For those of you with Class 4 Gaming Machines you will be well aware that the Department has carried out Mystery Shopper Exercises first in 2014 (non-club venues only) and then again in 2016 (included club venues).  The goal for the Department of Internal Affairs is now to introduce a rolling mystery shopper campaign, which much like a CPO would mean on any day at any time someone in your venue could be putting you to the test.

Clubs New Zealand is currently working with the Department as they pull together the likely scenarios and criteria for the Mystery Shops.  As with the last exercises the Department is likely to remain tight lipped on where and when they are carrying out the Mystery Shops, so as always we urge clubs to take a proactive approach to harm minimisation; waiting for an audit or mystery shopper to ensure you are compliant is not an option and the DIA have not ruled out enforcement actions for venues who fail a mystery shop.

It can be incredibly difficult for staff members to intervene when a patron is showing signs of problem gambling, the staff member may not recognise the signs, are not aware that they have a responsibility for intervening to prevent harm or they do not feel comfortable intervening.  This is something that has been acknowledged many time, but the DIA will not except it as an excuse for a club failing to meet its harm minimisation requirements.

As with the announcements of the last Mystery Shopper exercise, we have put together some information on harm minimisation activities that you should be doing every day.  We also recommend that club managers jump on the Club Managers Facebook Page, talk to each other - find out what works, what doesn't work.  Discuss certain situations and how you have dealt with them in your club.

Things you can do to ensure you and your staff are meeting the requirements of the Gambling Act 2003 and The Gambling (Harm Prevention and Minimisation) Regulations 2004.

1. Hold regular staff meetings which reiterate that everyone has a shared responsibility to identify potential problem gamblers.  Mystery Shoppers will be approaching the bar staff and/or your reception staff.  They are not going to seek out your trained in harm minimisation staff member.  So the bar staff and reception staff must know how to respond to signs of harmful gambling.  

2. Ensure that one or more staff members are conducting sweeps of the gaming room. Best practice is to have a walk through of the gaming area every 15 minutes. Staff can use this time to clear glasses, greet players, chat regularly and be observant for changes in a players behaviour, staff should also be looking to ensure no minors are in the gaming area or able to play the machines.

3. Keep a log book that is accessible to staff at all times that gaming machines are operating. Staff should be encouraged to write down any concerns or observations they make which might indicate a patron is experiencing gambling harm. Staff should review the log book prior to starting a shift and it should be reviewed by all staff during the regular staff meetings. When making an entry in the log book, staff should note;

  1. The Date and Time
  2. The name of the gambler invovled
  3. A description of the sign/s that have been observed
  4. What action was taken?
  5. The name of the staff member who noticed the signs.

If the log book has noted three of more general signs in one person in close succession, that person is very likely to be experiencing harm and should be approached.

The last mystery shopper exercise highlighted that clubs are not utilising log books and are relying on informal methods.  It is time to put that log book into practice and use it!

4. Ensure that all staff members particularly those involved in the gambling operation have read and understood your clubs Harm Minimisation Policy and know where to find a copy.

5. Your club must have someone on duty at all times the gaming machines are in operation that has competed harm minimisation training and can intervene and approach a patron who is suspected as experiencing gambling harm. All staff members should know who this/these trained staff members are and trained staff members must be able to act efficiently and have access to the exclusion order forms should they require them.

6. When approaching a potential problem gambler or a problem gambler approaches a staff member you need to;

  1. Act sensitively and discreetly
  2. Provide them with a Clubs New Zealand ClubSmart brochure or Gamble Host Pack harm minimisation leaflet that provides information on the characteristics of problem gambling and the potential risks.
  3. Offer support services.  Let the patron know that they can contact Gambling Helpline which is a free 24 hour gambling helpline 0800 654 655.
  4. Provide them with information on the self-exclusion process. Where you have serious concerns about a person’s gambling it’s recommended that you firstly offer to support them with the self-exclusion process. However, if they refuse and you have ongoing concerns, you should seriously consider issuing a venue-initiated exclusion order.

Our understanding is that this Mystery Shopper Campaign will target clubs and will be looking to ensure that clubs have the required information and signage available at all times.

The Gambling (Harm Prevention and Minimisation) Regulations 2004 require you to provide information about problem gambling in particular;

  • Pamphlets providing information about the odds of winning on gaming machines,
  • Information about the characteristics of problem gambling (including the recognised signs of problem gambling) and how to seek advice for problem gambling, and
  • Signage that is clearly visible that encourages players to gamble only at levels they can afford.

By using Clubs New Zealand’s Harm Minimisation Pack in conjunction with HPAs host gamble pack your club will meet the requirements of the Act. If you are concerned that your signage, information and resources are not up to date now is the time to contact Clubs New Zealand to ensure you are prepared before a mystery shopper enters your club.

Being a Responsible Gambling Host Training

The Gambling (Harm Prevention and Minimisation) Regulations 2004 and Racing (Harm Prevention and Minimisation) Regulations 2004, require that all class 4 gambling and TAB venues have a staff member available who has had problem gambling awareness training at all times when Class 4 or TAB gambling is available.

The Being a Responsible Gambling Hosts Training Course covers responsible hosting, minimising gambling harm and assisting problem gamblers.  The course meets host responsibility requirements and includes video and printed reference material.

The course is online and self-paced.  It can be completed within an hour or spread over a longer period. 

The Being a Responsible Gambling Host training is $20.00 per person for Clubs New Zealand members when booked through Clubs New Zealand.  To book just email This email address is being protected from spambots. You need JavaScript enabled to view it. with the following;

  1. Employees First Name
  2. Employees Last Name
  3. Date of Birth
  4. Personal Email Address

By completing this training your staff will not only learn to identify the signs of problem gambling, but be able to offer assistance as required by the law.


Get in touch with the team at ClubServ if you are finding you cannot get on top of your Harm Minimisation requirements.  You obviously cannot transfer responsibility for your clubs gaming operation, but ClubServ have a raft of knowledge, experience and resources that can help you identify what needs to be put in place and how you can go about doing it.

ClubServ have a specific Harm Minimisation package for clubs and we absolutely recommend you get in touch, visit their website using the link below; 

For more information on the Being a Responsible Gambling Host training or to order a Harm Minimisation Pack please get in touch with National Office on 0800 4 CLUBS.