Slide outline: Responsible Gambling Codes of Conduct: What purpose do they serve?

1. Responsible Gambling Codes of Conduct: What purpose do they serve?

Angela Rintoul, Julie Deblaqueire, & Anna Thomas
AIFS/AGRC Webinar,
8 June 2017

2. Disclosures

  • I am employed by AGRC which is funded by the Commonwealth Government
  • I do not work for, consult to, own shares in or receive funding from any company or organisation that would benefit from this study
  • Views expressed are mine and may not reflect the views of the AIFS or the Australian Government

3. Why this study?

  • 'Responsible gambling' Codes of conduct (CoC) are a  requirement of licensing in Victoria
    • Passive strategies: signage, protocols for cash payments, self exclusion program etc
    • Active strategies: Interact with gamblers showing signs of distress, interrupt EGM use
  • CoC valued by VCGLR in consideration of licensing applications
  • Venue staff: first to notice escalation of problematic gambling

4. Research questions

  • What do the CoC say venues will do in the event a gambler is showing signs of distress?
  • Are these protocols actually implemented?

5. Method overview

  • Venue profiles
    • Venue CoC (8 individual documents)
    • Venue type, machine numbers, annual losses
  • Site observations
    • 11 EGM venues & two local neighbourhoods
    • Unannounced observations
    • Used the behavioural checklist as a guide for expected and observed interactions

6. Excerpt from an approved Code

A customer displaying signs of distress or unacceptable behaviour will be approached by a staff member who will offer assistance. These signs may include, but not be limited to:

  • a person either gambling every day or finding it difficult to stop gambling at closing time;
  • gambling for extended periods. That is, gambling for three hours or more without a break;
  • avoiding contact while gambling, communicating very little with anyone else, barely reacting to events going on around them;
  • making requests to borrow money from staff or other customers or continuing to gamble with the proceeds of large wins;
  • displaying aggressive, anti-social or emotional behaviour while gambling.

This assistance may take the form of:

  • staff interacting with the customer and encouraging them to take a break from the gaming machine;
  • staff offering the customer some refreshments (eg. cup of tea or coffee) in a quieter, more private part of the gaming venue.

If the behaviour could be due to problem gambling, the customer will be referred to the Responsible Gambling Officer.

7. Observation Checklist

The Gambling Behaviour Checklist Instructions for staff

NO. Intensity and Duration COLOUR
1 Gambles intensely without reacting to what's going on around him/her RED
2 Often gambles for long periods (3+ hours) without a proper break RED
3 Gambles continuously RED
4 Plays very fast (e.g., inserts money/presses buttons rapidly) RED
5 Bets $2.50 or more per spin most of the time ORANGE
6 Gambles most days ORANGE
7 Spends $300 or more in a session ORANGE
8 Gambles on 2 or more machines at once ORANGE
9 Significant increase in spending pattern YELLOW
10 Rushes from 1 machine to another YELLOW
  Loss of Control  
11 Finds it difficult to stop gambling at closing time RED
12 Gambles right through normal meal times RED
13 Starts gambling when the venue is opening or only stops when venue is closing ORANGE
14 Tries obsessively to win on a particular machine YELLOW
  Money Seeking  
15 Borrows money from other people at venue or asks for a loan/credit from venues PURPLE
16 Leaves the venue to find money to continue gambling RED
17 Gets cash out on 2 or more occasions through ATM or EFTPOS RED
18 Puts large wins back into the machine and keeps playing RED
19 Avoids cashier and only uses cash facilities RED
20 Uses coin machine at least 4 times ORANGE
21 Has run out of all money when he/she leaves venue ORANGE
22 Asks to change large notes at venues before gambling YELLOW
23 Rummages around in purse or wallet for additional money YELLOW
  Social Behaviours  
24 Significant decline in personal grooming or appearance over several days PURPLE
25 Has friends or relatives contact the venue asking if the person is still there PURPLE
26 Asks venue staff not to let others know they are there PURPLE
27 Is rude or impolite to venue staff PURPLE
28 Becomes angry or stands over other players if someone takes their favorite machine/spot RED
29 Avoids contact or conversation with others RED
30 Stays on to gamble when friends leave the venue ORANGE
31 Brags about winning or makes a big show about their gambling skills YELLOW
  Emotional Responses  
32 Shows signs of anxiety while gambling (shaking, sweating, looking nervous/edgy) RED
33 Gets angry while gambling (kicking, hitting machines, swearing, grunting or groaning, playing roughly/aggressively) RED
34 Shows signs of distress after gambling (looks sad/depressed, crying, holding head in hands) RED
  Irrational Behaviours  
35 Complains to staff about losing, or blames venue or machines for losing ORANGE
36 Compulsively rubs belly of machine or screen while playing ORANGE

Use the checklist to help you think about ALL behaviours you may have seen in this person, now or in the recent past. 

