Reports & Compliance
HOUSE POLICY FOR THE RESPONSIBLE SERVICE OF ALCOHOL
We recognise that it is against the law to serve any patron to intoxication.
We recognise that it is against the law to serve or supply liquor to a customer under the age of eighteen (18) years.
We recognise that it is against the law to allow intoxicated, disruptive or violent behaviour to occur on the premises.
We seek to ensure that no harm comes to patrons as a result of our service of alcohol.
THE FOLLOWING POLICIES AND PROCEDURES HAVE BEEN ADOPTED TO ENSURE THE RESPONSIBLE SERVICE OF ALCOHOL
- A range of drinks are offered on the premises and these include non-alcoholic alternatives
- We supply tea and coffee as an alternative to alcohol.
- Non-alcoholic beverages are priced effectively and actively promoted.
- Ice water is available on a complimentary basis.
- We do not seek to encourage rapid or excessive consumption of alcohol through pricing mechanisms.
- We will not serve double nips of liqueurs or spirits.
- Low alcohol beer is stocked, priced effectively and promoted.
- Staff are trained and empowered to enforce this house policy and offer a range of alternative options to patrons they feel are becoming intoxicated.
- Staff will contact the supervisor and alert them to their impending state of intoxication.
- The Board of Directors, Management and Supervisors will not place staff in positions where they may be forced to contravene this policy.
- The Board of Directors, Management and Supervisors will not place staff in positions where they may come to harm as a result of a patron’s violent, quarrelsome or intoxicated behaviour.
HOUSE POLICY FOR THE RESPONSIBLE CONDUCT OF GAMING
Responsible Conduct of Gambling (RCG) refers to the delivery of gaming and wagering services in a manner that minimises the potential harm that may be caused by gambling to individuals, their families and the community generally.
Muswellbrook & District Workers Club strives to foster responsible gambling practices amongst patrons and staff. This is achieved by implementing and maintaining various harm minimisation and consumer protection measures as outlined in this policy.
Muswellbrook & District Workers Club Mission Statement
To properly conduct gambling services in a lawful and socially responsible manner, having regard to potential harm and community concerns about gambling.
Muswellbrook & District Workers Club has adopted the ClubSAFE policies. The ClubSAFE program assists Muswellbrook & District Workers Club to fulfil its stated RCG commitment through a variety of measures including:
- development and implementation of best‐practice policies and procedures for the responsible conduct of gambling.
- provision of a free 24-hour counselling and crisis intervention services for club patrons and staff that has a gambling problem or knows someone who has a problem.
- provision of an effective voluntary self‐exclusion scheme for patrons.
- responsible conduct of gambling training for staff.
- assistance and advice with the handling of gambling‐related incidents.
- promoting responsible gambling practices among club patrons and the community.
Muswellbrook & District Workers Club also observes legislated gambling harm minimisation requirements including:
- controls over the nature of certain gaming related advertising and promotion.
- prohibitions in relation to participation by minors, and the advancement of credit for gambling purposes.
- measures which limit the accessibility and availability of commercial gambling activities in the broader public interest.
- the requirement for Clubs to provide information to patrons and their guests on counselling services, the use and operation of gaming machines, the chances of winning and the problems caused from excessive gambling.
- on entering the Club and displayed on each gaming machine is an advisement on how to contact counselling providers.
- the placement of limitations on the payment of prizes by cash ($5000.00).
Muswellbrook & District Workers Club’s Responsible Conduct of Gambling Policy
- require cash dispensing facilities to be located away from the areas where gaming machines are located and the prohibition of the availability of cash to be withdrawn from a credit card account.
- place limitations on gambling related advertising;
- all gaming machine prize cheques clearly identified by the statement “prize winning cheque cashing rules apply”.
- the provision of working clocks set within 10 minutes of the correct time in all gambling areas.
- prohibit the offering of inducements to gamble.
- require the Club Secretary and certain employees to undertake an approved training course in the responsible conduct of gambling.
- availability of “Player Activity Statements” to members who use their cards whilst playing gaming machines.
