SAFER
GAMBLING
­CODE OF CONDUCT

 

Tabcorp VIC Pty Ltd Version 3 – 16 August 2024   OUR COMMITMENT TO SAFER GAMBLING


Tabcorp VIC Pty Ltd (“we/us”) is committed to delivering wagering products and services in a way that prevents and minimises harm to our customers and their families and friends.

We seek to normalise safer gambling through the design of our products and services, the use of our safer gambling tools by our customers and the behaviour of our employees and agents.

We aim to empower and support our customers to make informed decisions about how they gamble.

Our employees and TAB Venue staff will have the support, skills and knowledge they need to implement these commitments.

We will work with gambling harm prevention experts and services to enhance our harm prevention measures and performance.

We will respond to complaints by our customers in a fair and efficient manner.

This Safer Gambling Code of Conduct (“Code”) sets out these commitments in more detail.

 

Our Player Safety Promise

Caring for our customers is at the heart of what we do.

That means acknowledging that while our wagering products and services are enjoyed by most of our customers as a form of entertainment, they can also negatively impact or harm our customers, the people that care for them and the community.

So, we’re raising the game and committing to a Player Safety Promise designed to prevent and minimise gambling-related harm and drive better outcomes for individuals and the community.

We promise to:

Be Transparent and Raise Awareness
Prevent and Minimise Harm
Monitor and Provide a Safety Net
Continue to Learn and Build on Evidence
Contribute and Support the Community

 1. INTRODUCTION

  We are part of Tabcorp Holdings Limited, a world-class diversified gambling entertainment group.
We conduct wagering:

• online;
• over the phone;
• on course at metropolitan and country race meetings in Victoria; and
• at a network of agencies, licensed venues and clubs.

We acknowledge that gambling causes some people harm and this Code sets out how we will deliver our products and services safely and in a way that minimises the harm associated with gambling.

1.1 OBJECTIVES

  Our aim with the Code is to:

• provide our customers with a single document that outlines how we safely deliver our products and services;
• demonstrate our strong commitment to minimising the potential harm associated with gambling and promote safer gambling;
• empower and enable our customers to make informed decisions about gambling, as well as facilitating access to tools to manage their gambling or gambling help services where assistance is required; and
• ensure we comply with any relevant legislative and regulatory obligations, including the Victorian Responsible Gambling Code of Conduct Ministerial Direction.

1.2 APPLICATION OF THE CODE

 The Code applies to:

• us and our employees;
• our TAB Venues and all people employed by these venues that are responsible for providing our wagering services; and
• gambling services or products provided by us, including those provided online within Australia.

1.3 REVIEW OF THE CODE

We regularly review our compliance with the Code (including compliance within our TAB Venues). We will seek and consider feedback from key stakeholders, including TAB Venue staff, agents, customers, employees, and gambling help service providers about the effectiveness of the Code.

The Code may also be updated from time to time taking into account the feedback we receive and advances in research relating to gambling harm and the responsible service of gambling.
We will provide a copy of the updated Code to the Victorian gambling regulator before publishing.  

1.4 KEY DEFINITIONS

• TAB App means the TAB mobile application. 
• TAB Venue under the Code is an agency, licensed venue or racing club in Victoria where our services and products are sold.  
• TAB Website means the TAB website at www.tab.com.au.

 

2. COMMUNICATION AND AVAILABLITY OF THE CODE

We communicate and actively promote the Code and where to find it on signage across our TAB Venues and on our TAB Website and TAB App.
The Code is available at:   

• the TAB Website www.tab.com.au;
• the TAB Safer Gambling Website www.responsiblegambling.tab.com.au;
• Tabcorp’s Website www.tabcorp.com.au;
• the TAB App; and
• TAB Venues.

The Code is available in English and is also translated into Italian, Arabic, Chinese (Traditional and Simplified), Turkish, Greek, Vietnamese and Spanish. Translated versions of the Code are available online and in TAB Venues.

You can ask for a printed copy of the Code by phoning our Customer Service Centre on 131 802 or at a TAB Venue.
 

