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19/116198
Brimbank Electronic
Gambling Policy 2019
Reducing the economic, social and health harm
associated with EGMs and other forms of electronic
gambling in Brimbank.
May 2019

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Brimbank Electronic Gambling Policy 2019
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Brimbank Electronic Gambling Policy
Contents
1. Purpose........................................................................................................3
2. Rationale......................................................................................................3
3. Scope ...........................................................................................................4
4. Principles .....................................................................................................4
5. Council roles ................................................................................................5
6. Aim and Objectives ......................................................................................6
7. Commitments...............................................................................................7
8. Implementation and review .......................................................................10
9. Appendix 1: Description of terms ...............................................................11
10. Bibliography..............................................................................................15

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1. Purpose
This policy sets out the aim, objectives, principles and commitments for how Council will seek to
reduce the social, economic and health harm associated with electronic gambling in Brimbank.
Electronic gambling in this policy primarily refers to electronic gaming machines (EGMs),
otherwise known as poker machines or “pokies”. Other forms of electronic gambling include
online and sports betting.
2. Rationale
Gambling can be described as activities where people spend money to get the chance to win
money. All types of gambling involve different levels of chance with the common principle
being that the likelihood of losing is greater than the likelihood of winning. A number of forms of
gambling are legal in Victoria, including electronic gaming machines, casino games, wagering,
online sports betting, keno, lotteries and bingo.
Electronic Gaming Machines (EGMs) were introduced in Victoria in 1992. All EGMs must meet
specifications set by the state government and gaming venue operators are regulated by the
Victorian Commission for Gambling and Liquor Regulation (VCGLR).
While it is recognised that gambling is a legal activity, there is a body of evidence that many in
our community are vulnerable to experiencing gambling-related harm. This is particularly
evident in Brimbank, where there is both a high concentration of EGMs and high levels of
socio-economic disadvantage.
Brimbank has the unenviable record of attracting the highest losses on EGMs of any local
government area in Victoria for the last decade. Since 2007, over $1.4 billion dollars was lost on
EGMs in Brimbank. In Brimbank in 2017-18, over $139,000,000 was lost on EGMs and $382,
000 was lost every day
1
.
Brimbank also contains some of the most disadvantaged communities in Melbourne. The ABS
Social Economic Index for Areas (SEIFA) ranks Brimbank as the second most disadvantaged
municipality in metropolitan Melbourne. Communities experiencing disadvantage have the
highest density of EGMs and in turn, the highest losses
2
.
As a result, EGMs and other forms of electronic gambling are having an increasingly harmful
impact on the health and wellbeing of the community. Research has found that all levels of
gambling, including low, moderate and high risk gambling, results in some harm. Indeed, 85
per cent of gambling harm in Victoria is associated with low and moderate risk gambling
3
,
contrary to the popular view that most harm is associated with high risk gambling (commonly
known as problem gambling).
Harm experienced by people who gamble and those close to them can be broadly grouped into
the following six areas
4
:
-
Detriment to the person’s health, both morbidity and mortality.
-
Emotional or psychological distress.
-
Financial difficulties, diverted financial resources, bankruptcy or reduction of financial
situation.
1
(Victorian Commission for Gambling and Liquor Regulation (VCGLR), 2019)
2
(Brown, 2019)
3
(Browne, et al., 2017)
4
(Browne, et al., 2016)

