall, (1990: 56-57).

35

This current research project focuses only on Stage Four of the Planning and Evaluation

Cycle (Figure 2.1) - process evaluation - to evaluate the Code’s success in achieving itsstrategy objectives through providing and delivering the planned strategy activities

(Figure 2.2). While addressing the specific research objectives identified in Section Oneof this report, this process evaluation of the Queensland Responsible Gambling Code of

Practice will also address the following generic questions associated with process

evaluation of health programs:

ß Is the program reaching the target group? Are all parts of the program reaching all

parts of the target group?

ß Are participants satisfied with the program?

ß Are all the activities of the program being implemented?

ß Are all materials and components of the program of good quality?

(Hawe, Degeling and Hall, 1990:61)

In addressing these generic questions in relation to the Queensland Responsible

Gambling Code of Practice (Queensland Treasury, 2002b), this research project canevaluate the effectiveness of the Code in terms of its success in providing and

delivering what was planned. It can also inform later impact and outcome evaluationsthat may be conducted, including those planned by Queensland Treasury (2003a) in its

review of the Code over its first five years of implementation.

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SECTION THREE

3 RESEARCH METHODS

3.1 Introduction

This section details the research methods used for this study. Important aspects include

selection of an appropriate research design, selection of a sample of study areas andvenues located there, visits to venues, interviews with managers and staff, on-site

observation, interviews with industry associations and welfare agencies, and

observation of the local press at each location. Each of these aspects is explained below.

3.2 Research Design

The research design was based on three main elements - implementation of the

voluntary Queensland Responsible Gambling Code of Practice (Queensland Treasury,2002), management and staff perceptions of the adequacy of this Code (2002b) and on-

site observation of its practices.

The implementation of the voluntary Queensland Responsible Gambling Code of

Practice (2002) was investigated using a tick box questionnaire instrument developed

from the Code. Each of the forty-eight elements comprising the six major categories ofthe Code (provision of information; interaction with customers and community;

exclusion provisions; physical environments; financial transactions; and advertising andpromotions) was included in the questionnaire. Managers and staff in charge of gaming

were asked if each element of the Code had been implemented or not. Their answers

were entered onto the tick box sheet by the researchers. In the ensuing interview,matters discussed were the responsible gambling practices implemented and those not

implemented by the venue, reasons for any problems with implementation, and anyother consumer protection and harm minimisation practices they used.

Perceptions of the adequacy of the Queensland Responsible Gambling Code of Practice

were investigated using these same semi-structured interviews. The interviewinstrument (also incorporating a five point Likert scale) was based on responsible

gambling practices highlighted in the Code. Using the Likert scale, managers and staffwere asked for their views on the adequacy of the Code.

37

Additionally, gambling industry associations, key industry people, government and

welfare agencies were asked their perceptions of the adequacy of the Queensland

Responsible Gambling Code of Practice, using qualitative, semi-structured interviews.

With agreement from interviewees, notes were taken during the interview and fullytranscribed later that day.

To identify the obvious consumer protection and harm minimisation practices already

implemented under the six major categories of the Code, a site visit was undertaken. Atour of the venue with managers or staff identified the ‘visible’ consumer protection and

harm minimisation measures accessible to gamblers (e.g. provision of information andsignage; physical environment and layout). These were noted by the researchers. When

available in each location, local newspapers, venue newsletters and a variety of venue

print materials were examined to ascertain the style of advertisements, messages orthemes highlighted and space allocation for different venue products.

3.3 The Sample

There are 11 statistical divisions in Queensland, but due to budgetary and timeconstraints, gambling operators in only three divisions were included in the sample.

Three divisions were chosen to provide a cross-section of regional views (from outback,far north Queensland and the heavily populated south-east Queensland regions)

regarding the implementation and perceived adequacy of the Queensland Responsible

Gambling Code of Practice. The Central outback was represented by Longreach, farnorth Queensland was represented by Townsville and south-east Queensland was

represented by the Gold Coast.

Six hotels, six licensed clubs and one casino were needed in each location for an

appropriate research sample to ensure an adequate cross-section of gambling industry

views. However Longreach had no casino and only five venues with gambling facilities,so all of these were included.

To ensure an appropriate cross-section of views from venues of different size, venues

with large gaming installations and those with small gaming installations were needed

in the sample. For this study, venues having 25 gaming machines or less were classified

as ‘small’ venues, while venues with more than 25 gaming machines were classified as

‘large’ venues. Keno and TAB facilities were also available in most of the selected

38

venues. Thus, in each of the three regions, of the six hotels selected, three had large

gaming facilities and three had small gaming facilities. Of the six licensed clubs

selected, three had large gaming facilities and three had small gaming facilities. The

casinos all had large gaming facilities. All five venues in Longreach had small gaming

facilities.

With assistance of the Inspectorate Division of the QOGR, a list was produced of

licensed venues (clubs, hotels and casinos) and their gambling facilities for Longreach,Townsville and south-east Queensland. With further help from Clubs QLD and the

QHA, venues belonging to these industry associations were selected from this list as

examples of best practice in implementing the voluntary Code. These venues wereincluded to provide a benchmark of best practice for comparison with other venues.

From this list, every second venue was asked to participate in the research, dependingon the size of its gaming installation. The exception was Longreach where every venue

was asked to take part.

In total, thirty-nine venues were asked to participate and thirty venues agreed. Of thenine venues which declined to be interviewed all had small gaming facilities, two of

which were hotels and seven were licensed clubs. Reasons given for non-participation

were: lack of time or too busy, the venue was understaffed, the venue was too small tobe a typical representative, and if participation was not compulsory, then they were not

interested. In Longreach, one venue did not answer the phone and was closed during theweek of the research. In Townsville, two venue managers who had previously agreed to

participate declined on the day. In south-east Queensland, six venue managers declined

at the first phone contact.

3.4 Data Collection

In Longreach, four venues agreed to participate in the project. These included threehotels and one club, all with small gaming facilities including gaming machines, TAB

and keno. Seven interviews were conducted on-site with the owners, managers and staff

in these four venues, from 29 October to 1 November 2002.

In Townsville, twelve venues consented participate. Data were collected from 28

January to 31 January 2003. These twelve venues comprised one casino with a largegaming facility (tables, gaming machines, TAB, keno), seven hotels (four large and

39

three small), four licensed clubs (three large and one small) and one welfare agency. All

twelve venues (100%) had gaming machines, ten (83%) had keno facilities (100%) andnine (75%) had TAB facilities. In each venue, the owner, manager and/or gaming

manager were interviewed on-site. In the large venues, a selection of gaming staff wasalso interviewed. In total, twenty-two interviews were conducted on-site with people

managing or operating gaming in these twelve venues.

In south-east Queensland, fourteen venues agreed to participate in the research,conducted during March and April 2003. These fourteen venues comprised one casino

with a large gaming facility (tables, gaming machines, TAB, keno), seven hotels (threelarge and four small) and six licensed clubs (three large and three small). All fourteen

venues (100%) had gaming machines, all had keno facilities (100%) and ten (71%) had

TAB facilities. In each venue, the owner, manager or gaming manager was interviewed.In the large venues a selection of gaming staff was also interviewed on-site. In total,

twenty-one interviews were conducted with people managing or operating gaming in

these fourteen venues. Thus in the thirty venues visited, fifty interviews were conducted

with owners, managers and staff in gaming venues. Table 3.1 summarises key

characteristics of the thirty participating venues.

40

Table 3-1 Key Characteristics of Participating Venues

No. Size Gaming

1 Small Hotel 20 GM

2 Small Club 22 GM, TAB, Keno

3 Small Hotel 10 GM

4 Small Hotel 12 GM

5 Small Club 14 GM, Keno


7 Large Hotel 35 GM, 2 Keno, 3 TAB

8 Casino 1348 GM, 2 Keno, TAB, Table games

9 Large Club 203 GM, 2 Keno, TAB

10 Large Hotel 40 GM, Keno, TAB

11 Large Club 280 GM, Keno TAB

12 Small Hotel 20 GM, Keno, TAB



15 Large Club 125 GM, 2 Keno, TAB




19 Small Hotel 14 GM

20 Large Hotel 35 GM, Keno

21 Large Club 146 GM, Keno, TAB



24 Small Hotel 18 GM, TAB

25 Large Club 30 GM


27 Casino 240 GM, Keno, TAB, Table games




41

A copy of the data collection instrument used by the researchers for these interviews is

found in appendix C.

Additionally, gambling industry associations, key industry people, government and

welfare agencies were able to provide valuable background information on theQueensland Responsible Gambling Code of Practice, particularly how they had assisted

with its development and implementation. The welfare agencies explained how their

local regional venues were coping with the Code, how they were dealing with some ofthe ramifications of implementing it and some long-term strategies they were

developing as a consequence of implementing the Code. Two welfare counsellors, twoindustry associations and several state government personnel were interviewed to gather

this information.

3.5 Data Analysis

For the numerical data and Likert scale responses, descriptive statistics were used to

distinguish numerical differences and percentages between venues implementing or not

implementing various parts of the Code. For the interview or qualitative data, opencoding was used by breaking down, examining and comparing data to find emerging

themes. The analysis then pulled together emerging themes into meaningful corecategories of results.

3.6 Limitations of the Methodology

ß This project relied on the voluntary participation of the venues. Therefore, itwas not possible to evaluate the extent to which non-participating venues had

implemented the Code. It would be expected that implementation of the Codein less cooperative venues might reveal additional and different issues not

uncovered in this project.

ß This project is indicative of trends and issues emerging from the first stages ofthe implementation of the Code. Research in similar areas (e.g. responsible

service of alcohol, road safety programs) suggests that further research andevaluation over a longer timeframe would be appropriate. It takes many

months, sometimes years, for such policies to be developed, understood,

accepted and implemented. At the time of the research (Nov 2002 - April

42

2003), it became apparent that there had not been adequate time for the

implementation strategies to take full effect, even though the Code had beenlaunched in May 2002.

ß The research conducted only involved a process evaluation of the Code (seeSection Two) and did not examine the impacts or outcomes of the Code.

3.7 Conclusion

This section, Section Three, has detailed key aspects of this study’s methodology. Theseinclude the overall research design, the sample, data collection methods, analytical

techniques and methodological limitations. Section Four now presents the results fromthe first case study area, Longreach.

43

SECTION FOUR

4 THE LONGREACH CASE STUDY

4.1 Introduction

This section details findings from the research conducted in Longreach. Longreach is

situated approximately 1,200 kilometres north west of Brisbane with a population ofabout 4,000 people. While a number of tourists pass through, the economy is mostly

dependent on cattle and sheep. Longreach has three hotels and two clubs with gaming

facilities. The research team visited three hotels and one club for interviews. The otherclub was closed for the entire week that the research team was collecting data in

Longreach. All venues visited offered gambling, including gaming machines, TAB and

keno.

The ensuing discussion presents the results of this research, first on the interviewees’

general awareness of the Code and then on their opinions of its likely effectiveness. Ananalysis of the respondents’ perception of the adequacy of the Code will follow, along

with identification of perceived facilitators and impediments in implementing the Code.

Open-ended comments will then be highlighted, followed by a closing summary.

4.2 Awareness of the Code in Longreach

The managers from all four venues visited in Longreach were only vaguely cognisant ofthe Queensland Responsible Gambling Code of Practice. The Code had been delivered

to two of the hotels, but one hotel and the club reported they had not received a copy.

An inspector from the QOGR had installed signage on problem gambling in all venues.

Only one hotel licensee had possession of the Resource Manual that accompanies the

Code, but this licensee did not realise the manual was on the premises until theinterview with the researchers when he remembered, ‘seeing something behind the bar‘.

The Resource Manual had in fact been sent to the owner/nominee of the hotel. It was

coincidental that the licensee had come across the document.

The manager from the registered club noted that Clubs QLD was running a workshop

on the Code in Winton, a town in close proximity to Longreach, two weeks after theinterview. After participating in the interview, it appeared that the manager gained an

44

understanding of the importance of the Code and indicated that he and his staff would

definitely be attending the workshop.

All Longreach venue managers felt there was an important need for training of

managers and staff. The managers felt that the remote location of Longreach resulted infew opportunities for attending training on all aspects of gaming management, not just

responsible gambling. The managers would like to have seen more training offered in

close proximity.

Another issue relating to staff training in Longreach, according to venue managers, was

the high level of staff turnover. Generally, it was difficult to retain staff. All managersindicated they had a very high staff turnover and that training staff was almost a waste

of time because other employers would capture the value of that training. The high

turnover also meant that training opportunities would have to be offered frequently toensure all new staff were familiar with the Code.

In summary, it was clear that most managers and staff were not familiar with the Code

of Practice. However, they were very clear on the legal responsibilities relating toresponsible gambling that are reiterated in the Code. Overall, their acceptance of the

Code can be described according to the following four levels:

ß Committed to the Code and proactive (no venues)

ß Aware of, and compliant with, the Code (one venue)

ß Vaguely aware of the Code and its contents (one venue)

ß Unaware of the Code and generally only implementing its legislated element (two

venues).

4.3 Implementation of the Code in Longreach

Using a questionnaire based on the six major categories of the Queensland Responsible

Gambling Code of Practice, venue managers and staff were asked to identify those

parts of the Code they were implementing and those they were not. Table 4.1 shows

details of the implementation of the Code in Longreach for each venue and for each of

the six practice areas of the Code. The following sections on implementation relate to

these six practice areas, as previously described in detail in Table 2.1.

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Table 4-1 Implementation of the Code’s Elements in the Longreach Venues

CODE OF PRACTICE ELEMENTS SMALL HOTELSSMALL

CLUB

1. Provision of Information 1 3 4 2

Displays responsible gambling mission statement Y N N N

Displays help information in all gaming areas Y Y Y Y

Displays help information near EFTPOS/ATMs servicing gamblingareas

Y Y Y Y

Displays help information in toilets Y Y Y Y

Displays information on the responsible gaming policy document N Y N N

Displays information on the rules of play and odds of winning N N N N

Displays information on exclusion provisions N N N N

Displays information on gambling related complaints resolution N N N N

Displays information on financial transactions practices N Y N Y

Displays odds of winning a major prize N N N N

2. Interaction with Customers and Community 1 3 4 2

Establish links with support services N N Y N

Establish links with community N N Y N

Customer liaison provides information to customers N N N N

Support staff in providing assistance to customers N N N N

Provide assistance to staff with gambling related problems N N N N

Customer complaints system established and promoted N N N N

Ensure responsible gambling training is provided to relevant staff N Y N N

Owners, boards, managers receive appropriate information to guidedecision making

Y Y N N

3. Exclusion Provisions 1 3 4 2

Provide self-exclusion procedures and documentation N Y Y N

46

Offers self-exclusion contact information for appropriate counsellingagencies

N N Y N

Self-excluded customers supported in seeking mutual exclusionfrom other gambling providers

N N N N

Does not send correspondence or promotional material to excludedcustomers

NA NA NA NA

4. Physical Environment 1 3 4 2

Minors Prohibited from gambling Y Y Y Y

Minors excluded from area where adults gambling Y Y Y Y

Alcohol service encourage customers to take breaks in play Y Y Y Y

Intoxicated customers not permitted to continue gambling N Y Y N

Childcare facilities meet legislated standards NA NA NA NA

Staff in gambling areas not to encourage tips Y Y Y Y

Customers made aware of the passage of time N N Y Y

Customers discouraged from extended, intensive & repetitive play Y Y Y Y

5. Financial Transactions 1 3 4 2

ATM Facilities not located close to gambling areas Y Y Y Y

Est. limit above which all winnings are paid by cheque or EFT $250 $250 $250 $250

Gambling winnings above a set limit are paid by cheque and notcashed at venue until next day

Y Y Y Y

Prohibits cashing cheques not made payable to the venue Y Y Y Y

Prohibits cashing cheques not payable to the person presenting thecheque

N N N N

Prohibits cashing multiple cheques N N N N

Does not provide credit or lend money for gambling Y Y Y Y

6. Advertising and Promotions 1 3 4 2

Complies with advertising code of ethics by AANA NA NA NA NA

Is not false, misleading or deceptive NA NA NA NA

Does not misrepresent the probability of winning a prize NA NA NA NA

47

Does not give the impression that gambling is a responsiblestrategy for betterment

NA NA NA NA

Does not include misleading statements about odds, prizes, orchances of winning

NA NA NA NA

Does not offend prevailing community standards NA NA NA NA

Does not focus exclusively on gambling NA NA NA NA

Is not implicitly or explicitly directed at minors or vulnerable ordisadvantaged groups

NA NA NA NA

Does not involve any external signs advising of winnings paid NA NA NA NA

Does not involve any irresponsible trading practices by thegambling provider

NA NA NA NA

Does not depict or promote alcohol consumption with gambling NA NA NA NA

Obtains consent prior to publishing the ID of any person who wins aprize

NA NA NA NA

Y - YES N - NO NA – NOT APPLICABLE

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4.4 Implementation: Provision of Information

All venues displayed some of the relevant problem gambling signage because a QOGR

inspector had been to all venues to install them. However, only one venue displayed a

responsible gambling mission statement, and there was signage in only one venue on

their responsible gambling policy. No information on the nature of games; game rules

and odds or returns; self-exclusion provisions, complaints resolution mechanisms or the

odds of winning a major prize were displayed in any venue. The only area where most

venue managers had a grasp on the provision of information policy was regarding

certain aspects of financial transactions because, although these are included in the

voluntary Code, they are also legislative requirements. Despite this, only two of the four

venues displayed financial transactions information.

4.5 Implementation: Interaction with Customers and Community

It would not be unreasonable to expect strong community liaison and networks to existin a small rural community like Longreach; however this was not the case for gambling

support services. Only one venue manager had liased with a local problem gamblingsupport service provider and this relationship had been developed in the first instance

for a person with an alcohol problem. The other three managers did not know of the

existence of any local support providers, let alone liaise with them. No communityconsultative groups had been established for gambling in Longreach.

In all venues, the manager fulfilled the role of customer liaison contact. Being an

outback location with a small population, managers said that they or their staffpersonally knew most customers. They felt that, in the case of potential problem

gambling, they would be comfortable in quietly suggesting to a customer that it wastime to go home, to have a meal or to collect children from school, in order to

encourage that person to take a break. This personal concern for members of the

community was seen to be a part of everyday life in a remote location.

There were no formal mechanisms in place for resolving customer complaints, although

all venue managers were confident that their customers knew how to make a complaint.The managers suggested that customers would approach them directly or, if the

49

complaints were made to staff, then the staff member would bring the complaint to the

manager.

One venue reported that responsible gambling training was provided to relevant staff.

As stated previously, the club manager indicated that he was hoping he and his staffcould attend a Clubs QLD training course soon.

4.6 Implementation: Exclusion Provisions

None of the venues had a self-exclusion policy or any supporting documents, althoughall managers said they were willing to put such procedures in place. One manager had

previously been approached by a person wanting to be excluded from the venue and theexclusion was informally undertaken. However the venue manager was not certain that

this person had not gone to other venues in the town during the exclusion.

As noted previously, only one manager had developed any relationship with counsellingagencies in Longreach so it was not surprising that this was the only person who

suggested he could provide customers seeking self-exclusion with any information on

local support services. The other venue managers indicated they would give customersthe phone numbers provided on the signage displayed in the venues. However, these

were Brisbane numbers and the managers and staff suggested it was unlikely thatpeople in Longreach would feel comfortable about ringing a service in Brisbane.

Managers and staff were sympathetic to the plight of problem gamblers and their

families. On an informal basis, managers reported they would call in help from the localpastor, church or Salvation Army to assist a customer they felt was experiencing

problems with their gambling.

All managers were happy to support customers seeking consensual exclusions from

other gambling providers, although it did not appear that the managers had a great deal

of contact with each other. Additionally, none of the venues had customer mailing listsso had no policy about removing self-excluded customers from any lists.

However, while all managers were willing to implement self-exclusion procedures, theyall suggested that self-exclusion would not be successful because a self-excluded person

‘could walk down the road’ to another venue.

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4.7 Implementation: Physical Environments

Prohibiting minors from gambling and gambling areas, although included in thevoluntary Code, is also a legislative requirement. All managers and staff interviewed in

Longreach were aware of this obligation; however there was a degree of flexibility inapplying this. For example, two venue managers reported finding a person leaving a

child unattended while playing gaming machines. Both had taken steps to warn or

exclude this person. One manager, taking a formal approach, was sending the person aletter warning them not to continue this practice. The other manager took an informal

approach and asked the person to leave when they appeared with the child and started togamble. Managers and staff were concerned for the welfare of this pair.

All venue managers stated they discouraged extended hours of gaming machine play by

not offering alcohol service in gambling areas. In addition, gamblers had to leave thegaming room to use the toilets, the ATM and EFTPOS facilities.

The venue managers were also aware of their obligations to prevent intoxicated people

from gambling; but again there was flexibility in implementation. Two venue managersstated they excluded intoxicated people from playing gaming machines; however

another two managers stated they would only stop intoxicated people from playingmachines if they were causing inconvenience to other patrons. In saying this, most

venues had video cameras and staff were continually monitoring the gaming, bar and

food service areas. They were able to observe gaming activities in the venue at anytime.

None of the venues provided childcare facilities and so this section of the Code was notrelevant to those interviewed. All managers stated that staff are asked not to encourage

customers to give them gratuities. Nevertheless, managers suggested they could not be

certain this does not happen. Only one venue had a clock in the gambling room andthree venues had windows in their gambling areas. Two of these venues had their

windows covered to avoid outside observation of gaming rooms - a legislativerequirement. The gambling areas in all four venues had, to varying degrees, natural

light filtering through. The irony of this measure is that whilst natural light allows

people to keep track of time, covering windows to prevent outside observation ofgaming areas is a legislative requirement.

51

4.8 Implementation: Financial Transactions

Two venues had ATMs and two had EFTPOS, but none were located in the gamblingareas. Payment of winnings over $250 by cheque or electronic transfer, while being a

measure in the Code, is also a legislative requirement for clubs and hotels. All venuemanagers and staff were aware of this obligation.

All venue managers stated that they cashed third party cheques and two stated they

cashed personal cheques. One venue only cashed cheques for known locals. Themanagers stated that it was possible that multiple cheques were cashed because of

different staff working on different shifts. None of the venues provided credit forgambling purposes.

4.9 Implementation: Advertising

All venues reported that they did not advertise, and as such indicated that the provisions

of this section of the code were not applicable. However, the researchers noted that

three of the four venues had signs at the front of their buildings noting the gambling

facilities offered, while the other listed its gambling facilities in a venue brochure

available at the visitor information centre. Further questioning led to all the venue

managers stated that their signs would comply with the Advertising Code of Ethics as

adopted by the Australian Association of National Advertisers. They indicated that their

advertising was not false, misleading or deceptive, did not focus exclusively on

gambling, and did not target minors, the vulnerable or disadvantaged. None of the

venues used advertising depicting or promoting the consumption of alcohol while

gambling. Finally, all managers indicated they would gain the consent of people before

publicising their name as prize-winners and there was no evidence of any gaming

machine promotions. As noted above, the researchers relied on the self-assessment of

the interviewees of whether their advertising and promotions adhered to the Code. The

research team did not conduct any rigorous independent evaluation of the venues’

advertising and promotions practices.