3. RETAIL COMPLIANCE WITH THE CODE

  TAB Venues and their staff who provide wagering services must comply with the requirements set out in this Code.
In order to ensure TAB Venue compliance, we will:

• provide TAB Venues with the support, tools, information and training necessary to implement the Code and to ensure the safer delivery of our wagering products and services;
• conduct regular compliance checks and as soon as possible after a safer gambling incident or where there has been non-compliance with the Code or other legal obligation;
• investigate all safer gambling incidents, and breaches of the Code, or other legal obligations, by TAB Venues; and
• take action against non-compliant TAB Venues. Actions that may be taken include a requirement to undertake additional training, disciplinary action (a financial penalty or suspension) and, in the most serious cases, termination of the TAB Venue agreement. 

 

4. SAFER GAMBLING MESSAGES

We include safer gambling messages on all gambling-related promotional marketing materials, and on communications we send to our customers in line with the National Consumer Protection Framework for Online Wagering.

We also ensure that our advertising materials comply with any other legal requirements, including the consumer protection requirements of Ministerial Directions such as the Ministerial Direction dated 24 March 2023.

We will always have safer gambling messaging on the TAB Website and signage throughout the TAB Venues. We will also actively promote safer gambling messages on our TAB Website and TAB App.

5. SAFER GAMBLING AND GAMBLING PRODUCT INFORMATION  

5.1 AVAILABLE INFORMATION

We provide a range of safer gambling information so our customers, their families, and the community are informed about our safer gambling practices and so our customers are aware of our wagering products and services.

Our commitment to the safer provision of wagering means that we want to empower customers to make informed decisions about their gambling. This includes how much they spend and how much time they devote to gambling, taking into account their personal circumstances and financial means.

This includes information about:

• this Code;
• the betting rules that govern our totalisator, sports betting, and Trackside products;
• our products and services and accompanying explanatory material;
• how customers can manage their gambling by making and keeping a pre-commitment decision;
• how customers can utilise other safer gambling tools to manage their gambling;
• how customers can self-exclude online and in our TAB Venues;
• gambling support services available for individuals and/or their families to obtain assistance to manage a gambling problem;
• the prohibition of gambling by minors; 
• the prohibition of the provision of credit for gambling; and
• complaint resolution mechanisms.

5.2 WHERE YOU CAN FIND THE INFORMATION

We have safer gambling information publicly available on our dedicated TAB Safer Gambling Website at responsiblegambling.tab.com.au, on posters and brochures throughout TAB Venues or by calling the our Customer Service Centre on 131 802.

TAB Venues must display safer gambling signage at all points where bets are accepted.

Our betting rules and product information is available on the TAB Website and throughout TAB Venues. You can read our account terms, which include terms and conditions of promotional offers, on the TAB Website.

When we have specific promotional offers, we will include the applicable terms and conditions.  

You can also call our Customer Service Centre on 131 802 for assistance.
 

6. PRE-COMMITMENT DECISIONS

6.1 WHAT IS PRE-COMMITMENT?

Pre-commitment is a tool that customers can use to manage their gambling and prevent gambling harm. It involves customers setting a limit before they start gambling. This limit can be time and/or money based i.e. ‘pre-committing’ how much time and money you are prepared to spend before you start gambling.

Pre-commitment decisions are individual to each customer and customers should set limits in accordance with their personal circumstances.  

6.2 RETAIL CUSTOMERS

We promote and encourage all retail customers to set a time and money limit by displaying signage about how to set and keep limits in our TAB Venues.
Information is also available on the TAB Safer Gambling Website: responsiblegambling.tab.com.au.

How to make a pre-commitment decision

You can make a pre-commitment decision when betting in retail by:

• making a plan for your gambling – how much will you bet and deposit, and how long will you be in the TAB Venue;
• setting a budget for your gambling spending;
• deciding what you want to bet on – for example, if you will only be betting on horse racing;
• planning ahead about how you will be placing bets. If you will only be betting in cash, then only take the cash amount you plan to bet with and leave any bank cards at home;
• going to TAB Venues that have other activities that you can engage in; or
• plan for how to put aside funds when collecting any dividends.

