14 Staff Training
Staff training provides employees with a level of expertise to enable them to perform their duties confidently and efficiently and is essential to protect the operating, personal and premises licences that are required to operate a licensed bingo operation. These licences depend on understanding and upholding the Licensing Objectives set out in the Gambling Act 2005 and the Licensing Conditions and Codes of Practice (LCCP) issued by the Gambling Commission. The LCCP has 28 Code provisions (13 Social Responsibility Codes and 15 Ordinary Codes). Staff do not need to know them all, but the key areas that they need to be instructed on are detailed in this section. Particular attention should be given to the LCCP and other subjects as detailed below.
a) The Licensing Objectives
b) The Gambling Commission
c) The right of access to premises
d) Age verification policies and procedures
e) Problem gambling recognition, interaction and self-exclusion procedures
f) The complaint and dispute process
g) Anti-Money Laundering
h) Money lending between customers
i) Employment of children and young people
j) Free alcoholic drinks
k) The completion of logs and records for the relevant sections above and their training log.
14.2 The Licensing Objectives
The Licensing Objectives are the key to introducing the Gambling Act and its concepts to staff through training, as these are the foundations on which gambling legislation and regulation are built.
The Licensing Objectives are:
- Preventing gambling from being a source of crime or disorder, being associated with crime or disorder or being used to support crime
- Ensuring that gambling is conducted in a fair and open way
- Protecting children and other vulnerable persons from being harmed or exploited by gambling.
14.3 The Gambling Commission
Staff should understand what the powers of the Gambling Commission are and how the Commission enforces the Licensing Objectives through the Licensing Conditions and Codes of Practice.
14.4 The Right of Access to the Premises
The Act creates powers of entry and inspection for the Gambling Commission who regulate gambling in Great Britain.
Licence condition 14.1.1 – Access to premises
Licensees must have and put into effect policies and procedures (including staff training programmes) designed to ensure that their staff co-operate with the Commission’s enforcement officers in the proper performance of their compliance functions and are made aware of those officers’ rights of entry to premises contained in Part 15 of the Act.
Other Inspectorates that have right of entry to the premises are:
a) The local Licensing Authority
b) The Police
d) Fire authority/Fire Safety Officer
e) Environmental Health Officer
f) Trading Standards Officer
14.5 Age Verification Policies and Procedures
Staff should be aware of the social responsibility and ordinary code provisions 3.2.5 and 3.2.6, concerning Access to gambling by children and young persons.
As set out in these code provisions:
a) Training and procedures must be in place to prevent anyone under the age of 18 from gambling, and records must be kept of any attempts made by anyone under the age of 18 to gamble. In addition to this, companies must monitor the effectiveness of these procedures.
b) Staff should understand their responsibilities for preventing underage gambling, returning stakes and not paying prizes to underage customers and particularly for challenging any adult who may be complicit in allowing a child or young person to gamble.
c) Staff must check the proof of age documents for anyone who appears to be 25.
d) Staff must refuse entry to any adult-only areas to anyone unable to produce an acceptable form of identification proving their age.
e) Staff or Management must take action when there are unlawful attempts to enter the adult-only areas.
f) There must be evidence of staff training.
g) The Bingo Association carries out annual Age Verification exercises of its entire operational membership. The age verification testing emphasis will be on challenges for those who appeared to be 25 and under. Customers should be challenged on their appearance, not only on whether they had a membership card.
h) Staff should be aware that they will be observed on the following criteria:
- On entry, were you greeted by a member of staff?
- When approaching the membership desk, were you asked if you were already a member?
- At the membership desk, were you asked for ID?
- If you were asked for ID, was it checked thoroughly?
- Did the staff member make eye contact with you?
- If eye contact was made, when was it FIRST made?
- Was the staff member wearing a ‘Think 25’ badge?
- What was the name of the staff member (from the name badge)?
- What was the gender of the staff member?
- What was the approximate age of the staff member?
- Please accurately describe the staff member (include hair colour and style, build, height and any distinguishing features)
14.6 Problem Gambling Recognition, Interaction and Self-Exclusion Procedures
The Gambling Commission also provide an ordinary code provision forAny person authorised in writing by the fire
There are 3 elements within this area for staff training
1) Customer Interaction/intervention
2) Customer Self-exclusion
3) Responsible gambling information for staff
a) Customer Interaction: Management and staff should be trained on how to recognise and deal with customers exhibiting signs of problem gambling. Everyone should be clear on the procedures that must be followed when problem gambling is evident. When the appropriate interaction or intervention is made, there must be a summary record of the event and any action taken. Staff should be aware of the range of problem gambling information which is available to customers and how to deal with customer enquiries. Training should include conflict management situations when dealing with customers, given the emotional nature of the subject.