- keno rules prominently displayed at Keno points of sale
- other miscellaneous controls. Muswellbrook & District Workers Club promotes responsible gambling by not cashing Patrons’ cheques or providing credit.
- loyalty points: Redemption of Loyalty points for cash is forbidden.
Voluntary Self‐exclusion Scheme
Muswellbrook & District Workers Club operates a voluntary self-exclusion scheme for patrons and their guests who may have a problem with gambling. This information is gained from all gaming staff who will refer the patron to a duty supervisor or manager.
Problem Gambling Warning Signs:
- family and friends of the individual find that money is regularly going ‘missing.'
- constant borrowing of funds and difficulty in repayment.
- dishonesty in relation to financial matters.
- unexplained absences from home or work.
- a tendency toward selfishness and isolation.
- secretiveness with mail.
- when confronted, denial of the problem and its consequences.
- boredom with normal everyday activities.
- severe mood swings ‐ between elation and depression.
- increased alcohol consumption.
- loss of sexual drive ‐ or sexual addiction.
- unrealistic expectations.
- self-deception i.e. past problems are forgotten.
Where to Find Help:
ClubSAFE 1800 99 77 66
Gamblers Anonymous 02 9564 1574
Lifeline 131 114
Salvation Army 02 9212 2941
Wesley Gambling 1300 99 77 66
What Muswellbrook & District Workers Club Can Do:
Brochures are readily available from our Gaming Lounge, TAB and Keno terminals.
A confidential appointment can also be made with an officer of the Club. Patrons who are concerned about their inability to control their gambling habit may arrange for a ban on their entry to the club. Any information discussed during this meeting will remain strictly confidential. Out of this meeting, you may be referred to an independent, professional counsellor for an initial assessment. This may be the first step in the process of getting your life back on track.
HOUSE POLICY FOR AML/CTF
Introduction and Scope
As with any hospitality organisation, there is a risk of Muswellbrook & District Workers Club Ltd products and services being used to launder money and finance terrorism. Australian law and applicable local laws in the jurisdictions in which we operate, requires us to put training, processes and systems in place to identify, manage and mitigate this risk. We do this to protect Muswellbrook & District Workers Club Ltd's reputation, to comply with relevant laws and to be a good corporate citizen. Failure to do so may result in social harm and penalties that may include legal and regulatory action.
Our AML/CTF policy
This sets out how the Muswellbrook & District Workers Club Ltd complies with its legislative obligations. It applies to all department and employees (permanent, part time and casuals) working within the organisation.
Money laundering is the process of hiding or disguising the source of illegally obtained (“dirty”) funds to make them appear legitimate (“clean”), e.g. by filtering them through the legitimate channels.
Money laundering reduces the risk of detection and confiscation by authorities. It is just as serious as the criminal activity behind it – and preventing it can help reduce crime.
Terrorism financing differs from money laundering in 3 main ways:
Its primary purpose is to disguise the ultimate use of the funds, as opposed to their origin
It can involve relatively small sums of money, which can have a huge impact in terms of death, destruction and disruption.
Although terrorists may finance their activities through crime, legitimate funds can also be misappropriated to finance terrorism.
The AML/CTF Act provides a list of ‘designated services’, such as opening an account, placing a bet, receiving winnings or making a deposit. Before receiving any of these designated services, customers will be required to provide proof of identity or similar documentation.
Muswellbrook & District Workers Club Ltd is required to collect and verify this information, depending on the type of customer:
Personal - an individual person of any nationality
A sole trader - a person who trades in their own legal right without the use of a company structure, incorporation or partners and who, alone, has full liability for the activities of the business
Domestic company - incorporated in Australia, including proprietary, public and listed public companies
Foreign company incorporated outside Australia
Partnership - a relationship between persons (the partners) carrying on business in common, under a partnership agreement, with a view to profit
Trust - a relationship where the trustee holds property or assets for a beneficiary. The trustee can be an individual, a group of individuals or a company.
Association - a group of persons who have agreed to join together in pursuit of one or more common objectives. An association can be incorporated or unincorporated.