Some strategies you can use to record your pre-commitment decision include:

• making a note in your phone on what your pre-commitment decision is;
• telling the person you are with that you have made a pre-commitment decision and sharing those details with that person;
• if you have set a time limit to be in the TAB Venue, setting an alarm on your phone so you are alerted to when you have been in the TAB Venue for that period of time;
• making a note of the time that you arrived at the TAB Venue and keeping track of time; and
• telling a TAB Venue staff member that you have set a pre-commitment decision.   

If you have a TAB account, you can set up pre-commitment deposit limit on your TAB account and transact using your account while you are in a TAB Venue. You will not be able to deposit in excess of the pre-commitment deposit limit that you have set on your account.  


How to keep a pre-commitment decision

You can keep a pre-commitment decision when betting in retail by:

• keeping track of how much you have bet including using bet slips;
• use the time displayed in the TAB Venue to keep track of the passage of time;
• if you have set an alarm on your phone, leaving the TAB Venue or TAB service area when this alarm sounds;
• letting a TAB staff member know you have reached your pre-commitment decision limit and they will refuse to place any more of your bets and encourage you to leave the TAB Venue or TAB service area; and
• leaving the TAB Venue or TAB service area when you are about to or have reached your pre-commitment decision limit.

If you have a TAB account and have set up a pre-commitment limit, you can bet in a TAB Venue using your TAB Account and the deposit limit will be apply in line with your pre-commitment decision. 


How we support your pre-commitment decision

TAB Venues and their staff are trained to support you to make and keep your pre-commitment decisions. We will have proactive conversations with you about how to make and keep your pre-commitment decision. They will also have these discussions with any family members or friends who are concerned about your betting behaviour.  
We train TAB Venues and their staff to recognise potential signs that you could be overspending or losing control, and that may need to make or keep a pre-commitment decision. The potential signs we look for include:

• gambling every day or finding it hard to stop at closing time;
• gambling for long periods i.e. for three hours or more without a break;
• gambling right through normal meal times;
• avoiding contact while gambling, communicating very little and barely reacting to events going on around them;
• increasing spending;
• trying to borrow money from TAB Venue staff or other customers;
• continuing to gamble with the proceeds of large wins; and
• displaying signs of distress or anger.

When TAB Venue staff identify customers with these behaviours, they must assess the customer’s circumstances by speaking directly with the customer. To support these customers, TAB Venue staff will take a range of actions:

1. ask the customer if they have set any pre-commitment limits;
2. provide the customer with information about pre-commitment limits and how to set one;
3. encourage the customer to set a time and money limit;
4. encourage the customer to take a break from gambling by leaving the TAB service area and participating in other venue activities or taking a refreshment or lunch break; 
5. encourage the customer to take a break from gambling by leaving the venue;
6. provide information about TABCare (our retail self-exclusion program in Victoria);
7. provide information on available gambling support services and facilitating access to a service where required.

Where a customer has made a pre-commitment decision by setting a time and money limit, TAB Venue staff will support the customer to keep their pre-commitment by:

1. encouraging them to keep to their pre-commitment decision;
2. providing the customer with strategies to keep to their pre-commitment decision; and
3. refusing service when a customer tells the TAB Venue staff member that they have exceeded the time and money limits that they have set.

If you already have a TAB account, TAB Venue staff will encourage you to use the available tools on your TAB account to set and keep your pre-commitment decisions.

6.3 ACCOUNT CUSTOMERS

We promote and encourage all account customers to set a pre-commitment deposit limit. A pre-commitment deposit limit allows you to limit the maximum amount they can deposit into their account over a set time period. We offer you a choice of time periods. For example, this could be a daily, weekly, or monthly limit.

You can set or change your pre-commitment decisions by logging onto your TAB account either on the TAB App or on the TAB Website. Our TAB Customer Service Centre is available on 131 802 to help you in making a pre-commitment decision.