4.10 Perceived Adequacy of the Code in Longreach

Venue managers and staff were asked their opinions of the adequacy or potential

effectiveness of various aspects of the Code. There appeared a high degree of

52

agreement between all venue managers and staff that generally many of the strategies

would not be very successful, as discussed below for each practice area in the Code.Table 4.2 shows their responses about their perceived adequacy of the Code in

Longreach.

Table 4-2 Perceived Adequacy of the Code’s Practice Areas for Longreach

SMALL HOTELS SMALL

CLUBCODE OF PRACTICE AREAS

1 3 4 2

Provision of adequate information & signage

encourages responsible gamblingD DK D D

Support services are adequate to assist

customers and the community who need

help

A D A D

Exclusion really encourages responsible

gamblingDK DK D D

Physical layout & environment encourages

responsible gamblingDK A A A

Rules & limits on financial transactions

encourage responsible gamblingDK A DK A

Advertising and promotions help promote

responsible gamblingA A A D

A - AGREE D - DISAGREE DK – DON’T KNOW

4.11 Adequacy: Provision of Information

In three of the four venues, managers and staff thought that signage would have little

impact on encouraging responsible gambling. It was felt that ‘people will only take

notice of what they want to’ and that most gamblers would ignore the messages unless

they became desperate. One person believed that too much signage could actuallybecome confusing and therefore ineffective. Only one person in one venue could not

decide their stance on this.

4.12 Adequacy: Interaction with Customers and Community

Two venue managers reported that provision of support services for problem gambling

would be beneficial and two disagreed. Mostly, they felt these community support

53

services should be provided locally. It was the belief of all venue managers and staff

that people in Longreach would only be comfortable with local services. They wereunlikely to ring the Brisbane numbers provided on the signage about problem gambling

supplied by the QOGR.

4.13 Adequacy: Exclusion Provisions

Two venue managers stated that self-exclusion of problem gamblers was unlikely to be

a successful strategy, while two did not know. The first two managers believed thatself-exclusion was only a short-term strategy and that once problem gamblers had built

up sufficient funds they would start gambling again. The other two managers felt thatself-excluded gamblers could ‘go down the road’ to another venue and gamble.

Therefore self-exclusion was seen as having limited effectiveness.

4.14 Adequacy: Physical Environments

Three venue managers believed that encouraging people to take a break from gambling

would help to minimise problem gambling. One maintained that making a gambler get

cash in front of other people would reduce gambling on gaming machines because, inLongreach, there was a certain level of stigma associated with people playing gaming

machines. It was then suggested this was not the case for all gambling as, historically,Longreach has a long cultural association with horses, such that wagering on horses was

culturally more acceptable than using gaming machines. The provision of clocks and

natural light was also seen as an important measure in assisting responsible gambling.One manager did not have an opinion on whether physical environments for gambling

have any impact on responsible gambling.

4.15 Adequacy: Financial Transactions

Two managers stated they ‘didn’t know’ whether the Code’s rules and limits on

financial transactions were adequate or potentially effective in encouraging responsiblegambling. In contrast, the other two managers felt these rules and limits were

appropriate since the limits on cash payments of prizes gave winners a chance to cooldown after big wins.

54

4.16 Adequacy: Advertising

This area drew different responses. Three managers believed that certain approaches toadvertising and promotions could help to promote responsible gambling. One manager

felt that this practice would have little impact on encouraging responsible gambling.

4.17 Facilitators and Impediments for the Code in Longreach

Managers and staff were asked for their opinions on any facilitators and barriers for the

widespread implementation of the Queensland Responsible Gambling Code of Practice

in Longreach and its potential effectiveness in encouraging responsible gambling.

4.18 Facilitators

Respondents articulated the following factors which they consider might facilitate the

effectiveness of the Code in Longreach:

ß Managers and staff showed genuine concern for their customers and felt that theywould be able to facilitate their own support mechanisms if and when needed.

ß Because of the certain stigma attached to playing gaming machines in Longreach

and the difficulty of maintaining privacy in a small community, the physicalenvironment of gaming rooms can assist responsible gambling. This is because, if

this practice area is adhered to, gaming machine players have to take breaks in playto access change, food and drink in front of other venue customers and staff. They

usually know these people. This may deter them from prolonged play, repeated use

of EFTPOS and ATMs, and numerous requests for change from the bar.

4.19 Impediments

Respondents articulated the following factors they consider have impeded the potentialeffectiveness of the Code in Longreach:

ß Not all managers and staff interviewed in Longreach had received a copy of the

Code and Resource Manual.

55

ß Personnel in the Longreach venues had limited access to training and skills

development for responsible gambling.

ß The lack of training opportunities was exacerbated by the high turnover of staff in

the venues.

ß The lack of gambling support services and community networks in this remote

location meant that people seeking help only had access to the Brisbane-based

Gambling Helpline, which could deter people from calling it.

4.20 Summary

This final part of Section Four summarises the findings from the Longreach research interms of awareness and implementation and perceived adequacy of the Code.

4.21 Awareness and Implementation

It is apparent that, in Longreach, the Queensland Responsible Gambling Code of

Practice had not been fully implemented at the time of the study because the venue

managers were not fully cognisant of its existence, details and requirements, except for

the legal obligations contained therein. The managers and staff felt that more trainingand education, in all areas, not just in responsible gambling, should be available for

people in remote regions of Queensland, with one commenting that venues in remoteareas ‘get ignored unless something goes wrong’. In addition, the managers felt there

was a need for training of managers in general gaming operations. They also thought it

should be more difficult for someone to gain a gambling licence, since currently theonly requirement is a criminal and probity check.

Another issue with the Code for managers and staff in Longreach is that there has beena long history of cashing third party cheques. Pubs and clubs in remote regions often

operate as de facto banks and the significance of this has probably grown with the

reduction of bank services in rural towns. Given the isolation of many local residentsand the long distances travelled to get into town, third party cheque cashing is likely to

continue.

Another concern to arise from the research is that, even though the Code is voluntary,

certain aspects within it are legislative requirements. While all gambling providers

56

interviewed in Longreach were fully aware of these legislative requirements, there is a

possibility of misunderstandings arising between legislative and voluntary practices.

4.22 Adequacy

Finally, all managers and staff were generally sceptical about the likely effectiveness ofthe Code in encouraging responsible gambling. Some aspects of the Code were seen as

worth persevering with, such as the practices relating to physical environments, but

others, such as self-exclusion and the provision of information were considered a wasteof time. This less than enthusiastic view of responsible gambling practices could be

because managers and staff were not fully cognisant of the Code and its elements.Clearly there is an increased need for more education and training in Longreach in order

to familiarise venue personnel with the Code and hopefully encourage more positive

views about its likely outcomes.

57

SECTION FIVE

5 THE TOWNSVILLE CASE STUDY

5.1 Introduction

The City of Townsville, located some 1,400 kilometres north of Brisbane, is widelyregarded as the ‘capital’ of north Queensland. It provides the northern link for state and

federal governments, as well as for private enterprise in primary and secondary

industries, mining, commerce, retail and community and cultural services. Because ofits location, Townsville is the provincial city for the Northern Statistical Division which

is 100,951 square kilometres in area. In addition to the Cities of Townsville andThuringowa, it includes five other Local Government Authorities. Townsville’s

population is approximately 135,000 people, with the proportion of Aboriginal and

Torres Strait Islanders higher (4.5%) than for Queensland (2.8%) and Australia as awhole (2.0%). Townsville’s employment rate is approximately 90.6%, reflecting its

rapid economic development since the 1950s. Key employers are the copper and nickelprocessing plants, the defence forces, port activities, tourism and hospitality,

educational institutions, and Commonwealth and state government offices

(http://www.townsville.qld.gov.au).

The Townsville sample comprised twelve venues – the one casino, four large hotels,

three small hotels, three large clubs and one small club. All twelve venues (100%) hadgaming machines, ten (83%) had keno facilities and nine (75%) had TAB facilities. In

each venue, the owner, manager or gaming manager was interviewed. In the large

venues, a selection of gaming staff was also interviewed. In total, twenty-fourinterviews were conducted, twenty-two of which were with people managing gaming

venues and two with counsellors at a welfare agency. Another two clubs (with smallgaming facilities) which had initially agreed to an interview declined on the day.

The ensuing discussion presents the results of this research, first on the interviewees’

general awareness of the Code and then on their opinions of its likely effectiveness. Ananalysis of the respondents’ perception of the adequacy of the Code will follow, along

with identification of perceived facilitators and impediments in implementing the Code.

Open-ended comments will then be highlighted, followed by a closing summary.

58

5.2 Awareness of the Code in Townsville

Most managers from the twelve venues visited in Townsville were aware of theQueensland Responsible Gambling Code of Practice. The Code had been delivered to

ten (83%) venues. Two venue managers reported that they had not received a copy ofthe Code. These venues were owned by the same large hotel group, and the managers

assumed that a copy had been sent to their group head office. Of the twelve venues

visited, ten (83%) had possession of the Resource Manual that accompanies the Code.Again, the two members of the hotel chain assumed their head office had received a

copy but not forwarded it to them. A QOGR inspector or authorised agent had installedsignage on problem gambling in all twelve venues.

While the two managers with no access to either the Code or the Resource Manual were

vaguely aware of the Code, two other managers who had received these materials werenot aware of their contents. One reported that the Code and Resource Manual were

‘somewhere in the office’. The other said that, while he remembered seeing it arrive,

‘people don’t read those things’. In fact, the secretary at this venue is supposed to readall relevant material and keep the manager informed.

Thus, eight managers of the twelve venues visited (67%) were aware of the existenceand contents of the Queensland Responsible Gambling Code of Practice and the

Resource Manual. Of these eight managers, five (40%) had informally met with a local

welfare agency, Centacare, and formed a consultative group to discuss and reviewresponsible gambling practices in their venues and in the Townsville region generally.

This group of five included two clubs, two hotels and the casino, all with large gaminginstallations. They had two meetings in October and November 2002 and, after

participating in the interviews with the researchers, it appeared another meeting was to

be organised for 2003. At these meetings, this group of five (40%) had primarilydiscussed three issues: a common responsible gambling advertising campaign for the

Townsville region, a method to get all venues to participate in regionally based self-exclusions, and training for gaming staff. The two counsellors interviewed from

Centacare reported they were indeed working with this informal group of five and

hoped to follow this up with further action in 2003.

The first issue discussed by this informal group was a proposal for a common

responsible gambling advertising campaign. This could focus on firstly educating and

59

informing people about the merits of responsible gambling, particularly for families,

and secondly on sending the message that gambling is an entertaining leisure activitywhen people spend what they can afford. Several managers suggested TV and radio

advertising would be best, but one person maintained that a ‘traveling road show withsome sizzle’ would work. This person said that Toohey’s Brewery had had a road show

traveling around Queensland promoting its product and training bar staff in quality

service procedures. He believed it was a very popular and effective way of gettingToohey’s message to the public and hospitality staff, so a similar approach could be

tried for promoting responsible gambling.

The second issue was self-exclusion. These same five managers wanted to explore the

possibility of establishing a mechanism whereby self-excluded people could ban

themselves from all venues in the Townsville region, without breaching privacylegislation. The group felt that a welfare agency such as Centacare could establish and

operate mutual self-exclusions on behalf of all venues in the region. The managers

proposed that, with the person’s permission, they could advise Centacare of any self-exclusions so that Centacare could provide venues with a regional list of excluded

persons and then provide the excluded person with counselling and support. While thisproposal was hypothetical, these managers were genuinely looking for solutions to

prevent self-excluded people going to other less scrupulous venues where self-exclusion

was not treated seriously.

Management and staff training and education in responsible gambling was the third

important issue for this group of five venue managers. They felt that institutions such aslocal TAFE colleges or local welfare agencies, as well as industry associations, could

provide training. This would mean less reliance on Brisbane-based organisations

travelling to regional areas to provide suitable training and education courses. As well,when sufficient demand was present, local organisations could go to a venue to provide

short refresher courses to update staff on current trends in responsible gambling. Themanagers felt Community Development Funds could be used for this as these funds are

collected from gambling venues by the state government for community use.

In summary, there appeared four levels of awareness of the Code amongst venuemanagers in Townsville:

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ß The highest level of awareness comprised five venue managers and staff (40%) who

were committed to, and involved with, progressing the Queensland Responsible

Gambling Code of Practice. These managers and staff were very familiar with the

Code and the Resource Manual and were actively working with the welfare agencyCentacare to extend responsible gambling practices and education in the Townsville

region.

ß The next level of awareness was displayed by three venues (25%) where managersand staff were aware of, and compliant with, the Code.

ß It was clear that, at the next level down, managers and staff in two venues (17%)had received but not read the Code or the Resource Manual and were only vaguely

aware of their contents.

ß At the lowest level of awareness, managers in two venues (17%) had not receivedthe Code or the Resource Manual. This group was only aware of, and compliant

with, their legal responsibilities.

5.3 Implementation of the Code in Townsville

Using a questionnaire based on the six major categories of the Queensland Responsible

Gambling Code of Practice, venue managers and staff were asked to identify thoseparts of the Code they were implementing and those they were not. Table 5.1 shows

whether the various elements of the Code had been implemented in the Townsville

venues visited. The ensuing sections discuss the implementation details for each of theCode’s six practice areas.

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Table 5-1 Implementation of the Code’s Elements in the Townsville Venues

CODE OF PRACTICEELEMENTS

SMALLHOTELS

LARGE HOTELS LARGE CLUBS CA

1. Provision of Information 19 22 24 20 23 28 29 21 25 26 30 27

Displays responsible gamblingmission statement

Y N N N N Y Y N Y N Y Y

Displays help information in allgaming areas

Y Y Y Y Y Y Y Y Y Y Y Y

Displays help information nearEFTPOS/ATMs servicinggambling areas

Y Y N Y N Y Y Y Y Y Y Y

Displays help information in toilets Y Y Y Y Y Y Y Y Y Y Y Y

Displays information on theresponsible gaming policydocument

N N N Y N Y Y N Y N Y Y

Displays information on the rulesof play and odds of winning

N N N Y N Y Y N Y Y Y Y

Displays information on exclusionprovisions

N N N N N Y Y N Y Y Y N

Displays information on gamblingrelated complaints resolution

N N N N N Y Y N Y Y Y Y

Displays information on financialtransactions practices

Y N N Y Y Y Y Y Y Y Y Y

Displays odds of winning a majorprize

N N N N N N N N N Y N N

2. Interaction with Customers andCommunity

19 22 24 20 23 28 29 21 25 26 30 27

Establish links with supportservices

N N N Y N Y Y N N Y Y Y

Establish links with community N N N Y N Y Y Y N Y Y Y

Customer liaison providesinformation to customers

Y N N Y N Y Y Y Y Y Y Y

Support staff in providingassistance to customers


Provide assistance to staff withgambling related problems


Customer complaints systemestablished and promoted

N N N Y Y Y Y Y Y Y Y Y

Ensure responsible gamblingtraining is provided to relevantstaff


Owners, boards, managersreceive appropriate information toguide decision making


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3. Exclusion Provisions 19 22 24 20 23 28 29 21 25 26 30 27

Provide self-exclusion proceduresand documentation

N N N Y N Y Y Y Y Y Y Y

Offers self-exclusion contactinformation for appropriatecounselling agencies

Y Y N Y N Y Y Y Y Y Y Y

Self-excluded customerssupported in seeking mutualexclusion from other gamblingproviders

Y N N Y N Y N N N Y Y Y

Does not send correspondence orpromotional material to excludedcustomers

Y NA NA Y NA Y Y N NA Y Y Y

4. Physical Environment 19 22 24 20 23 28 29 21 25 26 30 27

Minors Prohibited from gambling Y Y Y Y Y Y Y Y Y Y Y Y

Minors excluded from area whereadults gambling


Alcohol service encouragecustomers to take breaks in play

N N Y N N N N N Y N Y Y

Intoxicated customers notpermitted to continue gambling


Childcare facilities meet legislatedstandards

NA NA NA NA NA Y NA NA NA Y NA NA

Staff in gambling areas not toencourage tips

Y Y Y N Y Y Y Y Y Y Y Y

Customers made aware of thepassage of time

Y Y N N Y N Y N Y N Y Y

Customers discouraged fromextended, intensive & repetitiveplay

Y Y N Y N N N Y Y N Y Y

5. Financial Transactions 19 22 24 20 23 28 29 21 25 26 30 27

ATM Facilities not located close togambling areas

Y Y Y Y N Y Y Y Y Y Y Y

Est. limit above which all winningsare paid by cheque or EFT $2

50

$300

$1,0

00

$1,0

00

$1,0

00

$1,0

00

$500

$3,0

00

$250

$1,0

00

$300

$10,

000

Gambling winnings above a setlimit are paid by cheque and notcashed at venue until next day


Prohibits cashing cheques notmade payable to the venue

Y N N N Y N N Y N N N N

Prohibits cashing cheques notpayable to the person presentingthe cheque

Y N N Y Y Y Y Y Y Y Y Y

Prohibits cashing multiplecheques

Y N Y Y Y N Y Y Y Y Y Y

Does not provide credit or lendmoney for gambling


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6. Advertising and Promotions 19 22 24 20 23 28 29 21 25 26 30 27

Complies with advertising code ofethics by AANA

NA NA NA Y NA Y Y Y Y Y Y Y

Is not false, misleading ordeceptive


Does not misrepresent theprobability of winning a prize


Does not give the impression thatgambling is a responsible strategyfor betterment


Does not include misleadingstatements about odds, prizes, orchances of winning


Does not offend prevailingcommunity standards


Does not focus exclusively ongambling


Is not implicitly or explicitlydirected at minors or vulnerable ordisadvantaged groups


Does not involve any externalsigns advising of winnings paid


Does not involve any irresponsibletrading practices by the gamblingprovider


Does not depict or promotealcohol consumption withgambling


Obtains consent prior topublishing the ID of any personwho wins a prize


Y - YES N – NO NA – NOT APPLICABLE

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Problem gambling signage was displayed in all twelve venues visited because aQOGR representative had installed them. Signs and business cards were placed near

ATM and EFTPOS facilities, in toilets, at cashiers’ desks, at reception, at the end ofrows of gaming machines, on walls in all gaming areas and some venues had a six-

foot freestanding sign.

Six of the twelve venues (50%) displayed a responsible gambling mission statement,plus a sign indicating a policy document was available. The responsible gambling

policy document was mostly available at reception, at the security desk or cashiers’booth in these six venues, but were also printed in venue brochures and newsletters.

Seven of the twelve venues (58%) had rules of play either printed in a player

information guide or available at reception or cashiers’ booth. However, explanationsof the odds of winning were much less evident. Only three venues (25%) had these

available for players. The stated reasons for this absence were that game combinations

were complex, the variety of denominations was broad, and explaining in print everycombination for every denomination was simply unrealistic. This went ‘above and

beyond what is required’ said one manager.

Information on self-exclusion policies was available at five venues (42%), either at

the security desk or cashiers’ booth. Information on resolving gambling complaints

resolution was on hand in six venues (50%). Six venues had security cameras, whichhelped provide evidence to settle complaints. Ten of the twelve venues (83%) had

information publicly displayed on their financial transactions policy, while only onevenue had the odds of winning a major prize displayed.

Analysing provision of information based on size of gaming installation, of the six

venues (50%) displaying a responsible gambling mission statement, five venues(42%) had large gaming installations while one (8%) had a small gaming installation.

Based on sector, three venues were hotels, two were clubs and one was a casino. Ofthe two venues (17%) that did not display their financial transactions policy, both

were hotels with small gaming installations.

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To conclude, apart from where the QOGR had installed signs, the only area where the

majority of venue managers and staff (83%) had a clear understanding of theprovision of information policy was in regards to financial transactions because,

although these are included in the voluntary Code, they are also legislativerequirements.

5.5 Implementation: Interaction with Customers and Community

Six of the twelve venues visited in Townsville (50%) had established effective linkswith gambling related services and community networks. Of the six, five venue

managers, all with large gaming installations, had formed an informal consultativegroup with the local Centacare welfare agency. The other venue, also with a large

gaming installation, had links with a different welfare agency. There was no other

local collaboration between venues on responsible gambling issues. Nevertheless,there was a real desire expressed by most managers that collaboration would be very

useful for managing self-exclusion.

In the customer liaison role, nine managers (75%) said they would provideinformation to customers on problem gambling support. A group of six staff members

said they would refer a request for problem gambling information up the chain ofcommand to the gaming manager or general manager. Staff commented that ‘it can be

frustrating to see people in need of help; they say they’re having problems – staff

can’t do much but refer them to supervisors’. The same nine managers (75%) reportedthey would support their staff in providing assistance to customers looking for

problem gambling support. These nine venues have a variety of ways to do this. Theyinclude holding staff meetings to share new information about responsible gambling;

having shift managers trained and ready to handle these customers; the owner or

manager being trained in this responsibility; and gaming staff being required to readthe Code and the Resource Manual then sign a register indicating they understand

their contents. Additionally, these nine managers (75%) stated they would support anyof their staff with gambling related problems. Within this group, the five who had

developed close links with Centacare said they would send their staff for counselling

at Centacare. The other four managers said that staff were not allowed to gamble and

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one actually discouraged staff from staying on the premises after their shift had

finished. One manager felt that ‘seeing gambling all day is often a deterrent’ for staff.

Customer complaints were handled usually by the shift or duty manager and then the

general manager or owner, moving up the organisation hierarchy depending on thenature of the complaint. Nine of the twelve managers (75%) said they had established

a complaints resolution mechanism, but only three of these (25%) had relevant

documents and policies in place. Nevertheless, all managers and staff interviewedwere confident that their customers knew how to make a complaint.

Staff training and skill development in responsible gambling had been undertaken inseven of the twelve venues (58%). Of these, three had completed training with Clubs

QLD, three with the QHA and one had a dedicated trainer on their human resources

staff who provided this training at induction. However, most venues reported that highstaff turnover is a problem in ensuring all staff are trained. Venue managers

emphasised the need for regular training for new employees and for refresher courses

for current staff from regional or local education providers. From a negativeviewpoint, one manager who had no staff trained in responsible gambling saw this

type of training as learning how to be a counsellor, rather than implementingresponsible gambling practices. Another said of the training that they ‘wouldn’t go if

they didn’t have to’. In a positive contrast, staff at one venue were being exposed to

counselling sessions to build empathy and understanding of people at risk in theirgambling behaviour. In this venue, management recognises that staff can get caught in

a ‘hospitality mindset that normalises heavy drinking and risky gambling’. In anothervenue, concerned staff alerted the gaming manager to a customer who was gambling

for long periods and possibly much more than s/he could afford. Using their local

knowledge, the staff knew this person worked at a local school canteen and would beunlikely to have a high income to sustain this level of gambling. The manager

checked this person’s expenditure discretely and the customer has not returned since.

The same seven managers (58%) who had supported staff training and skill

development in responsible gambling reported they had the support of their Boards,

owners and general managers in relation to their implementing responsible gamblingpractices.

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Analysing the Code’s practice area of interaction with customers and community

based on size and sector, three venues (25%), all hotels, reported that they would notbe in a position to assist customers by providing them with information on problem

gambling support. Two of these hotels were small, while one was large. Seven venuemanagers (58%) said their staff had undertaken training and skills development in

responsible gambling and that they had board or owners’ support for their responsible

gambling policies. This group comprised three hotels, three clubs and the casino, allwith large gaming installations.

Thus, while the majority of venue managers (75%) indicated they would supportcustomers by providing information on problem gambling help, only seven had the

means to do this effectively. That is, only six of the managers (50%) had formed links

with community support services and seven (58%) had provided staff training andskills development in the provision of responsible gambling. These same seven

venues all had large gaming installations.