There are six different types of signs to look out for, colour coded to indicate riskiness of behaviour.

  • PURPLE = gambling problems highly probable. These behaviours are uncommon but if you see them it is very likely to be a problem gambler. If you have seen purple flagged behaviours on more than one occasion you should consider organizing for someone to approach this patron. 
  • RED = gambling problems probable. These behaviours are more commonly observed than purple flagged behaviours. They are much more likely to be shown by people experiencing gambling problems and are good predictors of problem gambling. 
People displaying any red flag behaviours should be observed over a period of time at a minimum. If you have observed several red indicators or a mix of red and orange indicators over a period of time, this person is likely to be experiencing gambling problems and an approach should be considered. 
  • ORANGE = possible gambling problems. These behaviours are at least twice as likely to be seen in problem gamblers. 
Someone displaying several of these behaviours, especially across different areas may be experiencing some problems with their gambling. 
  • YELLOW = early warning signs. These behaviours are at least twice as likely to be seen in higher risk gamblers (compared to low risk gamblers). 
Seen by themselves these behaviours may be an early warning sign that gambling is moving out of control.

8. Method:  Overview cont…

  • Interviews
    • 40 gamblers (regular & 'problem') who used local EGM venues
      • purposively recruited via survey
    • 20 professionals (VSW, VCGLR, staff, manager)
      • purposively recruited via direct invitation
  • Thematically coded in Nvivo
  • Data triangulated (observations, interviews, codes)

9. Profile of venues

Venue observations

Venue type Instances observed Cumulative time (mins) Venue losses 2016 ($AU)a Total venue EGMs 2016b
Club A 4 150 6,173,931 60
Club B 3 210 516,534 18
Club C 2 135. 3,650,148 60
Club D 5 180 2,510,251 39
Club E 5 210 8,335,537 10
Hotel F 4 260 13,654,131 88
Hotel G 4 165 8,932,615 55
Hotel H 2 85 8,436,834 85
Hotel I 5 150 5,564,880 45
Hotel J 4 315 9,744,649 50
Hotel K 4 200 8,557,097 66
Total 42 2,060 76,076,607 576
Average observation (mins)   50    
Median observation (mins)    45.0    

Notes:     Observations were undertaken by the first two authors with both visiting each venue at least once. Eight venues were located in Site 1 and a further three venues were located in Site 2. a. Rounded to nearest dollar. b. Annual loss and EGM machine numbers for each venue to financial year 2016 (Victorian Commission for Gambling and Liquor Regulation, 2016a) Need accessible version

10. Gamblers interviewed

Characteristics of local EGM gamblers

  N Median Mean (SD)
Total scores (0–27) 40 9.0 10.9 (8.4)
PGSI categories N %  
Non-problem gambling (PGSI 0) 3 8.1  
Low-risk gambling (PGSI 1–2) 3 8.1  
Moderate-risk gambling (PGSI 3–7) 9 24.3  
High-risk gambling (PGSI 8+) 22 59.5  
Total 37 100.0  
Past gambling problem (Did not gamble in past 12 months) 3    
Lifetime gambling problem N a %  
Yes 34 89.5  
No 4 10.5  
Total 38 100.0  
Main gambling form  
Poker machines 32 80.0 2
Casino table games 3 7.5 2
Sports betting 2 5.0 2
Horse or dog races 2 5.0 6
Poker 1 2.5 2
Keno 0 0.0 0
Bingo 0 0.0 1
Lottery 0 0.0 0
Instant scratch tickets 0 0.0 0
Total 40 100.0  

Notes:  Percentages are based on available data and may not add to 100.0% due to rounding. Data presented was obtained from completion of the survey with additional information obtained at interview. a. Participants completed the PGSI and were also asked if they considered they had ever had a lifetime gambling problem when completing the survey. Four participants who answered no to this question had PGSI scores in the moderate risk range. Need accessible version

11. Results

  • Staff observed regularly on the gaming floor
    • focused on 'customer service' –servicing machines, book pays, food and beverages etc
  • Very limited, isolated evidence of supportive interventions to reduce harmful use
    • Some actions encouraged continued gambling
    • While some gamblers said they would have found an intervention embarrassing, others wanted support

12. Isolated instances of support

  • "Well the one that did it [provide support]to me. She looked like a friend. 'Cause I went up to her and I got really upset and [she said], "Wendy go home. Go home, Wendy. "… What are you doing out this late?" You know like 1 o'clock on the morning… That one time it happened … she was lovely 'cause she cared. - G286  [Name changed].