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-
Reduced performance / loss of role at employment or study.
-
Relationship conflict or breakdown.
-
Criminal activity and neglect of responsibilities, including the consequences of such
actions.
3. Scope
While the policy is concerned with electronic gambling, the primary focus is to reduce the
negative impact of EGMs in Brimbank. The rationale for this is:
-
EGMs generate the highest level of financial loss and other social and health harm when
compared to all other forms of gambling
5
.
-
Brimbank has the highest level of losses on EGMs of any local government area in
Victoria
6
.
-
The placement of EGMs in gaming venues has a distinct localised spatial element, unlike
other forms of gambling.
-
Council has a role in relation to gaming licence applications and planning permit
approvals for EGMs.
The secondary focus of this policy is on negative impact of online gambling and sports betting.
While the levels of harm from online gambling and sports betting are significantly lower than
those caused by EGMs, the level of participation in this form of gambling is growing rapidly.
Between 2001 and 2015 annual losses on sports betting grew by over 1000%
2
.
Online gambling and sports betting is of particular concern due to this rapid rate of growth and
the current lack of research into the prevalence and associated harm. The growing gamification
of gambling and the targeted expansion of online gambling into non-traditional markets such as
women and young people is of particular concern.
4. Principles
The following principles underpin Council’s approach to reducing harm associated with electronic
gambling:
4.1. Public Health
It is now widely accepted that gambling harm does not only affect people experiencing
gambling related harm, but also has significant impacts on low and moderate risk
gamblers, their family and friends, and the broader community. Recent evidence
indicates that “EGM designs very successfully employ psychological principles to maximise
users’ bet sizes and machine usage. These characteristics, such as losses disguised as
wins and programmed “near misses”, have the effect of increasing the addictive potential
of EGMs”
7
.
The public health model focuses on key risk and protective factors that impact the whole
of population. It considers how gambling impacts on, and is impacted by, the social,
economic, cultural and physical environment. This model is premised on a prevention
approach and shifting the blame from the individual to the industry and the product (see
appendix 1 for diagram outlining the partnership approach to health equity).
5
(Queensland Government Statistician's Office, 2018)
6
(Victorian Commission for Gambling and Liquor Regulation (VCGLR), 2019)
7
(Australian Gambling Research Centre , 2016)

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4.2. Harm minimisation
A harm minimisation approach recognises that, at least in the short to medium term,
people will be exposed to harmful forms of gambling. Consequently, it is important to
identify and implement initiatives that increase the safety or reduce the risks of an activity
or behaviour.
The harm minimisation approach can be categorised into the following three aspects;
Harm reduction
- strategies that aim to reduce the harm caused by gambling for both
individuals and communities. These strategies do not necessarily aim to stop gambling.
Examples include limits on ATM withdrawals from gaming venues.
Supply reduction
- strategies aimed at reducing availability and accessibility of gambling
opportunities. Examples include reducing the number of EGMs in Brimbank.
Demand reduction
- strategies aimed at preventing people from taking up harmful
gambling activity. Examples include increasing the supply of safe, accessible and
affordable non gambling recreational activities.
4.3. Social Justice
This policy is one of the mechanisms used to delivering on Council’s commitment to social
justice as defined by the
Brimbank Social Justice Charter
. The Charter pledges Council to
promote and integrate the principles of access, equity, inclusion and human rights into all
Council policies, procedures and plans.
The harm caused by gambling disproportionally impact disadvantaged communities. Lower
levels of resilience mean that vulnerable communities feel the negative impacts from
gambling sooner and more deeply. Social justice for the Brimbank community extends to
protecting those most vulnerable from the harm caused by gambling.
5. Council roles
Local government does not have the power to regulate the number, location and operation of
EGMs; nor is it responsible for the regulation of other forms of electronic gambling, being either
State or Federal government jurisdictions. However, local government has a legislated
responsibility to protect, promote and improve community health and wellbeing
8
and recognises
that “public health prevention works best when there is top down policy action coupled with
bottom up community pressure for change
9
.”
The following Council roles as identified in the
Brimbank Council Plan 2017-2021
are of
relevance to this policy.
5.1. Plan and Regulate
The location and use of EGMs requires both a gaming license and a planning permit. The
Victorian Commission for Gambling and Liquor Regulation (VCGLR) is responsible for
gaming license approvals and Council, as a referral authority, may lodge a submission as
to whether the net economic and social impact of the application will be detrimental to
the wellbeing of the community.
8
Victorian Public Health and Wellbeing Act 2008
9
Associate Professor Samantha Thomas, Deakin University 2018