When requested, self-exclusion procedures and supporting documentation would be

provided by eight of the twelve venues (67%) visited in Townsville. Managers andstaff from four venues (33%) reported they had had between two and four people self-

exclude in the past few years. Another manager said that the venue had informally

excluded one person on a partner’s request. Other venues noted they had never had arequest for self-exclusion, but were sympathetic and would oblige. Another manager

could not see how self-exclusion would ‘be effective’, implying that he could not becertain the person did not go to other venues during the exclusion. Yet in ten of the

twelve venues (83%), managers responded that they would offer customers seeking

self-exclusion relevant contact information for appropriate counselling agencies.Agencies named were Centacare, Breakeven and Gamblers’ Anonymous.

Self-excluded customers would be given support in seeking mutual exclusion fromother gambling venues in six of the venues (50%) visited. However, most respondents

reported that, as there were no formal mechanisms for mutual exclusion, it was

difficult to see how this could be successful. As well, they suggested that this practicewould have limited effectiveness, as ‘other venues may not be so ethical’. Further,

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they suggested there is a need for a regional or central system, possibly operated by a

welfare agency, to monitor and control shared mutual exclusion information.

All respondents agreed that they did not send out targeted correspondence or

promotional material to self-excluded customers, although one venue continued tosend general newsletters. Of interest was the fact that four venues did not send any

promotional material to customers at all.

In analysing this practice area by size and sector, it was apparent that, in the tenvenues (83%) offering customers seeking self-exclusion contact information for

appropriate counselling services, eight venues (67%) were large, while two (17%)were small. Five venues were hotels, four were clubs and one was the casino.

In summary, the majority of managers and staff (83%) reported that they would offer

customers seeking self-exclusion relevant contact information for counsellingservices. Managers and staff in large venues were more likely to assist customers than

those in small venues. Yet managers and staff were genuinely concerned for the plight

of problem gamblers and their families. A major barrier to supporting customersseeking consensual exclusions from other gambling providers was that ‘they could

walk into another pub/club’ that did not offer the same support. Approximately half ofthe respondents saw the need for a regionally based self-exclusion system.


All managers and staff interviewed in Townsville were aware of their legal obligationto exclude minors from gambling areas. However, there was some flexibility in the

implementation of this. For example, as one interview was taking place in the gamingroom of a small dark venue, a child was sitting on a chair with its parents while they

were having a drink. The venue was very small, the main bar was loud and it was hard

to see a place where a child could sit. Another venue found it difficult when a motherwith a three month old infant strapped to her chest in a harness wanted to play the

gaming machines.

Eight venues (67%) offered alcohol service in gambling areas. Five had call buttons

on the gaming machines and three provided tray service to their gaming areas,

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particularly when they were busy. The three which provided tray service in busy times

said that this was to alleviate crowding in bar areas. One person contended that‘gamblers are generally not drinkers and drinkers are generally not gamblers’,

suggesting that tray service of alcohol to gaming areas would not encourage any riskygambling behaviour. One venue noted that where drinks service is provided, service

staff may have a role in encouraging breaks.

All venue managers and staff (100%) were aware of their obligation to preventintoxicated people from gambling as part of their responsible service of alcohol

practices. Bar and security staff were said to monitor responsible service of alcoholcarefully and, in one venue, staff are sacked if found serving intoxicated customers.

Two venues (16%) provided childcare facilities. These comprised a room with

minimal equipment so as not to make it too attractive to stay for a long time. Therewas no staff supervision and a parent was expected to stay and supervise small

children.

Staff in eleven of the twelve venues (92%) were encouraged not to take tips fromcustomers, although managers suggested they could not be certain this does not

happen. In one venue, staff are allowed to accept tips, the manager saying that tips arepart of ‘the nature of the hospitality industry’.

Customers were made aware of the passage of time in seven venues (58%) through a

variety of means. For example, two venues (16%) had several clocks and natural lightflooding into the gaming areas. Five (42%) had either clocks with no natural light or

natural light with no clocks. Only one venue had a small dark gaming area with noclocks or natural light. Some managers also contended that regular events at the same

time each day (e.g. the traditional remembrance ode at RSL clubs and promotions at

set times) reminded patrons of the time.

Seven venues (58%) suggested they discouraged customers from extended, intensive

and repetitive gambling. Strategies used here included walking to get change ordrinks; walking to ATM or EFTPOS facilities; chairs in the middle of the gaming

room to encourage people to take a break; promotions taking place in the bar and not

in the gaming room; the venue closing for several hours each day; meal timesadvertised through loud in-house announcements; staff encouraging people to collect

70

when they build up a large bank of credits on gaming machines; and staff encouraging

people to use toilets at the far end of the building. However, all venues had somegaming machines with $20 note acceptors so walking to get change might be a less

likely measure that encourages breaks in play.

When analysed by size and sector, of the eight venues (67%) offering alcohol service

in gambling areas, six (50%) were large and two (17%) were small, while six were

hotels and two were clubs.

In summary, all managers and staff were very aware of the voluntary Code where it

coincided with legislative requirements. This was evident in the areas of excludingminors from gambling areas, excluding minors from gambling and in not serving

intoxicated persons. Over half the managers and staff (58%) stated they encouraged

customers to recognise the passage of time and to take breaks in their gambling.However, all venues had some gaming machines with $20 note acceptors. As well, the

majority of venues (67%), mostly those with large gaming installations, served

alcohol to gambling customers by tray service. These two practices are oftenconsidered as encouraging patrons to remain in the gaming room.


Of the twelve venues visited, ten (83%) had ATMs, while two (17%) had EFTPOS

facilities. These were usually located in the foyer, bar, bottle shop, restaurant, bistro

or outside the main entrance. Only one venue had its ATM in a gambling area, theirTAB. There was a wide range of limits above which winnings were paid by cheque or

electronic transfer. The range extended from $250 to $10,000. Generally, smallvenues had the lower limits while large venues had the highest limits. The most

common limit, found in five venues (42%), was $1,000. The payment of winnings

over $250 by cheque or electronic transfer, while being a practice of the Code, is alsoa legislative requirement. Most venues had requested their limits be raised because of

competition with the local casino (which had a $10,000 limit), but also because manywinnings were often significantly higher than $250, requiring numerous cheques,

often with two signatures, to be written every day. This was time consuming and a

problem when only one senior person was on duty.

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Analysing the limit above which venues paid out winnings by cheque, five venues

(42%) (three hotels and two clubs) had $500 or less as their limit. Another five venues(42%) (four hotels and one club) had a $1,000 limit. One club had a $3,000 limit,

while the casino had a $10,000 limit. Clubs had a higher average cash payout forwinnings limit ($1,130) than the hotel average ($675).

In all venues, gambling winnings paid by cheque were not cashed at the venue until

the next day. At one venue, the attitude was that ‘if people put cash in then theyshould be able to get cash back’. This venue had some big TAB gamblers and the

manager felt that restrictions on payouts for gaming machine winnings were unfaircompared to payouts for TAB winnings. In nine venues (75%), cheques not made

payable to the venue were cashed when they were small personal cheques and only up

to a certain amount with the managers’ approval. Two venues (17%) cashed knownthird party cheques, but not for gambling. Of the twelve venues visited, two venues

(17%) both hotels, cashed multiple cheques for known locals with the manager’s

approval, and no venue provided credit for gambling.

In summary, most venues had strict policies for payment of winnings by cheque or

electronic transfer and their managers stated they followed them diligently. They hada variety of cheque cashing policies and these were under the manager’s direct

control. On average, clubs had over $1,000 cash payout for winnings limits while

hotels had under $1,000 cash payout for winnings limits. Small venues were morelikely to have lower limits for paying winnings by cheque than large venues.


Advertising and promotions were undertaken by eight of the twelve venues (67%)

visited in Townsville. These venues advertise in various media - radio, television,

newspapers, newsletters and letterbox drops. These eight venues run promotionsconnected to rewards systems and loyalty cards with holidays, cars and similar as

major prizes, and dinner, wine or show tickets as minor prizes. The eight venuesreported they advertise all their facilities as a leisure and entertainment package and

do not concentrate on gambling activities. For example, one manager said that their

television advertisements focus on food and dining, with ‘just a flash of gambling’.Another venue advertisement featured ‘wine, dine, stay and play’ messages. Further,

72

one manager maintained that the venue’s 30 second radio advertisements feature 12

seconds of gambling and 18 seconds of other venue offerings. However whilstreading the local newspaper in Townsville, the researchers noticed a one page

advertisement where half the page was devoted to gambling. The four venues (33%)which did not otherwise advertise had signs identifying their gambling facilities at

front of their buildings.

The eight managers (67%) who advertised and promoted their venues contended thattheir advertising would comply with the Advertising Code of Ethics as adopted by the

Australian Association of National Advertisers. They indicated that their advertisingwas not false, misleading or deceptive, did not focus exclusively on gambling, and did

not target minors, the vulnerable or disadvantaged. None of the venues used

advertising depicting or promoting the consumption of alcohol while gambling.Additionally, all managers indicated they would gain the consent of people before

publicising their name as prizewinners. While venues sometimes publicise a large win

on a linked jackpot, keno or major prize in their newsletters, do not name the winner.Managers were very aware of their obligations under the Privacy Act 1988 Cth and

appeared to be complying with its amendments. Interestingly, one manager said hisvenue promotion nights for rewards systems players had lower gaming returns than

nights with no such promotions. This manager maintained that these players are

entertainment seekers looking for a night out once or twice a week. Another managerreported that inspectors from the QOGR were vigilant in scrutinising the legality of

promotions operated by licensed premises. In contrast, a manager reported that onevenue in Townsville was advertising on the radio two hours free child care for

parents, but particularly women who wanted to come to the venue to drink and

gamble. This manager could not remember which venue this was, but was ‘disgusted’with the campaign.

Venues with large gaming installations were much more likely to undertakeadvertising and promotion than those with small gaming installations. The eight

venues (67%) that did advertise and promote were all large, comprising four hotels,

four clubs and one casino.

73

In summary, all interviewees reported they complied with the Advertising Code of

Ethics. In practice, it was difficult in a short time to investigate the veracity of thesestatements.

5.10 Perceived Adequacy of the Code Townsville

Venue managers and staff were asked their opinions of the adequacy or potential

effectiveness of various aspects of the Code. Table 5.2 summarises these results for

each of the Code’s six practice areas, with details discussed below.

Table 5-2 Perceived Adequacy of the Code’s Practice Areas for Townsville

SMALL HOTEL LARGE HOTEL LARGE CLUB CA

CODE OF PRACTICE AREAS

19 22 24 20 23 28 29 21 25 26 30 27

Provision of adequate information &signage encourages responsiblegambling

DN D D D D A A D D A A A

Support services are adequate toassist customers and the communitywho need help

A DN A A A D A A A A A D

Exclusion really encouragesresponsible gambling

DN A D A A A D A D D A A

Physical layout & environmentencourages responsible gambling

DN D A A A A DN A A A A D

Rules & limits on financialtransactions encourage responsiblegambling

D D D A D A D A D A A A

Advertising and promotions helppromote responsible gambling

D D DN A A D DN DN A A A A


74


Opinion on the provision of information in encouraging responsible gambling wasalmost evenly divided. Managers and staff in six venues (50%) felt that information

and signage would have very little impact in encouraging responsible gambling. Theircomments included:

• ‘People don’t read signs or notice them therefore, there is no likely effect.’

• ‘People don’t look at signs.’

• ‘Most people don’t read signs and advertising the odds of winning is

ineffective.’

• ‘I don’t think it makes any difference. People probably don’t read signs. If

they do it wouldn't make a difference.’

• ‘On a scale from 1-10, my response is 2 as you can’t stop people who want togamble.’

• ‘I have never seen anyone in the club look at them or read them since they put

up signs, therefore, no’.

In contrast managers and staff in five venues (42%) maintained that information and

signage did assist in encouraging responsible gambling. Their comments included:

ß ‘People are becoming more aware of problem gambling due to the signage,

especially if we had a campaign that focused on effects of problem gambling

on families and others.’

ß ‘Responsible gambling business cards are taken discretely. Staff need to

replenish cards often.’

ß ‘Yes, big time.’

ß ‘It has made patrons aware, brought it out into the open. If they need it they

might start to look at themselves. Problem gambling signs might be a trigger.’

75

ß ‘Signage is good and wallet style business cards are great.’

ß ‘Yes, particularly on toilet doors. People stop and give it thought if they aregambling more than they’re comfortable with’.

In terms of differences by size and sector, of the six venues (50%) whose managersconsidered that signage and information have little impact on encouraging responsible

gambling, four were large and two were small, while four were hotels and two were

clubs. Of the five venues (40%) whose managers felt that signage and information didencourage responsible gambling, all had large gaming installations. Two of these

were hotels, two were clubs and one was the casino. Only one venue, a small hotel,did not have an opinion either way about the impact of information and signage on

encouraging responsible gambling. Thus, venues with large gaming installations felt

that signage and information did assist in encouraging responsible gambling, whilethose who disagreed were divided between venues with large and small gaming

installations.


Most managers and staff (75%) interviewed in the twelve venues agreed there were

adequate gambling related support services to assist customers and members of theTownsville community who need this help. In support, some observations were:

ß ‘Centrecare is good but they need more resources. I don’t know much about

the other services.’

ß ‘Lifeline agency numbers are displayed, but there should be a public health

agency separate from a religious organisation.’

ß ‘Yes, there are more services now than ever before. I believe that the venue

has to support these welfare agencies, but that they are not getting enough

support.’

ß ‘Yes, Salvation Army, Lifeline, Gamblers Anonymous - if the gamblers want

to help themselves.’

ß ‘Yes, Gamblers Anonymous.’

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ß ‘Centacare, Lifeline and Salvation Army provide good service.’

ß ‘Services need more funding.’

ß ‘It only works if the venue they (problem gamblers) gamble at, knows where

to send them. This depends on the venue, how active it is with responsiblegambling.’

ß ‘Yes, I would refer to Gamblers Anonymous.’

ß ‘I know that services are there, but not how many there are or how manypeople use them. I would say something personally to big gaming machine

punters’.

One manager (at a small hotel) did not have an opinion about the adequacy of

gambling related support services, saying ‘I think they're there, but people have to

make the decision to go’. While managers and staff at two large venues did not thinkthere were enough gambling related support services in the Townsville region, the

majority (75%) felt there were was adequate.


Of the twelve Townsville venues visited, seven managers and staff (58%) agreed that

self-exclusion for problem gamblers really worked, people in four venues (33%)thought that self-exclusion did not work, while one (8%) had no opinion. Positive

responses included:

ß ‘Self-exclusion is a most effective strategy. This is the first step to recovery.I have known people where it has worked. A regular gambler stopped

coming here for 3 years after a self-exclusion. But it is not the job of theoperational staff to know who is self excluded. Centacare should have more

reliable data than the venue.’

ß ‘Yes, but if they are real problem gamblers they will find a way to do it. Itwould be good if self-excluded people gave their names to Centrecare who

could then advise all gambling outlets.’

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ß ‘I don’t think self-exclusion hurts as it raises awareness of staff about

problem gambling amongst some punters.’

ß ‘Yes, providing the person has a photo and the ban is genuine.’

ß ‘Yes, but middle management needs to be more educated about it.’

ß ‘Yes, because they’ve admitted they have a problem.’

ß ‘We are working with Centrecare to devise a self-exclusion that applies to

all venues in region. But it’s a step for someone to recognise his or herproblem.’

ß ‘Good idea, but not effective as it is now with just photos. I’m not sure howit could be improved, possibly with a regional network. Self-exclusion can

stop people becoming members of clubs and rewards systems but not from

playing.’

ß ‘Yes, but they need to do lots more to encourage it. The government could

do more to assist.’

ß ‘I feel that self-exclusion has worked 100% for the one person excluded atthis venue, as there is only one hotel nearby and the person has no car. But

for someone with transport, self-exclusion would make no difference as theycould go from one venue to another.’

ß ‘It’s a good tool to have but are they going to exclude themselves from every

venue? It’s a tool for a person to think about their problem; self-exclusion isa wake up call’.’

Negative responses included:

ß ‘No, they can go to another venue. There is no network to advise other

venues. But such a network would be difficult to administer.’

78

ß ‘No, the manager would enforce it here but doesn’t stop them going

elsewhere.’

ß ‘No, they can go somewhere else.’

ß ‘I disagree that self-exclusion works at the moment. It is part of thesolution but the horse has bolted. Public education with more ‘sizzle’ is

needed and should be provided by government. As well, there is a need to

better train management and staff so that venues will have customers whowill be more aware, then there would not be a need for self-exclusion.

Problem gambling reflects some stupidity, therefore we need publiceducation.’

ß ‘I don’t know, we have no experience of this (self-exclusion)’.

In terms of size and sector, of the twelve Townsville venues, seven managers and staff(58%) agreed that self-exclusion for problem gamblers really works. Of these, six

(50%) were large venues and one (8%) was small. Four venues were hotels, two were

clubs and one was the casino. Of the four (33%) venues where managers and staffdisagreed that exclusion helped problem gamblers, two were hotels and two were

clubs. One hotel manager with a small gaming installation had no opinion on thisissue. Overall, the majority of people (58%) who felt that exclusion really helped

problem gamblers were from the large venues.


Managers and staff in eight venues (67%) agreed that appropriate physical

environments in gaming rooms encourages responsible gambling, those in two venues(17%) disagreed and two more did not know (17%). Some supportive comments from

the eight who agreed included:

ß ‘This is a step in the right direction. The toilets, cafe and courtyard are nearthe exit so patrons do not have to go back through gaming area to leave.’

ß ‘Of course, if they have to get up they might say they’ve had enough. Staff cankeep a reasonable eye on customers when they get change.’

79

ß ‘Yes, we have spacious lounge areas away from gambling areas, not in the

engine room. Keep flashy signage in gaming area to a minimum.’

ß ‘For sure – yes, when you make it harder for people to stay there without

having to get up.’

ß ‘Rooms are designed for effective business operations, but I don’t have a

problem with having clocks.’

ß ‘Yes certainly, clocks and natural light work. Crown Casino in Melbourne isan example of being very enclosed and dark.’

Some negative comments included:

ß ‘People come to venue to play and don’t lose track of time – I don’t know

of anyone without a watch. Irresponsible people, addicts, are different to

others- if they want to gamble they will find a way. Nothing in theenvironment will change them.’

ß ‘If government allows gambling, then that should be good enough –

changing physical layout doesn’t do much.’

ß ‘No, it doesn’t make any difference. Natural light might make room more

pleasant and encourage more gambling! ‘

ß ‘A user-friendly room means people will use it to gamble.’

ß ‘Don’t know. People feel more private in enclosed areas. Gaming

machines in rows work better than in carousels for business.’

Of the eight venues (67%) whose managers considered that appropriate physical

environments encourage responsible gambling, six (50%) were large and two (17%)were small, while four (33%) were hotels, three (25%) were clubs and one was the

casino. The two venues (17%) whose managers disagreed that this practice area was

effective were hotels, one large and one small. The two venues (17%) whosemanagers had no opinion either way were both large, with one a hotel and one a club.

Most venues (67%) whose managers believed that physical layout and environmentencourages responsible gambling had large gaming installations.

80


Opinion on the Code’s rules and limits on financial transactions in encouragingresponsible gambling was evenly divided, with managers and staff in six venues

(50%) agreeing and managers and staff in six venues (50%) disagreeing on theirpotential effectiveness. Managers and staff in six venues (50%) reported positively as

follows:

ß ‘Yes, if you can limit cash people can get a hold of, then this limitsoverspending.’

ß ‘Yes, but there is not much you can do if they win only $1,000. Peoplesometimes try to cash cheques but change their minds due to the complex

procedure set up in venue.’

ß ‘Definitely yes and room for more improvements in cheque cashingprocesses in Townsville.’

ß ‘Definitely by not providing credit. If we don’t cash cheques, someone

else will if they (gamblers) try hard enough.’

ß ‘It is already tough and needs to be.’

ß ‘Gamblers always find somewhere to cash a cheque, but having a cashlimit on winnings is a good idea as they would put less back through

gaming machines.’

ß ‘Electronic banking is one of the pitfalls for gamblers. ATMs are sonumerous and accessible. Gambling venues’ ATMs should only be used

for debit cards (by law).’

Managers and staff in six venues (50%) reported negatively as follows:

ß ‘If someone wants to gamble, they’ll access money from bank anyway.’

ß ‘No, they will go somewhere else if rules are too strict.’

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ß ‘No, it doesn’t stop them from drawing out what they draw out of EFTPOS

accounts and spending this on gambling.’

ß ‘People gamble in cash so they should be paid in cash. Big winners should

be offered a cheque for security reasons, but while there needs to be a cutoffpoint, $300 is too low. Give people a choice.’

ß ‘The manager doesn’t think limiting $50 and100 notes has made any

difference except in the very short term, just a blip.’

ß ‘If you can afford to gamble, why should you be limited to how much you

can gamble? This can be an annoyance to gamblers having to cash money ona regular basis. This requirement can actually extend the time people spend

gambling.’

The managers and staff in six venues (50%) who agreed that rules and limits onfinancial transactions encourage responsible gambling were all from large venues,

comprising three clubs, two hotels and one casino. The six (50%) who disagreed were

equally distributed. Three were large and three were small venues. Five of thesevenues were hotels and one was a club. Thus, while perceptions on the adequacy of

rules and limits on financial transactions in encouraging responsible gambling wereevenly divided, those who were supportive of this practice area had large gaming

installations and those who were not supportive were mostly hotels.


In response to the question ‘do you think that advertising and promotions can help

promote responsible gambling’, managers and staff in six venues (50%) said yes,three said no (25%) and three did not have an opinion (25%). Positive observations

included:

ß ‘It’s an awareness campaign. If you have problem, advertising brings it toyour attention. Advertising is a strong motivator. It also assists kids tomake responsible decisions. Irresponsible kids will do it anyway.’

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ß ‘Yes, especially family advertisements. Some gamblers might not think

they have a problem but it might trigger some awareness. It helps somepeople think about it.’

ß ‘Yes, we have had discussions with Centrecare about advertising our

venues as providing a responsible gambling environment.’

ß ‘Product warnings and counselling phone numbers could help. The kenoscreen could be used. Some advertising is irresponsible or misleading and

these venues get away with it. We need better monitoring.’

ß ‘We need a public education campaign by government – like speeding ordrink driving.’

ß ‘I’ve yet to see any rogues doing responsible advertising in Townsville..’

ß ‘Irresponsible advertising certainly encourages irresponsible gambling.This venue does not do or like promotions. Big prizes attract the less

advantaged.’

ß ‘The whole package of venue facilities are advertised, but people only seewhat they want to see.’

ß ‘The QHA seminar was informative about advertising. Morals of the

advertiser should be responsible for gambling. I agree that advertisingtargets poor working class people.’

ß ‘It would help to a certain degree’.

Negative observations included:

ß ‘It has not really made any difference.’

ß ‘People only take notice of what they want to notice.’

Of the managers and staff in the six venues (50%) who felt that appropriate

advertising and promotions can help promote responsible gambling, all had large

gaming installations. Three were clubs, two were hotels and one was the casino. Ofthe three (25%) who disagreed, all were hotels, one large and two small. Of the three

(25%) who had no view either way, two were large venues and one was small. Two of

83

these were hotels, while one was a club. Thus, six venues (50%) with large gaming

installations felt that this practice area could assist in promoting responsible gambling.

