Responsible Gambling Policy

Responsible Gambling Policy

The Frenchville Sports Club (FSC) offers a range of gambling products to its members, guests & visitors. FSC is committed to ensure that management of these products & related high customer service standards provided by the FSC team, are delivered in a manner which consistently demonstrates industry best practice. Through full commitment & endorsement by the FSC 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, is a priority in particular to responsible service of gambling. We have developed a strong partnership with our local Relationships Australia branch. Representatives from our management team attend regular Liquor Acord and OLGR 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. FSC’s Bus Drivers, Receptionists, Gaming Concierge team, Duty Managers, Customer Engagement Co-ordinator, Marketing & Promotions Manager, Human Resources Manager, CFO, Operations Manager & General Manager are CLOs & have participated in formal CLO training.

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 Oasis Gaming Cashier or Reception desk.

The following information is driven by the Responsible Gambling Code of Practice & describes how FSC provides & manages gambling products.

Provision of Information

Responsible Gambling Mission Statement

FSC has developed the following mission statement on the club’s commitment to providing responsible assistance to problem gambling, which is displayed in the Oasis Gaming Lounge.

The Frenchville Sports Club Ltd is committed to ethical and responsible behaviour, that recognises the importance of our members & patrons wellbeing, with a focus on minimising the potential for harm of gambling.

Responsible Gambling Policy Document

FSC has developed a 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 Venue (risk of problem gambling and where to get help)

FSC 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 connected to gambling areas, CRT machines and beside all ATM facilities.

FSC have gambling fact sheets in a range of languages that are available from our Oasis Gaming Cashier.

We also have discrete Responsible Gambling take home packs (available from our Oasis Gaming Cashier or Reception desk) which provide a wide range of information including Self Exclusion forms.

The FSC website has links to help services, has downloadable responsible gambling documents including Self Exclusion forms, links to foreign language help information & links to the Keno & TAB responsible gambling web pages.

Nature of games and game rules -

FSC have Gaming Concierge staff who can assist our patrons, in understanding the various gambling products and how they are played.

Odds of winning or returns to player -

FSC provides information (in an easy-to-understand format) that explains to our patrons the odds of winning a major prize. This information can be found in the Player Information Guide and is also prominently displayed next to our gaming cashier.

Exclusion mechanisms -

FSC 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 our Oasis Gaming Cashier or Reception desk) which provide a wide range of information including self exclusions & the Self Exclusion form.

The FSC website has a downloadable Self-Exclusion form.

Complaint resolution mechanisms -

FSC 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 from our Oasis Gaming Cashier or Reception desk.

Financial transaction policy -

Our Financial Transaction Policy outlines the key elements of how FSC manages certain in-house gambling related financial transactions. This is displayed in the Oasis Gaming Lounge and is available to patrons on request, at our Oasis Gaming Cashier or Reception desk.

Other information (e.g. legislative requirements) -

“Rules Ancillary to Gaming” is prominently displayed in next to our gaming cashier.

Interaction with customers and the community

The venue CLO provides appropriate information to assist patrons with gambling related problems -

FSC’s Bus Drivers, Receptionists, Gaming Concierge team, Duty Managers, Customer Engagement Co-ordinator, Marketing & Promotions Manager, Human Resources Manager, CFO, Operations 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.


Our CLOs are familiar and are trained to identify possible problem gambling risk indicators. We understand that a patron may display one or several of the indicators below. Displaying one risk indicator may not mean the patron is a problem gambler (unless they display that particular risk indicator to an unreasonable degree). However, a cluster of three or more indicators may indicate signs of problem gambling. Some indicators may be subtle whilst others may be obvious. Some indicators may be due to factors other than problem gambling such as a disability.


Our team will respond to these indicators with respect and care, based on key factors such as the examples provided below. Our CLOs understand that they are not trained counsellors and that they must be mindful & precautious when engaged in these situations.

  • Observe behaviours
  • Approach with caution and care
  • Refer and provide responsible gambling and or problem gambling resources
  • Document interaction/ gambling related incident in the Customer Care Log of the Eaglei360 program

Emotional responses

  • Suffering from depression and/or have thoughts of suicide due to gambling behaviour.
  • Vocally displaying anger (swearing to themselves, grunts) and/or threatening or causing physical harm to others or self.
  • Looking sad or depressed after gambling.
  • Crying after losing a lot of money

Faulty cognition

  • Having an unrealistic perception about the chance/ odds of winning.

Frequency, duration, intensity

  • Gambling frequently or for an extended period of time.
  • Gambling without taking a break over an extended period of time

Impaired control/loss of control

  • Trying obsessively to win on a particular machine.