We will assist you to make a pre-commitment decision by:

• requiring all account customers to set a deposit limit or specifically opt out of setting a deposit limit when opening an account with us;
• actively promoting setting a deposit limit on our TAB Website and TAB App as well as in emails to you;
• offering you the ability to set up a deposit limit at any time by logging into your TAB account online;
• advising you to set a deposit limit in line with your personal circumstances and what you can afford to bet with - our Customer Service Centre and Safer Gambling teams are available to assist you in setting a deposit limit;
• when reviewing accounts belonging to customers identified as potentially experiencing gambling harm, our TAB Safer Gambling team will review your previous deposit activity, betting history and whether you have set a deposit limit or used other safer gambling tools to determine if further action is required. This may include a call to discuss your specific behaviour and circumstances and provide advice on setting a deposit limit;
• when speaking with customers experiencing gambling harm, our TAB Safer Gambling team will encourage you to set a limit, provide advice on an appropriate limit to set and will set the limit for you if you agree;
• our TAB Safer Gambling team undertakes monitoring over increases to customer deposit limits to identify whether any increases require a call with the customer; and
• providing you with a prompt annually when you log into your TAB account to set a deposit limit or update your deposit limit if you’ve already set one. You will not be able to access other features on your account until you have responded to this prompt.

If you have made a pre-commitment decision, we will help you keep to your pre-commitment decision by doing the following:

• We will prevent you from depositing into your TAB account when you reach your deposit limit.
• We allow you to change your deposit limit at any time by logging into your TAB account online. Any decrease to the limit is effective immediately. Any increase will only take effect after 7 days. This provides you with time to change your mind – we call it a ‘cooling off’ period.
• We will remind you annually to review your deposit limit.

You can find additional information on what a pre-commitment deposit limit is, the benefits of setting a limit, and how to set one, on the TAB Safer Gambling Website at responsiblegambling.tab.com.au and by logging onto your TAB account.
 

7. SAFER GAMBLING TOOLS

In addition to pre-commitment deposit limits, there are other safer gambling tools that empower and support you to manage your gambling, and to gamble safely. We actively promote the following tools on our TAB Website, TAB App and through our Customer Service Centre.
 

SAFER GAMBLING TOOL	DESCRIPTION
TAKE A BREAK	You can take a break from your account for a certain time period. You have a choice of different time periods. During this time, you will not be able to access your account or receive any marketing or promotional material.
CREDIT/DEBIT CARD LIMITS	You can limit the daily amount you can deposit into your account via credit and/or debit card.
ACTIVITY AND BETTING STATEMENTS	We provide all TAB account customers with a monthly activity statement for months where they have had account transactions. The activity statement will set out your total deposits, withdrawals, spend, wins, and losses for the month, as well as your net win or loss for the month, as well as your net win or loss for the month, etc.
UNSUBSCRIBE FROM MARKETING	You can opt out of receiving marketing and promotional emails and messages.
ONLINE ACCOUNT CLOSURE	You can easily close your account online via the TAB Website, TAB App or by calling the TAB Customer Service Centre on 131 802. Once the request is processed, we will close your account and remaining funds are returned to you (once pending bets have been finalised).

 

8. SELF-EXCLUSION PROGRAMS

We are also committed to ensuring our online customers are aware of the passage of time. To help them do this we have the following in place:

• The TAB Website and TAB App contain information on upcoming scheduled racing and sports events. You can use this information to ensure you are aware of the passage of time.
• We actively monitor betting behaviours using a number of systems and tools to identify customers engaging in extended and intensive gambling. For example, if you are betting for extended periods of time.

If you’re identified as displaying signs of engaging in extended and intensive gambling (the full list of indicators is set out in section 9.2), our Safer Gambling Team will intervene and take action which may include, but is not limited to:

1. sending you an email and/or SMS with information about our safer gambling tools including self-exclusion;
2. providing you with information about available gambling support services;
3. reviewing your accounts to determine whether additional interventions are required - this includes reviewing previous interactions, betting activity, deposit activity, withdrawal activity and whether the customer has previously utilised safer gambling tools;
4. calling you;  
5. proactively freezing your accounts; and
6. proactively closing your accounts.