In summary, in descending order of importance, most respondents in the Townsville

interviews perceived that there are adequate gambling related support services (75%),that the physical environments of gaming rooms are important in encouraging

responsible gambling (67%), and that self-exclusion for problem gamblers is an

effective practice that assists at-risk gamblers (58%). Management and staff opinionson the potential effectiveness of the other three practice areas (provision of

information, financial transactions and advertising) were evenly divided betweenagreement and disagreement. Generally, venues with large gaming installations were

more likely to respond that the Code was effective in trying to encourage responsible

gambling practices than small venues.

5.17 Facilitators and Impediments for the Code in Townsville

Managers and staff were asked for their opinions on any facilitators and barriers for

the widespread implementation of the Queensland Responsible Gambling Code of

Practice in Townsville and its potential effectiveness in encouraging responsible

gambling. The responses presented below include points relating to which practicesare considered the most appropriate and inappropriate, as well as actions that might be

taken to facilitate the Code’s implementation and those which are seen to be impeding

implementation.

5.18 Facilitators

Respondents articulated the following points which indicate their support for elementsof the Code. It is expected that such support is critical to the Code’s acceptance in

industry. They also mentioned some measures they consider have very much helped

in operationalising the Code in their venues:

ß ‘All practices support each other – the package as a whole assists.’

ß ‘All practices are effective.’

ß ‘Nothing is a waste of time when you’re trying to help someone.’

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ß ‘Everything helps, but we are not advocating shutting down a gaming

machine after a certain period of time.’

ß ‘Self-exclusion is the most effective.’

ß ‘Pamphlets, signs and notices stick out the most, but we always had self-exclusion anyway.’

ß ‘The staff being able to handle it well – knowledge, attitude, awareness –

hiring the right staff and training is important.’

ß ‘Anything to make it easier for staff.’

ß ‘Staff you have on the floor see them (gamblers) day in day out, and willexpress any concerns to manager. This manager constantly monitors

gamblers. Good staff, with caring and genuine attitudes are important.’

ß ‘Personal contact, knowing your customers, a caring attitude and treatingcustomers with respect. If the Code of Practice helps one person then it’s

worth it, but I’m a bit sceptical about its effectiveness – I don’t really

know.’

ß ‘Centacare are very good. They have taken onus or burden away from

individual venues. We can get advice from them. Getting the messageabout what excess spending can do to an individual or a family can greatly

help. But government allowed too much gambling in first place with too

little thought and in inappropriate places e.g. shopping malls and nearschools.’

ß ‘Nothing is a waste of time. They might seem like little things to somepeople but reducing notes acceptors to $20 means they have to get up to

get change. Or it might be easier to put in a $20 note rather than a $50. $50

is a lot for some people to gamble.’

ß ‘Financial transactions is most effective, especially cheque cashing and

paying winnings by cheque. But whole package is important.’

85

ß ‘Moving ATMs outside the building, physically taking someone outside

the business premises, is effective.’

ß ‘Clocks are a reality check. However once a problem gambler is in the

venue then the environment doesn’t make any difference’.

Thus, the most commonly mentioned facilitator was having well trained staff.

However, almost the entire range of responsible gambling practices, adequate

information, community support services, self-exclusion, physical environment andfinancial transactions were mentioned by different people as being important practices

encouraging responsible gambling. One practice, advertising and promotion was notmentioned at all and obviously not perceived by this group as being influential in

encouraging responsible gambling.

5.19 Impediments

Respondents articulated the following points that indicate their lack of support for

elements of the Code which would seem to limit its acceptance in industry. They also

mentioned some measures they consider have impeded the operationalisation of theCode in their venues:

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ß ‘Most of it is a waste of time.’

ß ‘Signage makes no difference.’

ß ‘Training from Brisbane is infrequent. We’re left behind in the regions’.

ß ‘QOGR audits once every two years now, previously once every year. Weneed more random inspection of venues.’

ß ‘Lack of adherence by other venues to policy, as we think the policy is

fine. The barrier is a lack of others abiding by the responsible gamblingcode of practice.’

ß ‘Some pubs and clubs do not manage children on premises very well, forexample kids sitting at machines while parents play next machine. We are

against the provision of childcare facilities at venues.’

ß ‘Differences in sectors - hotels, clubs casinos are all different, and one sizedoes not fit all. The Code of Practice may have varying degree of

effectiveness. For example hotels might be more avaricious and take

money from anyone. The casinos are less worried about individual patrons.Clubs don’t want drunks, have a duty of care, and do not bleed members

dry, as they are not under so much pressure to make a profit.’

ß ‘I do not think that any of these practices have changed gambling

behaviors in this venue; we still have the same clientele, the same

expenditures. Nothing has changed. For example, reducing $50 and $100notes reduced spending for about six weeks. Turnover went down by about

28%, but now is only 4% less - a short-term effect only.’

ß ‘Changing $50 to $20 note limit has made no difference at this venue. In

fact, the reverse happened - revenue went up. It’s a waste of time and just

creates more work for staff. People on limited money may only have $20to spend. People still spend the same amount.’

87

ß ‘The least effective measure was the $50 and $100 note removal. No

change in trade but lots of work for the venue in counting notes. Irecommend that we get rid of this measure.’

ß ‘The $50 and $100 note change is totally ineffective. It just means that thecoin dispenser is used more. It affected revenue for one month then it

returned to normal.’

ß ‘The reduction of $50 and $100 note use in gaming machines was nobarrier. It dropped turnover by 25% for one week. Turnover has now risen

to the same level. However the ATM now has $20 notes and lots of them.’

ß ‘Nothing, the reduction of the $50 and $100 note acceptor made no

difference. Why not have the same restrictions on TAB?’

As can be seen from these comments, issues of non-compliance with the Code anddifferences in sectors paled into insignificance compared to the overwhelming

objections to the removal of $50 and $100 note acceptors on gaming machines. Most

venues claimed that this measure had made very little difference to gamblingexpenditure, but more importantly had little effect in reducing problem gambling. It

had just made much more work for the venue staff.

Some other issues that could potentially affect the effectiveness of the Code were

raised by three venue managers (25%):

ß ‘If family members can approach venues for help, this (package) wouldhelp. They could include gambling in kids’ helpline service.’

ß ‘Drug problems are more serious gambling problems (in Townsville).’

ß ‘It is rare to have big TAB punters at this venue. The owner knows just

about all patrons, but some could have problems and you wouldn’t know.

Big TAB punters are potentially drug dealers (on the phone a lot, doingdeals and then leaving quickly). Indigenous ladies play gaming machines

to escape husbands who would take their money, drink it and becomeviolent to their wives.’

88

These comments opened up another set of issues, such as the consequences for

families living with problem gambling and drug crime that might be associated withgambling. Whilst only three venue managers made these comments, their venues were

located in poorer areas of Townsville, those showing signs of neglect and need. Thesemanagers observed that their customers were generally manual workers, casuals,

retired or unemployed. In lower socio-economic areas in Townsville, further research

appears needed to fully investigate the issues raised by these comments. Theserespondents appeared to be suggesting that these fundamental problems could

undermine the Code’s effectiveness.

5.20 Summary

This final part of Section Five summarises the findings from the Townsville research

in terms of awareness and implementation, perceived adequacy of the Code, andfacilitators and barriers to its efficacy.


It is apparent that, in Townsville, the Queensland Responsible Gambling Code of

Practice had not been fully implemented at the time of the study because not all the

venue operators were cognisant of its existence, details and requirements, while othersreceived it with varying levels of enthusiasm. Eight of the twelve venue managers

(67%) interviewed were aware of, and compliant with, the Code or the Resource

Manual. Of these, five (42%) could be considered committed and proactive, three(25%) were compliant, and four (17%) met only the legal obligations.

In terms of implementation, apart from where the QOGR representative had installedproblem gambling signs, the only area where a large number of venue managers

(83%) had a clear understanding of the provision of information area of the Code was

in regards to displaying financial transactions information. The majority of venuemanagers (75%) said they would support customers by providing information on

problem gambling help, but only half had the means to do this effectively. A highproportion of managers and staff (75%) reported they would offer patrons seeking

self-exclusion relevant contact information for appropriate counselling agencies.

Large venues were more likely to assist customers than small venues. Approximately

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half of the respondents saw the need for a regionally based self-exclusion system. All

interviewees were aware of the Code’s practices where they coincided with legislativerequirements. Minors were excluded from gambling areas and from gambling, and

intoxicated persons were not served any further alcohol. All interviewees reportedthey encouraged customers to recognise the passage of time and to take breaks in

play. However, most venues (67%), mainly large ones, provided tray service of

alcohol to gamblers. Most venues had strict financial transactions policies. Smallvenues with small gaming installations were more likely to have lower limits for

paying winnings by cheque than large venues. Cheque cashing policies varied,depending on the manager’s or owner’s decisions. Most (67%) venues reported they

complied with the Advertising Code of Ethics, although there was some evidence (in

interviews and in the press) to suggest this was not entirely accurate. Large venueswere more likely to undertake advertising and promotion than small venues.

5.22 Adequacy

Most respondents (75%) perceived that the Townsville region has adequate gamblingrelated support services. To a lesser extent, managers and staff (67%) felt that an

appropriate gaming environment is important for encouraging responsible gambling.A small majority (58%) think that self-exclusion for problem gamblers is an effective

practice that assists at-risk gamblers. The other three practices contained in the Code,

provision of signage and information, rules and limits on financial transactions andadvertising and promotions gained mixed support.

5.23 Facilitators and Impediments

Training, education and skills development of gaming management and staff was

perceived as being the most important facilitator in encouraging responsible

gambling. However, almost the entire range of responsible gambling practices,adequate information, community support services, self-exclusion, physical

environment and financial transactions were also mentioned by different people asbeing important facilitators. Conspicuous by its absence was advertising and

promotions, obviously not seen as being significant in encouraging responsible

gambling. The most frequently mentioned practice raised as being ineffective in

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encouraging responsible gambling practices was the removal of $50 and $100 note

acceptors on gaming machines. It was claimed that this measure had practically noeffect on reducing problem gambling and made little difference to gambling

expenditure in the long term.

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SECTION SIX

6 THE SOUTH EAST QUEENSLAND CASE STUDY

6.1 Introduction

The south-east Queensland region covers an area of 20,400 square kilometres from

Noosa in the north, south to the NSW border and west to Toowoomba. Its populationis 2.2 million, and expected to grow to 3.2 million by 2011. The current population is

approximately 66% of the Queensland population. The region generates 62% of the

gross state product and 10% of Australia's gross domestic product. Gold Coast Cityand Brisbane are the main population centres in south-east Queensland

(http://www.seqroc.qld.gov.au/history.htm). Gold Coast City spans 1,402 square

kilometres, featuring 70 kilometres of coastline from South Stradbroke Island toRainbow Bay. Its population is 425,418, the sixth most populated Australian city,

expected to increase to over 500,000 within the next decade. Gold Coast City has adiverse population. About one-fifth is aged 0 to 24 years and about one-quarter is

aged 55 years and over. About one-quarter of Gold Coast City residents were born

overseas. The Gold Coast has developed a reputation nationally and internationally asthe tourism capital of Australia (http://www.goldcoast.qld.gov.au). Brisbane,

Queensland's capital city, is less than one hour's drive from the Gold Coast. TheBrisbane City Council governs an area of 1,220 square kilometres and has a

population of 898,480. The Greater Brisbane Area covers 4,643 square kilometres and

has a population of 1,653,365 people. Brisbane's rapid economic growth, favourableclimate and abolition of death duties have all attracted a massive wave of internal

migration. Since 1980, over half a million Australians from other states have movedto Queensland. The city and suburbs have grown steadily, benefiting from an influx

of post-war immigrants, and Vietnamese refugees in the 1980s. Along the way

Brisbane has shed its reputation as a ‘big country town’ and emerged as acosmopolitan Australian city (http://www.brisbane.qld.gov.au).

Twenty organisations in south-east Queensland were approached for interviews forthis study. Between February and April 2003, managers and/or key staff members at

fourteen venues and two industry associations were interviewed. These venues

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comprised one casino with a large gaming facility (tables, gaming machines, TAB,

keno), seven hotels (three large and four small), six clubs (three large and threesmall). All fourteen venues (100%) had gaming machines and keno facilities, while

ten (71%) offered TAB facilities. In each venue, the owner, manager or gamingmanager was interviewed. In the large venues, a selection of gaming staff was

interviewed. In total, 21 interviews were conducted.

The ensuing discussion presents the results of this research, first on the interviewees’general awareness of the Code and then on their opinions of its likely effectiveness.

An analysis of the respondents’ perception of the adequacy of the Code will follow,along with identification of perceived facilitators and impediments in implementing

the Code. Open-ended comments will then be highlighted, followed by a closing

summary.

6.2 Awareness of the Code in South-East Queensland

The majority of managers from the fourteen venues visited in south-east Queensland

were aware of the Queensland Responsible Gambling Code of Practice. The Codehad been delivered to thirteen (93%) of the fourteen venues. The one venue reporting

that it had not received a copy of the Code had appointed a new manager in theprevious three weeks and was concentrating on reversing the poor financial situation

of the venue. This venue had been closed for a short time and had no responsible

gambling resources or signs. Of the fourteen venues visited, thirteen (93%) hadpossession of the Resource Manual. On authority from the QOGR a commercial

agency had installed signage on problem gambling in twelve of the fourteen venues.The casino had installed its signage when it rolled out its responsible gambling

strategies in March 2002.

While the one manager who had no access to either the Queensland Responsible

Gambling Code of Practice or the Resource Manual was not aware of the voluntary

Code, two other managers (14%) who had received these materials were not aware oftheir content. One said his gaming staff and cashiers looked after all gaming matters,

while the other was only aware of signage placement and legislative requirements.

Yet the industry associations, Clubs QLD and the QHA, said that they ensured thatcopies of the Code and the Resource Manual went to all clubs and hotels, members

93

and non-members. Some copies were personally delivered, others were distributed at

workshops and some others were mailed out. Future training opportunities wereforeshadowed in letters accompanying the mail-out. Thus, eleven managers (79%) of

the fourteen venues visited were aware of the contents of the Queensland Responsible

Gambling Code of Practice and the Resource Manual.

Overall, there appeared to be four levels of awareness of the Code:

ß The highest level of awareness comprised seven venue managers and staff(50%) who were committed to progressing the Code. They were very

familiar with, and supportive of, the Code.

ß The next level of awareness was demonstrated by four venues (29%) where

managers and staff were aware of, and compliant with, the Code.

ß Managers and staff in two venues (14%) had received, but not read, the

Code or the Resource Manual. This group was vaguely aware of the Code.

ß At the lowest level of awareness of the Code the manager in one venue (7%)

had not received the Code or Resource Manual. This manager was onlyaware of, and compliant with legislative requirements.

6.3 Implementation of the Code in South-East Queensland

Venue managers and staff were asked to identify those parts of the voluntary Codethey were implementing and those they not. Table 6.1 summarises their responses,

with the details discussed below.

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Table 6-1 Implementation of the Code’s Elements in the South-East QueenslandVenues

CODE OF PRACTICEELEMENTS

SMALL HOTELSLARGEHOTELS

SMALL CLUBS LARGE CLUBS CA

1. Provision of Information 12 16 17 18 7 10 14 5 6 13 9 11 15 8

Displays responsible gamblingmission statement

Y Y Y Y Y Y Y N N Y N Y Y Y

Displays help information in allgaming areas

Y Y Y Y Y Y Y Y N Y Y Y Y Y

Displays help information nearEFTPOS/ATMs servicinggambling areas

Y Y N Y Y Y Y Y N Y Y Y Y Y

Displays help information intoilets

Y Y Y N Y Y Y Y N Y Y Y Y Y

Displays information on theresponsible gaming policydocument

N Y N N Y Y Y N N N Y Y N Y

Displays information on therules of play and odds ofwinning

N Y N N Y N N Y N N Y Y N Y

Displays information onexclusion provisions

N Y N N Y Y Y N N N Y Y N Y

Displays information ongambling related complaintsresolution

Y Y N N N Y Y N N N Y N N Y

Displays information onfinancial transactions practices

Y Y Y N Y Y Y N N N Y Y N Y

Displays odds of winning amajor prize

Y Y N N N Y N Y N N N Y N Y

2. Interaction with Customersand Community

12 16 17 18 7 10 14 5 6 13 9 11 15 8

Establish links with supportservices

N Y N Y N N Y N N Y Y N Y Y

Establish links withcommunity

N Y N N N N Y N N Y Y Y N Y

Customer liaison providesinformation to customers

N Y N Y N Y Y Y N Y Y Y Y Y

Support staff in providingassistance to customers

N Y Y Y Y Y Y Y N Y Y Y Y Y

Provide assistance to staffwith gambling relatedproblems

N Y Y Y Y Y Y N N Y N Y Y Y

Customer complaints systemestablished and promoted

N Y Y Y Y Y Y N N Y Y Y Y Y

Ensure responsible gamblingtraining is provided torelevant staff

N Y Y N Y Y Y Y N Y Y Y Y Y

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Owners, boards, managersreceive appropriateinformation to guide decisionmaking

Y Y Y Y Y Y Y Y N Y N Y Y Y

3. Exclusion Provisions 12 16 17 18 7 10 14 5 6 13 9 11 15 8

Provide self-exclusionprocedures anddocumentation

N Y N Y Y Y Y N N N Y Y Y Y

Offers self-exclusion contactinformation for appropriatecounselling agencies

Y Y N Y Y Y Y Y N N Y Y Y Y

Self-excluded customerssupported in seeking mutualexclusion from othergambling providers

N N N N Y Y Y N N N Y N Y Y

Does not sendcorrespondence orpromotional material toexcluded customers

Y Y Y Y Y Y Y Y Y Y Y Y Y Y

4. Physical Environment 12 16 17 18 7 10 14 5 6 13 9 11 15 8

Minors Prohibited fromgambling


Minors excluded from areawhere adults gambling


Alcohol service encouragecustomers to take breaks inplay

Y Y Y Y N Y Y Y Y Y Y N N Y

Intoxicated customers notpermitted to continuegambling

Y Y Y Y N Y Y Y Y Y Y N Y Y

Childcare facilities meetlegislated standards

N N Y N N N N N N N N Y Y Y

Staff in gambling areas not toencourage tips

N Y Y Y Y Y Y N N Y Y Y Y Y

Customers made aware ofthe passage of time

N Y N Y Y Y Y Y Y Y Y Y Y Y

Customers discouraged fromextended, intensive &repetitive play

Y Y N Y Y Y Y Y N Y Y N N Y

5. Financial Transactions 12 16 17 18 7 10 14 5 6 13 9 11 15 8

ATM Facilities not locatedclose to gambling areas

N Y N Y Y Y Y Y Y Y Y Y Y Y

Est. limit above which allwinnings are paid by chequeor EFT $5

00

$100

0

$250

$500

$100

0

$100

0

$500

$500

$600

$500

$250

0

$100

0

$200

0

$100

00

Gambling winnings above aset limit are paid by chequeand not cashed at venue untilnext day


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Prohibits cashing chequesnot made payable to thevenue

N Y Y N Y Y Y Y N Y Y Y Y Y

Prohibits cashing chequesnot payable to the personpresenting the cheque

Y Y Y Y Y Y Y Y N Y Y Y Y Y

Prohibits cashing multiplecheques


Does not provide credit orlend money for gambling


6. Advertising andPromotions

12 16 17 18 7 10 14 5 6 13 9 11 15 8

Complies with advertising codeof ethics by AANA

Y Y NA Y Y Y Y NA NA Y Y Y Y Y

Is not false, misleading ordeceptive


Does not misrepresent theprobability of winning a prize


Does not give the impressionthat gambling is a responsiblestrategy for betterment


Does not include misleadingstatements about odds, prizes,or chances of winning


Does not offend prevailingcommunity standards


Does not focus exclusively ongambling


Is not implicitly or explicitlydirected at minors orvulnerable or disadvantagedgroups


Does not involve any externalsigns advising of winnings paid


Does not involve anyirresponsible trading practicesby the gambling provider


Does not depict or promotealcohol consumption withgambling


Obtains consent prior topublishing the ID of any personwho wins a prize


Y – YES N – NO NA – NOT APPLICABLE

97


Problem gambling signage was displayed in thirteen (93%) of the fourteen venuesvisited. While the casino had installed signs earlier, an agency acting for the QOGR

had installed signs in another twelve venues. Signs and business cards were placednear ATM and EFTPOS facilities, in toilets, at cashiers’ desks, at reception, at the end

of rows of gaming machines, and on walls in all gaming areas, while some venues had

a six-foot sign. While most venues visited had signs and business cards in all theseareas, two (14%) had one or two signs missing. Many venues reported that they

needed to continually replenish the business cards. They felt that the cards werepopular as they were small, able to be taken away and read discretely. Alternatively,

some people wondered if the cards were used for other purposes, such as writing

messages, for jokes or just vandalised.

Twelve of the fourteen venues (86%) displayed their responsible gambling mission

statements, while seven venues (50%) had a sign indicating they had a responsible

gambling policy document. This policy document was mostly available at reception,at the security desk or cashiers’ booth, but also printed in some venue brochures and

newsletters. Six of the thirteen venues (43%) had rules of play and odds of winningeither printed in a player information guide or available at reception or the cashiers’

desk.

Information on self-exclusion policies was available at seven venues (50%) either atthe security desk or cashiers’ booth. Information on resolving gambling complaints

was on hand in six venues (43%). Nine of the fourteen venues (64%) had informationpublicly displayed on their financial transactions policy, while six venues (43%) had

the odds of winning a major prize displayed. Three venues (21%) reported they were

waiting for the odds of winning sign to arrive from their industry association,expecting it would be available soon.

In considering variations according to the size and sector of the venues, adistinguishing aspect of those seven venues (50%) who provided gamblers with

practically all the information highlighted in the Code, was that six of them were large

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venues. Of the seven adhering to the Code’s provision of information practices, four

were hotels, two were clubs and one was the casino.

Overall, compliance with this practice area was evenly divided amongst the sample.

Seven venues (50%) provided gamblers with nearly all the information outlined in theCode, while the other seven (50%) provided less than half this information. Large

venues were much more active in abiding by this practice area, as were hotels and the

casino compared to the clubs. The only area where most managers and staff (93%)had a clear understanding of the provision of information practices related to

displaying problem gambling signage.

6.5 Interaction with Customers and Community

Six of the fourteen venues (43%) had established effective links with gambling related

services and community networks. These six venue managers had formed links eitherwith the local Relationships Australia agency or the Salvation Army. A further three

venues (21%) were intending to establish links with local community and support

agencies and the research team’s visit seemed to be a catalyst for this. If this occurs,then it will support the claim expressed by most managers that they genuinely want to

assist at risk gamblers.

In the customer liaison role, ten venue managers (71%) stated that they would provide

information to customers on problem gambling support services. Staff members in

these venues said they would refer a request for problem gambling information up thechain of command to the manager. Two managers (14%) in different venues, both

large, reported they each had been approached by three to four people in the recentpast seeking such information. They felt this was a result of the publicity surrounding

the roll out of the Queensland Responsible Gambling Code of Practice. The campaign

made it ‘more acceptable’ for people to seek information about problem gambling.

