Policy
Submissions

Submissions and Open Letters from the Alliance for Gambling Reform to Decision-Making Bodies

ALLIANCE POLICIES AND POSITION PAPERS ON REFORM ISSUES

NATIONAL ADVOCACY

The National Consumer Protection Framework for Online Wagering
 

The Alliance takes a public health approach to gambling harm. In this submission, we use the term ‘harm’ to describe any negative consequence that results from a person’s own or another’s gambling. These commonly accepted harms include:

● Financial problems
● Relationship conflict or breakdown
● Health problems
● Emotional or psychological distress
● Reduced capacity in other parts of your life
● Cultural harms
● Criminal activity

Gambling harm extends beyond addiction, often impacting many people, not just the person who is gambling. Family members, friends, employers and the broader community can also be harmed by someone else’s gambling. As a community, we have recognised the harms to others that tobacco represents, and have policies that aim to prevent passive smoking. We need to build protections for those who are harmed by an activity they cannot directly control. 
READ MORE

In 2010, the Productivity Commission presented evidence that supported earlier
commencement and longer duration of mandatory shutdown. It found that the mandatory
shutdown should occur no later than 2am and be for at least six hours. The Commission
accepted that venues’ revenue derived from gaming machines would decline as a result of
mandatory shutdowns and is to be expected if the measure is having an effect on reducing
harm on gambling.¹


In 2008, NSW reviewed the effectiveness of a six hour shut down period introduced in 2003.² Findings included a correlation between gambling harm and late night hours (12am to 6am) and found a venue shutdown is effective in mitigating gambling harm by forcing a ‘break in play.’² READ MORE

The Alliance for Gambling Reform (The Alliance) welcomes the development of and
consultation for the Victorian sucide prevention and response strategy. The Alliance will
address the impact gambling has on contributing to mental health problems
and suicides in Victoria.


Victoria’s new Suicide and Prevention and Response Strategy must include a dedicated
focus on gambling related suicides. If the strategy’s vision of ‘towards zero suicides’ is to be achieved, there must be significant gambling reform and a genuine focus on gambling as a public health concern. READ MORE

NSW Crime Commission Inquiry into Money-laundering in pubs and clubs

The Alliance has made a submission in relation to possible recommendations of the Inquiry, urging it to consider a universal, identity-linked cashless payment system which is designed to reduce gambling harm as well as hinder money-laundering. Without good design features, cashless payment systems will be exploited by the gambling industry to increase losses. Our submission will be uploaded once the Inquiry gives permission (28/1/2022).

The Alliance is campaigning to have SBS remove gambling ads from all its services. We know that as a cash strapped public broadcaster, some Board members are anxious about revenue. We have submitted to Federal Treasury to increase the annual budget of SBS by the equivalent of their gambling ad revenue, which we believe to be around $4million a year. The Alliance and its supporters could then continue to pressure the Board to change its policy, knowing it has the replacement revenue (28/1/2022)

Creating a single portal where people can exclude themselves from all online bookmakers (of which there are about 130 currently operating) in one action will be a significant benefit. Developing the Rules around the Register includes numerous consultations. The Alliance also consulted with Voices for Gambling Reform to prepare our responses. There are a number of areas we believe can be improved from this draft, including less onerous sign-on processes, provisions for reimbursements for bets made after application for self-exclusion but before that is made active, more obvious links to the Register, and changes to advertising to promote the Register instead of mumbling "Gamble Responsibly" (23/12/2021)

You won't have noticed previous administrative reviews of The Star casino in Sydney because they have traditionally been cozy affairs between the casino and the person conducting the review. Not this time. The Review is being conducted by Adam Bell, who assisted in the Inquiry to Crown/Barangaroo's suitability to hold a license in NSW. While there was only one explicit clause in the terms of reference to gambling harm minimisation programs in the casino, the Casino Control Act also requires that the casino take action to stop harm to individuals and the community. A key part of the Review involves examining money-laundering and other criminal acts, but we have been instrumental in improving the focus on gambling harm. We made 10 recommendations around improved research and data about the impact of gambling at The Star on the NSW community, improving and making independent a new code for responsible gambling, improving the exclusion system and ceasing to criminalise gambling compulsion, and ending linking loyalty programs to gambling activity (10/12/2021)

The Alliance for Gambling Reform responded to the questions posed in the section titled ‘Harm minimisation and the responsible service of gambling within the casino environment’. We recommended that there be an independent authority to develop responsible gambling codes of conduct, and that people with lived experience of gambling harm have a strong voice in developing those codes. We point out the conflicts of interest that the casino has, as a profit taker, and recommended that oversight be made more independent and rigorous. The submission was written by our Reform Campaigner Rose O'Leary (Dec 2021)

