CSI will manage gambling related complaints in accordance with the procedures as outlined below;
CSI offers a range of gambling products to its members, guests & visitors. CSI is committed to ensure that management of these products & related high customer service standards provided by the CSI team are delivered in a manner which consistently demonstrates industry best practice. Through full commitment & endorsement of the CSI Board Members, the implementation & monitoring by the senior management team, & delivery by our fully trained team, we ensure the safety & wellbeing of our members, guests & visitors, in particular to responsible service of gambling, is a priority. We have developed a strong partnership with our local Relationships Australia branch. Representatives from our management team attend regular Clubs Queensland meetings. We are passionate about ensuring that all our team are fully trained in all aspects of Responsible Service of Gambling, and Relationships Australia has a key role in facilitating this. All of our Duty Managers are Customer Liaison Officers (CLO’s) and also our Gaming Hosts.
As a community club & part of our commitment to our partnership with Relationships Australia, we will in the near future be providing the weekly use of the CSI Boardroom for the use by Relationships Australia gambling related individual & group counselling sessions.
Our focus is to be able to provide quality & current information to assist anyone who may be experiencing issues with gambling. Below is a wide range of self-help resources as well as our relevant policies & procedures. Hard copies of our policies & procedures as well as Relationships Australia & Gambling Help pamphlets etc are available from our Carpark Reception, throughout our Gaming Lounge or Gaming Cashier.
The following information is driven by the Responsible Gambling Code of Practice & describes how CSI provides & manages gambling products;
Practice 1 Provision of Information
- Responsible Gambling Statement.
CSI has developed a written statement on the club’s commitment to providing responsible assistance to problem gambling.
- Responsible Gambling Policy Document (House Policy).
CSI has developed our policy which contains information on how we address the problem gambling issue in the local community to be available to patrons on request and a notice advising patrons that it is available to be clearly displayed in the venue.
- Responsible Gambling Signs in venues (risk of problem gambling and where to get help).
CSI provides information about potential risks of gambling and where to get help for problem gambling, e.g. Gambling Help Service, Gambling Help Line & Relationships Australia is prominently displayed in throughout all gambling areas, all toilets, notebreakers and beside all ATM, EFTPOS facilities.
CSI have gambling help brochures in 11 different languages available at our gaming cashier.
We also have discrete Responsible Gambling take home packs (available from both of our club receptions & gaming cashier) which provide a wide range of information including Self Exclusion forms.
The CSI website has links to the above help services, has all of our responsible gambling in downloadable documents including Self Exclusion forms, links to foreign language help information & links to the Keno & UBet responsible gambling web pages.
- Nature of games and game rules
CSI provides information (in an easy-to-understand format) that explains to our patrons how the various gambling products are played) is available to patrons on request and to be included in the Player Information Guide. See also 1.3 Responsible Gambling Signs (above)
- Odds of winning or returns to player
CSI provides information (in an easy-to-understand format) that explains to our patrons the odds of winning major prize to be included in the Player Information Guide (availability to be clearly displayed). See also 1.3 Responsible Gambling Signs (above)
CSI provides information regarding exclusion provisions (self exclusions and venue-initiated exclusions) to our patrons. We provide discrete Responsible Gambling take home packs on request (available from both of our club receptions & gaming cashier) which provide a wide range of information including self exclusions & the Self Exclusion form.
The CSI website has downloadable a Self Exclusion form.
- Complaint resolution mechanisms
CSI has a gambling related Complaint Handling Procedure which contains information on how a patron can lodge a gambling-related complaint at the club and how it will be resolved. This procedure is available on request at both of the club’s reception areas & our gaming cashier.
- Financial transaction policy
Our Financial Transaction Policy outlines the key elements of how CSI manages certain in-house gambling related financial transactions. This is available to patrons on request at both of the club’s reception areas & our gaming cashier.
1.9 Other information (e.g. legislative requirements)
“Rules Ancillary to Gaming” is prominently displayed in next to our gaming cashier & 2 additional areas within the gaming room.
