Compliance in Practice

On your club notice board, you should display your board approved Gaming Code of Practice Policy Statement, a copy of your liquor licence, ClubSAFE certificate of membership, ‘Important Information for Members and Guests’ signage, as well as a list of any unclaimed gaming payouts over ten dollars expiring in the next 31 days. By displaying this information in one place, it allows staff to direct the relevant authorities or patrons to one ‘source of truth’.

Inspectors and licensing police will always check to ensure appropriate signage is in place. Signage, as cumbersome a requirement as it may sometimes feel, is a very low difficultly obligation. [LB1] If ‘Help is Close at Hand’ stickers are missing from gaming machines, or signage in bar or gaming areas is non-compliant, or brochures are not in relevant areas, this may prompt an inspector to delve further into questioning a venue’s governance to assess if and how it is complying with relevant requirements.

Having a staff member with relevant experience tasked with completing regular L&G self-audit checklists is an effective way to firstly maintain a history of compliance and correction, and secondly, it trains staff to automatically identify missing signage throughout their shift.

The Club Gaming Code of Practice is a significant document which demonstrates how seriously clubs take their responsibility for harm minimisation. A key requirement is to appoint a Responsible Gambling Officer (RGO) – tasked with ensuring compliance with the Code. It is important the RGO has been trained to deliver Code compliance and provide the board relevant information to maintain its oversight of the Code. ClubSAFE can provide this training virtually, or RGOs can complete the training in self-guided modules — please reach out to us prior to 30 June 2024 via [email protected].

L&G regularly request staff to provide evidence of their RSA or RCG competency. Although the requirement is on the staff member to always be able to provide their physical card, or display their digital driver’s licence, clubs should hold a copy and records of each staff member’s competencies, monitoring expiry to ensure no staff can work without current certification. There are numerous examples where staff members have changed email addresses and not received a notification to complete mandatory refresher courses and have subsequently worked uncertified. Allowing a staff member to work without an RSA or RCG risks financial penalties – for the staff member, as well as the venue.   

L&G have remained actively engaged in consultation with the industry via their Regulatory Roadshows. They have also shared their regulatory priorities for the remainder of 2023, which focus on harm minimisation within gaming venues such as assessing ATM visibility from the gaming floor, and ensuring staff are aware of self-exclusion processes and local counselling service providers. They have publicly disclosed targeted compliance operations between October and December in areas including Bathurst, Lithgow, Blue Mountains, Newcastle, Tweed Shire, Albury and Coffs Harbour.

If a member has any questions on how best to comply with their obligations under the Code, or the legislation, they are encouraged to call ClubASSIST on 1300 730 001. You can also register your expression of interest regarding ClubSAFE packages of training and compliance assurance services here.