Irrational behaviours

  • Blaming the venue, the staff or gaming machines because they lost.
  • Displaying aggression, kicking machines, anger towards staff.

Raising funds/chasing behaviour

  • Getting cash out from an ATM at venue on multiple occasions for the purposes of gambling.
  • Trying to borrow, ‘scam’ money or sell valuables to others for gambling.
  • Putting large win amounts back into the machine and keep playing.

Social behaviours

  • Friends or relatives call or arrive to ask if the person is still at the venue.
  • Spending too much time and/or money gambling

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.

Our CLOs provide 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.

Our CLOs can provide contact details of the local Gambling Help Service -

We have local contact details for counsellors at Relationships Australia & Gambling Help Service pamphlets.

Our CLOs have 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 Liquor Accord & OLGR 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. FSC has partnered with Relationships Australia, to host the annual Responsible Gambling Network Forum (RGNET Regional Event, established in 2021). Members of FSC staff & management attend this forum, to keep our team educated on the importance of harm minimisation efforts for gaming venues and Gambling Help Service Staff. Our team network with other regional gaming venues, with hopes to achieve reduced impacts of problem gambling in our local community.

FSC staff are familiar with the venue’s customer complaint resolution mechanism, or the venue CLO can advise staff in this regard -

FSC 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 FSC’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 advice (at their own expense should they wish).

The CLO will record details of the complaint and action taken in a gambling related incident report. in the Customer Care Log of the Eaglei360 program.

FSC staff have received training from Relationships Australia and include the GHS in ongoing staff training in responsible gambling -

All team members are encouraged to renew their RSG certification yearly. FSC will maintain a training program to provide ongoing responsible gambling training for all staff who provide gambling products and services to patrons at least on a semi-annual basis.

Exclusion Provisions

Our CLOs understand Self Exclusion -

FSC must & will exclude a patron who requests self exclusion.

The CLO must provide the patron with a self-exclusion notice (Form 3A). The CLO may request that the patron provide a recent photo to assist staff to enforce the exclusion. The patron must provide a recent photo if requested. The patron completes and returns the Self-exclusion notice to the CLO. The Self-exclusion notice will need to be witnessed by an adult over 18 years of age. This may be the CLO or another member of staff.

The Self-exclusion order is effective from when it is given to the patron for a maximum of five years, after which time it will automatically expire. There is a 24-hour cooling-off period in which the patron can revoke the Self-exclusion order. If the patron pursues a revocation within the 24-hour period, the CLO must provide the patron with a Revocation notice: self-exclusion order (Form 3C) to complete and submit to the club within the 24-hour time limit. If the Revocation notice: self-exclusion order is submitted by the patron to the club within the 24-hour time limit, then the Self-exclusion order is considered void, and the patron may freely re-enter the premises and gaming area/s as though the Order had never been in place. The CLO may give a Conditions of re-entry (participation in gambling activities).

Our team takes reasonable steps to prevent a patron who is excluded, from entering or remaining on a premises. All management team are sent notifications identifying new exclusions. A photo log of all current excluded persons is sighted & signed off on when changes occur to the register.

Should an excluded patron enter an area in which they are prohibited, our staff are to notify the Duty Manager or Customer Engagement Co-ordinator immediately, to have the patron removed from the premises. The appropriate CLO will refer to the exclusion register, confirm the identity of the patron and approach with exclusion details. The patron will be removed from the area, shown the current exclusion order in place, and then informed of the potential consequences and steps moving forward. The patron will be advised that this type of incident is classed as a contravention, which legally must be reported to OLGR. It will be explained that OLGR will review the incident and correspond with them directly from this point forward. The patron will then be instructed to leave the premises. Form 3H – Notice of contravention of self-exclusion order/exclusion direction, will be filled out by the CLO and lodged immediately. A copy of this form will be kept with the with the patron’s exclusion order. A record of this incident will be logged in the Customer Care Log of the Eaglei360 program.

Our CLOs understand Venue Initiated Exclusions –

Staff within the venue observe a patron who may have a gambling problem which is to be documented in the Customer Care Log of Eaglei360. The patron will be referred to gambling help resources. If the patron is unwilling to self-exclude and the CLO believes on reasonable grounds, that the patron is, or is at significant risk of being, a problem gambler, the club may issue a venue-initiated exclusion, Exclusion direction (Form 3D). Reasonable grounds include an approach by a third party or observation by staff.

Our CLOs are 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.

Our CLOs provide advice and information to venue staff on the exclusion process -

Relationships Australia has provided in-house training relating to exclusions.

Our CLOs ensure 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.

Our CLOs ensure the local Gambling Help Service details are provided to the excluded patron -

As FSC has developed a strong relationship with Relationships Australia, we have recommend & provided direct persons of contact as well as the Gambling Help Service information.