Practice 2 Interaction with customers and the community
2.1 The venue CLO provides appropriate information to assist patrons with gambling related problems.
All of CSI’s Duty Managers, Assistant Manager & General Manager are CLOs & have participated in formal CLO training.
All club team members are aware where all responsible gambling information is displayed in the venue; what information is available upon request and what information is contained in each document.
2.2 Our CLOs support staff in providing assistance to those patrons with gambling related problems.
Our CLOs can provide advice to our team on responsible gambling materials, exclusion provisions, physical environment, financial transaction policy and practices and advertising and promotions policies.
2.3 The venue CLO provides assistance to staff with gambling related problems.
Our management team/CLOs understand that patrons experiencing difficulty with problem gambling can adversely affect a team member’s emotional state. As well, team members may become problem gamblers themselves.
2.4 The venue CLO can provide contact details of the local Gambling Help Service.
We have pamphlets available with both Relationships Australia & Gambling Help Service.
2.5 The venue CLO has established links with the local Gambling Help Service.
We have developed a strong partnership with our local Relationships Australia branch. Representatives from our management team attend regular Gold Coast RG Net meetings. We are passionate about ensuring that all our team are fully trained in all aspects of Responsible Service of Gambling, and Relationships Australia has a key role in facilitating this.
2.6 Venue staff are familiar with the venue’s customer complaint resolution mechanism or the venue CLO can advise staff in this regard.
CSI team members are to refer gambling-related complaints to the CLO on duty. The Duty Manager on every shift is a CLO.
The CLO will make contact with the patron and identify and define the nature and cause of the complaint, including giving assurance on confidentiality and privacy as per CSI’s policies.
The CLO will determine whether the complaint can be resolved immediately or should be referred to a higher level;
If the complaint can be resolved immediately, the CLO will take necessary steps to resolve the complaint on the spot.
If the complaint is to be referred to a higher level, the CLO will then inform the patron of the timeframe involved in communicating and getting a response on to compliant from the higher level.
The CLO will communicate the proposed solution to the patron, including the basis (legislation, policies etc.) on which the solution was framed.
If the patron is not satisfied with the outcome, the CLO will advise the patron to seek their own legal or professional advise (at their own expense should they wish).
The CLO will record details of the complaint and action taken in a Gambling – Related Incident Report.
2.7 The venue staff have received training from the Gambling Help Service and include the GHS in ongoing staff training in responsible gambling.
CSI has developed a strong partnership with our local Relationships Australia branch. Representatives from our management team attend regular Clubs Queensland meetings. We are passionate about ensuring that all our team are fully trained in all aspects of Responsible Service of Gambling, and Relationships Australia has a key role in facilitating this through guest speaking at our whole of team & gaming team meetings. All our management & team members are required to renew their RSG certification.
Practice 3 Exclusion Provisions
3.1 The CLO understands Self Exclusion.
CSI must & will exclude a patron who requests self exclusion.
Our team takes reasonable steps to prevent patron who is excluded from entering or remaining on a premises. All management team are sent emails identifying new exclusions. A photo log of all current excluded persons is sighted & signed off on daily by all team members on commencement of their shift.
The patron is issued with an Exclusion Notice and Exclusion Order.
The patron has a 24-hour cooling off period to reconsider their decision. If the patron changes their mind within 24 hours, a Revocation Notice & subsequently a self exclusion will be completed within the 24-hour time limit.
3.2 The CLO understands Venue Initiated Exclusions.
3.3 The CLO is aware of exclusion time periods.
Once exclusion takes effect, a patron cannot apply for it to be revoked for a minimum of 12 months. A patron can apply for an exclusion to be revoked only once a year. Exclusions remain in effect (unless revoked) for a maximum of 5 years.
3.4 The CLO provides advice and information to venue staff on the exclusion process.
Relationships Australia has provided in-house training relating to exclusions. All team members are required to renew their RGS certification on a yearly basis.
