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SUBMISSIONS
AND
OPEN LETTERS

Alliance for Gambling Reform - Northern Territory Code of Practice for Safer Online Wagering 

The Alliance has provided a submission to the Northern Territory draft Code of Practice which they intend to finalise by June 30 this year. The Alliance believes firmly that a National Gambling Regulator should be established as per the Federal Government’s online inquiry report. We see this Code as a temporary measure for licensees based in the Territory while we wait for the Federal Government to take national action. The Code as put forward by the Territory Racing Commission unfortunately has a number of deficiencies and fails to offer all possible measures to support preventing gambling harm.

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Alliance for Gambling Reform 2024-25 Pre-budget Submission

This submission recommends urgent government actions be adopted in the 2024-25 Federal Budget:
» Invest in an independent peak body to reduce gambling harm
» Adopt key aspects of the Albanese Government’s strategy and funding to reduce smoking and vaping and apply them to reducing gambling harm
» Fund and implement all 31 recommendations from the inquiry to tackle the escalating harms caused by gambling

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Submission to the Senate Finance and Public Administration Reference Committee

Inquiry into Access to Australian Parliament House by Lobbyists

The Alliance is concerned that powerful vested interests from the gambling industry, and their allies, have a growing influence via increasing access to Australia’s Parliament House, due to a lack of regulation and transparency.

If adequately regulated and transparent, political lobbying can support democratic representation by providing a means for diverse views to be heard and responded to by government.

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The Alliance welcomed the recommendations in the independent external review of the Queensland operations of Star and Palaszczuk Government’s announcement to accept all the recommendations in principle. The Alliance also acknowledges the effort of the Queensland Government to replace terms such as ‘problem gambler’ and ‘responsible gambling’ in relevant legislation and replace it with wording to reduce stigma and shame. This is a positive, nation-leading step by the Queensland Government.

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The Alliance for Gambling Reform is a national peak body which represents a collaboration of organisations with a shared concern about the harmful aspects of gambling and its normalisation in Australian culture. We are a registered health promotion charity. The Alliance supports public policy and regulatory regimes that make Australia a safer, healthier, and more equitable society by reducing the level of gambling harm.


The Alliance has responded to the relevant questions set out in the Review of Victoria’s Responsible Gambling Codes of Conduct consultation paper and provided recommendations in eleven key areas. The Alliance welcomes the Victorian Government’s commitment to major reforms to poker machines and hopes that same commitment will be made to reforming the Codes of Conduct. The current Codes have not kept pace with technology and product advancements and this needs to change. We urge the government to take the strongest approach to the new Codes; these are set out in our recommendations and submission.

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The Alliance for Gambling Reform is a national peak body which represents a collaboration of organisations with a shared concern about the harmful aspects of gambling and its normalisation in Australian culture. We are a registered health promotion charity. The Alliance supports public policy and regulatory regimes that make Australia a safer, healthier, and more equitable society by reducing the level of gambling harm.

 

The Alliance has responded to the relevant questions set out in the ‘pre-commitment and carded play’ consultation paper and provided recommendations in nine key areas. The Alliance welcomes the Victorian Government’s commitment to major reforms to poker machines and urges the government to take swift action to implement the changes. We also urge the government to take the strongest approach to the reforms; these are set out in this submission.

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Australians lose over $25 billion on legal forms of gambling each year, representing the largest per capita losses globally1 . Online gambling has grown substantially over the past decade and the related harms are of increasing concern 2 . Australians also lose the most money to online gambling per capita, more than 20% more than any other country in the world.

 

Online gambling has evolved so swiftly that research, policy, regulation, and governments have not been able to keep up to prevent the exponential growth in gabling harm. The lack of regulatory measures to prevent these developments is harming not only adults, but more frequently children.

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Alliance for Gambling Reform Submission Inquiry into Gaming Machine Amendment Bill 2023 - ACT Legislative Assembly

The Alliance for Gambling Reform is a national peak body which represents a collaboration of organisations with a shared concern about the harmful aspects of gambling and its normalisation in Australian culture. We are a registered health promotion charity. The Alliance supports public policy and regulatory regimes that make Australia a safer, healthier, and more equitable society by reducing the level of gambling harm. We prioritise policies and actively campaign for changes that prevent gambling harm and minimise its consequences.

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The amendments to the Gaming Machine Act 2004 will preclude the ACT Gambling and Racing Commission from issuing authorisation certificates for Class C gaming machines in the Molonglo Valley and other undeveloped areas of the ACT.

 

The Alliance for Gambling Reform warmly welcomes the Gaming Machine Amendment Bill 2023 to ensure that the Molonglo Valley and other undeveloped areas of the ACT will not have poker machines in their communities. This Bill has been underpinned by community consultation which has shown support a poker machine free community in the Molonglo Valley and ensures this developing community is able to thrive and develop without the harms poker machines create.