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Council, as the responsible authority, has the power to grant or refuse a planning permit
for the installation or use of EGMs. Before deciding on an application, on a case-by case
basis, Council must consider any significant social and economic effects of the use or
development for which the application is made.
5.2. Partner and Advocate
Council will take a collaborative and proactive approach to meeting the aims and
objectives of this policy by partnering with key stakeholders whenever possible and
appropriate.
5.3. Lead and Represent:
Council has a responsibility to identify and act on community needs and aspirations and
recommend courses of action to State and Federal governments, statutory authorities
and other sectors.
5.4. Fund and Resource:
Council funds and resources a range of services, infrastructure, programs and initiatives
to meet a range of community needs and expectations. It also provides assets that are
managed by non-profit organisations such as sporting clubs.
6. Aim and Objectives
6.1. Aim
This policy seeks to reduce the economic, social and health harm associated with electronic
gaming machines (EGMs) and other forms of electronic gambling in Brimbank.
6.2. Objectives
i. Advocate to Federal and State Governments for a safer gambling environment and
stronger regulatory reforms to prevent and reduce harm.
ii. Minimise the impact of electronic gambling and promote alternatives that have positive
economic, social and health outcomes.
iii. Increase understanding of and take action to prevent and reduce gambling related harm.

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7. Commitments
The following commitments have been established to guide Council’s action to meet the aims and objectives of this policy.
Objective i) Advocate to Federal and State Governments
for a safer gambling environment and stronger
regulatory reforms to prevent and reduce harm
Council
Role
Intended outcome
7.1. Advocate for changes to State government legislation to
support a reduction in the total number of EGMs in the
municipality, including the introduction of a sinking cap.
Partner &
Advocate
The total number of EGMs allowable in Brimbank is
reduced over time.
7.2. Advocate for regulatory reform to increase harm reduction
measures and reduce harmful practices in the gambling
industry.
Partner &
Advocate
Stronger regulatory and enforcement measures are
adopted to reduce harm.
7.3. Make submissions to State and Federal government
inquiries that reflect Council’s policy positions.
Partner &
Advocate
The needs of the Brimbank community are considered
in State and Federal government decision making
processes.
7.4. Build and maintain relationships with key strategic
partners to inform gambling advocacy.
Lead &
Represent
Council will work with a range of partners advocating
for gambling reform locally, statewide and nationally,
including peak bodies, local government, non
government organisations, ethno-specific, health and
community service organisations.
7.5. Advocate for independent research into the prevalence and
harm caused by online gambling, in particular sports
betting and the gamification of gambling.
Partner &
Advocate
The evidence base is improved and decisions are
informed by relevant evidence.
7.6. Advocate to the Federal government for more stringent
regulation of electronic gambling and its promotion.
Partner &
Advocate
Stronger regulatory and enforcement measures are
adopted to reduce harm.

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Objective ii) Minimise the impact of electronic gambling and
promote alternatives that have positive economic, social
and health outcomes.
Council Role Intended outcome
7.7. Oppose any licensing application for new EGMs, or the transfer of
EGMs within the municipality or in neighbouring areas, where
evidence indicates the net economic and social impact of the
application will be detrimental to the wellbeing of the Brimbank
community.
Plan & Regulate The VCGLR will have regard to Council’s
submissions regarding net detriment to
community wellbeing.
7.8. Assess any planning application for new EGMs, or the transfer of
EGMs in the municipality to ensure that the area, site and
gaming venue characteristics contribute to net community
benefit.
Plan & Regulate Approvals for new or additional EGMs
provide a net community benefit as defined
in the Planning Scheme.
7.9. Prohibit the siting and operation of any new EGMs on council
owned land.
Plan & Regulate There are no new EGMs on Council land.
7.10. Renegotiation of Council leases in which State Government
approved EGMs are deployed by the existing lessee will be
subject to commercial terms and limited term leases (see
appendix for details).
Plan & Regulate To recognise gaming venues as commercial
operations, maximise community return for
existing EGMs on Council land, and retain
flexibility of lease arrangements over the
long term.
7.11. Ensure that Council events, activities or programs are conducted
in venues where no gambling-related activity is present.
Fund & Resource Council business is conducted in
environments where there is not exposure to
gambling.
7.12. Prohibit access to online gambling at all Council provided,
supported or sponsored internet access points.
Lead &
Represent
Gambling activities will not occur in Council
facilities.

