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Gaming Machine Harm Minimisation Measures Consultation Paper

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Your details

|Name |Roman Sharawara |

|Organisation (If applicable) |Magpie and Stump Hotel |

|Email address |townandcountry@.au |

|Address |Magpie and Stump Hotel |

| |3313 Epping Kilmore Road |

| |Wandong Vic 3758 |

|Telephone | |

Please note:

All submissions will be published on the Department of Justice and Regulation’s website.

Please ensure that your submission does not include confidential, commercial-in-confidence or personal information.

The department reserves the right to not publish information that could be seen to be defamatory, discriminatory or unrelated to the review.

Questions: Gaming Machine Harm Minimisation Measures

These questions should be read in conjunction with the Gaming Machine Harm Minimisation Measures Consultation Paper

|Q.1. Is the current $200 per EFTPOS transaction limit appropriate? If not, what other regulatory measures would support the objectives of the |

|Act? |

|The Current $200 per EFTPOS transaction limit is adequate. |

|Anecdotally, it is important to note that many non-gaming users of the hotel feel that, by banning ATMs in these businesses (gaming venues), |

|they are being unfairly inconvenienced. |

|A law which is designed to reduce a problem of a few encompasses a majority who do not have a problem.. |

|Q.2. Is the current $1,000 threshold for the payment of winnings by cheque appropriate? If not, what should be the limit and why? |

|The limit should be increased to $5000. The $1000 limit has been in place for a very long time and has not taken inflation into consideration. |

|There is no doubt having a limit of $1000 payment of winnings encourages people to play off credits to get below this limit. |

|People do not want to have a cheque. |

|On many occasions I have heard their argument, as simplistic as it may be, “I have put my cash in and should be allowed to redeem my winnings |

|in cash. |

|Q.3. Should payment by EFT be permitted in addition to, or as a replacement for, payment by cheque? |

|I believe an EFT payment is the way to go. Cheques most likely will have a limited life span in the banking world. The reality is an |

|alternative system should be put in place now. |

|Also this will eliminate cheque fraud which there has been instances of where the amount payable has been altered on the cheque. |

|For the EFT payment we would give the customer a receipt for the transaction. Money would be deposited in their account on the next working |

|day. |

|In our own daily business world we never write cheques and have not done so for a number of years. |

|Q.4. Are there other payment methods that should be considered for the payment of credits / winnings? |

| |

|I agree with permitting payment of winnings by Electronic Funds Transfer (EFT) that would reduce administrative costs for the venue operator. |

|We would need to have the ability and permission to do this transaction through an EFTPOS terminal. |

|I agree in delaying the transaction to ensure that winnings are not immediately accessible by players. |

|Doing an EFT from the venue’s bank account to the player’s bank account via an online facility could cause administrative delays even though |

|this could be an additional alternative available. |

|Q.5. Should venue operators be able to exchange personal cheques for cash? |

|My preference is to permit the venue to cash personal cheques as per the existing Act to a maximum value of $400 and no more than one cheque |

|for cash for any person within a period of 24 hours. There is no need to change because of the following reasons: |

|We know many venue operators have committed to not cash personal cheques as part of their Responsible Gambling Code of Conduct. |

|We also know that most hotels have always had a policy of not cashing cheques regardless of whether they were a gaming venue. |

|The use of cheques is almost extinct in the modern world of finance. |

| |

| |

|Q.6. If cashless gaming and or TITO is introduced, how should they be regulated so that they are consistent with other measures that limit |

|access to cash? What harm minimisation measures should apply? |

|Firstly I believe TITO should be a choice for the venue operator. They should be allowed to make that choice. |

|Its’ implementation depending on the size of the venue could reduce staffing costs but would incur a cost to implement. |

|The financial profitability of the exercise would dictate whether the venue wanted it or not. |

|The TITO system should free up staff from the following tasks (i) filling hoppers (ii) clearing note jams (iii) emptying drop boxes(iv) book |

|pays(v) cash pays. |

|A myriad of other problems which can arise from the wear and tear of anything mechanical may be lessened. |

|If staff is freed up from many of these manual tasks they would have more time to interact with customers which could in itself be useful as a |

|part of harm minimisation. |

|I do not think TITO is going to influence what a problem gambler is going to do. |

|We have enough adequate measures in place. |

|A look into the past may give us an idea of what the gambler generally may do. |

|When poker machines were first introduced to Victoria the two providers of machines used two different models. |

|Tabcorp went with a cashless system. Punters used a card system similar to the TITO system for all machines with no cash transaction other than|

