Perceived efficacy of responsible gambling strategies

Southern Cross University

ePublications@SCU School of Commerce and Management

2003

Perceived efficacy of responsible gambling strategies in Queensland hotels, casinos and licensed clubs Helen Breen Southern Cross University, [email protected]

Jeremy Buultjens Southern Cross University, [email protected]

Nerilee Hing Southern Cross University, [email protected]

Suggested Citation Breen, 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.

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

centre for gambling education & research

The Perceived Efficacy of Responsible Gambling Strategies in Queensland Hotels, Casinos and Licensed Clubs By Ms. Helen Breen, Dr. Jeremy Buultjens and Dr. Nerilee Hing Centre for Gambling Education and Research School of Tourism and Hospitality Management Southern Cross University Lismore NSW 2480 Final Report For the Research and Community Engagement Division (formerly the Gambling Policy Directorate) of Queensland Treasury August 2003 Reviewed December 2003

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 2.6.1 The Queensland Responsible Gambling Resource Manual 2.6.2 Training in Implementing the Code 2.6.3 Other Support and Involvement of the Industry Associations 2.6.4 Placement of Responsible Gambling Signage by the QOGR

22 22 23 25 26

2.7 Accountability and Review of the Queensland Responsible Gambling Code of Practice 27 2.8 Evaluating the Queensland Responsible Gambling Code of Practice: A Theoretical Framework

29

2.9 Evaluating the Queensland Responsible Gambling Code of Practice: A Practical Framework

33

3

36

RESEARCH METHODS

3.1 Introduction 3.2 Research Design

36 36

3.3

The Sample

37

3.4

Data Collection

38

i

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 4.3.1 Implementation: Provision of Information 4.3.2 Implementation: Interaction with Customers and Community 4.3.3 Implementation: Exclusion Provisions 4.3.4 Implementation: Physical Environments 4.3.5 Implementation: Financial Transactions 4.3.6 Implementation: Advertising

44 48 48 49 50 51 51

4.4 Perceived Adequacy of the Code in Longreach 4.4.1 Adequacy: Provision of Information 4.4.2 Adequacy: Interaction with Customers and Community 4.4.3 Adequacy: Exclusion Provisions 4.4.4 Adequacy: Physical Environments 4.4.5 Adequacy: Financial Transactions 4.4.6 Adequacy: Advertising

51 52 52 53 53 53 54

4.5 Facilitators and Impediments for the Code in Longreach 4.5.1 Facilitators 4.5.2 Impediments

54 54 54

4.6 Summary 4.6.1 Awareness and Implementation 4.6.2 Adequacy

55 55 56

5

57

THE TOWNSVILLE CASE STUDY

5.1

Introduction

57

5.2

Awareness of the Code in Townsville

58

5.3 Implementation of the Code in Townsville 5.3.1 Implementation: Provision of Information 5.3.2 Implementation: Interaction with Customers and Community 5.3.3 Implementation: Exclusion Provisions 5.3.4 Implementation: Physical Environments 5.3.5 Implementation: Financial Transactions 5.3.6 Implementation: Advertising

60 64 65 67 69 71 72

ii

5.4 Perceived Adequacy of the Code Townsville 5.4.1 Adequacy: Provision of Information 5.4.2 Adequacy: Interaction with Customers and Community 5.4.3 Adequacy: Exclusion Provisions 5.4.4 Adequacy: Physical Environments 5.4.5 Adequacy: Financial Transactions 5.4.6 Adequacy: Advertising

73 75 76 77 79 81 83

5.5 Facilitators and Impediments for the Code in Townsville 5.5.1 Facilitators 5.5.2 Impediments

84 85 86

5.6 Summary 5.6.1 Awareness and Implementation 5.6.2 Adequacy 5.6.3 Facilitators and Impediments

89 89 90 90

6

92

THE SOUTH EAST QUEENSLAND CASE STUDY

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 6.3.1 Implementation: Provision of Information 6.3.2 Interaction with Customers and Community 6.3.3 Implementation: Exclusion Provisions 6.3.4 Implementation: Physical Environments 6.3.5 Implementation: Financial Transactions 6.3.6 Implementation: Advertising

94 98 99 101 103 105 106

6.4 Adequacy of the Code in South-East Queensland 6.4.1 Adequacy: Provision of Information 6.4.2 Adequacy: Interaction with Customers and Community 6.4.3 Adequacy: Exclusion Provisions 6.4.4 Adequacy: Physical Environments 6.4.5 Adequacy: Financial Transactions 6.4.6 Adequacy: Advertising

108 110 112 113 115 116 118

6.5 Facilitators and Impediments for the Code in South-East Queensland 6.5.1 Facilitators 6.5.2 Impediments

120 120 122

6.6 Summary 6.6.1 Awareness and Implementation 6.6.2 Adequacy 6.6.3 Facilitators and Impediments

123 123 124 126

7

127

CROSS-CASE ANALYSES OF THE THREE CASE STUDIES

iii

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

8.3

Results for Research Objective 2

143

8.4

Results for Research Objective 3

144

8.5

Results for Research Objective 4

148

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 Particular Circumstances

154

10.4

Awareness and Education of the Code of Practice

154

11

REFERENCES

157

12

APPENDICES

160 iv

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 Code of 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 Queensland Venues .................................................................................................................. 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

v

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 voluntary Queensland Responsible Gambling Code of Practice (Queensland Treasury, 2002b), the subject of this research. 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 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 perceived efficacy of these six broad responsible gambling practices in selected Queensland hotels, casinos and clubs in three case study areas - Longreach, Townsville and southeast Queensland. These areas were selected as representing remote, regional and urban areas. More specifically, the project measured and compared gambling providers’ awareness and perceived adequacy of the provisions of 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; 6

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, Townsville and 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 the perceived adequacy of the Code, from the perspective of managers and key staff in these organisations. On-site observation of responsible gambling practices was also conducted 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 to was advertising. Twenty venues or 66% of the venues visited, all based in heavily populated locations, used advertising and promotions to attract customers. 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 qualifiers that should be noted. The first is that the researchers did not conduct an independent evaluation of the advertising practices in the venues, but relied on self-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 not being responsible in their advertising practices, with several examples cited. Indeed, the researchers did encounter such breaches of the Code during their field work, including some by venues who participated in the study and who nevertheless reported compliance with the Code’s advertising practices.

7

ß

The financial transactions practice area of the Code had an average 85% implementation rate. Venues in south-east Queensland were much more likely to 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 levels of 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 two casinos 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 the Code’s practices than venues with large gaming installations. The former’s adherence to the Code in the area of interaction with customers and the community 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 community and responsible advertising and promotions 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% believe that exclusion provisions are appropriate. Respondents were generally not convinced that the provision of information and signage was adequate to support responsible gambling.

ß

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 in Townsville were very positive about the adequacy of their interaction with customers and support services networks. In 8

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 large gaming 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 gaming installations.

ß

Based on type of venue, managers and staff in clubs were more positive about the 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 practices relevant 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 underpinning the 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 remote location, being a busy owner-manager, and not receiving a copy of the Code and other 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.

9

SECTION ONE 1 1.1

INTRODUCTION TO THE STUDY

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 southeast 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.

10

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.

11

SECTION TWO 2 2.1

BACKGROUND TO THE RESEARCH TOPIC

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 and responsible provision of gambling are illuminated, along with some challenges for effective implementation of responsible gambling codes of conduct. Later discussion focuses 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 this investigation 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 and governments. However, gambling does create social, health and welfare costs (Korn and Shaffer, 1999) due mainly to problem gambling. There have been difficulties with defining 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 variously emphasised 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 that problem 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): 12

‘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. The most widely used estimates for Australia are those derived by the Productivity Commission (1999). The Commission estimated that approximately 1 per cent of the adult 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 adult Australians (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 that the resulting figures probably underestimate the extent of the problem (Productivity Commission, 1999). In Queensland, the Queensland Household Gambling Survey (2001) used the Canadian Problem 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 from their 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 from gambling’ 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 13

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 (Queensland Treasury, 2002a, 2002b). While the number of problem gamblers indicated by these surveys represents a very small 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 the consequences 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 on family 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 each person 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 health perspective, the costs associated with gambling problems include the more obvious, such as treatment programs, impaired work performance, family breakdown and gambling 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 leisure pursuits (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.

14

2.3

Responsible Gambling

Despite being widely used, the terms ‘responsible gambling’ and ‘responsible provision of 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. Such practices 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 of ATMs and credit, and self-exclusion options. The introduction of such practices in responsible gambling programs in Australia recognises that, as gambling is a legalised activity, 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 to redefine 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 consequences associated 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 vocabulary that 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 various mandatory 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; 15

•

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

•

not making the decision to gamble under conditions of strong emotion or personal crisis.

Responsible provision of gambling also implies that gambling is provided in a socially responsible 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 a community’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 responsible provision 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 introduced responsible 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 to inform 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 in responsible 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 16

extend upon the mandatory measures in responsible gambling. However, given the diverse frameworks underpinning these voluntary initiatives, the practices they include and the ways they have been implemented vary significantly, with a wide variety of stewardship processes in place to facilitate their implementation. Further, the researchers 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 in terms of their effectiveness in addressing problem gambling or in promoting responsible gambling. Despite the diversity of strategies found by the researchers, there were sufficient common themes amongst the codes examined to highlight the following deficiencies: ß

definitions of key elements, such as responsible gaming, problem gambling or informed 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 as alcohol and cigarettes;

ß

the codes failed to develop strategies based on established principles or causal themes 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 harm minimisation strategies, there has been no research collaboration even though the very different prevalence levels of problem gambling across states provide a natural ‘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 selfexclusion procedures, avoid targeting those most at risk and avoid the use of advertising of a similar power and sophistication to that employed in marketing the gambling products themselves.

