Responsible Gambling Policy



Commitment to Responsible Gambling

The Clifton Springs Golf Club (Club) is committed to providing the highest standards of customer care and responsible gambling.   Management and Staff recognise that gambling occurs in a regulated environment where consumers can make informed choices about gambling and can exercise a rational and sensible choice based on their individual circumstances.  We acknowledge responsible gambling is a shared responsibility and that collective action needs to be taken by the gambling industry, government, individuals and communities. The Policy is designed to operate in conjunction with the Responsible Gambling Code of Conduct and the Self Exclusion Program. 

Board & Senior Management Oversight

The Club is dedicated to the delivery of all gaming and wagering products in a manner that is responsible and conforms with or exceeds all prevailing government requirements and industry standards.  All board members are required to complete and maintain Responsible Service of Gaming (RSG) and Responsible Service of Alcohol (RSA) certificates during their board tenure. A Responsible Gambling Activity report will be provided to the board each month.  The report will outline; incidents, self-exclusion issues and figures, training events, customer complaints and emerging issues. 

Staff Gambling Policy

Staff at this venue are not permitted to play a gaming machine on a rostered day of work at this venue. This venue provides information to staff so that they are aware of their increased risk of harm from gambling.

Staff Roles and Responsibilities

Management and staff are sensitive to the needs of those people who may develop an unacceptable dependency on gaming machine activity.  All gaming staff are required to engage in responsible gaming practices at all times. It is the responsibility of all gaming staff to attend suitable training sessions in order to gain a thorough understanding of the issues relating to problem gambling. Also, staff are required to know and understand the processes and procedures in dealing with problem gambling issues and to confidently deal with these. Staff feedback regarding RSG operations are vital in maintaining a best practice approach to responsible gambling.  Feedback can be either raised with gaming supervisors, senior management or in staff meetings.  Nominated staff will act as Responsible Gaming Officers, (RGOs). Their responsibilities as RGOs will include assisting customers with relevant responsible gambling and Gambler’s Help support material and supported referral where required.   A person, who approaches a staff member for information about problem gambling services or shows signs of having a problem with their gambling, will be directed to the RGO or Duty Manager for assistance. All staff will be expected to talk to customers about the key messages of the Your Play program and are also required to provide assistance to customers who request to use the program. When enrolling a customer in our Loyalty Program, staff are required to provide Your Play information and ask the customer if they would like to register with the program. If a patron displays any sign of unacceptable behaviour whilst in the venue or playing a gaming machine, the incident is to be immediately referred to either the Responsible Gaming Officer (RGO) or the duty manager.   The customer will then be approached by a staff member who will offer assistance.   Staff will ensure that intoxicated persons are prevented from entering or being in the restricted gaming area.  Staff are to ensure that all gaming related activities engaged in by patrons remain confidential and shall not be discussed with other patrons and other members of the general community. Staff should remember that problem gambling can affect some of the people who gamble.  It is important not to over react but to be aware of the warning signs that may indicate that for some customers gambling has become a problem.   If in doubt, refer to the RGO on shift or Duty Manager. 

Responsible Gaming Officers Roles and Responsibilities

A requirement of the Responsible Gambling Code of Conduct is that venues ensure a Responsible Gambling Officer is always available during operating hours. The nominated RGO will be identified on the roster and staff need to ensure they are aware of the nominated RGO rostered for their shift.  This role will always be held by either the Gaming Manager or Gaming Supervisor on duty.  An outline of roles and responsibilities for the RGO’s are as follows; 
  • Ensure that all compliance checklists are completed prior to each day’s trade.
  • Ensure all point of sale materials including Gambler’s Help information and materials prescribed by legislation or regulation are appropriately located throughout the venue.
  • Ensure adequate stocks of Responsible Gambling materials are maintained and in good order.  
  • Ensure that clocks on machines are in good working order and set to the correct time. 
  • Ensure the Your Play system is functioning
  • Ensure adequate stocks of casual Your play cards are displayed  
  • Ensure all staff on duty know how to log into the Your Play portal to encode and register cards and can assist players when they ask for assistance. 
  • Engage and support customers who disclose that they are having issues with their gambling.
  • Monitor and where appropriate provide support to customers who display problem gambling behaviours.
  • Engage customers displaying unacceptable or anti -social behaviours within the venue.
  • Engage with customers who are identified as breaching their Self-Exclusion Deeds.
  • Engage with Gambler’s Help regarding responsible gambling issues where necessary.
  • Ensure that incidents and complaints at the venue are responded to in accordance with the Code of Conduct and the Group’s policies and procedures. 
  • Ensure that all incidents and complaints are correctly recorded in the Responsible Gambling Register. 
  • Ensure the Club has copies of the Code of Conduct complaint resolution process information and that staff understand the complaint resolution process. 
  • Ensure that the self-exclusion program is operating in accordance with the Code of Conduct and that all staff view photos of self-excluded patrons prior to each shift.  
  • Ensure that all staff are aware and comply with large win procedures.