Twelve venue managers (86%) said they would support their staff in providing

assistance to customers looking for problem gambling advice. One venue keeps adiary for staff to record any observations or remarks that indicate if customers are

worried about their gambling. Another venue has staff meetings to share information

about responsible gambling to reduce the personal stress some staff experience when

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a customer expresses concern or shows signs of distress about their gambling. Ten

venue managers (71%) stated they would support any of their staff with gambling-related problems. In five of these venues (38%) staff are not permitted to gamble.

Three managers (21%) reported they have had staff who presented as problemgamblers. One was found to have been ‘borrowing’ money and quickly left. The other

two were moved to different departments of their respective venues, and given

appropriate advice and counselling. These three venues have bans on staff gambling.

Customer complaints were usually handled in the first instance by the operations staff,

then the shift or duty manager, and finally the general manager or owner, dependingon the nature and severity of the complaint. Eleven of the fourteen venues (79%) had

some type of complaints resolution mechanism in place. Managers and staff were in

no doubt that their customers knew how to make a complaint.

Staff training and skills development in responsible gambling provision had been

undertaken in eleven of the fourteen venues (79%). Of the eleven, two had completed

training with Clubs QLD, three with the QHA, three had dedicated trainers on theirhuman resources staff or within their industry group who provided this training at

induction, and three venues used private providers. In two venues, where seniorgaming staff had been trained in New South Wales, managers complained about the

courses provided by one industry association in Queensland. They felt that the courses

were too short, only a half day, compared to a full day in New South Wales. As aresult, some topics were ‘too rushed’ and others were ‘brushed over’. One of these

venues was hoping to introduce in-house staff training in responsible gambling.

Eleven managers (79%) reported that they had the support of their boards, owners and

general managers in implementing responsible gambling practices.

In analysing these results by size and sector, of the ten venue managers and staff(71%) reporting that they provide information to customers on problem gambling

assistance, six were large, while four were small. Similarly, of the eleven venuemanagers (79%) whose staff had undertaken responsible gambling training, seven

were from large venues and four from small ones. In contrast, of the six venue

managers (43%) who had established links with gambling related support services, thevenues were evenly divided by size, three being large and three being small.

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Thus, the majority of venues had the means to assist customers by providing problem

gambling advice. Most managers (79%) had supported related training and skillsdevelopment for their staff, yet less than half (43%) had any links with gambling

related support services or community networks. Large venues appeared betterequipped to provide customers with information on where to get help for gambling

problems and have more trained staff than small venues.


When requested, self-exclusion procedures and supporting documentation could be

provided by nine of the fourteen venues (64%) visited in south-east Queensland.Managers and staff from six venues (43%) reported that they had self-excluded

between one and four people in the past year or two. One manager claimed that his

venue would not have any self-exclusions as its trade was almost all from tourists.Three other respondents said that, when a customer was obviously experiencing

physical distress with their gambling but not requesting self-exclusion information,

then they or their liaison person would be proactive and speak to that person. Theywould offer that customer advice and information on exclusion, after ascertaining if it

was actually risky gambling that was causing the distress. Two venues kept anincident book to record incidents involving potential and actual self-exclusion.

Another manager suggested that, in a nearby locality with low socio-economic

indicators, there were probably more gambling problems than in most other places,but people were less likely to ask for exclusion. Self-exclusion might be seen as being

weak or result in loss of respect in this particular community. Other venues said thatthey had never had a call for self-exclusion, but were sympathetic and would ban on

request.

In eleven of the fourteen venues (79%), managers indicated that they would offercustomers seeking self-exclusion relevant information to contact appropriate

counselling agencies. Agencies named were the Gambling Helpline, RelationshipsAustralia, Breakeven, Salvation Army and Gamblers Anonymous.

Excluded customers would also be given support in seeking mutual exclusion from

other gambling venues by six of the venues (43%) visited. However, theserespondents reported that, as there were no formal mechanisms for mutual exclusion,

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it was difficult to manage this practice. Further, they suggested that mutual exclusion

would have limited effectiveness, as it was ‘very hard to police’ and that it mightbreach legislation. Further, one person said there is a need for a Queensland-wide card

system to monitor and control shared mutual exclusion information. Another personwanted stronger legal backing for self-exclusions, saying that excluded people can

change their minds and be back in a gaming room after only one month.

Thirteen (93%) of the fourteen venues stated that they did not send out targetedcorrespondence or promotional material to self-excluded customers. However some

still sent out general newsletters. Three venues (21%) did not send any promotionalmaterial to customers at all.

In terms of size and sector, the eleven venues (79%) able to offer customers seeking

self-exclusion contact with appropriate counselling agencies, seven were large andfour were small venues. On a sector basis, six were hotels, four were clubs and one a

casino.

In summary, the majority of managers and staff (79%) reported they would offercustomers seeking self-exclusion relevant contact information for appropriate

counselling agencies. Nine (64%) of these eleven venues had formal self-exclusionprocedures and processes established and ready to use. Seven (50%) of these eleven

venues had large gaming installations. Managers and staff were honestly concerned

about problem gamblers and their families. A major barrier to supporting customersseeking consensual exclusions from other gambling providers was that this was hard

to regulate, potentially law breaking and therefore needed more development.


All managers and staff interviewed were aware of their legal obligation to exclude

minors and reported they are also active in supervising their car parks, bistros andadjacent areas for unattended children. For example, one venue had asked a customer

to leave recently as this person had left a child playing in an outside dining area orcourtyard while she gambled.

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Three venues (21%) offered alcohol tray service in gambling areas. One of these

provided tray service to their gaming area only when business was slow and it was noextra trouble. One venue provided tray service to its table games area, but not to its

gaming machines, while the other provided tray service everywhere in the venue.

Managers and staff in twelve of the fourteen venues (86%) were aware of their

obligations to prevent intoxicated people from gambling, maintaining they needed to

comply with responsible service of alcohol practices. However one manager felt that,if the person was not abusive or disturbing anyone, then no harm would be done if

they were allowed to gamble. In contrast, another manager said that ‘if people can’tmake decisions on their drinking then they can’t make decisions on their gambling’.

One respondent said that responsible alcohol and gambling policies were closely

linked and that intoxicated customers were removed from the table games area beforethey began to play. Another person reported that s/he sent intoxicated people home in

a taxi.

Four venues (29%) provided childcare facilities. Two of these offer childcare as partof their hotel and resort service rather than their gaming service, but speculated that

hotel customers who gambled could also use this. At one venue, childcare wasprovided for three hours each night during dinner and was only available for children

between the ages of five and fifteen years. However, two other venues were

considering building childcare facilities. One sporting club said that it had juniormembers and that the venue could be considered a proxy for childcare particularly

during the school holidays. This club had strict limits on junior members’ activities.

Staff in eleven of the fourteen venues (79%) are not encouraged to take tips from

customers. One manager said that ‘if a tip of $20 has been given to a staff member

when a customer was winning they might want to borrow it back when losing’. Inthree venues staff are allowed to receive tips but not solicit them.

Customers are made aware of the passage of time in all but two venues (86%) througha variety of means. The twelve venues either had several clocks and natural light,

clocks with no natural light or natural light without any clocks. Two venues had timed

their promotions and prize draws for the same time each day and felt this was onemechanism to remind people of the time. One venue had a small dark gaming area

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with no clocks or natural light, while another had the same but was in the process of

renovating. A problem with this practice is that, whilst natural light allows people tokeep track of time, covering windows to prevent outside observation of gaming areas

is a legislative requirement. Additionally, when the casino was built, natural light wasnot part of the original design, as the Casino Control Act did not allow gaming

installations to be seen from the outside. Changes are now being considered to allow

more natural light inside.

While all venues (100%) reported they discouraged customers from extended,

intensive and repetitive gambling, from observation during and after the interviews,

only 10 venues (71%) seemed to have practical strategies in operation. Strategies used

here included walking to get change or drinks; walking to the ATM or EFTPOS

machines; payout provided in $50 notes so that they have to be changed to $20 and

$10 notes to gamble; timing of promotions; the time being advertised through in-

house announcements; staff encouraging people to get their own change by saying

they are busy; and some venues becoming non-smoking premises so smokers had to

go outside to smoke. However, most venues had gaming machines with $20 note

acceptors so walking to get change was less likely to be a measure encouraging breaks

in play.

Size was not a factor in the ten venues (71%) that had established strategies to

discourage extended, repetitive and intensive gambling. Five large and five smallvenues had these measures in place. In terms of sector, six were hotels, three were

clubs and one was a casino. The two venues (14%) where customers were not madeaware of the time were both small hotels. All three venues (21%) where staff are

permitted to keep tips were small, two being clubs and one a hotel.

In summary, all managers and staff were very aware of this practice area where itoverlapped with legislative requirements. This was evident in the practices of

excluding minors from gambling areas, excluding minors from gambling and in notserving intoxicated persons. Very few venues provided tray service of alcohol to

people gambling. Most managers and staff stated they encouraged customers to

recognise the passage of time and to take breaks in their gambling, yet this was notalways the case in practice. More hotels than clubs were likely to have strategies in

place to discourage extended, intensive and repetitive play. Large venues appeared

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more likely to have embraced responsible gambling practices in their physical

environment than the small venues.


All fourteen venues had a mixture of ATMs and EFTPOS facilities for financialtransactions. These facilities were usually located in the foyer, bar, bottle shop,

restaurant, bistro, and outside the main entrance. Only one venue (7%) had its ATM

in a bar, which also had gambling facilities. There was a wide range of limits abovewhich winnings are paid by cheque or electronic transfer. The range extended from

$250 to $10,000. Generally, the small venues had lower limits on cash payment forwinnings than the large venues. For example, six small hotels and clubs (43%) had

$600 or less as their limit, while six large hotels, clubs and the casino (43%) had

$1,000 or more as their limit. The most common limit, found in five venues (38%),was $1,000. Clubs had a higher average cash payout for winnings limit ($1,100) than

the hotel average of ($678).

The payment of winnings over $250 by cheque or electronic transfer for clubs andhotels, while being a practice of the Code, is also a legislative requirement. The

payment of winnings from casino table games by cheque or cash was excluded fromthis limit by their specific legislation. Maximum cash payout for casino winnings is

$10,000 ($50,000 in the private gaming areas). This policy also applies to gaming

machines, keno and the TAB. However, it does not apply to table games because it isnot possible to clearly identify proportion of winnings versus the original stake.

Winning cheques are not cashed at the casino for 24 hours.

While one large venue in this investigation had requested their limit of payment of

winnings by cash be reduced from $1,000 to $500 as a responsible gambling measure,

most venues had requested their limit be raised. This was because local competitionwas high, with some customers expecting wins to be cash payments in return for

gambling with cash. Some venue managers said that they encourage winners of largeamounts from the TAB to be paid by cheque at the same limits as for gaming

machines and keno.

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Gambling winnings paid by cheque were not cashed until the next day in every venue

visited. In eleven venues (79%), cashing cheques not payable to the venue wasprohibited. The other three venues (21%) had a variety of policies, but most cashed

small personal cheques for known locals, with the managers’ approval. One venue(7%) cashed known third party cheques. All fourteen venues (100%) prohibited

cashing multiple cheques and no venue provided credit for gambling.

Thus, all venues said that they had stringent financial transactions policies. Smallvenues usually had lower limits on payment of winnings in cash than the large

venues. On average, clubs had limits over $1,000 while hotels had limits under$1,000.


Advertising and promotions were undertaken by eleven of the fourteen venues (79%)

visited in south-east Queensland. These venues advertises in various media, including

radio, television, newspapers, newsletters, letterbox drops, external signs on buildings

and internal signage. Many of the eleven (79%) run promotions connected to rewards

systems and loyalty cards, with a few major prizes (e.g. holidays) and frequent minor

prizes (e.g. bottle of wine, voucher or meal). Most of these eleven venues reported

that they advertise entertainment, venue, food, beverage and events. They said they do

not concentrate solely on gambling activities. For example, one manager said that the

venue’s advertising policy was to focus on the whole venue with ‘one-third devoted to

venue facilities (such as air conditioning), one-third focused on food and beverage

and one-third on gambling’. Another venue has an 80/20 rule, in which 20% of

advertising is focused on gambling and 80% on other venue facilities and services.

Additionally, this venue purposely features older models (at least 25 years old) in

their advertisements, depicting a more mature market. In contrast, two managers

(14%) felt that gambling advertising and promotions should be banned. One of these

believed that advertising and promotions are ‘intrusive’ and ‘encourage people to

gamble more that they can afford’. Three venues (21%) that did no advertising had

signs noting the availability of their gambling facilities at the front of the building.

One manager said the venue conducted no advertising or promotions because of the

cost. This venue was struggling with a difficult financial situation.

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The eleven managers (79%) who advertised and promoted their venues stated that

their advertising would comply with the Advertising Code of Ethics. They maintainedthat they did not use false, misleading or deceptive advertising. One manager said that

all their promotions are ‘approved by the QOGR’ and do ‘not contravene the Trade

Practices Act’. By way of promotions, there were weekly and monthly members’

draws, spin and win on a wheel, a $5 gaming machine voucher when purchasing two

meals on a Saturday night, free raffles, prizes with redemption of points for loyaltyschemes, happy hours with cheap drinks, and the like.

The same eleven managers (79%) also suggested that their advertising did notmisrepresent the probability of winning a prize, give the impression that gambling

would lead to financial betterment, offend community standards, focus exclusively on

gambling, or target minors, the vulnerable or disadvantaged. One manager said thathis club had recently surveyed its members and that members thought, ‘that the club

is a good contributor to the community’, supporting the claim that its advertising did

not offend community standards. No venues claimed to use advertising that depicts orpromotes the consumption of alcohol with gambling. Finally, all managers indicated

they did or would gain the consent of people before publicising their name as prize-winners. Managers were very aware of their obligations under the Privacy Act 1988

Cth.

Advertising practices by size and sector are now considered. Eleven venues (79%)used advertising and promotions to attract customers into their premises. Of these,

seven were large and four were small venues. The three venues (21%), which ran noadvertisements or promotions all, had small gaming installations. Six of the eleven

venues were hotels, four were clubs and one the casino.

In summary, the majority of those interviewed (79%) reported that their advertisingand promotions complied with the Advertising Code of Ethics. Large venues were

more likely than small ones to advertise and promote. Hotels and the casino tended toadvertise and promote more than clubs. The three small venues (21%) who did little

to advertise or promote their venues were situated in very popular tourist areas so

their external signs would be seen by a large number of people.

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6.10 Adequacy of the Code in South-East Queensland

Venue managers and staff were asked their opinions of the adequacy or potentialeffectiveness of various aspects of the Code of Practice. Table 6.2 summarises these

results, with details discussed below.

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Table 6-2 Perceived Adequacy of the Code’s Practice Areas for South-East QLD

SMALL HOTEL LARGE HOTEL SMALL CLUBS LARGE CLUBS CA

CODE OF PRACTICE AREAS

12 16 17 18 7 10 14 5 6 13 9 11 15 8

Provision of adequate information &signage encourages responsiblegambling

D A A D A D A D A A D D A D

Support services are adequate toassist customers and the communitywho need help

DN A A A DN DN A DN DN A A A A A

Exclusion really encouragesresponsible gambling

A A D A A A A A DN A A D D A

Physical layout & environmentencourages responsible gambling

A A A A A A A A A A A D A A

Rules & limits on financial transactionsencourage responsible gambling

A D D A A A DN A A A A D A A

Advertising and promotions helppromote responsible gambling

A D A D A A A A A A A D A A

A – AGREE D – DISAGREE DN – DON’T KNOW

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Opinion on the adequacy of information and signage in encouraging responsiblegambling was evenly divided. Managers and staff in seven venues (50%) maintained

that information and signage was adequate and did assist in encouraging responsiblegambling. Their comments were:

ß ‘People probably read signs, especially in the toilets. They may help

people to think or slow down.’

ß ‘Yes, especially if they include gambling support services. The more

welfare agency notices the better.’

ß ‘Yes, I agree but only to a certain extent.’

ß ‘Signs probably help people make a little more informed decisions, but

they would not affect a problem gambler. Knowing the odds of winningmight redirect money into gaming machines with better odds, but people

would still spend the same.’

ß ‘Yes, I agree to a point. If you provide information, then at least peoplecan make an informed choice. It is hard to say if people use the

information provided.’

ß ‘All signage helps a bit, but people don’t read signs. We replace about 30

wallet cards in the toilets each week. Someone is taking them, so they are

beneficial’.

In contrast, managers and staff in seven venues (50%) felt that information and

signage would have little impact on encouraging responsible gambling. Theircomments included:

ß ‘While signage might be good, it has a low effect because people with

information overload don’t read signs.’

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ß ‘It is a waste of time. Gaming machine players are focused on the

machine; it is hard to get to them with peripheral signage.’

ß ‘If someone wants to gamble, then they will anyway. People don’t analyse

the odds of winning on different gaming machines. I don’t think peopleread responsible gambling signs.’

ß ‘People don’t read signs.’

ß ‘People don’t read signs. It might help having wallet cards in the toiletswhere people can pick them up without being seen.’

ß ‘The signage is adequate but not effective, as it does not target people with

gambling problems. Problem gamblers take no notice of these signs.Unless signs target the right people then this is not a solution for them.’

ß ‘People want to beat the odds, but knowing the odds does not helpespecially when they are after a major prize. Older people get lost in the

mathematics of trying to work out the odds. However it helps to put credits

in dollars on gaming machines.’

ß ‘Everyone is used to the red signs and don’t take any notice of them. The

signs need to change the same way any good advertiser would change theiradvertisements and signs’.

Making some distinctions amongst responses about the adequacy of this practice area,

the responses were compared between the large (50%) and small venues (50%). Thesewere equally divided. Of the seven large venues visited, three agreed and four

disagreed that the provision of appropriate information encourages responsiblegambling. Of the seven small venues, four agreed and three disagreed with this.

By sector, three clubs agreed and three clubs disagreed that adequate provision of

information encourages responsible gambling. Similarly, in the hotel sector (includingthe casino), four agreed and four disagreed that this practice area was potentially

effective. Thus, the perception of adequacy of this practice was evenly shared.

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The majority of managers and staff (64%) interviewed in the fourteen venues agreedthat there were adequate gambling related support services to assist customers and

members of the south-east Queensland community who need this help. In support, themajority observed:

ß ‘It is good to be able to refer people to these services but they are seldom

used.’

ß ‘There are enough services but they are not available 24 hours a day. It

could be that the at-risk people need help at say 5am.’

ß ‘Fifteen years ago there was nothing, but now it is a much better situation.There is a closer professional relationship with support agencies.’

ß ‘I agree that there are enough and may even be too many when people getconfused with different agencies. We had some feedback that the Helpline

was not that useful, so we keep Breakeven numbers displayed. People do

respond better with face to face counselling and the personal touch.’

ß ‘We have never had to use any of these agencies but they are there if

people need them.’

ß ‘Yes, but Gamblers Anonymous does not have the same credibility as

Alcoholics Anonymous’.

Based on size and sector, there was little difference in opinion between venues.Managers from five large venues and four small venues had similar opinions and

agreed that there were adequate gambling related support services to assist customersand the community. Based on sector, four hotels, four clubs and the casino agreed that

these were adequate.

Attitudes on the adequacy of this measure were shared almost equally by size andsector, although, in five venues (38%), the managers and staff interviewed did not

have an opinion about the adequacy of gambling related support services saying:

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ß ‘We have had no contact with them.’

ß ‘I’m not fully aware of local agencies that are around.’

ß ‘I haven’t had much to do with them.’

Two large and three small venues did not know if there were adequate gamblingrelated support services to assist customers and the community. Based on sector, three

hotels and two clubs made up this group. Thus, this lack of opinion was shared almost

equally by size and by sector.


Of the fourteen south-east Queensland venues visited, managers and staff from ten

venues (71%) agreed that self-exclusion for problem gamblers was a practice thatworked effectively; people in three venues (21%) thought that self-exclusion did not

work; while one (7%) had no opinion either way. Positive comments were as follows:

ß ‘Self-exclusion is a good responsible gambling tool. It is the first step,

when people recognise that they have a problem. Our club suggests that

they suspend membership for 6 to 12 months and exclude from all othervenues that they use. It is difficult to police self-excluded people. That is

why we prefer to suspend membership, but the onus is on the individual.’

ß ‘Self-exclusion gives members the impression that the venue is a

responsible organisation. The problems are that an individual needs to self-

exclude from other venues and it can be difficult to monitor people cominginto the venue.’

ß ‘It probably does work if they seriously believe they have a problem. Butthey could just go somewhere else.’

ß ‘Yes, the one excluded person has not been back.’

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ß ‘Yes and good procedures help, that is information packages for

customers, documentation, counselling and identity photographs.Cooperation between gaming staff, security, shift managers and legal staff

is important for effectiveness.’

ß ‘Self-exclusion contributes to, and backs up, the other practices, therefore

it assists responsible gambling in total. It should definitely be retained as

an option.’

ß ‘Yes, but it is very hard to police.’

ß ‘The three people that we have self-excluded from our venue have not

been back therefore we can assume that it works.’

Negative responses were:

ß ‘It is human nature to change your mind. This can cause tension betweenthe player and the facilitator.’

ß ‘Self-exclusion is very reactive. The damage has already been done as the

gambler has hit rock bottom. It is great that the self-exclusion option is inplace but it is not going to prevent someone becoming a problem gambler.’

ß ‘Self-exclusion needs adequate follow-up support over time thatstrengthens the initial decision to self-exclude. Otherwise a person is likely

to relapse.’

The one person who had no opinion either way responded that ‘it should work, but alot of it is self-help’.

In terms of size and sector, of the ten (71%) venues who agreed that exclusion forproblem gamblers really works, five were large and five were small venues. That is,

they were evenly divided based on size. However, some difference was detected in

terms of sector. Of the ten venues who agreed, one was a casino; six were hotels andthree were clubs. Thus, twice as many managers of hotels as clubs agreed that that

self-exclusion for problem gamblers was an adequate responsible gambling practice.

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Managers and staff in thirteen (93%) of the fourteen venues agreed that appropriatephysical layout and a light environment in gaming rooms encourage responsible

gambling, while one disagreed. Those who agreed stated:

ß ‘One entry and exit point is important. It is helpful if people do not have to

walk through the gaming area to get to other venue areas. Clocks are good

because people play gaming machines to time or money restrictions.’

ß ‘Yes, natural light, but most gaming rooms need to give players the

privacy they want. Tray service is seen a good service. It means that

people don’t have to get up.’

ß ‘Our gaming room here is like a fishbowl. This helps prevent extended

play, because people like privacy when gambling.’

ß ‘Yes, players don’t like people walking past seeing them. A lack of

privacy helps responsible gambling.’

ß ‘Yes, white gaming machines reflect light and raised light levels addgenerally to a lighter more natural environment.’

ß ‘Natural light helps, but people do not look around at clocks. I feel that thegambling environment should not be exciting or flashy.’

ß ‘A sense of time is important.’

ß ‘Dark gaming rooms are no good. Clocks, free tea or coffee and staff allhelp.’

ß ‘Many gambling venues are too dark, confined and removed from othervenue activities.’

ß ‘Natural lights and clocks are important so they can tell how long they

have been here.’

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ß I am very critical of gaming rooms where a person can walk in off the

street, where kids can see inside and flashy lights entice people in.’

The one manager who disagreed stated:

ß ‘While I have no problem with having windows and clocks in gamblingrooms, these really don’t make any difference, except make it more

pleasant and comfortable for customers. They won’t make a person

gamble more or less.’