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Legislative Assembly for the Australian Capital Territory Standing Committee on Justice and Community Safety Inquiry into Cashless Gambling

The Alliance for Gambling Reform (The Alliance) advocates for a mandatory, cashless registered gambling card with mandatory pre-commitment which is binding and has reasonable default limits. Cashless gambling without robust harm minimisation features have a potential to cause greater harm due to the frictionless nature of being cash-free.

 

The evidence is clear: approaches relying on voluntary and/ or anonymous gambling cards are self-defeating. They simply do not achieve the aims of minimising and preventing gambling harm and/or addressing criminal activity.

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The Alliance for Gambling Reform (The Alliance) has been concerned about the impact of gambling-like features in both computer games and phone apps for many years. It is not only one element of Australian children being groomed to become gamblers, but it is also being impacted by harm very similar and on-par with gambling harm due to loot boxes. There are a number of useful studies as well as international case studies that provide the Australian Government with the evidence it needs to go further when it comes to classifications of video games, and the Alliance would strongly urge the government to ensure this legislation includes phone apps.

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The now Victorian Gambling and Casino Control Commission (VGCCC) has gone through extensive changes since the VAGO 2019 Regulating Gambling and Liquor report. The most significant were not due to the findings and recommendations of the VAGO report but instead were due to the Royal Commission into the Casino Operator and Licence (RCCOL).

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Harm from gambling is a serious public health issue that is growing rapidly and directly impacting millions of people, as well as placing a burden on the economy. Australians lose the most to gambling per capita, at around double the average of other Western Countries1 . The gambling industry has expertly crafted a system which is not only very profitable but also makes significant direct contributions to politicians and political parties that form our governments. Taxes derived from gambling are often placed in state hospital, mental health and charities funds which makes it difficult for governments to justify regulatory changes that would reduce tax revenue.

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Alliance for Gambling Reform - 2023-24 Pre-budget Submission

The Alliance for Gambling Reform is pleased to provide this submission to the 2023-24 Federal Budget process. Our submission is focussed on preventing and reducing all aspects of gambling harm in Australia. 
 

This submission builds on our evidence provided to the Standing Committee on Social Policy and Legal Affairs inquiry into online gambling and its impacts on those experiencing gambling harm. We appeared before the Committee and provided additional evidence in late 2022. 
 

Gambling harm is a public health issue that is rapidly growing and impacting millions of Australians. There is a critical need for an immediate national investment to reduce and prevent gambling harm. The Alliance has worked with people who have a lived experience of gambling harm, adopting an evidence-based public health approach in developing the policy positions and proposals outlined in this submission. 
 

This submission recommends four urgent government actions be adopted in the 2023-24 Federal Budget: 

  1. Establish a national gambling regulator 

  2. Increase public awareness of gambling and its harms though a multi-platform national gambling harm campaign

  3. Promote and improve treatment and referrals for people experiencing gambling harm

  4. Significantly increase funding for independent research to investigate the impacts of, and treatment for, gambling harm

 

The alliance welcomes this opportunity to provide this brief Pre-Budget submission and would also welcome any further opportunities to provide more detail or discuss any aspect of this submission.
 

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The Alliance for Gambling Reform (The Alliance) strongly supports the prohibition of gambling with credit including using credit cards, ‘buy now, pay later’ systems, digital or ewallets and third-party payment mechanisms based on the principle that people should not be able to gamble with money they do not have. READ MORE

Alliance For Gambling Reform - Position Paper Facial Recognition Technology (FRT)

Facial Recognition Technology (FRT) is defined as a system which scans people’s faces by identifying and measuring facial features which then matches a digital image or video frame against a database of faces. In terms of its possible uses for the gambling industry, the primary use is to alert staff of a person entering a venue or gambling area who may be registered as an excluded person. An excluded person may be excluded on their own terms due to harm associated with gambling, or a venue has excluded them for a variety of reasons including potential harms being experienced or poor behaviour in a venue. READ MORE

The Alliance for Gambling Reform calls on all Australian jurisdictions to introduce a requirement for mandatory, registered cashless gambling cards for use with Electronic Gaming Machines (EGMs, otherwise known as poker machines or “pokies”) in all venues that have EGMs, including hotels and clubs as well as casinos. There is compelling evidence that a mandatory cashless gambling card will help minimise the harm caused by gambling, and will have the additional benefit of addressing criminal activity related to EGMs. READ MORE

Alliance for Gambling Reform Inquiry into online gambling and its impact on those experiencing gambling harm

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. 
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Alliance For Gambling Reform - Opening Hours Policy Paper

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

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