|cashing out with a cashier. Tattersalls cash model quickly grabbed a sizable business advantage. Tabcorp very soon phased out the cashless |

|system and regained market share parity with Tattersalls. If it is anything to go by it indicates that people still prefer to gamble with |

|cash. |

|Q.7. What opportunities are there to improve the way codes operate in Victoria? |

|Are there other models that would be more effective? If so, what are they? |

|Would a more prescriptive approach for all venue operators be better? Could the operation of codes be simplified? |

|Are there other matters that should be provided for in the Ministerial Direction for codes? |

|What requirements for loyalty schemes should be included in a code to promote responsible gambling? |

|Does the annual review process contribute to fostering responsible gambling? If not, why not? Are there other options to ensure that the codes |

|meet this aim? |

|We are committed to our Responsible Gambling Code of Conduct. They should remain in place. I see no problem with different bodies producing |

|codes of conduct which all follow the ministerial directions. |

|I do not believe “Loyalty programs” have any effect on the problem gambler. |

|I do not have the facts but from anecdotal experience loyalty programs are more likely to have a high participation rate by people who like to |

|be rewarded with a meal discount or a free glass of wine or beer. These people feel it is nice to have small rewards. They then may choose one|

|venue over another which does not have a loyalty program. |

|If anything was to be included in the code of conduct it would be that rewards have a life span and should be redeemed to a perceived retail |

|value capped of say $1000. |

|Annual reviews of the program should be kept simple. I am happy with the process we have today. |

| |

|Q.8. Should the requirement to interact with customers who are showing signs of distress from gambling be part of codes, or should a separate |

|offence be created for venue operators who fail to respond to suspected problem gambling? |

|I am against introducing more penalties. I firmly believe the issue of problem gambling should be a joint effort by all the stake holders in |

|the industry. We are dealing with an extremely difficult problem. Even the experts recognise what extremes the problem gambler will do to avoid|

|detection. I think it grossly unfair to place the responsibility, under the threat of punishment, of not being able to deal with a problem |

|gambler situation by the book on a staff member who is not trained at a tertiary level in the field of psychologically or equivalent |

|qualification. If a possible opportunity to approach a distressed customer has been missed and detected by an officer from the VCGLR the |

|problem should be solved through consultation and advice. A joint effort to help each other help the problem gambler. |

|Our code of conduct already refers to our staff’s responsibility to approach customers who show signs of distress and it is also in included in|

|our procedures manual. |

|Q.9. Are self-exclusion programs best administered by the industry or by another body? |

|The administration of the self-exclusion program by our industry body, the Australian Hotel Association (AHA) Victoria has been professionally |

|organised and has survived the test of time. In my time within the gaming industry I have never heard of any complaints from the self-excluded |

|or members of the public. |

|Q.10. Should there be one self-exclusion program in Victoria? |

|There would be a strong argument for one program but administered by a number of organisations e.g. AHA, CLUBS Victoria. The people who |

|excluded themselves from gaming venues, I would assume, would do so from pubs and clubs in most circumstances. They would certainly be advised |

|to do so by their councillors. |

| |

|Q.11. How could self-exclusion programs be improved? |

|Self-exclusion compliance by the individual and monitoring by the venue is probably the most difficult part of the program. |

|Venues do get information re breaches on individuals which certainly puts those people on high alert on our watch, |

|Individuals who want to breach their commitment will go to extra ordinary measures to avoid detection. This is a problem for staff members who |

|are well aware of their responsibilities but must live in the fear that they are being compromised. |

|Q.12. Is the annual review useful or are there other ways to report on program trends and compliance? |

|The present annual review is adequate. |

|Q.13. Should there be a separate offence for venue operators who knowingly allow self-excluded persons to enter or remain in the venue? |

|I do not believe that there would be any venue which knowingly would allow self-excluded people remain in the venue. |

|Introducing rules which carry separate penalties just complicate an issue which would be a rarity. |

|If this was to occur this problem should be dealt with on a one to one level with the VCGL office and the offending venue. There would be |

|enough provisions within the existing rules to discipline the offender. |

|Q.14. Should a new requirement to undertake advanced responsible service of gaming training be introduced? |

|No I do not think this is necessary. |

|I believe there are enough outside resources a venue can rely on to get help if needed over and beyond their normal watch via the code of |

|conduct and RSG training being conducted today. These being Gamblers Help and in our local case Gateway Health. |