When we freeze or close your account due to advice from the Safer Gambling team, you will stop receiving marketing material. If we close your account for a safer gambling reason, we will put blocks in place to prevent you from opening future accounts with us using the same details. We also check for where accounts are opened using similar details as customers who have had their accounts closed. We will not allow you to use our wagering products and services if we become aware that you are intoxicated or under the influence of drugs. All customer-facing employees, including those in TAB Venues, have been trained to identify signs of intoxication or where someone is under the influence of drugs and refuse service, including proactively freezing your TAB account. You must pay for bets when purchased. We do not provide credit or lend money for gambling.

We do not accept customer cheques as payment or allow you to cash cheques. You will be informed about this restriction if you present a cheque.

All winnings are paid (at the discretion of the TAB Venue) either in cash, by cheque, betting voucher, or by crediting the winnings to a TAB account or EFTPOS debit card in accordance with applicable regulations, industry codes or policies and our betting rules. The betting rules are available on the TAB Website and throughout TAB Venues.

We will use best reasonable endeavours to make payments for winning bets placed with us through your account to your betting account as soon as the official result is confirmed.

17. SAFER ADVERTISING AND PROMOTIONS

  We ensure advertising and promotions permitted under the Gambling Regulation Act 2003 (VIC) related to gambling will:

• comply with all applicable Commonwealth and State laws, regulations and codes relating to the advertising or promotion of wagering products, including the advertising code of ethics adopted by the Australian Association of National Advertisers;
• not be false, misleading or deceptive about odds, prizes or the chances of winning, and not misrepresent the probability of winning or financial gain;
• not make claims related to winning or prizes that can be won that are not based on fact, are unable to be proven or are exaggerated;
• not state or imply that a player’s skill can influence the outcome of a gambling activity, where it cannot be factually substantiated;
• be correct, accurate and truthful;
• require the consent of any person identified as winning a prize prior to publishing their name;
• be in good taste (given prevailing community standards) and not be offensive or indecent in nature;
• be socially responsible;
• not create an impression that gambling is a reasonable strategy for financial betterment;
• not promote gambling as a means of funding routine household purchases, cost of living, nor relieving financial or personal difficulties;
• not promote the consumption of alcohol while gambling and does not associate gambling with alcohol;
• not be intentionally directed, expressly or indirectly, to vulnerable or disadvantaged groups and minors;
• not be aimed at or designed to appeal to minors and does not appear in conjunction with an offer, event or venue advertisement that pertains to minors;
• not offer any rewards, inducement or vouchers that encourage customers to bet more frequently;
• not promote gambling as a means of enhancing social standing or employment, social or sexual prospects; and
• not exaggerate the connection between the gambling activity and the use to which the gambler’s profits may be put. 

17.2 HOW WE COMPLY WITH ADVERTISING REQUIREMENTS

To ensure that our advertising, marketing and promotions comply with the relevant requirements and do not encourage customers to gamble excessively or beyond their means:

• We make sure that all advertising and marketing includes safer gambling messages in accordance with relevant legislation.
• When we send you direct marketing, we include information on how you can opt out of receiving direct marketing.
• We document the safer advertising and promotions obligations in our internal Marketing Guidelines, which are provided to all team members involved in marketing and advertising.
• We train all marketing team members at the start of their employment on their safer advertising and promotions obligations and conduct mandatory annual refresher training.
• We place all self-excluded customers and customers using the Take a Break function on a list to make sure they do not receive any marketing and advertising.
• We have processes in place to review our advertising and marketing material before it is seen by the general public. This includes the review of advertising and marketing by a Senior Marketing Manager, along with our Legal and Safer Gambling team, where relevant.
• Our Marketing team undertakes monthly quality assurance to ensure that our marketing processes are adhered to by marketing team members.  
• The effectiveness of marketing controls is assessed annually by our Risk team.

We will not release new products or change our existing products without assessing their potential impact on customers vulnerable to gambling harm. Our Safer Gambling team performs an assessment over all new products or services to ensure that they do not:

• appeal to minors;
• expose minors to gambling;
• encourage customers to bet more frequently than usual;
• encourage customers to bet for longer periods of time than usual;
• encourage customers to bet more than they normally would;
• encourage customers to bet beyond their means;
• increase the chance of impulsive decision making; and
• normalise gambling.