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Objective iii) Increase understanding of and take action to
prevent and reduce gambling related harm.
Council
Role
Intended outcome
7.13. Participate in and support independent research to increase
knowledge and understanding of the prevalence and impact of
gambling in Brimbank.
Partner &
Advocate
Improved evidence base on local impacts and
social, economic and health effects of gambling
7.14. Monitor emerging trends and ongoing issues in relation to EGMs
and other forms of electronic gambling, in particular their impact
on CALD and vulnerable communities in Brimbank.
Lead &
Represent
Improved evidence base on local impacts and
social, economic and health effects of gambling.
7.15. Inform and educate the community on gambling harm and where
to seek support.
Lead &
Represent
Improved awareness of risks and consequences
of gambling and support available.
7.16. Build and maintain relationships with key strategic partners to
develop and implement harm reduction measures.
Lead &
Represent
Council will work positively and productively with
a range of partners including gambling industry
organisations and local gaming venues, peak
bodies, local government, non-government,
ethno-specific, health and community service
organisations.
7.17. Work with community groups and sporting clubs to reduce
reliance on funding or support received from the gambling
industry.
Fund &
Resource
Community groups and sporting clubs continue
to deliver community benefits that are not
dependent on gambling activity.
7.18. Engage with gaming venues in Brimbank to develop and/or
expand approaches to prevent and reduce gambling related
harm.
Partner &
Advocate
Council and gaming venue operators will work in
partnership to reduce harm.
7.19. Encourage, resource and promote a range of accessible social,
cultural and recreational opportunities as alternatives to
gambling.
Fund &
Resource
Non-gambling recreation, leisure and
entertainment activities are available and
accessible to community.

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8. Implementation and review
The Electronic Gambling Policy will be implemented over the next four years in partnership with
relevant internal and external stakeholders. Progress will be reported each year through an
Annual Action Plan.

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9. Appendix 1: Description of terms
9.1.
CALD (culturally and linguistically diverse)
Culturally and linguistically diverse is a broad and inclusive descriptor for communities
with diverse language, ethnic background, nationality, dress, traditions, food, societal
structures, art and religion characteristics.
This term is used broadly and often synonymously with the term ‘ethnic communities’.
CALD is the preferred term for many government and community agencies as a
contemporary descriptor for ethnic communities.
CALD people are generally defined as those people born overseas, in countries other than
those classified by the Australian Bureau of Statistics (ABS) as “main English speaking
countries”. The set of main English speaking countries other than Australia used by the
ABS comprises: Canada, the Republic of Ireland, New Zealand, South Africa, the United
Kingdom (England, Scotland, Wales, Northern Ireland) and the United States of America.
9.2.
Electronic Gaming Machines (EGMs)
EGMs (also known as poker machines or “pokies”) were introduced in Victoria in 1992. All
EGMs must meet specifications set by the state government which are regulated by the
Victorian Commission for Gambling and Liquor Regulation (VCGLR).
The number of EGMs in Victoria is limited to 30,000 with 2,628 of these located in
Melbourne's Crown Casino. The rest are located in hotels and clubs across Victoria.
EGMs are computers that use randomised mathematical programming. This means the
machine will pay out prizes at random intervals, keeping a percentage of the money put
into them.
In Victoria, the law stipulates that EGMs must pay back 87 per cent of the money spent on
it each year, after the deductions of any special jackpots. For every individual bet placed
on an EGM, the user is likely to lose 13%. Therefore, based on the law of diminishing
returns, people who gamble and use their returns to keep gambling will eventually lose all
their money.
9.3.
Gambling
Gambling can be described as activities where people spend money to get the chance to
win money. All types of gambling involve different levels of chance with the common
principle being that the likelihood of losing is greater than the likelihood of winning.
In principle gambling falls into two categories;
Pure chance - these are activities where the chance of winning cannot be influenced by
the user in any way. The probability of winning is mathematically constructed to
ensure that over time the user will always lose more than they win. Examples include:
EGMs, Keno, and casino games like roulette.
Skill and chance - these actives incorporate a component of skill with the key principle
of chance. In this category of gambling, the chance of winning can be influenced by
some knowledge or judgement. Chance is still the most significant factor and the odds
of losing are still always greater than the odds of winning. Examples include: poker,
blackjack and betting on horses, football teams or events.