The social responsibility code provision relating to this area is Customer Interaction 3.4.1.
In May 2015 an additional ordinary code provision 3.4.2 for Customer Interaction was added to the code of practice to ensure operators shared best practise.
b) Customer Self-exclusion: Part of the Customer Interaction process provides customers with advice on how to take a break from gambling by instigating a self-exclusion agreement. The social responsibility code provision 3.5.1 sets out what must be done and the company must provide the training to facilitate this.
c) Responsible gambling information for staff
Licensees have a responsibility to their own staff to make sure that they are also aware of problem gambling and where they can find help. This is detailed in the social responsibility code provision 7.1.2.
14.7 The Complaint and Dispute Process
Staff should know the stages for the customer complaint procedure. All complaints are initially handled internally through the internal complaints procedure. When this is exhausted (i.e. not resolved), the licensee will provide information about its customer complaints procedure, including ADR, to the customer.
14.8 Anti-Money Laundering
Trading Standards Officers (TSOs) woOperators should train their staff on the POCA (Proceeds of Crime Act) legislation, how to identify the signs of money laundering and how to record and report on any known or suspected money-laundering activity.
Staff should be trained on the requirements of the regulations and will need to report any suspicious cash transactions over a defined amount as set out in the licencees policy to the Duty Manager.
The licensee should appoint a Designated Money Laundering Officer (MLO) also known as a nominated officer. Where a nominated officer has been appointed, they should be actively involved in devising and managing the delivery of the training, taking particular care to ensure that systems are in place to cover all part-time or casual employees.
14.9 Money Lending Between Customers
Staff should also be trained to be vigilant about significant money lending between customers, as this can be away of laundering money. This does not refer to lending money to a friend or relative as a favour.
Money lending between customers is covered by the ordinary code provision 3.8.2.
14.10 Employment of Children and Young People
The ordinary code provision 3.6.2 is self-explanatory concerning the limitations of work that can be done within the bingo premises of an employee who is under 18 years old. Staff need to receive this briefing if they are, or work with people that are, under 18.
14.11 Alcoholic Drinks
Staff should understand the social responsibility code provision 5.1.3 with regard to free alcoholic drinks.
14.12 Other Gaming Training Areas
14.12.1 Cash Control Procedures
Staff should receive training on debit card transactions and be aware the credit card transactions are not allowed.
14.12.2 Prize Bingo
Staff should be aware of the limits on stakes and prizes
14.12.3 Company Terms and Conditions
Staff should have the knowledge of what is included in the terms and conditions and where a customer can view a copy.
14.13 Other Non-Gaming Training Areas
Although the following training areas do not relate to gambling, they are necessary to maintain a crime-free environment and as such, are key to the licensing objective.
14.13.1 Cash Handling
There will be a process for the uplift or banking of site cash which is applies to certain staff. Other procedures will be in place for cash handling within the bingo premises.
Procedures in regard to security of premises and safety of staff. This will include the use of fire chains for example or door control.
Bingo premises opening and closing procedures
Robbery and hold-up procedure and guidance.
Any zero-tolerance policy for customer or other staff behaviour
14.14 Other Training Areas
It would be impractical to cover all training areas in this section as the subject matter will include HR and departmental training. Some key areas however that are normally part of the training regime are:
Emergency procedures such as fire evacuation or dealing with suspect packages and First Aid Training.
Bar Licensing – weights and measures, ‘Think 25’ etc.
Additional training for management and supervisory grades for areas covered in this section and other areas such as Marketing CAP and BCAP codes.
14.15 The Completion of Training Logs and Records
Normally staff members will have an individual training log to record their training on site. This helps to prove that the company is providing training in the key licensing areas.
In addition to this log other details must also be recorded such as:
a) Attempted entry by under 18s
b) Customer problem gambling interventions
c) Self-exclusion details (via the Smart Tablet)
d) Members returning from self-exclusion
e) Attempts to gamble while self-excluded
f) Suspected money laundering activity
g) Incidents involving the Police that are gambling related.