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Executive Summary
This inquiry into the design and implementation of a
mandatory pre-commitment system arose in recognition of the significant harms
caused to individuals, families and the wider community through problem gambling
associated with high intensity Electronic Gaming Machines (EGMs). Individuals
who experienced the harms of poker machine gambling shared their stories of
personal devastation and provided their insights. Their voices are rarely
heard. These stories and their advice on design features are outlined in
chapter two. EGM addiction has resulted in children going hungry, family
breakdowns, homes and businesses lost, relationships damaged and, most tragically,
suicide. Our duty of care starts well before an individual hits rock bottom
financially and emotionally.
Mandatory pre-commitment—requiring players to pre-set limits
before they play—will reduce the harms of problem gambling by encouraging all
players to make rational and conscious decisions about their gambling. It will
intervene to stop individuals and their families from reaching desperate
circumstances. Pre-commitment is a management tool for all. For those not at
risk it will assist them make sensible choices while not diminishing their
enjoyment. As outlined in chapter four, which explains the need for a broad
population based approach, pre-commitment will hinder the progression of EGM
players from no risk to at risk. For those at risk or with a gambling problem, pre-commitment
is a tool for long-term change and learning new, healthier gambling behaviours.
EGMs of today are not the 'one armed bandits' of yesteryear.
Their design and features have changed significantly. EGMs are now predominantly
high intensity, high risk machines. This means players can and do lose a lot of
money in a short space of time—well over $1,000 per hour in some cases.[1]
They are no longer a harmless recreation.
Due to the intensity and ready availability of EGMs, poker
machine gambling is considered the riskiest form of gambling. EGMs display conditioning
features designed to attract people to play continuously, leading in some
cases, to addiction. This is explained in detail in chapter three. The
committee agrees that the modern design features of high intensity machines
make them unsafe and safeguards should be put in place to protect players. Along
with mandatory pre-commitment on high intensity machines, the committee
believes low intensity machines that feature a number of intensity limiting parameters,[2]
should be made available. While recognising that no EGM is entirely safe, the
committee believes that increasing the availability of low intensity machines,
either on their own or in combination with high intensity machines with
mandatory pre-commitment, would provide greater choice for those players
seeking a lower risk, more recreational activity and greater choice for venues.
Such low intensity machines would operate outside the mandatory pre-commitment system.
This is further described in chapters three, eight and nine.
Academic experts, former problem gamblers and social service
agencies all agreed, and trials of voluntary pre-commitment show, that in order
to be effective pre-commitment must be mandatory. If a person can opt out once
they reach their limit by playing on another machine it will be of little benefit.
The key design features that the committee recommends in chapter six are as
follows:
-
introduction by the earliest possible date—2014;
-
a requirement for all players to set their maximum loss before
they start gambling;
-
lock out when limits are reached;
-
cooling-off periods for limit increases;
-
safeguards to prevent gamblers machine and venue hopping; and
-
an effective self-exclusion function.
The committee does not prescribe a specific technical
solution. However, it explicitly rejects biometrics for identity purposes. Technology
options that could facilitate mandatory pre-commitment are outlined in chapter
seven. Witnesses advised that implementation can be achieved in the timeframe
required.
The committee recognises the different technical
environments across jurisdictions cause the industry significant extra costs. Noting
this is a longer term issue, the committee recommends a phased approach working
towards the adoption of common national technical standards over time. In the
first phase, implementation of mandatory pre-commitment by 2014 is jurisdiction
based but with national oversight. In the second phase, jurisdictions move
towards harmonisation of technical standards. Full implementation of uniform
national technical standards that will also include consumer safety and harm
minimisation principles is the final phase. This staged approach allows for
early action to address problem gambling, while facilitating the longer-term
goals of adopting national technical standards and addressing technical
challenges. While the cost of implementing mandatory pre-commitment is yet to
be determined, the top of the credible cost range is much less than the amount
of money lost by problem gamblers in a single year.
The committee agreed a national independent regulatory body to
oversee pre-commitment arrangements, develop new national standards which
include the required pre-commitment features and other consumer protection
measures, is needed. While having national oversight, the body should
incorporate a jurisdictionally-focussed inspection and monitoring regime. More
details on this are provided in chapter six.
The committee is mindful of industry concerns, and acknowledges
the harm minimisation measures already in place. While not denying the
community contributions made, many larger venues increasingly resemble mini
casinos and big businesses. They bear little resemblance to the smaller, mostly
regional and rural, community venues and it is disingenuous to claim otherwise.
The committee makes a number of recommendations which address industry concerns
in chapter nine.
The committee believes that low intensity machines, subject to
certain parameters, be introduced. Venues not wishing to be included in the
mandatory pre-commitment scheme which will apply to high intensity machines
have the option of choosing to run low intensity machines. The advantages for venues
include that machines modified to low intensity play can be drawn from the
current fleet; venues have a choice of what machines to operate; and venues operating
both high and low intensity machines give players greater choice.
The committee does not want the introduction of mandatory
pre-commitment to disadvantage smaller venues—venues operating 15 machines or
less—largely
in regional and rural areas, or see important services and facilities being
removed from these communities. To this end it believes such venues require
special consideration and assistance with the implementation timeframe and
costs. The committee agrees with the Productivity Commission that a longer
timeframe to implement mandatory pre-commitment for these venues is needed.
However, as the Commission's anticipated commencement date has now slipped the
committee recommends that smaller venues now be given until 2018 to establish the
scheme. Mindful of the specific needs of small venues, they will be allowed
four years more than large venues to implement these reforms. To assist with
implementation or other costs or revenue shortfalls the committee proposes a
transitional assistance fund to which smaller venues could apply. These issues,
the use of low intensity machines and the circumstances facing casinos with
accommodating foreign tourists are discussed in chapter nine.
These reforms are about reducing the harm to individuals,
families and the wider community from poker machines. Inevitably, they target
the revenue streams from problem gamblers. Venues have stated that they do not wish
to receive a single dollar from problem gamblers. Any venue which can't sustain
a drop in revenue from problem gamblers has a business model that is
fundamentally flawed, unsound, and unethical. Venues which claim they have few
or no problem gamblers will see little drop in revenue, as recreational
gamblers can either join this simple to use pre-commitment scheme or opt to
play on low intensity machines.
As well as making recommendations on the design of a mandatory
pre-commitment scheme, the committee has taken the opportunity to make
recommendations on other issues raised in relation to EGMs and wider issues where
relevant throughout the report.
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