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9.4.
Gambling related harm
Research has found that any gambling can result in a diverse range of negative
consequences to people who gamble, their family, friends and the broader community.
While the gambling industry generates economic activity, tax revenue and recreational
opportunities for community members, the cumulative economic, social and health cost of
gambling arguably outweigh any actual or perceived benefit.
The seven dimensions of gambling harm
Potential problems arising from gambling can occur to the individual gambler, their family
and friends, and to the broader community. A public health approach encourages us to
understand these potential negative effects in terms of their impact on the totality of an
individual’s health and wellbeing. Harm experienced by people who gamble and those
close to them can be grouped into the following seven dimensions
10
.
Financial – such as diverted spending on essential and beneficial items, debt and
bankruptcy.
Work or study – such as reduced performance, absenteeism or exclusion.
Health – such as stress, increased use of health related services, or suicidal or self
harming thoughts.
Emotional or psychological – such as feelings of worthlessness, regret or extreme
distress.
Relationships – such as relationship conflict, neglect of responsibilities or family
violence.
Cultural harm and criminal activities – such as offending to pay back debt.
9.5.
Gambling industry
For the purposes of this policy, Gambling Industry encompasses all businesses, services
and organisations that promote or offer gambling as a commercial activity.
In Brimbank in 2018, there are a total of 15 gaming venues in Brimbank that are licenced
to operate 953 EGMs (see appendix 2). These are comprised of nine hotels and six clubs.
For more information on venues and locations refer to the VCGLR.
9.6.
Gamification
The application of typical elements of game playing (e.g. point scoring, competition with
others, rules of play) to other areas of activity, typically as an online marketing technique
to encourage engagement with a product or service
11
.
9.7.
Leases
There are currently lease agreements in effect with two clubs that are approved to operate
EGMs on Council land. These are St Albans Sports Club and Green Gully Soccer Club.
The lease agreement refers to the occupancy of a specified Council facility for a set period
of time that grants exclusive use.
The renegotiation of lease agreements, including the tenure, terms and conditions, are
based on past history, the core business of the lessee and any relevant Council policies
and plans that impact on the facility. As such exact conditions are to be determined on a
case by case basis.
Market rent is defined as “the estimated amount for which an interest in real property
should be leased on the valuation date between a willing lessor and a willing lessee on
10
(Browne, et al., The Social Cost of Gamling to Victoria , 2017)
11
(Oxford Living Dictionary , 2018)
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appropriate lease terms in an arm’s length transaction, after proper marketing and where
the parties had each acted knowledgeably, prudently and without compulsion”
12
.
Commercial terms refer to the commencing market rent payable for the leasehold of
occupied land, determined by an independent commercial valuation conducted in advance
of the commencement of a new lease.
Lessees are eligible for a discount up to a maximum of 80% on the market rent should
they meet Council’s community and sports development objectives, and pursue additional
gambling harm minimisation initiatives in excess of statutory community benefit
obligations.
9.8.
Online gambling
Online gambling comprises of a wide range of different forms of gambling that can be
provided in an online format i.e. accessed and played via the internet. This can include
forms of poker, casinos (blackjack, roulette etc.), sports betting, bingo, lotteries, horse
racing betting.
9.9.
Public health
To achieve health equity, the public health model is premised on a partnership approach
that works to align public policy and community action, as described in the following
figure.
Figure 1: The nutcracker effect (Baum, 2007)
12
(Australian Property Institute , 2019)