17

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 selfgoverning, 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 optimise their implementation and compliance rates: ß

Explicit industry commitment - with clear objectives, expectations and groundrules;

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 negative consequences for failure to comply;

ß

Community confidence - gained through open processes in development and implementation, 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 of Hing, 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

18

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 gambling operations 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 per registered club and 35 per hotel) were included. The legislation also provided for imposed exclusion from playing gaming machines for one month where there are reasonable 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 ‘overarching objective…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 and concerns. To address the fifth priority area above, the Queensland Responsible Gambling Advisory Committee developed the Queensland Responsible Gambling Code of 19

Practice, the subject of this research. The Queensland Responsible Gambling Advisory Committee had its genesis as the Problem Gambling Advisory Committee, formed in August 1996, ‘with the aim of providing a community, industry and government forum to monitor the impact of problem gambling in Queensland’ (Queensland Responsible Gambling 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 the development 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.

20

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

21

2.6

Implementation of the Queensland Responsible Gambling Code of Practice

As noted earlier, the Queensland Responsible Gambling Code of Practice was launched in 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 gambling signage 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 to clarify 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, Responsible Gambling 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 the Gambling Policy Directorate (now the Research and Community Engagement Division) of Queensland Treasury with advice from the Queensland Responsible Gambling Advisory 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 that conform to industry best practice, and an outline of responsible gambling strategies specific to each industry sector and based upon the Code’s practices (Queensland Treasury, 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 22

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 Wilson indicated 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 it out 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 of QHA (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 commenced this 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 importance of 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 February 2003), 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 and to ‘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 training sessions 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 are made 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 keep offering 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’. 23

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 training provision. 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 the interview (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, Stage Three 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 may identify 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 the QHA 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 discussion in 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 only 740 of these employees were directly involved with the provision of gambling products, the training was also delivered to all staff, including supervisors and managers across the 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 offer responsible 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 24

Hospitality. However, the number of responsible gambling training providers is relatively few in Queensland as responsible gambling certificates are not required by law, 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 the association’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 through newsletters 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’), that some 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 an important 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 hotel consortia to small owner-operators. It also drew on other responsible gambling codes of practice, particularly the one already developed by the Australian Liquor and Hospitality 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 amongst Queensland hotels. These include the difficulty in attracting non-association members 25

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 problem gamblers’, that hotel managers in remote areas may feel that they do not need formal procedures, preferring instead to ‘approach problem gamblers and generally look out for 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, resources and 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 machine promotions’ 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 visible from 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 of the 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’ VicePresident at the time of this study, Mr Grant Bowie, represented the casino group on the Queensland Responsible Gambling Advisory Committee, and was active in publicising and promoting the Code via conferences and other outlets. Jupiters also has management 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 Casino and 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:

26

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 get help for problem gambling.

ß

An information display board which alerts customers to information available on 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 of Practice The Queensland Responsible Gambling Code of Practice has been described as ‘a living document’ that ‘will be reviewed periodically’ (Queensland Responsible Gambling Advisory Committee, 2002). The Code states a commitment to regular independent monitoring and evaluation for its effectiveness (Queensland Treasury, 2002b). The Review will occur in three phases with the focus for each phase changing, in recognition 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:

27

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 ß

evaluate the effectiveness of implementation of the Code of Practice; 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 Responsible Gambling 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 had not 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 weeks prior to a QOGR gaming machine audit, with the survey then collected by gaming inspectors on audit day. 28

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 provided with 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's level 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 in Queensland. 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 in this study and reported later in this document. 2.12 Evaluating the Queensland Responsible Gambling Code of Practice: A Theoretical Framework To guide this investigation into the perceived efficacy of responsible gambling strategies in Queensland hotels, casinos and licensed clubs, the public health literature on 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. 29

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 assessment through 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 where the current research project fits into this planning and evaluation cycle. 1. Needs assessment. Needs assessments are conducted to gain a comprehensive picture 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 decisions are guided by extensive consultation with relevant stakeholders and wide 30

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 collect additional 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 desired change. Ideally, it involves specifying the program goals (desired change in the health problem, e.g. a reduction in problem gambling in the community), the program 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 health problem, 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 venues and 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 to optimise the likelihood that the activities of the program are implemented. 4. Process evaluation. Process evaluation aims to measure the activities of the program, 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 the program?; 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 31

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 identified deficiencies, 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 and what should be measured. 7. Impact evaluation. Impact evaluation focuses on assessing the immediate effects of the 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 and whether 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 32

its strategy objectives) will reduce the risk factors associated with the health problem (achieving its program sub-objectives), which in turn will achieve the desired behavioural 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) is considered next. 2.13 Evaluating the Queensland Responsible Gambling Code of Practice: A Practical 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 independent monitoring, 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 to delineate 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 the Code to compile Figure 2.2.

33

Figure 2-2: A Framework for Evaluating the Queensland Responsible Gambling Code of Practice ASPECTS OF THE PROGRAM

•

•

•

• •

•

APPROPRIATE TYPE OF EVALUATION

Program Goals To promote responsible gambling, that is, gambling that ‘occurs in a regulated environment where the potential for harm associated with gambling is minimised and people make informed decisions about their participation in gambling’.

Outcome Evaluation

Program Objectives Individuals, communities, the gambling industry and the Government have a shared understanding of responsible gambling practices. Individuals, communities, the gambling industry and the Government have an understanding of their rights and responsibilities in relation to responsible gambling practices. The gambling industry provides safe and supportive environments for the delivery of gambling products and services. Customers make informed decisions about their gambling practices. Harm from gambling to individuals and the broader community is minimised. People adversely affected by gambling have access to timely and appropriate assistance and information.

Impact Evaluation

Strategy Objectives To implement and achieve whole-of-industry voluntary compliance with the QLD Responsible Gambling Code of Practice and provide assistance for this via mechanisms such as the QLD Responsible Gambling Resource Manual and training.

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

Process Evaluation

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

34

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 its strategy objectives through providing and delivering the planned strategy activities (Figure 2.2). While addressing the specific research objectives identified in Section One of 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 can evaluate 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 evaluations that may be conducted, including those planned by Queensland Treasury (2003a) in its review of the Code over its first five years of implementation.

35

SECTION THREE 3 3.1

RESEARCH METHODS

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 and venues 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 onsite 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 of the Code (provision of information; interaction with customers and community; exclusion provisions; physical environments; financial transactions; and advertising and promotions) 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 any other 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 interview instrument (also incorporating a five point Likert scale) was based on responsible gambling practices highlighted in the Code. Using the Likert scale, managers and staff were asked for their views on the adequacy of the Code. 36

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 fully transcribed 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. A tour of the venue with managers or staff identified the ‘visible’ consumer protection and harm minimisation measures accessible to gamblers (e.g. provision of information and signage; 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 or themes highlighted and space allocation for different venue products. 3.3

The Sample

There are 11 statistical divisions in Queensland, but due to budgetary and time constraints, 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, far north 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 37

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 were included 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, depending on 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 the nine 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 to be 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 the week 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 three hotels 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 large gaming facility (tables, gaming machines, TAB, keno), seven hotels (four large and 38

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%) and nine (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 was also 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 (three large 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.

39

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

6

Small Club

21 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

13

Small Club

16 GM, Keno

14

Large Hotel

40 GM, Keno, TAB

15

Large Club

125 GM, 2 Keno, TAB

16

Small Hotel

25 GM, Keno, TAB

17

Small Hotel

15 GM, Keno, TAB

18

Small Hotel

25 GM, Keno, TAB

19

Small Hotel

14 GM

20

Large Hotel

35 GM, Keno

21

Large Club

146 GM, Keno, TAB

22

Small Hotel

15 GM, Keno, TAB

23

Large Hotel

40 GM, Keno, TAB

24

Small Hotel

18 GM, TAB

25

Large Club

30 GM

26

Large Club

140 GM, Keno, TAB

27

Casino

240 GM, Keno, TAB, Table games

28

Large Hotel

40 GM, Keno, TAB

29

Large Hotel

40 GM, Keno, TAB

30

Large Club

80 GM, Keno, TAB

40

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 the Queensland 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 of the ramifications of implementing it and some long-term strategies they were developing as a consequence of implementing the Code. Two welfare counsellors, two industry 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, open coding was used by breaking down, examining and comparing data to find emerging themes. The analysis then pulled together emerging themes into meaningful core categories of results. 3.6

Limitations of the Methodology ß This project relied on the voluntary participation of the venues. Therefore, it was not possible to evaluate the extent to which non-participating venues had implemented the Code. It would be expected that implementation of the Code in 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 of the implementation of the Code. Research in similar areas (e.g. responsible service of alcohol, road safety programs) suggests that further research and evaluation 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 41

2003), it became apparent that there had not been adequate time for the implementation strategies to take full effect, even though the Code had been launched in May 2002. ß The research conducted only involved a process evaluation of the Code (see Section 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. These include the overall research design, the sample, data collection methods, analytical techniques and methodological limitations. Section Four now presents the results from the first case study area, Longreach.

42

SECTION FOUR 4 4.1

THE LONGREACH CASE STUDY

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 of about 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 other club 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. 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. 4.2

Awareness of the Code in Longreach

The managers from all four venues visited in Longreach were only vaguely cognisant of the 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 the interview 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 the interview. After participating in the interview, it appeared that the manager gained an 43

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 in few 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 managers indicated 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 to ensure 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 to responsible 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. 44

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

CODE OF PRACTICE ELEMENTS

SMALL CLUB

SMALL HOTELS

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 gambling areas

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 guide decision making

Y

Y

N

N

3. Exclusion Provisions

1

3

4

2

Provide self-exclusion procedures and documentation

N

Y

Y

N

45

Offers self-exclusion contact information for appropriate counselling agencies

N

N

Y

N

Self-excluded customers supported in seeking mutual exclusion from other gambling providers

N

N

N

N

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

$250

$250

$250

$250

Gambling winnings above a set limit are paid by cheque and not cashed 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 the cheque

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

Does not send correspondence or promotional material to excluded customers

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

46

Does not give the impression that gambling is a responsible strategy for betterment

NA

NA

NA

NA

Does not include misleading statements about odds, prizes, or chances 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 or disadvantaged 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 the gambling 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 a prize

NA

NA

NA

NA

Y - YES

N - NO

NA – NOT APPLICABLE

47

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 exist in 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 gambling support 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 community consultative 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 staff personally 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 was time 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

48

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 staff could 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, although all 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 the exclusion 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 counselling agencies 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 customers the phone numbers provided on the signage displayed in the venues. However, these were Brisbane numbers and the managers and staff suggested it was unlikely that people 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 local pastor, 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 lists so had no policy about removing self-excluded customers from any lists. However, while all managers were willing to implement self-exclusion procedures, they all suggested that self-exclusion would not be successful because a self-excluded person ‘could walk down the road’ to another venue.