3.5 The CLO ensures the excluded patron is fully advised of the exclusion details and
process and can issue the patron with the relevant Exclusion Notice and Order or Direction.
Our CLO completes the exclusion documentation and the excluded person is fully informed of the terms of the exclusion, the products they are barred from using and the areas of the club they are not permitted to access during the period of exclusion.
3.6 The CLO ensures the local Gambling Help Service details are provided to the excluded patron.
As CSI has developed a strong relationship with Relationships Australia, we have recommend & provide their brochure as well as the Gambling Help Service information.
3.7 The CLO has sought assistance from the local Gambling Help Service regarding exclusions.
CSI’s strong relationship with Relationships Australia’s Gambling Help Service Community Educator/Counsellor ensures that we have access to over the phone, email & face to face advice relating to effectively encouraging patrons to seek assistance. We are aware that we can contact Gambling Helpline for assistance with non English speaking patrons.
Our CLO’s are aware that they can refer TAB patrons to the UBet website to initiate both online & self exclusion.
The CLO can contact the local gambling help service and discreetly request advice or guidance, asking general questions relating to the situation and not disclosing the patron’s identity at this stage.
3.8 The CLO has ensured promotional materials are not sent to an excluded patron.
Part of CSI’s internal self exclusion process is to stop correspondence or promotional material being sent to members who are excluded or known to have formally requested that this information not be sent.
3.9 The CLO has ensured that all excluded patrons have been treated with respect and dignity and strict confidentiality is maintained. The privacy of the patron should be protected at all times.
3.10 Venue staff are able to recognize the possible signs of problem gambling and to respond appropriately.
CSI has engaged the Community Educator from Relationships Australia to deliver training addressing the possible warning behaviours commonly displayed by patrons at recent whole of team meeting.
Practice 4 Physical Environment
4.1 Equipment is positioned appropriately ATMs, EFTPOS devices and change machines are positioned away from gambling areas where practicable.
All ATM’s on the premises are positioned outside areas where gambling products are located – in high traffic, high visibility areas which are exposed to natural light, next to clocks & other products & services of the club ie pool table, bar, entertainment lounge. This means that patrons who are gambling must leave the gambling area to access further cash to gamble. This “break in play” is providing the patron with an opportunity to consider whether they wish to continue gambling.
4.2 Venue environment is safe for patrons all of the time.
CSI engages an external WHS specialist who conducts regular safety audits & safety training to ensure the physical practices are maintained.
4.3 Minors are prohibited from gambling.
Signs warning prohibiting underage gambling are prominently displayed at both entrances to the gaming room & TAB/Trumps Sports Bar area. Appropriate proof of age is requested from gaming, keno & TAB customers if they look under the age of 25.
4.4 Minors are prohibited from designated gambling areas.
Signs advising patrons that minors are prohibited from our both our gaming room entrances & TAB/Trumps Sports Bar area are clearly displayed.
4.4 The service of alcohol is managed in such a way as to encourage patrons to take breaks in play.
CSI employs Gaming Hosts who manage the service of alcoholic & non alcoholic beverages to our customers in the gaming room.
4.5 Patrons who are unduly intoxicated are not permitted to continue gambling
All team members are required to renew their RSA certification yearly & refresher sessions are conducted at whole of team meetings to ensure proactive management of the service of alcohol & early identification of undue intoxication.
4.6 Venues offering adjunct child care.
CSI provides its members, guests & visitors with a childrens’ playroom – Kids Zone. This is not classified as an adjunct childcare facility. Conditions of use of Kids Zone are that the children must be supervised by a suitable parent or guardian at all times.
4.7 Staff working in gambling areas are not to encourage gambling patrons to give them gratuities (tips).
CSI gaming team members are not permitted to encourage or accept tips from playing customers. Team members inform the customer of this & if they could make a donation to one of our preferred local charities (Paradise Kids, or Volunteer Coast Guard) via the donation box instead.