|I think once a venue has recognised the signs a person may have problems with gambling and has instigated the appropriate measures to help |

|and guide that individual in accordance with the code of conduct, that venue has done all it can at this level. |

|Recognition of problem gamblers by the staff members who are the coal face is in itself an onerous task. Some signals can be obvious and can be|

|addressed by staff as required |

|These are: |

|Asking/begging for credit from the staff or other customers: Aggressive behaviour at the machine or towards other customers whilst gambling. |

|Repetitive withdrawals from the EFTPOS Facility: Excessive time spent at a machine: Excessive visits to a venue: A plea for help from a |

|relative or friend. |

|Dealing with problem gamblers requires specialist people who are trained at a tertiary level and can provide the professional guidance needed. |

|Even these trained professionals agree that the task of reforming a problem gambler is extremely difficult. |

|Introducing more and more levels of training for individuals who may not have the ability to cope nor administer the new set of |

|responsibilities is not the way to deliver the best outcomes. |

|E.g. In my work place most of my staff have Year 10 or 11 as their highest educational qualification. |

|If we are serious about tackling problem gambling we are missing a couple of very glaring Issues within our society and culture. Poker machine|

|have now been with us in Victoria since 1992. In NSW since 1956.In other states except Western Australia at different starting points. |

|Australia has a passionate love affair with gambling. The productivity commission has recognised this via many published statistics over many |

|years. |

|If we wish to reduce irresponsible gambling and the incidence of people become problem gamblers we should be looking at the big picture. |

|Why do people become problem gamblers? How can we reduce the incidence of problem gamblers in the first place? |

|Problem gamblers can come from any levels of socio economic backgrounds, cultures and education. |

|Wikipedia explains how problem gambling can develop and the signs problem gamblers exhibit. |

|Wikipedia Reference: |

|“There are both environmental and genetic factors that can influence on gambler and cause some type of addiction. In order to be diagnosed, an|

|individual must have at least four of the following symptoms in a 12-month period: |

|Needs to gamble with increasing amounts of money in order to achieve the desired excitement |

|Is restless or irritable when attempting to cut down or stop gambling |

|Has made repeated unsuccessful efforts to control, cut back, or stop gambling |

|Is often preoccupied with gambling (e.g., having persistent thoughts of reliving past gambling experiences, handicapping or planning the next |

|venture, thinking of ways to get money with which to gamble) |

|Often gambles when feeling distressed (e.g., helpless, guilty, anxious, depressed) |

|After losing money gambling, often returns another day to get even ("chasing" one's losses) |

|Lies to conceal the extent of involvement with gambling |

|Has jeopardized or lost a significant relationship, job, education or career opportunity because of gambling |

|Relies on others to provide money to relieve desperate financial situations caused by gambling” |

|Giving assistance to problem gamblers is extremely involved and needs supervision by professionally trained practioners. Wikipedia makes |

|reference to the various treatments involved. |

|Wikipedia Reference: |

|“Most treatment for problem gambling involves counselling, step-based programs, self-help, peer-support, medication, or a combination of these.|

|However, no one treatment is considered to be most efficacious and no medications have been approved for the treatment of pathological gambling|

|by the U.S. Food and Drug Administration (FDA)” |

|How do we seriously look at the long term solutions to mitigate the possible evolution of problem gamblers? |

|We should be embarking on an education program which begins at a very early age. We should be reducing exposure to gambling of younger |

|population well before they can gamble legally. |

|I wish to identify some problems within our society which we totally ignore as a nation. |

|We expose young people to the following forms of gambling from as early as four years of age. |

|Raffles: |

|Raffles held at schools, kindergartens, sporting clubs and social clubs to name a few. . You may argue these are harmless and are needed to |

|raise funds. I do not disagree with the need to raise funds but in many cases we are encouraging and involving very young children in selling |

|the tickets. |

|Melbourne Cup Sweeps: |

|I have seen many parents put their young children into these sweeps so they can have a horse in the race. |

|Horse Race Meeting Promoting Families to Attend: |

|Promotion to attend horse race meetings (especially picnic meetings) which have provision for under age children entertainment. These meetings|

|are promoted as family affairs. |

|Advertising : |

|Blanket exposure with media advertisements encouraging gambling exposing underage people to gambling products. |

|I propose the government embark on an education program to be included in the school curriculum to educate children from an early age about the|

|pitfalls of gambling. |

|There should be measures put in place which control what under age children cannot and should not do which relate in any shape or form of |

