The Gambling Regulation Act 2003 makes it compulsory for certain organisations that hold gambling industry licences to have a Responsible Gambling Code of Conduct and, in the case of gaming venue operators, a Self Exclusion Program (SEP) in place. Organisations required to have a VCGLR approved code include but are not limited to:
- Gaming venue operators
- Bingo centre operators
- The holder of the wagering licence or the wagering operator
- Keno operators
The Victorian Commission for Gambling & Liquor Regulation is responsible for approving those Codes and ensuring they are in place.
The Codes encompass a number of initiatives designed to ensure club members are able to make informed choices, as well as providing support mechanisms for those who need assistance.
CCV recommends clubs adopt the CCV Responsible Gambling Code of Conduct (Code 28)
This is a PDF file that requires the front page and page 8 to be tailored to your club. Please download the pages below and insert them into your document.
Compliance with the CCV Code requires that the Code to be available on your clubs website (if you have one) including in community languages which you can download below;
- CCV Code of Conduct Greek
- CCV Code of Conduct Italian
- CCV Code of Conduct Vietnamese
- CCV Code of Conduct Chinese
- CCV Code of Conduct Arabic
- CCV Code of Conduct Turkish
- CCV Code Of Conduct Spanish
CCV provides guidelines to help clubs effectively implement and operate the Community Clubs Victoria’s (CCV) Responsible Gambling Code of Conduct (Code 28).
Annual Code Review
Ministerial guidelines require clubs to undertake an annual review of the operation of the code in their club. CCV Code Annual Review Guidelines 2016
CCV, by virtue of the amalgamation, now has responsibility for three RG Codes:
The Clubs Victoria RG Code – Code 3;
The CCAV RG Code – Code 22; and
The CCV RG Code – Code 28.
While the CCV Code differs slightly from the other two in the way that certain information is gathered and reported, the procedures below are common to all three Codes.
There are three elements to complete the 2016 reviews of all three of these RG Codes,- Member/Customer Review, Management and Staff Review, and Code Author Summary 2016.
Member/Customer Review – complete by 10th May
- Download the Member/Customer Survey Wall Poster for Members and Guests and the Member/Customer Survey sheet, PLUS the Member/Customer Survey Summary Sheet below. Display the Notice within the approved gaming area and make the Survey sheets available from the service counter or on request. For Code 3 (old Clubs Vic) RG Code users – the Survey Sheet differs from the previous forms supplied. It is more direct and seeks feedback on specific aspects of the Code. It may be necessary to interview members and/ or guests to achieve any response – however, please bear in mind that any customer issue raised during the review should be addressed promptly, and the action noted in the Member/Customer Survey Summary.
- Once completed, summarise all responses from the customer surveys onto the Member/ Customer Survey Summary sheet.
- Return the Member/Customer Survey Summary to CCV (firstname.lastname@example.org) by the required date.* The CV Code stipulates a response date of 30th March for this element of the review. A number of clubs have already sought extensions of time, and so as not to disadvantage any member, we have extended the date for completion of the Customer Review to 10th May.
Management and Staff Review – complete by 30th June
Download the Management and Staff Survey and issue to staff. In addition to its role in helping clubs review their RG Codes, this Review is also an excellent document for refreshing knowledge of clubs’ Codes and RG in general.
Once completed, summarise all responses from the Management and Staff surveys onto the Management and Staff Summary sheet.
It should be returned for your clubs’ assessment and action in sufficient time for you to forward a summary to email@example.com no later than 30th June .
Code Author summary
CCV will complete the Code Author summary incorporating all club feedback and submit the overall summary to the VCGLR as required.
Please note that the operation of the three Codes is unworkable, and that CCV will can not actively continue to support the Clubs Victoria RG Code (Code 3) and the CCAV RG Code (Code 22). We are requesting that all clubs adopt the CCV RG Code (Code 28) as soon as possible so that for all CCV members who are not bound to service providers’ RG Codes, a single RG Code will apply. There is no fee payable for clubs who adopt the CCV code.
Adopting the CCV Code of Conduct
It is relatively easy for a club to adopt the CCV Responsible Gambling Code of Conduct (Code 28).
All venue operators, must complete a statement of adoption confirming that an approved Responsible Gambling Code of Conduct has been formally adopted.
New Club licensees adopting a generic CCV’s Code of Conduct (code 28) for the first time, must provide the Victorian Commission for Gambling and Liquor Regulation with:
- A completed Statement of adoption – code of conduct for a new licensee application form
- A copy of the minutes from a board or committee meeting confirming the decision to adopt a particular code of conduct. An appropriate minute could be;
i. “(Your Club) will adopt the CCV Responsible Gambling Code of Conduct (Code 28) forthwith.”
Existing club licensees switching to a different code of conduct, must provide the VCGLR with a completed Statement of adoption – code of conduct for an existing licensee application form .
Transition at your club should occur as soon as reasonably possible.