The outcome of the assessment determines if and how the product or service is released.

  From time to time, we will send and communicate to our customers marketing offers and promotions. These may include bonus bet offers, deposit match offers, competitions and invitations to attend experiences like race days. We will not send offers to customers that are self-excluded or using the Take a Break function. These offers and promotions are made as a way to attract and retain customers, promote certain sporting and racing events, promote a new product or promote a certain product e.g. pari-mutuel betting.

Some offers and promotions will be made available to all customers, whilst other offers and promotions will be personalised to customers. Customers are selected for personalised offers and promotions based on a number of different factors including their previous betting history, their betting preferences and their betting location. Offers and promotions may expire if they are not used within the set timeframes.

To ensure customers clearly understand the offers and promotions are available to them:

• we clearly communicate any offers or promotions available to customers via email, SMS or verbally;
• we provide customers with information on any terms and conditions associated with the offer or promotion. For example, if there are any time periods that apply, if there are any eligibility requirements, if there are any conditions of entry for a competition, how to enter etc;
• customers can access information about available offers and promotions, including their available bonus bets at any time by logging into their TAB account online;
• customers can access the terms and conditions that apply to our promotions on the TAB Website and App; and
• customers can contact our Customer Service Centre on 131 802 if they have any queries about our offers and promotions.

You can opt-out of receiving direct marketing from us at any time.

We do not offer a system that tracks a person’s expenditure on a gambling product and rewards that expenditure with bonus, loyalty or reward points. We previously offered a TAB Rewards program that involved an accruing points system. This program is currently not operational, and we do not offer a structured customer loyalty program.   You can make a complaint to us either online, by contacting the Customer Service Centre on 131 802 or by post. We have detailed the process for customer complaints on the TAB Website. https://help.tab.com.au/s/article/Submitting-a-Complaint

Complaints about wagering matters can also be directed to the Victorian gambling regulator as an independent body for investigation and resolution via their website https://www.vgccc.vic.gov.au/i-want/complaints.

• post: GPO 4168 SYDNEY NSW 2001
• phone: 02 9218 1111 – If you call with a complaint, we may ask you for details of the complaint in writing.

We have a formal complaint management policy and process in place to ensure that customer complaints are reviewed and addressed appropriately.
When we receive a complaint from you, our Safer Gambling Team will:

1. Acknowledge written or email complaints in writing or by email within 5 working days of receiving the complaint.
2. Review and investigate the complaint. This includes reviewing the information provided, as well as other relevant information such as your betting history or your previous interactions with us.  
3. Advise you of the review outcome within 21 days. If we are unable to finalise the review within 21 days, we will let you know of the new timeframe.  
4. Provide you with the outcome of the complaint. Where relevant the outcome of the complaint is determined by the Complex Complaints Committee which includes senior representatives from across our business.

If the matter is resolved, no further action is taken.

You can request an internal review of the decision by sending a request in writing to complaintappeals@tabcorp.com.au. A Complaints Appeals Committee will then review the decision to make a final determination. This final determination will be provided to you within 10 working days.

If you request an independent review of this decision, we will refer the matter to a member of a panel of independent mediators, such as the Institute of Arbitrators and Mediators Australia, for either a determination from an arbitrator based on submitted paperwork or to arrange mediation.

Costs of this process will be shared equally by us and you, unless otherwise agreed or as determined by the arbitrator.
  We keep records of complaints, all complaints documentation and decisions in our Safer Gambling Complaints Register, held for a period of seven years. These are made available for inspection by the Minister for Consumer Affairs, Gaming and Liquor Regulation or the Victorian gambling regulator on request in accordance with our record keeping obligations and to allow the Victorian gambling regulator to monitor our compliance with the complaints process.
  We are committed to privacy, transparency and information security. To honour this commitment, we handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. Our Privacy Policy sets out how we handle personal information. You can access a copy of our Privacy Policy at https://www.tabcorp.com.au/privacy. You may also contact
privacy@tabcorp.com.au with any queries or concerns.