The Online Safety Act came into effect on 23 January 2022. The Expectations set out standards the government expects online service providers to adhere to. The Act excludes advertising from coverage. The Alliance presented the community's expectations on safety. Our recommendations were that all gambling advertising, marketing and sponsorship be banned on any platform, as tobacco is. Failing this, noting the dangers that gambling advertising has, particularly for children, we recommended that people be able to make complaints about all or many service providers at once. We also recommended that "other harmful material" be expanded to include the harmful industries of gambling, alcohol, tobacco and unhealthy food, so that service providers would have to make explicit decisions about allowing advertising of these dangerous products. (19/11/2021)

An open letter to the Victorian Premier, Gambling minister, and Health minister, from Rev Tim Costello, asking for them to take this extraordinary opportunity to rebuild Victoria with a stronger and healthier pubs and clubs sector, free from harm and machines of addiction. (September 2021)

After weeks of lockdown, especially in Sydney, our communities need to rebuild. People need safe, healthy places to reconnect with families and friends. Workers in hospitality need safe jobs, looking after their customers. We know from 2020 that unless care is taken, when venues with poker machines reopen, the stress and anxiety of lockdown and COVID is often released through unproductive gambling. Every state last year saw a spike in losses after COVID Lockdown #1. We are urging decision makers to not make the same mistakes in 2021 (letter 29/9/2021).

We shared our submission to the Victorian Crown Royal Commission, as it contains a great deal of general material in relation to casinos and gambling harm that is relevant to the WA situation. In our submission to WA, we acknowledged the importance of not having poker machines in pubs and clubs. We noted that the Gaming and Wagering Commission in WA had demonstrably failed to manage conflicts of interests in its dealings with Crown Perth. In addition, we recommended that there be an independent body developing and overseeing gambling harm reduction programs in the Casino, rather than as at present, and as in every state, allowing the Casino to manage its own program. We also noted the inappropriate membership of the WA Problem Gambling Support Services Committee, which is stacked with gambling industry reps. (Aug 2021)

The Alliance expanded on its submission to the Senate inquiry on Interactive Gambling Amendment (Prohibition of Credit Card Use) [see below]. We again recommended a legislative solution, as we do not believe the gambling and finance sectors can produce an effective code of conduct that prioritises customer protection over profits. We discussed the issues of digital wallets and other digital payment methods, recommending language be used that will capture future digital payment methods and ensure that no-one can gamble with money they do not have. ( 25 June 2021)

This letter was sent on June 22 2021 to all NSW MPs in relation to the Budget. NSW cannot afford to continue to budget on increased GamblingTaxes. The human and public health costs are too high. We must see the true cost of gambling in the Budget papers.

The Alliance for Gambling Reform (Alliance) strongly supports the prohibition of gambling with credit including using credit cards, based on the principle that people should not be encouraged to gamble with money they do not have. The amendments simply extend the existing ban on providing or promoting credit for gambling to include third party credit in the form of credit cards. (29/4/2021)

The Alliance for Gambling Reform (Alliance) strongly supports the prohibition of gambling with credit including using credit cards, based on the principle that people should not be encouraged to gamble with money they do not have. The amendments simply extend the existing ban on providing or promoting credit for gambling to include third party credit in the form of credit cards. (29/4/2021)

The Alliance for Gambling Reform (Alliance) strongly supports the prohibition of gambling with credit including using credit cards, based on the principle that people should not be encouraged to gamble with money they do not have. The amendments simply extend the existing ban on providing or promoting credit for gambling to include third party credit in the form of credit cards. (29/4/2021)

The Alliance's detailed submission (11/12/2020) on the proposed reforms to the gambling exclusion system in NSW. It includes obliging venues to exclude, or promptly remove, people who have self-excluded, or have been excluded for other reasons. Rather than a punitive measure, this ensures venues are also taking responsibility for helping to keep people safe, if those people have taken the steps to acknowledge their problems and wish to stay away from poker machines. Other parts of the reform bring in pathways for families to apply for exclusion of a loved one, in a crisis. It will establish a state-wide exclusion register, hopefully finally allowing people to exclude from every venue, rather than the artificial limits imposed now by ClubSafe and BetSafe. We have also called for the addition of a universal cashless gambling system to act as a back up for exclusion processes, and to allow people to choose to set their budget from anywhere from $0.

