International responsible gaming strategies, new technology to help identify excluded clientele and implementation of the American Gaming Association (AGA) Code of Conduct for Responsible Gaming were among topics discussed during the fourth annual conference program at Global Gaming Expo (G2E) in October.
International Panel Discusses the Dynamic of Responsibility and Emerging Technology
The conference session "Avoiding the Backlash: Protecting the Public Good…and the Bottom Line," moderated by Lyle Hall, president of Hall Hospitality Advisors, offered guidance on how to be pro-active in implementing effective responsible gaming programs.
Dale Fuga, chief operating officer of the Manitoba Gaming Control Commission (MGCC), shared his perspective on the unique gaming climate in Canada where casinos are both regulated and operated by the government. Such a system, said Fuga, "requires greater responsibility…to ensure that members of the public who gamble do so with informed choice." The MGCC views itself as an agency balancing the mandates of the Manitoba Lotteries Corporation and the Addictions Foundation of Manitoba. In fact, recent amendments to the Gaming Control Act in Manitoba have formalized that relationship by mandating that the MGCC ensure gaming operators adopt a responsible gaming policy that includes employee training programs, consumer information, public education and voluntary exclusion programs. "As a regulator, it is our view that gambling is a personal choice; it is our responsibility to ensure that activity has honesty and integrity, that it takes place in the public interest and that players make an informed choice," Fuga said. The MGCC continually evaluates its responsible gaming services and initiatives and is currently appraising the effectiveness of responsible gaming messages on new VLTs in its jurisdiction.
Shared responsibility continued to be a key message in this panel discussion, as Howard Dreitzer described the Queensland Responsible Code of Practice in Australia. The Queensland code aims to balance social and economic benefits with the costs of gambling. It is designed to be a resource for the gaming industry, to provide a safe environment for clientele, to minimize adverse effects from gambling behavior and to encourage shared responsibility. "A key concept here is the shared responsibility of operators, government and players themselves," Dreitzer said. "We cannot force people to be responsible; we can only encourage them."
The six-pronged Code of Practice in Queensland is a voluntary policy, but the government has made it clear that it will become mandatory if it is not universally followed or effective. A report on the implementation of this code was released in February, 21 months after its launch. The program assessment was successful enough that the report recommended continuation of self-regulation by the operators.
Blake Cumbers, vice president of development for Boyd Gaming Corporation, discussed various elements of the AGA Code of Conduct, including its pledges to employees, patrons and the public. Cumbers' main focus, however, was on the exclusion pledge to patrons. If the objective is to identify and exclude compulsive gamblers from gaming enterprises, he believes the best strategy will be to use the biometric identity of those gamblers to control their access to gaming machines and tables. Biometrics is an emerging technology that allows passive identification of physical attributes through infrared recognition of heat patterns emitted by facial blood vessels, iris recognition and facial recognition. Cumbers argued that the use of this technology would be a logical extension of the existing casino technology infrastructure - gaming machines and player tracking systems are already on high-capacity networks, more than 160 casino surveillance systems currently use biometric identification and central databases of excluded players already exist. "As legislators call for greater protection for compulsive gamblers, and gaming regulators begin issuing fines for failure to exclude these players, the gaming industry should be compelled to use the most effective tools available to control them," Cumbers said.
Members Share Experience of Implementing the AGA Code of Conduct
American Gaming Association Chairman Phil Satre, also chairman of Harrah's Entertainment, led Bill Bingham, vice president of table games for Bellagio; Mark Clayton, vice president of corporate law for Caesars Entertainment; Blake Cumbers, vice president of development for Boyd Gaming Corporation; and Virginia McDowell, senior vice president of operations for Argosy Gaming Company, in a panel discussion of the issues and challenges faced during implementation of the AGA Code of Conduct for Responsible Gaming.
"The gaming industry must recognize that there are those who cannot gamble responsibly," said Satre. "Hand and glove with that recognition comes the obligation to do our part in dealing with the issue. Because the AGA Code of Conduct pledges to make responsible gaming an integral part of its member companies' daily operations, the code is much more than words - it requires action.
"Each company took a different approach to launching its Code of Conduct efforts. MGM MIRAGE sent a personal letter to every employee from Chairman and CEO Terry Lanni stating its commitment to the code and plan for implementation. A similar letter from each property president followed. To show its commitment to the code and responsible gaming, Caesars chose to form a corporate-level committee chaired by company President and CEO Wally Barr. Boyd Gaming Corporation also formed a corporate-level committee, which was charged with performing a property-by-property audit of the code's content.
"Because we already had many of these elements in place, much of the code's implementation was seamless [at MGM MIRAGE]," Bingham said. McDowell concurred, noting that Argosy "had more aggressive programs in place in [its] more conservative markets." She believes the most challenging aspect could have been the pledge to make a gaming probabilities guide available, but "the AGA helped tremendously with that by producing and making that available to its members."
The executives agreed that many of the implementation challenges surrounded the exclusion pledge to patrons. In particular, challenges such as those related to computers and marketing systems "have to be done with forethought and take time," Cumbers said. Similarly, as casino operators continue to grow, and for companies like Harrah's, which operates in 14 different states, self-exclusion becomes increasingly challenging because laws vary dramatically across those jurisdictions. "Solutions concerning a self-excluded customer in multiple-jurisdiction play are very complicated," said Satre. "If they aren't using a players club card, it's difficult to track."
Other complications noted involve the pledge to advertise responsibly, specifically the provision promising that advertising and marketing materials will not be placed in media or in venues where most of the audience is normally expected to be below the legal age to participate in gambling activities. Many AGA members have relationships with universities and charitable organizations devoted to youth that could be compromised by that pledge if misinterpreted. However, as Clayton pointed out, "We're not involved with [those] organizations because we're marketing to youth; we're trying to be good corporate citizens."
The AGA Code of Conduct also states that members will conduct annual reviews of compliance. To answer that, Caesars will treat the code as it does any other regulatory requirement. "It is part of the internal audit department's regular audit of compliance," Clayton said."Because of the potentially damaging social impacts … it is an integral part of the entire company done at least once a year." Most companies also have responsible gaming committees that perform compliance checks throughout the year.
Looking ahead, Satre offered his thoughts on the future life of this code: "To me the biggest opportunity is for a uniform code to be adopted by states so that the gaming companies have some rational basis for looking at these problems across multiple jurisdictions. I understand that individual states have their own approach and consider themselves to be autonomous on these particular issues, and I'm not suggesting they give up autonomy. I'm suggesting they look at a more rational approach to this issue."