World Lottery Association
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1 World Lottery Association SUBMISSION FOR ACCREDITATION May 1, 2014 ONTARIO LOTTERY AND GAMING CORPORATION
2 TABLE OF CONTENTS 01 Preface 02 Glossary 05 Introduction 18 WLA Program Element 1: Research 20 OLG Program Research 27 Multi-Jurisdictional Research 29 Facilitating Research 50 WLA Program Element 5: Remote Gaming Channels 59 Stakeholder Engagement 63 Player Education 68 Treatment Referral 69 Employee Training 71 Game Design 72 Advertising and Marketing 64 WLA Program Element 6: Advertising and Marketing Communications 31 WLA Program Element 2: Employee Training 35 Gaming RG Training 39 Charitable Gaming RG Training 40 Support Centre RG Training 41 Lottery RG Training 70 WLA Program Element 7: Player Education 85 Education Initiatives Marked to the General Public 88 Gaming and Lottery 95 Charitable Gaming 98 Self-Exclusion 40 WLA Program Element 3: Retailer Program 46 Lottery Retail 48 Charitable Gaming 46 WLA Program Element 4: Game Design 90 WLA Program Element 8: Treatment Referral 94 WLA Program Element 9: Stakeholder Engagement 104 WLA Program Element 10: Reporting and Measurement 123 Internal and External RG Reporting Program 128 External Independent Assessment Program 112 Appendix A: Independent Assessment Panel (IAP)
3 PREFACE: OLG S RESPONSIBLE GAMBLING PROGRAM In our WLA Level 4 submission four years ago, OLG presented its Responsible Gambling (RG) mandate and program during a period when we were still broadening the scope and depth of our activities. The organizational drivers at the time included applying a new RG strategy to the development of a core program, establishing an approach for program controls to achieve standards compliance, and assessing how RG would support emerging business opportunities and corporate priorities. Today, OLG has a complex enterprisewide program that includes core policy and program elements tailored to the needs of individual lines of business, compliance controls, and continuous improvement based on stakeholder input and research evidence. Our 2014 Level 4 resubmission now begins with a refined and more focused RG strategy and program objectives, rooted in the concept that OLG s business needs to serve a sustainable player base in order to meet integrated commercial and RG objectives. Fundamentally, RG is core to our players experiences we help customers manage the risks inherent to gambling behaviour and future revenues and profit will depend on RG success. Secondarily, RG also contributes to our corporate brand and risk management because OLG must consistently demonstrate the social value and integrity expected of a good community and stakeholder partner. Brand reputation cannot meaningfully improve until the central objective successfully helping players prevent and mitigate the effects of problem gambling is first achieved. The social responsibility team is working with business lines to define and apply this sustainable player strategy across our customers experiences. We are seeking to prove the working hypothesis that players who get into trouble with gambling are not good long-term customers, and that those who can play in a healthy manner are the customers we want. The next wave of RG policy and program developments is intended to support the future commercial success of OLG s business strategy. Going forward, the gaming industry will not grow and evolve without RG risk mitigation and the subsequent corporate risk management which is necessary for long-term, commercial viability and product offering expansion. 1
4 GLOSSARY Alcohol and Gaming Commission of Ontario (AGCO): The agency of the Government of Ontario that regulates gaming and liquor in Ontario under the authority of the Ontario Ministry of the Attorney General. Centre for Addiction and Mental Health (CAMH): CAMH is Canada s leading addiction and mental health teaching hospital and research facility. Its mandate is to transform the lives of people affected by addiction and mental illness. OLG has worked with CAMH since 2005 to co-design and co-deliver Responsible Gambling (RG) Training for employees and as a research partner. OLG s relationship with CAMH is discussed in detail through the submission, especially in WLA Program Elements 1: Research and 2: Employee Training. Charitable Gaming (cgaming): Lottery schemes (typically Bingo, Electronic Bingo and Break Open Nevada Tickets) that are operated at commercially-owned Bingo centres. A portion of the proceeds goes to support local charities. With a mandate defined by the AGCO, OLG conducts and manages the operations of commerciallyowned facilities through contracts with commercial operators, charities and municipalities. Charitable Gaming Centres (CGCs): Revitalized bingo halls in Ontario which include electronic bingo and electronic bingo-themed games. Also known as cgaming Centres. Executive Leadership Team (ELT): OLG s executivelevel management team. Facial Recognition (FR): A facial recognition system is a computer application for automatically identifying a person from a digital image or a video frame from a video source. OLG uses FR at OLG Gaming Sites to support its Self-Exclusion program. Gambling Assessment Measure Guidance about Responsible Design (GAM-GaRD): An RG software tool developed by an external vendor that provides a quantitative analysis of structural and situational characteristics of a game based on a scoring matrix that expresses risk through a stop light indicator. Gaming Management System (GMS): A software suite that is responsible for managing the back-end operations of all OLG Gaming Sites, including slot machine operations, loyalty card memberships and financial accounting. Gaming Sites: All OLG land-based sites that offer live table games and slot machines, or only slot machines, for play. Interprovincial Lottery Corporation (ILC): A nationwide lottery organization made up of five provincial lottery corporations - Atlantic Lottery Corporation, British Columbia Lottery Corporation, Ontario Lottery and Gaming Corporation, Loto-Québec and Western Canada Lottery Corporation - who are joined together to undertake national lotteries, instant games and other initiatives of common interest. ILC Responsible Gambling Subcommittee (ILC- RGSC): A committee of the ILC comprised of RG professionals from member organizations. The ILC-RGSC was established to advance the level, effectiveness and operational integration of RG programming within the Canadian gaming industry, and to establish Canada as a leader in this regard. It Pays to Know (IPTK): OLG s player-focused communications platform. IPTK is an umbrella under which a range of RG messages are communicated to players in a compelling, innovative and visually consistent way. itrak: OLG s Self-Exclusion database. 2
5 Knowyourlimit.ca (KYL): An OLG website that acts as an interactive hub for the provision of RG information and resources to players and the general public. The site represents a critical step in the evolution of how RG education is delivered, from the static distribution of brochures to the dynamic use of interactive tools and games that engage gamblers with RG information. This program is fully described in WLA Program Element 7: Player Education. Marketing, Communications and Stakeholder Relations (MCSR-Social Responsibility): The division within OLG with responsibility for RG strategy and policy development, program design, implementation and evaluation. Mobile Access to Responsible Gaming Information (MARGI): An easy-to-use interactive RG information kiosk used at OLG Gaming Sites and Charitable Gaming Centres. Ontario Problem Gambling Research Centre (OPGRC): Up until 2013, OPGRC was mandated to enhance the collective understanding of the nature and causes of problem gambling, and improve the scope and effectiveness of related treatment and prevention responses. Under this mandate, OPGRC has contributed to developing impartial, well-designed research to inform the development of RG policy and programming. For OLG specifically, OPGRC has been instrumental to providing a research perspective or element to OLG RG programming design, development and implementation. See WLA Program Element 1: Research and 9: Stakeholder Engagement for further details. Problem Gambling (PG): A type of gambling behaviour with harmful consequences to the individual involved. Red Flag Guidelines: A set of guidelines for Gaming Site employees (developed for OLG by CAMH) to identify and respond to customers based on a continuum of visible customer behaviours that indicate a potential risk for gambling problems. Reinstatement: This refers to the return to gambling at OLG facilities (i.e., Gaming Site or Internet website) after a period of Self-Exclusion. Although self-excluded individuals can decide to remain self-excluded indefinitely, they may also decide to apply to return to gambling at OLG facilities after their chosen term of Self-Exclusion is complete. Responsible Gambling (RG): An approach that seeks to provide information to players about how the games work and ways to play safely in order to prevent problems from occurring. For those individuals whose gambling has become a problem, RG seeks to reduce the harm and bridge them to support services. Responsible Gambling Centres (RG Centres): Specially designated, onsite, stand-alone facilities that offer a wide range of RG information and services. RG Centre operations are typically contracted to an independent third-party organization with expertise in RG and PG. Responsible Gaming Resource Centres (RGRCs): The current name of the RG Centres, which are operated by the Responsible Gambling Council. RGRCs are independent entities located at all OLG Slots and Casinos. They are also being implemented at 37 Charitable Gaming Centres across Ontario. RG Check: An independent third-party RG accreditation program for land-based Gaming Sites that is offered by the Responsible Gambling Council. Responsible Gambling Council (RGC): An Ontariobased non-profit organization committed to the development and implementation of problem gambling prevention programming. OLG contracts RGC to operate RGRCs at all Gaming Sites and cgaming Centres. RGC is also a vendor to OLG for various research and evaluation projects. RGC also operates RG Check for land-based gaming sites and is working to finalize RG standards and an accreditation program for Internet gaming sites. This relationship is described throughout the submission and especially in WLA Program Elements 7: Player Education, 9: Stakeholder Engagement and 10: Measurement and Certification. 3
6 RG Program Areas: Areas of common focus, intent, and objectives that comprise the OLG RG Program. The areas were identified as part of OLG s RG Program design process in 2012 that grouped together the RG-related regulatory and third-party accreditation standards that applied to OLG. The areas for Gaming are: RG Corporate Commitment, RG Customer Education, RG Marketing, RG Customer Access to Money, RG Customer Assistance, RG Game and Venue Design, Self-Exclusion, and RG Employee Engagement and Training. The Program Directives of the other lines of business include all the Program Areas listed above except Corporate Commitment. RG Program Descriptions: Completed and approved high-level descriptions of program features and rationale for the RG Program as executed within a line of business. OLG has drafted RG Program Descriptions for Gaming, cgaming and Lottery. Defining the RG Program Description document is generally the first stage of designing and standardizing OLG s RG Program for each line of business. RG Program Directives: The key policies and procedures of the RG Program for each line of business. Creating the RG Program Directives document is the second stage of formalizing and standardizing OLG s RG Program for each line of business. Self-Exclusion: A voluntary program offered by OLG whereby an individual is excluded and prohibited from entering OLG Gaming Sites as a means of assisting the person to gain control over their gambling. Winner s Circle: OLG s loyalty program for OLG Slots and Casinos Gaming Sites. 4
7 CORPORATE PROFILE OVERVIEW CORPORATE MISSION Ontario Lottery and Gaming Corporation ( OLG or the Corporation ) and its contract management companies employ nearly 17,000 people across Ontario. OLG is responsible for 24 gaming sites as well as the sale of lottery products at approximately 9,800 retail locations. An Operational Enterprise created by the Government of Ontario, the Corporation is intended to provide gaming entertainment in an efficient and socially responsible manner that maximizes economic benefits for the people of Ontario, related economic sectors and host communities. The Ontario Lottery and Gaming Corporation Act, 1999 requires that net revenue from lotteries, casinos and Slots at Racetracks be paid to the Government of Ontario Consolidated Revenue Fund. In fiscal , this revenue supported services such as the operation of hospitals, amateur sports and problem gambling and related programs. Revenue from these activities is also made available to the Ontario Trillium Foundation (the Foundation ) by the Government for distribution to charitable and not-for-profit organizations every year. The amount directed to the Foundation in fiscal totaled $120 million. OLG s corporate mission guides employees in their work with customers and stakeholders. In all we do, we are asked to reflect on our purpose, realize our vision and embody clearly identified values. PURPOSE Making life better for people across Ontario. We make it possible by generating revenue provincially and economic and social benefits locally. Our vision is to create excitement and fulfill dreams. Our commitment is to build trust by delivering gaming responsibly. Our success is demonstrated by the profit and jobs we generate. Our strength is our sophisticated understanding of our customers. Our goal is to be a destination of choice for world-class entertainment. VALUES Be Accountable. We accept the responsibility of setting and attaining high standards for ourselves in servicing our customers and acting in the public interest. Act with Integrity. This means doing the right thing. We will balance what our customers and business partners ask of us with what the people of Ontario expect of us. Respect our customers, employees, partners and the people of Ontario. Respect starts with listening openly and honestly to the diversity of people and ideas around us. 5
8 GOVERNANCE The legislative authority of the Corporation is set out in the Ontario Lottery and Gaming Corporation Act, Classified as a Government Business Enterprise, OLG has a single shareholder, the Government of Ontario, and for fiscal reported through its Board of Directors to the Minister of Finance. Members of the Board of Directors and its Chair are appointed by the Lieutenant Governor in Council. Neither the Chair nor members of the Board are full-time, nor are they members of Management. BOARD MANDATE The Board of Directors establishes policies for the Corporation and counsels the President and CEO and senior executives, who oversee the Corporation s business operations. The Board s mandate is to direct Management s focus to optimizing the Corporation s overall performance and increasing shareholder value by executing its various responsibilities, which include: to establish a well-defined strategic planning process, setting strategic direction to approve the annual business plan as well as operating and capital budgets to define and assess business risks to review the adequacy and effectiveness of internal controls in managing risks to appraise the performance of the President and Chief Executive Officer to oversee a code of conduct to ensure the highest standards in dealing with customers, suppliers and staff, with due regard to ethical values and the interests of the community at large in all corporate endeavours to track the overall performance of the Corporation to remain informed and provide input, as required, concerning communications with the Government of Ontario and stakeholders to ensure compliance with key policies, laws and regulations. SOCIAL RESPONSIBILITY COMMITTEE The Social Responsibility Committee assists the Board to ensure that the Corporation conducts its business in a socially responsible manner. It inquires into and oversees such areas as responsible gambling, game integrity, and Smart Serve food and beverage service. It reviews, in particular, the design and implementation of Internet gaming and other new game offerings, with a particular focus on preventing underage and problem gambling. Other board committees include: Governance and Nominating Committee Audit and Risk Management Committee Leadership Development and Compensation Committee Budget/Finance Committee 6
9 SOURCES OF REVENUE OLG s operations and revenues are organized under three operating segments. In fiscal , these operating segments collectively generated $6.63 billion in revenue. REVENUE BY OPERATING SEGMENT LOTTERY AND CHARITABLE GAMING OLG operates 18 terminal-based lottery and sports games and offers 75 INSTANT lottery products through approximately 9,800 independent retailers across the province. OLG conducts and manages the operations of 11 Charitable Gaming Centres across Ontario. These sites offer bingo games on tabletop devices in addition to the classic paper-based play. OLG RESORT CASINOS OLG is responsible for conducting and managing four Resort Casinos Caesars Windsor, Casino Rama, Casino Niagara and Niagara Fallsview Casino Resort. These sites are operated, under contract, by private operating companies. Lottery and Charitable Gaming $3,327 million Resort Casinos $1,297 million OLG Slots & Casinos $2,008 million OLG SLOTS AND CASINOS OLG owns and operates five casinos in Ontario. It also owns and maintains authority over the slot machine operation at the Great Blue Heron Casino, an aboriginal casino owned by the Mississaugas of Scugog Island First Nation. OLG also operates 14 slot machine facilities at racetracks across Ontario. 7
10 ECONOMIC IMPACT OLG s annual payments to the Province on Ontario of close to $2 billion for the past several years have helped support health care and education, research, prevention and treatment of problem gambling, amateur sport through the Quest for Gold program, and local and provincial charities through the Ontario Trillium Foundation. In addition to OLG s payments to the Province, there are several direct beneficiaries of gaming proceeds, including 23 host municipalities and Ontario First Nations. Lottery and gaming also contribute to the economy in a number of other ways. In fiscal , OLG operations generated $3.4 billion in total economic activity in Ontario. $ 1.8 billion NET PROFIT TO THE PROVINCE* This includes: $1.6 billion directed to the operation of hospitals and other provincial priorities $120 million distributed through the Ontario Trillium Foundation for the benefit of local and provincial charities $38.8 million directed by the Ministry of Health and Long-Term Care for research, prevention and mitigation of problem gambling** $10 million to support amateur athletes through the Quest for Gold program *Net Profit to the Province is the amount the Corporation returns to the Province of Ontario after stakeholder and other payments. **based on government policy that directs 2% of OLG slot revenue to problem gambling funding $ 23.6 million CORPORATE RESPONSIBILITY This includes: $12.1 million what OLG directed to its Responsible Gaming Resource Centres, policy and program development, staff training and Self-Exclusion capital costs. Together, OLG and the Ministry of Health and Long-Term Care spent $50.9 million on responsible gambling in Ontario. $9.3 million in charitable gaming proceeds distributed to participating local charities $2.2 million dedicated to the sponsorship of community festivals and events $ 1.6 billion SUPPORT FOR LOCAL ECONOMIES This includes: $892.5 million to pay OLG s 16,900 direct and indirect employees across the province $333.1 million in payments relating to Ontario s horse racing industry through the Slots at Racetracks Program (This program ended on March 31, 2013.) $228.3 million in commissions paid to lottery retailers across Ontario $94.1 million in payments to municipalities that host OLG gaming facilities, including Resort Casinos and Charitable Gaming Centres $58.2 million in goods and services purchased from Ontario businesses to support gaming operations (excludes Resort Casinos) Host municipalities benefit directly from hosting fees, property tax revenue, development fees and the creation of well-paying permanent jobs. Hosting fees can be spent by a municipality in any way it sees fit. For example, the City of Brantford, which has received nearly $50 million in hosting fees since 1999, used the funds to revitalize its downtown core. Sault Ste. Marie, which has received more than $21 million in hosting fees since 1999, used the money to help build a new state-of-the-art hospital. 8
11 KEY INITIATIVES MODERNIZATION AT OLG At the request of the Ontario provincial government, OLG s modernization began in March 2012, after completing a year-long comprehensive strategic review of its business. The review revealed that OLG s current business model is not sustainable over the long term. Advances in technology, changes to shopping patterns, aging demographics and declining visits from the U.S. combined to threaten the industry and the contribution to the Province. All these factors were putting OLG s future financial contribution to the Province at risk. In a report delivered to the Minister of Finance, the organization outlined three recommendations: Become more customer-focused. Expand regulated private sector delivery of lottery and gaming. Renew OLG s role in oversight of lottery and gaming. The modernization of OLG will assist in the creation of thousands of jobs in the industry and increase revenue for the Province and the people of Ontario. Modernization represents a significant shift in Ontario s lottery and gaming industry. It is also an innovative model for reforming government and its agencies, while preserving government control over the business. The successful implementation of OLG s modernization is expected to widen the appeal of gaming in Ontario, creating a broader player base while reducing the amount of public capital dedicated to gaming and lottery infrastructure. Some specific initiatives include: Modernizing and shifting the day-to-day operation and capital development of gaming facilities to the private sector; building new facilities based on customer interest; renegotiating the funding formula for municipalities to allow for a broader game offering; and ending the funding formula for slots at racetracks. Modernizing and shifting the day-to-day operation of the lottery network to private sector operators; investing in new player technology; allowing the private sector to design lottery games; and expanding the distribution of lottery products through new channels. Delivering a full range of games including lottery tickets, interactive casino-style games (i.e. players wager against the house) and peer-to-peer games (e.g. poker) on the Internet through an online website accessible by computers and other Internet-connected devices. Improving efficiencies at OLG as it transforms into a smaller organization that is focused on market management and leading in responsible gambling. Delivering gaming using a gold standard for RG programming. CHARITABLE BINGO AND GAMING REVITALIZATION INITIATIVE Recently, there has been a significant decline in Charitable Gaming in Ontario. Ten years ago, there were more than 6,000 charities raising funds at approximately 230 bingo halls, but today, there are just under 3,000 charities fundraising in 61 halls. To generate interest, and ultimately more money for thousands of local charities, OLG is looking to develop new products and technologies that will invigorate the traditional bingo experience and appeal to a wider audience. The plan is to introduce a standardized suite of paper and electronic games to all interested bingo halls in Ontario. Currently, there are 37 bingo centres which have expressed interest in the initiative, and six pilot sites that will test the newly expanded model. The new product offering will include: Paper Bingo Electronic Bingo (ebingo) Paper Break Open Tickets Break Open Ticket Dispensers esuite Games (electronic bingo, electronic INSTANTS, electronic Break Open Tickets) Rapid Draw Bingo Electronic Shutterboard 9
12 RESPONSIBLE GAMBLING (RG) AT OLG RG STANDARDS IN ONTARIO The OLG is subject to two legal statutes: the Gaming Control Act, 1992 and the Ontario Lottery and Gaming Corporation Act, The Alcohol and Gaming Control of Ontario (AGCO) is the government agency that regulates gaming in Ontario under these statutes. In November 2013, the AGCO issued the Registrar s Standards for gaming that apply to all lottery schemes conducted at OLG gaming sites including, casinos, charitable gaming sites, and Internet gaming sites. AGCO is also currently developing RG standards for Lottery, which are expected to closely mirror the gaming Standards and to be completed in The new AGCO Standards represent a change in the AGCO regulatory approach in two significant ways for OLG. First, the Standards shift the regulatory focus from detailed prescriptive requirements to broader outcomes or objectives. This standards-based approach is outputdriven and allows for variation in ways to achieve the same result. OLG and its Service Providers are responsible for developing the systems and control environments to meet the Standards. Second, the AGCO Standards explicitly cover areas pertaining to responsible gambling, which mean OLG RG programming is being regulated for the first time in Ontario. RG STANDARDS IMPLEMENTATION OLG is currently standardizing its RG Program for not only current but future operations under Modernization. This RG Standards Implementation project consists of three general stages although practicalities and timing have dictated the extent to which these stages are executed for each line of business. 1. Program Design Completed and approved high-level description of program features and rationale. The RG program design is described according to three concepts: program direction (i.e., overall objective), program elements (i.e., main features) and program performance and reporting measures (i.e., activity indicators). The document that describes the program design is the RG Program Description. 2. Program Policy Completed official program policies and procedures. The key program policies and procedures can be found in the RG Program Directives. This document contains more granular prescriptions compared to the content of the Program Description documents and aim to guide gaming operations in following specific policies and procedures that would enable it to meet RG standards. Compliance to the AGCO RG Standards is a part of a broader objective of the OLG Modernization plan, which is to deliver a gold standard for RG programming. For OLG, this means delivering a comprehensive RG program that meets or exceeds the RG standards of the AGCO and third-party RG accreditation programs (i.e., RG Check, WLA RG Framework) and is consistent as possible across OLG s four product lines. 3. Program Implementation Fully operational policies and procedures, including operable tools and resources. The RG Program is considered fully implemented when all the RG Program Directives are operational in the field. This includes translating the Directives into the specific operational procedural manuals for relevant departments, having the tools and resources some of which need to be created - outlined in the Directives available, functional and operational; and full employee awareness and compliance with the relevant policies and procedures. 10
13 The project is occurring at different rates across the lines of business. Thus far, Gaming has just started implementing its RG Program after completing its RG Program Directives for OLG-operated Gaming Sites. These Directives will be adapted and implemented for the Resort Gaming Sites beginning May cgaming has completed its RG Program Description and has implemented parts of the Program. igaming is nearing completion of full program implementation and is expected to launch with the Internet site, PlayOLG.ca, in Lastly, Lottery is nearing completion of its Program Description and will begin the Program Policy and Implementation phases immediately after. Finally, it should be noted that a line of business that has not completed the program implementation stage does not mean it has no RG programming; rather it means that the programming is not operating with a certain function and capacity that fully meets OLG s gold standard for RG programming. RG PROGRAM AREAS As a part of its program design process, OLG conducted an analysis in 2012 that grouped RG-related regulatory and third-party accreditation Standards that applied to OLG together into areas of common focus, intent, and objectives, so as to minimize overlap and duplication between similar RG Standards frameworks. The result was eight areas of RG standards which in turn, led to the identification of the following eight areas of RG programming, also known as the eight OLG RG Program areas. RG Corporate Commitment RG Customer Assistance RG Customer Education RG Marketing RESPONSIBLE GAMBLING PROGRAM RG Game and Venue Design Self-Exclusion RG Customer Access to Money RG Employee Engagement and Training In comparison to the ten WLA RG Program Elements, while there are some directly comparable categorizations (e.g., Customer Education and Player Education), the OLG RG Program Areas tend to be more customer-oriented and organized around generic services aimed directly at the customer of specific product lines. The WLA Program Elements, on the other hand, consists of broader categories that include multiple product lines (i.e., remote gaming, retailer program) and activities that are more directly relevant to the gaming service provider interest and operations rather than the customer (e.g., stakeholder engagement, reporting and measurement). 11
14 RG PROGRAM STRATEGY The design, development, and delivery of OLG s RG Program throughout the process of Standards implementation is driven by OLG s corporate RG Program Strategy. This Strategy provides overarching direction to the program and is a key accountability tool. The goal of the RG Program Strategy is: To build a sustainable base of customers by helping to prevent and mitigate problem gambling amongst our customers by: 1. Enabling players to make informed choices about their gambling, and 2. Encouraging and facilitating access to a range of support services. Within this goal statement there are three key concepts: 1. Sustainable players are people who can gamble in a healthy manner over the course of their adult life, and their behaviour does not adversely affect their individual financial situation, mental and physical health, or personal relationships. To help gamblers develop and use healthy habits, OLG s Responsible Gambling efforts must be integrated into an overall business strategy in which OLG, and its service providers, engender a positive player experience by treating RG as basic customer care. 2. Enabling informed choice involves providing players with: Information to help players understand how the games work, the risks of gambling, how to adopt healthy play habits, and what to do if gambling becomes problematic including the availability of support services Tools to help players manage their gambling and adopt healthy play habits, such as interactive applications or options to set time and money limits on electronic forms of gambling 3. Access to support services involves providing players with: Information, assistance and referral related to gambling counseling services, credit counseling services, family support and relationship counselling services, and legal aid in local communities where gambling is offered. RG PROGRAM STRATEGIC OBJECTIVES Underlying this Goal Statement, are a number of Strategic Objectives. As per the Strategy, all areas of OLG s RG Program must intend to fulfil at least one of the following. 1. Player Experience Objectives i. Awareness: Players are aware of risks, safe play habits, and resources for getting help. ii. Knowledge and Behaviour: players understand and apply information on safe play habits when gambling. iii. Support Service Usage: tracking how many players are using each type of service OLG promotes. 2. Program Design and Delivery Objectives: i. Standards: OLG has the organizational capacity to meet, and it demonstrates adherence with regulatory and third party standards, as well as government policy objectives. ii. Continuous improvement: OLG regularly measures and evaluates the outputs and outcomes of its RG program, identifies areas for improvement, and deliberately evolves areas of program over time. 12
