Submission to The Gambling Commission on the Review of the charitable trust licence conditions for New Zealand casinos

Executive summary

1. Overall, The Salvation Army Oasis is opposed to the use of gambling proceeds to fund charities and community organisations. Particularly in the class four environment, we have seen how this funding model can distort the relationship between gambling providers and community organisations, who come to rely on gambling to fund their activities. This is a broken funding model which encourages the growth of gambling and increased consumption of gambling products, contrary to the public health principles of the Gambling Act 2003.
2. We do not believe that gambling proceeds can ‘balance’ the harm caused by gambling, particularly when they are often derived from harmful gambling.
3. The recipients of gambling proceeds are worthy organisations, and in our view deserve access to funding that does put them in moral jeopardy.
4. We submit that under section 224(1)(f) of the Gambling Act 2003 the Gambling Commission should review the host responsibility programme licence conditions for New Zealand casinos to ensure the programmes are effectively preventing and minimising gambling harm. In our view this would include a condition requiring regular independent evaluation of the programmes and their implementation.

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