In practice, little change will be needed, however there are some things to consider:
- Ensure staff awareness of the change by convening a staff meeting or formal training session;
- Ensure formal and regular contact with Gambler’s Help and Venue Support Workers;
- Ensure the updated code versions in different languages are made available on your website if you have one;
- Ensure your Responsible Gambling Register is current;
- Preparation for the annual review of the Code.
Use the code guidelines above to ensure all processes are updated to your new code.
Commitment to Responsible Gambling
Clubs adopting the CCV Code are required to display the above message at the entrance to the gaming room and/or at the cashier’s station in the gaming room. Please print off a copy for display at your club.
Responsible Advertising and Promotions
Adherence to your Responsible Gambling Code of Conduct requires that each proposed advertisement and promotion at your club be checked against the AANA Code of Ethics to ensure compliance. (Note-Unaddressed advertising of Electronic Gaming Machine (EGM) gambling products is prohibited in Victoria.)
The AANA Code of Ethics is designed to ensure that advertisements and other forms of marketing communications are legal, decent, honest and truthful and that they have been prepared with a sense of obligation to the consumer and society and a sense of fairness and responsibility to competitors.
For your information a copy of the code of ethics follows and as you can see it is not onerous, but it does highlight the need for every advert and promo to be checked.
SECTION 1 COMPETITOR COMPLAINTS
1.1 Advertising or Marketing Communications shall comply with Commonwealth law and the law of the relevant State or Territory.
1.2 Advertising or Marketing Communications shall not be misleading or deceptive or be likely to mislead or deceive.
1.3 Advertising or Marketing Communications shall not contain a misrepresentation, which is likely to cause damage to the business or goodwill of a competitor.
CODE OF ETHICS
1.4 Advertising or Marketing Communications shall not exploit community concerns in relation to protecting the environment by presenting or portraying distinctions in products or services advertised in a misleading way or in a way which implies a benefit to the environment which the product or services do not have.
1.5 Advertising or Marketing Communications shall not make claims about the Australian origin or content of products advertised in a manner which is misleading.
SECTION 2 CONSUMER COMPLAINTS
2.1 Advertising or Marketing Communications shall not portray people or depict material in a way which discriminates against or vilifies a person or section of the community on account of race, ethnicity, nationality, gender, age, sexual preference, religion, disability, mental illness or political belief.
2.2 Advertising or marketing communications should not employ sexual appeal in a manner which is exploitative and degrading of any individual or group of people.
2.3 Advertising or Marketing Communications shall not present or portray violence unless it is justifiable in the context of the product or service advertised.
2.4 Advertising or Marketing Communications shall treat sex, sexuality and nudity with sensitivity to the relevant audience.
2.5 Advertising or Marketing Communications shall only use language which is appropriate in the circumstances (including appropriate for the relevant audience and medium). Strong or obscene language shall be avoided.
2.6 Advertising or Marketing Communications shall not depict material contrary to Prevailing Community Standards on health and safety.
SECTION 3 OTHER CODES
3.1 Advertising or Marketing Communications to Children shall comply with the AANA’s Code of Advertising &Marketing Communications to Children and section 2.6 of this Code shall not apply to advertisements to which AANA’s Code of Advertising & Marketing Communications to Children applies.
3.2 Advertising or Marketing Communications for motor vehicles shall comply with the Federal Chamber of Automotive Industries Code of Practice relating to Advertising for Motor Vehicles.
3.3 Advertising or Marketing Communications for food or beverage products shall comply with the AANA Food & Beverages Advertising & Marketing Communications Code as well as to the provisions of this Code.
Clubs may wish to encourage employee feedback in relation to the operation of the code. This can be sought as part of the annual review, or, via this feedback form.
Club Staff Gambling Policy
Your code requires clubs to have Staff Gambling Policy (page 8) and offers two options. The first option reads
Employees of this venue are not permitted to gamble here at any time including playing gaming machines, keno, wagering or purchasing lottery tickets.
At first glance this might seem overly restrictive and unfair on staff, however the reasons clubs might adopt this approach include
- guard against the risk of staff developing a problem with gambling. Some research exists that indicates staff who have greater exposure to gambling have a higher than average propensity to developing problems with gambling
- member perception-where staff are seen to be winning members may think they have an ability to manipulate the outcomes
Your policy should reiterate your club’s commitment to a responsible gambling environment, detail what is and what is not permitted as well as detailing where a staff member might seek information if they believe they or a fellow worker may have a problem with gambling. CCV has a Staff Gambling Policy Template which can be tailored to suit your club.
The other option in your code for a staff gambling policy states
Employees of this venue are not permitted to gamble while on duty. Off-duty employees of this venue may gamble at the venue providing they are not in uniform, not wearing their gaming licence identification and have been absent from the venue since their last rostered shift.
This alternative stance is more commonly suggested by regional clubs where no other entertainment options might be available.
It is the club’s choice as to which option to include in your code, but it is important to ensure the information has been clearly communicated via induction and regularly reminded at staff training sessions.