Registered co-operative - a legal entity owned and controlled by the people for whom it was established and who benefit from using its services
Government body - can be domestic (e.g. Commonwealth, State, Territory) or foreign government body.
Please note the Muswellbrook & District Workers Club Ltd complies with the National Privacy Principles.
Money laundering and terrorism financing (ML/TF) are sometimes detected because a customer acts or behaves in a suspicious way.
For a ‘suspicion’ to be valid, we must have reasonable grounds to believe ML/TF activity may be occurring. To support this, employees receive training in identifying and reporting suspicious matters.
Muswellbrook & District Workers Club Ltd ‘s 4 key AML/CTF principles
Comply with AML/CTF legislation.
Work in conjunction with the Australian Government and support its objectives in relation to the prevention, detection and control of ML/TF.
Muswellbrook & District Workers Club Ltd may decide not to provide products or services based upon decisions guided by ML/TF risk appetite and corporate social responsibility.
Maintain and comply with an AML/CTF program, as required by Australian AML/CTF legislation.
Policy Roles and Responsibilities
Muswellbrook & District Workers Club Ltd’s Board of Directors and Senior Management have ongoing oversight of our AML/CTF policy and procedures. All permanent, part time and casual employees must comply with these, attend training specific to their role, and report suspicious matters or behaviours.
Our Administration Manager is the Muswellbrook & District Workers Club Ltd AML/CTF Officer, responsible for monitoring the status and effectiveness of the Muswellbrook & District Workers Club Ltd ‘s AML/CTF risk management and compliance and reporting it to our Board of Directors and Executive Management team on a monthly interval and whenever any transaction or more to the value of $10,000.00 has taken place.
Muswellbrook & District Workers Club Ltd’s AML/CTF program
The design and implementation of the program was tailored to our ML/TF risk profile, applying specific systems and controls, including:
ML/TF risk assessment monitoring and updated when required
Employee training annually
Employee and customer due diligence
Monitoring and reporting
We also report the following information to AUSTRAC, Australia’s AML/CTF regulator:
Transactions with a cash component of $10,000 or more
Any transactions or other activities regarded as suspicious
Maintaining a Compliance Officer, approved by the Board of Directors
Maintaining Board of Directors approval of all policies procedures and training including revisions
Comply to the AML/CTF Act 2006 using AML/CTF Rules February 2018.
CODE OF ETHICS POLICY
For Muswellbrook & District Workers Club to be a successful and respected organisation it is essential that the Board of Directors, Management and staff embrace an ethical approach to all dealings with clients, customers, competitors, suppliers, employees, colleagues, the media, all business and industry associates and the wider community.
Ethical behaviour must start at the top. To be genuine and to really impact on Muswellbrook & District Workers Club, business ethics must determine the behaviour and decision making of the most senior executives who act as role models for everyone else in the organisation. When representing Muswellbrook & District Workers Club the Board of Directors, Management and staff shall abide by the following ethical principles:
- Respect for the Law and the Regulatory and Statutory Requirements
- To obey all Government laws and regulations.
- To abide by all relevant rules and standards of bodies empowered to regulate the Club industry.
- To deal fairly and honestly with all parties.
- To respect the confidentiality of information entrusted by other parties, and not to disclose such information without the consent of the relevant parties.
- To avoid conflict of interest in dealings with all other parties by identifying potential conflicts of interest and managing these situations to ensure fair treatment to the satisfaction of all parties involved.
- To exercise the highest standards of professionalism and work ethic.
- To exercise due care and attention when dealing with other parties.
- To provide proper care and protection of all assets owned by Muswellbrook & District Workers Club.
- To undertake all work in a diligent and timely manner.
- To give fair value to Muswellbrook & District Workers Club as an employer by working in an industrious manner, showing initiative and representing Muswellbrook & District Workers Club professionally in all dealings with others.
- Respect for all Persons
- To respect the individual rights and dignity of all the Club’s employees by providing fair, open, honest, dignified and non-discriminatory treatment.