49

4.7

Implementation: Physical Environments

Prohibiting minors from gambling and gambling areas, although included in the voluntary 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 in applying 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 a letter 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 to gamble. 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 the gaming 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 managers stated they excluded intoxicated people from playing gaming machines; however another two managers stated they would only stop intoxicated people from playing machines 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 any time. None of the venues provided childcare facilities and so this section of the Code was not relevant 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 and three venues had windows in their gambling areas. Two of these venues had their windows covered to avoid outside observation of gaming rooms - a legislative requirement. 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 of gaming areas is a legislative requirement. 50

4.8

Implementation: Financial Transactions

Two venues had ATMs and two had EFTPOS, but none were located in the gambling areas. 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 venue managers 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. The managers stated that it was possible that multiple cheques were cashed because of different staff working on different shifts. None of the venues provided credit for gambling 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 51

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

SMALL HOTELS

CLUB

CODE OF PRACTICE AREAS

Provision of adequate information & signage

1

3

4

2

D

DK

D

D

A

D

A

D

DK

DK

D

D

DK

A

A

A

DK

A

DK

A

A

A

A

D

encourages responsible gambling Support services are adequate to assist customers and the community who need help Exclusion really encourages responsible gambling Physical layout & environment encourages responsible gambling Rules & limits on financial transactions encourage responsible gambling Advertising and promotions help promote responsible gambling 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 actually become 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 52

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 were unlikely 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 that self-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 that self-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, in Longreach, 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 responsible gambling. 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 cool down after big wins.

53

4.16 Adequacy: Advertising This area drew different responses. Three managers believed that certain approaches to advertising 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 they would 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 physical environment 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 play to 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 potential effectiveness of the Code in Longreach: ß

Not all managers and staff interviewed in Longreach had received a copy of the Code and Resource Manual.

54

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 in terms 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 training and 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 remote areas ‘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 the only requirement is a criminal and probity check. Another issue with the Code for managers and staff in Longreach is that there has been a 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 residents and 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 55

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 of the 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 waste of 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.

56

SECTION FIVE 5 5.1

THE TOWNSVILLE CASE STUDY

Introduction

The City of Townsville, located some 1,400 kilometres north of Brisbane, is widely regarded 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 of its 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 and Thuringowa, 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 a whole (2.0%). Townsville’s employment rate is approximately 90.6%, reflecting its rapid economic development since the 1950s. Key employers are the copper and nickel processing 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%) had gaming 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-four interviews were conducted, twenty-two of which were with people managing gaming venues and two with counsellors at a welfare agency. Another two clubs (with small gaming 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. 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. 57

5.2

Awareness of the Code in Townsville

Most managers from the twelve venues visited in Townsville were aware of the Queensland 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 of the 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 installed signage 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 were not 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 read all relevant material and keep the manager informed. Thus, eight managers of the twelve venues visited (67%) were aware of the existence and 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 review responsible 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 gaming installations. 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 primarily discussed three issues: a common responsible gambling advertising campaign for the Townsville region, a method to get all venues to participate in regionally based selfexclusions, 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 58

informing people about the merits of responsible gambling, particularly for families, and secondly on sending the message that gambling is an entertaining leisure activity when 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 with some 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 getting Toohey’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 privacy legislation. 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 selfexclusions so that Centacare could provide venues with a regional list of excluded persons and then provide the excluded person with counselling and support. While this proposal 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 as local 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. The managers 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 venue managers in Townsville:

59

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 agency Centacare to extend responsible gambling practices and education in the Townsville region.

ß

The next level of awareness was displayed by three venues (25%) where managers and 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 received the 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 those parts 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 the Code’s six practice areas.

60

Table 5-1 Implementation of the Code’s Elements in the Townsville Venues CODE OF PRACTICE ELEMENTS

SMALL HOTELS

LARGE HOTELS

LARGE CLUBS

CA

1. Provision of Information

19

22

24

20

23

28

29

21

25

26

30

27

Displays responsible gambling mission statement

Y

N

N

N

N

Y

Y

N

Y

N

Y

Y

Displays help information in all gaming areas

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Displays help information near EFTPOS/ATMs servicing gambling 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 the responsible gaming policy document

N

N

N

Y

N

Y

Y

N

Y

N

Y

Y

Displays information on the rules of play and odds of winning

N

N

N

Y

N

Y

Y

N

Y

Y

Y

Y

Displays information on exclusion provisions

N

N

N

N

N

Y

Y

N

Y

Y

Y

N

Displays information on gambling related complaints resolution

N

N

N

N

N

Y

Y

N

Y

Y

Y

Y

Displays information on financial transactions practices

Y

N

N

Y

Y

Y

Y

Y

Y

Y

Y

Y

Displays odds of winning a major prize

N

N

N

N

N

N

N

N

N

Y

N

N

2. Interaction with Customers and Community

19

22

24

20

23

28

29

21

25

26

30

27

Establish links with support services

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 provides information to customers

Y

N

N

Y

N

Y

Y

Y

Y

Y

Y

Y

Support staff in providing assistance to customers

Y

N

N

Y

N

Y

Y

Y

Y

Y

Y

Y

Provide assistance to staff with gambling related problems

Y

N

N

Y

N

Y

Y

Y

Y

Y

Y

Y

Customer complaints system established and promoted

N

N

N

Y

Y

Y

Y

Y

Y

Y

Y

Y

N

N

N

Y

N

Y

Y

N

Y

Y

Y

Y

N

N

N

Y

N

Y

Y

N

Y

Y

Y

Y

Ensure responsible gambling training is provided to relevant staff Owners, boards, managers receive appropriate information to guide decision making

61

3. Exclusion Provisions

19

22

24

20

23

28

29

21

25

26

30

27

Provide self-exclusion procedures and documentation

N

N

N

Y

N

Y

Y

Y

Y

Y

Y

Y

Y

Y

N

Y

N

Y

Y

Y

Y

Y

Y

Y

Y

N

N

Y

N

Y

N

N

N

Y

Y

Y

promotional material to excluded customers

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 where adults gambling

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Alcohol service encourage customers to take breaks in play

N

N

Y

N

N

N

N

N

Y

N

Y

Y

Intoxicated customers not permitted to continue gambling

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

NA

NA

NA

NA

NA

Y

NA

NA

NA

Y

NA

NA

Staff in gambling areas not to encourage tips

Y

Y

Y

N

Y

Y

Y

Y

Y

Y

Y

Y

Customers made aware of the passage of time

Y

Y

N

N

Y

N

Y

N

Y

N

Y

Y

Customers discouraged from extended, intensive & repetitive play

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 to gambling areas

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

Y

Y

Offers self-exclusion contact information for appropriate counselling agencies Self-excluded customers supported in seeking mutual exclusion from other gambling providers Does not send correspondence or

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

$250

$300

$1,000

$1,000

$1,000

$1,000

$500

$3,000

$250

$1,000

$300

$10,000

Childcare facilities meet legislated standards

Gambling winnings above a set limit are paid by cheque and not cashed at venue until next day

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Prohibits cashing cheques not made payable to the venue

Y

N

N

N

Y

N

N

Y

N

N

N

N

Prohibits cashing cheques not payable to the person presenting the cheque

Y

N

N

Y

Y

Y

Y

Y

Y

Y

Y

Y

Prohibits cashing multiple cheques

Y

N

Y

Y

Y

N

Y

Y

Y

Y

Y

Y

Does not provide credit or lend money for gambling

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

62

6. Advertising and Promotions

19

22

24

20

23

28

29

21

25

26

30

27

Complies with advertising code of ethics by AANA

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

Is not false, misleading or deceptive

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

Does not misrepresent the probability of winning a prize

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

Does not offend prevailing community standards

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

Does not focus exclusively on gambling

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

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

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

Does not involve any external signs advising of winnings paid

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

NA

NA

NA

Y

NA

Y

Y

Y

Y

Y

Y

Y

Does not give the impression that gambling is a responsible strategy for betterment Does not include misleading statements about odds, prizes, or chances of winning

Does not involve any irresponsible trading practices by the gambling provider Does not depict or promote alcohol consumption with gambling Obtains consent prior to publishing the ID of any person who wins a prize Y - YES

N – NO

NA – NOT APPLICABLE

63

5.4

Implementation: Provision of Information

Problem gambling signage was displayed in all twelve venues visited because a QOGR 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 of rows of gaming machines, on walls in all gaming areas and some venues had a sixfoot 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, explanations of 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 every combination 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, which helped provide evidence to settle complaints. Ten of the twelve venues (83%) had information publicly displayed on their financial transactions policy, while only one venue 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. Of the 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 the provision of information policy was in regards to financial transactions because, although these are included in the voluntary Code, they are also legislative requirements. 5.5

Implementation: Interaction with Customers and Community

Six of the twelve venues visited in Townsville (50%) had established effective links with gambling related services and community networks. Of the six, five venue managers, all with large gaming installations, had formed an informal consultative group 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 provide information 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 of command 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%) reported they 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. They include 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 read the Code and the Resource Manual then sign a register indicating they understand their contents. Additionally, these nine managers (75%) stated they would support any of 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

65

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 the nature 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 interviewed were confident that their customers knew how to make a complaint. Staff training and skill development in responsible gambling had been undertaken in seven 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 high staff 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 negative viewpoint, one manager who had no staff trained in responsible gambling saw this type of training as learning how to be a counsellor, rather than implementing responsible 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 their gambling behaviour. In this venue, management recognises that staff can get caught in a ‘hospitality mindset that normalises heavy drinking and risky gambling’. In another venue, 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 be unlikely 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 gambling practices.