13. Lack of interaction and support

  • "I've never been offered the support. Which is quite funny 'cause I often say to them things like, even last fortnight I said to the girl, "I've got a list here of things that I have to do and a note on the bottom saying 'do not spend this money it is not spare'", you know. I said "so much for that note" and she [staff member] went "Oh, you know" [oh well]" – G1134

14. Desired support not provided

  • "There's been many, many times where I would've loved for someone to stop by and say, "Do you need someone to speak to?" …I'm sitting there and promising myself, "Okay, this is the last $50, this is the last $50." And you see the money go down quite quickly and you know that that money is needed for so many other things in your life and yet you can't walk out so maybe just having that someone come up to you and say, " Do you need assistance?" would have just been enough to get you out even that one time to be able to …have that money for something else." - G364

15. Venues encourage gambling 

  • "The only reason they'd approach you, …"Would you like another drink, sir?"  You know, that's it.  Or, "Look, we've got a tray of sausage rolls by the by. You're welcome to go grab a couple"." - G1094
  • "No they'd encourage it [continued gambling]. They'd give you a coffee or a Coke or - the longer you played there, the more they'd give you… when you're winning, they'd attend to you. But if you're losing or anything - they wouldn't come near you." - G258

16. Not all gamblers want to be identified

  • "No…I'd be so negative about it [staff offering gamblers help support], yeah. I think I'd be a bit upset with them, a bit spare with them, thinking, "…  Do they know that I'm a problematic gambler or something?" …  I think that would be quite the embarrassment."  – G251 
  •  "The only reason they'd approach you, …"Would you like another drink, sir?"  You know, that's it.  Or, "Look, we've got a tray of sausage rolls by the by. You're welcome to go grab a couple"." - G1094

17. Better regulation of cash withdrawals needed

  • "… when they had them [ATMs] and you could only get $400 after that you had to leave the venue and go somewhere else… which gave you time to think and break.... Nowadays you can go up to the bar but you can only get 200 at a time. However you can do that as many times as you like. So I've gone through a $1,000 [a session] that way" - G1134.
  • "I can't fathom on what planet we thought taking away that $400 limit was okay... there's no need for it to be more than $400 a day. I don't care whether you're addicted to playing or you're a social gambler, $400 for anyone is a lot of money." -P1703

18. Management not supportive of staff

  • "…You get your responsible service of gaming license and you [learn you] can legally tell them [gamblers] 'no you've had enough go home, stop, cool down … but you get [to work] and your boss is like 'you do that, you're out of here'… well, he didn't say it directly but that was what he was hinting at  ... I had one guy come in and get like $200 cash out three times in an hour … the kind of guy who had dirty work boots, you know, ripped up clothes and he was just really desperate. And it was like my third shift there and I knew I should've said something like, "Dude, slow down" but then the manager's just like … "No, no, no, give him another one [cash withdrawal]" -P1063

19. Breaches of self-exclusion

  • "After I had done it, I called them and said, "Look, you know, I'm self-excluded from your venue and I've just come in there and of course did a lot of money and I'd like you to look out for my photo or maybe the staff should be aware of my picture" and I gave them my name and that was about it." – G215
  • 'Interviewee: … they don't really care because I did have myself on the …exclusion list… it only lasted three months, if that, because one of the security guards on the door…said, "Oh well, I haven't seen you come into today so I don't know what's going on".

There were some reports from gamblers that SEP were not enforced by venues

20. The problem

  • We know there are significant harms resulting to problematic gambling, venues at the front line
  • But venues not adhering to CoC
    • No reported formal warnings issued to venues by VCGLR 2015-16
    • Why are CoC given so much weight in regulatory settings?
  • Not all gamblers welcome interaction
  • Staff not comfortable/ discouraged by management to interrupt gambling
  • Would interventions even be efficacious?