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9.10.
Socio-Economic Index For Areas (SEIFA)
SEIFA is a product developed by the Australian Bureau of Statistics that ranks areas in
Australia according to relative socio-economic advantage and disadvantage. The index
summarises different information collected from the Census of Population and Housing
that indicates socio economic status such as such as: income, internet connection,
occupation, and education and housing costs. The index is standardised with an average
of 1000, meaning areas with an index below 1000 are more disadvantaged while those
with an index above 1000 are more advantaged than average.
9.11.
Sports Betting
Sports betting involve gambling on traditional sports such as football and cricket along
with less traditional contests like the outcome of elections or the results of reality TV
shows.
Bets can be placed on the result of a game and what happens during the game. For
example, who will score the first goal or who will be ahead at half time.
Despite its rapid growth and high profile, sports betting accounts for a relatively small
proportion of total gambling losses in Victoria.

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10. Bibliography
Alliance for Gambling Reform. (2019).
March 2019 News
. Retrieved March 2019, from
http://www.pokiesplayyou.org.au/gamblingnews_22032019
Australian Gambling Research Centre . (2016).
How electronic gambling machines work:
structural characteristics
. Retrieved March 2019, from
https://aifs.gov.au/agrc/publications/how-electronic-gambling-machines-work/export
Australian Property Institute . (2019). Retrieved May 15, 2019, from Definitions :
https://www.api.org.au/definitions
Baum, F. (2007).
Cracking the nut of health equity: top down and bottom up pressure for action
on the social determinants of health.
Promotion & Education .
Brown, H. (2019).
A Review of Gambling Related Issues.
City of Greater Dandenong.
Browne, M., Greer, N., Armstrong , T., Doran, C., Kinchin, I., Langham, E., et al. (2017).
The
Social Cost of Gambling to Victoria .
Melbourne: Victorian Responsible Gambling
Foundation.
Browne, M., Greer, N., Armstrong , T., Doran, C., Kinchin, I., Langham, E., et al. (2017).
The
Social Cost of Gamling to Victoria .
Melbourne: Victorian Responsible Gambling
Foundation .
Browne, M., Langham, E., Rawat, V., Greer, N., Li, E., Rose, J., et al. (16).
Assessing Gambling
Related Harm in Victoria: A Public Health Perspective.
Melbourne: Victorian Responsible
Gambling Foundation.
Oxford Living Dictionary . (2018).
Definition of gamification in English
. Retrieved March 2019,
from https://en.oxforddictionaries.com/definition/gamification
Queensland Government Statistician's Office. (2018).
Australian Gambling Statistics 1991-2 to
2016-17 34th Edition.
Queensland Government Statistician's Office.
Victorian Commission for Gambling and Liquor Regulation (VCGLR). (2019).
Gaming
expenditure by local area
. Retrieved November 2019, from
https://www.vcglr.vic.gov.au/resources/data-and-research/gambling-data/gaming
expenditure-local-area
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History of amendment
Rev
Review date
Reason for amendment
Next review date
A 28/06/2011
Review
28/06/2014
B 9/12/2014
Review
9/12/2019
C 21/05/2019
Review
21/05/2023
Approved by council:
Yes
Date approved by council: 21 May 2019

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