66

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 not be 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 venue managers (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, all with large gaming installations. Thus, while the majority of venue managers (75%) indicated they would support customers 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 and skills development in the provision of responsible gambling. These same seven venues all had large gaming installations. 5.6

Implementation: Exclusion Provisions

When requested, self-exclusion procedures and supporting documentation would be provided by eight of the twelve venues (67%) visited in Townsville. Managers and staff from four venues (33%) reported they had had between two and four people selfexclude 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 a request 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 be certain 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 from other 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 practice would have limited effectiveness, as ‘other venues may not be so ethical’. Further, 67

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 to send 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 ten venues (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 counselling services. 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 customers seeking consensual exclusions from other gambling providers was that ‘they could walk into another pub/club’ that did not offer the same support. Approximately half of the respondents saw the need for a regionally based self-exclusion system. 5.7

Implementation: Physical Environments

All managers and staff interviewed in Townsville were aware of their legal obligation to 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 gaming room 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 mother with 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,

68

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 risky gambling 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 prevent intoxicated people from gambling as part of their responsible service of alcohol practices. Bar and security staff were said to monitor responsible service of alcohol carefully 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. There was 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 from customers, 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 are part 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 light flooding 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 no clocks 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 or drinks; 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 times advertised through loud in-house announcements; staff encouraging people to collect 69

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 some gaming 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 excluding minors 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 often considered as encouraging patrons to remain in the gaming room. 5.8

Implementation: Financial Transactions

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, their TAB. 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, small venues 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 also a 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 many winnings 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.

70

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 for winnings 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 they should 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 unfair compared 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 known third 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 had a 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 more likely to have lower limits for paying winnings by cheque than large venues. 5.9

Implementation: Advertising

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 promotions connected 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 venues reported 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, 71

one manager maintained that the venue’s 30 second radio advertisements feature 12 seconds of gambling and 18 seconds of other venue offerings. However whilst reading 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 that their advertising 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. 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 his venue 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 manager reported that inspectors from the QOGR were vigilant in scrutinising the legality of promotions operated by licensed premises. In contrast, a manager reported that one venue 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 undertake advertising 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.

72

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 these statements. 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 responsible gambling

DN

D

D

D

D

A

A

D

D

A

A

A

Support services are adequate to assist customers and the community who need help

A

DN

A

A

A

D

A

A

A

A

A

D

Exclusion really encourages responsible gambling

DN

A

D

A

A

A

D

A

D

D

A

A

Physical layout & environment encourages responsible gambling

DN

D

A

A

A

A

DN

A

A

A

A

D

Rules & limits on financial transactions encourage responsible gambling

D

D

D

A

D

A

D

A

D

A

A

A

Advertising and promotions help promote responsible gambling

D

D

DN

A

A

D

DN

DN

A

A

A

A

A - AGREE

D - DISAGREE

DK – DON’T KNOW

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5.11 Adequacy: Provision of Information Opinion on the provision of information in encouraging responsible gambling was almost evenly divided. Managers and staff in six venues (50%) felt that information and signage would have very little impact in encouraging responsible gambling. Their comments 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 to gamble.’

•

‘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.’

74

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 are gambling more than they’re comfortable with’.

In terms of differences by size and sector, of the six venues (50%) whose managers considered 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 did encourage 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, while those who disagreed were divided between venues with large and small gaming installations. 5.12 Adequacy: Interaction with Customers and Community Most managers and staff (75%) interviewed in the twelve venues agreed there were adequate gambling related support services to assist customers and members of the Townsville 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.’ 75

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 responsible gambling.’

ß

‘Yes, I would refer to Gamblers Anonymous.’

ß

‘I know that services are there, but not how many there are or how many people 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 think there were enough gambling related support services in the Townsville region, the majority (75%) felt there were was adequate. 5.13 Adequacy: Exclusion Provisions 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 the operational 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. It would 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 her problem.’ ß ‘Good idea, but not effective as it is now with just photos. I’m not sure how it 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 at this 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 they could 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 is a 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.’

77

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 the solution 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 who will be more aware, then there would not be a need for self-exclusion. Problem gambling reflects some stupidity, therefore we need public education.’

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 staff disagreed that exclusion helped problem gamblers, two were hotels and two were clubs. One hotel manager with a small gaming installation had no opinion on this issue. Overall, the majority of people (58%) who felt that exclusion really helped problem gamblers were from the large venues. 5.14 Adequacy: Physical Environments 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 near the 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 can keep a reasonable eye on customers when they get change.’

78

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 is an 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 the environment 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%) whose managers 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 environment encourages responsible gambling had large gaming installations. 79

5.15 Adequacy: Financial Transactions Opinion on the Code’s rules and limits on financial transactions in encouraging responsible gambling was evenly divided, with managers and staff in six venues (50%) agreeing and managers and staff in six venues (50%) disagreeing on their potential 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 limits overspending.’

ß

‘Yes, but there is not much you can do if they win only $1,000. People sometimes 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 cashing processes 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 cash limit 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 so numerous 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.’

80

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 cutoff point, $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 on a 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 on financial 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 these venues were hotels and one was a club. Thus, while perceptions on the adequacy of rules and limits on financial transactions in encouraging responsible gambling were evenly divided, those who were supportive of this practice area had large gaming installations and those who were not supportive were mostly hotels. 5.16 Adequacy: Advertising 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 to your attention. Advertising is a strong motivator. It also assists kids to make responsible decisions. Irresponsible kids will do it anyway.’

81

ß

‘Yes, especially family advertisements. Some gamblers might not think they have a problem but it might trigger some awareness. It helps some people 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 keno screen 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 or drink 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 see what they want to see.’

ß

‘The QHA seminar was informative about advertising. Morals of the advertiser should be responsible for gambling. I agree that advertising targets 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. Of the 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

82

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 opinions on the potential effectiveness of the other three practice areas (provision of information, financial transactions and advertising) were evenly divided between agreement 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 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 be impeding implementation. 5.18 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 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.’

83

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 selfexclusion 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 will express 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 treating customers 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 message about 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 near schools.’

ß

‘Nothing is a waste of time. They might seem like little things to some people 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.’

84

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 and financial transactions were mentioned by different people as being important practices encouraging responsible gambling. One practice, advertising and promotion was not mentioned 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 the Code in their venues:

85

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. We need 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 gambling code of practice.’

ß

‘Some pubs and clubs do not manage children on premises very well, for example 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 size does 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 $100 notes 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 $20 to spend. People still spend the same amount.’

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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. I recommend that we get rid of this measure.’

ß

‘The $50 and $100 note change is totally ineffective. It just means that the coin 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 no barrier. 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 and differences 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 gambling expenditure, 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) would help. 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, doing deals and then leaving quickly). Indigenous ladies play gaming machines to escape husbands who would take their money, drink it and become violent to their wives.’

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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 with gambling. Whilst only three venue managers made these comments, their venues were located in poorer areas of Townsville, those showing signs of neglect and need. These managers 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. These respondents 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, and facilitators and barriers to its efficacy. 5.21 Awareness and Implementation 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 others received 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 installed problem 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 venue managers (75%) said they would support customers by providing information on problem gambling help, but only half had the means to do this effectively. A high proportion 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 88

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 legislative requirements. Minors were excluded from gambling areas and from gambling, and intoxicated persons were not served any further alcohol. All interviewees reported they 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. Small venues 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 venues were more likely to undertake advertising and promotion than small venues. 5.22 Adequacy Most respondents (75%) perceived that the Townsville region has adequate gambling related 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 and advertising 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 as being 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 89

encouraging responsible gambling practices was the removal of $50 and $100 note acceptors on gaming machines. It was claimed that this measure had practically no effect on reducing problem gambling and made little difference to gambling expenditure in the long term.

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SECTION SIX 6 6.1

THE SOUTH EAST QUEENSLAND CASE STUDY

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 population is 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 City and 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 to Rainbow 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 a diverse 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 as the 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. The Brisbane 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, favourable climate 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 moved to 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 a cosmopolitan Australian city (http://www.brisbane.qld.gov.au).