Our CLOs have sought assistance from the local Gambling Help Service regarding exclusions -

FSC’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 TAB 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.

Our CLOs have ensured promotional materials are not sent to an excluded patron -

Part of FSC’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.

Our CLOs have 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 -

FSC staff are able to recognise the possible signs of problem gambling and to respond appropriately -

FSC will engage Relationships Australia regularly, to deliver training addressing the possible warning behaviours commonly displayed by patrons, at whole of team meetings.

Physical Environment

Suitably trained staff will conduct ‘walk-throughs’ of the gaming room area at one hourly intervals. Should they observe any patrons displaying behaviours associated with problem gambling, they must maintain a record of the observations in the Customer Care Log of the Eaglei360 program.

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. 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.

Venue environment is safe for patrons all of the time -

FSC completes safety audits & safety training to ensure the physical practices are maintained.

Minors are prohibited from gambling -

Signs prohibiting underage gambling are prominently displayed at both entrances to the Oasis Gaming Lounge & Champions Sports Bar. Appropriate proof of age is requested from gaming, keno & TAB customers if they look under the age of 25.

Minors are prohibited from designated gambling areas -

Signs advising patrons that minors are prohibited from both our Oasis Gaming Lounge entrances are clearly displayed.

The service of alcohol is managed in such a way as to encourage patrons to take breaks in play -

FSC employs Gaming Concierge staff who manage the service of alcoholic & non-alcoholic beverages to our customers in the gaming room.

Patrons who are unduly intoxicated are not permitted to continue gambling

All team members are encouraged 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.

Offering adjunct childcare -

FSC provides its members, guests & visitors with a children’s’ playroom – Kids Corner. This is not classified as an adjunct childcare facility. Conditions of use of the Kids Corner, are that the children are the responsibility of the Parent/ Guardian at all times. Parents/ Guardians must provide identification and a contact number upon signing children in. Parents/ Guardians are required to report to their children every hour. Children must be supervised by a suitable parent or guardian at all times, if this facility is unattended by staff who hold an appropriate Blue Card.

FSC implements practices to ensure that patrons are made aware of the passage of time -

All FSC gambling areas have clearly visible clocks and have regular club announcements broadcasted through the PA system, which refer to the time in some of the messaging.

FSC implements practices to ensure that patrons are discouraged from participating in extended, intensive and repetitive play -

FSC Gaming Concierge staff, manage customers who may be participating in extended play i.e. engaging in conversation, reminding them that it is a meal time, outlining other activities in the club (live entertainment) etc.

Financial Transactions

The FSC’s financial transactions policy document outlines the financial practices at the venue and can be made available to any patron upon request -

FSC’s Financial Transactions Policy outlines the key elements of how FSC 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 from our gaming cashier and reception desk.

ATMs are not to be located in close proximity to gambling areas -

All ATM’s on the premises are positioned outside areas where gambling products are located – in high traffic & high visibility areas. 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.

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).

Large wins above the approved payout limit for the venue, must be paid by EFT or cheque – part payments of cash and EFT/ cheque, to the total win amount, are permitted.

FSC has a cash payout limit for gaming machines of $5,000 & Keno of $5,000. 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).

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.

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.

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.

The Customer Liaison Officer:

  • provides advice/information to FSC team members and patrons on any of the venue’s financial transactions policies;
  • responds to issues brought to their attention by other FSC team members (i.e., rectifying those issues);
  • ensures breaches do not occur (e.g., credit betting); and
  • documents any such breaches as required

FSC 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

Advertising and promotions

FSC ensures that advertising and promotions:

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.

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.

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.

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.

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.

Does not offend prevailing community standards Responsible advertising and promotion will reflect decency, dignity and good taste and adhere to prevailing community standards.

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.

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.

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.

Does not involve any irresponsible trading practices by the gambling provider -

Does not 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.

Does not depict or promote the consumption of alcohol while engaged in the activity of gambling.

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.

Where appropriate, positive responsible gambling messages are incorporated in advertising and promotion -

An example of a positive message: “Keep gambling enjoyable, gamble responsibly, etc.”

FSC will ensure that patrons who are excluded (either self-exclusion or venue-initiated exclusion) are not sent advertisements or promotional materials.

Similarly, FSC will respect the wishes of patrons (not excluded) who request that such advertising and promotional materials are not sent to them.

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).

FSC 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 FSC 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.

Further information

Useful Links

Relationships Australia Queensland (Rockhampton)

Gambling Help Online

TAB

  • In writing: RG Complaints, c/o Customer Administration Team; Locked Bag 7000 GRANVILLE NSW 2142

Keno

Form 3a Self Exclusion Policy