21. The solution

Reduce burden on gamblers & staff

  • Ban practices that don't reflect in spirit of CoC
    • Prohibit food and drink service at machines
    • Prohibit multiple cash withdrawals
  • Staff need legislative support to implement CoC
    • penalties should apply to venues that breach CoC
  • Use algorithms to identify patterns of escalating harm and send pop up messages to the gambler
  • Activate universal binding pre-commitment system

22. Conclusions

  • Self regulation appears to be ineffective:
    • Need legislation requiring venues to adhere to SEP, CoC likely to improve compliance
    • VCGLR requires resources to monitor compliance
  • Technology to support gamblers and staff in negotiating awkward encounters is available but not yet well utilised

23. References and further reading

Delfabbro, P., Thomas, A., & Armstrong, A. (2016). Observable indicators and behaviors for the identification of problem gamblers in venue environments. Journal of Behavioral Addictions, 5(3), 419-428.

Francis L, Livingstone C, Rintoul A. (2017). Analysis of EGM licensing decisions by the gambling regulator, Victoria, Australia. Int Gambl Stud. 17:65–86.

Livingstone C, Rintoul A, Francis L. (2014). What is the evidence for harm minimisation measures in gambling venues? Evid Base. 2:1–24. Available from:

Rintoul, A., Deblaquiere, J., & Thomas, A. (2017). Responsible gambling codes of conduct: lack of harm minimisation intervention in the context of venue self-regulation. Addiction Research & Theory, 1-11,  doi:10.1080/16066359.2017.1314465 [this presentation available online at ]

Victorian Commission for Gambling and Liquor Regulation (VCGLR).(2016a). Expenditure by Venue [Internet]. Available from:

Victorian Commission for Gambling and Liquor Regulation (VCGLR).  (2016b). Annual Report. Melbourne: VCGLR [Internet]. Available from: 

24. Presentation based on new paper

Addiction Research & Theory

Responsible gambling codes of conduct: Lack of harm minimisation intervention in the context of venue self-regulation

Angela Rintoul, Julie Deblaquiere and Anna Thomas

25. Comments on the ACT Gambling & Racing Code of Practice and Behaviour of Clubs in the ACT

By Professor Laurie Brown, 8 June 2017.

AIFS Webinar 

26. Role of ACT Gambling and Racing Commission

  • Currently audits ACT Clubs with respect to requirements under the Code of Practice – letter of the law
  • What is needed is
    • 'Policing' the implementation of Code of Practice regulations by the Clubs –
      • spirit or intent of the law

27. Meaning of gambling problem in the Code

  • "a person has a gambling problem if the person has difficulty limiting the amount of money or time spent on gambling and this leads to adverse consequences for the person or another person"
  • A licensee commits an offence if the licensee contravenes the code of practice e.g.
  • licensee fails to have gambling contact officer
  • make available for inspection by the Commission a record of problem gambling incidents kept by the licensee under the code of practice

28. 1.4 Staff care and training

  • (1)       The licensee of a gambling facility must ensure that—
    • (a)       each staff member who is directly involved in providing gambling services to patrons and each person who supervises the staff members—
      • (i) has successfully completed an approved training program within the previous 3 years;
  • (b)       each staff member is made aware of his or her obligations under this code of practice

Why do staff not put their training into action?

29. 1.6A     Recording problem gambling incidents

  • (1)  A licensee of a gambling facility must keep a record of the following incidents (a problem gambling incident):
    • (a) anyone who shows signs of having a gambling problem
    • Examples—signs that person has gambling problem
      • admitting being unable to stop gambling or to gamble within the person's means
      • expressing concern about the amount of time or money the person spends on gambling
      • acknowledging the person spends on gambling money needed for day-to-day living expenses, including for dependents
      • having a disagreement with a family member or friend about the person's gambling behaviour
      • making multiple ATM cash withdrawals in the gambling facility
  • 1.11     Dealing with people with gambling problem
    • (1) The licensee of a gambling facility must ensure the gambling contact officer for the facility is told about—
      • (a) any person in the facility whom the licensee or a staff member has reasonable grounds for believing has a gambling problem; and
      • (b) the details of the person's behaviour that led to the belief.
  • 1.18     Licensee must keep deeds and notices of exclusion
  • (1) A licensee of a gambling facility must keep—
    • (b) a copy of each notice of exclusion given by the licensee for 7 years from the day the notice is given.

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