Twenty organisations in south-east Queensland were approached for interviews for this study. Between February and April 2003, managers and/or key staff members at fourteen venues and two industry associations were interviewed. These venues

91

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 three small). All fourteen venues (100%) had gaming machines and keno facilities, while ten (71%) offered TAB facilities. In each venue, the owner, manager or gaming manager 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 Code had 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 the previous 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%) had possession 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 of their 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 that copies of the Code and the Resource Manual went to all clubs and hotels, members 92

and non-members. Some copies were personally delivered, others were distributed at workshops and some others were mailed out. Future training opportunities were foreshadowed 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 only aware 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 Code they 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 Queensland Venues CODE OF PRACTICE ELEMENTS

LARGE HOTELS

SMALL HOTELS

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 gambling mission statement

Y

Y

Y

Y

Y

Y

Y

N

N

Y

N

Y

Y

Y

Displays help information in all gaming areas

Y

Y

Y

Y

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

Displays help information near EFTPOS/ATMs servicing gambling areas

Y

Y

N

Y

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

Displays help information in toilets

Y

Y

Y

N

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

Displays information on the responsible gaming policy document

N

Y

N

N

Y

Y

Y

N

N

N

Y

Y

N

Y

Displays information on the rules of play and odds of winning

N

Y

N

N

Y

N

N

Y

N

N

Y

Y

N

Y

Displays information on exclusion provisions

N

Y

N

N

Y

Y

Y

N

N

N

Y

Y

N

Y

Displays information on gambling related complaints resolution

Y

Y

N

N

N

Y

Y

N

N

N

Y

N

N

Y

Displays information on financial transactions practices

Y

Y

Y

N

Y

Y

Y

N

N

N

Y

Y

N

Y

Displays odds of winning a major prize

Y

Y

N

N

N

Y

N

Y

N

N

N

Y

N

Y

2. Interaction with Customers and Community

12

16

17

18

7

10

14

5

6

13

9

11

15

8

Establish links with support services

N

Y

N

Y

N

N

Y

N

N

Y

Y

N

Y

Y

Establish links with community

N

Y

N

N

N

N

Y

N

N

Y

Y

Y

N

Y

Customer liaison provides information to customers

N

Y

N

Y

N

Y

Y

Y

N

Y

Y

Y

Y

Y

Support staff in providing assistance to customers

N

Y

Y

Y

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

Provide assistance to staff with gambling related problems

N

Y

Y

Y

Y

Y

Y

N

N

Y

N

Y

Y

Y

Customer complaints system established and promoted

N

Y

Y

Y

Y

Y

Y

N

N

Y

Y

Y

Y

Y

Ensure responsible gambling training is provided to relevant staff

N

Y

Y

N

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

94

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-exclusion procedures and documentation

N

Y

N

Y

Y

Y

Y

N

N

N

Y

Y

Y

Y

Offers self-exclusion contact information for appropriate counselling agencies

Y

Y

N

Y

Y

Y

Y

Y

N

N

Y

Y

Y

Y

Self-excluded customers supported in seeking mutual exclusion from other gambling providers

N

N

N

N

Y

Y

Y

N

N

N

Y

N

Y

Y

Does not send correspondence or promotional material to excluded 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 from gambling

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Minors excluded from area where adults gambling

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Alcohol service encourage customers to take breaks in play

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

Y

N

N

Y

Intoxicated customers not permitted to continue gambling

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

Y

N

Y

Y

Childcare facilities meet legislated standards

N

N

Y

N

N

N

N

N

N

N

N

Y

Y

Y

Staff in gambling areas not to encourage tips

N

Y

Y

Y

Y

Y

Y

N

N

Y

Y

Y

Y

Y

Customers made aware of the passage of time

N

Y

N

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Customers discouraged from extended, 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 located close to gambling areas

N

Y

N

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

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

$500

$1000

$250

$500

$1000

$1000

$500

$500

$600

$500

$2500

$1000

$2000

$10000

Owners, boards, managers receive appropriate information to guide decision making

Gambling winnings above a set limit are paid by cheque and not cashed at venue until next day

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

95

Prohibits cashing cheques not made payable to the venue

N

Y

Y

N

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

Prohibits cashing cheques not payable to the person presenting the cheque

Y

Y

Y

Y

Y

Y

Y

Y

N

Y

Y

Y

Y

Y

Prohibits cashing multiple cheques

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Does not provide credit or lend money for gambling

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

Y

6. Advertising and Promotions

12

16

17

18

7

10

14

5

6

13

9

11

15

8

Complies with advertising code of ethics by AANA

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Is not false, misleading or deceptive

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Does not misrepresent the probability of winning a prize

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Does not give the impression that gambling is a responsible strategy for betterment

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Does not include misleading statements about odds, prizes, or chances of winning

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Does not offend prevailing community standards

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Does not focus exclusively on gambling

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

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

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Does not involve any external signs advising of winnings paid

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Does not involve any irresponsible trading practices by the gambling provider

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Y

Y

NA

Y

Y

Y

Y

NA

NA

Y

Y

Y

Y

Y

Does not depict or promote alcohol consumption with gambling Obtains consent prior to publishing the ID of any person who wins a prize Y – YES

N – NO

NA – NOT APPLICABLE

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6.4

Implementation: Provision of Information

Problem gambling signage was displayed in thirteen (93%) of the fourteen venues visited. 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 placed near 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 these areas, 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 were popular 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 winning either 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 at the security desk or cashiers’ booth. Information on resolving gambling complaints was on hand in six venues (43%). Nine of the fourteen venues (64%) had information publicly 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, a distinguishing 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

97

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 the Code, 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 either with 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 the chain 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 recent past 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 a diary 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

98

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 gamblingrelated problems. In five of these venues (38%) staff are not permitted to gamble. Three managers (21%) reported they have had staff who presented as problem gamblers. 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, depending on 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 their human resources staff or within their industry group who provided this training at induction, and three venues used private providers. In two venues, where senior gaming 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 a result, 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 venue managers (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, the venues were evenly divided by size, three being large and three being small.

99

Thus, the majority of venues had the means to assist customers by providing problem gambling advice. Most managers (79%) had supported related training and skills development for their staff, yet less than half (43%) had any links with gambling related support services or community networks. Large venues appeared better equipped to provide customers with information on where to get help for gambling problems and have more trained staff than small venues. 6.6

Implementation: Exclusion Provisions

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. They would offer that customer advice and information on exclusion, after ascertaining if it was actually risky gambling that was causing the distress. Two venues kept an incident 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 that they 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 offer customers seeking self-exclusion relevant information to contact appropriate counselling agencies. Agencies named were the Gambling Helpline, Relationships Australia, 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, these respondents reported that, as there were no formal mechanisms for mutual exclusion,

100

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 might breach legislation. Further, one person said there is a need for a Queensland-wide card system to monitor and control shared mutual exclusion information. Another person wanted 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 targeted correspondence or promotional material to self-excluded customers. However some still sent out general newsletters. Three venues (21%) did not send any promotional material 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 and four 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 offer customers seeking self-exclusion relevant contact information for appropriate counselling agencies. Nine (64%) of these eleven venues had formal self-exclusion procedures 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 customers seeking consensual exclusions from other gambling providers was that this was hard to regulate, potentially law breaking and therefore needed more development. 6.7

Implementation: Physical Environments

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 and adjacent 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 or courtyard while she gambled.

101

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 no extra 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’t make 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 before they 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 part of 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 was provided 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 junior members 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’. In three 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%) through a 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 one mechanism 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 to keep track of time, covering windows to prevent outside observation of gaming areas is a legislative requirement. Additionally, when the casino was built, natural light was not 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 inhouse 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 small venues 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 made aware 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 it overlapped with legislative requirements. This was evident in the practices of excluding minors from gambling areas, excluding minors from gambling and in not serving 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 not always 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

103

more likely to have embraced responsible gambling practices in their physical environment than the small venues. 6.8

Implementation: Financial Transactions

All fourteen venues had a mixture of ATMs and EFTPOS facilities for financial transactions. 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 above which 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 for winnings 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 and hotels, 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 from this 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 is not 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 competition was 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 large amounts 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 was prohibited. 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. Small venues 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. 6.9

Implementation: Advertising

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.

105

The eleven managers (79%) who advertised and promoted their venues stated that their advertising would comply with the Advertising Code of Ethics. They maintained that 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 loyalty schemes, happy hours with cheap drinks, and the like. The same eleven managers (79%) also suggested that their advertising did not misrepresent 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 that his 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 or promotes the consumption of alcohol with gambling. Finally, all managers indicated they did or would gain the consent of people before publicising their name as prizewinners. 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 no advertisements 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 advertising and 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 to advertise 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 potential effectiveness 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 responsible gambling

D

A

A

D

A

D

A

D

A

A

D

D

A

D

Support services are adequate to assist customers and the community who need help

DN

A

A

A

DN

DN

A

DN

DN

A

A

A

A

A

Exclusion really encourages responsible gambling

A

A

D

A

A

A

A

A

DN

A

A

D

D

A

Physical layout & environment encourages responsible gambling

A

A

A

A

A

A

A

A

A

A

A

D

A

A

Rules & limits on financial transactions encourage responsible gambling

A

D

D

A

A

A

DN

A

A

A

A

D

A

A

Advertising and promotions help promote 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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6.11 Adequacy: Provision of Information Opinion on the adequacy of information and signage in encouraging responsible gambling was evenly divided. Managers and staff in seven venues (50%) maintained that information and signage was adequate and did assist in encouraging responsible gambling. 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 winning might 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 people can 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. Their comments included: ß

‘While signage might be good, it has a low effect because people with information overload don’t read signs.’

109

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 people read responsible gambling signs.’

ß

‘People don’t read signs.’

ß

‘People don’t read signs. It might help having wallet cards in the toilets where 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 help especially 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 their advertisements 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%). These were equally divided. Of the seven large venues visited, three agreed and four disagreed that the provision of appropriate information encourages responsible gambling. 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 (including the 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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6.12 Adequacy: Interaction with Customers and Community The majority of managers and staff (64%) interviewed in the fourteen venues agreed that there were adequate gambling related support services to assist customers and members of the south-east Queensland community who need this help. In support, the majority 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 get confused 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 customers and 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 and sector, although, in five venues (38%), the managers and staff interviewed did not have an opinion about the adequacy of gambling related support services saying:

111

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 gambling related 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. 6.13 Adequacy: Exclusion Provisions 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 that worked 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 other venues 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 selfexclude from other venues and it can be difficult to monitor people coming into the venue.’

ß

‘It probably does work if they seriously believe they have a problem. But they 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 between the 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 in place but it is not going to prevent someone becoming a problem gambler.’

ß

‘Self-exclusion needs adequate follow-up support over time that strengthens 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 a lot of it is self-help’. In terms of size and sector, of the ten (71%) venues who agreed that exclusion for problem 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 and three 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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6.14 Adequacy: Physical Environments Managers and staff in thirteen (93%) of the fourteen venues agreed that appropriate physical 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 add generally to a lighter more natural environment.’

ß

‘Natural light helps, but people do not look around at clocks. I feel that the gambling 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 all help.’

ß

‘Many gambling venues are too dark, confined and removed from other venue activities.’

ß

‘Natural lights and clocks are important so they can tell how long they have been here.’