Your Play Ambassadors Role

Your Play Ambassadors will be required to have a good understanding of the Your Play program and ensure that all Your Play requirements are met and maintained.  Your Play Ambassadors are also required to ensure all staff are confident in using the Your Play portal and proficient in promoting and assisting customers with the program.   The Club will ensure that all staff promote Your Play to customers and assist customers to sign up and use Your Play, always whilst the venue is operational.  The Club will ensure that all staff have completed Your Play training and are able to encode cards, register players and provide further assistance to customers who wish to use Your Play both at the gaming machine and the kiosk. Staff will be expected to talk to customers about the key messages in their interactions with customers. Customers can use Your Play to:
  • track time and money spent on gaming machines 
  • set limits of the amount of time and money spent
  • set personal messages that appear on the machine while they play
  • view their playing history 

Harm Minimisation 

A key responsible gambling initiative of the Club is our commitment to a harm minimisation process designed to enhance customer care.  It is imperative for all staff to interact with customers and be aware of the various responsible gambling and problem gambling situations that may arise from time to time. These situations may include, but not be limited to:
  • A patron either gambling every day or finding it difficult to stop gambling at closing time;
  • A patron gambling for extended periods.  That is, gambling for three hours or more without a break;
  • A patron avoiding contact while gambling, communicating very little with anyone else, barely reacting to events going on around them;
  • A patron making requests to borrow money from staff or other customers or continuing to gamble with the proceeds of large wins;
  • A patron declaring, they have a gambling problem or asking for assistance;
  • A person phones the venue to enquire whether their relative, partner or friend is in the gaming room and claims they have a gambling problem; 
  • A patron displaying aggressive, anti-social or emotional behaviour while gambling;
  • A patron frequently withdrawing funds via the venues EFT facility;
  • A patron becoming distressed upon receiving their player activity statement.
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 (e.g. cup of tea or coffee) in a quieter, more private part of the gaming venue.
Nominated Responsible Gaming Officers or the Duty Manager will further respond to these situations, however it is important to remember that when dealing with problem gaming issues, all gaming staff are expected to-
  • Be discreet
  • Speak quietly
  • Do not be judgemental
  • Show empathy
  • Whenever possible, seek a quiet area away from other customers to provide support
  • If possible, refer the customer to Responsible Gaming Officer or a Duty Manager
  • Know where the appropriate pamphlets are located and hand them to the customer
  • Try to obtain the customer’s agreement to seek professional assistance

Breaks in Play

Customers will be encouraged to take regular breaks from gaming machine play.  This encouragement may take the form of announcements regarding:
  • Non-gaming related activities
  • The availability of the Your Play program
  • Gambler’s Help information
  • Time announcements
  • The promotion of refreshments and bistro meals 
Clocks are also located in all major areas of the venue for the benefit of customers.  Staff are also required regularly to engage with customers whilst conducting gaming room cleans.

Gaming Machine Reservation

The Club’s Gaming Machine Reservation policy is intended to provide customers with a further opportunity to take a break from their gaming machine play.  Reservation signs must be available for all gaming machines in the venue. Customers can reserve a gaming machine for ten minutes however, staff should be flexible depending on the circumstances of the customer’s situation.   The Club will also prohibit customers playing more than one gaming machine at a time.  Where staff identify this behaviour, the customer will be made aware of this policy and requested to cease playing multiple gaming machines.  

Payment of Winnings

All winnings of $2000 and over must be paid by cheque and not made payable to cash.  All customers who win amounts in excess of $500 will be offered a cheque as payment of winnings.  Any customer who requests a cheque for an amount lower than $2000 will be accommodated.

Self-Exclusion Program

The Club operates a Self-Exclusion Program and staff need to be aware of the principles of the self-exclusion program. Nominated RGOs will be required to approach persons entering the gaming room who have registered for self-exclusion.  It is important to note that people must enter the program at their own request and of their own free will, as it is a voluntary program.   A person cannot enter the program under duress from family members or friends, and staff members are not authorised to insist that a person enter the program.  A copy of the Self-Exclusion Program is provided in the appendices section of this policy. At the commencement of each shift, staff will be required to review photographs of the Club’s self-excluded patrons.  Staff also always need to ensure that photographs of self-excluded patrons, names and expiry dates are displayed in the cashier’s station and are only accessible to gaming staff and are not visible to the public.  Staff should always remember that confidentiality and patrons’ privacy is vital.  Staff should never give personal information about any patron to family members or friends. Further, staff should never disclose information to unknown callers questioning them about patrons participating in self-exclusion. Such disclosure may lead to legal liability for gaming staff or the venue. When advised of a patron who has registered for self-exclusion, RGOs are responsible for: 
  • The immediate display of the patron’s photograph, name and ‘Deed’ expiry date in an area accessible to staff only. This information is not to be in view of members of the public.
  • Where the Club participates in Customer Loyalty Programs, RGOs will verify that all patrons who have registered for self-exclusion in the previous month have been removed from the database. 
  •  Monitoring the gaming room for self-excluded patrons who have breached their deed by entering the gaming room, and asking them to leave the gaming room. 
When approaching an excluded patron, it is important to remember to;
  • Always be discreet
  • Speak with the Responsible Gaming Officer or Duty Manager 
  • Check photographic profile of patron 
  • Ask patron for proof of identification to ascertain whether it is the patron you suspect
  • Do not draw undue attention to the patron
  • Once you are sure that the patron is on the self-exclusion program, remind them that they have committed to the self-exclusion program and that the venue would request that they leave the gaming room.  Let the patron know that they are permitted access to the bistro & bar areas
  • If the person refuses to leave, remind them that you are permitted under the deed of self-exclusion to use reasonable force
  • Although the deed states that reasonable force can be used, staff must understand the intended meaning of “reasonable”
  • Staff should not at any time attempt to use physical force on patrons unless the patron becomes physically aggressive. You can inform them that the police will be called if they still refuse
  • After the patron has left, record the breach in the Responsible Gaming Register