Thus, the majority (93%) of venues agreed that a well thought out gaming room with

a light open environment would be effective in encouraging responsible gambling.


In the fourteen south-east Queensland venues, ten managers and staff (71%) agreed

rules and limits on financial transactions were adequate in encouraging responsiblegambling, people in three venues (21%) disagreed, while one (7%) had no opinion

either way. Positive responses included the following:

ß ‘Yes, I have often seen winners put winnings straight back in, either atthis venue or at another venue. It is amazing how often this happens.

Therefore it is effective. ATMs outside the gaming areas also make playersget up, look around and become aware of the time.’

ß ‘They do encourage responsible gambling, but how far can you go? If you

want to be totally responsible then have no ATMs, EFTPOS and nogaming machines! Banks could be more accountable by removing credit

card facilities. However cheque cashing restrictions are good.’

ß ‘Cheque cashing limits encourage responsible gambling. But cash

payments are the right of the player.’

ß ‘They help, definitely.’

ß ‘Yes, as a patron can’t put it back through; they must go to the bank.’

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ß ‘Cash limits for winnings payments help with a 24-hour cooling off

period. ATM locations outside the gambling room put some distancebetween the gambler and their money.’

ß ‘Casinos have different legislative requirements to hotels and clubs, butthey escort people off the premises if they have had a big win. This helps

with security on and off the premises and stops spur of the moment

gambling splurges. They offer to pay winnings by cheque or electronicbanking.’

ß ‘Not so much the location of ATMs, but rather they cannot access credit

cards is the measure that encourages responsible gambling. Cheque limitsare good, but are not a long-term solution.’

ß ‘I was going to raise my limit on paying winnings by cheque from $500 to$1,000 but changed my mind, as I would need to provide extra security to

get winning patrons home. Now I just try to give as much of the winnings

in a cheque as I can to limit cash payments and for security.’

ß ‘This is important with payouts of winnings, so that they don’t put it all

back in. We give them the option of taking it all in a cheque.’

ß ‘Limited cash payouts and cheque cashing helps’.

Managers and staff (21%) reported negatively:

ß ‘If they have the will, then they will get access to the cash.’

ß ‘The average bet here is between 48 – 65 cents, therefore they are not

affected by financial limits.’

ß ‘Machine denominations do not make any difference, neither do $50 or

$20 notes’.

In analysing differences based on size, of the ten (71%) venues who agreed that rules

and limits on financial transactions encourage responsible gambling, five were large

and five were small venues. That is, they were evenly divided based on size. They

117

were also nearly equally divided in terms of sector. Of the ten venues that agreed, five

were clubs, four were hotels and one a casino. Thus, judgment on the adequacy of this

measure was shared almost equally by size and by sector.


In response to the question ‘do you think that advertising and promotions can help

promote responsible gambling’, managers and staff in eleven venues (78%) said yes,

while three (21%) said no. Positive observations included:

ß ‘Hard core players probably don’t look at newspapers or newsletters

anyway.’

ß ‘Yes, we are big believers in ethical advertising. Marketing can be a very

effective responsible gambling tool.’

ß ‘Yes I agree but we don’t do any advertising.’

ß ‘If it is done correctly it should help.’

ß ‘Yes, we have changed all our advertisements, removing gambling anddrinking images. We send entertainment messages.’

ß ‘Ethical and responsible advertising helps, as does advice on how to

gamble responsibly and where to go for help.’

ß ‘I don’t think that people are that gullible to believe that everyone’s a

winner.’

ß ‘I agree, but only if the whole of industry adopts this stance. This is hardbecause some operators do not subscribe to responsible gambling therefore

our group (named) is somewhat disadvantaged by competing againstunethical operators. This is especially the case in Brisbane where some

gaming machine operators hand out gaming machine credit vouchers on

the street. However this is very hard to police.’

Negative observations included:

118

ß ‘Every consumer transaction is linked to a promotion somehow. You can’t

stop promotions. However, people do need to be responsible about themand we feel that this happens anyway.’

ß ‘Promotions over do it. Promotions encourage people to gamble more thanthey otherwise would and more than they can afford.’

ß ‘Some promotions do encourage people to gamble more that they

otherwise would.’

ß ‘Promotions can’t hurt. If someone has a problem, it is not going to

influence them anyway.’

There was little difference of opinion of the adequacy of this practice area based onsize or sector. Six large and five small venues had similar opinions and agreed that

advertising and promotions can help promote responsible gambling. Based on sector,five hotels, five clubs and a casino agreed with this. Thus, views on the adequacy of

this practice were shared almost equally by size and by sector.

Thus in descending order of importance, the majority of respondents in the south-eastQueensland interviews agreed that an appropriate physical layout and a well lit

environment for gaming rooms are a very important measure for encouragingresponsible gambling (93%); that responsible advertising and promotion can assist in

responsible gambling (78%); that self-exclusion is an effective practice that assists

problem gamblers (71%); that the Code’s rules and limits on financial transactionsalso facilitate responsible gambling (71%); and that there are adequate gambling

related support services (64%). The provision of information and signage did notreceive a great deal of support amongst managers in south-east QLD, with only 25%

of managers seeing it as a positive initiative.

Attitudes towards the adequacy of responsible gambling practices were not seen tovary much between gaming installation size or sector (hotel, club and casino). The

one exception was for self-exclusion, where twice as many managers of hotels asclubs thought that self-exclusion for problem gamblers was very effective in


119

6.17 Facilitators and Impediments for the Code in South-East Queensland

Managers and staff were asked for their opinions on any facilitators and barriers forthe widespread implementation of the Queensland Responsible Gambling Code of

Practice in south-east Queensland and its potential effectiveness in encouragingresponsible gambling. The responses presented below include points relating to which

practices are considered the most appropriate and inappropriate, as well as actions that

might be taken to facilitate the Code’s implementation and those which are seen to beimpeding implementation.

6.18 Facilitators

Respondents articulated the following points, which indicate their support for

elements of the Code. It is expected that such support is critical to the Code’s

acceptance in industry. They also mentioned some measures they consider have

greatly assisted in operationalising the Code in their venues:

ß ‘Training needs improvement. We need club managers involved, not ClubsQLD staff. Clubs QLD needs to make implementation of the Code part of

their membership and do an audit of their members. It is a goodopportunity to be proactive on legislation. Clubs QLD has a conflict of

interest between increasing membership and enforcing codes.’

ß ‘Training as vitally important. Our management committee is dedicated totraining. This is a huge commitment. They have trained everybody

including cleaners and back of house to demonstrate that this is a real teameffort. In some extreme cases they have done some interventions. But, I

believe it is far too early to measure the effectiveness of the Code of

Practice.’

ß ‘Better training, focused on practical applications to identify problem

gamblers and to deal with problem gamblers. Only managers have beentrained so far. Not all workers have been through training as it is so new.’

120

ß ‘Education of gaming staff and provision of information (the best

practice). Others I’m not certain about, but self-exclusion should be there.’

ß ‘Physical environment. If the room is like a fishbowl, people are not going

to gamble much.’

ß ‘Making sure all venues have support material and information, but they

need to freshen it up regularly so people keep noticing.’

ß ‘Signage, there in your face.’

ß ‘Financial transactions, staff training and self-exclusion. If promotions are

cut out some people might stop gambling. The physical environment less

so, as venues want to make customers comfortable, but we have noproblems with clocks and natural light.’

ß ‘Promoting financial transactions and self-exclusions. Card basedgambling could help if it was the only way to gamble, then the card could

be disengaged from time to time. This would require one common card.

We need to get banks involved to limit the number of transactions per dayper venue or amounts per day.’

ß ‘Physical environment. Types of financial transactions (no access to creditaccount) and staff training to be supportive of any patrons with problems.

Strong house policy.’

ß ‘Self-exclusion. But true problem gamblers won’t admit their problem andthere is nothing a venue can do about this. Therefore self-exclusion is not

targeting the true problem gamblers.’

ß ‘People ultimately need to be responsible for their own actions. They can

ask us for help but we cannot be responsible.’

ß ‘I have been working in hospitality a long time. We just offer people aservice for their own enjoyment. They make their own choices.’

121

As evident from the above comments, training, education and skills development of

gaming management and staff were perceived as being the most important facilitatorsin encouraging responsible gambling.

6.19 Impediments

Respondents expressed the following points indicating their lack of support for

elements of the Code which would seem to limit its industry acceptance. They also

mentioned some measures they consider have impeded the implementation of theCode in their venues:

ß ‘Signage could be more effective, for example, a sticker on the gaming

machines where they have to look.’

ß ‘People ignore signage.’

ß ‘Signage. This won’t have any impact on people with a problem. Theyshould get it into schools for education reasons. This is not going to

change behaviour by the time they are adults.’

ß ‘Advertising the odds of winning major prizes may encourage people totry to beat the odds.’

ß ‘It makes no difference telling people the odds of winning.’

ß ‘Knowing the odds, although people do have the right to know.’

ß ‘Not promoting gambling.’

ß ‘I don’t think that advertising gambling makes any difference, althoughmaybe promotions do.’

ß ‘Brochures and information, financial transactions, light and clocks, self-exclusion.’

ß ‘Moving ATMs away from the gaming area.’

ß ‘Physical layout; if you want to gamble you will.’

122

ß ‘Self-exclusion. Any manager would dread to have it put upon them to

baby-sit a bloke 35 years of age.’

ß ‘The media sensationalised problem gambling so most people never saw

themselves as having problems with their gambling, just occasionallyhaving some loss of control. People at risk do not see themselves as having

problems.’

From the above comments, provision of information, including signage and knowingthe odds of winning, was perceived to be the least potentially effective practice in


6.20 Summary

This final part of Section Six summarises the findings from the south-east Queensland

research in terms of awareness and implementation, perceived adequacy of the Code,and facilitators and barriers to its efficacy.


Thirteen (93%) of the fourteen venue managers and staff interviewed had receivedand were aware of the Queensland Responsible Gambling Code of Practice and the

Resource Manual. There appeared to be four levels of compliance with the Code –seven venues (50%) were committed and proactive; four (29%) were aware of, and

compliant with, the Code; two (14%) who were vaguely aware of, but had not read

the Code; and one venue (7%) which not received the Queensland Responsible

Gambling Code of Practice or the Resource Manual.

Seven committed venues (50%) provided gamblers with nearly all the informationoutlined in the Code, while the other seven (50%) provided less than half this

information. Large venues abided by the information practices of the Code more than

small venues, as did the hotels and the casino compared to clubs. The only area wheremost managers and staff (93%) had a clear understanding of this practice area was in

the importance of having problem gambling signage in place. Most venues couldassist people by providing contact details for gambling-related support services. Most

123

venues (79%) had staff trained in responsible gambling. However less than half (43%)

had any relationship with a gambling related support service or community networks.Large venues appeared better able than the small ones to provide customers with

assistance for, and information on, problem gambling. Similarly, large venues hadmore staff trained in responsible gambling than the smaller venues. Three-quarters of

managers and staff (79%) maintained they would offer customers seeking self-

exclusion relevant contact information for appropriate counselling agencies. Nine(64%) of these eleven venues had formalised their exclusion procedures, with seven

of these being large facilities. Managers and staff expressed concern for problem

gamblers and their families. However, a major barrier to supporting self-excludedcustomers was mutual exclusion from other gambling venues. All managers and staff

were cognisant of the legislative requirements included in the Code, such as excludingminors and intoxicated persons from gambling. Very few venues (21%) offered tray

service of alcohol to people gambling. Most interviewees contended that their

practices discouraged prolonged periods of gambling, but from observation, this wasnot always the case. More hotels than clubs were likely to have strategies to

discourage extended, intensive and repetitive play and large venues appeared morelikely than small ones to have embraced responsible gambling practices in their

physical environment. All venues said that they had stringent financial transactions

policies. Small venues generally had lower limits for cash payment of winningscompared to large venues, as did hotels compared to clubs.

The majority of respondents (79%) reported that their advertising and promotionscomplied with the Advertising Code of Ethics. Large venues were more likely than

small ones to engage in advertising and promotional activities, as were the hotels and

the casino compared to the clubs.

6.22 Adequacy

Opinions amongst the venue managers on the practice area, provision of information,in encouraging responsible gambling was evenly divided. Those in seven venues

(50%) felt it would have little impact, while the other seven felt the opposite. Analysis

by size and sector also revealed an even division of opinion between large and small

124

venues and between clubs and hotels. Nine managers and staff (64%) interviewed

considered there were adequate gambling related support services in the region, andattitudes on the adequacy of this measure were distributed almost equally by size and

sector. Of the ten (71%) venue managers and staff who agreed that self-exclusion forproblem gamblers works, five were large and five were small venues. However, there

were differences based on sector. Of the ten respondents who agreed, one was the

casino; six were hotels and three were clubs. Thus, twice as many managers of hotelsthan clubs thought that self-exclusion is a potentially effective measure. The

interviewees from most venues (93%) considered that an appropriate physical

environment in gaming rooms encourages responsible gambling. Respondents ineleven venues (78%) agreed that advertising practices could play a role in responsible

gambling, while three (21%) disagreed. Views on the adequacy of this practice areawere distributed almost equally by size and by sector.

Overall, the respondents perceived that:

• the physical environment of a gaming room is the most important practice areafor encouraging responsible gambling;

• ethical advertising and promotions are the next most important forencouraging responsible gambling;

• self-exclusion for problem gamblers is an effective practice that assists

problem gamblers and equally that rules and limits on financial transactionsencourage responsible gambling;

• there are adequate gambling related support services;

• the provision of information and signage may not be effective in encouraging

responsible gambling.

Perceptions of the adequacy of responsible gambling practices were not seen to vary

much between gaming installation size or sector (hotel, club or casino). The one

exception was for self-exclusion, where twice as many managers of hotels as clubs

considering that self-exclusion for problem gamblers was potentially very effective in


125

6.23 Facilitators and Impediments

The most frequently mentioned factor raised as being effective in encouragingresponsible gambling practices was training, education and skills development in

gaming management and staff. The most commonly mentioned factor consideredpotentially ineffective in encouraging responsible gambling was the provision of

information including signage and knowing the odds of winning.

126

SECTION SEVEN

7 CROSS-CASE ANALYSES OF THE THREE CASE STUDIES

7.1 Introduction

While Sections Four to Six presented findings from the case studies in the three

regional locations chosen for this study, this section presents a comparison of data in

relation to venue location, size and type. Because this study focused mainly on

qualitative information, data were collected from only thirty venues in total, an

insufficient quantity for statistical analyses. Nevertheless, it is instructive to examine

patterns that exist in the data. These are discussed below in terms of compliance with

the Queensland Responsible Gambling Code of Practice and perceptions of its

adequacy.

7.2 Compliance with the Code

Tables 7.1 to 7.3 illustrate the level of compliance with the Code by the 30 venuesexamined in this research. The tables are constructed by examining how many of the

elements in each of the six practice areas of the Code are complied with by the

venues. The percentage of compliance is also calculated for each element. Forexample, within the practice area, provision of information, there are ten possible

elements for venues to comply with and implement. It can be seen in Table 7.1 that

Venue 1 has complied with four of the ten elements or 40% of elements. In somecases, an element is not applicable to a particular venue. For example, Venue 1 does

not send promotional material to its patrons; therefore the fourth element in theexclusion practice area (gambling providers are not to send correspondence or

promotional material to gambling customers who are excluded or known to have

formally requested that this information not be sent) does not apply to this venue. Inthis situation, the percentage compliance with this practice is calculated by comparing

the number of elements complied with against the total number of elements applicableto the venue (not the total number of elements in the Code). For example, in the case

of Venue 3, there is a 33% compliance rate with the exclusion practice not 25%

because the venue does not undertake any advertising or promotions.

Table 7.1 Regional Location and Compliance with the Code

VenueInformation

(10)No. %

Interaction(8)

No. %

Exclusion(4)

No. %

Environment(8)

No. %

Fin Transaction(6)

No. %

Advertising(12)

No. %

Total(48)

No. %

1 4 40 1 12 0/1 0 5/1 71 4 67 0/12 - 14/14 41

2 4 40 0 0 0/1 0 6/1 86 4 67 0/12 - 14/14 41

3 5 50 2 25 1/1 33 6/1 86 4 67 0/12 - 18/14 53

4 3 30 2 25 2/1 67 7/1 100 4 67 0/12 - 18/14 53

Ave for Longreach 40 16 25 86 67 - 47

5 5 50 4 50 2 50 6 75 6 100 0/12 - 23/12 64

6 0 0 0 0 1 25 5 63 4 67 0/12 - 10/12 28

7 8 80 5 63 4 100 5 63 6 100 12 100 40 83

8 10 100 8 100 4 100 8 100 6 100 12 100 48 100

9 8 80 6 75 4 100 7 88 6 100 12 100 43 90

10 9 90 6 75 4 100 7 88 6 100 12 100 44 92

11 9 90 7 88 3 75 5 63 6 100 12 100 42 88

12 7 70 1 12 2 50 5 63 4 67 12 100 31/1 66

13 4 40 8 100 1 25 7 88 6 100 12 100 38 79

14 8 80 8 100 4 100 7 88 6 100 12 100 45 94

15 4 40 7 88 4 100 6 75 6 100 12 100 39 81

16 10 100 8 100 3 75 7 88 6 100 12 100 46 96

17 4 40 5 63 1 25 6 75 5 83 0/12 - 21/12 58

18 3 30 6 75 3 75 7 88 5 83 12 100 36 75

Ave for SEQLD 64 71 71 79 93 100 78

19 5 50 3 38 3 75 6/1 86 6 100 0/12 - 23/13 66

20 6 60 8 100 4 100 4/1 57 5 83 12 100 39/1 83

21 4 40 5 63 2 50 5/1 71 6 100 12 100 34/1 72

22 3 30 0 0 1/1 33 6/1 86 3 50 0/12 - 13/14 38

23 3 30 0 0 0/1 0 5/1 71 5 83 0/12 - 13/14 38

24 2 20 0 0 0/1 0 5/1 71 4 67 0/12 - 11/14 32

25 9 90 6 75 2/1 67 7/1 100 5 83 12 100 41/2 91

26 8 80 8 100 4 100 5 63 5 83 12 100 42 88

27 8 80 8 100 4 100 7/1 100 5 83 12 100 44/1 94

28 9 90 8 100 4 100 5 63 4 67 12 100 42 88

29 9 90 8 100 3 75 5/1 71 5 83 12 100 42/1 89

30 9 90 8 100 4 100 7/1 100 5 83 12 100 45/1 96

Ave for Townsville 63 65 67 78 74 100 73

Ave for all Venues 60 61 63 80 84 100 72

128

On average, the venues in this study had implemented 72% of the elements in the six major

practice areas. Clearly, the most commonly implemented elements were those that centredon the practice area of advertising. Ten venues indicated that they did not undertake any

advertising. The other 20 venues that did advertise reported that their advertising wasresponsible and adhered to all relevant aspects of the Code, resulting in 100% compliance

with this practice. However, there are two qualifiers that should be noted. The first is that

the researchers did not conduct an independent evaluation of the advertising practices in thevenues, but relied on self-reported data from the interviewees. As such, the researchers

cannot verify these self-reported levels of compliance with the practices in the Coderelating to advertising. Second, a number of managers and staff stated that other venues

were not being responsible in their advertising practices, with several examples cited.

Indeed, the researchers did encounter such breaches of the Code in their investigation,including some by venues who participated in the study and who nevertheless reported

compliance with the Code’s advertising practices.

In descending order, the next most complied with practices areas were financialtransactions (an average of 85%) and physical environments (an average of 80%). The

remaining three practice areas had lower levels of compliance. For example, there was anaverage of 63% compliance with exclusion provisions, an average of 61% compliance with

the practice area, interaction with customers and the community, followed by an average of

60% compliance with the elements in the practice area, provision of information.

7.3 Regional Location and Compliance with the Code

Table 7.1 also illustrates important regional differences in the level of compliance with theCode’s practice areas. In Longreach, the average level of compliance with all the elements

in the Code was 47% compared to an average of 73% in Townsville and 78% in south-east

Queensland. The compliance rate in south-east Queensland, in comparison withTownsville, is enhanced by the fact that the south-east Queensland sample included four

more small venues than the Townsville sample. As will be shown in Table 7.2, smallvenues are much less likely to have complied with the practices in the Code than large

venues. Given the difference in the level of compliance between large and small venues, it

appears that the compliance rate in south-east Queensland is even more positive than inTownsville, after taking the size of the venues in the respective samples into consideration.

129

The other interesting pattern to emerge from the regional comparison is that south-east

Queensland is much less flexible in regards to the financial transactions practice area thanthe remote and regional locations. For example, venues in south-east Queensland comply

with 94% of elements in this practice compared with 67% in Longreach and 85% inTownsville. This difference can probably be explained by the closer relationships that are

likely to exist between the customer and venue in regional and remote areas and also by the

fact that venues may act as surrogate banks in the more remote areas.

7.4 Venue Size and Compliance with the Code

Table 7.2 shows the differences in compliance rates between small and large venues. It isclear that these differences are quite marked, with small venues much less compliant with

the Code’s practices (56%) than large venues (85%). The overall difference in compliance

between small and large venues is due to major differences in three practice areas - theprovision of information, interaction with customers and the community, and exclusion

provisions. Differences in the other three practice areas are either non-existent or negligible.

Table 7.2 Venue Size and Compliance with the Code

VenueInformation

(10)No. %

Interaction(8)

No. %

Exclusion(4)

No. %

Environment(8)

No. %

Fin Transaction(6)

No. %

Advertising(12)

No. %

Total(48)

No. %1 4 40 1 12 0/1 0 5/1 71 4 67 0/12 - 14/14 41

2 4 40 0 0 0/1 0 6/1 86 4 67 0/12 - 14/14 41

3 5 50 2 25 1/1 33 6/1 86 4 67 0/12 - 18/14 53

4 3 30 2 25 2/1 67 7/1 100 4 67 0/12 - 18/14 53

5 5 50 4 50 2 50 6 75 6 100 0/12 - 23/12 64

6 0 0 0 0 1 25 5 63 4 67 0/12 - 10/12 28

12 7 70 1 12 2 50 5 63 4 67 12 100 31/1 66

13 4 40 8 100 1 25 7 88 6 100 12 100 38 79

16 10 100 8 100 3 75 7 88 6 100 12 100 46 96

17 4 40 5 63 1 25 6 75 5 83 0/12 - 21/12 58

18 3 30 6 75 3 75 7 88 5 83 12 100 36 75

19 5 50 3 38 3 75 6/1 86 6 100 0/12 - 23/13 66

22 3 30 0 0 1/1 33 6/1 86 3 50 0/12 - 13/14 38

24 2 20 0 0 0/1 0 5/1 71 4 67 0/12 - 11/14 32

Ave for Small 42 36 38 80 77 100 56

7 8 80 5 63 4 100 5 63 6 100 12 100 40 83

8 10 100 8 100 4 100 8 100 6 100 12 100 48 100

9 8 80 6 75 4 100 7 88 6 100 12 100 43 90

10 9 90 6 75 4 100 7 88 6 100 12 100 44 92

11 9 90 7 88 3 75 5 63 6 100 12 100 42 88

14 8 80 8 100 4 100 7 88 6 100 12 100 45 94

15 4 40 7 88 4 100 6 75 6 100 12 100 39 81

20 6 60 8 100 4 100 4/1 57 5 83 12 100 39/1 83

21 4 40 5 63 2 50 5/1 71 6 100 12 100 34/1 72

23 3 30 0 0 0/1 0 5/1 71 5 83 0/12 - 13/14 38

25 9 90 6 75 2/1 67 7/1 100 5 83 12 100 41/2 91

26 8 80 8 100 4 100 5 63 5 83 12 100 42 88

27 8 80 8 100 4 100 7/1 100 5 83 12 100 44/1 94

28 9 90 8 100 4 100 5 63 4 67 12 100 42 88

29 9 90 8 100 3 75 5/1 71 5 83 12 100 42/1 89

30 9 90 8 100 4 100 7/1 100 5 83 12 100 45/1 96

Ave for Large 76 83 85 79 91 100 85

Av for all Venues 60 61 63 80 84 100 74

131

7.5 Venue Type and Compliance with the Code

Table 7.3 outlines the rate of compliance with the Code according to venue type. Clearly, thecasinos in this study, with an average of 97% compliance, are much more compliant with the

Code’s practices than either the hotels or clubs. There appear to be few differences between clubsand hotels, with hotels complying on average with 67% of practices, and clubs complying on

average with 74%. The difference between hotels and clubs can probably be explained, to some

extent, by the fact that there were fewer small venues in the club sample than in the hotel sample.As noted previously, small venues had a lower average compliance rate than large venues.