114

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 gambling rooms, 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. 6.15 Adequacy: Financial Transactions In the fourteen south-east Queensland venues, ten managers and staff (71%) agreed rules and limits on financial transactions were adequate in encouraging responsible gambling, 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 at this venue or at another venue. It is amazing how often this happens. Therefore it is effective. ATMs outside the gaming areas also make players get 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 no gaming 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.’

115

ß

‘Cash limits for winnings payments help with a 24-hour cooling off period. ATM locations outside the gambling room put some distance between the gambler and their money.’

ß

‘Casinos have different legislative requirements to hotels and clubs, but they 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 electronic banking.’

ß

‘Not so much the location of ATMs, but rather they cannot access credit cards is the measure that encourages responsible gambling. Cheque limits are 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 116

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. 6.16 Adequacy: Advertising 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 and drinking 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 hard because some operators do not subscribe to responsible gambling therefore our group (named) is somewhat disadvantaged by competing against unethical 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: 117

ß

‘Every consumer transaction is linked to a promotion somehow. You can’t stop promotions. However, people do need to be responsible about them and we feel that this happens anyway.’

ß

‘Promotions over do it. Promotions encourage people to gamble more than they 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 on size 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-east Queensland interviews agreed that an appropriate physical layout and a well lit environment for gaming rooms are a very important measure for encouraging responsible 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 transactions also facilitate responsible gambling (71%); and that there are adequate gambling related support services (64%). The provision of information and signage did not receive 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 to vary 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 as clubs thought that self-exclusion for problem gamblers was very effective in encouraging responsible gambling.

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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 for the widespread implementation of the Queensland Responsible Gambling Code of Practice in south-east Queensland and its potential effectiveness in encouraging responsible 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 be impeding 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 Clubs QLD staff. Clubs QLD needs to make implementation of the Code part of their membership and do an audit of their members. It is a good opportunity 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 to training. This is a huge commitment. They have trained everybody including cleaners and back of house to demonstrate that this is a real team effort. 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 been trained so far. Not all workers have been through training as it is so new.’

119

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 no problems with clocks and natural light.’

ß

‘Promoting financial transactions and self-exclusions. Card based gambling 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 day per venue or amounts per day.’

ß

‘Physical environment. Types of financial transactions (no access to credit account) 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 and there 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 a service for their own enjoyment. They make their own choices.’

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As evident from the above comments, training, education and skills development of gaming management and staff were perceived as being the most important facilitators in 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 the Code 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. They should 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 to try 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, although maybe promotions do.’

ß

‘Brochures and information, financial transactions, light and clocks, selfexclusion.’

ß

‘Moving ATMs away from the gaming area.’

ß

‘Physical layout; if you want to gamble you will.’ 121

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 occasionally having some loss of control. People at risk do not see themselves as having problems.’

From the above comments, provision of information, including signage and knowing the odds of winning, was perceived to be the least potentially effective practice in encouraging responsible gambling. 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. 6.21 Awareness and Implementation Thirteen (93%) of the fourteen venue managers and staff interviewed had received and 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 information outlined 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 where most 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 could assist people by providing contact details for gambling-related support services. Most

122

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 had more staff trained in responsible gambling than the smaller venues. Three-quarters of managers and staff (79%) maintained they would offer customers seeking selfexclusion 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-excluded customers was mutual exclusion from other gambling venues. All managers and staff were cognisant of the legislative requirements included in the Code, such as excluding minors 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 was not always the case. More hotels than clubs were likely to have strategies to discourage extended, intensive and repetitive play and large venues appeared more likely 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 winnings compared to large venues, as did hotels compared to clubs. The majority of respondents (79%) reported that their advertising and promotions complied 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

123

venues and between clubs and hotels. Nine managers and staff (64%) interviewed considered there were adequate gambling related support services in the region, and attitudes 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 for problem 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 hotels than 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 in eleven venues (78%) agreed that advertising practices could play a role in responsible gambling, while three (21%) disagreed. Views on the adequacy of this practice area were 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 area for encouraging responsible gambling;

•

ethical advertising and promotions are the next most important for encouraging responsible gambling;

•

self-exclusion for problem gamblers is an effective practice that assists problem gamblers and equally that rules and limits on financial transactions encourage 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 encouraging responsible gambling. 124

6.23 Facilitators and Impediments The most frequently mentioned factor raised as being effective in encouraging responsible gambling practices was training, education and skills development in gaming management and staff. The most commonly mentioned factor considered potentially ineffective in encouraging responsible gambling was the provision of information including signage and knowing the odds of winning.

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SECTION SEVEN

7 7.1

CROSS-CASE ANALYSES OF THE THREE CASE STUDIES 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 venues examined 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. For example, 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 some cases, 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 the exclusion 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. In this situation, the percentage compliance with this practice is calculated by comparing the number of elements complied with against the total number of elements applicable to 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.

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Table 7.1 Regional Location and Compliance with the Code

Venue 1 2 3 4

Information (10) No. % 4 40 4 40 5 50 3 30

Ave for Longreach

Interaction (8) No. % 1 12 0 0 2 25 2 25

40

Exclusion (4) No. % 0/1 0 0/1 0 1/1 33 2/1 67

16

Environment (8) No. % 5/1 71 6/1 86 6/1 86 7/1 100

25

Fin Transaction (6) No. % 4 67 4 67 4 67 4 67

86

Advertising (12) No. % 0/12 0/12 0/12 0/12 -

67

Total (48) No. % 14/14 41 14/14 41 18/14 53 18/14 53

-

47

5 6 7 8 9 10 11 12 13 14 15 16 17

5 0 8 10 8 9 9 7 4 8 4 10 4

50 0 80 100 80 90 90 70 40 80 40 100 40

4 0 5 8 6 6 7 1 8 8 7 8 5

50 0 63 100 75 75 88 12 100 100 88 100 63

2 1 4 4 4 4 3 2 1 4 4 3 1

50 25 100 100 100 100 75 50 25 100 100 75 25

6 5 5 8 7 7 5 5 7 7 6 7 6

75 63 63 100 88 88 63 63 88 88 75 88 75

6 4 6 6 6 6 6 4 6 6 6 6 5

100 67 100 100 100 100 100 67 100 100 100 100 83

0/12 0/12 12 12 12 12 12 12 12 12 12 12 0/12

100 100 100 100 100 100 100 100 100 100 -

23/12 10/12 40 48 43 44 42 31/1 38 45 39 46 21/12

64 28 83 100 90 92 88 66 79 94 81 96 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

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 centred on 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 was responsible 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 the venues, 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 Code relating 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 financial transactions (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 an average 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 the Code’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 with Townsville, 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, small venues 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 in Townsville, after taking the size of the venues in the respective samples into consideration.

128

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 than the 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% in Townsville. 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 is clear 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 - the provision of information, interaction with customers and the community, and exclusion provisions. Differences in the other three practice areas are either non-existent or negligible.

129

Table 7.2 Venue Size and Compliance with the Code Venue 1 2 3 4 5 6 12 13 16 17 18 19 22 24

Information (10) No. % 4 40 4 40 5 50 3 30 5 50 0 0 7 70 4 40 10 100 4 40 3 30 5 50 3 30 2 20

Interaction (8) No. % 1 12 0 0 2 25 2 25 4 50 0 0 1 12 8 100 8 100 5 63 6 75 3 38 0 0 0 0

Exclusion (4) No. % 0/1 0 0/1 0 1/1 33 2/1 67 2 50 1 25 2 50 1 25 3 75 1 25 3 75 3 75 1/1 33 0/1 0

Environment (8) No. % 5/1 71 6/1 86 6/1 86 7/1 100 6 75 5 63 5 63 7 88 7 88 6 75 7 88 6/1 86 6/1 86 5/1 71

42

36

38

80

Ave for Small 7 8 9 10 11 14 15 20 21 23 25 26 27 28 29 30

8 10 8 9 9 8 4 6 4 3 9 8 8 9 9 9

80 100 80 90 90 80 40 60 40 30 90 80 80 90 90 90

5 8 6 6 7 8 7 8 5 0 6 8 8 8 8 8

63 100 75 75 88 100 88 100 63 0 75 100 100 100 100 100

4 4 4 4 3 4 4 4 2 0/1 2/1 4 4 4 3 4

100 100 100 100 75 100 100 100 50 0 67 100 100 100 75 100

5 8 7 7 5 7 6 4/1 5/1 5/1 7/1 5 7/1 5 5/1 7/1

63 100 88 88 63 88 75 57 71 71 100 63 100 63 71 100

Fin Transaction (6) No. % 4 67 4 67 4 67 4 67 6 100 4 67 4 67 6 100 6 100 5 83 5 83 6 100 3 50 4 67

Advertising (12) No. % 0/12 0/12 0/12 0/12 0/12 0/12 12 100 12 100 12 100 0/12 12 100 0/12 0/12 0/12 -

Total (48) No. % 14/14 41 14/14 41 18/14 53 18/14 53 23/12 64 10/12 28 31/1 66 38 79 46 96 21/12 58 36 75 23/13 66 13/14 38 11/14 32

100

56

77 6 6 6 6 6 6 6 5 6 5 5 5 5 4 5 5

100 100 100 100 100 100 100 83 100 83 83 83 83 67 83 83

12 12 12 12 12 12 12 12 12 0/12 12 12 12 12 12 12

100 100 100 100 100 100 100 100 100 100 100 100 100 100 100

40 48 43 44 42 45 39 39/1 34/1 13/14 41/2 42 44/1 42 42/1 45/1

83 100 90 92 88 94 81 83 72 38 91 88 94 88 89 96

Ave for Large

76

83

85

79

91

100

85

Av for all Venues

60

61

63

80

84

100

74

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, the casinos 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 clubs and 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.