15 CONTINUOUS IMPROVEMENT This submission demonstrates that since 2010 (with Level 4 certification in 2011), OLG has continuously improved its RG Program. While this effort was planned for most areas, two major business opportunities that emerged Charitable Gaming revitalization and OLG s Modernization plan were unanticipated and drew upon significant dedicated RG resources. The following section highlights achievements based on three strategic organizational drivers: 1. Evolving the core RG Program 2. Expanding internal capacity to meet strategic priorities 3. Supporting operations to meet demands of changing business environment Forward-looking priorities and objectives for the next three to five years will be framed based upon these drivers, plus a new one: 4. Building knowledge in the RG field. CONTINUOUS IMPROVEMENT PROGRESS Evolving core policy and program elements Policies and programming were advanced across the following areas: Player education (WLA Program Element 7: Player Education): Through the It Pays to Know interactive program and RG Centres at 24 slots and casino facilities, hundreds of thousands of players have received a range of targeted information on risks, facts, play management techniques and support services. Enhanced voluntary Self-Exclusion policy for slots and casinos (WLA Program Element 7: Player Education Self-Exclusion): Supports are now provided through RG Centres and off-site treatment offices. Education modules are being developed to encourage enrolment in treatment and to reinforce safe gambling concepts for those who choose to return to gambling after their Self-Exclusion period is complete. Facial recognition technology has more than doubled the detection of self-excluders who attempt to breach their agreements. Formal continuous improvement: The elements, tools and approach of a continuous improvement regime are now established for policy and program development. Ongoing evaluation efforts measure success and indicate where improvements are required, for example, annual employee survey, annual player survey, It Pays to Know metrics, RG Centre metrics, and Self-Exclusion reporting (WLA Program Element 10: Reporting and Measurement). Moreover, when new areas of development emerge, such as the creation of an RG platform for Internet gaming (WLA Program Element 5: Remote Gaming Channels) or new training for charitable gaming (WLA Program Element 2: Employee Program), OLG in addition to its regular monitoring of current research and information about best practices from other jurisdictions engages stakeholders and experts to ensure leading research and best practices are captured (WLA Program Element 9: Stakeholder Engagement). Employee training and culture building (WLA Program Element 2: Employee Program): Core training principles and techniques have been customized and distilled into training for seven distinct business units (Gaming Frontline and Supervisor employees, OLG Support Centre, Lottery Sales, Prize Centre, igaming, cgaming), drawing from multiple needs assessments and evidence-based learnings. This training has been supported by a range of cultural reinforcement initiatives. 13
16 Select metrics illustrating program improvements: Degree of Improvement F2010 to F2013 Priority Scorecard Metric for OLG RG Program Actual Change Fiscal Fiscal % Players who understand safe play habits 72% of survey respondents 49% 398% Players referred to support services by RG Centres 3301 people % People educated and assisted at RG Centres across casinos in Ontario 191,758 people 147, % Self-excluders supported by RG Centres 3020 people % Self-excluders detected while trying to breach 1933 people % Employees who are somewhat or very knowledgeable about RG as it relates to their jobs 97% of employees surveyed 85% 19% OLG s internal budget for RG program $12.1 million $9.8 million 2. Expanding capacity to meet strategic priorities The following capabilities were built or enhanced in the corporate social responsibility team at OLG and across the enterprise to support RG program performance. Control environments to meet third party and regulatory standards: 19 OLG slots and casino facilities have achieved thirdparty RG Check standard (WLA Program Element 10: Reporting and Measurement) OLG has served as national lead on the design of the Canadian Interprovincial Lottery Corporation s RG Standards Framework, and OLG has attained a high level of compliance with the first two standards developed (Self-Exclusion, Training) (WLA Program Element 1: Research) To prepare for the launch of the new regulatory standards created by the Alcohol and Gaming Commission of Ontario, OLG has built a robust control environment consisting of program and procedural controls that will enable OLG to comply with the standards (See above RG Standards in Ontario ) Expansion of internal resources and functional experts: While the basic organizational structure and corporate governance were established at the time of OLG s 2010 WLA submission, we have subsequently identified additional roles and responsibilities for corporate employees and across lines of business The central Social Responsibility team s functions expanded as personnel grew from six to 14 (with one more addition anticipated in 2014), and more than 90 per cent of this team s efforts are devoted to responsible gambling. Expectations within each line of business have also grown. A Social Responsibility committee of the Board of Directors now oversees the RG program In 2012, the Social Responsibility team began adding data analytics capabilities to the RG Program through the planning and development of the Internet gaming platform, and by adding a dedicated data specialist to our team 14
17 3. Supporting operations to meet demands of changing business environments Core RG program elements have been defined and established based on specific requirements for the following emergent business areas, two of which were not anticipated in Internet gaming: Based on our government shareholder s direction to develop a gold standard RG platform, OLG conducted extensive research and consultation to design RG programming for the forthcoming PlayOLG.ca business (WLA Program Element 5: Remote Gaming Channels). As of April 2014, construction of the RG platform was completed and preparations for its business launch are underway, pending regulatory and final user acceptance testing. Electronic bingo games for Charitable Gaming: The revitalization of Ontario s bingo sector has involved a significant new role for OLG in the development of game product, and commensurate RG support from the Social Responsibility team. While basic RG efforts supported this line of business prior to 2010, OLG is now applying to Charitable Gaming, the same footprint of core RG Program elements developed for Lottery and Gaming, for example adding: RG Training and cultural reinforcements, RG Centres and player education, risk assessment analysis of new games, voluntary Self-Exclusion, and evaluation metrics (WLA Program Element 3: Retailer Program). variety of audiences, including municipalities, stakeholders, public health officials, media and industry groups As part of the Modernization plan, our government shareholder also directed OLG to collaborate with horse racing tracks and provide direction on how that sector should build a robust RG program FUTURE PROGRAM DIRECTION Over the next half decade, we will work to advance program priorities driven by organizational needs, with critical examples illustrated below. 1. Evolving the Core RG Program Five scorecard metrics for the RG Player Education program have declined over two years (please see chart on page 16). In response, OLG has undertaken a strategic review of its player education program and initiated efforts to re-brand the program, change RG Centres, modify the tone, and expand the channels and messages delivered to meet the needs of players occupying a broader range of risk profiles. RG Centres will evolve with a new look and feel, new names and new technology. RG messages integrated into product marketing will continue to evolve as well, and more sophisticated approaches to player segmentation are in development (WLA Program Element 7: Player Education). OLG s Modernization plan: OLG s Modernization plan involved re-scoping OLG s organization and purpose to ensure overall management of Ontario s gaming market and integrity oversight of third-party private sector operators RG and Social Responsibility have been defined as pillars of the new organization, with our government shareholder directing OLG to ensure that a gold standard for RG underpins the new business model The Social Responsibility team has embedded RG into the design of the new OLG (i.e., post-modernization) through the procurement and operator contractual requirements, and by touring Ontario (almost 100 appearances from March 2012 to June 2013) to explain the Modernization plan and engage a wide 15
18 Select metrics illustrating areas of decline in performance: Degree of Decline Priority Scorecard Metric for OLG RG Program Fiscal Actual Change Peak Fiscal Year 27% People who have viewed pages on knowyourlimit.ca 93, ,329 (2012) 12% 7% Plateau reached 26% Players who have interacted with educational kiosk at gaming sites Direct RG marketing communications to players (# of communications) Employees who are somewhat or very knowledgeable about RG as it relates to their jobs Total problem calls to the Ontario Problem Gambling Helpline 41,614 47,265 (2012) 27.3 million 29.3 million (2011) 97% 98% (2012) 1,676 2,262 (2011) 10% Total counselling clients in Ontario 5,513 6,132 (2011) Training and cultural reinforcement initiatives have advanced an RG culture across the lines of business. Moving forward, specific training programs will be refreshed (e.g., a new gaming division training for 10,000+ employees will begin in the spring of 2014), and reinforcement initiatives will evolve in a similar manner, such as an online refresher program for gaming (WLA Program Element 2: Employee Training). gaming industry approach RG. This development of risk profiles will enable the transmission of direct feedback to players based on specific profiles, tailoring related messages and adjusting marketing approaches. Time and limits will be introduced into the gambling experience for Internet gaming (WLA Program Element 5: Remote Gaming Channels) in 2014, and will advance to the Gaming division in The decline of get help service measures (i.e., helpline calls, counseling clients) is harder to interpret because the causes are less straightforward than those for the prevention and training metrics described above. While it may be possible that rates of problem gambling are decreasing, OLG cannot draw such causal correlations with any certainty, and will continue to work to increase the uptake of people seeking support services. OLG is currently developing a research-based video to encourage people registering for Self-Exclusion to seek treatment, and is also in early discussions to expand its Off-Site Self-Exclusion registration meetings to better serve aboriginal populations. 2. Expanding internal capacity to meet strategic priorities The following are highlights of our future direction: Data: The addition of data analytics capability (WLA Program Elements 4: Game Design, 5: Remote Gaming Channels) to the RG Program, and related work to improve player education and interaction through the application of risk segmentation, will change how OLG and the Customer hub: The entire organization s use of data will also deepen as an enterprise-wide customer hub is developed. This initiative, which is a central part of the new OLG under our Modernization plan, will for the first time enable access to, and analysis of, customer data from across all divisions of OLG. RG is a primary business owner of this hub, and we are devising plans to have a single view of the player across lines of business, to provide more personalized, data-driven RG support. Continuous improvement: OLG s Modernization plan has involved a new organizational design for the enterprise, which has allowed the Social Responsibility team to restructure itself into three areas: strategy, policy and program development. Within the strategy and policy areas, a more structured, systematic and continuous improvement function will be developed. While we currently use research and evaluations to guide development and changes to specific elements of the program as they arise, we are currently working to embed codified responsibilities for overall program improvement within the team. 16
19 3. Supporting operations to meet demands of changing business environment Contractual obligations for RG: The new OLG will be responsible for managing private operator performance on RG, which will be based on detailed contractual obligations including key performance indicators. All aspects of the program described in this WLA Level 4 submission will continue, and OLG will have the ability to evolve the program in a manner consistent with our growth over the last four years. Addition of RG support for the horse racing sector: Our government shareholder recently modified some details of OLG s Modernization plan, including the assignment of a role for OLG to advise and support horse racetracks in the development of an RG program. While the details of this work are still being planned, this will require a significant amount of new effort for the Social Responsibility team. Business relationship management: The aforementioned changes to the Social Responsibility team s structure and function related to Modernization include the addition of specific roles for managing program development or all interfaces with lines of business operations. This role has commenced in the current organization and will continue in the future modernized model, following the outsourcing of operations. These team members will ensure that program implementations are successful, support dayto-day operations and issues management, and provide a coaching and culture-building role to ensure that strategic RG expectations are realized in player environments. 4. Contributing to knowledge in the RG field In response to requests from researchers, OLG has been providing access to data for a number of years. OLG has established protocols for responding to and managing these individual requests. Over the next three years, OLG seeks to develop a more open, fair, proactive and purposeful process that will support our ongoing understanding of healthy and problematic gambling through research, and inform OLG s Responsible Gambling Program. The objective is to expand the potential of OLG data to achieve innovation and leadership in responsible gambling. OLG is currently exploring processes for enabling data access to ensure that the organization meets its objectives, values and operational requirements. This work will also consider collaboration with responsible gambling stakeholders, a data access process, and key questions for the problem gambling/rg communities. In addition to all of the other stakeholder and research work that OLG undertakes, OLG seeks to build upon the policy work undertaken through the AGCO provincial policy roundtable (WLA Program Element 9: Stakeholder Engagement). This work will not only inform the evolution of regulatory standards in Ontario, but can also help identify research questions and considerations that can influence the development of RG in Canada and internationally. Compliance and standards: The growth and development of the RG control environment to manage regulatory and third-party standards has prompted enhancements to formal, structured records management to ensure appropriate indicators, documentation and reports are gathered, analyzed and managed. Requirements for systems, databases and personnel are being defined and built to ensure requirements are met. 17
20 WLA PROGRAM ELEMENT 1: RESEARCH PROGRAM STATUS: 2010 SUBMISSION In 2010, OLG reported its reliance on impartial, evidence-based research to inform the development of its RG policies and programming. Three key paths of research were being used: 1) internal research methods in conjunction with Corporate Learning, including OLG s Public Awareness and Employee RG Surveys; 2) collaborative research projects based primarily on Memoranda of Understanding (MOUs) with the Responsible Gambling Council (RGC) and Ontario Problem Gambling Research Centre (OPGRC); and 3) multi-jurisdictional research and providing access to independent researchers in order to advance broad knowledge of problem gambling and inform RG programming across jurisdictions. These research pursuits provided a strong foundation for OLG s work to improve the scope and effectiveness of prevention and mitigation responses on a broad range of RG issues across all lines of business. A status update on the gaps and opportunities identified in OLG s 2010 submission is provided in Table1.0. Table 1.0 Gaps and Opportunities in 2010 Submission Annual Employee Survey: Amend survey to specifically gauge training effectiveness Current Status Update Completed: The Annual Employee RG Survey has provided valuable insights for improving the RG Training program. See WLA Program Element 2: Employee Training Enhance Player Research: Conduct qualitative and quantitative research to evaluate RG Customer Education initiative, It Pays to Know (also see WLA Program Element 7: Player Education) Completed: Survey has been launched at Gaming Sites and sponsorship events. Targeted Player Communication: Research to support implementation of predictive RG tools, including analysis of player card data to identify patterns and variables that may indicate higher risk players Ongoing: An RFP has been developed for a vendor to analyze play behaviour generated through player/loyalty cards. Data will be used to send customized RG messages to players of different risk levels to promote informed choice. This initiative is also discussed in WLA Program Element 4: Game Design. 18
21 Gaps and Opportunities in 2010 Submission Multi-Jurisdictional Research: Participation in ILC RG Sub-Committee (ILC-RGCC) Current Status Update Continuous: OLG is an active participant in the ILC-RGCC. OLG s Executive Director, Policy & Social Responsibility is currently Vice-Chair of the RG Sub-Committee. The ILC-RGCC has conducted several research projects (described on page 28/29) which OLG has both participated in and benefited from, including national inventories for Self-Exclusion and RG training; RG National Standards Framework; Self-Exclusion Treatment Motivation Video; RG information Centres Evaluation Framework and research to identify the best approach for communicating statistical information for electronic gaming machines (EGMs). OLG participation on the ILC-RGCC is also discussed in WLA Program Element 9: Stakeholder Engagement. Employee Training: Respond to RG Employee Survey to enhance RG training. (also see WLA Program Element 2: Employee Training) Continuous: The new training module discussed in the 2010 submission was implemented and subsequent improvements have been made. Enhanced RG training provides more interactive practice opportunities that give employees the opportunity to apply skills and knowledge and, in so doing, build confidence. See WLA Program Element 2: Employee Training PROGRAM STATUS: 2011 TO PRESENT POLICIES AND PROGRAMS OLG s RG research program and strategy is a well-established and vital component of overall RG Program development and evaluation. Using a multi-disciplinary and coordinated approach, OLG works with RG stakeholders, academics and independent market researchers to ensure RG programming is relevant, effective and evidence-based. OLG s commitment to enhancing RG and problem gambling knowledge extends well beyond OLG s RG Program. OLG strives for data transparency and readily provide academics, clinicians and treatment counsellors with anonymized player data and comprehensive reports outlining OLG s on-the-floor RG interactions and Self-Exclusion program statistics. The goal is to advance knowledge, share information and deepen a global understanding of what makes an effective RG program. OLG s research program has three specific components: OLG Program Research, Multi-Jurisdictional Research and Research Facilitation. These research-type groups differ slightly from the 2010 groupings in order to more accurately reflect the broader range of research initiatives with which OLG is currently involved. OLG Program Research includes qualitative focus groups, market research surveys and research studies conducted in conjunction with external third parties such as RGexpert academics and interest groups, including OPGRC and the Centre for Addiction and Mental Health (CAMH). All OLG Program Research has been commissioned and designed by OLG to meet specific program needs or address particular gaps. Multi-jurisdictional Research is a specific type of collaborative research where OLG, along with more than one other provincial jurisdiction, is a study participant or a source of data for the research. Research Facilitation involves providing researchers with information around relevant OLG policies and practices as well as access to OLG sites, employees and customers. 19
22 Lastly, in response to the new AGCO standards that require OLG to ensure RG policies are kept up to date and relevant and reviewed periodically for effectiveness, OLG has RG Program directives to review RG programming in its Gaming operations every three years to ensure programming continues to be accurate; up to date with current OLG policies and procedures, research and knowledge; and reflective of industry best practice. Research can be an important part of these reviews by providing a benchmark to evaluate programming, being a methodological component of the review, or providing a means to answer questions or resolve issues raised by the review. OLG Program Research QUALITATIVE RESEARCH OLG uses qualitative research to better understand how players respond and interact with OLG gaming products and player information. Focus groups and advisory panels are an interactive way to gain immediate feedback that informs RG programming. In particular, OLG strives to better understand its players so that RG information can be communicated in a way that is culturally meaningful and specific. In 2013, we conducted a series of qualitative research studies to probe how different cultures internalize and respond to RG messages. The results of these findings will inform OLG s 2014 ethno-cultural player education strategy. Understanding Chinese and South Asian Players In 2013, OLG commissioned a third-party market research firm to interview Chinese and South Asian (Muslim and Non-Muslim) gamblers to understand the drivers, receptiveness and perceptions of RG and problem gambling (PG). The results enabled an indepth examination into the differences in how various ethnic cultural groups perceive PG, RG and marketing communications. Interestingly, the results indicated that the path to gambling varied tremendously by culture depending on social acceptance within the community. For example, Chinese participants tended to have early exposure and broad penetration of gambling behaviours in their communities. South Asian, and especially Muslim participants, generally had no early imprinting; gambling was something they discovered in Canada and is seen as innocent fun and entertainment by Non-Muslims but inappropriate behavior by Muslims. All cultural groups interviewed viewed gambling loss as a potential pathway to addiction and danger. The Chinese respondents found balance in loss by seeing it as a way to avert other bad luck. The South Asian Non-Muslims found perspective in loss by seeing it as the cost of having fun. Loss for Muslims confirmed the error of their ways and created more guilt and shame. OLG is working to develop an ethno-cultural player education strategy and deepen stakeholder relationships with multiple ethnic cultural groups. These findings will help formulate messaging that will resonate with specific cultural groups. The future direction for ensuring information accessibility and message dissemination through multi-media will also be considered. (For more information, please see Multicultural Marketing in WLA Program Element 7: Player Education.) Understanding Players from Aboriginal Communities Similar to the qualitative research with Chinese and South Asian Players, OLG conducted a series of focus groups in 2013 to better understand its Aboriginal Players. Results from the qualitative groups, held in Toronto and Thunder Bay, suggest some intriguing potential insights about Aboriginal persons and their relationship with gambling: persons from the Aboriginal community may have early exposure and broad penetration of gambling behaviours in their communities starting with bingo, then broadening to other forms of gambling once they reach age of majority gambling may be a part of the social fabric of the community extremely widespread and public the need for money may be the greatest driver, outstripping any social benefits and the enjoyment of play particularly in Northern Ontario, there may be a sense of resignation around problem gambling and a belief that it is difficult or even impossible to help a person unless they want to be helped persons from the Aboriginal community may have little expectation of external support, as many have been disappointed when they have tried to reach out for help RG efforts by OLG appear to be evident in that many had RG keepsakes in their pockets and have participated in RG events or Self-Exclusions; nonetheless, the concept of trained employees and interventions at the Gaming Sites were not considered 20
23 Aboriginals seem to be painfully aware of the impacts of loss in their community and work hard to implement controls or avoid temptation for themselves These findings were shared with the Ontario Aboriginal Responsible Gambling Program (OARGP), a group funded by the Ministry of Health and Long-Term Care that seeks to develop culturally relevant ways to address the risks associated with gambling. In 2014, OLG hopes to work collaboratively with OARGP members to implement relevant programming based on these findings. (For more information, please see Aboriginal Advertising Campaign in WLA Program Element 7: Player Education.) Player perceptions of knowyourlimit.ca Since its launch in 2009, the tools and information on knowyourlimit.ca have been assessed and have evolved to include a host of new resources and tools for players. In December 2012, a third-party research firm conducted qualitative focus groups in order to assess the effectiveness and value of tools and information on knowyourlimit.ca, and to determine which features were interesting versus those that were dull. Overall, knowyourlimit.ca was perceived as relatively appealing and providing interesting, useful information. Participants reported that navigation was easy and user-friendly, and that the layout was simple and straightforward. At the same time, however, there was no enticing factor that would bring players to the website. Part of the problem is the nature of RG information, which always seems to be useful for somebody else, but not for myself. OLG is currently working to develop and segment content that will appeal to all individuals on the spectrum of problem gambling, from non-gamblers to recreational gamblers to at-risk gamblers to problem gamblers. The study results also generated ideas on how to drive users back to the site and increase repeat visits. (For more information, please see knowyourlimit.ca in WLA Program Element 7: Player Education.) Classification of Slot Machines OLG is developing a strategy to inform gaming choice and enhance the gaming experience by educating players on slot machines structural characteristics. In 2013, OLG commissioned focus group testing by a research firm to help understand players knowledge levels, decisionmaking approaches, informational needs and preferences around slot play, as well as gather reactions to different proposed slot machine characteristics. The focus groups examined players perspectives on the preference, usefulness and communication of information around volatility, odds of winning and payback percentage. Perspectives were also analyzed according to play frequency, age and Asian ethnicity. The findings suggest that the game factors that influenced slot choice are denomination, jackpot size, bonus rounds and game style which in turn influence expectations around play experience and duration. Most participants valued information on volatility and bonus round hit frequency, which would seem to be most helpful in situations where the players are unfamiliar with the machines. Many players value information that helps them decide on a game, but it must be made available in the moment and ideally on the machine. Preplanning is not typical for most players, given that their choice of game is often spontaneous and also influenced by what machines are available. Following the focus group research, OLG is now engaged with academic researchers from the University of Waterloo to validate and expand the research objectives of this project. See below for a description of the proposed research (Classification of Slot Machines in Ontario: Providing Relevant Information to Players on page 25). The CEO Player Advisory Panel - Bridging Problem Gamblers to OLG s Executives In 2012, the first Executive Advisory Panel took place for OLG s CEO to gain first-hand information on the experiences of problem gamblers. Panels are conducted by a treatment provider and intended to provide OLG executives with insights and unique perspectives on the potentially negative effects of OLG s gambling products and environments. To date, OLG has facilitated three panels where problem gamblers have provided extensive input on a range of topics, including gambling motivations, employee interactions at gaming facilities, RGRCs, Self-Exclusion, Internet gambling and RG play management tools, and the Chinese gambling and problem gambling experience and context. A fourth panel is scheduled for April 2014 and will focus on Charitable Gaming and RG awareness. As OLG s RG strategies and practices continue to evolve under Ontario s Charitable Bingo and Gaming Revitalization Initiative, obtaining direct feedback from a roster of gamblers represents an informative touch point for the RG Program. 21
24 OLG will continue to expand its topic selection for the panel. Possible future topics include sessions with family members of youth gamblers, women gamblers and other ethno-cultural groups such as Aboriginals. OLG will use the information gathered from these sessions to better understand the needs and concerns of specific demographics. OLG MARKET RESEARCH SURVEYS Employee RG Awareness Survey Every year since December 2005, OLG administers an online Employee RG Awareness Survey that tracks employee awareness and knowledge on RG concepts and behaviours. The objectives of the survey are to: 1) measure employees level of RG knowledge; 2) understand employee views on the importance and performance of various aspects of OLG s RG policies and programs; and 3) compare results year over year. OLG will continue to use results from the Employee RG Awareness Survey to inform the level of RG knowledge of gaming and non-gaming employees, and will continue to develop initiatives to engage employees in RG-related education and information. Results also provide a look at what elements employees find to be most important and will help to guide OLG s direction on what are key priorities for employees. RG Player Awareness Survey Since 2005, OLG has been tracking awareness, perceptions and knowledge of Ontarians on responsible gambling. In 2011, OLG revised the RG Player Awareness Survey to reflect new research needs and, as a result, the survey now focuses more on program awareness and effectiveness among gamblers and lottery players. The main objectives of the research are to: understand general perceptions of responsible gambling and level of knowledge about gambling among players understand the effect of gambling myths on playing patterns measure awareness of OLG Responsible Gambling initiatives assess usage and effectiveness of OLG Responsible Gambling initiatives The RG Player Awareness Survey provides OLG with year over year comparisons of players levels of RG knowledge, which allows OLG to analyze where improvement occurred and where there is still work to do. Survey results guide OLG s player education program priorities and initiatives, including information dissemination. Targets for player perceptions and knowledge are set, tracked and reported through OLG s RG Scorecard and Measurement Report. Treatment Provider Survey In 2012, OLG conducted an online survey of treatment providers across the province to determine key areas of engagement. The objectives were to: understand how effectively OLG is communicating information to treatment providers determine the best methods of communicating information to treatment providers understand how effective the process and procedures are for Off-Site Self-Exclusion registration at participating treatment providers Results from the treatment provider survey inform OLG about the most effective and desirable ways of communicating information to treatment providers. The survey also provides an evaluation of the strengths and weaknesses of how Off-Site Self-Exclusion registration is executed, and provides an opportunity to adjust and improve practices or procedures that are ineffective. (For more information, please see WLA Program Element 8: Treatment Referral Monitoring and Evaluation and Gaps and Opportunities.) Mystery Shop Until 2013, the Gaming division had a Mystery Shop program whereby approximately ten to 12 times per month, a mystery shopper visited a Gaming site and posed a series of customer service questions to any employee on the gaming floor (e.g., What machine do I have the best chance to win with? I am here too much, is there something I can do to keep me out of here? ) to assess a gaming site s ability to serve players and find areas of improvement that can impact the customer experience. OLG s Mystery Shop program produced strong evidence that gaming employees are knowledgeable and responsive when faced with an inquiry regarding RG. Though the Mystery Shop program was discontinued at the end of 2013 for non RG-related reasons, OLG continues to monitor and evaluate employees responsiveness to customer service. (For further details, please see WLA Program Element 2: Employee Training.) 22