The one practice area where there appears some difference between hotels and clubs is in

interaction with customers and the community. Clubs (67%) appear to be more proactive in

engaging with customers and the community than hotels (52%). It is difficult to explain this

difference, other than to surmise that links are stronger because of the community focus of clubs.

Table 7.3 Venue Type and Compliance with the Code

VenueInformation

(10) No. %

Interaction(8)

No. %

Exclusion(4)

No. %

Environment(8)

No. %

Fin Transaction(6)

No. %

Advertising(12)

No. %

Total(48)

No. %1 4 40 1 12 0/1 0 5/1 71 4 67 0/12 - 14/14 41

3 5 50 2 25 1/1 33 6/1 86 4 67 0/12 - 18/14 53

4 3 30 2 25 2/1 67 7/1 100 4 67 0/12 - 18/14 53

7 8 80 5 63 4 100 5 63 6 100 12 100 40 83

10 9 90 6 75 4 100 7 88 6 100 12 100 44 92

12 7 70 1 12 2 50 5 63 4 67 12 100 31/1 66

14 8 80 8 100 4 100 7 88 6 100 12 100 45 94

16 10 100 8 100 3 75 7 88 6 100 12 100 46 96

17 4 40 5 63 1 25 6 75 5 83 0/12 - 21/12 58

18 3 30 6 75 3 75 7 88 5 83 12 100 36 75

19 5 50 3 38 3 75 6/1 86 6 100 0/12 - 23/13 66

20 6 60 8 100 4 100 4/1 57 5 83 12 100 39/1 83

22 3 30 0 0 1/1 33 6/1 86 3 50 0/12 - 13/14 38

23 3 30 0 0 0/1 0 5/1 71 5 83 0/12 - 13/14 38

24 2 20 0 0 0/1 0 5/1 71 4 67 0/12 - 11/14 32

28 9 90 8 100 4 100 5 63 4 67 12 100 42 88

29 9 90 8 100 3 75 5/1 71 5 83 12 100 42/1 89

Ave for Hotels 58 52 59 77 80 100 67

2 4 40 0 0 0/1 0 6/1 86 4 67 0/12 - 14/14 41

5 5 50 4 50 2 50 6 75 6 100 0/12 - 23/12 64

6 0 0 0 0 1 25 5 63 4 67 0/12 - 10/12 28

9 8 80 6 75 4 100 7 88 6 100 12 100 43 90

11 9 90 7 88 3 75 5 63 6 100 12 100 42 88

13 4 40 8 100 1 25 7 88 6 100 12 100 38 79

15 4 40 7 88 4 100 6 75 6 100 12 100 39 81

21 4 40 5 63 2 50 5/1 71 6 100 12 100 34/1 72

25 9 90 6 75 2/1 67 7/1 100 5 83 12 100 41/2 91

26 8 80 8 100 4 100 5 63 5 83 12 100 42 88

30 9 90 8 100 4 100 7/1 100 5 83 12 100 45/1 96

Ave for Clubs 58 67 63 79 89 100 74

8 10 100 8 100 4 100 8 100 6 100 12 100 48 100

27 8 80 8 100 4 100 7/1 100 5 83 12 100 44/1 94

Ave for Casinos 90 100 100 100 92 100 97

Ave for all Venues 60 61 63 80 84 100 74

133

7.6 Perceived Adequacy of the Code

The level of compliance with the Code should logically be related to venue managers’ perceptionsof the value of the practices. That is, the more satisfied a manager is that the practices are likely to

be successful, the more likely he or she will comply with them. This study attempted to examine theperceived adequacy of the practices by asking venue managers how successful they believed the

practices would be in encouraging responsible gambling.

The practice area considered by venue managers and staff as being the most likely to succeed wasphysical environments. Managers and staff from 80% of venues agreed that this practice area is

likely to encourage responsible gambling. Interactions with customers and the community received

a 67% rate of approval from managers and staff, as did advertising. Sixty% of managers agreed thatthe practice area of financial transactions would promote responsible gambling, while 57% believe

that exclusion provisions would be successful. The least supported practice area, with a rating of40%, was the provision of information.

Table 7.4 Regional Location and Perceived Adequacy of the Code

Location of

venue

Provision of adequate

information & signage

encourages responsible

gambling

Support services are

adequate to assist

customers and the

community who need

help

Exclusion really


gambling

Physical layout &

environment


gambling

Rules & limits on

financial transactions

encourage responsible

gambling

Advertising and

promotions help promote

responsible gambling

A D DK A D DK A D DK A D DK A D DK A D DK

L’reach (4) 0 3 1 2 2 0 0 2 2 3 0 1 2 0 2 3 1 0

% - 75 25 50 50 - - 50 50 75 - 25 50 - 50 75 25 -

SEQLD (14) 7 7 0 9 0 5 10 3 1 13 1 0 10 3 1 11 3 0

% 25 25 - 64 - 36 71 22 7 93 7 - 71 22 7 78 22 -

T’ville (12) 5 6 1 9 2 1 7 4 1 8 2 2 6 6 0 6 3 3

% 42 50 8 75 17 8 59 33 8 66 17 17 50 50 - 50 25 25

Total (30) 12 16 2 20 4 6 17 9 4 24 3 3 18 9 3 20 7 3

% 40 53 7 67 13 20 57 30 13 80 10 10 60 30 10 67 23 10


135

7.7 Regional Location and the Perceived Adequacy of the Code

Table 7.4 also shows regional differences in the perceived adequacy of the Code. In comparison toall venues, managers and staff in Longreach were less positive about the practices, with the

exception of advertising. The high level of support for responsible advertising in Longreachoccurred despite the fact that none of the venues in the town undertook any advertising.

Venue managers and staff in Townsville were most positive about the practice area of interaction

with customers and community. The high level of support for this practice amongst Townsvillerespondents is probably indicative of the active cooperation that exists between some gambling

providers and the local community support sector.

Club managers and staff in south-east Queensland were generally more positive about the practices

than managers and staff in the other two regions, with the exception of provision of information and

interaction with customers and the community. This more positive view amongst club managers andstaff in south-east Queensland could be a result of easier access to the Code, a transfer of supportive

attitudes to responsible gambling from southern states, and the higher level of training in

responsible provision of gambling undertaken in the region.

7.8 Venue Size and Perceived Adequacy of the Code

Table 7.5 shows differences in the views about the potential effectiveness of the Code’s practicesbetween small and large venue managers and staff. Clearly, except for the practice of physical

environments, managers and staff at small venues are less sure of the value of the Code's practices

than managers and staff in large venues. This would suggest that the government, Clubs QLD andthe QHA should increase the exposure of small venues to the benefits of the Code in order to

increase compliance by small gambling establishments.

Table 7.5 Venue Size and Perceived Adequacy of the Code

Size of

venue

Provision of

adequate information

& signage

encourages



adequate to assist

customers and the

community who need

help

Exclusion really

encourages


Physical layout &

environment

encourages


Rules & limits on


encourage


Advertising and

promotions help

promote responsible

gambling


Small (14) 4 8 2 8 2 4 6 4 4 11 1 2 7 5 2 8 5 1

% 29 57 14 57 14 29 42 29 29 79 7 14 50 36 14 57 36 7

Large (16) 8 8 0 12 2 2 11 5 0 13 2 1 11 4 1 12 2 2

% 50 50 - 75 12 12 69 31 - 81 13 6 69 25 6 75 12 12

Total (30) 12 16 2 20 4 6 17 9 4 24 3 3 18 9 3 20 7 3

% 40 53 7 67 13 20 57 30 13 80 10 10 60 30 10 67 23 10


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7.9 Venue Type and Perceived Adequacy of the Code

There are some important differences between the perceptions of managers and staff in hotels and

those in clubs (see Table 7.6). Club managers and staff are more positive about all the practice

areas, except for exclusion provisions. Again, the more positive attitude amongst club personnel

may be an explanation for the higher level of Code compliance in the club sector. It is difficult to

find an explanation for the differences in perceptions between club and hotel managers and staff,

other than perhaps historical and cultural differences between the sectors.

Table 7.6 Venue Type and Perceived Adequacy of the Code

Type of

venue

Provision of

adequate information

& signage

encourages



adequate to assist

customers and the

community who need

help

Exclusion really

encourages


Physical layout &

environment

encourages


Rules & limits on


encourage


Advertising and

promotions help

promote responsible

gambling


Hotel (17) 6 9 2 11 2 4 10 4 3 13 1 3 7 7 3 10 5 2

% 35 53 12 65 12 23 59 23 18 76 6 18 41 41 18 59 29 12

Club (11) 5 6 0 8 1 2 5 5 1 10 1 0 9 2 0 8 2 1

% 45 55 - 73 9 18 45 45 9 91 9 - 82 18 - 73 18 9

Casino (2) 1 1 0 1 1 0 2 0 0 1 1 0 2 0 0 2 0 0

% 50 50 - 50 50 - 100 - - 50 50 - 100 - - 100 - -

Total (30) 12 16 2 20 4 6 17 9 4 24 3 3 18 9 3 20 7 3

% 40 53 7 67 13 20 57 30 13 80 10 10 60 30 10 67 23 10


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7.10 Conclusion

This section has provided a cross-case analysis of the level of compliance with and the perceived

adequacy of the Queensland Responsible Gambling Code of Practice. Generally, the level ofcompliance with the practices of the Code is variable, with some venues more compliant than

others. Clearly, small venues and venues in remote locations are much less likely to be compliant

with the Code. The data also suggest that casinos have a higher level of compliance than eitherhotels or clubs.

Location, venue size and venue type also appear related to perceived adequacy of the Code. Thedata suggest that managers and staff in Longreach are less convinced about the potential

effectiveness of the Code’s practices than managers and staff in the other two regions. In addition,

managers and staff in small venues are generally less positive about the practices than theircounterparts in large venues. Managers and staff in clubs, with the exception of the exclusion

practice area, have a more optimistic attitude towards the adequacy of the practices than hotel

personnel. It is quite likely that there is a relationship between the level of compliance and theperceived effectiveness of the practices. However, this link cannot be confirmed statistically in this

research.

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SECTION EIGHT

8 CONCLUSIONS

8.1 Introduction

The Queensland Responsible Gambling Code of Practice was launched in May 2002 with the aim

of ensuring that gambling environments are safer and more supportive for consumers. Developed bythe Queensland Responsible Gambling Advisory Committee, this voluntary Code advocates that

gambling providers implement a range of responsible gambling practices in six broad areas -

provision of information, interaction with customers and the community, exclusion provisions,physical environments, financial transactions, and advertising.

The aim of this project was to assess the perceived efficacy of the responsible gambling practices

contained in the Queensland Responsible Gambling Code of Practice in selected Queensland hotels,casinos, and licensed clubs. Specifically, the project measured and compared gambling operators’

awareness and perceived adequacy of the provisions in the Code, and facilitators and impedimentsto implementing the Code and to meeting its objectives. Four research objectives were addressed in

this study to achieve this aim, as identified in Section 1.2. This ensuing discussion outlines the

conclusions drawn from this study, according to these four research objectives.

8.2 Results for Research Objective 1

The first research objective was to identify those elements of the Queensland Responsible

Gambling Code of Practice that are and are not being implemented in the selected hotels, casinos

and licensed clubs in the three case study areas – Longreach, Townsville and south-east

Queensland.

Of the six practice areas in the Code, the one most commonly reported as being implemented

related to advertising. This practice area advocates for ‘gambling providers to develop andimplement strategies to ensure advertising and promotions are delivered in a responsible manner

with consideration given to the potential impact on people adversely affected by gambling’

(Queensland Treasury, 2002b). While managers of all the venues reported they complied with theCode’s suggested advertising practices, there were distinct differences between the usage of

advertising and promotions by venues in heavily populated and sparsely populated locations. Mostvenues in heavily populated locations engaged in advertising and promotions, yet little advertising

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and promotions were found in sparsely populated locations. Twenty venues, or 66% of those

visited, all based in heavily populated locations, used advertising and promotions to attractcustomers. Managers and staff in these venues stated that their advertising was responsible,

resulting in a 100% implementation rate with this practice area. However, as previously noted, theresearch team did not verify these self-reports through independent evaluation. Further, several

venue personnel reported other venues which were being less than responsible in their advertising

and promotions. Field observations could not confirm or disaffirm this, but evidence was found insome local newspaper advertising that either raised questions about the veracity of some

respondents’ answers to these questions or raised questions about their understanding andimplementation of this area of the Code. Indeed, the Queensland Responsible Gambling Advisory

Committee has established a working party to further progress understanding in this area.

The practice area of financial transactions had an average implementation rate of 85% amongst thevenues. Venues in south-east Queensland were much more likely to have implemented all elements

of the financial transactions area of the Code than those located in the other two case study areas.

Hotels and clubs in more remote areas tend to personally know their customers and so are morewilling to operate as surrogate banks for them, particularly where banking services are scarce. Thus,

they are more likely to cash personal, third-party and multiple cheques for these customers.

The practice area relating to physical environments had an average of 80% implementation rate.

Venues in the remote location were closest to having this practice fully implemented, compared to

those in regional and city centre locations. The remaining three practices in the Code, provision ofinformation, interaction with customers and the community, and exclusion provisions, had lower

levels of implementation. On average, there was 63% conformity with the exclusion provisions,61% conformity with practices relating to interaction with customers and the community, and 60%

conformity with the provision of information practices in the Code. For each of these practices,

venues in the remote location of Longreach had by far the lowest levels of implementation of theelements in these practice areas.

Based on venue type, implementation of all measures contained in the Code in the casinos thatparticipated in this study was very high. The casinos had implemented 97% of the Code’s practices,

while the clubs had implemented 74% and the hotels had implemented 67%. There were few

differences in the implementation of the Code between clubs and hotels, except in the practice areaof interaction with customers and the community. In this practice area, clubs had a higher level of

implementation than hotels, 67% compared to 52%. This may be because clubs are considered as

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community-based organisations whose not-for-profit status is based on their links with, and support

for, their local communities. Nevertheless, the compliance rates for both the clubs and hotels werefound to be less than optimal.

The difference in the implementation of the Queensland Responsible Gambling Code of Practice

between venues with small gaming installations and large gaming installations is stark. Venues with

small gaming installations had implemented 56% of the six major practices in the Code, while

venues with large gaming installations had implemented 85% of these practices. Prominentdifferences in implementation rates relate particularly to the practice areas of provision of

information, interaction with customers and the community, and exclusion provisions. That is, smallvenues were much less likely to have adhered to these three practices areas compared to large

venues. The lowest implementation rate, 36%, was for interaction with customers and the

community. These same three practices (provision of information, interaction with customers andthe community, and exclusion provisions) also had low implementation rates based on location,

where remoteness was associated with having a lower implementation rate. Implementation

differences between the other three major practices in the Code, physical environments, financialtransactions and advertising, were minor.


The second research objective was to assess the perceptions of key staff in the selected venues of

the adequacy of the Code to provide an indication of its potential effectiveness from a venue

perspective.

The aspect of the Code considered most adequate, with 80% agreement, was based on physical

environments. Interaction with customers and the community and responsible advertising andpromotions both received a 67% rate of approval from managers and staff. Managers in 60% of the

venues agreed that financial rules and limits were adequate to promote responsible gambling, while

57% believed that exclusion provisions are appropriate. Respondents were generally not convincedthat the provision of information and signage was adequate to support responsible gambling. While

some interviewees considered that people generally do not read signs, others felt that the currentGambling Helpline signs need changing on a regular basis to optimise their impact.

Based on regional differences, managers and staff in Longreach were less positive about the

adequacy or potential effectiveness of most of the practices in the Code. Managers and staff inTownsville were very positive about the adequacy of their interaction with customers and support

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services networks. In south-east Queensland, the physical layout and environment practice area was

perceived as the being the most potentially effective measure in the Code.

Perceptions of the Code’s adequacy and potential effectiveness based on size of gaming installation

showed differences between venues with small and large gaming installations. Except for thepractice of physical layout and environment, managers and staff with small gaming installations

were less favourable towards and optimistic about the Code than those with large gaming

installations. Venues with large gaming installations were evenly divided for and against on theadequacy of the provision of information practice area.

Based on type of venue, managers and staff in clubs were more positive about the adequacy andpotential effectiveness of all practices in the Code except for the exclusion provisions. Managers

and staff in casinos were evenly divided in their opinions about the adequacy and potential

effectiveness of the practices relevant to provision of information, interaction with customers andthe community, and physical environments.

Throughout the research, individual respondents made suggestions to improve the adequacy of

certain aspects of the Code or mechanisms that support its effectiveness. Apart from those alreadyidentified, these comprised: constantly updating details of support providers; ensuring that helpline

numbers are accurate; having adequate numbers of counsellors to respond to helpline callers;publicizing the Code widely in the venues and to the public; and developing regional self-exclusion

networks with support services.


The third research objective was to identify factors facilitating and impeding the implementation of

the Queensland Responsible Gambling Code of Practice.

Several facilitators were found to heighten compliance with the Code, thus assisting in its effective

implementation:

ß First, a very important facilitator, was seen to be staff training, education and developmentin the provision of responsible gambling. Respondents in south-east Queensland and

Townsville rated staff training and education as having the highest priority in effectiveimplementation of the Code. Well-informed, professionally trained staff that understood the

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Code and could apply requirements of the Resource Manual were seen as assets in these

gaming venues.

ß A second facilitator encouraging implementation of the Code was being a member of an

industry association. Members had received the Code from their hotel or club association,and were mostly knowledgeable and aware of the Code and its contents. They usually knew

about, or had undertaken, staff training with the association, and used the Resource Manual

proformas when necessary. Attendance at association conferences and seminars meant theyhad ongoing opportunities for continuous improvement and professional development in

their management of responsible gambling issues. Association commitment to the Code andmember commitment to the Code were significant in facilitating the implementation of the

Code.

ß A third facilitator for assisting in achieving high compliance with the Code was a soundunderstanding of the philosophy behind the Code. The Code makes explicit that gambling

providers are expected to provide a safe and supportive gambling environment to minimise

the potential for harm associated with gambling and to allow consumers to make informeddecisions about their gambling. The Code does not expect gambling providers to be able to

identify problem gamblers or to act as counsellors. An accurate understanding of thisconcept led committed managers and staff to realise that their role in implementing the Code

was less complex than they may have first thought. Equally, venue managers and staff who

misunderstood the philosophy underpinning the Code were deterred by the misguidedprospect of having to ‘baby-sit’ or counsel patrons.

ß Support materials were a fourth important facilitator for venues complying with the Code.Signs and wallet cards supplied by the QOGR or its agents were seen by some managers and

staff as important reminders for people who were at risk with their gambling. Committed

managers had re-ordered support materials, such as wallet cards for their toilets or signs thathad been pulled down. Equally, the Resource Manual accompanying the Code was

considered valuable in helping venues to operationalise the Code’s practices and insupplying them with proformas they could adapt for their own venues.

ß A fifth facilitator in compliance with some practices in the Code was legislation. There was

very high compliance with elements of the Code that are legal obligations for gamblingproviders. In contrast, there was variable compliance with voluntary aspects of the Code. As

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well, some managers and staff considered that, if the voluntary Code was not a success, they

may face the same situation as that in New South Wales, where responsible gambling isgoverned by much more stringent legislative requirements.

ß Experience in the provision of responsible gambling was a sixth factor assistingimplementation of the Code. In some venues, managers and staff had previously worked in

gambling venues in New South Wales and so had some experience with responsible conduct

of gambling. They had often been well-trained in this area, understood their role inresponsible gambling, knew how to operationalise responsible gambling practices, and

realised the possible negative consequences for non-compliance with a voluntary code. Theimport of professional experience was an important advantage for these venues.

ß Audits of venues were a seventh factor encouraging compliance with the Code. Audits can

remind venues of their responsible gambling duties and encourage them to reintroduce anypractices that have become neglected. Audits also provide some performance measures to

target. Communicating the results of audits publicly might further encourage some of the

committed venues, by showing that their efforts are recognised by industry, government andsupport services. Equally, this could encourage non-compliant venues to improve their

responsible gambling practices.

ß Finally, in some venues, especially in Townsville, links to community support services were

important facilitators towards implementing the Code. A group of committed managers and

staff had developed a solid relationship with a support service and, through opencommunication, were working on the exclusion aspect of the Code. This involvement built a

sense of confidence and trust between the parties. Their cooperation was a model that couldbe emulated in other communities.

Several barriers were found to hinder compliance with the Queensland Responsible Gambling Code

of Practice, thus preventing its effective implementation:

ß The first barrier related to staff in gaming venues. Many venues managers reported that high

staff turnover was factor in not having staff trained in responsible gambling. This is a featureof the hospitality industry generally, but had poor consequences for the implementation of

the Code. Compounding this turnover problem was the fact that staff training was not

readily available in remote and regional locations. Managers and staff in Longreach andTownsville had major concerns about the dearth of staff training and skills development for

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hospitality in general and for gaming in particular in regional and remote areas. Due to the

apathy of some managers and staff, high staff turnover, or the tyranny of distance in remoteregions, on average less than half the managers and staff interviewed had undertaken

training and education in responsible provision of gambling.

ß Not being an association member is a second barrier in implementing the Code. Industry

associations provide many services, such as professional assistance, resources, advice, and

training and education for their members. These are the same types of services andassistance needed to support those venues with the lowest implementation of the Code, as

seen amongst venues with small gaming installations. As well, association members areregularly sent current information on all gambling matters by their association, including

copies of the Code and the Resource Manual. Generally, members of industry associations

were more aware and informed about the Code than those who were not members.

ß A third barrier to implementing the Code is the apathy of some managers towards it. Some

managers do not consider the Code as relevant to their venue. Some consider that, as they

have only a small gaming installation, not a large critical mass of gaming machines, theCode does not apply to them. They feel that parts of the Code, such as advertising and

promotions, are not relevant as their venue does very little of either. As well, some managerswith small gaming installations are not particularly interested in the Code, as gaming is a

small part of their overall business. Also, many of these know their customers well and feel

that they would know if one was having gambling-related problems. These managers wouldtherefore intervene personally, with some considering that some procedures in the Code

were too formal for their venue. The fact that most venues have video surveillance or cansee into the gaming area from the bar means that they do, in fact, have control through

visibility of their gaming. However some of these managers think that responsible gambling

is not an issue when they can personally see what their customers are doing.