|gambling. |

|Parent bodies, Schools, Sporting Clubs, Social Clubs and any organisation which attempts to raise money should be made to adhere to a Gambling |

|Code of Conduct which will encourage responsible gambling from an early age. |

|A great number of the measures, we are now trying to come up with, whilst with good intention, may be too late for many. You may say the horse|

|has bolted. And we may never catch him because problem gambling is like any compulsive disease very hard to correct. |

|I am not advocating we stop what we have in place but we must look at the possible root causes. |

|One of the signs Wikipedia identifies with problem gambling is that the person often gambles when feeling distressed (e.g., helpless, guilty,|

|anxious, depressed) |

| |

|I believe the health of our population is a factor which can be associated with problem gamblers. There many references to state of obesity in |

|Australia. It is a well known fact that people who are obese suffer from a variety ailments. They get depressed, feel helpless and suffer from|

|Asthma; Arthritis; Cancer; Diabetes mellitus; Heart and circulatory conditions; Kidney disease; Mental and behavioural conditions; Sight and |

|hearing problems; and Osteoporosis. |

|I refer to The Australian Bureau of Statistics numbers in relation to how many people in Australia are over weight and the cost to the |

|Australian tax payer. |

|Reference: |

|“2014-15, 63.4% of Australians aged 18 years and over were overweight or obese (11.2 million people), comprised of 35.5% overweight (6.3 |

|million people) and 27.9% obese (4.9 million people). A further 35.0% were of normal weight and 1.6% were underweight.” |

|The cost to Australia quoted in the Sydney Morning Herald is |

|Reference: |

| |

| |

|“The cost to Australia's wellbeing caused by obesity has leapt by 84 per cent in the past decade to more than $130 billion a year. |

|The Fairfax-Lateral Economics Index of Australia's Wellbeing – which uses a range of indicators to measure our collective welfare – reveals the|

|huge social and economic toll of obesity.” |

|In comparison gamblers lost 23 Billion dollars in the last financial year according to the Age newspaper. |

|Reference : |

| |

|“Australian punters lost nearly $23 billion last year 2015, with a 30 per cent growth in sports betting helping to drive a continued rise in |

|annual gambling losses.” |

|The questions that need to be asked are. |

|Do people who are overweight gamble more? There are a lot of them. |

|Do people who are depressed gamble more? |

|Do people become depressed because they have become problem gamblers or do they gamble excessively because they are depressed? |

|Do people who have low self esteem gamble more? |

|Are we looking at all the reasons why people gamble to excess? |

|Should we be spending more time on decreasing the incidence of obesity which may be a trigger to problem gambles? |

|There is one thing for sure it is our culture needs to address the many issues which contribute to the plight of a problem gambler. |

|In conclusion I do not think that an advanced course for another staff member is the solution to help the problem gambler. |

|The issue needs urgent attention on a nationwide scale through education and restrictive practices to begin a cycle of a reversal of exposure |

|of young people to gambling. |

|The health and wellbeing of Australian people needs to be addressed to stem the multitudes of problems caused by obesity which may include |

|problem gambling. |

| |

|Q.15. If so, who should be required to complete the advanced training and what content should the training include? |

|Please refer to my comments made in Item 14 |

|I do not believe we need this course other measure should be taken. |

|Q.16. Who should be responsible for the development and provision of the advanced training? |

|Please refer to my comments made in Item 14 |

|I do not believe we need this course other measure should be taken. |

|Q.17. Do you think regional caps and municipal limits should be maintained? Why? |

|Regional Caps should be reviewed and revised if necessary. My view is that they should be kept in line with population changes. If the |

|population in a capped area increases so should the cap. Municipal limits have formula in place which do not need to be changed. |

|Q.18. Should regional caps be extended beyond the existing capped areas and if so, why? |

|I do not think so. The areas of Victoria which are perceived to be at greatest risk to problem gamblers have been identified and there does not|

|need to be any more intervention. |

|Q.19. Are the current regional cap and municipal limit levels appropriate? |

|Yes. The existing formulas of machine ratio to population are in place and they are adequate. |

| |

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Interested persons and organisations can make a submission on the issues raised in the Gaming Machine Harm Minimisation Measures Consultation Paper by completing this submission form.

This response form includes the questions from the Gaming Machine Harm Minimisation Measures Consultation Paper.

If you have any queries about this process please email the following address with the subject heading – Harm Minimisation Consultation Paper.

Email: liquorgamingandracingenquiries@justice..au

Submissions must be received by 5pm, Monday 16 January 2017.

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