An open letter to the Premier, and members of the NSW Cabinet from Rev Tim Costello.
The letter is calling for support for Minister Dominello's anti-money laundering measures and card proposal, and expressing concerns about the implications of money laundering within the gambling industry.

An open letter to ask Premier Andrews, Gambling Minister Melissa Horne, Treasurer Tim Pallas, Health Minister Jenny Mikakos, Minister for Mental Health Martin Foley, Minister for Prevention of Family Violence Gabrielle Williams, and Minister for Small Business Jaala Pulford.


The letter is calling for changes to opening hours of businesses with gaming facilities in Victoria, in an effort to prevent gambling harm.


Signed by mayors of the following 13 Councils: Maribyrnong, Banyule, City of Monash, City of Darebin, City of Kingston, Brimbank Council, Wyndham City, City of Greater Dandenong, Moreland Council, the City of Whittlesea, Frankston Council, Knox City Council, and Mitchell Shire. 

A letter to ask the NSW Premier to express our shared concerns regarding the continued use of gaming rooms in NSW during COVID-19. Co-signed by Joanna Quilty, CEO NCOSS; Rev Keith V Garner AM, CEO/Superintendent Wesley Mission; Billie Sankovic, CEO Western Sydney Community Forum; and Rev Tim Costello, Chief Advocate, Alliance for Gambling Reform.

The Alliance's brief submission, requesting that the proposed Cumulative Impact Assessment Framework include gambling densities - poker machines, TAB, Keno outlets etc.

An open letter from Tim Costello to NSW MPs asking if it the Chief Medical Officer had all of the available medical information to make an informed decision regarding switching poker machines back on.

A letter to ask the NSW Premier to ask her to reconsider the role of poker machines in NSW post COVID-19.

A letter to ask the NSW Premier to ask her to reconsider the role of poker machines in NSW post COVID-19.

The Alliance strongly supports the prohibition of gambling with credit, based on the principle that people should not be encouraged to gamble with money they do not have. This provision should apply to all forms of gambling, however, focused on online gambling where harm is most acute, and implemented at the earliest possible time. Gambling with borrowed money is well-established as a risk factor for harmful gambling and financial institutions have a responsibility to ensure customers are not putting themselves and their families at risk by gambling more than they can afford.  March 2020 

The Alliance supported the creation of a National Self-Exclusion Register as part of the National Consumer Protection Framework for Online Wagering, and suggested additional protections be added. We also called for annual data reporting, and that the Register be operated by a government agency, not a private corporation (25 October 2019)

The Alliance's submission on Social Policy and Legal Affairs inquiry into age verfication for online wagering and online pornography (25 October 2019)

The Alliance's submission on Social Policy and Legal Affairs inquiry into age verfication for online wagering and online pornography (25 October 2019)

The Human Rights Law Centre, the Australian Conservation Foundation and the Uniting Church in Australia, Synod of Victoria and Tasmania together with 9 other civil society organisations urging that caps be imposed on the amount of money candidates, political parties, political campaigners and third parties can spend in the lead up to and during Federal elections (23 September 2019)

The Human Rights Law Centre, the Australian Conservation Foundation and the Uniting Church in Australia, Synod of Victoria and Tasmania together with 9 other civil society organisations urging that caps be imposed on the amount of money candidates, political parties, political campaigners and third parties can spend in the lead up to and during Federal elections (23 September 2019)

The Human Rights Law Centre, the Australian Conservation Foundation and the Uniting Church in Australia, Synod of Victoria and Tasmania together with 9 other civil society organisations urging that caps be imposed on the amount of money candidates, political parties, political campaigners and third parties can spend in the lead up to and during Federal elections (23 September 2019)

The Alliance's recommendations for extensive improvements which could be made to the Regulation, with a particular focus on removing the phrase "problem gambler", and prioritizing the reduction of gambling harm (July 2019)

12 January 2018, Submission by the Alliance, VLGA & Victorian Inter-church Gambling Taskforce 

The Alliance's letter to the Minister regarding the absence of a cap on pokies in the CBD

Submission by Uniting Church in Australia, Synod of Victoria and Tasmania; the Alliance for Gambling Reform; the Foundation for Alcohol Research and Education; and the National Alliance

Submission into the 5 yearly review of Crown Melbourne licence

The Alliance has called for a maximum 20% shareholding to be introduced

2017 submission to NSW process looking at how pokies applications are assessed 

To see motions passed by Local Councils related to gambling issues: click here