ß In remote areas, a fourth barrier is location, being west of the Dividing Range. Managers

and staff felt they were ignored in important decision making, that city-centric managersmade decisions for the large population centres without due consideration for consequences

in remote locations. There was some cynicism about decisions that come from Brisbane. As

well, the lack of counselling agencies to advocate change is an important barrier connectedto remote locations. Counselling services for problem gambling assistance in remote areas

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are physically few and far between. This means that building long-term relationships

between venues and support services is not an easy task.

ß A fifth barrier is the busy nature of work for owner-managers in venues with small gaming

installations. These owner-managers ran their businesses, generally small businesses, withfew staff and limited resources. Thus, some knew about the Code and Resource Manual, but

claimed they had not had time to read it, let alone implement its practices.

ß Another barrier is that some managers felt that the competitive advantage of their venuewould be compromised if they implemented certain elements of the Code, if their

competitors did not. This sixth barrier indicates a perception amongst some providers thatimplementing the Code would have adverse consequences for their trade, and reflects the

potential conflict between commercial and social objectives.

ß Finally, a seventh barrier to implementing the Code is that some managers said that they hadnot received it or the Resource Manual. It appears that their copies were sent to the owner of

the venue or the chain of venues, not the actual manager or licensee of the premises. In

outback Longreach, only half the venue managers said that they had received a copy of theCode and the Resource Manual. In Townsville, individual venues that were part of a hotel

group had not received the Code. In south-east Queensland, one venue that had been closedtemporarily due to managerial problems, high staff turnover and financial difficulties had no

copy of the Code or the Resource Manual.


The fourth research objective was to recommend a range of options to encourage further

implementation of the Code. These recommendations are presented in a separate section, Section

Nine, for easy reference.

8.6 Conclusion

This section has presented the conclusions of this study, based on the study’s four researchobjectives. The next section provides eighteen recommendations based on the conclusions drawn in

Section Eight.

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SECTION NINE

9 RECOMMENDATIONS

Based on the conclusions in Section Eight, this section provides the following recommendations toimprove the implementation and potential effectiveness of the Queensland Responsible Gambling

Code of Practice, to inform current policy, and to assist later evaluations of the Code, includingthose planned by Queensland Treasury (2003a) in its review of the Code over its first five years of

implementation.

1. That the Queensland Government, Clubs QLD and the QHA investigate ways toimprove compliance with the Code amongst clubs and hotels in Queensland

generally.

2. That the Code be better publicised in gambling venues and in the media.

3. That the Queensland Responsible Gambling Advisory Committee investigate ways

that information on responsible gambling, problem gambling, and counsellingservices can be disseminated more widely to maximise awareness and knowledge of

these in the community.

4. That research be conducted to demonstrate the actual effectiveness of the Code inminimising the harm associated with gambling and in allowing people to make

informed decisions about their gambling.

5. That the Queensland Government, Clubs QLD and the QHA investigate ways to

improve communication of the benefits of the Code amongst venue managers and

staff, particularly those in remote areas and in venues with small gaminginstallations.

6. That the Queensland Government, Clubs QLD and the QHA investigate ways toimprove compliance with the Code amongst venues with small gaming machine

installations, particularly in the practice areas of provision of information, interaction

with customers and the community, and exclusion provisions.

149

7. That the Queensland Government, Clubs QLD and the QHA investigate ways to

increase compliance in remote areas with the practice areas of provision ofinformation, interaction with customers and the community, and exclusion

provisions.

8. That research be undertaken to develop the most effective venue-based signage and

information on responsible gambling, problem gambling, and counselling services.

9. That gambling-related support services be encouraged to be more proactive inliaising with gambling providers in their region, in providing their contact details,

and in establishing mechanisms to encourage community networks that promoteresponsible gambling.

10. That the Gambling Helpline ensures it has the capacity to respond to all calls

effectively and in a timely manner.

11. That the Queensland Responsible Advisory Committee investigates the development

of regional mutual self-exclusion mechanisms.

12. That regional strategy for remote locations in the cheque-cashing elements containedin the financial transactions practice area be considered for inclusion in the Code.

13. That the Queensland Government, Clubs QLD and the QHA organise for morefrequent staff training in responsible gambling in regional and remote areas of

Queensland and ensure widespread publicity about these to clubs and hotels.

14. That further research be conducted into the advertising and promotions practices ofgambling operators and their understanding of what constitutes responsible and

irresponsible advertising and promotions practices.

15. That the Queensland Government or its agencies conducts regular audits of venue

compliance to the Code, with feedback to gambling venues, to establish best practice

standards, to remind venues of their duties and to identify instances where help withimplementing the Code is needed.

150

16. That the Queensland Responsible Advisory Committee, Clubs QLD and the QHA

regularly review the Resource Manuals and support materials for the Code, withimprovements based on venue feedback, sound research and wide consultation.

17. That Clubs QLD and the QHA investigate ways to optimise their membership ratesand find further ways to liaise with non-member clubs and hotels on responsible

gambling matters.

18. That Clubs QLD and the QHA review their mailing lists to ensure responsiblegambling materials are sent to all managers of clubs and hotels in Queensland.

151

SECTION TEN10 ACTIONS ALREADY UNDERTAKEN

The authors of this report acknowledge that a number of the recommendations made in chapter nine

have been addressed by the Queensland Office of Gaming Regulation in the period between the

collection of the data and presentation of the report. These initiatives are noted below.

10.1 Responsible Gambling Advisory Committee

The Responsible Gambling Advisory Committee (RGAC) has adopted an active approach in

dealing with the issues relating to the implementation of the Queensland Responsible Gambling

Code of Practice (the Code of Practice). They have:

• provided advice on the development of the trial and review of the effectiveness of the Code

of Practice

• developed signage about the potential risks of gambling as well and information about


• created processes and pathways for dealing with impediments to the Code of Practice.

RGAC industry peak bodies’ have been responsible for developing the Responsible Gambling

Resource Manual, in consultation with Queensland Treasury, ensuring that the guides to

implementing responsible gambling practices are relevant and appropriate to each industry’s

environment.

Working parties, comprised of RGAC members, were developed as mechanisms to resolve complex

issues and determine, where appropriate, minimum standards. The RGAC has established the

Advertising and Promotions Working Party to develop guidelines on the implementation of

responsible gambling advertising and promotions, taking into account issues raised by key

stakeholders and the general public.

The guidelines will include examples of advertisements and promotions which adhere to the Code

of Practice and examples which do not adhere to the Code of Practice. The Working Party has also

been taking into account issues raised by key stakeholders and the general public.

In developing the Code of Practice, the RGAC was aware of the sensitive nature of practices

relating to exclusions and established a working party consisting of community, industry and

152

government representatives to address issues including legislative support required to effectively

implement exclusion provisions. Since the launch of the Code of Practice, this working party (the

Exclusions Focus Group) has developed a proposal for a preferred legislative model. This would be

supported by operational protocols which could be used to implement a new exclusion regime in

Queensland for people who have a problem with gambling.

10.2 Responsible Gambling Training

QOGR has conducted an internal review of the effectiveness of the implementation of the Code of

Practice. The findings of the review concurred that one of the significant impediments to the

implementation of the Code of Practice are the issues surrounding the provision of responsible

gambling training. Clubs Queensland (Clubs QLD) and Queensland Hotels Association (QHA)

undertook to provide training and support to all clubs and hotels in Queensland. Despite this

commitment, a range of issues arose regarding the effectiveness of the training, including:

• the geographic dispersion of venues

• difficulties for small gambling providers in being able to take time away from the business

to attend training and/or afford the training

• discrepancies in the quality of training provided to staff

• lack of relevance to the staff.

Mailing lists for the distribution of Resource Manuals and other related responsible gambling

resources and training information was provided by QOGR to the peak bodies ensuring coverage of

all venues, not only members of a peak body. Concurrently, this provided an opportunity for the

peak bodies to increase their membership base through having contact with non-members during

training.

The Responsible Gambling Training Framework for Industry, launched on 15 August 2003,

provides learning outcomes, criteria and statewide benchmarks designed to support training

providers in the development of their responsible gambling courses. The framework will supply a

consistent approach for clubs and hotels in the training undertaken and enhance QOGR’s capacity

to evaluate a venue’s responsible gambling skills base.

153

Phase 2 of the review is currently in development. Phase 2 will primarily focus on developing

strategies to create a cultural shift making responsible gambling an inherent part of business. In

addition, Phase 2 will create strategies to mitigate the issues identified as impeding the

implementation of the Code of Practice. Initiatives proposed include:

• development of a training package on CD-ROM to assist venues who cannot attend training

sessions; and

• organising more training sessions for regional areas, including Longreach and Mount Isa.

10.3 Need for Variations to Practices in the Code of Practice in Particular Circumstances

For effective implementation of the Code of Practice to occur, all gambling providers must be

responsible for, and committed to, the Code of Practice, regardless of their geographical location or

size. There may be some practices in the Code of Practice, however, which need to be varied by

some smaller gambling providers and/or for gambling providers in particular circumstances.

For example, QOGR has determined it reasonable for gambling providers located in areas where

there are no banking facilities to cash certain cheques without prior arrangements, even though this

may contravene a practice in the Code of Practice. In developing the Code of Practice, the RGAC

considered this issue and included a statement where gambling providers have an obligation to

respond to the needs of their local community, including taking account of geographical and

cultural diversity.

In preparing strategies to address issues associated with the diversity of venues, QOGR has deemed

a risk assessment approach appropriate, giving consideration to measuring the capacity of gambling

providers to respond to problem gambling within the context of the broader environment.

10.4 Awareness and Education of the Code of Practice

A number of issues were highlighted throughout the report regarding the effectiveness of the

various communication strategies at reaching a number of target groups, for example small venues

and remote and regional venues. In respect to addressing these issues, a number of educational and

awareness strategies have been implemented by QOGR to promote the Code of Practice to venues,

including:

154

• initial signage provided free of charge to every hotel and club in Queensland (excluding

casinos)

• initial training and Resource Manuals provided by Clubs QLD and QHA to all venues in

Queensland, either during training or mailout

• mailout sent to every gaming machine venue in Queensland notifying them of their

responsible gambling obligations and signage requirements

• regular two-page spread in the quarterly QOGR newsletter promoting best practice in


• development of a Responsible Gambling website as a central information resource with

links to the Code of Practice, the Resource Manual and frequently asked questions and

answers

• regional Responsible Gambling Advisory Committee meetings held to promote the shared

role of community, industry and Government and to provide stakeholders with the

opportunity of engaging with the RGAC to explore issues.

Further communication strategies in development are:

• inclusion of Gambling help-services insert in the Phase 2 survey to provide information on

the services available, locations and contact details

• development of a resource package for new licensees to inform them of their responsible

gambling obligations

• mailout to all venues notifying them of amendments made to the Code of Practice since

implementation

• updating the Responsible Gambling website to make it more user-friendly for clients

As part of the Phase 1 Review of the Code of Practice - effectiveness of implementation, self-audit

surveys was sent to every club and hotel in Queensland, when they were due to be inspected. This

data collection process has created the opportunity for venues to raise any concerns or queries they

may have about their responsible gambling obligations with an inspector, which has acted as an

155

additional and valuable education resource. In addition, all gambling providers are encouraged to

contact the Responsible Gambling Officer in relation to any enquiries or concerns.

This process has been in progress since October 2002 and may not have reached a wide range of

venues at the time of your research. Between the period October 2002 and September 2003, 1120

gambling providers had been surveyed. The results of the self-audit survey are similar, although

not directly comparable, to the results of the report with 70% of venues assessed as ‘committed’,

compared with the findings you reported, that, on average 72% of the elements of the practices were

implemented.

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SECTION ELEVEN

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Michaleas, T., (2000). ‘Problem Gambling: Challenges of Addressing a Health Issue’, in G. Coman(ed.), Lessons of the Past: Proceedings of the 10th National Association for Gambling Studies

Conference, National Association for Gambling Studies, Perth, pp. 116-125.

Ministerial Council on Drug Strategy, (1998). National Drug Strategic Framework 1998-99 to

2002-03, Commonwealth of Australia, Canberra.

Plant, M., E. Single and T. Stockwell (eds), (1997). Alcohol: Minimising the Harm, FreeAssociation Books, London.

Productivity Commission, (1999). Australia’s Gambling Industries: Final Report, Commonwealthof Australia, Canberra.

Queensland Government, (2000). Policy Direction for Gambling in Queensland, Queensland

Government, Brisbane.

Queensland Office of Gaming Regulation (2002). Gaming Newsletter, Vol. 5, No. 3, October.

158

Queensland Responsible Gambling Advisory Committee, (2001). Queensland Responsible

Gambling Advisory Committee Annual Report 2001, Queensland Government, Brisbane.

Queensland Responsible Gambling Advisory Committee, (2002). What’s New,

http://www.responsiblegambling.qld.gov.au/whatsnew.htm (accessed 17 June 2002).

Queensland Treasury, (2001). Queensland Household Gambling Survey 2001, Queensland

Government, Brisbane.

Queensland Treasury, (2002a). The Queensland Responsible Gambling Strategy: A Partnership

Approach, Queensland Government, Brisbane.

Queensland Treasury, (2002b). Queensland Responsible Gambling Code of Practice: Trial and

Review, Queensland Government, Brisbane.

Queens l and T rea su ry , ( 2003a ) . Review of the Code of Practice,

http://www.responsiblegambling.qld.gov.au/industry/COPReview.html (accessed 3 July 2003).

Queensland Treasury, (2003b). Responsible Gambling Practices Survey ,

http://www.responsiblegambling.qld.gov.au/industry/PracticesSurvey.html (accessed 3 July

2003).

Walker, M.B., (1992). The Psychology of Gambling, Permagon Press, Oxford.

Walker, M.B., (1998). Gambling Government: The Economic and Social Impacts, University ofNSW Press, Sydney.

SECTION ELEVEN

12 APPENDICES

160

Appendix A

Dissemination of the Research Results

With the permission of the Research and Community Engagement Division of QueenslandTreasury, and as a requirement of the project contract, the following presentations and publications

relating to this study have been undertaken or are in preparation:

ß Hing, N., Buultjens, J. and Breen, H. (2002). ‘Assessing Responsible Gambling Strategies:A Case Study in Queensland’, 12th National Association for Gambling Studies Conference,

Melbourne, November, 2002.

ß A published paper, based on the NAGS Conference presentation, will be printed in the

National Association of Gambling Studies conference proceedings later in 2003.

ß Presentation by Buultjens, J. and Breen, H. to QLD Clubs Alliance at Wynnum ManlyLeagues Club, November 14, 2003.

ß Hing, N., Breen, H and Buultjens, J. (2003). ‘Responsible Gambling in Queensland: A Case

Study’, Australian Tourism and Hospitality Research Conference, editors: R. W.Braithwaite and R. L Braithwaite, ISBN 1 86 3844899, Southern Cross University, Coffs

Harbour, February 5 - 8, 2003.

ß Breen, H., Buultjens, J. and Hing, N. (2003). Investigate the Perceived Efficacy of Current

Responsible Gambling Strategies in Selected Queensland Hotels, Casinos and Registered

and Licensed Clubs, Six month report for the Gambling Policy Directorate, QLD Treasury,Brisbane. February 26, 2003.

ß Breen, H., Buultjens, J. and Hing, N. (2003). The Perceived Efficacy of Responsible

Gambling Strategies in Queensland Hotels, Casinos and Licensed Clubs, Final report for theResearch and Community Engagement Division, QLD Treasury, Brisbane. August 26, 2003.

ß Buultjens, J., Breen, H. and Hing, N. (2003). ‘The Introduction of a Voluntary ResponsibleGambling Code of Practice: The Experience in North Queensland, Australia’, Ravings on

Research Seminar at Southern Cross University Lismore, 29 May, 2003.

ß Breen, H., Buultjens, J. and Hing, N. (2003). ‘The Introduction of a Voluntary ResponsibleGambling Code of Practice: The Experience in North Queensland, Australia’ 9th. Asia

161

Pacific Association Conference, editors: Tony Griffin and Rob Harris, University of

Technology, Sydney. ISBN 1-86365-654-6, July 6-9, 2003.

ß Breen, H. (2003) ‘Worldwide Gaming Perspective’, Winning Strategies in Community

Gaming and Club Management, RSL & Services Clubs Conference July 21-23, Twin TownsServices Club Tweed Heads. NSW.

ß Research papers are proposed for suitable refereed publications such as: International

Gambling Studies; Journal of Gambling Studies; Journal of the National Association of

Gambling Studies; and the Gaming Research and Review Journal.

APPENDIX B

ACTUAL and COMMITMENTS v TOTAL BUDGET

Project: 50302 QLD Treas Breen Resp Gambling Strategies

BudgetedPrior Year

Actual YTD ActualTotal

Actual

CommitsOrders and

Batches

Prior Year/s+ Current

+ CommitsVariance

Under/Over % Var

Income03 - Government Research Grants 98,282 98,282 0 98,282 0 98,282 0

Total Income 98,282 98,282 0 98,282 0 98,282 0

Salaries26 - Principal Researcher 25,000 0 25,000 25,000 25,000 026 - Secondary Researcher 18,975 0 18,975 18,975 18,975 026 -Secondary Researcher 18,975 0 18,975 18,975 18,975 027 - Consultant Researcher 5,000 0 5,000 5,000 5,000 027 - Research Assistant 959 0 1,158 1,158 1,158 199

Total Salaries 68,909 0 69,108 69,108 0 69,108 199 0%

NSI's 31 - Travel and Accommodation 12,410 5,607 3,944 2,396 9,880 12,276 (134) -1%32 - Vehicle Costs 1,239 161 945 1,106 0 1,106 (133) -11%37 - Printing 123 0 118 118 0 118 (5) -4%44 - Staff related expenses 7,601 4,664 2,482 7,146 527 7,673 72 1%49 - CGER administration costs 8,000 0 1,279 8,000 0 8,000 0 0%

Total NSI's 29,373 10,432 8,769 18,766 10,407 29,174 (199) -1%

Total Expenditure 98,282 10,432 77,877 87,875 10,407 98,282 0 0%

Surplus/(Deficit) 0 87,850 (77,877) 10,407 (10,407) (0)

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APPENDIX C

The Perceived Efficacy of Responsible Gambling Strategies in QLD Hotels,Clubs & Casinos: Questionnaire

The overall purpose of this interview today is to ask you about the current responsible gambling practices in QLDhotels, casinos, and registered and licensed clubs in minimising harm and protecting consumers in their gambling. Wewould like to concentrate on Awareness - to assess the level of responsible gambling awareness by staff and managersin your gambling venue, and Adequacy - to ask staff and managers whether they think their responsible gamblingpractices are adequate in minimizing harm and protecting consumers.

Part A: Implementation of the Code of Practice

1. Provision of informationGamingareas

Kenoareas

Wageringareas

Reasons: facilitate / inhibitresponsible gamblingpractices

1.1 Responsible gambling mission statementdisplayed

1.2 Information on help for problem gamblingdisplayed in all gambling areas

AND near ATM and EFTPOS servicinggambling areas

AND in toilets

1.3 Information is displayed on: the venueResponsible gambling policy document

Explaining rules of play and odds of winning

Exclusion provisions

Gambling related complaints resolution

Financial transaction practices

1.4 Odds of winning major prizes displayed

2. Interaction with customers andcommunity

Gamingareas

Kenoareas

Wageringareas


2.1 Community liaison establish effective linkswith gambling related support services

And community networks

2.2 Customer liaison role to provideinformation to customers

To support staff in providing assistance tothose customers

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Provide assistance to staff with gamblingrelated problems

2.3 Customer Complaints mechanisms areestablished & promoted

2.4 Training & skills development to ensureresponsible gambling training is provided torelevant staffAnd, owners boards & managers receiveappropriate information to guide decisionmaking about responsible gambling

3. Exclusion provisionsGamingareas

Kenoareas

Wageringareas


3.1 Provide self-exclusion procedures anddocumentation

3.2 Offers customers seeking self-exclusioncontact information for appropriate counselingagencies3.3 Self-excluded customers given support inseeking mutual exclusion from other gamblingproviders3.4 Do not send correspondence orpromotional material to excluded customers oron request

4. Physical EnvironmentGamingareas

Kenoareas

Wageringareas


4.1 Minors prohibited from gambling

4.2 minors excluded from areas where adultsare gambling

4.3 Alcohol service encourage customers totake breaks in play

4.4 Intoxicated customers not permitted tocontinue to gamble

4.5 Childcare facilities

4.6 Staff in gambling areas not to encouragetips

4.7 Customers are made aware of the passageof time

4.8 Customers discouraged from extended,intensive & repetitive play

5. Financial TransactionsGamingareas

Kenoareas

Wageringareas


5.1 ATM facilities

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Not located close to entry of gambling areas

5.2 Established limit above which all winningsare paid by cheque or electronic transfer

Gambling winnings above a set limit are paidby cheque and not cashed at the venue until thenext day

Prohibits cashing cheques not payable to thevenue

Prohibits paying cheques not payable to theperson presenting the cheque

Prohibits cashing multiple cheques

5.3 Gambling provider does not provide creditor lend money for gambling

6. Advertising and promotionsGamingareas

Kenoareas

Wageringareas


6.1 Complies with advertising code of ethicsby AANA

6.2 Is not false, misleading or deceptive

6.3 Does implicitly or explicitly misrepresentthe probability of winning a prize

6.4 Does not give he impression that gamblingis a responsible strategy for betterment

6.5 Does not include misleading statementsabout odds, prizes, or chances of winning

6.6 Does not offend prevailing communitystandards

6.7 Does not focus exclusively on gambling

6.8 Is not implicitly or explicitly directed atminors or vulnerable or disadvantaged groups

6.9 Does not involve any external signsadvising of winnings paid

6.10 Does involve any irresponsible tradingpractices by the gambling provider

6.11 Does not depict or promote alcoholconsumption with gambling

6.12 Obtains consent prior to publishing theidentification of any person who wins a prize

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Part B: Awareness and Adequacy of the Code

Now we’d like to move on to the second topic for this research, the adequacy of responsible gambling strategies. (Rateeach question by placing a circle around your answer below)

1. In your opinion, is it likely that the provision of adequate information and signage about gambling (suchas knowing odds of winning, rules of games) encourages responsible gambling?

Strongly Disagree; Disagree; Don’t Know; Agree; Strongly AgreeFurther Comments:

2. Do you think that there are adequate gambling related support services to assist customers andmembers of the community who need this help?


3. Does exclusion for problem gamblers really encourage responsible gambling?


4. Is it likely that a venue’s physical layout and environment can encourage responsible gambling?


5. In your view, do rules and limits on financial transactions encourage responsible gambling?


6. Do you think that current advertising and promotions help promote responsible gambling?


7. In the package of responsible gambling practices mentioned above, does any one stand out as being animportant barrier in encouraging responsible gambling?

8. In the package of responsible gambling practices mentioned above, does any one stand out as being animportant facilitator in encouraging responsible gambling?

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Well, thank you very much for your cooperation in this research on responsible gambling practices. We hope that as aresult of this and other similar research, that these strategies will be reviewed and refined so that they are better able toprotect gambling consumers.

Documents

Perceived efficacy of responsible gambling strategies in Queensland hotels, casinos and licensed clubs