The Canberra Gambling Reform Alliance (CGRA) recognises that current community contributions are highly valued by those organisations who receive these cash donations and in-kind support. CGRA also recognises that this scheme aims to redistribute gambling profits towards activities that deliver community benefit.

While this aim is commendable, CGRA believes that the current scheme is completely inadequate and not fit-for purpose. Key concerns of the scheme include the fact that the current scheme does not prioritise mitigating the harms caused by this form of gambling and the current allocations made by individual clubs reflect this. The current design of the scheme does not reflect the Government’s stated commitment to a public health approach, the distribution of funds are not transparent and the scheme is managed by the very organisations who are making profits from gambling.

CGRA believes that the current framing of this scheme as ‘community contributions’ rather than a gambling harm levy creates a false understanding of the role of the scheme and sees the majority of these funds allocated to activities that are in line with gambling operators interests rather than where funds are most needed. Reframing these funds as a gambling harm levy is consistent with the accepted Government approach of expecting mitigation of harms caused by selling products such as tobacco and alcohol.

CGRA believes the obligation to contribute 8% of profits from an activity known to be harmful is modest, particularly given that at least 40% of these profits are derived from gamblers who are experiencing significant harm from this activity.[1] This obligation still enables venues to direct the other 92% of profits in a manner that its members and directors see fit. CGRA believes that the distribution of these profits should also come with an obligation to prioritise activities that reduce the harms caused by gambling and be distributed in a manner that is transparent and accountable back to the community. The distribution of funds collected from the scheme must be managed separately from the organisations who are profiting from gambling activity.

Given the track record of clubs around the allocation of funds from the community contributions scheme in addition to the potential of poker machines being located in the Casino, there is the need to radically overhaul the scheme’s design and operation.

 

RECOMMENDATIONS AND CALL FOR ACTION

CGRA calls on ACT Government to act immediately to overhaul the community contributions scheme to make it fit-for-purpose. In particular, CGRA calls for the ACT Government to:

1. Rename the scheme to better reflect is purpose, to identify the allocation as a ‘Gambling Harm Levy’ and the broader scheme as the Gambling Harm Reduction Scheme;
2. In line with public health principles around reducing the harms caused by gambling, amend governance arrangements so that the authorising agency for administration of funds is allocated to ACT Health;
3. Remove the ability to recognise in-kind contributions as part of the scheme. Instead, given revenue is generated through the transfer of actual losses (with 40% of these coming from people experiencing harm) only recognise actual monetary contributions to the scheme.
4. Mandate minimum contributions into specific areas of work, to mitigate the harm caused by gambling in the ACT. Specifically CGRA recommends that:

• 30% of funds should be targeted towards prevention strategies (including public health responses, education and research),
• 30% towards recovery services and addressing the negative impacts of harm including financial harm and wider community harms (welfare responses such as emergency relief etc),
• 40% towards supporting organisations and projects that are strengthening communities, building community capital and supporting social and emotional wellbeing, including education institutions and sport and recreational activities

5. Overhaul the decision-making process for allocation of these funds. This includes:

• Requiring gambling operators to transfer funds raised through the levy to Government rather than make independent decisions around the allocations (noting that operators are welcome to make decisions around the allocation of in-kind services and funds above the mandated 8%);
• Transferring the oversight of decision-making process for the allocation of funds targeted towards prevention and recovery services be given to ACT Health, given their expertise in the provision of prevention and recovery services (60% of the allocation). We recommend that independent governance and contracting arrangements are put in place to ensure appropriate and transparent allocation of funds and the engagement of experts for activities such as specific counselling; and
• Establishing or empowering a stand-alone entity with governance arrangements, independent of Government and Industry, to be responsible for the management of the distribution process for the 40% of funds to be allocated to projects with strengthening communities, building community capital and supporting social and emotional wellbeing.

6. Ensure that the scheme and new operating arrangements are in place well in advance to the Casino operating poker machines in the Territory and being required to contribute to the scheme.

 

 

Developed by the CGRA June 2018

[1] Productivity Commission 2010, Gambling, Report no. 50, Canberra.