25 Vital Signs Vital Signs is a monthly telephone survey of 400 randomly-sampled Ontario adults that measures OLG s brand health and reputation. The survey collects opinions and perspectives in six areas: 1. Overall Image 2. Public Trust 3. Public Support of the Industry 4. Responsible Gaming/Social Responsibility 5. Player Experience 6. Community Partnership This survey reaches a general population outside of our typical player and employee populations. It allows us to evaluate our engagement efforts with the public through their perception of RG in Ontario, and helps guide future community partnerships or campaigns. It Pays to Know Participant Feedback Survey The It Pays to Know (IPTK) kiosk promotion has proved to be a successful means of gathering valuable information from our gaming customers. The promotion campaign includes a survey with questions regarding personal play habits as well as beliefs in gambling myths. OLG analyzes the play behaviour and gambling beliefs of customers that had played at an OLG slots or casino facility in the 60 days prior to and post promotion to assess any behavioural and attitudinal impacts of exposure to the campaign using several different metrics. The survey has been launched at gaming sites and sponsorship events through special kiosks, and in the promotion attracted over 35,000 participants. (Please see WLA Program Element 7: Player Education for more details.) As a corollary to the IPTK onsite campaigns, a successful online promotion was implemented on knowyourlimit.ca to drive traffic to the website. In 2013, a trivia component was added to the promotion to help generate awareness and increase participation. The success of this campaign will direct future opportunities to cross-promote on other OLG sites such as olg.ca and at other relevant lottery touch points and prizing centres. The results also guide the development of future player education materials, external RG messaging and communications, and focus areas for future RG initiatives. COLLABORATIVE RESEARCH OLG Responsible Gambling Innovations OLG engaged an external consulting/research firm to conduct a literature review in 2014 to inform future RG innovation in three areas: 1) gambling accessibility 24/7 operating policy; 2) the role of ATMs in harm reduction measures at slots and casino facilities; and 3) providing research access to gambling/player data. In order to develop options in these three areas, a multi-faceted approach was taken that included a review of research literature, a jurisdictional scan of policies and practices in Canada and internationally, consultation with international experts, and an analysis of the operational and political context of OLG, including OLG s existing and potential collaborative relationships. Since previous evidence-based research is limited in this area, OLG will continue to support research to better understand the risk to players and player profiles, including those who are more likely to gamble at certain times of the day or regularly use ATMs. This information will inform policy development and provide more customized responses to customers/gaming employee interactions and RG messaging. Additionally, the report will help guide OLG in developing requirements and policies involving researcher access to player data. Reducing Erroneous Cognitions and Facilitating Adherence to Monetary Limits During Slot Machine Gambling: 30-day Follow-up Study In , OLG, as part of the Interprovincial Lottery Corporation (ILC), collaborated with Ontario Problem Gambling Research Center (OPGRC) and academic researchers from Carleton University and the University of Waterloo to produce a nine-minute animated video, The Slot Machine: What Every Player Needs to Know, to educate gamblers on how slot machines work. In 2012, the group produced a three-minute version of the same video and then conducted research to evaluate the short versus long versions with respect to their impact on players erroneous cognitions, gambling motivation/ attitudes and adherence to money-limiting strategies. The findings indicated that the animated educational video was effective in changing cognitions and behaviours in the short term and that both videos were effective for different situations or audiences. The effects waned after 30 days however; suggesting a single exposure to the animation 23
26 video is insufficient to produce lasting behavioural change. As OLG continues to develop player education materials and tools, reinforcement of repeated exposure to communications will be taken into consideration. 2) creating material (e.g., brochures, slot machine labels) to be provided in the casino to players regarding gambling concepts; and 3) conducting a research study to determine the efficacy of the material provided. As a result of this study, the three minute video is currently featured on knowyourlimit.ca. Analytics show that it is one of the most commonly viewed RG tools on the knowyourlimit.ca website. Through OLG and the OPGRC, this video has been licensed free of charge to dozens of organizations (clinicians, gaming operators, RG prevention specialists) across many jurisdictions, and is widely regarded as a leading tool in gambling education. Link: Identifying Problem Gamblers in Gambling Venues in Ontario In 2013, CAMH gathered and analyzed the perceptions and opinions of 130 OLG gaming employees in a research study to understand: 1) casino employees experience with potential indicators of gambling-related difficulties, 2) perspectives of, and responses, to such indicators, and 3) the effectiveness of OLG RG employee training in addressing such issues. The study s findings will be used to evolve RG programming such as employee training to place greater emphasis on how to sensitively and appropriately respond to signs of problem gambling. As well, the findings may also help improve RG customer assistance by suggesting ways to facilitate efficient information sharing and communications between employees regarding customers and RG interactions before, during and after work shifts. (For more information, see WLA Program Element 2: Employee Training.) The following collaborative research projects are in various stages of development. These are projects that have been approved conceptually but whose details are still being considered, or projects that are in the procurement or design stages. Classification of Slot Machines in Ontario: Providing Relevant Information to Players This project is intended to use the results from the qualitative research of Classification of Slot Machines, described above, to further the OLG s RG strategy by: 1) surveying gamblers who have higher gambling frequency than those surveyed in the focus groups; The main goal of this project is to have a graphical label on each slot machine to provide information about gambling concepts such as volatility, payback percentage and bonus mode hit frequency. The intent is to provide players with an enhanced gaming experience so that they can easily identify the type of game/machine (e.g., high versus low volatility) they want to play based on the machine s characteristics and the player s motivations for play. Subsequently, we wish to educate players on volatility, odds of winning, payback percentage and related concepts through easy-to-understand and easily accessible communications. Assessing the Impact of a Win/Loss Tool among Winner s Circle Rewards Members OLG is developing a tool that will promote RG by providing loyalty club players (members of the Winner s Circle Rewards) with accurate information about their play patterns. As currently designed, players will be asked to indicate how much money they have won and lost over the previous twelve months. Following this, players will be made aware of their actual play patterns, including any discrepancies between perceived and actual play. (Please see WLA Program Element 7: Player Education for more details.) OLG has commissioned an academic researcher from Carleton University to empirically test and systematically examine the win/loss tool from a responsible gambling standpoint. The proposed research will provide OLG with knowledge about how accurate its players are in terms of the amount of money they have lost. Importantly, this research will also provide initial data on whether the win/ loss tool helps gamblers alter their gambling behaviour. This study is viewed as a required first step in an examination of the responsible gambling impact of OLG s new win/loss tool. There is opportunity to gather future behavioural data from participants at the six-month and twelve-month mark. The effectiveness of the tool may wane over time, and there may thus be a need for a reinforcement session. 24
27 RG Advanced Training at Resort Casinos Two of Ontario s Resort Casinos, Casino Rama and Great Blue Heron Casino, are implementing OLG s Gaming employee RG Training Program in fall (Please see WLA Program Element 2: Employee Training for more details.) OLG is collaborating with the Centre for Addiction and Mental Health (CAMH) to conduct focus groups made up of employees who will complete the RG Advanced Training module. The aim is to better understand current employee knowledge and attitudes related to RG at Resort Casinos and any obstacles or barriers that will affect the implementation of the RG training program. Examples of questions include: What do you feel is appropriate for you to do in terms of promoting RG, given your role? Describe any job aids or tools that guide how you respond to customers. Do you have any apprehensions about receiving this training? Will you be apprehensive in implementing this training into your daily job duties? These focus groups will help OLG, CAMH and the casino operators understand the level of buy-in and support from supervisors in adopting the concepts and approaches that will be introduced within the RG Advanced Training Module. In addition, the focus groups will help identify areas for communications and tactics to help training facilitators tailor their delivery approach for optimal effectiveness. Self-Exclusion Reinstatement Tutorial Evaluation OLG is collaborating with CAMH to develop a tutorial designed to provide players with practical information on game odds, safe gambling tips and player control tools when they choose to return to gambling after Self-Exclusion. The content for the tutorial will be recommended by CAMH and will be used for landbased as well as online reinstatements to igaming. Once the tutorial is completed, research is being planned to evaluate the effectiveness of the reinstatement tutorial at reducing the risk of recurrence of problem gambling by the player. The reinstatement tutorial evaluation will provide an opportunity to collect anonymized data that can be used to improve the Self-Exclusion program and reinstatement process, and to enhance future player education initiatives and RG messaging. Responsible Gambling Training Research OLG has engaged CAMH to conduct a three-study research project that will focus on: 1) effectiveness of RG training and reinforcement activities and employees retention of the training; 2) the association between employee satisfaction and RG skills; and 3) player perceptions of employees responses to customer interactions. The project is also discussed in the Gaps and Opportunities section of WLA Program Element 2: Employee Training. Study one aims to: investigate responsible gambling knowledge following both online and classroom RG training and reinforcement training investigate employee satisfaction, knowledge/skill, confidence and use of RG skills and strategies Study two aims to: investigate what RG knowledge is best/worst retained over time evaluate employee-observed Red Flag Behaviours (behaviours that indicate a customer either doesn t understand how the games work or may be experiencing difficulties with their gambling) and reported RG responses evaluate the links between employee characteristics and Red Flag responses Study three aims to: explore player perceptions of employee RG responses evaluate player-reported Red Flag Behaviours and the RG response experienced by the player investigate the links between player characteristics, Red Flag Behaviours and RG responses This research will be conducted over a two-year period and will provide insight into future directions of OLG s RG employee training and what information is wellretained over time. Results will be used to better support employees with information and relevant RG skills during employee/customer interactions. Further Research on Customized Risk Profiles OLG is pursuing research to improve methods to communicate customized RG messages to players of different risk levels to provide a greater level of informed choice to their gaming experience. Research to inform player risk profiles will help guide development of RG messaging and communications. This will allow for more relevant personalized messaging to be communicated 25
28 to players to ensure the appropriate information and support are being provided. As described in WLA Program Element 4: Game Design, the establishment of a new Gaming Management System (GMS) in accordance with the Modernization plan will provide OLG with a degree of player information that it has not had in the past. OLG is currently working to procure a vendor to develop a risk algorithm for our land-based gaming sites. OLG will be able to use the data generated through player/loyalty cards to analyze play behavior and identify players that may be exhibiting various levels of risk. Multi-Jurisdictional Research OLG participates in numerous research projects that involve the participation of various provincial jurisdictions. In this type of research, OLG, along with other provincial jurisdictions, are study participants in the sense of being sources of data to be analyzed for the research project. Responsible Gambling Council Insight Each year the Responsible Gambling Council (RGC) conducts a multi-methodology research study in a specific RG area to inform RG policy decisions for the gaming industry. These research studies typically include an extensive literature review, focus groups with gamblers, interviews with key stakeholders and a discussion forum of experts. OLG supports this research not only as a funder, but also as a participant by providing data for RGC analyses (e.g., OLG policies and current practices) and participating in the discussion forum. The following is a list of the Insight research that was conducted since 2010: Insight 2010 Informed Decision Making: This study identified ways to inform players choices when gambling and provided policy recommendations on how best to generate informed decision-making amongst gamblers. Insight 2011 Responding to Patrons with Potential Gambling Problems: This study developed a framework of best practices for gaming providers and employees to respond to customers who may be at risk of developing a gambling related problem. Insight 2012 Responsible Gambling for Lotteries: This study investigated the current RG practices for lottery across Canada and other jurisdictions. The report recommended ways that current practices could be improved and explored possibilities for development of new practices. Insight 2013 Best Practices in Responsible Gambling for Player Incentives at Land-Based Venues (in progress): This study will explore the practice of providing players with incentives from an RG perspective and make suggestions for how player incentives could be done in alignment with RG. OLG has already provided to RGC the following information on its own policies and procedures: policies for loyalty programs, bonuses and promotions procedures for employees for loyalty programs, bonuses and promotions employee communications or resources (newsletters or messages with updates and/or information about RG, new promotions, bonuses, etc.) designated employee training RGC s Insight studies are an important source of information for OLG because they are both practical and policy-oriented. They provide insight and recommendations for best practices in a way that can inform or identify future directions and any potential changes to OLG s existing RG policies and programming. ILC RG Subcommittee Since the 2010 WLA submission, OLG continues to be an active participant in the RG Sub-Committee of the Interprovincial Lottery Corporation (ILC-RGSC) and has served as committee Vice-Chair since One of the benefits of this multi-jurisdictional body is to share expertise and resources in RG program development and research projects. The ILC-RGSC has conducted numerous collaborative research projects listed below. National Inventories of Program Elements for Self-Exclusion and RG Training In 2011, ILC contracted a consulting firm to conduct two separate extensive information-gathering inventories of the Self-Exclusion and RG employee training programs administered in the ILC jurisdictions. The purpose was to understand how the programs operated in the various provinces and identify similarities, differences, challenges and potential service gaps in the structure and administration of the programs. The research findings from these two reports were used as resource documents for the validation process in the RG National Standards Framework project. 26
29 RG National Standards Framework The vision for the RG National Standards Framework project is for Canadian operators to lead industry participation in the global evolution of RG standards across all types of gambling. This framework draws upon the work of other ILC-RGSC projects to assess the state of RG programming in member jurisdictions and create national standards for responsible gambling. The framework will also create a structure for the ILC-RGSC to advance other common interests including standardizing RG approaches to emerging technologies and the ability to negotiate with vendors and service providers. When complete, the RG National Standards Framework will express common elements in the form of statements of risks that RG seeks to address, standards for meeting those risks, and common control activities under those standards. The framework will not prescribe control activities, as these will be left up to each RGSC member to define and implement. The research elements for the development of the framework are provincial inventory surveys of gaming operations to validate the proposed risks, standards and common control activities; interviews with key stakeholders from provincial jurisdictions; and benchmarking and gap analyses. ILC-RGSC has contracted these activities to an external consultant who won separate competitive bids for two phases so far Self-Exclusion and RG Training and expects to have a set of approved risks, standards and common control activities for each of these areas by May Other remaining phases include employee engagement, player/ public education, research, marketing communications, stakeholder relations and other topics as they develop. Self-Exclusion Treatment Motivation Video The ILC is working with the OPGRC and academic researchers from University of Sydney, Université Laval and the University of Guelph to produce an empirically-tested video to improve the links between Self-Exclusion and treatment by motivating self-excluders to seek treatment at the time of registration. The project has two research components: focus groups with self-excluders for input into the development and production of the video field-testing the video at gaming sites on actual selfexcluders at the time of registration using a random experimental survey design with two, potentially three, conditions, including a control group (depending on number of videos to be tested) The project has incurred numerous delays but one video has been produced and a second video, taking a different persuasive approach, is being considered. If the second video is approved, the field-test experiment will have three conditions, which further strengthens the experimental design. Field testing is expected to begin in the summer 2014 in various jurisdictions across Canada and the study findings should be available in RG Information Centres (RGIC) Evaluation Framework Responsible Gambling Information Centres (RGIC), known as RGRCs at OLG, provide player education and information about the key principles of gambling, costs of a typical gambling session, tips on responsible play, as well as referral and support services at gaming sites. While RGIC program evaluations have occurred across Canadian jurisdictions, there has been growing awareness of the need for developing national evaluation standards. This initiative seeks to obtain standardized data that are nationally comparable and reveal important trends in RGIC operations, which in turn will open new avenues for continuous program improvement and the sharing of best practices. After extensive consultation and involvement by the respective provinces, the evaluation framework is completed and all provinces with onsite casino information centres are now collecting program statistics using the common framework. Future program evaluations will use the evaluation framework to obtain comparable crossjurisdictional results that can lead to the identification of program gaps and opportunities which can be addressed by the RGSC. Electronic Gaming Machines (EGMs) Odds/RTP Language The ILC-RGSC seeks to provide players with information about certain game characteristics in a useful and meaningful way that will inform their decision-making around gambling. The RGC has undertaken a research project on behalf of the ILC-RGSC to empirically identify the best approach for communicating statistical information for electronic gaming machines (e.g., Return to Player and Odds of Winning information) and to develop and refine specific ways to do so. 27
30 The project had two separate but complementary research elements. First, focus groups were conducted with players in Vancouver to obtain player understandings and feedback on various ways to communicate information. RGC identified the most promising approaches to communicating game characteristics and tested them on a large sample of gamblers taken from BCLC player panel (N=756) for their effects on players interpretations and knowledge. The RGC study enabled BCLC to propose a specific standard for providing this information, which is currently being planned for focus group testing with a sample of gamblers from two major cities. Once the standard for communicating this information is finalized, a separate video lottery terminal (VLT) research component will be required to support all regions. Facilitating Research Effectiveness of a Brief Educational Intervention and ATM Removal in Reducing Erroneous Cognitions and Over-Expenditure during Slot Machine Play In 2010, OLG provided access to researchers to conduct a study at OLG Slots at Mohawk Racetrack and Flamboro Downs to investigate the effectiveness of a short animated educational video to modify cognitive and behavioural risk factors for problem gambling associated with slot machine players. Total recruitment for the study was 1,511 participants. The research findings showed the video to be effective in changing people s understanding of the games and attitudes towards playing in the immediate term. However, there was no evidence of changes in actual reported behaviour. A second purpose to the study was to test whether the removal of Automated Teller Machines (ATMs) from the gaming floor would improve problem gamblers adherence to their spending limits. The findings suggest that, although ATM removal may have reduced expenditures on the initial day of testing, there was no such reduction reported after 30 days. This research contributes to the effort to fully understand the effects of ATMs on gaming floors. OLG has used this research to help inform best practices for the placement of ATMs at gaming sites and support its policy position. A Test of Transferability of Findings of Casino Design Effects from the Lab to the Casino Floor In , researchers conducted a study at an OLG casino to test the transferability of results found in a research lab involving the effects of casino design elements on at-risk gambling behaviour (N=223). Anecdotally gamblers tend to feel they would gamble the same way regardless of whether they were gambling in a research lab or casino environment. However results in the lab demonstrate that specific casino décor elements can increase potential at-risk tendencies. The results of this study will help advance the discussion on the effect of casino design elements on player behaviours. An Assessment of Gambling and Problem Gambling among Older Adult Casino Customers This study is currently in progress and aims to assess the impact of casino and slot machine gambling on seniors players in Ontario. OLG provided researchers access to seven OLG Gaming Sites to recruit a total of 2,100 participants. Older adults may be considered a vulnerable population for problem gambling consequences since many are on fixed incomes. In facilitating this study by providing researcher access, OLG wants to further advance the understanding of the gambling experiences of this group and to enhance their player experience while providing the best possible support. Erroneous Cognitions and Near Misses In 2013, OLG provided researchers site access to conduct a study to investigate if players believe near misses are reflective of their skill, especially with use of the stop button. A belief in having some control over the outcome of a game is a commonly held belief. Gaining knowledge of a player s response to near wins and the use of a stop button will provide OLG with a better understanding of how to educate and correct players on this erroneous idea. MONITORING AND EVALUATION OLG stays abreast of current research needs and guides future research projects by responding to market research and survey results, program assessment needs, evolution of best practices and stakeholder feedback. Many of the internal reports described in WLA Program Element 10: Measurement provide valuable insight into potential research topics. In recognition of the potential in player data analysis, OLG established the position of Manager, RG Data Analytics in fall In addition to 28
31 other duties, this position is responsible for producing the following reports: Responsible Gambling Interaction Report, KnowYourLimit.ca Quarterly Report, Self-Exclusion Registrations and Self-Exclusion Reinstatement Report, and Responsible Gambling Resource Centre Report. OLG s annual RG Scorecard and Measurement Reports, as well as the RG Report on progress, also use relevant metrics and indicators that enable ongoing analysis. The stakeholder engagement activities described in WLA Program Element 9: Stakeholder Engagement are closely linked to the research direction described above. OLG s ongoing relationships with treatment providers, independent agencies, industry associations, and various groups of customers and employees are instrumental in identifying emerging issues and have a significant impact on various types of research projects that are pursued. In particular, OLG s longstanding relationship with OPRGC enables OLG to participate in impartial, well-designed research and offers OLG the opportunity to further general RG research by facilitating site access. OPRGC s new mandate to focus on the Knowledge, Translation, and Exchange (KTE) of problem and responsible gambling research offers expanded opportunities to effectively disseminate research. Monitoring best practices and staying aware of current research are also sources of new research areas. A key responsibility of the Social Responsibility Analyst position involves tracking, monitoring and circulating relevant RG research and RG best practices. This is done through multiple subscriptions to academic journals, news alerts and industry announcements. In addition, OLG s participation in the ILC RG Sub-Committee and its various RG standards-related projects has resulted in OLG being subject to monitoring or evaluation of its RG programming elements, particularly in relation to programming from other jurisdictions. As illustrated throughout this submission, both OLG-directed and third-party research is essential to monitoring and evaluating various RG program areas. Continuous improvements informed by qualitative and quantitative research are outlined in various WLA Program Elements, particularly Employee Training, Player Education, Treatment Referral and Game Design. Conducting program reviews and designing program improvements also inform and support the need for further research. For example, the collaboration with CAMH on RG training research described above is being conducted to determine how to best train employees and increase retention of RG information. GAPS AND OPPORTUNITIES Opportunities from Current Research Projects Many of the projects described above present further opportunities for additional research and improvement in other program areas. To summarize from the above content, the possible follow-up projects include: develop an ethno-cultural player education strategy and deepen stakeholder relationships with multiple ethnic cultural groups. Provide more hard-hitting messaging that directly addresses some of the negative consequences that could be associated with problem gambling such as relationship break up or impacts of large financial losses. Consider accessibility to information and how messaging will be disseminated through multi-media. work collaboratively with members of the Ontario Aboriginal Responsible Gambling Program (OARGP) to implement relevant programming based on research findings continue to enhance knowyourlimit.ca with segmented content validate and expand the research objectives of the Classification of Slot Machines in Ontario project use the CEO Player Advisory Panel to better understand the needs and concerns of specific demographics expand and conduct another Treatment Provider survey RG Program Directives for cgaming and Lottery While RG Program Directives for Gaming have been completed, OLG still needs to develop and implement RG Program Directives for cgaming and Lottery. As in Gaming, these Directives will ensure that every OLG Program area for these lines of business will have a Program Area Review at least every 36 months. These reviews will assess the major elements of an RG Program area and, in particular, ensure they reflect current research and knowledge, as well as leading/evolving best practices from other organizations and jurisdictions. 29
32 AGCO Regulatory Assurance AGCO regulatory requirements may require OLG to provide any research evidence for its RG programming. The abundance of primary and secondary research that OLG relies on will require OLG to have a technological infrastructure that can house such research in an easily accessible manner for audit purposes, as well as for OLG s own programming, communication or operational purposes. OLG is currently in the early planning stages for developing a comprehensive one-stop database to store numerous RG programming information, tools and resources, including primary and secondary research studies and projects. RG and Credit Practices To meet an AGCO regulatory requirement that gaming sites cannot provide credit to problem gamblers, OLG has developed RG Program Directives to be able to identify and respond to credit applicants who may have gambling problems. This programming will apply to any gaming site that grants credit to its customers to gamble. Given that this is a new area of operational concern for RG under Modernization, OLG plans to commission an external independent review of its RG programming for its RG credit services practices. This will include such research components as a literature review of existing practices and best practices in the areas of credit services, risk and problem gambling identification methods, and, if possible, an evaluative project to assess the effectiveness of the current programming. Data Governance Strategy WLA Program Element 3: Remote Gaming Channel With the launch of OLG s igaming platform, PlayOLG.ca, there is an opportunity to fully exploit the potential of OLG data to achieve innovation and leadership in responsible gambling by sharing anonymized data with RG researchers. OLG has engaged a third-party agency to conduct a literature review and provide recommendations on best practices for sharing data and will actively explore ways to develop a fair, proactive and purposeful process to support our RG Program and ongoing understanding of problem gambling. In 2014, we will be developing a process to enable data access for researchers in such a way that meets the objectives, values and operational requirements of OLG. 30