4.8 Venues implement practices to ensure that patrons are made aware of the passage of time.
All CSI gambling areas have clearly visible clocks, have plenty of natural light.
4.9 Venues implement practices to ensure that patrons are discouraged from participating in extended, intensive and repetitive play.
CSI Gaming Hosts manage customers who may be participating in extended play by ie engaging in conversation, reminding them that it is a meal time, outlining other activities in the club (live entertainment) etc
Practice 5 Financial Transactions
5.1 Venue’s financial transactions policy document should outline the financial
practices at the venue and should be made available to any patron upon request.
CSI’s Financial Transactions Policy outlines the key elements of how CSI manages certain in-house gambling related financial transactions e.g., how cheques can be cashed, how winnings are to be paid, etc. This is available to patrons on request at both of the club’s reception areas & our gaming cashier. This document should be available upon request by a patron (and this fact is to be displayed in the venue).
5.2 ATMs are not to be located in close proximity or in the entry to gambling areas.
All ATM’s on the premises are positioned outside areas where gambling products are located – in high traffic, high visibility areas which are exposed to natural light, next to clocks & other products & services of the club ie pool table, bar, entertainment lounge.
This means that patrons who are gambling must leave the gambling area to access further cash to gamble. This “break in play” is providing the patron with an opportunity to consider whether they wish to continue gambling.
5.3 ATMs should not allow patrons to access cash advances on their credit card account (ATM should only allow access to savings or cheque accounts.
This measure ensures that patrons only gamble with money they possess (e.g. in their savings account) and cannot gamble with money they “do not have” (i.e., their credit card accounts).
5.4 Large wins above the approved cheque clearance limit for the venue must be paid by cheque – part payments of cash and a cheque to the total win amount are permitted.
CSI has a cash payout limit, for gaming machines, of $5000 & Keno of $5000. This allows the patron to have a period of time (at least 24 hours) to consider what to do with their winnings (rather than having the cash available to continue gambling). Team members who work in Keno, gaming machines or TAB, encourage customers to deposit large winnings into their bank account via our EFTPOS terminal.
5.5 Patrons cannot cash a winner’s cheque at the venue for at least 24 hours (or 1 working day) after that win.
As previously mentioned, this ensures that patrons have an opportunity (minimum 24 hours or next trading day) to consider how to spend large wins and patrons are not able to gamble those winnings on the same day. Gaming cheques may only be cashed by previous arrangement & approval.
5.6 Venue has a policy on what types of cheques can be cashed at the venue.
Gaming cheques may only be cashed by previous arrangement & approval. No other cheques can be cashed at our venue.
5.7 Under no circumstances does the venue allow credit betting to take place.
The Code or Practice (and all Queensland gambling legislation) states that:
gambling providers must not provide credit or lend money to anyone for the purpose of gambling. Severe penalties apply to this practice, ranging from fines to the cancellation of the gambling provider’s licence. The rationale, again, is to ensure that patrons only gamble with money they possess – that patrons do not gamble with money they “do not have” (i.e.
money they have borrowed) and patrons do not run up gambling debts.
5.8 The Customer Liaison Officer:
- provides advice/information to CSI team members and patrons on any of the venue’s financial transactions policies;
- responds to issues brought to their attention by other CSI team members (i.e., rectifying those issues);
- ensures breaches do not occur (e.g.,credit betting); and
- documents any such breaches as required.
5.9 Venue staff support the CLO in this regard by:
- providing advice/information to patrons and referring any query they cannot answer to the CLO and
- ensuring breaches do not occur (e.g., credit betting) and bringing any such issue to the attention of the CLO.
Practice 6 Advertising and promotions
The Code of Practice outlines 13 practices ensure advertising and promotions are delivered in a responsible manner.
Our external management company HSC employs a Group Marketing Manager who audits all CSI internal & external promotional materials. Compliance documents include; Liquor Act 1991 Guideline 60, Code of Ethics (AANA), RG Code of Practice Resource Manual and QLD Responsible Gambling Advertising and Promotions Guideline.
