Level 32, RBS Tower@Aurora Place 88 Phillip Street Sydney NSW 2000 E: [email protected] P: +612 8211 0639 F: +612 8211 0555W: www.auscasinos.com 5 September 2012 Ms Lyn Beverley Committee Secretary Joint Select Committee on Gambling Reform Parliament House Canberra ACT 2600 By Email: [email protected] Dear Ms Beverley, Please find attached the Australasian Casino Association’s response to the Questions on Notice attached to your letter dated 29 June 2012. If you require further information please do not hesitate to contact me on the numbers above or by email. Yours sincerely, Chris Downy Executive Director Questions on Notice: Submission 46 (Australasian Casino Association) INTRODUCTION The Australasian Casino Association (ACA) appreciates the opportunity to provide additional information regarding its submission to the Joint Select Committee Inquiry into the Prevention and Treatment of Problem Gambling. Before providing a response to the questions proposed by the Committee, the ACA wishes to make the following points: Casinos are regulated under each state and territory’s specific legislation. Requirements regarding casino operations are generally stricter as a result of licensing requirements in each state and territory. This point has been outlined in the ACA’s submission. These strict and extensive statutory regulatory frameworks include: o casino specific legislation; o subsidiary legislation (and in some cases additional contractual commitments); o government approved controls and operating procedures; o external government audits and compliance assessments; o government inspectors; o security and surveillance requirements; o extensive Responsible Service of Gaming (RSG) programs; as well as o robust codes of practice. Casinos also employ internal mechanisms and controls to audit compliance with those codes and frameworks (both via external and via their own internal audit) incorporating regular review processes aligned with an ongoing commitment to continuous improvement. Each state and territory casino regulator is actively involved in the ongoing regulation and monitoring of the casinos located in their jurisdiction. Many of the references to evidence that are contained within the questions on notice refer to licensed venues other than casinos. It appears that no attempt has been made to differentiate casinos from these venues. It should be noted that the Commonwealth published a National Snapshot of Gambling in April 2010 that provides an overview of the legislation that covers the operation of casinos and other licensed gaming venues in each particular jurisdiction. This is attached for the information of the Joint Select Committee as it is still relevant. STAFF INTERVENTION The original ACA submission outlines Australian casinos’ extensive Responsible Service of Gaming Training Programs and refresher training program frequencies. All casinos train their staff, at a minimum at the mandated level in the responsible service of gaming. Furthermore, the ACA supports the principle that casinos should train their staff in this area to higher standards than mandated. Training in all casinos is specific and checks for competency in how each individual casino’s processes deal with responsible gaming enquiries. All casinos have trained, and the larger casinos have both specially trained and dedicated, responsible gaming staff to assist those customers who may be experiencing difficulties with their gambling behaviours. Management at the larger operators are trained at higher levels in the responsible service of gaming for escalation paths that aim to provide for sustainable and responsible operations. The service ethos of casinos includes a fundamental and superior customer service principle, which necessarily requires interaction by staff with customers who appear to be in distress, for whatever reason/s. Inherent in the delivery of any goods or services is the training and expectation to do so in a responsible and compliant manner to achieve relevant and appropriate outcomes for all stakeholders. Casinos train their staff to report observable signs that may indicate problem gambling behaviours. Page 1 of 10 The major report conducted by Paul Delfabbro (referred to in Question 7) into the identification of problem gamblers within the gaming venue was completed in 2007 (in association with a number of others) for Gambling Research Australia (GRA). ACA member casinos are aware of this research and in many cases it has been used to develop many of the processes, resources and staff training programs related to identification of problem gambling behaviours. Some examples of the extent of training conducted follows: • At Lasseters Casino in Alice Springs, all gaming related staff are required to undergo training under a nationally accredited course. Staff are also required to undergo external training sessions provided by Amity Community Services. • At Wrest Point and Country Club Casino in Tasmania, all licensed gaming staff must undertake a Responsible Conduct of Gambling course within three months of being licensed. Additionally all gaming and relevant non-gaming staff are required to undertake a course that outlines the processes and resources under which the two casinos deliver Responsible Gambling practices. • At Echo Entertainment Group’s (Echo) Queensland casinos (Jupiters Gold Coast, Jupiters Townsville and Treasury Brisbane) , an on-line learning course has been developed and is made available to all staff through their designated Learning Centres on-site. Echo has developed a training DVD based on the Delfabbro research for use by its employees in its four casinos. Additionally, Echo has also developed a list of possible problem gambling risk indicators to identify problem gamblers in the casino using observable signs, reported signs and a combination of observed and/or reported signs. Professor Paul Delfabbro was consulted to peer review the list and he provided positive confirmation that the indicators developed were appropriate for the casino environment. • At Crown Limited casinos (Crown Melbourne and Burswood Entertainment Complex, soon to be Crown Perth), training is regularly conducted and reviewed and takes into account relevant peer reviewed and evidence based research such as Professor Paul Delfabbro’s ‘Identifying Problem Gamblers in Gambling Venues’, and ‘Current issues related to identifying the problem gambler in the gambling venue’ which was in fact co-authored by one of Crown Melbourne’s Responsible Gaming Psychologists. Staff dedicated to assist players who may need help with their gambling are specially recruited and trained. Chiefly, their duties include the education and provision of strategies to assist customers in managing their gambling behaviours; foster responsible gambling and assisting in preventing difficulties from arising and to deliver the casino’s responsible gaming programs. For example, Host Responsibility staff at SKYCITY Adelaide provide ongoing support through case management and referral to Gambling Help Services. Responsible Gaming Liaison Officers at Crown Melbourne provide assistance and information on Crown Melbourne’s Responsible Gaming Programs; provide referral information about Gambler’s Help and other community services and facilitate the Crown Melbourne’s Self-Exclusion program. Referrals come from other casino staff, customers, friends and family of customers who may be experiencing difficulties with their gambling behaviours, counselling staff and Gambling Help services. Burswood Entertainment Complex’s 24/7 functionality of their Responsible Gambling Information Centre and dedicated Responsible Gambling Advisors commences in September this year. Close working relationships with problem gambling help services have been established by casinos, or indeed they have engaged them as a third party provider - e.g. BetCare has been appointed by The Star in Sydney to provide gambling counselling and assistance for customers who identify with problem gambling behaviours. Both Wrest Point and Country Club Casinos have a close relationship with Gambler’s Help counsellors and both encourage them to attend both properties regularly. By welcoming Gambler’s Help counsellors to the properties, a better understanding of the gaming environment is facilitated for the counsellors and staff are able to have higher levels of contact with counsellors so that they are comfortable in contacting them for advice or referral. Page 2 of 10 Casinos do not train their staff to be counsellors. An exception may exist, such as at Crown Melbourne where professionals are specifically employed to provide an immediate and on site response counselling service, for example, the Responsible Gaming Psychologists that are employed at Crown Melbourne are employed to assist in many areas, including staff and patron welfare. Any crisis intervention (if required) is handled immediately and sensitively, at relevant properties often by dedicated responsible gaming staff or others, security or similar staff aligned always with the superior customer service ethos of our represented members. Given the many and varied visitors to our member properties for a variety of different entertainment options, any crisis event is various in nature and so is not necessarily linked to problem gambling behaviours. Casinos have processes that enable employees to report any behaviours they may feel require investigation. This is achieved through escalation paths to managers. Whistle-blower policies and third