33 WLA PROGRAM ELEMENT 2: EMPLOYEE TRAINING At OLG, Responsible Gambling (RG) Training for employees positions RG as an extension of good customer service and provides important RG knowledge and skills to help ensure employees are able to promote RG to customers and provide assistance as required. This approach and its effects have been found to be important by OLG employees, players, the general public and problem gambling clinicians across the province. Since 2005, OLG has collaborated with the Centre for Addiction and Mental Health (CAMH) for their expertise in responsible and problem gambling and adult learning. We work together to co-design and co-deliver RG Training for corporate employees and for all four lines of business: Gaming, Lottery, cgaming and igaming. PROGRAM STATUS: 2010 SUBMISSION In OLG s 2010 WLA submission, employee RG Training was directed by the RG Code of Conduct which emphasized a culture of care with all employees having a role to play in supporting and promoting responsible gambling. The Centre for Addiction and Mental Health (CAMH) was a key partner in developing and delivering responsive training programs across all of OLG s lines of business. Three tiers of training were in place (General, Advanced and Reinforcement) and formed the basis of OLG s RG Training, with role-specific training being implemented where required. Monitoring and compliance activities including tracking training completion, employee evaluations, employee surveys and data collection provided understanding of employee s attitudes, awareness and comprehension to drive continuous improvement. A status update on the gaps and opportunities identified in OLG s 2010 submission is summarized in Table 2.0 and detailed in the update below. Table 2.0 Gaps and Opportunities in 2010 Submission Work with HR representative and RG Site Teams to plan and deliver regular RG educational reinforcement and evolve employee training Current Status Update In place: A formal training reinforcement plan was developed and deployed utilizing HR/Communications input and RG Site Teams. Revise RG code or augment existing Code of Business Conduct to formalize RG compliance In place: The RG Code of Conduct for Gaming has been revised to clearly articulate employee accountabilities with respect to RG. Separate, similar but customized RG Codes are currently in development for the other lines of business. Work with HR to include RG components in employee performance objectives and performance plans and integrate RG requirements into recruitment In place: An RG component has been included in all front-line gaming employee annual performance reviews. RG is integrated into employee recruitment as a mandatory component of New Hire Orientation. 31
34 Gaps and Opportunities in 2010 Submission Leverage It Pays to Know communications platform to better equip employees with resources and support employee awareness across all lines of business (also see Program Element: Player Education) Current Status Update In place: Internal communication materials to Lottery, Gaming and Charitable Gaming sites have been expanded. Work with HR to develop compliance reporting on RG training Improvements still needed: All Gaming Sites will be required to report RG Training completion status in a Quarterly RG Report as part of the OLG-Operated Gaming Site RG Program Directives. Continue to evolve training program with feedback from site level employees and customer tracking tools In place: A new training program has been developed and will be implemented at all OLG Gaming Sites by December 31 st, The new RG Reinforcement modules will be completed by all Gaming employees in the following calendar year (2015). PROGRAM STATUS: 2011 TO PRESENT Gaming RG Training POLICIES AND PROGRAMS When the OLG s 2010 WLA Level 4 submission was made, enhanced Gaming employee RG Training had just been developed collaboratively with learning and RG/PG experts from CAMH. The new training was subsequently deployed to over 6,000 Gaming Site employees and a completion compliance rate of 99.4 per cent has been obtained. The enhanced training focuses on empowering employees to Recognize, Respond to, and Report Red Flag Behaviours (behaviours that indicate a customer either doesn t understand how the games work or may be experiencing difficulties with their gambling) based on expectations identified in the RG Red Flag Guidelines. RG Training has continued to evolve for the past three years based on feedback from employees and customer tracking tools. In April 2014, OLG will launch newly enhanced RG Training for Gaming employees. The newly revised RG Training is focused on evidence-based approaches and application of knowledge and skills. Using non-clinical interventionist strategies, CAMH has evolved the Recognize, Respond, and Report model by validating it through independent research. Additionally, the model has been enhanced by the continuum approach, which helps employees recognize the nature of Red Flag Behaviours through the lens of frequency, complexity, and intensity. This approach also helps employees learn how to tailor appropriate RG referral and assistance messages based on the level of a player s gambling involvement and the associated risk. The newly enhanced RG Training has been refined with an added focus on serious Red Flag Behaviours reporting, enhanced Red Flag Guidelines, and formal elearning reinforcement modules. This program will be implemented at all OLG Gaming Sites by December 31, The new RG Reinforcement modules will be completed by all gaming employees in the following calendar year (2015). Improvements in RG Employee Training at OLG Gaming Sites have been developed and informed by various stakeholders and RG information resources such as RG Site Team meetings, Annual Employee Surveys and the RG Interaction Database. The RG Mystery Shop program described in the 2010 WLA submission, however, was discontinued at the end of fiscal The RG scores were consistently above 98 per cent in the prior years and therefore the program was not providing additional insight into potential improvements. The OLG Host Training, outlined in the 2010 WLA submission, received overwhelming interest from the Host cohort. Because of this and the important role Hosts have in maintaining relationships with Gaming customers, all Hosts are now required to complete Advanced RG Training. 32
35 RG Program Directives The RG Program Directives for RG Employee Engagement and Training document and standardize training across all Gaming Sites, including the program enhancements described above, as well as for the implementation of new training modules described below. Having been finalized in February 2014, they are currently being implemented. The new RG Training modules will broaden OLG s RG Training program and support Gaming Site employees in fulfilling other RG-related roles and responsibilities in addition to assisting customers who may have gambling problems or unhealthy gambling perceptions or attitudes. Development is underway for two new training modules: RG Marketing Training and RG Credit Services Training. Full implementation is expected to be completed by March RG Marketing Training The RG Marketing Training module will train employees involved in the development and approval of Gaming product marketing to conduct RG assessments on marketing initiatives, including all content, materials and channels used to deploy the initiative. This training will introduce employees to applicable RG standards in this area and explain general RG themes and principles that employees should consider when developing and approving any marketing initiatives, materials and communications. It will also describe available OLG resources that can assist employees in decision-making and producing RG-appropriate marketing content. RG Credit Services Training The RG Credit Services Training module will train employees who process customer credit requests from the site. Currently, OLG Gaming Sites do not offer credit; however, Resort Gaming Sites grant credit, and new service providers under Modernization are expected to follow suit. The module will train credit services employees to execute the policies and procedures for processing credit requests in order to prevent granting credit to customers who may have gambling problems. MONITORING AND EVALUATION OLG employee RG Training is informed by feedback from employees, customer tracking tools and third-party research and analysis. The development of the new RG Training in 2013 involved a Needs Assessment that included the measurable impacts of the 2011 RG Training, an update on the current RG Training Reinforcement, and recommendations to address RG Training needs going forward. A complete Training Evaluation Data Collection Plan including objectives, measures, data sources and collection methods, and roles/responsibilities was completed in December Customer Tracking: RG Interaction Reporting Database OLG s Gaming Employee RG Training focuses on developing skills and instilling confidence in employees to respond effectively to problem gambling warning signs as outlined by the RG Red Flag Guidelines. The interactions that gaming employees have with customers while responding to red flag behaviours are logged using the RG Interaction Reporting Tool. The data collected from the RG Interaction Reports is extremely valuable to the continuous improvement of OLG s RG Program. For instance, the entries help illustrate which Red Flag Behaviours are most commonly observed and what actions are taken in response to them. This information helps to shape and refine future RG training and contributes to the development of new RG Program elements like employee communications or training reinforcement tools. Also, the data from the RG Interaction Reports represents tangible assurance that employees are assisting customers displaying Red Flag Behaviours on the gaming floor. RG Interaction Reports are tracked and monitored on an ongoing basis by Gaming Site RG Champions, the Gaming RG Manager and the Manager of Social Responsibility Analytics. 33
36 RG Scorecard Results from the RG Interaction Reporting Database are also reported publicly in OLG s RG Metrics Report: Measuring Awareness and Outcomes. Results from the past three years in measuring RG education to players via OLG Gaming Employees are presented in the following table (Table 2.1): Table 2.1 Measure Indicator Results Source RG education to # of recorded interactions where RG players via OLG Gaming Employees employee provided a player with a verbal explanation of how Interaction Database OLG Gaming employees gambling works are trained to understand key gambling concepts and provide information and referrals accordingly. These # of recorded interactions where employee suggested taking a break interactions are tracked in an RG interaction database. The RG Program aligns training to assist employees in handling # of recorded interactions where employee followed OLG s Fatigue Impairment policy n/a the types of RG interactions that most commonly occur. Recording of interactions by employees is encouraged but # of recorded interactions where employee directed player to knowyourlimit.ca not mandatory. # of recorded interactions where employee directed player to an RGRC for more information # of recorded interactions where employee escalated the incident n/a to a senior manager # of recorded interactions where employees directed player to the Ontario Problem n/a Gambling Helpline # of recorded interactions where employee provided a Responsible Gambling or n/a Problem Gambling brochure # of recorded interactions where employee involved security n/a Total # of recorded interactions 1,
37 Employee Feedback A key contributor to the success of OLG s RG Training is the focus on addressing the needs of employees during the development process. Both the annual Employee RG Awareness Survey and Participant Surveys provide valuable insight for seeking improvements in the training. Results from both of these tools have helped to evolve and enhance training content. As an example, in multiple annual Employee RG Awareness Surveys, data indicated that employees needed improvement in confidence in responding to customers displaying RG Red Flag Behaviors. As a result, the enhanced RG Training provides more interactive practice opportunities to give employees the opportunity to apply skills and knowledge and, in so doing, builds confidence. Third Party Research A key piece of research which influenced RG Program improvements was a study entitled Identifying Problem Gamblers in Gambling Venues in Ontario, Canada. The authors of this study were the project leads from CAMH who were responsible for designing the latest Core, Advanced and Reinforcement modules of OLG s RG Training. Training enhancements were also based on a Training Needs Assessment completed in March 2013 by CAMH. The analysis summarized the findings of multiple responsible gambling program evaluation tools from various data sources including research evidence, Ontario-wide clinician focus groups, adult education/ training literature on workplace learning, anecdotal evidence based on training experience, and clinical feedback of treatment-seeking gamblers. Key findings and recommendations can be found in the attached report. ILC RG National Standards Framework As member of the ILC s Responsible Gambling Subcommittee, OLG led the project to develop a National RG Training Framework. The purpose of this framework is to identify national standards and control activities to meet those standards. The project inventoried and benchmarked training components across the RG training programs of ILC members, thereby enabling ILC members to monitor and assess their training against their national counterparts. This approach also allows the ILC to identify standards for training and formulate future aspirations for evolving the RG training programs of each ILC member, as well as for increasing the quality level of RG training in Canada on the whole. The outcome of the RG Training Framework is a set of risks, standards and control activities for RG Training that are flexible enough to incorporate existing differences in operating realities (such as lines of business), while at the same time driving the sector towards common best practices and new benchmarks for future performance. RG Program Area Review The RG Program Directives stipulate that Gaming employee RG Training will be formally reviewed every 36 months by OLG in consultation with Gaming Sites. The review will assess whether RG Training reflects and supports current RG policy and other RG Program Areas and is consistent with latest research and industry best practice with the aim of identifying potential improvements to training content, delivery and program monitoring. OLG may engage third party expert organizations such as CAMH to conduct the review and/or validate some or all of review results for quality assurance purposes. OLG Quarterly RG Report The RG Program Directives outline a set of quarterly reporting and performance measures that OLG must collect and document on RG Gaming Employee Training. This will enable assessments of RG Training s performance and effectiveness. These measures include training participation completion rates and the RG Site Report. GAPS AND OPPORTUNITIES Third Party Research Currently, there is minimal third-party academic research assessing the effectiveness and outcomes of Gaming employee RG Training. In the documentation listed above (see Third-Party Research), a recent study with OLG employees as participants is included. OLG plans to continue working with third-party academic researchers to improve the body of research and understanding of the effectiveness, outcomes and impacts of Gaming employee RG Training. Training Evaluation OLG will launch a newly enhanced Gaming employee RG Training in fiscal A key component of this program is the implementation of the Evaluation and Data Collection Plan described above. This plan will help evaluate the training s impact and guide the evolution of future enhancements. 35
38 Province-wide Program Consistency Currently, OLG s Gaming employee RG Training is deployed to all employees of OLG direct-operated gaming sites (19 sites in Ontario). The newly enhanced Gaming employee RG Training program will also be deployed for the first time to the privately-operated Resort Casino properties, Great Blue Heron Casino and Casino Rama, in fiscal Currently, there are two additional Resort Casinos properties, Niagra Fallsview Casino Resort and Caesar s Windsor, that do not have immediate plans to deploy OLG s Gaming employee RG Training. OLG intends to work towards standardization of Gaming employee RG Training, so that eventually all Gaming employees in Ontario will be required to complete mandatory and consistent RG Training. Compliance Assurance While the RG Program Directives outline documentation and reporting tools and requirements, there is no system for compliance assurance, and it is not clear at this time how the tools and requirements will fit within OLG s broader compliance monitoring and assurance regime. OLG is currently planning to establish a task force consisting of individuals from multiple OLG departments to set up this regime. Once set up, the compliance monitoring for the RG Program can be defined and implemented. Charitable Gaming RG Training POLICIES AND PROGRAMS Since 2011, OLG has delivered RG Training to over 600 employees at more than 20 cgaming Sites, for example, Charitable Gaming Centres (CGC). To help develop appropriate and effective RG training and to better understand employee responsibilities and challenges, OLG contracted CAMH to conduct focus groups with CGC employees in November Focus group results were used to develop RG training specifically tailored for CGC employees. CAMH also developed training content that was meant to standardize RG knowledge and expectations across CGCs. Building on experience in the Gaming environment, the RG Training for CGCs focused on employees roles and responsibilities. The Gaming model of Recognize, Respond, and Report was used for the cgaming environment with responsibilities divided between customer-facing employees and supervisors/managers. CGC-specific Red Flag Guidelines were created and serve as the focal point of training and a key instructional aid for guiding daily RG interactions. All CGC employees are required to take the core RG training, which is provided in a 30-minute online e-learning module. Supervisors and above are also required to attend a 2-hour in-class training session facilitated by CAMH. cgaming site volunteers are not expected to take the RG training, but are provided a one page handout in their orientation packages. MONITORING AND EVALUATION Training surveys are administered at the end of the e-learning module and in-class sessions to help refresh training content. RG Training is being rolled out as part of the Charitable Bingo and Gaming Revitalization Initiative described in the Introduction. Once the initial roll-out of training to Charitable Gaming sites is complete, OLG will re-evaluate the effectiveness of the RG Training through formal surveys and focus groups, similar to the needs assessment that was conducted for the RG Training for Gaming. Many of the learnings from the monitoring and evaluation tools described in Gaming RG Training are also used to enhance training for Charitable Gaming employees, particularly third-party research and the ILC RG National Standards Framework. As OLG moves forward with the documentation and standardization of its overall RG Program, cgaming Program Directives will be developed from the cgaming Program Description. Additional monitoring and evaluation tools, similar to those established in Gaming, will be incorporated and are described below. GAPS AND OPPORTUNITIES Corporate Learning Management System As part of the Charitable Bingo and Gaming Revitalization Initiative, a corporate learning management system is being considered to support all areas of employee training initiatives at CGCs. This will facilitate the implementation and design of RG training and reinforcement communication, as well as provide data and material to help third party researchers study the effectiveness of RG training in CGCs. 36
39 RG Interaction Database An RG interaction database similar to the RG Interaction Reporting Database for Gaming Sites has not yet been established in the Charitable Gaming environment. As such, there is a gap in gathering information on Red Flag Behaviours in cgaming. As the cgaming longer-term business plan comes to fruition, OLG will work towards filling this gap in the CGC operations. RG Program Directives for cgaming OLG is currently finalizing the design of its overall RG Program for cgaming sites, which is expected to be completed in April Upon finalization, OLG will create specific RG Program Directives to document and standardize the Program s policies and procedures for the CGCs. The cgaming directives, including RG Training, are expected to be fully completed and implemented by December Some of the program elements being planned will aim to increase RG engagement and build RG culture in the CGC environment (i.e., RG Coordinator, RG Code of Conduct, RG Marketing and Game Design Training, quarterly performance and reporting measures, and periodic program area review. (For details, see WLA Program Element 3 Retailer Program: cgaming.) Support Centre RG Training POLICIES AND PROGRAMS OLG has developed RG Training suited for the OLG Support Centre that supports the entire OLG enterprise. In order to ensure consistency across all lines of business, OLG engaged CAMH to help develop the core content, with input from the OLG Support Centre. This Training leverages the model of Recognize, Respond, and Report that is the basis for the other RG Training modules in other lines of business. OLG Support Centre is comprised of three tiers of support, with the third tier responsible for handling escalated RGrelated customer communications. Upon the launch of the OLG igaming Channel, the Support Centre will also serve as the Tier 3 response for the igaming Customer Care that handles inquiries and calls to igaming (see Program Element 5: Remote Gaming). All calls to OLG relating to treatment referrals, Self-Exclusion and reinstatement, players in distress or exhibiting red flag behaviours, in addition to any contentious issues unrelated to responsible or problem gambling, are escalated to Tier 3 Support Centre. Tier 3 employees take the in-class Advanced RG Support Centre Training. This Advanced Training is currently being refreshed and will focus on Self-Exclusion, reinstatement, crisis intervention, de-escalation, and linking individuals to appropriate resources. It will include specific instruction on recognizing, responding to and reporting Red Flag Behaviours, in the absence of visual cues. Red Flag Guidelines have been created specifically for the support centre environment that will to help the OLG Support Centre respond to different RG interactions. Following the launch of PlayOLG in 2014, Tier 3 Support Centre will also be provided with an online RG Reinforcement Tool and Resource Hub focused on providing practice to Support Center employees. This reinforcement tool and resource hub will allow for updated RG information to be communicated to employees on an ongoing basis. MONITORING AND EVALUATION Similar to RG Training for Gaming, training content will be continuously validated by feedback from employees, customers and third party research. Customer Care interactions will be reviewed to ensure training objectives are being met. Additionally, training surveys have been included in both the e-learning and classroom training that will provide feedback to help improve future iterations of training. All RG interactions are recorded and logged in various support centre databases. After the launch of igaming, support centre data can be used to identify which red flags are most commonly encountered and to tailor future training to address CSR needs. GAPS AND OPPORTUNITIES OLG Support Centre has a quality assurance process already in place in which calls are reviewed on a periodic basis. RG quality control is set to be embedded in that process within the next three years. As with the other lines of business, there is also an opportunity to use third party research to validate the effectiveness of RG Training within the support centre experience and to determine how it contributes to the overall customer experience. 37
40 Lottery RG Training POLICIES AND PROGRAMS In the 2010 WLA submission, Lottery RG Training was covered in WLA Program Element 3: Retailer Program. RG Training is a key component to the overall approach in ensuring Lottery Sales Operations are fully aware of RG as a core business strategy and are able to communicate RG information to the retail network on a regular basis. As such, RG Training is still mentioned in WLA Program Element 3. In order to present a consistent overview of OLG RG Training across all lines of business, we have also included details on Lottery RG Training here. The scope and reach of OLG s lottery business presents many challenges in implementing full scale retailer training. OLG s strategy has been to focus on integrating RG training into general training, thereby educating through the main points of contact with retailers. Current initiatives also extend our reach to lottery retailers and Customer Support. Lottery Sales Operations Training RG Training is a component of OLG Lottery Training for key lottery employees including: executives responsible for lottery sales and managers employees responsible for executing and overseeing the Lottery RG Program sales employees who provide support to retailers (i.e., sales reps or other individuals who regularly visit retail sites and oversee retailer practices in accordance with Service Provider requirements) Key Account Managers and related employees supporting Key Account Head Offices and their retailers employees responsible for internal operational compliance monitoring Lottery Retailer Training OLG works to ensure that lottery retailers have general awareness and understanding of RG and problem gambling as well as instruction on how to respond appropriately to customers who request RG-related information and/or assistance. To support the various materials and information sources as described in WLA Program Element 3: Retailer Program, OLG is currently piloting the launch of an online e-learning module for lottery retailers. The electronic version of training will facilitate future rollouts of new training content, evaluations, compliance and testing. OLG Support Centre OLG Support Centre received a refreshed RG Training in January This new RG Training, which was developed and delivered by CAMH, trained Support Centre employees on the skills to recognize and respond to Red Flag Behaviours. As a key point of contact for lottery retailers, these employees are uniquely positioned to answer RG questions and provide advice to lottery retailers. MONITORING AND EVALUATION Feedback from employees and customers and third party research drive continuous improvement in RG Training at OLG. As with other lines of business, content for Lottery RG Training will be continuously validated with periodic reviews to ensure training objectives are being met. Surveys have been included in both e-learning and classroom training sessions to provide feedback to improve future sessions. In regard to third-party research, the ILC RG National Standards Framework project described above will be instrumental in helping OLG identify improvements in content and delivery of RG Training for OLG Lottery Retailers. GAPS AND OPPORTUNITIES Lottery Retailer Training The ILC RG National Standards Framework project identified the need to increase accessibility of RG training to a greater range of retail employees. The online pilot training described above was conducted as a result of this analysis and the feasibility of expanding the scope will be explored. By expanding the e-learning environment, OLG will be able to track training completion and evaluate effectiveness, as well as implement a more comprehensive training and reinforcement strategy that covers a broad range of retail staff. In Modernization, the Lottery Service Provider will be required to administer OLG s RG Retailer training. To support this initiative OLG will be looking into possibilities for revising retailer training content to strengthen retailer capacity to address more effectively a broader range of RG customer-retailer interactions. 38
41 Additional Lottery RG Training As in Gaming, Lottery RG training will also extend beyond training frontline customer-facing personnel in responding to customers around RG-related issues to include training other Lottery personnel to execute other RG-related duties. Policies and procedures will be developed and implemented to assist Lottery Marketing employees, including third-party marketing service providers, to assess their marketing from an RG perspective and produce RG-appropriate marketing. The RG Marketing Training module described above will be used to support those policies and procedures. Lottery employees responsible for game design and development will also receive specialized RG Training. Employees involved in the design and/or approval of Lottery products will complete the RG Game Design Training module to promote RG appropriate games. This training will introduce applicable RG standards in this area and explain general RG themes and principles, and available OLG resources that employees should consider when developing, selecting or approving any new games or game designs. Lastly, RG Training will be reinforced periodically with regular RG communications delivered to Lottery employees. The successful delivery and reinforcement of RG training will be particularly important under Modernization where a new private sector Service Provider takes over Lottery operations. 39
42 WLA PROGRAM ELEMENT 3: RETAILER PROGRAM PROGRAM STATUS: 2010 SUBMISSION POLICIES AND PROGRAMS Three diverse retailer relationships were detailed in OLG s 2010 WLA submission: 1) retail outlets providing lottery products; 2) Charitable Gaming retail partners; and 3) independently managed Resort Casinos. In order to ensure integration of RG into operations, a balance of RG compliance and awareness measures were used. Contracts, policy directives, training programs, communication materials and other job aids were tailored to the different channels. Continuous improvement was directed primarily by training evaluations and the Mystery Shop Program. The gaps and opportunities identified in OLG s 2010 submission are summarized in Table 3.0 and are detailed in the update below. Table 3.0 Gaps and Opportunities in 2010 Submission Strengthen training for lottery retailers Current Status Update In place: RG Training is in place for Lottery Sales Operations, Lottery Retailer and OLG Support Centre. See WLA Program Element 2: Employee Training Develop and promote tools to help ensure engagement in RG initiatives among lottery retailers and Service Providers. In place/continuous: Ad hoc presentations as well as specific job aids offer opportunities to reinforce training and support dissemination of RG lottery information. See WLA Program Element 7: Player Education for information on knowyourlimit.ca messaging. Develop training and reinforcement program for Charitable Gaming In place/continuous: Mandatory RG Training for cgaming Site employees was introduced with two modules being available to employees based on their level of responsibility. See WLA Program Element 2: Employee Training Complete RG needs assessment for Bingo Partners to inform additional RG procedures, programs and targets Completed: OLG conducted a needs assessment among players and employees in The results were used to develop and disseminate player education materials which are fully described in WLA Program Element 7: Player Education. 40
43 Gaps and Opportunities in 2010 Submission Strengthen collaboration with Resort Casinos to help ensure consistent level of RG assistance and information Current Status Update Continuous: Continues to be a gap. OLG began early stakeholder consultations with Resort Casinos in 2013 to provide information on the RG Program and the development of AGCO control activities. In April 2014, AGCO will reconvene stakeholder consultations with Resort Casinos to determine how to adapt and implement the RG Program Directives for the resort context. In fall 2014, Great Blue Heron Charity Casino and Casino Rama will be implementing the latest version of OLG RG Training. Niagara Fallsview Casino Resort and Caesar s Windsor do not have immediate plans to deploy OLG s employee RG Training. OLG intends to work towards standardization of Gaming employee RG Training so that eventually, all Gaming employees in Ontario will be required to complete mandatory and consistent RG Training. See WLA Program Element 2: Employee Training Standardize data collection across Resort Casinos to support training and program evaluation Continues to be an opportunity/future implementation planned: OLG will be working in 2014 to harmonize its RG Program for Gaming Sites with that of the Resort Casinos to ensure all Gaming Sites within the oversight of OLG deliver a gold standard for RG programming under Modernization. The OLG-Operated Gaming Site RG Program Directives are the key policies and procedures for RG programming. The harmonization process for Resort Casinos is currently in the planning stage and implementation is expected to begin in May PROGRAM STATUS: 2011 TO PRESENT The OLG retailer relationships are most salient in the Lottery and cgaming divisions, with all product offerings, representing a portion of all the OLG Gaming Sites, have a similar retailer operating relationship in that external private sector companies operate these facilities under contract to, and oversight by, OLG. The large majority of Gaming Sites are operated directly by OLG. This will change under Modernization, however, as the private sector operating model under the resorts will be applied to all current OLG-operated gaming facilities and the dayto-day operations and capital development are transferred to the private sector. While expectations and requirements to adopt the OLG RG Program in the future are being built into the Gaming policies, contracts and agreements that will govern new Gaming Service Providers, OLG will need to harmonize the RG Program with that of the existing Resort Casinos to ensure all Gaming Sites within the oversight of OLG deliver a gold standard for RG programming under Modernization. The OLG-operated Gaming Site RG Program Directives are the key policies and procedures of the OLG RG Program that all Gaming Sites, including OLG and private sector operated sites, will follow. The harmonization process with Resorts began in 2013 and will reconvene in May 2014 with stakeholder consultations being scheduled to inform the planning stage. 41