She has also provided an in-house condensed checklist from the Gambling Advertising and Promotions Guidelines for all internal materials to be compared against. All of the Club Marketing Materials (including entertainment and events) have the Gambling Help Online logo and contact details, a positive gaming message and where any promotional relevant terms and conditions can be viewed (Print and Electronic material).
The Club produces a publication every 2 months (7,500 copies) that has a highlighted section in the general info for Gambling Help assistance. All internally created brochures (CardIt and Rewards program) all have contact details for Gambling help agencies.
CSI ensures that advertising and promotions:
6.1 comply with the Advertising Code of Ethics as adopted by the Australian Association of National Advertisers. Any advertising or promotions aligns with the Advertiser Code of Ethics.
6.2 are not false, misleading or deceptive Any advertisement or promotion is based on fact.
Having available any terms and conditions to any promotion or condition of winning.
Ensuring that any prize or offer that is advertised or promoted is available at the time of the advertisement or promotion.
6.3 does not implicitly or explicitly misrepresent the probability of winning a prize.
Responsible advertising and promotion will emphasise the fun and entertainment aspect of gambling and not imply an individual promise /guarantee of winning. Winning will not be presented as the probable or likely outcome in each playing instance or session of play.
6.4 does not give the impression that gambling is a reasonable strategy for financial betterment. Responsible advertising and promotion will not promote gambling as an easy and automatic: alternative to employment or earning an income, financial investment, way of solving financial problems or way to achieve financial security.
6.5 does not include misleading statements about odds, prizes or chances of winning
Responsible advertising and promotion will not make false promises/statements about the odds, prizes or chance of winning. This includes not suggesting that skill can influence games that are really games of chance.
6.6 does not offend prevailing community standards Responsible advertising and promotion will reflect decency, dignity and good taste and adhere to prevailing community standards.
6.7 does not allow gambling to dominate, where there are other activities to promote
Responsible gambling advertising and promotion will ensure there is a balance between messages about gambling and other activities offered by the gambling provider.
6.8 is not implicitly or explicitly directed at minors or vulnerable or disadvantaged groups
Media selection and placement of television advertising will be in accordance with the Commercial Television Industry Code of Practice. Advertising and promotion is not directed primarily at the vulnerable or disadvantaged groups by linking social and financial betterment issues to gambling.
6.9 does not involve any external signs advising of winnings paid.
External signs include signage able to be viewed from any external part of a gambling provider’s premises. This also includes signage not on the premises, such as highway billboards.
6.10 does not involve any irresponsible trading practices by the gambling provider –
persuade an individual to gamble who, in the absence of an inappropriate inducement, would not have otherwise. This may result in individuals being persuaded to gamble for longer periods of time and in a more excessive and irresponsible manner than they otherwise would have done.
6.11 does not depict or promote the consumption of alcohol while engaged in the activity of gambling
6.12 has the consent of the person prior to publishing or causing to be published anything which identifies a person who has won a prize Gambling provider will not publish anything which identifies any person who has won a prize, unless that person has given prior consent.
6.13 where appropriate, positive responsible gambling messages are incorporated in advertising and promotion
An example of a positive message : “Keep gambling enjoyable, gamble responsibly.”
6.14 Venues are to ensure that patrons who are excluded (either self-exclusion or venue-initiated exclusion) are not sent advertisements or promotional materials
6.15 Similarly, venues are to respect the wishes of patrons (not excluded) who request that such advertising and promotional materials are not sent to them
6.16 The role of the Customer Liaison Officer (CLO) includes:
Providing advice and information to venue staff and patrons on any of the venues’ advertising and promotion policies Responding to issues brought to their attention by other venue staff (i.e., resolving those issues),
6.17 Venue staff support the CLO in this regard by providing advice and information to patrons and referring any query they cannot answer to the CLO.
The CSI Responsible Gambling Policy will be reviewed on a regular basis by the Management team in consultation with Relationships Australia, & subsequently endorsed by the Board of Directors.