What is a Responsible Gambling Code of Conduct? It is a condition for all venue EGM operator licensees to have a Responsible Gambling Code of Conduct at your establishment. Your code of conduct must be in detail how you will foster responsible gambling compliance at your venue. In Victoria, the code of conduct must comply with the Ministerial Directions and be approved by the Victorian Commission for Gambling and Liquor Regulation. Of course, there are differences between the requirements for different states and territories.

The Codes cover many responsible gambling issues, but not all matters may be applicable to all licensees. In general terms, the Ministerial Directions state that a Code must include information on the following matters:


  • Responsible gambling
  • The gambling products offered
  • Customers
  • Staff
  • Problem gambling support services
  • A transparent process for recording and resolving customer complaints
  • How to comply with the prohibition of gambling by minors
  • The gambling environment – how to discourage extended gambling
  • Responsible advertising and promotions

The following persons are required to have a code of conduct that has been approved by the Victorian Commission for Gambling and Liquor Regulation:

  • a venue operator
  • a wagering operator
  • a public lottery licensee
  • a commercial raffle organiser
  • a bingo centre operator
  • a casino operator
  • the holder of an interactive gaming licence and
  • the holder of the Keno licence
  • the holder of the wagering and betting licence.
  • a registered bookmaker.


For any gaming machine licensee, a gambling compliance program document (that sits behind the Code) is necessary for your business. This document contains precise details of your gaming compliance program, including policies and staff training, and the Victorian Commission for Gambling and Liquor Regulation will utilise this to make initial and then regular assessments to see whether or not your compliance program can meet the standards.

There are certain compliance obligations for signage that gaming machine licensees must have displayed on licensed premises regarding the cash payouts, gaming rules, responsible gambling, as well as staff behaviours pertaining to responsible gambling.

If you hold a venue operator's licence and you are acquiring another approved gambling venue, you may apply to have the approved venue added to your existing licence.

LBA’s Responsible Gambling Code

At Leigh Barrett and Associates, we not only have our own approved Responsible Gambling Code (regarded by problem gambling services as a best practice) but have experts in gambling regulatory compliance who:

  • Outline compliance obligations for gaming machine licence holders
  • Assist venues in managing changes to their gambling operations
  • Conduct regular audits of venue gambling regulatory compliance
  • Provide specific customer care training for your establishment, often in conjunction with government-funded problem gambling services
  • Implement best practice, establishment specific responsible gambling policies and procedures, and
  • Conduct annual gambling compliance evaluations in accordance with State legislation

Feel free to contact us today to know more about our gambling regulatory compliance programs and how they help your businesses.



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