44 For some program elements such as RG Employee Training, the transition process has begun. In the 2010 WLA submission, RG Training for Resort Casinos was included under Program Element: Retailer Program. For this submission, we included RG Training for Resort Casinos in Program Element 2: Employee Training to be consistent with the development of RG Program areas. Lottery and cgaming are the two lines of business that rely most on relationships with external retailers. Under Modernization, Lottery operations will be even further separated from OLG as the private sector takes over operations. Many of the program elements that support OLG Retailers for Lottery and cgaming are also described in other WLA Program Elements, especially Program Element 2: Employee Training, Program Element 4: Game Design and Program Element 7: Player Education. Lottery Retail POLICIES AND PROGRAMS Since 2010, OLG has introduced a number of measures to enhance our RG presence in the retail environment including training, message reinforcement and retailer job aids. Retailer RG Job Aids In September and October 2010, OLG Sales Specialists trained retailers using two updated job aids to initiate an RG dialogue and provide retailers with a straightforward, easily accessible reference document to answer RG questions. The first job aid, Responsible Gambling, provides retailers with an overview of RG, what their role should be, and includes guidelines for handling different problem gambling and RG-related issues. The second, Age Control, It s the Law, provides retailers with an overview of provincial regulations prohibiting selling to minors and outlines OLG s expectations to ensure all retailers ask for photo I.D. if a customer appears under the age of 25. These training documents were updated in January 2014 and distributed to retailers in January and February 2014 by our Sales Specialists. I.D.25 In December 2011, OLG introduced the We Expect ID button on all lottery terminals to assist retailers when manually checking a customer s identification. The We Expect ID button displays the current minimum date of birth required to purchase age-controlled products. This gives retailers improved capability to manually verify any type of ID. Manual verification will become increasingly important as the magnetic strip on Ontario drivers licenses is being phased out by our Government. RG Training One of the key methods of supporting retailers is by providing RG training to Lottery Sales Operations (including field sales, corporate and key accounts) to create awareness of RG as a core business strategy and communicate RG information to the retail network on a regular basis. (For details, see WLA Program Element 2 Employee Training: Lottery RG Training.) Reinforcement OLG also seizes opportunities to reinforce RG information. One key touch point has been Convenience U, one of the largest trade shows for Convenience and Gas retailers, who represent a significant portion of key account retailers. OLG uses the opportunity to present RG information in an engaging way and probe lottery retailers to correctly answer RG information questions. The Responsible Gambling Council has also been invited to participate as the distributor of key RG information. MONITORING AND EVALUATION I.D.25 Mystery Shop Program Throughout 2012 and 2013, the Mystery Shop program evaluated 2,390 stores to determine compliance with the I.D.25 directive. Results demonstrated 20 per cent of retailers did not require proper identification. Conversely, 80 per cent of retailers refused the sale. This data will be used to advance compliance measures for OLG s retail partners. Moving forward, OLG will look for additional opportunities to use mystery shoppers as a feedback mechanism for the efficacy of our RG Programs at the retail level. To support continuous improvement, OLG has begun tracking the review of its I.D.25 policy with retailers. Since January 2014, OLG has reviewed the policy with over 4,900 retailers. 42
45 2012 Responsible Gambling Council Insight Study In 2012, the Responsible Gambling Council conducted a study of current RG practices for lottery. The study was funded by OLG as well as the Alberta Gaming and Liquor Commission, Atlantic Lottery Corporation, British Columbia Lottery Corporation, Manitoba Lotteries Corporation and Nova Scotia Provincial Lotteries & Casino Corporation. RGC gathered information and sought viewpoints from multiple stakeholder groups, including lottery operators, regulators, players, treatment providers and retailers from Canadian and international jurisdictions. The project identified best practices, recommended improvements and explored opportunities for the development of new RG Lottery programs. OLG used the study to validate many of its current Lottery RG policies and programs for training, advertising and player information, and benchmark them against best practices. OLG has integrated many of the recommendations into future initiatives and planning, which are reflected in the RG Program Description for Lottery, and will continue to explore possibilities for improvement. Key findings and emerging best practices identified in the Insight study can be found in the attached report. Lottery RG Training Evaluation Monitoring and evaluation of RG training for Lottery occurs through feedback from employees and customers, as well as third-party research. (For details, see WLA Program Element 2: Employee Training Lottery RG Training.) GAPS AND OPPORTUNITIES Retailer RG Training Direct retailer training continues to be a major opportunity to reach thousands of retailers across the province (For details, see WLA Program Element 2: Employee Training Lottery RG Training). RG Code of Conduct Modernization will see the introduction of private sector operator employees to OLG Lottery operations. These new employees represent a potential gap in commitment to RG and employee culture if the new private sector operator does not have an established RG employee culture or commitment. To address this potential gap, OLG requires all OLG and Service Provider lottery employees to acknowledge and follow the OLG RG Code of Conduct for Lottery. This Code of Conduct is a personal and public declaration of awareness and adherence to RG principles and practices. Explicit affirmation to these key principles and practices at the employee level is fundamental to building RG cultural acceptance and commitment within Service Provider personnel. AGCO Control Activities The impending AGCO RG Standards for Lottery, which are likely to be very similar to the Standards for Gaming, will require formal, documented policies, procedures and resource tools to execute the RG Program for Lottery and ensure OLG compliance to the Standards. In preparation for the Standards, OLG is working towards formalizing, documenting and designing its Lottery RG program to meet or exceed the AGCO RG Standards (as described in the Introduction: RG Standards Implementation). The documentation of the RG Program is also critical for the Modernization Plan since it will provide direction for the new Lottery Service Provider that takes over Lottery operations. The RG Program for Lottery will have control activities for seven Program areas: RG Customer Education, RG Marketing, RG Customer Access to Money, RG Customer Assistance, RG Game and Site Design, Self-Exclusion, and Employee Engagement and Training. Program design (i.e., RG Program Description for Lottery) is nearing completion, and development of the RG Program Directives for Lottery is expected to begin in April Leveraging the RG Program Directives for Gaming, there are several new program elements of the Lottery RG Program being proposed or planned: RG Champion and Corporate Team The RG Champion is a senior employee who is responsible for promoting RG awareness and culture at the Corporate level. The RG Champion will lead an RG Corporate Team, consisting of individuals from various departments (e.g., Sales, Marketing, Data Analytics, Policy Planning and Continuous Improvement) that are integral to ensuring RG culture and programming are embedded within Lottery operations. RG Marketing and Game Design Lottery employees involved in marketing and game development will have specific policies, procedures and resources to help ensure marketing and product planning employees consider RG in their product marketing and development. Specific RG employee training will also 43
46 be developed to support employee capacity to produce or identify RG-appropriate marketing and games (see WLA Program Elements of Game Design, Advertising and Marketing Communications and Employee Training). Monitoring and Evaluation Lottery will be required to produce RG reporting and performance measures for specified RG Program areas to enable assessments of the effectiveness of a particular RG Program area and its program elements. In addition, OLG will conduct a triennial review of specific RG Program areas to ensure the Program is kept relevant and effective in light of current research and knowledge, leading or evolving best practices in the industry or field, or changes in the operational context. Charitable Gaming POLICIES AND PROGRAMS The Charitable Bingo and Gaming Revitalization Initiative has shaped OLG s relationship with Bingo retail partners for the past three years. The initiative aims to transform existing retail bingo halls into Charitable Gaming Centres (CGCs) with new products and technologies, including new electronic games. These games have structural risks that are new to this business environment and require a renewed focus on RG. OLG has proactively engaged local stakeholders, treatment providers and credit counsellors to provide information about the mechanics of electronic bingo games and to ensure local support services are available to promote their services within the CGCs. Over 20 bingo halls have been converted to CGCs since During this time the following RG initiatives were rolled out or are being planned for all new CGCs and/or bingo halls: RG Customer Education RG programming at CGCs provides greater opportunity to educate cgaming players with RG information, including RG messaging such as the Ontario Problem Gambling Helpline in the help screen of electronic games and on ticket in/ticket out vouchers. In addition, the implementation of the RG Centres at CGCs began in The RG Centres provide a one-stop shop of RG information on how the games work, problem gambling risks, help resources and responsible gambling advice. Thus far, 12 RG Centres have been implemented at cgaming sites and full implementation for 37 sites is expected to be completed by March RG Training Since 2011, OLG has delivered RG Training to over 600 employees at more than 20 cgaming Sites. (For details, see WLA Program Element 2 Employee Training: Charitable Gaming RG Training.) RG Site Design The introduction of electronic games can result in losing track of time. To assist customers in tracking the passage of time and encouraging taking breaks in play, clocks were installed in every gaming area where electronic games are present. Chapter 2: Employee Program Chapter 3: Treatment Referral Chapter 7: Player Education MONITORING AND EVALUATION Needs Assessment In order to better understand risk and embed RG within the Bingo environment among players and employees, OLG carried out a needs assessment in Focus groups were held with bingo players to gather information about the way Responsible Gambling is perceived within the charitable gaming environment. Information was also collected from the Ontario Problem Gambling Helpline about the number of bingo-related calls they receive. The results of the needs assessment were used to develop and disseminate player education materials, which are fully described in WLA Program Element 7: Player Education. CAMH Research In , researchers from CAMH recruited participants from CGCs to conduct research about effective RG program elements in the cgaming environment. Although the study results have not been released, OLG will continue to utilize and facilitate research in the bingo environment to: a) build a base of knowledge in a previously understudied arena, and b) validate the effectiveness of new RG Program elements in cgaming. RG Training Evaluation Training surveys, focus groups, needs assessment and third-party research are used to monitor and evaluate RG Training for Charitable Gaming. As with other lines of business, OLG contracts CAMH to monitor and evaluate training effectiveness. (For complete details on monitoring and evaluation of cgaming RG Training, please see WLA Program Element 2: Employee Training.) 44
47 GAPS AND OPPORTUNITIES AGCO Control Activities With the new AGCO RG Standards in effect for cgaming, OLG will need to ensure that its RG Program for cgaming is compliant to the Standards. OLG is currently designing control activities in seven RG program areas RG Customer Education, RG Marketing, RG Customer Access to Money, RG Customer Assistance, RG Game and Site Design, Self-Exclusion, and RG Employee Engagement and Training that will enable the program to meet the AGCO RG Standards. One particular challenge with designing such a program is that the cgaming operational environment is currently unstable, having very limited resources and experiencing economic uncertainty. The RG Program will need to reflect this reality. Program design will be completed in May 2014, from which OLG can develop RG Program Directives for implementation. Leveraging the RG Program Directives for Gaming, there are several new program elements of the cgaming RG Program being planned: RG Coordinator An RG Coordinator will be established at each CGC or group of CGCs to help distribute RG information and reinforcement materials to Centre employees. RG coordinators will be a single point of contact to help grow RG culture and awareness within the CGC environment. RG Code of Conduct Similar to the RG Code of Conduct for Gaming employees, cgaming employees will be required to read and acknowledge an RG Code of Conduct specifically for cgaming. This will commit them to specific RG accountabilities and responsibilities that will be supported by RG training. Self-Exclusion OLG conducted a Self-Exclusion feasibility review in 2013 to identify potential ways in which a Self-Exclusion program could be operated within the cgaming context. OLG will continue its due diligence in designing a suitable Self-Exclusion program that will fit within the current limited operating and economic climate of cgaming but still meeting the AGCO RG Standards for Self-Exclusion. RG Interactions CGC employees are trained using OLG employee RG training aimed at engaging customers who are observed displaying Red Flag Behaviours. However, at this point, CGCs have no way to systematically document the serious Red Flag Behaviours that they are required to report and OLG will need to pursue ways to gather such information so that it can be used to assess the RG Program and Training. Quarterly Reporting and Performance Measures cgaming will be required to produce quarterly RG reporting and performance measures for specified RG Program areas (e.g., RG Employee Training) to enable assessments of the effectiveness of a particular RG Program area and its program elements. RG Program Area Review Every three years, OLG will conduct a review of particular cgaming RG Program areas to ensure the RG Program is kept relevant with respect to current research and leading or evolving best practices, and to changes in the operational context. RG Marketing and Game Development cgaming employees involved in marketing and game development will have specific policies, procedures and resources that will ensure marketing and product planning employees consider RG in its product marketing and development process, as well as provide training to support employees capacity to produce or identify RG-appropriate marketing and games (see WLA Program Elements of Game Design, Advertising and Marketing Communications and Employee Training). 45
48 WLA PROGRAM ELEMENT 4: GAME DESIGN PROGRAM STATUS: 2010 SUBMISSION In 2010, OLG was in the early stages of establishing a more robust implementation plan for game design for its lottery gaming operations. GAMGaRD had been implemented in lottery and was being considered for casino-style games and bingo offerings. For Gaming operations, third-party vendors developed games and gaming integrity was regulated by the Ontario Alcohol and Gaming Commission (AGCO). The provincial legislative framework, namely the Gaming Control Act, was used as the baseline for safeguards for problem gambling and guided OLG s approach to game design. A new software suite responsible for managing back-end operations at Gaming Sites, Gaming Management System (GMS), was in the procurement process and would incorporate RG features that promote informed play. Evaluation and success measures for continuous improvement measures were not yet in place. The gaps and opportunities identified in OLG s 2010 submission are summarized in Table 4.0 and are detailed in the update below. Table 4.0 Gaps and Opportunities in 2010 Submission Accommodate emerging RG tools that support player empowerment; development of RG features in new GMS Current Status Update Change in direction due to Modernization: In Modernization, Service Providers will be required to comply with RG business requirements including game design elements. Analyze available data in order to support RG tools Ongoing: Continues to be an Opportunity. Player analytics program is currently being developed. Expand GAM-GaRD assessment across OLG lines of business In place: OLG expanded the use of GAM-GaRD to three product lines Lottery, cgaming, igaming. For Gaming products, OLG can only select products from a list of products that have been pre-approved by AGCO. 46
49 PROGRAM STATUS: 2011 TO PRESENT POLICIES AND PROGRAMS RG Game Design Policies The new AGCO RG standards prohibit games that mislead in some manner or encourage excessive or underage play. Gaming In February 2014, MCSR Social Responsibility completed development of RG Program policies and procedures (i.e., RG Program Directives for OLG-operated Gaming Sites) that establish a control activity environment to ensure these standards will be met at OLG Gaming Sites. Part of the overall purpose of this program area is to ensure games are clear, accurate, truthful and not misleading in any way, as well as do not encourage excessive or underage gambling. Currently, game manufacturers submit gaming products to the AGCO for approval. OLG can only select products from a list of products that have been pre-approved by AGCO. This system negates any chance that OLG will be in non-compliance with the AGCO Standards. igaming The igaming channel has developed the RG Game Design policy and procedures to ensure that RG is appropriately considered in game review prior to games being deployed. (For more detail, see Program Element: Remote Gaming.) GAM-GaRD In 2011, as a member of the Interprovincial Lottery Corporation Responsible Gambling Sub-Committee (ILC-RGSC), OLG commissioned and participated in a study by two academic researchers to review, assess and develop a better understanding of RG Product Assessment tools, including GAM-GaRD. Out of the four assessment tools studied, GAM-GaRD was the most prevalent tool used by the gaming companies that completed the survey study (ten out of 11). The tool was positively received, with most companies agreeing it was easy to use and access, objective, and useful for comparing within and between games and identifying options for game improvement. However, some limitations were also identified (e.g., tool did not take into account the broader RG programming context beyond the game itself). The study findings were fed into the development of the next version of GAM-GaRD. The study s positive assessment of GAM-GaRD and the tool developers willingness to revise and improve the tool based on research and feedback provided OLG with quality assurance for the tool and the confidence to continue its use. To support decisions around game approvals, OLG expanded the use of GAM-GaRD to three product lines: Lottery, cgaming and igaming. Unlike its Gaming products, OLG does not select these products from a pre-approved list determined by the AGCO. Currently, OLG conducts a GAM-GaRD assessment on all new games in these areas. In Modernization, Gaming Service Providers seeking to modify and/or add to the AGCO Approved Lists of Rules of Play, Electronic Equipment, and Gaming Machines, will first submit a proposal to OLG. As part of this proposal, Gaming Service Providers will consider and address any potential RG game design issues and describe how they will respond to mitigate any issues. In support of the proposal, the Service Provider can submit the game to OLG to conduct a GAM-GaRD assessment. For all uses of GAM-GaRD, an assessment of a yellow or red rating suggests re-thinking the game approval or selection or proposing modifications and/or RG features that will mitigate the risk. OLG MCSR Social Responsibility is available for consultation in reviewing or formulating potential responses to mitigate risk. Pre-commitment Limits In our 2010 submission, OLG reported that it was in the process of procuring a new Gaming Management System (GMS) that would enable RG programming for games such as pre-commitment limits and play information. The GMS project, however, changed direction and will no longer be rolled out by OLG under the Modernization plan. Instead, the capital spend for the GMS will be transferred to the private sector that takes over Gaming Site operations. In this arrangement, the GMS becomes more complicated, involving coordination between OLG and numerous systems managed and/or owned by private sector Service Providers. Potential Gaming Service Providers will be given a specific set of RG business requirements in the Modernization Gaming procurement process that need to be met by their 47
50 GMS. These requirements, as set out in the governing policies and operating agreements for new Service Providers, stipulate the Service Provider GMS offers players an option to register for pre-commitment game limits through a variety of means, including Customer Loyalty Program desk, kiosk and website, and at each electronic gaming machine. Electronic gaming machines in particular must have options to set play limits with the following features: customizable time and monetary limits various types of real-time warning messages and consequences sent directly to player on machines, including suspension of player loyalty points prompts to take breaks after reaching set time limits prevention of further play after limits have been reached or exceeded records of all limit activity (e.g., registration/change of limits, alert messages, responses to alert messages etc.) gaming activity summary (i.e., wins and losses) reports for players MONITORING AND EVALUATION RG Program Area Review The RG Program area of Game and Venue Design will be formally reviewed every 36 months by OLG in consultation with Gaming Sites after implementation. The review is to determine whether the RG Program area, as operationalized in OLG-operated Gaming Sites, continues to be accurate; up to date with current OLG policies and procedures, research and knowledge; and reflective of industry good practice. The review will identify potential changes and enhancements for RG game assessment and deploy RG game features. OLG may engage third-party expert organizations to conduct the review and/or validate some or all of review results for quality assurance purposes. GAPS AND OPPORTUNITIES Data Analytics The establishment of a new GMS as per the Modernization plan will be important for making pre-commitment tools available to players, but it should also provide OLG with a degree of player information that it has not had in the past: real-time play behavior activity data. There is currently a gap in the RG Program for collecting and leveraging this type of player data for RG purposes. OLG is planning and developing its player analytics program and anticipating using such data. It is currently working to procure a vendor for a Risk Algorithm for our landbased casinos that will analyze play behavior generated through player/loyalty cards to identify players that may be exhibiting various levels of risk. In conjunction with the new GMS, OLG is seeking to send customized RG messages to players of different risk levels while they are gaming and thereby provide a greater level of informed choice to their gaming experience. AGCO Control Activities: cgaming and Lottery The new AGCO RG standards for game design apply not only to OLG s Gaming and igaming product lines but also to its cgaming lines of business. AGCO is also currently developing RG standards for Lottery, which are expected to closely mirror the current Standards and to be completed in mid to late While games deployed at Gaming Sites require AGCO approval prior to deployment, lottery, cgaming, and igaming products may be deployed prior to AGCO game review or approval. This means that the OLG RG Program require control activities for these product lines to ensure that any new product line offerings meet AGCO standards. The lack of policies and procedures in this area for cgaming and Lottery represents a gap in the RG Program. OLG is currently designing and evolving the RG Program for these other lines of business that will embed RG consideration into the internal game design, development and approval processes for these product lines. The RG Program area of Game Design will also need to be applicable to the current state of OLG-operated lines of business and the future state under Modernization and the cgaming revitalization plans. Program Directives for Lottery and cgaming are expected by the end of 2014, with implementation to follow immediately. In addition, while igaming has policies and procedures in place to ensure RG considerations are made in the game design and/or approval process (for further detail, see Program Element: Remote Gaming channels), there is room to enhance them with other program elements being planned for cgaming and Lottery. The longer-term goal for the overall OLG RG Program is to eventually standardize the RG Program area of Game Design for all lines of business that perform a game design or approval function. Current Program designs for Lottery and cgaming plan on developing and/or incorporating the following seven control activities to assist OLG game development and approval: 48
51 1. RG Game Design Assessment Tool OLG game developers/approvers will apply an RG Game Design Assessment Tool that specifically lists explicit criteria (e.g., found in AGCO and RG Check RG Standards) for RG-appropriate game design. The tool will serve as an auditable record of decision-making by game developers/ approvers to demonstrate appropriate consideration for RG in the game development and approval process. 7. RG Program Area Review Every three years, OLG will conduct a review of its RG Program area of Game Design for applicable lines of business to ensure the program area has kept relevant with respect to current research and leading or evolving best practices and to changes in the operational context. 2. RG Marketing and Game Design Reference Database OLG game developers/approvers will have access to an MCSR Social Responsibility-maintained electronic resource database that contains information to assist in determining RG-appropriate games; i.e., real world examples of RG-appropriate and inappropriate games and game designs, and of RG issues that have arisen in the course of determining RG-appropriate games and game designs. 3. MCSR Advice and Consultation MCSR Social Responsibility will be available to game developers/approvers for ongoing advice and consultation with respect to RG game design. 4. RG Game Design Training All OLG employees involved in key aspects of game design and approval will complete an RG employee training module to promote development and approval of RG-appropriate game offerings. This module will include how to use the RG Game Assessment Tool and available OLG resources that can assist in decision-making. 5. GAM-GaRD In Modernization, OLG will continue to deploy and encourage the use of GAM-GaRD as part of the approval process of new or modified cgaming and Lottery games. 6. Quarterly Program Reporting and Performance Measures OLG and future Lottery Service Providers will provide quarterly data on the game approval process and outcomes to enable assessments on the use and impact of the RG Game Design review process. 49
52 WLA PROGRAM ELEMENT 5: REMOTE GAMING CHANNELS In 2010, the Government of Ontario gave OLG the mandate to pursue the implementation and delivery of a remote gaming (igaming) channel to the residents of Ontario. At the time that the igaming channel was announced, the Government also mandated OLG to work towards delivering a gold standard for Responsible Gambling (RG). Following from this, OLG committed to embedding RG program elements within its igaming channel as well as having members of its Marketing, Communications and Stakeholder Relations Social Responsibility Department (i.e., RG team) integrated into the planning, development and launch of igaming. OLG also contributed RG requirements to the igaming Marketing and Advertising Standard. These policies and procedures reflect OLG s current approach for delivering and continuously improving its RG Program. OLG is currently seeking regulatory approval for its igaming channel from the Alcohol and Gaming Commission of Ontario (AGCO). Pending this approval, OLG plans to launch igaming under the brand name PlayOLG in To guide RG programming for the igaming channel, OLG developed a set of comprehensive RG policies and procedures for the following areas: Player Education RG Game Design RG Employee Training RG Player Assistance Self-Exclusion PROGRAM STATUS: 2010 SUBMISSION At the time of OLG s WLA submission in 2010, initial steps had been taken to incorporate best-in-class practices and technology to ensure the safety and security of igaming player accounts and identification. OLG is subject to, and strictly adheres to, the Ontario Freedom of Information and Protection of Privacy Act (FIPPA) in order to maintain confidentiality and the protection of personal privacy. As a result, OLG has developed an IT infrastructure and internal processes for its igaming channel that is designed to ensure personal player information is protected. Recognizing that underage gambling is a serious matter, OLG was also exploring options for ensuring age and identity verification including parental control options. OLG initially sought to offer parents in Ontario free software to block access to Internet gambling websites. However, an expert s report commissioned by OLG revealed a number of significant drawbacks with this approach: software may not be robust enough to block new gambling sites and social media gambling applications (like those available on Facebook), giving parents a false sense of security lack of interoperability with other protective software, like anti-virus programs based on case studies, OLG could expect a low user adoption rate, making the cost per user unreasonably high 50
53 In light of these drawbacks, sophisticated third-party age and identity verification technology has been integrated into the igaming registration process to limit unauthorized access to its website. Further, OLG also renewed its commitment to providing clear information and resources for parents on the igaming website, including how to recognize the signs of underage gambling and links to further resources if a parent has a concern. In addition, OLG plans a public awareness campaign at launch, one of the themes of which is controls to prevent underage gambling. Table 5.0 identifies gaps and opportunities that were identified and addressed since the 2010 WLA submission when OLG was beginning development of its igaming platform. Table 5.0 Gaps and Opportunities in 2010 Submission Enhance the appeal of OLG s igaming platform by embedding RG controls, support and tools into the design of the system Conduct a thorough stakeholder engagement process and incorporate the input and advice of OLG s stakeholders into the design, development and delivery of world-leading, RG online gaming protocols Current Status Update Continuous: OLG has developed and integrated a set of comprehensive RG policies and procedures for the igaming platform in the following areas: Player Education, RG Game Design, RG Employee Training, RG Player Assistance and Self-Exclusion. OLG also contributed RG requirements to the igaming Marketing and Advertising Standard In place: OLG conducted continuous stakeholder consultation and engagement in the early planning and during the development stages of the igaming channel, and will continue to provide updates and solicit feedback from RG organizations, the treatment community and RG/PG academics during the launch and beyond. See Table