- A safe and healthy working environment.
- Training and development to maximise individual potential and contribution to the Club.
- Fair and equitable remuneration.
- Fair and equitable performance appraisal system to provide feedback on individual performance.
- Not to speak disparagingly of others (e.g., customers, competitors, colleagues)
- To treat competitors with respect and to engage only in fair and vigorous competition
- Commitment to Equal Employment Opportunity (EEO), Affirmative Action (AA) and Anti-Discrimination and Sexual Harassment legislation to ensure all employees and customers are treated fairly, justly and reasonably.
- Proper Use of Resources and Power
- To apply and use the Club’s resources and corporate power in a responsible manner.
- To avoid waste, abuse and extravagance in the provision or use of the Club’s resources.
- To not use influence or seek to obtain improper advantage when dealing with other parties.
- Not to solicit or accept (except under conditions approved by the General Manager) benefits and gifts from other parties.
ETHICAL BEHAVIOUR IS EVERYBODY’S RESPONSIBILITY
THE “ETHICS CHECK” QUESTIONS
Is it legal?
Will I be violating either the law or Muswellbrook & District Workers Club rules or policy?
Is it balanced?
Is it fair to all concerned?
Does it promote a win-win situation?
How will it make me feel about myself?
Will it make me proud?
Would I feel good if my decision were published in the newspaper?
Would I feel good if my family knew about it?
CODE OF CONDUCT POLICY
The Code of Conduct is a formal statement prescribing what is acceptable and unacceptable behaviour by employees in particular circumstances (e.g., conflicts of interest, use of confidential information). The provisions of the Code of Conduct are derived from the set of values incorporated in the Code of Ethics and specific obligations imposed by legislation.
1. Policy Statement
Muswellbrook & District Workers Club is proud of its reputation for uncompromising integrity and fairness. All employees are expected to observe the highest ethical standards and must act in a fair and objective manner when involved in dealings on behalf of the Club.
The avoidance of any real, expressed or apparent conflict of interest is vital to our organisation. All employees must avoid situations which could lead to their personal interest conflicting with those of our business or which might be perceived to create a potential conflict of interest.
2. Conflict of Interest
a. A conflict exists whenever an employee, a member of an employee’s immediate family or business associates could benefit either directly or indirectly from an association or transaction with Muswellbrook & District Workers Club. The interest is such that a business decision of the employee might be affected or determined by that relationship or association. Common conflicts include:
i. Financial Interest - This generally involves ownership by an employee or an employee’s family of a significant financial interest in an outside enterprise that does business with, or seeks to do business with, or is a competitor of Muswellbrook & District Workers Club.
ii. Key Outside Role - If the employee serves as a director, officer, partner, consultant, or in another key role, in any enterprise which does business with, or seeks to do business with, or is a competitor of Muswellbrook & District Workers Club.
iii. Agent of a Third Party - This position acts as a broker, finder or other intermediary for the benefit of a third party in transactions involving Muswellbrook & District Workers Club.
iv. Other - Arrangements or circumstances, including family or personal relationships, which might dissuade the employee from acting in the best interests of Muswellbrook & District Workers Club.
b. A conflict exists whenever an employee, a member of an employee’s immediate family or in circumstances where a conflict of interest either becomes a possibility or does arise. The employee is to immediately declare such interest to their manager. If an employee is unsure of their position they should raise it on a confidential basis with the Operations Manager.
3. Guidelines on Employee Conduct with regard to:
a. Inducements and Gratuities
The offer or acceptance of inducements or gratuities from outside Muswellbrook & District Workers Club clearly creates a conflict of interest and must not occur. Employees should avoid credits, rebates, discounts or allowances on any company’s product or service. It is the policy of Muswellbrook & District Workers Club that no employee may give or accept gifts or favours of value in their business relationships with commercial firms or persons with whom Muswellbrook & District Workers Club does business unless recognised as proper under the following guidelines:
i. Certain business courtesies, such as payment for a modest lunch or dinner in connection with a business meeting, normally would not be a gift in the context of the policy. Employees should endeavour to keep such categories on a reciprocal basis, to the extent practicable in order to demonstrate that no gift is sought or granted.