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Table 7.3 Venue Type and Compliance with the Code Venue 1 3 4 7 10 12 14 16 17 18 19 20 22 23 24 28 29

Information (10) No. % 4 40 5 50 3 30 8 80 9 90 7 70 8 80 10 100 4 40 3 30 5 50 6 60 3 30 3 30 2 20 9 90 9 90

Interaction (8) No. % 1 12 2 25 2 25 5 63 6 75 1 12 8 100 8 100 5 63 6 75 3 38 8 100 0 0 0 0 0 0 8 100 8 100

Exclusion (4) No. % 0/1 0 1/1 33 2/1 67 4 100 4 100 2 50 4 100 3 75 1 25 3 75 3 75 4 100 1/1 33 0/1 0 0/1 0 4 100 3 75

Environment (8) No. % 5/1 71 6/1 86 7/1 100 5 63 7 88 5 63 7 88 7 88 6 75 7 88 6/1 86 4/1 57 6/1 86 5/1 71 5/1 71 5 63 5/1 71

58

52

59

77

Ave for Hotels 2 5 6 9 11 13 15 21 25 26 30

4 5 0 8 9 4 4 4 9 8 9

40 50 0 80 90 40 40 40 90 80 90

10 8

100 80

Ave for Clubs 8 27

0 4 0 6 7 8 7 5 6 8 8

0 50 0 75 88 100 88 63 75 100 100

8 8

100 100

58

0/1 2 1 4 3 1 4 2 2/1 4 4

0 50 25 100 75 25 100 50 67 100 100

4 4

100 100

67

6/1 6 5 7 5 7 6 5/1 7/1 5 7/1

86 75 63 88 63 88 75 71 100 63 100

8 7/1

100 100

63

Fin Transaction (6) No. % 4 67 4 67 4 67 6 100 6 100 4 67 6 100 6 100 5 83 5 83 6 100 5 83 3 50 5 83 4 67 4 67 5 83

Advertising (12) No. % 0/12 0/12 0/12 12 100 12 100 12 100 12 100 12 100 0/12 12 100 0/12 12 100 0/12 0/12 0/12 12 100 12 100

Total (48) No. % 14/14 41 18/14 53 18/14 53 40 83 44 92 31/1 66 45 94 46 96 21/12 58 36 75 23/13 66 39/1 83 13/14 38 13/14 38 11/14 32 42 88 42/1 89

100

67

80 4 6 4 6 6 6 6 6 5 5 5

67 100 67 100 100 100 100 100 83 83 83

6 5

100 83

79

0/12 0/12 0/12 12 12 12 12 12 12 12 12

89

100 100 100 100 100 100 100 100

14/14 23/12 10/12 43 42 38 39 34/1 41/2 42 45/1

41 64 28 90 88 79 81 72 91 88 96

48 44/1

100 94

100 12 12

100 100

74

Ave for Casinos

90

100

100

100

92

100

97

Ave for all Venues

60

61

63

80

84

100

74

7.6

Perceived Adequacy of the Code

The level of compliance with the Code should logically be related to venue managers’ perceptions of 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 the perceived 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 was physical 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 that the 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 of 40%, was the provision of information.

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Table 7.4 Regional Location and Perceived Adequacy of the Code

Location of

Provision of adequate

Support services are

Exclusion really

Physical layout &

Rules & limits on

Advertising and

venue

information & signage

adequate to assist

encourages responsible

environment

financial transactions

promotions help promote

encourages responsible

customers and the

gambling

encourages responsible

encourage responsible

responsible gambling

gambling

community who need

gambling

gambling

help A

D

DK

A

D

DK

A

D

DK

A

D

DK

A

D

DK

A

D

DK

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

-

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

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

L’reach (4)

T’ville (12)

% Total (30) %

A - AGREE

D - DISAGREE

DK – DON’T KNOW

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 to all 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 Longreach occurred 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 Townsville respondents 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 and staff 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 practices between 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 and the QHA should increase the exposure of small venues to the benefits of the Code in order to increase compliance by small gambling establishments.

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Table 7.5 Venue Size and Perceived Adequacy of the Code

Size of

Provision of

Support services are

Exclusion really

Physical layout &

Rules & limits on

Advertising and

venue

adequate information

adequate to assist

encourages

environment

financial transactions

promotions help

& signage

customers and the

responsible gambling

encourages

encourage

promote responsible

encourages

community who need

responsible gambling

responsible gambling

gambling

responsible gambling

help

Small (14) % Large (16) % Total (30) %

A

D

DK

A

D

DK

A

D

DK

A

D

DK

A

D

DK

A

D

DK

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

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

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

A - AGREE

D - DISAGREE

DK – DON’T KNOW

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.

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Table 7.6 Venue Type and Perceived Adequacy of the Code

Type of

Provision of

Support services are

Exclusion really

Physical layout &

Rules & limits on

Advertising and

venue

adequate information

adequate to assist

encourages

environment

financial transactions

promotions help

& signage

customers and the

responsible gambling

encourages

encourage

promote responsible

encourages

community who need

responsible gambling

responsible gambling

gambling

responsible gambling

help

Hotel (17) % Club (11) % Casino (2) % Total (30) %

A

D

DK

A

D

DK

A

D

DK

A

D

DK

A

D

DK

A

D

DK

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

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

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

-

-

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

A - AGREE

D - DISAGREE

DK – DON’T KNOW

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 of compliance 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 either hotels or clubs. Location, venue size and venue type also appear related to perceived adequacy of the Code. The data 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 their counterparts 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 the perceived effectiveness of the practices. However, this link cannot be confirmed statistically in this research.

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SECTION EIGHT

8 8.1

CONCLUSIONS

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 by the 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 impediments to 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 and implement 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 the Code’s suggested advertising practices, there were distinct differences between the usage of advertising and promotions by venues in heavily populated and sparsely populated locations. Most venues in heavily populated locations engaged in advertising and promotions, yet little advertising 140

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 attract customers. 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, the research 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 in some local newspaper advertising that either raised questions about the veracity of some respondents’ answers to these questions or raised questions about their understanding and implementation 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 the venues. 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 more willing 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 of information, 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 the elements in these practice areas. Based on venue type, implementation of all measures contained in the Code in the casinos that participated 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 area of 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 141

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 were found 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. Prominent differences in implementation rates relate particularly to the practice areas of provision of information, interaction with customers and the community, and exclusion provisions. That is, small venues 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 and the 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, financial transactions and advertising, were minor. 8.3

Results for Research Objective 2

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 and promotions 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 convinced that 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 current Gambling 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 in Townsville were very positive about the adequacy of their interaction with customers and support 142

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 the practice 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 the adequacy of the provision of information practice area. Based on type of venue, managers and staff in clubs were more positive about the 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 practices relevant to provision of information, interaction with customers and the 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 already identified, 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. 8.4

Results for Research Objective 3

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 development in the provision of responsible gambling. Respondents in south-east Queensland and Townsville rated staff training and education as having the highest priority in effective implementation of the Code. Well-informed, professionally trained staff that understood the

143

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 they had ongoing opportunities for continuous improvement and professional development in their management of responsible gambling issues. Association commitment to the Code and member 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 sound understanding 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 informed decisions 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 this concept 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 misguided prospect 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 that had been pulled down. Equally, the Resource Manual accompanying the Code was considered valuable in helping venues to operationalise the Code’s practices and in supplying 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 gambling providers. In contrast, there was variable compliance with voluntary aspects of the Code. As 144

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 is governed by much more stringent legislative requirements. ß

Experience in the provision of responsible gambling was a sixth factor assisting implementation 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 in responsible gambling, knew how to operationalise responsible gambling practices, and realised the possible negative consequences for non-compliance with a voluntary code. The import 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 any practices 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 and support 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 open communication, 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 could be 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 feature of 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 and Townsville had major concerns about the dearth of staff training and skills development for 145

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 remote regions, 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 and assistance needed to support those venues with the lowest implementation of the Code, as seen amongst venues with small gaming installations. As well, association members are regularly 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, the Code 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 managers with 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 would therefore 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 can see 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 managers made 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 connected to remote locations. Counselling services for problem gambling assistance in remote areas

146

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, with few 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 venue would be compromised if they implemented certain elements of the Code, if their competitors did not. This sixth barrier indicates a perception amongst some providers that implementing 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 had not 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 the Code 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 closed temporarily due to managerial problems, high staff turnover and financial difficulties had no copy of the Code or the Resource Manual.

8.5

Results for Research Objective 4

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 research objectives. The next section provides eighteen recommendations based on the conclusions drawn in Section Eight.

147

SECTION NINE 9

RECOMMENDATIONS

Based on the conclusions in Section Eight, this section provides the following recommendations to improve 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, including those 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 to improve 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 counselling services 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 in minimising 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 gaming installations. 6. That the Queensland Government, Clubs QLD and the QHA investigate ways to improve 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.

148

7. That the Queensland Government, Clubs QLD and the QHA investigate ways to increase compliance in remote areas with the practice areas of provision of information, 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 in liaising with gambling providers in their region, in providing their contact details, and in establishing mechanisms to encourage community networks that promote responsible 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 contained in the financial transactions practice area be considered for inclusion in the Code. 13. That the Queensland Government, Clubs QLD and the QHA organise for more frequent 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 of gambling 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 with implementing the Code is needed.

149

16. That the Queensland Responsible Advisory Committee, Clubs QLD and the QHA regularly review the Resource Manuals and support materials for the Code, with improvements based on venue feedback, sound research and wide consultation. 17. That Clubs QLD and the QHA investigate ways to optimise their membership rates and 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 responsible gambling materials are sent to all managers of clubs and hotels in Queensland.

150

SECTION TEN 10 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 responsible gambling

•

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 151

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.