54 PROGRAM STATUS: 2011 TO PRESENT Stakeholder Engagement POLICIES AND PROGRAMS At the time of OLG s 2010 WLA submission, a formal consultation process was being planned with three key RG stakeholders (CAMH, OPGRC and RGC) to elicit input for igaming RG policy development. This consultation process took place over several months as part of OLG s ongoing commitment to engage with RG stakeholders for all of its gaming channels. OLG carefully documented and considered all input throughout the consultations. Key stakeholders Centre for Addiction and Mental Health (CAMH) Ontario Problem Gambling Research Centre (OPGRC) Responsible Gambling Council (RGC) Consultation process Stage 1: January April 2011 Distribution of consultation paper, presentation of RG policy questions for the igaming channel OLG circulated initial draft of consultation paper to stakeholders for review and comment. OLG analyzed and incorporated stakeholder comments into materials for roundtable discussion. Stage 2: April-May 2011 Stakeholder Roundtable Discussion OLG hosted in-person roundtable with stakeholders to discuss feedback and engage in open dialogue about igaming RG policy directions. A summary of the roundtable discussions was circulated to participants following the consultations. Our regulator, the Alcohol and Gaming Commission of Ontario (AGCO) also participated over the course of consultations in order to provide regulatory guidance. Objectives The primary goals of stakeholder consultations were: to obtain advice on the creation of a substantial and meaningful RG platform for Internet gaming that fosters a positive player experience on a viable, profit-generating Internet gaming site to obtain input from invited independent organizations and experts on program elements, tools and policies that support players in the prevention and mitigation of problem gambling This incremental approach to stakeholder engagement was productive and served to inform and verify OLG s early approach to RG policy directions. Stakeholder recommendations were explored during the roundtable discussion stage in order to ensure that OLG had full understanding of the nature and scope of each response. 52
55 Table 5.1 below outlines a selection of stakeholder feedback and corresponding OLG actions. Area of feedback Selected stakeholder feedback OLG policy direction for igaming Implementation for launch Explanation and promotion of RG tools for online site Video tutorials to instruct players how to use RG features and types of games Agreed with feedback and incorporated video tutorials in player education strategy igaming website will provide video tutorials on RG tools, Self-Exclusion as well as how to play Roulette, Blackjack and slot machine games Weekly or monthly deposit limits with option to set loss limits. Players receive notification when they reach a limit and play is stopped. This aspect is made clear when limits are set Supported approach to offering limits, communicating information and notifications functionality igaming website will offer mandatory weekly deposit limit and a variety of optional RG limits (see igaming Player Education for more information) Time limit setting/ cooling-off period Increases to limits should be delayed by 7 days. Changes to reduce limits should take effect immediately Agreed with approach, OLG committed to this feature applying to time limit as well as all monetary limits Any removal or increase to a limit is subject to the 7 day cooling-off period Monetary limits Gambling for real cannot resume until the timeframe of the limit is complete This is consistent with OLG s approach to enforcing limits Once a monetary limit is reached, corresponding restriction will be enforced by system on player s account for the duration of the term (e.g. inability to gamble for real for rest of calendar month once Monthly Loss Limit is reached) Customer service does not have the ability to override system restrictions. Self-assessment test and data analysis Provide resource and referral information to players following the test OLG shares stakeholder views and will include selfassessment test and data analytics in igaming channel A self-assessment test is available on the website, results incorporated into player segmentation Real time feedback Offer practical behavioural strategies players can implement based on their risk level OLG agreed that capability for customizable messaging to players is a key consideration for igaming procurement process and will include data analytics for launch Players receive risk profile with risk-adjusted gambling recommendations 53
56 Area of Feedback Selected Stakeholder Feedback OLG Policy Direction for igaming Implementation for Launch Voluntary breaks and Self-Exclusion Short-term play breaks and long-term exclusions should be offered OLG planned to implement a Self-Exclusion program for its igaming channel and Self-Exclusion and Breaks are described throughout igaming website and may introduce breaks from play as be initiated directly from a new option to players My Account section Payment policy Prevent excessive use of multiple credit cards In line with OLG igaming security and fraud concerns A maximum of two credit cards may be linked to a player account at any time. Player may only use a second deposit source if account balance is less than $1,000 Marketing Do not use inflated payout Agreed that play-for-free Games in play-for-free mode rates on demo games mode for games is an will use same mechanics as important educational tool play-for-real mode External links Provide hyperlinks to accredited and appropriate OLG agreed to continue its ongoing partnerships with igaming channel will offer links to RG organizations like sites such as treatment RG stakeholders Ontario Problem Gambling services organizations to ensure Helpline and the Centre for effective treatment referral Addiction and Mental Health for players with concerns Stakeholder Engagement During Development of igaming channel As the igaming channel developed, OLG continued to engage with RG stakeholders in a variety of forums. These discussions included presentations to a wide variety of RG stakeholder groups, offering OLG the opportunity to widely share its ongoing progress of embedding RG within the igaming channel and to verify its RG policy approach. Continued Engagement with Key Stakeholders: OLG continued its engagement with the three key stakeholders it consulted prior to the development the igaming channel. Discussions were initiated to update stakeholders on the approach OLG has taken as a result of their initial input as well as to elicit additional feedback. RG Conference Participation: OLG sought to further engage with its broader stakeholder base through Canadian-based RG conferences. Attendees included groups that may not be readily accessible to OLG for in-person interactions such as treatment providers from remote areas, igaming industry experts and RG-related organizations from across Ontario. OLG provided igaming progress updates through presentations at the following RG-related conferences: Centre for Addiction and Mental Health s Problem Gambling Institute of Ontario Annual Forum (2012) Centre for Addiction and Mental Health s Problem Gambling Institute of Ontario Annual Forum (2013) Responsible Gambling Council s Discovery Conference (2013) British Columbia Lottery Corporation s New Horizons in Responsible Gambling Conference (2014) RG academics and researchers: OLG continued to advance its engagement with RG stakeholders by arranging individual, in-person or teleconference meetings with prominent RG/PG academics and researchers in Canada, the United States and Australia. These meetings allowed OLG to provide direct progress updates on the development of the igaming Channel and to gain feedback from academic and research perspectives. Feedback from these meetings was generally positive and all stakeholders conveyed a willingness to maintain an ongoing dialogue with OLG. 54
57 Engagements with Treatment Community: OLG initiated regular outreach to community treatment providers and other stakeholders in order to further relations and improve communications with these groups. (For more information on this process and outcomes, please see WLA Program Element 8: Treatment Referral and WLA Program Element 9: Stakeholder Engagement.) MONITORING AND EVALUATION As the commercial launch of its igaming channel approaches, OLG remains committed to continuously improving its RG offering. Stakeholder engagement will continue to serve as an important source of feedback and will support OLG s ongoing efforts to identify potential enhancements to the igaming channel. Around the time of launch, OLG will provide further progress updates to RG organizations, the treatment community and RG/PG academics. GAPS AND OPPORTUNITIES Sharing anonymized data with researchers: The player data that igaming will have collected through its gaming website represents a great opportunity for OLG to further research on player behaviour that is generally limited by its reliance on self-reported player data. OLG has communicated its willingness to share anonymized data with RG researchers. Although this research may not necessarily be directed by OLG, this collaboration represents a unique opportunity for OLG to work with its stakeholders towards furthering the public interest through better understanding RG-related behaviour and activities of igaming players. It is expected that Self-Exclusion and limit-setting will be considered areas for research. Player Education POLICIES AND PROGRAMS OLG views the igaming website as an important, new information channel for empowering and educating igaming players with key RG messages. Early on, OLG committed to providing a suite of player education tools as well as clear and meaningful information about gambling and the games available on the igaming website. Our primary objective in this area is to provide players with information and tools to encourage healthy gambling choices. OLG s Self-Exclusion and Player Education policies and procedures for igaming serve to guide the operations for this area of activity. RG built into the igaming user experience OLG has taken the following deliberate measures to incorporate RG content and features as part of the igaming user experience: the registration process includes setting a mandatory deposit limit prior to making a deposit; players are also given the option to set optional time and money limits (See Table 5.4) the website s main navigation bar features a Responsible Gambling tab which provides information on a variety of RG topics the centralized My Account section has a number of RG-related tabs, like gambling history and limitsetting preferences a hyperlinked Know Your Limit logo is promoted in the header or footer of nearly every page in the igaming website the heading of nearly every igaming webpage prominently displays the player s account balances (cash and bonus), the elapsed time since login, and the current time during casino gaming, the game window displays the current time, the game session time, and account balance Basic gambling information A core element of promoting informed choice is to provide clear and straightforward information about gambling and its potential risks. The igaming website provides foundational RG information to support our players understanding about how gambling works and how to gamble online responsibly. Player education topics include: how to keep gambling within a player s limits risks associated with gambling how to identify signs of a problem, including warning signs importance of safe gambling practices myths and facts about games available on the igaming website Game-specific information To help our players better understand the games they choose to play on the igaming website, OLG provides clear and relevant information about each game, including: clearly stated rules of play odds of winning, payout odds, and/or return to players 55
58 In addition, all casino games are available in a play-forfree mode operating with the same game mechanics when played for real. Our players may therefore play trial games to know how they operate before wagering real money. Any games or gambling questions may also be directed to our customer support representatives 24 hours a day, seven days a week. Player history igaming players can easily access a detailed history of their activity so they may stay informed about the amount of time and money they spend. The following information is displayed in the My Account section on the website and available for download in CSV format: deposit and withdrawal history and current balance login history date and time (including current session) logout date and time and duration of session(s) deposit and withdrawal history and current balance login history date and time (including current session) logout date and time and duration of session(s) deposit and withdrawal history with date, time, transaction ID, transaction method, amount, starting balance, ending balance, transaction status (e.g., complete, declined, etc.) casino game session history with name of game, start date and time, end date and time, duration, amount wagered, amount won lottery purchase history with draw date, product, prize amount, status (e.g., winner, not winner), ticket ID and link to copy of ticket purchase with details (i.e., number of plays, cost per play, numbers selected, product) promotions redemption history Self-Exclusion for igaming Channel As a part of OLG s Self-Exclusion program and compliance with AGCO RG regulatory standards, players who wish to stop gambling on the igaming website have the opportunity to do so by registering for igaming Self-Exclusion (see Table 5.3). The igaming website provides relevant information designed to inform and support our players understanding of the OLG Self-Exclusion program. This information includes: general program description, in plain language duration terms the registration process how to apply for Reinstatement information about land-based (Gaming) Self-Exclusion Table 5.3 Self-Exclusion Registration igaming Self-Exclusion applies to all of its online games, including lottery duration options are six months, one year, indefinite registration may be completed online if player has igaming account player may initiate Self-Exclusion registration process through multiple access points: igaming website (while logged in or logged out) knowyourlimit.ca website a player who registers for Self-Exclusion from land-based gaming is automatically excluded from the igaming website a player registering online for igaming Self-Exclusion is not automatically registered to land-based Self-Exclusion, but is provided with information for doing so No Marketing while Self-Excluded OLG will not market directly to those registered for Self-Exclusion OLG will make reasonable efforts to remove the names and contacts of individuals who have self-excluded from marketing lists, including other OLG channel marketing lists igaming Reinstatement Process reinstatement is not automatic and player is only eligible to apply once term of Self-Exclusion is complete upon reinstatement, player must complete an online RG education tutorial before s/he may resume access to igaming website reinstated players will not receive marketing from OLG unless they opt back in 56
59 RG tools for igaming The igaming channel offers a variety of RG limits and tools designed to help players stay informed about their gambling. Table 5.4 Money and Time Limits Overview Types of limits offered Changing and removing limits OLG igaming channel offers a suite of player-defined limits to help players manage their time and money mandatory deposit limit must be set prior to depositing money daily, weekly and monthly loss limits for casino games session time limit for casino games weekly lottery purchase limit the player, and only the player, may change or remove limits and this may be initiated at any time lowering of limit(s) occurs immediately a mandatory seven day delay applies to limit(s) that are raised or removed (i.e., seven day cooling-off period) Breaks from Play Overview How it works Access points OLG igaming channel offers options for players who wish to take an immediate break from real play duration ranges from 24 hours to three months player may withdraw money from account player can access casino games in play-for-free mode break may be initiated through My Account section of website during casino gambling, the game window prominently displays link to setting breaks page Self-Assessment Tool Overview Methodology for tool Results of test OLG igaming channel offers self-assessment tool to help player better understand his/her gambling habits questionnaire is based on the Problem Gambling Everity Index recommendations displayed to player about their gambling results incorporated in player s risk analysis Risk rating Overview How it works Player feedback OLG igaming channel utilizes data analytics to provide player with a risk rating to help players better understand his/her gambling habits risk rating based on analysis of player s activity on the igaming website ( Low, Moderate, High, Not Rated ) as well as self-assessment test if taken description of risk profile with risk-appropriate gambling recommendations 57
60 RG Video Tutorials In an effort to facilitate our players awareness and understanding of igaming channels RG features, OLG contracted an animation company with previous RG experience to develop the following short video tutorials: Self-Exclusion provides players with an overview of the program, including Self-Exclusion registration, purpose of program, and reinstatement RG Play Management Tools introduces the igaming play and risk profile OLG is also in the process of creating video tutorials for three types of casino games which demonstrate how each game operates and basic rules of play: Slots tutorial video Blackjack tutorial video Roulette tutorial video Several existing RG videos with gambling education content are available on the igaming website: Gus the Prospector explains the concept of randomness and how it applies in games of chance Royal Couple demonstrates that strategy cannot overcome randomness and unpredictability in games of skill or knowledge The Slot Machine: What Every Player Needs to Know describes how slot games work and some commonlyheld myths As with other RG content, all of these videos may be accessed by those who are logged either in or out of the igaming website. RG awareness campaign: OLG recognizes the igaming website will provide Ontarians with greater access to regulated gambling. As such, a pre-launch awareness campaign is being developed to reaffirm OLG s commitment to RG and to create awareness among the general public for the purposes of mitigating harm and promoting healthy gambling. The campaign will focus on three areas of particular RG concern for the igaming channel: (1) underage gambling, (2) Self-Exclusion, and (3) setting limits for online gambling. Messaging for the campaign will direct individuals to an area of the igaming website that provides tailored information for each topic. MONITORING & EVALUATION A variety of Key Performance Indicators (KPIs) will be used to monitor specific player education aspects of the igaming channel. The process for collection will involve a variety of data sources, including igaming systems and player surveys. The appropriate processes for collection of this data and the timings for review will be determined closer to launch. Player Education: Self-Exclusion Key Performance Indicators percentage of players with an awareness of Self-Exclusion program number of customer service interactions related to self-exclusion or Reinstatement percentage of customer service interactions related to Self-Exclusion or Reinstatement broken down by channel (phone, , chat) number of Self-Exclusions by logged-in players number of Self-Exclusions through knowyourlimit.ca number of Reinstatements General Player Education Key Performance Indicators percentage of players with an awareness of igaming time and money limits, other RG features percentage of players who have viewed RG video tutorials or RG pages on igaming website average video usage metrics (e.g., time spent watching RG video tutorials) percentage of players with a Casino Loss Limit set (daily, weekly or monthly) percentage of players with a Lottery Purchase Limit set percentage of players with a Session Time Limit set for casino games percentage of players who have ever used the Break functionality percentage of players who have ever taken Self-Check (self-assessment) test percentage of players who have ever viewed their Risk Profile number of customer service interactions related to time and money limits, other RG features percentage of players whose risk profile is Not Rated percentage of players whose risk profile is Low percentage of players whose risk profile is Moderate percentage of players whose risk profile is High In addition to the above collection of KPIs, OLG will consider future enhancements to RG Player Education through input derived from a number of evaluation streams currently underway. (For further details please see WLA Program Element 1: Research.) 58
61 Heuristic evaluation As part of OLG s commitment to continuously improve and assess the effectiveness of its RG Program, a user experience vendor will conduct a heuristic assessment of the igaming launch website. This research will inform ways in which the design and presentation of RG features may be enhanced after launch to improve our players experience. Usability evaluation To anticipate and improve upon the user experience of our players, OLG has contracted a vendor to conduct and evaluate a series of usability tests of the igaming website. The outcomes of this study will help guide future refinements to the usability of RG-related features such as limit-setting, communication of RG content and Self-Exclusion registration. Participant profiles will be representative of those expected to register as players with igaming. RG Pre-launch evaluation OLG has contracted the Responsible Gambling Council (RGC) to review the RG elements of its website prior to launch. The expected outcomes of this review are twofold: (1) to gain third-party assessment of OLG s RG approach to igaming, and (2) to identify gaps and opportunities that will inform planning for future improvements following the commercial launch of igaming s website. As part this evaluation, RGC will assess the website using their recently released set of RG Internet standards for their RG accreditation program. RG Public Awareness Campaign Tracking OLG will evaluate and track the RG public awareness campaign for igaming through a number of metrics following the launch. While these metrics and methods for collection are currently being defined, they may include: visits to campaign landing pages customer support calls GAPS AND OPPORTUNITIES As the commercial launch of its igaming channel approaches, OLG remains committed to continuously improving its RG offering. At present, OLG has identified the following potential player education enhancements to the igaming channel for future consideration: player-defined limits on total gambling time (weekly and monthly basis) historic view of past RG limits in the player history section schedule pre-planned break(s) from the igaming website schedule recurring breaks from the igaming website (e.g., a day in the week, day in the month, etc.) historic view of past breaks in the player history section an immediate 24-hour break button embedded in the game window (i.e., panic button ) access to personal record of past igaming Self-Exclusions igaming feedback microsite The igaming channel is working to develop an interactive platform that will be used to elicit written feedback from players on their user experience. Feedback will be collected for the purposes of guiding future development of functional elements of the igaming website, including those related to RG. This platform will also allow for the igaming channel to communicate with players and provide updates for known issues and to validate concerns. Policy review cycle OLG will review and update its policy on player education at a minimum of every three years. Future enhancements to player education will be an important outcome of this ongoing review process. Treatment Referral POLICIES AND PROGRAMS Providing support to players who may be experiencing problems with their gambling is a key element of OLG s RG strategy. The igaming channel has included treatment referral information and protocols in key touch points to help build our players awareness of resources and to bridge them to third-party support when necessary. The RG Player Assistance policy and procedures for igaming guide operations for this purpose. Customer Service: igaming customer service employees receive a specialized RG training protocol so they may recognize, respond to and report red flag behaviour during their interactions with players. OLG customer service for igaming is available to deliver treatment 59
62 referral information to players 24 hours a day, seven days a week through telephone, online chat and channels. (For more information about customer service training for igaming please see WLA Program Element 2: Employee Training and the Employee Training section of WLA Program Element 5: Remote Gaming Channels below.) Links to third-party support: The igaming website provides the following descriptions and hyperlinks to RG organizations, available to players both logged-in and logged-out: Ontario Problem Gambling Helpline Centre for Addiction and Mental Health (ProblemGambling.ca) Credit Canada Debt Solutions GamTalk International Centre for Youth Gambling Problems and High-Risk Behaviours Youth Gambling Awareness Program The toll-free number for the Ontario Problem Gambling Helpline is displayed in a number of locations on the igaming website so that players may contact the service directly. Availability of Self-Exclusion Registration Links: OLG has designed the igaming website to include information about its Self-Exclusion information program in a number of key areas across the website. Any player with an igaming account who wishes to self-exclude from igaming may register online. Furthermore, customer service is available to support a player through this process 24 hours a day, seven days a week. During Self-Exclusion registration: As part of the Self-Exclusion registration process for igaming, OLG provides individuals with RG information and contact information to province-wide resources for problem gambling. MONITORING AND EVALUATION Following the launch of PlayOLG, the following Key Performance Indicators will be used to monitor the availability and use of treatment referral information by players. percentage of players with an awareness of support options percentage or number of players who have accessed external support services directly from the igaming website percentage or number of RG customer service interactions related to Red Flag Behaviours percentage of RG customer service interactions related to red flag behaviours broken down by channel (phone, , chat) percentage or number of RG customer service interactions related to problem gambling disclosure or requests for help percentage of RG customer service interactions related to problem gambling disclosure or requests for help, broken down by channel (phone, , chat) percentage or number of RG customer service interactions related to third-party requests for assistance percentage or number of RG customer service interactions related to reports of underage gambling Policy review cycle: OLG will review and update its policies at a minimum of every three years. Future enhancements to treatment referral will be an important outcome of this ongoing review process. GAPS AND OPPORTUNITIES As the commercial launch of its igaming channel approaches, OLG remains committed to continuously improving its RG offering. It is expected that future enhancements to treatment referral mechanisms will be identified through KPIs, player feedback and the triennial policy review. Employee Training POLICIES AND PROGRAMS igaming customer support is available to players 24 hours per day, seven days a week through telephone, online chat and communication channels. RG Training for these customer support employees follows a similar development and implementation process as outlined in WLA Program Element 2: Employee Training; that is, all employees who interact with igaming players receive targeted RG Training through a variety of modules that reflect current RG best practices and applicable education methodologies. Providing OLG employees with the tools and information they need to respond effectively to igaming players with RG concerns is a primary goal of this service. 60
63 RG Employee Training policy: The igaming channel has developed policies and procedures for RG Training to guide its related activities and to ensure that employees who have direct contact with our players receive appropriate training. The objectives for igaming RG Training are to: Support players with information and tools to help them make informed choices when they gamble Provide referrals for people who want assistance related to problem gambling Collaborate with independent organizations, professionals, and experts in responsible gambling. igaming players are supported by igaming Customer Care, which consists of three tiers of customer service, each with their own defined roles and responsibilities (see Table 5.5). igaming Customer Care represents OLG s frontline interaction with players for the igaming platform. Players with RG concerns may communicate with Customer Care via phone, , and online chat. This represents a new channel of communication, and as such OLG will ensure that igaming Customer Care employees are properly trained to respond to all RG/PG concerns. In order to provide high-level and efficient support to players with RG concerns, each Customer Care group receives appropriate RG training upon hire (see Table 5.5). Central to igaming RG Training is the Responsible Gambling Red Flag and Escalation Guidelines for Internet Gaming which details protocol for recognizing, responding to, and reporting signs of Red Flag Behaviours during customer interactions. This protocol was developed in collaboration with CAMH in Table 5.5 Customer Care Group Customer Service Expertise Required Level of RG Education Tier 1 First point-of-contact and may provide support to players with general RG inquiries (e.g., limitsetting, gambling myths etc.) Basic RG Training Tier 2 Escalated non-rg concerns, (e.g., anti-fraud, technical problems) Tier 3 Escalated RG support for players with serious concerns (e.g., treatment referral, Self-Exclusion questions, extreme behaviours, etc.) Advanced RG Training Tiers 1 and 2 Customer Care employees complete Basic RG Training, a 30-minute elearning module that provides a foundational understanding of RG and how to recognize, respond to (i.e., escalate calls), and report signs of Red Flag Behaviours, as defined by the Responsible Gambling Red Flag and Escalation Guidelines for Internet Gaming. which includes content from Basic RG Training and specialized training so that employees can support players who display/express Red Flag Behaviours or have other serious RG concerns. This training includes imparting the process and knowledge necessary to provide efficient referral to the appropriate third-party support(s). Tier 3 Customer Care employees are a part of the OLG Support Centre that services all of OLG lines of business and is responsible for handling all escalated RG-related customer communications (see Program Element: Employee Training). They are required to take Advanced RG Training, To ensure a high level of RG competency, all employees who interact with igaming players require RG training at least every three years or as required. Refresher and reinforcement materials are also provided on an as-needed basis. 61
64 MONITORING AND EVALUATION Formal Evaluation: RG Training for igaming will be reviewed as part of a formal evaluation process and updated based on a needs assessment. RG components of this evaluation process include: identifying new best RG practices and relevant findings of problem gambling research continuously collaborating with RG and adult education specialists (e.g., CAMH) reviewing training participant feedback forms To evaluate training effectiveness, OLG may assess igaming employees using post-training reviews, player interaction analysis and the annual Employee Survey. RG Training Key Performance Indicators: KPIs will also play a key role in monitoring and enhancing RG training content, delivery and execution. These indicators include: percentage of Customer Care employees by Tier group who have participated in RG Training percentage of Customer Care employees by Tier who consider themselves knowledgeable about RG and the expectations of their roles, and confident about applying their RG knowledge on the job Policy review cycle: OLG will review and update its policies at a minimum of every three years. Future enhancements to employee training will be an important outcome of this ongoing review process. Stakeholder engagement: OLG will continue to engage with expert RG stakeholders like CAMH to ensure RG training reflects current research. Policy review cycle: OLG will review and update its policies at a minimum of every three years. Future enhancements to employee training will be an important outcome of this ongoing review process. Game Design POLICIES AND PROGRAMS RG Game Design policy: The igaming channel has developed the RG Game Design policy and procedures to ensure that RG is appropriately considered in game review prior to being deployed. The Integration of Responsible Gambling into the Product Management Checklist (Table 5.6) represents an important way in which RG has been embedded into OLG s igaming channel. The checklist is a standardized, streamlined review process for any new or modified game. This review incorporates both regulator standards and additional RG requirements that OLG has identified as being important to responsible game design. GAPS AND OPPORTUNITIES Continuous Improvement of Training: As the commercial launch of its igaming channel approaches, OLG remains committed to continuously improving its training for RG. It is expected that recordings of interactions with players will provide OLG with a new tool for training both newly hired and current customer service employees. There is also an opportunity to also use third-party research to validate the effectiveness of RG training for the call centre experience, and to determine how it contributes to overall customer experience. New best practices in RG and applicable education methodologies will also help develop the delivery of training modules. 62