ii. Advertising novelties would not be inappropriate to give or receive provided the item is of no appreciable value and is widely distributed to others under essentially the same business relationship with the donor.
iii. Company product models and pictures made available under customer and public relations programs would not be in violation of this policy.
iv. It is recognised that some employees will have close personal friends who represent the Club's suppliers or customers. When warranted by the employee’s position within Muswellbrook & District Workers Club, they must take special efforts to emphasis the personal rather than the business nature of the friendship and avoid all circumstances where this might not be evident. In particular, they must recognise those situations in which they should disqualify themselves from participating in Muswellbrook & District Workers Club’s business transactions involving the other individual.
b. Preservation of Assets
Employees are expected to protect the Club's assets, which includes materials, equipment, money, services, personnel and intangibles (ideas, concepts, data, information etc). Taking, giving to another or using for personal benefit assets belonging to Muswellbrook & District Workers Club, or aiding others in doing so is prohibited.
c. Muswellbrook & District Workers Club Loyalty
Each employee should act in the best interests of the law and in accordance with the highest ethical standards, in doing so the employee will always act in Muswellbrook & District Workers Club’s best interests. No employee should be influenced by outside interests or relationships that jeopardise Muswellbrook & District Workers Club’s or the employee’s reputation and integrity.
d. Employment of Family and Associates
Employment of family and other associates within Muswellbrook & District Workers Club is permitted but not where the employee can have direct influence over employment conditions, career path, promotion, transfer and performance assessment. Each case will be determined on its merits.
e. Personal Use Of Muswellbrook & District Workers Club Property
Employees may not use, divert or appropriate Muswellbrook & District Workers Club property, equipment, services or assets for personal use or benefit. The improper and unauthorised use of any of these will be treated as theft.
Minor activities such as using photocopiers and telephones for personal use erode Muswellbrook & District Workers Club profits and creates unhealthy precedents.
4. Confidential Muswellbrook & District Workers Club Information
Confidential Muswellbrook & District Workers Club information is considered Club property and may be used and disclosed only with proper authorisation and only in the exercise of an employee’s duties.
Muswellbrook & District Workers Club will endeavour to keep the amount of information that needs to remain confidential to a minimum. However, it has the right to protect certain types of information especially that which may jeopardise Muswellbrook & District Workers Club existence; give competitors overwhelming advantage and harm Muswellbrook & District Workers Club employees or members.
a. Release of Information
Confidential information may only be released by official Muswellbrook & District Workers Club announcement by the General Manager, or with the General Manager’s written permission. The Board of Directors has delegated this function to the General Manager.
b. Protection of Information
Each employee must protect confidential information to which he/she has authorised access or to which he/she gains inadvertent access. Access, in itself, never confers the privilege of disclosing the information.
5. Computer Access
Computers are a resource and are to be used only for Muswellbrook & District Workers Club business, unless authorised otherwise. Any use of Muswellbrook & District Workers Club computer resources for other than official Muswellbrook & District Workers Club business will be considered misconduct and will be subject to discipline.
Computer terminal passwords are confidential and must be safeguarded at all times. It is the operator’s responsibility to ensure that passwords are never left unprotected or unsecured. All unprotected passwords constitute a security violation.
Operators are held accountable for all processing done on their terminal and employees must therefore ensure that their passwords are not shared with anyone other than designated supervisory personnel.
All computer programs written for and used by Muswellbrook & District Workers Club are Club property, and are protected by copyright or are protected by a contract that the Muswellbrook & District Workers Club has signed. No program or data should ever be copied for personal use or given to anyone outside Muswellbrook & District Workers Club without the written approval of an officer of the Club.
6. Employees’ Responsibility
Employees are to acknowledge their commitment to this Policy and agree to adhere to both the spirit and the letter of the Policy. Failure to abide to the Policy may constitute a breach of their terms of employment and a serious breach of this Policy will lead to instant dismissal from employment.