by Fiona Skivington
The Victorian Responsible Gambling Foundation has responded to an invitation by the Royal Commission into the Casino Operator and Licence to make a submission and, subsequently, provide evidence, to the Commission.
The Foundation’s submission is based on contemporary research and understanding that the social impact of gambling harm is poorer health and wellbeing, not only for the person who gambles, but for families, communities, and the general population.
In the submission, we make a case for amending the regulatory framework within which Crown operates to minimise gambling harms as part of a public health response, rather than focus, as it currently does, on the narrower concepts of 'responsible gambling' and 'problem gambling'.
…the social impact of gambling harm is poorer health and wellbeing.
This would reflect the findings of research, which tell us that the negative consequences associated with gambling are not only experienced by those who gamble or, specifically, by 'problem gamblers'. Harms from gambling affect individuals who gamble, individuals who do not gamble and the broader community.
Further, we argue that evidence demonstrates that regulating access to gambling products and their operational features is an effective way of reducing gambling harms at a population level.
The Foundation responds in the submission to a series of questions put to us by the Commission, which address a range of issues, including:
- responsible gambling codes of conduct
- steps a casino should take to detect problem gambling and gambling harm
- better practices for reducing problem gambling and gambling harm in a casino environment
- steps a casino operator should be required to take to prevent, detect and manage problem gambling.
In the absence of any settled research specific to best practice in reducing gambling harm in casinos, the Foundation identifies in the submission a series of better practices. These include:
- monitoring customers
- with reference to the full list of validated observable signs of harm documented by Thomas, A et al (2014)
- using data analytics to inform staff observations, such as real time monitoring of spend and time of continuous play
- via sufficient numbers of appropriately trained staff available on gambling floors
- preventing inducements to gamble, including via loyalty programs
- setting limits
- imposing mandatory universal pre-commitment systems that require customers to set a binding monetary and/or time gambling limit(s) per day prior to entering the casino
- imposing time limits on electronic gaming machines (EGMs) and table games to prevent continuous play
- setting appropriate maximum bet limits for EGMs
- aligning the operation of casino EGMs with the regulatory restrictions placed on other Victorian venues
- providing appropriate self-exclusion programs that:
- are easy to access, transparent in their operation and accessible outside of the casino
- facilitate additional support to the person who is excluding
- remove those who sign up to be removed from direct marketing lists
- supporting independent research and evaluation, including by participating in that research and collecting, and providing access to, relevant data.
Regulatory framework amendments
The Foundation argues that all providers of gambling services and products, which carry an inherent risk of harm, should be required to meet specified minimum standards to prevent gambling harm.
In relation to Crown, we call for the regulatory framework to be amended to:
- incorporate definitions of 'gambling harm' and 'problem gambling' based on research
- place responsibility on Crown to reduce gambling harm
- be capable of adapting to new research as it evolves, to improve public health outcomes for those at risk of harm
- make codes of conduct easily enforceable with the ability for penalties to be applied to breaches
- require Crown to collect and make available data in relation to gambling activity at the Melbourne Casino
- ensure that the Foundation's expertise is taken into account in regulation of Crown's obligations with respect to minimising gambling harm.
- Royal Commission website
- Foundation submission
- Videos of witnesses giving evidence at public hearings, including from the Foundation:
- CEO Shane Lucas – Day 12 – 4 June 2021 (at 3.58.50)
- Branch Head, Research & Evaluation Rosa Billi – Day 14 – 8 June 2021 (3.47.02).
The Royal Commission is due to report its findings and any recommendations by 15 October 2021.