65 Table Technical review of game design Review of RG-related game mechanics, for example: screening for elements that give player the perception that skill affects outcome of the game when it does not 2 Qualitative review of game design components Review of RG-related game qualitative elements, for example: screening for game design that may appeal to minors no encouragement of players to chase losses 3 GAM GaRD review A third-party RG tool that scores game risk based on analysis of structural and situational characteristics 4 Risk analysis and mitigation strategy Qualitative assessment of potential risk to player and the development of corresponding mitigation strategies if required, for example: including Q&A material to inform players about a particular game theme Policy review cycle: OLG will review and update its policies at a minimum of every three years. Future enhancements to game reviews will be an important outcome of this ongoing review process. As the commercial launch of its igaming channel approaches, OLG remains committed to continuously improving its RG offering. Following the launch of the igaming channel, appropriate game design monitoring and evaluation processes will be identified. It is expected that player feedback through customer service and other communication channels will be an important instrument for gaining input and may help guide the RG game review process. Advertising and Marketing POLICIES AND PROGRAMS igaming advertising and marketing will demonstrate a level of responsibility that is consistent with the channel s offering and with OLG s commitment to responsible practices in other lines of business, as outlined in WLA Program Element 6: Advertising and Marketing Communications. igaming Marketing and Advertising Standard: The igaming channel has developed a Marketing and Advertising Standard to guide its related activities and ensure that RG is appropriately considered in its marketing. One aspect of this process is the utilization of the RG Marketing Assessment Tool which is also being employed for OLG s other channels. The tool serves as a practical checklist of RG-specific criteria to help marketing ensure their marketing initiatives meet specific RG standards related to marketing. It also serves as documentation for audit and compliance purposes to demonstrate a deliberate effort to consider RG in the development and approval of OLG marketing. (For more information about this tool, see WLA Program Element 6: Advertising and Marketing Communications.) MONITORING AND EVALUATION Tier 3 Customer Care complaints: OLG will track types of complaints obtained through the Tier 3 Customer Care that are concerned with the RG appropriateness of igaming product marketing. Policy review cycle: OLG will review and update its policies at a minimum of every three years. Future enhancements to advertising and marketing will be an important outcome of this ongoing review process. As the commercial launch of its igaming channel approaches, OLG remains committed to continuously improving its RG offering. It is expected that refinements to RG-related advertising and marketing monitoring processes will be identified after launch. 63
66 WLA PROGRAM ELEMENT 6: ADVERTISING AND MARKETING COMMUNICATIONS PROGRAM STATUS: 2010 SUBMISSION OLG s 2010 WLA submission outlined several codes and standards that guided advertising and marketing communications, namely the OLG Code of Advertising Standard; OLG s RG Corporate Brand Guidelines; Lottery and Advertising Marketing Guidelines; and Lottery, Experiential Events Guidelines. Monitoring and evaluation were conducted through responsible gambling assessments across the lottery, gaming and cgaming lines of business. The gaps and opportunities identified in OLG s 2010 submission are summarized in Table 6.0 and are detailed in the update below. Table 6.0 Gaps and Opportunities in 2010 Submission Implement RG assessment and guidelines for Gaming Marketing Improve monitoring and evaluation of RG standards by enhanced tracking of advertising complaints Harmonize tracking of Resort Casinos advertising and marketing Current Status Update Developed/being implemented: Standardized guidelines, evaluation measures and assessment tools are part of the RG Program Directives for Marketing which have been created and are being implemented for OLG-operated Gaming Sites. Developed/being implemented: Gaming Marketing is required to provide quarterly reports on marketing activity and RG-related complaints. Being implemented: The OLG RG Program Directives for Marketing will be implemented at the Resorts beginning May 2014, which will include quarterly performance and reporting measures on marketing activity and RG-related complaints on resort marketing. Leverage RG messages in external marketing initiatives across all lines of business In place: External marketing initiatives for cross-promotion have been completed including kiosk promotion across all lines of business. See WLA Program Element 7: Player Education Develop new corporate brand guidelines to support communication of mandatory age limits and knowyourlimit.ca Continues to be an opportunity: Efforts to develop corporate brand guidelines have been redirected due to Modernization to the Standardization project. OLG is working towards developing a common Marketing Standard for all lines of business as well as Corporate Marketing 64
67 PROGRAM STATUS: 2011 TO PRESENT POLICIES AND PROGRAMS Advertising and Marketing Communications at OLG are conducted in accordance with the following external regulations: Alcohol and Gaming Commission of Ontario s (AGCO) Registrar s Standards for Gaming (November 2013) Television Bureau of Canada s Telecaster Gambling Advertising Guidelines Link: Internally, OLG has developed the following Codes and Standards: OLG Code of Conduct OLG Gaming Code of Advertising Practices OLG Advertising and Marketing Standard The provisions of these codes and regulations include a wide range of requirements and guidance on various social responsibility issues. In regard to RG, the regulations stipulate that all OLG s marketing and advertising materials must not mislead in any way, must not target underage ( minor defined as under the age of 19) or self-excluded individuals, and must, where effective, contain a Responsible Gambling message such as OLG s knowyourlimit.ca. The initiatives below reflect OLG s objective to combine the various regulatory requirements and integrate the principles of, and responsibility for, RG throughout the organization. Through these initiatives, OLG strives to not only comply with the regulations, but also to document compliance and drive improvements in program effectiveness through monitoring and evaluation. Commitment to RG Appropriate Marketing As a part of the new RG Program Directives for Gaming Sites around Corporate Commitment and Marketing, OLG is currently developing a clear Statement of Corporate Commitment within its enterprise-wide RG Program Strategy that explicitly supports RG-appropriate marketing and related materials and communications. This Statement is an expression of OLG senior management and the Board of Directors, and is communicated to all employees, customers, and the public. New Gaming Service Providers under Modernization will also be required to have a Statement of Corporate Commitment to RG-appropriate marketing. The Statement may be specific to the Service Provider, or alternatively, be a formal endorsement of the OLG Statement of Corporate Commitment. Service Providers will communicate that commitment to all employees, customers and the public. All OLG and Service Provider gaming employees will be required to read and sign the OLG RG Code of Conduct for Gaming. This Code states that employees will ensure product and service marketing is conducted with accuracy and integrity, including the incorporation of OLGdeveloped RG content, as well as be familiar with the relevant marketing guidelines and AGCO standards. RG Assessment of Marketing and Related Materials and Communications OLG is in the process of transitioning to a different approach to ensure OLG products are marketed in a manner that is appropriate for RG. Currently, OLG MCSR Social Responsibility conducts RG assessments on marketing material that is submitted to them by a line of business. OLG is working towards an objective whereby RG considerations will be embedded into the marketing development process so that responsibility for making such considerations lies with the line of business itself. This change ensures the RG perspective is taken into account in the early stages of the marketing development process and prevents any unnecessary work on marketing that contravenes RG standards. RG Program Directives have been completed to guide Gaming Marketing and Gaming Site marketing departments in assessing their own marketing and to ensure it is RG-appropriate. This is particularly significant given that marketing employees have traditionally left RG decisions up to OLG MCSR Social Responsibility. There are several program elements that are currently being implemented in Gaming to assist marketing employees in this responsibility: 65
68 Gaming Marketing and Advertising Standard OLG is currently in the process of incorporating and consolidating a number of marketing standards that Gaming is required to follow into one document entitled Gaming Marketing and Advertising Standards. OLG igaming has a similar set of Standards entitled igaming Marketing and Advertising Standard that applies to igaming (see WLA Program Element 5: Remote Gaming Channel). Both these Standards consolidate all applicable marketing standards with the line of business. The Gaming Standard will incorporate content from existing standards or guidelines used throughout OLG, including the enterprise-wide OLG Advertising and Marketing Standards, Gaming Advertising Code of Conduct (tailored version of OLG Advertising and Marketing Standard for Gaming), the new AGCO Standards, igaming Marketing and Advertising Standards, and Gaming Policies for new Service Providers under modernization. This new set of standards will contain a consolidated subset of specific RG Standards for Marketing. The Gaming Marketing and Advertising Standards are expected to be completed in May RG Risk Assessment The Risk Assessment was designed to assist employees with RG Marketing decision-making in general and to be particularly useful in specific situations where the application of one or more RG Standards may not be clear or where there are potential risks and impacts that should be explored further as part of RG due diligence. RG Marketing Reference Database As a companion to the RG Marketing Assessment Tool, OLG will maintain an electronic database of real world examples of appropriate and inappropriate marketing, as well as examples of issues that have arisen in the course of applying the RG Assessment Tool and their resolutions. The purpose of the database is to support decision-making in marketing development and approval with practical examples of past decisions. Gaming marketing employees can refer to this database at any point in the development/approval process to assist them in determining the RG-appropriateness of proposed marketing content and materials. RG Marketing Assessment Tool A RG Marketing Assessment Tool is currently in development and is expected to be implemented by May For each Marketing initiative, a Marketing employee will complete the RG Marketing Assessment Tool, which explicitly outlines specific RG-related marketing criteria from the new Gaming Marketing and Advertising Standards. In applying the tool, the marketing content and/ or materials are compared against the RG marketing criteria to ensure they do not contravene the RG standards outlined by the Gaming Marketing and Advertising Standards. The tool includes: specific criteria for assessing the RG-appropriateness of product marketing, including all advertising and promotion initiatives, materials and communications, and the types of activities that are captured by these criteria (e.g., print and television advertising, free play vouchers or other comping ) documentation of the application of the tool, use of support resources and resulting decisions After its initial launch for Gaming Marketing, the tool is also expected to be used in marketing for all lines of business. Development of this database is underway and expected to be completed in early RG Marketing Training All Gaming employees involved in the development and approval of marketing content will complete the RG Training Marketing module, which will be designed to facilitate the production of RG-appropriate marketing. In addition to explaining how to use the RG Marketing Assessment Tool, this module introduces applicable RG Marketing standards and explains general RG themes and principles that employees should consider when developing, assessing or approving any Marketing content or materials. It also describes the OLG resources, such as the RG Marketing Reference Database, that are available to assist employees at any point in the production of marketing. Planning is underway for the development of this new training module and development is expected to begin in April MCSR Social Responsibility Consultation MCSR Social Responsibility employees are available to OLG or Service Provider marketing employees on an asneeded basis for consultation on marketing assessments and advisement on potential risk-mitigating measures. In the event of a disagreement, MCSR Social Responsibility can require the marketing employees to conduct a risk 66
69 assessment on the marketing in question using the template provided in the RG Marketing Assessment Tool. The marketing employee, however, remains accountable for final approval of any marketing and any risk-mitigating measures that are executed. This assessment is a decision support tool and also ensures that marketing employees are aware of the risks involved with executing a marketing initiative in a particular way. Under Modernization, while OLG will not expressly pre-approve Service Provider marketing, it may impose such a requirement in the event that a Service Provider is unable to comply with the OLG Gaming Policies and RG standards around marketing and related materials and communications. Removal of Self-Excluded Individuals from Direct Marketing Lists Participants in the Self-Exclusion program for Gaming are removed from all OLG and Gaming Service Provider direct marketing or other forms of customer contact once the participant is entered into the Self-Exclusion database. Direct marketing databases are directly connected to or scrubbed against the SE database to ensure the marketing databases are updated as soon possible but within 31 days. For Gaming Marketing specifically, once a person has been registered into the program, the Personal Information Repository (PIR), which is the OLG Marketing database, is updated automatically within 24 hours of registration so that if the individual has a PIR account, they are flagged, placed in do not contact status, and removed from any direct marketing mailing lists. Once an individual is placed on the do not contact list, they must opt back into the marketing database, even if their ban is over. This requirement forces people to consciously decide to receive marketing rather than automatically receiving unwanted marketing after their ban. Due to potential gaps in the timing of the automatic do not contact flagging process of self-excluders in the PIR, within ten days prior to launching a marketing initiative, Gaming Marketing will scrub the initiative s mailing list against a list of newly self-excluded individuals who were added after the initiative s initial marketing list was created, and will remove them from the list. MONITORING AND EVALUATION Direct Marketing Channels In addition to the programs described above that ensure that all OLG marketing and advertising is appropriate and in compliance with related standards and regulations, OLG also integrates specific RG messages into its direct marketing across the various lines of business. This has been ongoing since the 2010 WLA submission and is in addition to the RG Player Education initiatives described in WLA Program Element 7: Player Education. The following indicators are part of OLG s RG Scorecard and Measurement Report and provide details on the reach of direct marketing channels. 67
70 Table 6.1 Measure Indicator Results Source RG Education via Number of calls to Lotto Win Line, OLG s Lottery Direct Marketing hotline where players can call to hear winning Division Channels Across all OLG s lines of business, RG lottery numbers Before players are able to hear numbers, they 5.0 (million) 5.3 (million) 6.1 (million) messages are delivered listen to an RG message. to players through a variety of direct Number of Lottery newsletters distributed marketing channels. Every e-newsletter contains some element of 780, , ,000 RG messaging. Number of newsletters distributed to lottery retailer All lottery retailers receive a monthly newsletter 150, , ,000 which contains some type of RG messaging. Estimated reach of customer display units at lottery retail RG-specific content made up five per cent of the digital content and messages are rotated on a regular basis. Total figure includes digital 400 (million) 396 (million) n/a messages that rotate at Lottery Prize Centre. OLG began reporting on the estimated reach of CDUs beginning in , and reporting is based on an estimated number of patrons. Number of newsletters distributed to Winner s Circle Rewards Members Gaming Loyalty Card members are mailed a 848, (million) 1.3 (million) newsletter three times a year. The newsletter has a dedicated RG section. Number of newsletters distributed to Loyalty Members via 573, , ,000 Estimate reach of digital signage at OLG Gaming Sites OLG has multiple screens across all OLG slots and casino facilities (does not include Great Blue Heron Casino or Resort Casinos). Beginning 20 (million) 21 (million) 21 (million) in 2010, RG-specific messaging made up five per cent of the digital content. Messages are rotated on a regular basis. 68
71 RG Program Quarterly Reporting and Performance Measures Following the full implementation of the RG Program Directives, Gaming Marketing will be required to provide on a quarterly basis the following RG program reporting and performance measures related to RG Marketing: total number of marketing initiatives (i.e., promotions, brand advertising, direct marketing etc.) executed by Service Provider with description including campaign/ promotion name, target audience, advertising medium (e.g., direct marketing, print, online, television), and timing total number of RG Marketing Assessments completed total number of complaints from self-excluded individuals and Service Provider response to the complaints OLG will use these measures to assess the effectiveness of its efforts to ensure Gaming marketing is RG-appropriate. RG Program Area Review OLG will provide an overall assurance of quality of the RG assessment criteria, tool and resources for developing RG-appropriate marketing by conducting a formal review every 36 months. The purpose of the review is to ensure the criteria, tools and resources continue to be informed by recent developments in the available research, as well as leading/evolving best practices from other organizations and jurisdictions, and are updated periodically in response to issues that arise in the practical application of the criteria, tools and resources. OLG may engage a third-party expert agency to conduct the review and/or to validate review results for quality assurance. GAPS AND OPPORTUNITIES Control Activities: Resort Casinos, cgaming, Lottery, and igaming The new AGCO RG standards for advertising and marketing apply not only to OLG s Gaming and igaming product lines but also to its cgaming lines of business. AGCO is also currently developing RG standards for Lottery, which are expected to closely mirror the current Standards and to be completed in mid-late and OLG will be working in 2014 to harmonize its RG Program with that of the Resort Casinos to ensure all Gaming Sites within the oversight of OLG will have a gold standard for RG programming under Modernization. The project to harmonize RG Programs with the Resorts is currently in the planning stage and implementation is expected to begin in May Lottery and cgaming The lack of formal policies and procedures in cgaming and Lottery represents a gap in their RG Programs to ensure compliance to the OLG RG marketing standards. OLG is currently designing and evolving the RG Programs for these other lines of business to incorporate the RG Marketing Program area from Gaming, which builds RG consideration into the marketing development and approval process and supports marketing employees capacity to develop RG-appropriate marketing. The program elements will have to apply to the current state of OLG-operated lines of business and the future state under Modernization and the cgaming revitalization plans. Program Directives for Lottery and cgaming are expected to be completed by August 2014, with implementation to follow immediately. igaming For igaming, although the marketing process does include the use of the RG Marketing Assessment Tool, OLG will look into opportunities to make the process more robust by deploying one or all of the other RG marketing elements being used by Gaming. This fits into a longer-term goal for the overall OLG RG Program, which is to eventually standardize the RG Program area of RG Marketing for all lines of business that perform a marketing function. This would include one Marketing and Advertising Standard, one RG Marketing Assessment tool, the availability of decision support tools, and the same reporting requirements that would apply to all lines of business. Resort Casinos The Gaming Program Directives described above establish a control environment for OLG-operated Gaming Sites to ensure these AGCO RG standards are met. The level of compliance for OLG Resort Casinos is not clear, however, 69
72 WLA PROGRAM ELEMENT 7: PLAYER EDUCATION PROGRAM STATUS: 2010 SUBMISSION OLG s 2010 WLA submission outlined a comprehensive player education program spanning its gaming and lottery operations, as well as programming aimed at the general public. It Pays to Know was a newly launched, player-focused communications platform that successfully delivered RG information to players through multifaceted media. The strategic focus of player education programming was clear: communicate to players directly - in gaming sites, at lottery retail locations and through direct marketing channels. For the first time, players were incented to learn about RG through marketing promotions and contests. Qualitative and quantitative research validated that this approach was effective: players RG awareness and knowledge had increased, and they had a desire to learn more about RG and understand how it contributed to a positive player experience. The gaps and opportunities identified in OLG s 2010 submission are summarized in Table 7.0 and are detailed in the update below: Table 7.0 Gaps and Opportunities in 2010 Submission Current Status Update Player Education Across Gaming Channels Develop measurement tools and targets for different player education deliverables specifically based on the It Pays to Know platform Integrate It Pays to Know communications into Charitable Gaming Explore potential of providing play activity to Loyalty Card members through online statements In place/continuous: Updated metrics document (RG Scorecard) allows us to track interaction and awareness year over year to help make informed decisions about the areas in need of further program development. In place: Distribution and placement of Bingo-specific It Pays To Know material including brochure and posters. In place/continuous: The website for OLG s Winner s Circle Rewards loyalty program allows members to check their win/loss statement over the past calendar year. In 2014, OLG will launch a full-scale promotion targeted to Winner s Circle Rewards members incenting them to assess their play with this tool. Responsible Gaming Resource Centres (RGRCs) Enhance awareness and promote value of RGRCs at Gaming Sites and resorts Develop feedback and reporting system to inform enhancements to interactions with player awareness of RGRCs (measurement, targets) In place/continuous: RGRC s value and educational events have been promoted directly to players through onsite digital signage advertising. In place: Quarterly Reports are produced by RGC for OLG MCSR. 70
73 Gaps and Opportunities in 2010 Submission Current Status Update Lottery Retail Develop evaluation tools and targets to improve lottery players RG awareness In place/continuous: Perceptions regarding lotteries are measured through the Annual Player RG Awareness Study. Targets are set and tracked in the RG Scorecard and Measurement Report. In 2014, OLG contracted a market research firm to conduct a player awareness survey to understand general perceptions of RG and level of knowledge about gambling among different types of players including lottery. Use the It Pays to Know (IPTK) communications platform to target lottery players In place/continuous: OLG has implemented structural and design changes, including new interactive tools such as Lotto Draw Simulator, risk assessment and the Slot Machine Video. An online contest was successful in directing players and the public to knowyourlimit.ca. Lotto Draw Simulator Risk Assessment The Slot Machine General Public and Players Maximize the value of knowyourlimit.ca website In place/continuous: OLG has implemented structural and design changes, including new interactive tools such as the Lotto Draw Simulator, risk assessment and the Slot Machine Video. An online contest was successful in directing players and the public to knowyourlimit.ca. Lotto Draw Simulator Risk Assessment The Slot Machine Focus on direct, targeted communications; Leverage It Pays to Know platform In place: The It Pays to Know trivia game kiosk initiative was promoted across OLG Slots and Casinos locations and extended to other lines of business. An online version of the It Pays to Know promotion was also launched and promoted to Gaming and Lottery players. See It Pays To Know Trivia Game Kiosk Promotion below. 71
74 Gaps and Opportunities in 2010 Submission Current Status Update Self-Exclusion Increase support to Self-Excluded individuals; Renew Self-Exclusion s effectiveness as a self-help tool. Introduce prize disentitlement Ongoing: A 30-minute online tutorial for individuals applying for reinstatement is currently in development. The tutorial will be mandatory for persons seeking to return to OLG s land-based and/or Internet gaming offering and is expected to launch in fall The tutorial is being developed in conjunction with CAMH and will equip individuals returning to gambling with practical information to support them in managing their play. Ongoing: OLG had developed a policy and a project implementation plan in 2010 to re-direct jackpots won by self-excluders, but the program required changes to government regulations to move forward. The AGCO Standards released in November 2013 now give OLG the mandate to proceed. Currently, OLG is developing a strategy and internal policies and procedures to implement prize disentitlement at all Gaming Sites. Self-Exclusion Launch Off-Site Self-Exclusion In place: Off-Site Self-Exclusion has been rolled out at 21 off-site offices across the province. OLG has established formal Memorandums of Understanding (MOUs) with local problem gambling counsellors or credit counselling offices. Off-Site Self-Exclusion is also discussed in WLA Program Element 6: Treatment Referral. Implement Facial Recognition technology In place: Since 2011, OLG has implemented Facial Recognition (FR) at all OLG Slots and Casinos as well as Caesar s Windsor. Implementation at the remaining Resort Casinos (Casino Rama, Niagara Fallsview Casino Resort, Casino Niagara, and Great Blue Heron Casino) is being planned over the next three years. 72
75 PROGRAM STATUS: 2011 TO PRESENT Since 2011, OLG has substantively evolved its RG player education programming. Program updates detailed below are segmented by audience: All players and the general public Lottery and Gaming players Charitable Gaming and Bingo players OLG s Self-Exclusion program is also discussed in detail in this chapter. Player Education for the Internet gaming platform, PlayOLG.ca, which will launch in 2014, is detailed in WLA Program Element 5: Remote Gaming Channels. Education Initiatives Marketed to General Public POLICIES AND PROGRAMS Knowyourlimit.ca, OLG s key online resource of RG information, is described in this section along with four other external communication initiatives that target all players and the general public: 1) GamTalk.org, 2) a print campaign for Self-Exclusion and treatment options, 3) advertising of the Ontario Problem Gambling Helpline, and 4) advertorials produced by OLG. Knowyourlimit.ca OLG s knowyourlimit.ca website is an engaging, interactive hub for the provision of rich RG information and resources to players and the general public. The site, which won the North American Association of State and Provincial Lotteries (NASPL) award for Best RG Web Site in 2012, is an important tool that works to embed critical elements of RG knowledge, practices and behaviours in the player experience. The development and enrichment of knowyourlimit.ca is an ongoing priority. Since 2010, the website improvements outlined below have been used to maximize the user experience and to reach a broader network of players and stakeholders. Enhancements to Visuals and Navigation In 2012, recognizing the need to advance the knowyourlimit.ca website to meet evolving user needs and expectations, OLG partnered with a third-party research firm to conduct a qualitative research study. In response to the findings of the study, OLG incorporated a number of structural and design changes to modernize the site, including refreshing the look and design, increasing the aspect ratio and implementing new icons and graphics. OLG continues to explore improvements to the presentation of information as well as navigation functionality. Introduction of new interactive tools Lotto Draw Simulator In 2012, OLG launched an innovative new tool featured on knowyourlimit.ca, the Lotto Draw Simulator. The first of its kind, the Lotto Draw Simulator provides players with a visual representation of the odds of winning the lottery. The simulation has the capability to display total ticket counts up to eight digits and allows players to: continuously view the simulation for as long as they desire compare odds of winning against the number of tickets purchased, emulating odds of winnings over a long period of time contrast the likelihood of matching one versus seven numbers on a single ticket view the likelihood of winning when purchasing tens versus several millions of tickets Lotto Draw Simulator RG Risk Assessment In 2013, OLG introduced How Do You Stack Up?, an interactive risk-assessment quiz that asks respondents nine questions from the Canadian Problem Gambling Index (CPGI) test to rate their risk level of problem gambling. The questionnaire and answers are designed to be visually compelling. Risk Assessment Shortened slot video In 2012, the Interprovincial Lottery Corporation s RG Sub-Committee produced a three-minute version of the nine minute video, The Slot Machine: What Every Player Needs to Know, that educates viewers on how a slot machine works. Research was conducted that revealed the shorter video to be as effective as the longer video in changing gambling cognitions and behaviours (See WLA Program Element 1: Research for more details). The threeminute version is currently featured on the website and has become one of its most commonly used tools. 73