Staff Training & Development

Prior to the commencement of gaming operations, all gaming staff will be required to hold a Responsible Service of Gaming certificate.  In the event where new staff are employed without a Responsible Service of Gaming certificate, staff will be required to complete part 1 of the online RSG training course within 1 month of employment.  New staff are then required to complete part 2 of the approved RSG training course within 6 months of their employment commencement date. All new staff are required to complete Your Play online training prior to the commencement of their first shift.   At the commencement of employment, staff are provided with an RSG information pack containing copies of the Clifton Springs Golf Club Code of Conduct, Responsible Gambling Policy and relevant Gambler’s Help material.  New staff are also required to attend Gambler’s Help Venue Support Training within the first 3 months of their employment where possible.  Staff will be required to attend responsible gaming information sessions conducted by Gambler’s Help.  These sessions are vital to our ongoing commitment to responsible gambling and staff are strongly encouraged to make use of these information sessions for their continuing development. The Club will maintain an RSG staff training register for all staff. The register will be regularly updated and include details of employees’ accredited RSG course completion.  Gambler’s Help information session attendance and any further RSG professional development will also be recorded in Responsible Gambling Register.  The Club will conduct regular staff RSG communications as part of the ongoing employee development.  This communication also provides staff with the opportunity to offer feedback regarding the venue’s ongoing RSG operations.  

Stakeholder Relationships

The Club is committed to establishing and building meaningful working relationships with all stakeholders, including local Gambler’s Help Venue Support services, the city of Greater Gelong and other support providers servicing the local area.   Senior management in consultation with the Gambler’s Help Venue Support Program will aim to conduct a minimum of two staff training sessions each year.   Additional training sessions will be conducted by the Gambler’s Help Venue Support Worker where required.  The Club is also committed to participate in activities and events held during the Responsible Gambling Awareness Week and regular Your Play Days.

Dealing with Children in the Venue

All persons under the age of 18 are prohibited from gambling or being present in areas where adults are gambling.  Signage will be displayed alerting customers of these restrictions at the entrance to all gaming areas.    The Club will display signage advising customers not to leave children unattended either in the venue or venue car park and will adopt procedures to check the venue and venue’s car parks under their control.  If staff locate an unattended child, the welfare of the child is the immediate consideration.  Police or emergency services may be notified so that appropriate action can be taken to protect the needs of the child.  A child may be reasonably taken to be unattended if: 
  • It appears the child is without appropriate adult supervision, i.e. a child being supervised by another minor is not deemed to be appropriate supervision, a child in the play area in full view of a parent or guardian would generally not be deemed as unattended 
  • A child is found unattended in or about the venue and is unable to identify the whereabouts of their parent or guardian, or appears lost or distressed 
  • The child is left alone in a vehicle in the venue’s car park, or is found unattended in the car park itself 
If a child is found unattended in the venue or venue car park 
  • Venue staff should escort the child to a secure location 
  • Immediately escalate and report to a Senior Venue Manager 
  • All reasonable efforts should be made to re-unite the child with their parent/guardian.  

Provision of RSG Information

The Club will make available information, including brochures, outlining odds/win rates of major prizes and brochures on where to access assistance with a gaming problem (including all material required by law).   For customers seeking information on support provider services or who may wish to impose restrictions on their gaming activity, their query is to be immediately referred to either the RGO or Duty Manager. Gambler’s Help information will be displayed throughout the venue. The provision of Your Play materials and casual customer cards will be located at the cashier’s station and additional Your Play brochures will be located throughout the gaming room and at the Your Play Kiosk.  Staff will ensure that customers who request information regarding the Player Information Display screens and/or the Your Play program will be assisted with their enquiry and guided through the systems. The Club will ensure that copies of the Code together with copies in community languages will be made available to all customers.  This information will also be made available on the Club’s website. 

Customer Complaints Procedure

All complaints regarding the code will be directed to the Responsible Gambling Officer or the Duty Manager on shift. The RGO will follow through with the complaints resolution process identified in the Code in order to resolve complaints. In addition, information pertaining to the complaints process will be made available at the cashier’s station and will be given to patrons upon request. Documentation regarding all complaints against the Code must be maintained in the Responsible Gambling Register for access by the VCGLR as required.

Policy Review

The Club will review the Responsible Gaming Policy annually or when required to update legislative and/or industry standards.