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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:

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•

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 responsible gambling

•

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

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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 11 REFERENCES Australian Institute for Gambling Research, (1997). Definition and Incidence of Problem Gambling, Including the Socio-Economic Distribution of Gamblers, Victorian Casino and Gaming Authority, Melbourne. Carroll, A.B., (1979). ‘A Three-Dimensional Model Conceptual Model of Corporate Social Performance’, Academy of Management Review, Vol. 4, October, pp. 497-506. Carroll, A.B., (1991). ‘The Pyramid of Corporate Social Responsibility: Toward the Moral Management of Organizational Stakeholders’, Business Horizons, Vol. 34, No. 4, pp. 39-48. Clubs Queensland, (1999). Clubs Queensland Advertising and Promotions Code of Ethics, Clubs Queensland, Brisbane. Clubs Queensland, (1999). Clubs Queensland Responsible Gaming Policy, Clubs Queensland, Brisbane. Dickerson, M.G., (1993). ‘A Preliminary Exploration of a Two-Stage Methodology in the Assessment of the Extent and Degree of Gambling Related Problems in the Australian Population’, in W.R. Eadington and J.A. Cornelius (eds), Gambling Behavior and Problem Gambling, Institute for the Study of Gambling and Commercial Gaming, Reno, pp. 347-364. Dickerson, M.G., (1998). ‘EGM Players and Responsible Gambling’, in G. Coman (ed.), National Association for Gambling Studies Practitioners Conference Proceedings, National Association for Gambling Studies, pp. 33-42. Doherty, K., (1999). ‘Gambling Industry Codes of Practice: A Critical Review’, in J. McMillen and L. Laker (eds), Developing Strategic Alliances: Proceedings of the 9th National Association for Gambling Studies Conference, National Association for Gambling Studies, pp. 505-523. Hawe, P., D. Degeling and J. Hall, (1990). Evaluating Health Promotion: A Health Worker’s Guide, MacLennan and Petty Pty Ltd, Artarmon.

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Hing, N., (2000). Changing Fortunes: Past, Present and Future Perspectives on the Management of Problem Gambling by New South Wales Registered Clubs, unpublished Ph.D. thesis, University of Western Sydney – Macarthur, Sydney. Hing, N., (2003). ‘Principles, Processes and Practices in Responsible Provision of Gambling: A Conceptual Discussion’, Gaming Research and Review Journal, Vol. 7, No. 1, pp. 33 - 48. Hing, N., M. Dickerson and J. Mackellar, (2001). Australian Gaming Council Summary Responsible Gambling Document, Australian Gaming Council, Melbourne. Korn, D. and H. Shaffer, (1999). ‘Gambling and the Health of the Public: Adopting a Public Health Perspective’, Journal of Gambling Studies, Vol. 15, No. 4, pp. 289-264. Lesieur, H., (1996). ‘Measuring the Costs of Pathological Gambling’, in B. Tolchard (ed.), Towards 2000: The Future of Gambling, Proceedings of 7th National Conference of the National Association for Gambling Studies, National Association for Gambling Studies, Adelaide, pp. 11-22. Livingstone, C., (1999). ‘Hopelessness and Loss’, Arena Magazine, August, p. 34. 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, Free Association Books, London. Productivity Commission, (1999). Australia’s Gambling Industries: Final Report, Commonwealth of 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.

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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. Queensland

Treasury,

(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 of NSW Press, Sydney.

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SECTION ELEVEN 12 APPENDICES

Appendix A Dissemination of the Research Results With the permission of the Research and Community Engagement Division of Queensland Treasury, 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 Manly Leagues 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 the Research and Community Engagement Division, QLD Treasury, Brisbane. August 26, 2003.

ß

Buultjens, J., Breen, H. and Hing, N. (2003). ‘The Introduction of a Voluntary Responsible Gambling 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 Responsible Gambling Code of Practice: The Experience in North Queensland, Australia’ 9th. Asia 160

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 Towns Services 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.

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APPENDIX B ACTUAL and COMMITMENTS v TOTAL BUDGET Project: 50302 QLD Treas Breen Resp Gambling Strategies

YTD Actual

Total Actual

Commits Orders and Batches

Prior Year/s + Current + Commits

Variance Under/Over

98,282

0

98,282

0

98,282

0

98,282

98,282

0

98,282

0

98,282

0

Salaries 26 - Principal Researcher 26 - Secondary Researcher 26 -Secondary Researcher 27 - Consultant Researcher 27 - Research Assistant

25,000 18,975 18,975 5,000 959

0 0 0 0 0

25,000 18,975 18,975 5,000 1,158

25,000 18,975 18,975 5,000 1,158

25,000 18,975 18,975 5,000 1,158

0 0 0 0 199

Total Salaries

68,909

0

69,108

69,108

0

69,108

199

0%

NSI's 31 - Travel and Accommodation 32 - Vehicle Costs 37 - Printing 44 - Staff related expenses 49 - CGER administration costs

12,410 1,239 123 7,601 8,000

5,607 161 0 4,664 0

3,944 945 118 2,482 1,279

2,396 1,106 118 7,146 8,000

9,880 0 0 527 0

12,276 1,106 118 7,673 8,000

(134) (133) (5) 72 0

-1% -11% -4% 1% 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%

0

87,850

(77,877)

10,407

(10,407)

(0)

Budgeted

Prior Year Actual

Income 03 - Government Research Grants

98,282

Total Income

Surplus/(Deficit)

% Var

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 QLD hotels, casinos, and registered and licensed clubs in minimising harm and protecting consumers in their gambling. We would like to concentrate on Awareness - to assess the level of responsible gambling awareness by staff and managers in your gambling venue, and Adequacy - to ask staff and managers whether they think their responsible gambling practices are adequate in minimizing harm and protecting consumers.

Part A: Implementation of the Code of Practice 1. Provision of information

Gaming areas

Keno areas

Wagering areas

Reasons: facilitate / inhibit responsible gambling practices

Gaming areas

Keno areas

Wagering areas

Reasons: facilitate / inhibit responsible gambling practices

1.1 Responsible gambling mission statement displayed 1.2 Information on help for problem gambling displayed in all gambling areas AND near ATM and EFTPOS servicing gambling areas AND in toilets 1.3 Information is displayed on: the venue Responsible 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 and community 2.1 Community liaison establish effective links with gambling related support services And community networks 2.2 Customer liaison role to provide information to customers To support staff in providing assistance to those customers

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Provide assistance to staff with gambling related problems 2.3 Customer Complaints mechanisms are established & promoted 2.4 Training & skills development to ensure responsible gambling training is provided to relevant staff And, owners boards & managers receive appropriate information to guide decision making about responsible gambling 3. Exclusion provisions

Gaming areas

Keno areas

Wagering areas

Reasons: facilitate / inhibit responsible gambling practices

Gaming areas

Keno areas

Wagering areas

Reasons: facilitate / inhibit responsible gambling practices

Gaming areas

Keno areas

Wagering areas

Reasons: facilitate / inhibit responsible gambling practices

3.1 Provide self-exclusion procedures and documentation 3.2 Offers customers seeking self-exclusion contact information for appropriate counseling agencies 3.3 Self-excluded customers given support in seeking mutual exclusion from other gambling providers 3.4 Do not send correspondence or promotional material to excluded customers or on request 4. Physical Environment

4.1 Minors prohibited from gambling 4.2 minors excluded from areas where adults are gambling 4.3 Alcohol service encourage customers to take breaks in play 4.4 Intoxicated customers not permitted to continue to gamble 4.5 Childcare facilities 4.6 Staff in gambling areas not to encourage tips 4.7 Customers are made aware of the passage of time 4.8 Customers discouraged from extended, intensive & repetitive play 5. Financial Transactions

5.1 ATM facilities

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Not located close to entry of gambling areas 5.2 Established limit above which all winnings are paid by cheque or electronic transfer Gambling winnings above a set limit are paid by cheque and not cashed at the venue until the next day Prohibits cashing cheques not payable to the venue Prohibits paying cheques not payable to the person presenting the cheque Prohibits cashing multiple cheques 5.3 Gambling provider does not provide credit or lend money for gambling 6. Advertising and promotions

Gaming areas

Keno areas

Wagering areas

Reasons: facilitate / inhibit responsible gambling practices

6.1 Complies with advertising code of ethics by AANA 6.2 Is not false, misleading or deceptive 6.3 Does implicitly or explicitly misrepresent the probability of winning a prize 6.4 Does not give he impression that gambling is a responsible strategy for betterment 6.5 Does not include misleading statements about odds, prizes, or chances of winning 6.6 Does not offend prevailing community standards 6.7 Does not focus exclusively on gambling 6.8 Is not implicitly or explicitly directed at minors or vulnerable or disadvantaged groups 6.9 Does not involve any external signs advising of winnings paid 6.10 Does involve any irresponsible trading practices by the gambling provider 6.11 Does not depict or promote alcohol consumption with gambling 6.12 Obtains consent prior to publishing the identification 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. (Rate each 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 (such as knowing odds of winning, rules of games) encourages responsible gambling? Strongly Disagree; Disagree; Don’t Know; Agree; Strongly Agree

Further Comments:

2.

Do you think that there are adequate gambling related support services to assist customers and members of the community who need this help? Strongly Disagree; Disagree; Don’t Know; Agree; Strongly Agree

Further Comments:

3.

Does exclusion for problem gamblers really encourage responsible gambling? Strongly Disagree; Disagree; Don’t Know; Agree; Strongly Agree

Further Comments:

4.

Is it likely that a venue’s physical layout and environment can encourage responsible gambling? Strongly Disagree; Disagree; Don’t Know; Agree; Strongly Agree

Further Comments:

5.

In your view, do rules and limits on financial transactions encourage responsible gambling? Strongly Disagree; Disagree; Don’t Know; Agree; Strongly Agree

Further Comments:

6.

Do you think that current advertising and promotions help promote responsible gambling? Strongly Disagree; Disagree; Don’t Know; Agree; Strongly Agree

Further Comments:

7. In the package of responsible gambling practices mentioned above, does any one stand out as being an important barrier in encouraging responsible gambling?

8. In the package of responsible gambling practices mentioned above, does any one stand out as being an important 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 a result of this and other similar research, that these strategies will be reviewed and refined so that they are better able to protect gambling consumers.

167