promotions and ‘below cost’ meals, free transport, and vouchers. The practice of ‘minimum stays’ for visiting groups – in which visiting organisations are offered incentives in return for ensuring their members must stay on site for several hours – should also be prohibited. These marketing strategies are designed to circumvent the defences of deprived and vulnerable populations and Q 8. There should be a separate offence for failure to respond to demonstrations of problem gambling. As operators of a high-risk and potentially harmful product, gambling venue operators have a duty of care to ensure that their customers are not harmed by their product, as far as is practical. This offence should apply to all gambling venues in the state, including Crown Casino. The Government should consider how this might be applied to non-venue based gambling offered within Victoria. Penalties for offences considered by this consultation should be linked to venue losses. As a guide, one penalty unit should be equivalent to the average daily losses on EGMs in that venue. Establishment of an Ombudsman The Government should establish a Gambling and Liquor Ombudsman. This officer would be a venue for complaints about the operation of gambling venues and services. Q 9-11. Self-exclusion systems should be simple and easy to use, and allow a person to restrict themselves from as many venues as they require. This system should be covered by a single point of entry and administered by Gambler’s Help services. This point of entry should be functionally identical at any place in the state.
promotions and ‘below cost’ meals, free transport, and vouchers. The practice of ‘minimum stays’ for visiting groups – in which visiting organisations are offered incentives in return for ensuring their members must stay on site for several hours – should also be prohibited. These marketing strategies are designed to circumvent the defences of deprived and vulnerable populations and Q 8. There should be a separate offence for failure to respond to demonstrations of problem gambling. As operators of a high-risk and potentially harmful product, gambling venue operators have a duty of care to ensure that their customers are not harmed by their product, as far as is practical. This offence should apply to all gambling venues in the state, including Crown Casino. The Government should consider how this might be applied to non-venue based gambling offered within Victoria. Penalties for offences considered by this consultation should be linked to venue losses. As a guide, one penalty unit should be equivalent to the average daily losses on EGMs in that venue. Establishment of an Ombudsman The Government should establish a Gambling and Liquor Ombudsman. This officer would be a venue for complaints about the operation of gambling venues and services. Q 9-11. Self-exclusion systems should be simple and easy to use, and allow a person to restrict themselves from as many venues as they require. This system should be covered by a single point of entry and administered by Gambler’s Help services. This point of entry should be functionally identical at any place in the state.
Submission_-_VLGA_-_Victorian_Local_Governance_Association_response_to_harm_minimisation_measures_consultation.DOCX