76 The Slot Machine Promotion of knowyourlimit.ca In 2012 and 2013, OLG launched an online contest, directing players and the public to knowyourlimit.ca. The contest, which asked players a series of RG trivia questions, attracted over 42,000 online participants. This was accomplished by promoting the website and promotion through a province-wide paid online media campaign, as well heavy distribution through existing marketing channels including: POS at all Slots and Casinos (poster stand and take ones) 10,000+ digital signage screens across all Slots and Casinos and Lottery retail locations blast to RG database and WC database digital signs at Charitable Gaming Centres (where available) banner on homepage of OLG.ca, Lottery Winning Numbers page, and Contests and Promotions page web banner on knowyourlimit.ca discovery RG Conference (poster stand and take ones) More information regarding the It Pays to Know online promotion is detailed in the Gaming and Lottery section below in this Program Element. The chart below demonstrates a sharp increase in visitation traffic following the execution of the online promotion in 2013: Table 7.1 RG Feature Number of Page Views Total knowyourlimit.ca 105, ,329 93, , ,669 Cost of Play Calculator n/a n/a 2,896 7,489 10,385 Can You Beat the Odds? Pick-a-Card 5,658 6,763 3,888 3,680 19,989 What s Your Gambling IQ 5,128 5,689 2,343 5,328 18,488 The Slot Machine: What Every Player Needs to Know 13,679 14,520 6,852 8,235 43,286 Your Gambling Profile How Do You Stack Up? n/a n/a 1,423 13,939 15,362 Lotto Draw Simulator n/a n/a 1,642 6,298 7,940 Print Advertising Campaign GamTalk.org In 2013, OLG, in partnership with GamTalk, an independent non-profit organization led by Dr. Richard Wood, launched a print campaign designed to advertise the GamTalk.org website, an online community that chronicles Stories of Hope tales of problem gambling, their consequences and the journey to recovery. The primary objective of the campaign was to raise public awareness of GamTalk and OLG s association with it, and to encourage problem gamblers to submit their own Stories of Hope. A half-page full colour advertisement launched the week of June 3 rd and 10 th, 2013 and reached over 5.7 million Ontarians. Print Advertising Campaign Self-Exclusion and Treatment Options In May 2012, working with problem gambling treatment providers and credit counsellors, OLG launched a province-wide print campaign to advertise to the general public and players about OLG s new option to register for the Off-Site Self-Exclusion treatment offices. The campaign was intended to build awareness of local services, raise public awareness of problem gambling and encourage gamblers who have self-identified as having a problem to seek treatment. To execute the plan, OLG partnered with 21 treatment counsellors from across Ontario and developed 21 separate ads, each highlighting the local counseling office and related services. 74
77 The campaign was featured prominently in over 22 communities across the province through local newspapers, medical waiting room digital screens and online advertising. OLG s player research showed awareness of the Self-Exclusion program increased from 38 per cent in 2011 to 44 per cent in 2012 following the campaign. Ontario Problem Gambling Helpline Promotion in Medical Offices across Ontario In March 2012, OLG, in partnership with the Ontario Problem Gambling Helpline, ran a series of digital ads across Ontario s Medical Health Network. The ads ran for three weeks, reaching approximately 1.5 million Ontarians in medical waiting offices. Following the launch of the digital ads, there was a significant and continuous increase in calls in the subsequent months. From February 2012 to July 2012, there was a 41 per cent increase in the number of calls to OPGH. RG Advertorials In January 2013, OLG produced two advertorials published in two of Ontario s largest papers: the National Post and the Toronto Star. The articles demonstrated OLG s commitment to a sustainable player base, excellence in program research and data analysis, and a determination to support all players and connect people to local counseling services. The articles were intended to demonstrate to the public OLG s commitment to RG program excellence. MONITORING AND EVALUATION Vital Signs One of the primary ways OLG measures the impact of its public-facing messaging is through a market research survey called Vital Signs. Results show that, generally, public perception of OLG s RG Program is favourable and highly supported. In , approximately half of the people surveyed were aware of RG resources and available support services at slots and casino facilities in Ontario. Specifically, in March 2013, 51 per cent were aware that every casino or slot facility in Ontario has an RG centre, relatively unchanged from the previous year at 50 per cent. (For more information, see WLA Program Element 10: Measurement and Reporting.) Knowyourlimit.ca OLG monitors the ongoing awareness and effectiveness of knowyourlimit.ca through a variety of means. Tracking through our annual RG Player Awareness Survey shows awareness of the site has increased steadily by ten per cent since Currently, eight out of ten players are familiar with the site. Raw visitation stats show that in there were 93,500 page views and 30,000 unique visitors to knowyourlimit.ca. The chart above outlines a year-overyear illustration of visitation to different sections. In 2012, OLG conducted a series of qualitative focus groups to assess the overall effectiveness and value of the tools and information offered on knowyourlimit.ca. As a result, a number of structural and visual changes were implemented to improve the functionality of the site. Overall, most participants agreed that the site is an extremely valuable resource and would highly recommend it to friends and family. (For more information, see WLA Program Element 10: Measurement and Reporting.) OLG will continue to assess the ongoing effectiveness of the site through qualitative focus groups. GAPS AND OPPORTUNITIES Knowyourlimit.ca Currently, the technical infrastructure behind knowyourlimit.ca makes it difficult to update content on a consistent and frequent basis. A recent change in technical vendor will now make it easier to update content more frequently to ensure dynamic, changing content to encourage players to return to the site more often. As well, due to regulatory stipulations and limitations imposed by the Ontario government, OLG has been slower than other organizations to participate in social media. Recent changes have ensured that in 2014, OLG will develop a robust presence in popular social media sites and use this as a means to drive more traffic to knowyourlimit.ca. Additional Promotions Given the success of the online knowyourlimit.ca promotion described above, OLG will continue to hold annual online RG promotions, encouraging players and the general public to gamble responsibly. Site Re-Design and Development of New Interactive Modules Plans for a site re-design are underway to ensure OLG s RG web site is more flexible and better suited to mobile phones and tablets. A more mobile and tablet-friendly site and the development of new interactive modules are expected to attract more players. 75
78 More Mass Marketing In the last five years, OLG s player education strategy has been focused on players, reaching them in the environments and through the channels most likely to resonate with them. This strategy has proven to be successful, with awareness of RG initiatives resoundingly high among frequent (i.e., core) players. Yet in 2014 and beyond, OLG will shift its focus and develop more mass marketing player education campaigns such as radio, online and newspapers ads. Research shows player and public appetite to learn more about OLG s RG programming, including such initiatives as Where the Money Goes, employee training programs and OLG contributions to the RG research field. Multicultural Marketing To date, OLG s RG programming and related marketing materials (knowyourlimit.ca and It Pays to Know) have been targeted broadly to all players, across all segments and lines of business. Current market and social research indicates that there are many different ethnic groups that have a strong cultural affinity for gambling. However, according to OLG s own quantitative research, its existing RG marketing materials are not resonating with these players. As Ontario s multicultural populations become an increasingly important market for OLG s business due to their growth and increasing purchasing power, it is critical that the RG team develop culturally relevant and meaningful problem gambling prevention and support materials designed to reach these audiences. Aboriginal Advertising Campaign Ontario has the largest Aboriginal population in Canada. Research shows that persons from Aboriginal communities are in some instances three times more likely to have a gambling problem than the rest of the population. OLG has completed extensive qualitative research to understand how to best communicate responsible gambling information to distinct Aboriginal communities across the province. (Please see WLA Program Element 1: Research.) Developing RG communications that will resonate with Aboriginal communities presents a substantive yet necessary undertaking. In 2014, and in conjunction with Aboriginal communities from across the province, OLG hopes to implement a culturallyspecific marketing campaign aimed at reaching Aboriginal populations in Ontario. Gaming and Lottery POLICIES AND PROGRAMS OLG has a robust and well-established player education program in place across all its Gaming Sites and lottery retail network. Since OLG s 2010 submission, significant program developments have occurred. The section below will outline expanded It Pays to Know RG materials and placement guidelines, interactive RG promotions and new RG messaging at Lottery retail outlets. The Responsible Gaming Resource Centres (RGRCs) in all Gaming Sites also continue to be a key component of OLG s Player Education strategy and are described below. Enhancements to the program resulting from the development and implementation of the OLG-Operated Gaming Site RG Program Directives are also discussed. It Pays to Know RG Materials New RG Education Materials One of the main sources of RG information for players at gaming facilities is the availability of OLG s It Pays to Know brochures. In 2012 OLG s RG It Pays to Know brochures were updated and redesigned with a fresh look and feel. For Gaming, the updated brochures include: It Pays To Know Concerned About Someone s Gambling It Pays To Know Your Guide To Playing OLG Slots It Pays To Know Self-Exclusion: A Chance For Change It Pays To Know What s Next? Getting The Most From Self-Exclusion Recognizing the need to reach OLG s ethnically diverse and non-english or non-french speaking players, the brochures have been translated into multiple languages including: Cantonese, Mandarin, Spanish, Italian, Punjabi and Portuguese. Translated languages were determined by a needs assessment that examined a number of factors including: the multicultural makeup of Ontario the multicultural makeup of Ontario in the next ten years the participation rates in gambling of ethno-cultural groups in the Province of Ontario the geographic breakdown of ethno-cultural groups in the Province of Ontario (e.g., are they principally centered in Toronto or dispersed across Ontario, etc.) For multi-language versions visit: brochures.jsp 76
79 RG Material Requirements and Placement Guidelines In order to ensure a consistently strong presence of RG information at Gaming Sites, OLG in 2013 developed RG Material Requirement Guidelines. The Guidelines ensure that players will have reliable access to RG information to help them make informed choices about gambling, and awareness of problem gambling warning signs and local support services. The Guidelines will be reviewed biannually and will be redistributed to all gaming sites as required changes dictate. Expanded Use of Digital Signage Screens at Gaming Sites Since 2010, OLG has expanded the use of RG messages running across OLG s vast gaming digital signage marketing network. To complement the updated It Pays to Know messages already in rotation, messages regarding upcoming RG events and promotions, awareness of problem gambling prevention week, and lottery-related RG messages were included. RG content still comprises five to ten per cent of total screen content in rotation. OLG has one of the largest digital networks in North America, reaching an estimated 20 million people in New Digital Signage messages introduced in 2014 include: RGRC Take a Break encouraging players to take a short break from gambling and enjoy a cup of coffee at the Responsible Gambling Centre Problem Gambling Awareness Week to highlight various problem gambling awareness weeks across Ontario Don t Bank on a Big Win a Lottery-themed message encouraging players to set realistic expectations when playing the lottery. Interactive RG Promotions It Pays To Know Trivia Game Kiosk Promotion Building on the success of the initial pilot program described in OLG s 2010 submission, the It Pays to Know interactive kiosk promotion was rolled out to all OLG Slots and Casinos locations and extended to Charitable Gaming locations, the Lottery Prize Centre, Resort Casinos and a number of OLG community and sponsorship events. The promotion, now available to all lines of OLG s business, has customized content and asks trivia questions specific to the respondents primary form of gambling. Designed to increase player awareness of key RG principles and potentially change player behavior, players are incented to participate with the chance to win a $5,000 gift card. From , the It Pays to Know kiosk promotion received highly positive customer feedback and successfully engaged with 124,000 customers by delivering RG information in a both entertaining and convincing format. The promotion also provided OLG with a wealth of player market research data. Notably, for players who chose to provide their Winner s Circle Rewards card information, we were able to analyze their play patterns 60 days prior to the promotion and 60 days after it. The analysis included players play and looked at different metrics, including Coin In, Net Win, Visitation and Duration. It Pays to Know Trivia Game Online Promotion Building on the success of the kiosk promotion and expanding its reach, an online version of the It Pays to Know promotion was launched in the spring of For those who didn t have the opportunity to interact with the travelling tour, they could now participate online. The online microsite was promoted with online banners, POS at lottery retailers across Ontario, and POS at all 19 Slots and Casino locations in the province. The online initiative attracted over 42,000 participants who completed the Trivia Game while testing and receiving RG-related information. Loyalty Member Customer Statements In June 2012, OLG s Winner s Circle Rewards loyalty program launched a new feature on its website enabling online members to check their win/loss statement over the past calendar year. This new feature was advertised to players via the Winner s Circle Rewards Newsletter and through digital signage at all OLG Gaming Sites. Since its launch, nearly 25,000 Winner s Circle Rewards members have used this feature. Given this strong response, OLG plans to launch a full-scale promotion in 2014 targeted to Winner s Circle Rewards members and incenting them to assess their play using an innovative and interactive tool. RG Loyalty Program: Direct Marketing to Gaming Players The RG team has built a database of RG player information. Data fields include contact information, some Winner s Circle Rewards numbers, and the customers answers to a series of RG related questions depending on which promotions they entered. The current database has approximately 60,000 individual customers and is growing. 77
80 OLG engages with these customers by sending three blasts to them throughout the year. Content typically consists of RG-specific messaging about upcoming and ongoing RG promotions, and RG information and resources available. The goals are to create awareness around RG and drive visitation and traffic to knowyourlimit.ca. It Pays To Know Play Smarter Sticker at Lottery Retail In 2012, OLG s RG team, in conjunction with the lottery retail marketing team, developed a Play Smarter sticker, placed prominently on all Lottery retail booths, that conveys a simple message to play responsibly and find out how by visiting knowyourlimit.ca. It is an important way to reach customers at the moment of decision. Responsible Gaming Resource Centres (RGRCs) RGRCs are specially designated, onsite, stand-alone facilities that offer comprehensive RG information through trained and dedicated staff, and through multiple formats such as brochures, videos, posters, digital signage, interactive kiosks and special education events. The Responsible Gambling Council (RGC), an independent non-profit organization dedicated to the prevention of problem gambling, operates an RGRC at each of the 24 Gaming Sites (19 OLG land-based Gaming Sites and five privately-operated Resort Casinos) across Ontario. Funding for the program and space for the Centres are provided by OLG. From fiscal to the end of fiscal , over 500,000 customers accessed RGRC services at Gaming Sites in Ontario. Since inception of the program in 2005, over 750,000 customers have visited an RGRC or taken part in an RGRC-run player education initiative. RG Program Directives The RG Program Directives for RG Customer Education were finalized in February 2014 and are currently being implemented. The Directives were developed to meet the ACGO s RG Standards for Gaming and to standardize the delivery of RG customer education across all Gaming Sites. They will ensure that essential RG information will be available, visible and accessible to all Gaming Site customers through the strategic development and deployment of the RG Customer Education initiatives. Essential RG information includes gambling risks, setting time and money limits, where to get help (i.e., Ontario Problem Gambling Helpline, OLG Self-Exclusion program) and game information (i.e., rules of play, odds of winning, payout odds and/or return to players). Full implementation is expected by March MONITORING AND EVALUATION OLG has a number of qualitative and quantitative means of monitoring and evaluating the success and progress of our player education programming at Gaming Sites and through the lottery retail network. With Know Your Limit. Play Within it as our umbrella message for safe gambling and It Pays to Know as our core educational concept, OLG s player research results have consistently shown high player awareness of key RG program components. Player Awareness Research Our strategy to market RG information directly to players in the environments where they gamble has been successful. In 2014, OLG commissioned player research of frequent casino-style gamblers which showed that 76 per cent consider themselves to be knowledgeable about responsible gambling. Table Total Frequent Gamblers Infrequent Gamblers Lapsed Gamblers base: total gamblers (501) (100) (106) (295) % % % % top 2 boxes (very knowledgeable or somewhat knowledgeable) very knowledgeable somewhat knowledgeable not very knowledgeable not at all knowledgeable don't know
81 Year over year statistics among casino-style gamblers remain positive, with over 93 per cent in 2014 aware they should only bet money they can afford to lose, and 90 per cent sticking to pre-set limits (n=502) (n=501) You should only gamble with money you can afford to lose You should set spending limits you can afford, and stick to it each time you gamble You should gamble for entertainment and not to win money You should never gamble to win back losses It is important to set a time limit when you gamble You should take frequent breaks when you gamble Similarly, lottery players particularly frequent lottery players who ostensibly have the greatest exposure to RG information claim to be knowledgeable of the key fundamentals of the games. Table Total Core Players Regular Players Infrequent Players base: total lottery players (508) (197) (181) (130) % % % % top 2 box very knowledgeable somewhat knowledgeable not very knowledgeable not at all knowledgeable don't know arm instead of push the button
82 As well, year over year lottery survey results show a solid understanding of randomness and odds, while around 40 per cent believe in a lottery myth of some kind, as the chart below demonstrates: Table 7.4 agreement with statements (% agree) sample size (lottery players only) (400) % (601) % (500) % (508) % do not believe in any myth n/a n/a you can improve your chances of winning a lottery by choosing certain numbers or combinations of numbers your chances of winning a lottery are better if you choose your own numbers with a selection slip your chances of winning a lottery are better if you choose numbers that have come up more frequently than others in the past the organization who runs lotteries in Ontario chooses who wins jackpots based on where the ticket is sold your chances of winning a lottery are better if you choose numbers that have not come up in the draw for a while playing lottery tickets is a form of gambling n/a n/a people who play lottery tickets are at risk of developing unsafe gaming habits or problem gaming n/a n/a As we advance our player education strategy, OLG s goal is to reach all players across the entire customer lifecycle and to provide a platform that will not only create strong RG awareness among players, but also embed key RG principles into the overall player experience. Independent Player Education Program Overview In 2013, we consulted with an external brand agency to examine our existing player education platform, to assess its strengths and weaknesses and to explore creative ways to maximize OLG s player education efforts. The external firm performed a thorough analysis of OLG s existing player education program. Specifically they: 1. reviewed and aggregated existing, OLG-supplied research findings 2. comparatively reviewed OLG RG, RGC, and other organizations RG player communications materials and websites 3. reconceived and rebranded player education offering, developing an extensible platform a larger umbrella that can encompass a wider range of ideas and connect more strongly as part of actual gaming experience rather than adjacent to experience 4. interviewed key personnel from OLG RG, OLG corporate, RGC, CAMH, BCLC RG (GameSense), and Research Strategy Group 5. conducted site visits to observe Responsible Gambling Resource Centres (staffed and unstaffed) and other promotions and tactics (OLG Slots at Ajax Downs and Mohawk Racetrack) and to conduct employee interviews 6. consulted secondary sources including: RG and PG resources (publications, websites) commercial gambling websites The assessment highlighted key areas of the program s strengths, such as established player awareness, strong visible presence in gambling facilities and the community, and a consistent message across an expandable framework. It also highlighted areas for improvement, including messages that are too narrow (cautionary) in scope. Most notably, although RG messages were deemed relevant to players, they weren t considered to be part of the actual gaming experience. 80
83 RGRC Quarterly and Year End Reports Since the previous OLG WLA submission, the RGRC Program has worked to standardize reporting and now provides OLG quarterly visitation reports and annual year end program overview reports. The following chart illustrates quantitative RGRC metrics which are tracked annually to assess performance. This tracking data helps to identify program focus areas. For example, in fiscal educational event participation had declined; therefore, RGRC was tasked with boosting participation in fiscal Also, a decline in MARGI use in fiscal has resulted in RGRC developing new MARGI activities and proposing a new MARGI technology refresh/replacement. Table 7.5 Quantitative Measures from Annual RGRC Report - Year Over Year Comparison Measure Description Fiscal Fiscal % Change Total RGRC Visits (Information, Assistance, Education) 191, ,376 21% Information Visits 72,965 75,214-3% Assistance Visits 3,301 2,848 16% Educational Event Participation 115,492 80,314 44% Customer Referrals to Support Services 3,301 2,985 11% MARGI Usage 41,614 47,277-12% Website Visits 20,307 18,493 10% Self-Exclusion Support 3,020 2,511 20% Venue Referrals to RGRC 1,652 1,474 12% RG Program Area Review Gaming RG Customer Education will be formally reviewed every 36 months by MCSR Social Responsibility in consultation with Gaming Sites after implementation of the Program Directives. The review will assess whether RG Customer Education reflects and supports current RG policy and other RG Program areas and is consistent with latest research and industry best practice, in order to identify potential improvements to educational content, delivery and program monitoring. OLG may engage third-party expert organizations to conduct the review and/or validate some or all of review results for quality assurance purposes. OLG Quarterly RG Report - Gaming After implementation of the Program Directives, OLG will produce quarterly reporting and performance measures on RG Customer Education that will enable assessments of program performance and effectiveness. These measures include many of the metrics above as well as types of RG collateral delivered to Gaming Sites and the number of RG-related Gaming Site customer referrals received by the OLG Customer Support line. GAPS AND OPPORTUNITIES New RG Branding As a result of the findings from the player education program overview that was conducted in 2013 by an external brand agency, OLG plans to reconceive and rebrand its player education offering with a platform that will support a wide range of ideas and connect to the actual gaming experience. As part of this rebranding, we will broaden the scope of messaging to target a wider range of players. For example, instead of targeting RG messages to existing casual, serious or at-risk players, we will cover the entire frequency spectrum to communicate to: new/infrequent gamblers: reach them before they develop bad habits and learn myths serious gamblers: build on the current suite of communications to make them more engaging and relevant chronic/pathological gamblers: reinforce and support better awareness of the problem and help options 81
84 Win/Loss Promotion To incent loyalty card members to check how much they re actually spending per year on gambling, in 2014 OLG will launch a promotion to enter card members into a contest for a chance to win a $5,000 gift card. The contest will ask participants to guess how much money they have won and lost at slot games in the previous year. Players will then be provided with their actual wins and losses. OLG has engaged academic researcher Dr. Michael Wohl of Carleton University to assess the short- and longterm impact of this knowledge on participants player behaviour. (For more details, please see Assessing the Impact of a Win/Loss Tool Among Winner s Circle Members in WLA Program Element 1: Research.) Slot Classification Project As part of OLG s strategy to promote informed player choice, a project is underway to educate players on some statistical concepts behind slot machine mechanics. Game concepts like slot cycle, odds of winning, payback percentage, volatility, and bonus round hit frequency will be presented to players in an easy-to-understand format and design. Working with academic researchers from the University of Waterloo, a series of player education materials will be developed including: printed materials, a short animation, a self-assessment and, ultimately, a colour/ symbol coded sticker on slot machines that articulates the game s structural characteristics (i.e., low volatility or high volatility). Communications content and materials will be thoroughly researched prior to execution. RG Loyalty Database OLG has an RG database of over 60,000 customers who have consented to receive RG communications from OLG. In the past, OLG has sent quarterly newsletters to this group, highlighting key features of knowyourlimit.ca and encouraging uptake of RG tools. In 2014 and beyond, an opportunity exists to use this database more strategically and to engage these players in a conversation about our RG Program. For example, one possibility is to incent players to participate in RG research and/or focus groups. AGCO Control Activities for Lottery The impending AGCO RG Standards for Lottery, which are likely to be very similar to the Standards for Gaming, will require formal, documented policies, procedures and resource tools to ensure that Lottery customers will be exposed to appropriate RG customer education. In preparation for the Standards, OLG is working towards formalizing, documenting and designing its Lottery RG Program to meet or exceed the AGCO RG Standards for customer education (as described in the Introduction: RG Standards Implementation). The documentation of the RG Program is also critical for the Modernization Plan since it will provide direction for the new Lottery Service Provider that takes over Lottery operations. Like the RG Program Directives for Gaming, the RG Program Directives for Lottery will ensure that essential RG information will be available, visible and accessible to all Lottery customers through the strategic development and deployment of RG Customer Education initiatives for the Lottery retail environment. The Lottery RG Program will also include RG reporting and measurement requirements to enable assessments of program effectiveness. As well, to ensure the customer education programming is kept relevant and up to date in light of current research and knowledge, leading or evolving best practices in the industry or field, or changes in the operational context, OLG will conduct periodic review of the programming area. Program design (i.e., RG Program Description for Lottery) is nearing completion and development of the RG Program Directives for Lottery is expected to begin in April Charitable Gaming POLICIES AND PROGRAMS Integration of It Pays To Know Communications In 2011, OLG developed some product line-specific communications for its Charitable Gaming environment. OLG distributed an It Pays To Know brochure, entitled Your Guide to Playing at OLG Charitable Bingo and Gaming Centres, that was the first of its kind in providing Charitable Gaming players with specific information about: the facts about bingo games in Ontario and your chances of winning and losing Break Open Tickets (BOTs), INSTANT Win Games, Seal Cards and Event Games Electronic Play On Demand (POD) Games how to keep Charitable Bingo and Gaming fun warning signs that your play is becoming a problem Along with its onsite availability, the brochure was widely distributed to key RG stakeholders and made available at a number of RG conferences and available for download on olg.ca. 82
85 OLG also developed Charitable Gaming-specific It Pays to Know posters that are widely distributed across Charitable Gaming Centres in Ontario. A poster communicating the availability of the Ontario Problem Gaming Hotline (OPGH) was also widely distributed and displayed for players at the Centres. Responsible Gaming Resource Centres (RGRCs) As described in the Introduction, the Charitable Gaming sector in Ontario is undergoing a significant transformation, with expanded electronic game offerings at 37 commercially operated centres. This industry expansion has considerably increased OLG s need to continue to expand its robust RG player education offerings at Charitable Gaming locations. In response to this need, OLG and the Responsible Gaming Council (RGC) are in the process of installing 37 self-serve RGRCs at these Charitable Gaming Centres. RGRCs are specially designated, on-site, stand-alone facilities that offer comprehensive RG information through multiple formats such as brochures, videos, posters, digital signage, interactive kiosks and special education events. As with the RG player education programming at OLG Gaming sites, RGRCs will be a key component of RG player education programming at cgaming sites in that they are one of the primary ways OLG provides RG information and support to its customers on site will see the first 12 RGRCs installed, with all 37 complete by March 31 st, The self-serve RGRCs will have employees providing regular RGRC operational support and engaging in periodic opportunities for RG promotion and education. RGRC employees visit the RGRCs on a regular basis to: deliver RG educational events (three times a year, each delivered twice to extend reach) complete regular site visits (three times a year). At these visits, RGRC employees share information with customers face-to-face, respond to customer questions about responsible gambling-related topics and provide immediate assistance and referrals if a concern is raised by a customer respond to Bingo employee questions about supporting customers who may express a gamblingrelated concern organize and implement a back-of-house educational event once a year for Bingo employees to share information about the role and services of the RGRC restock the literature stand during each visit The self-service RGRC offers a number of educational services that are designed to be appealing, accessible and educative to RGRC visitors. Literature The RGRC will offer five brochures for customers: A Quick Guide to Safer Gambling A Quick Guide to Safer Gambling for Older People Are You Concerned About Someone s Gambling? Why it s Important to Talk to your Teen about Gambling Gambling Myths and Gambling Facts Gambling Myths and Gambling Facts will be re-written for the Charitable Gaming context and will be produced in nine additional languages, bringing it to the same level of language accessibility as the other RGRC brochures. In addition, community resource material will continue to be sourced and available in the RGRC literature rack. MARGI MARGI is an easy-to-use interactive RG information kiosk which has been re-designed specifically for the cgaming environment. This new floor-standing MARGI offers a variety of fun and interactive activities for customers to play. Through these game-style activities, customers will gain knowledge on key gambling concepts such as odds, independent outcomes, randomness, house edge and chance. To keep MARGI engaging for customers, a new MARGI activity will be added or updated on an annual basis. The first new activity to be introduced into MARGI will be geared specifically for customers RG experience with the new Bingo products. In future years, a needs assessment will determine the focus for the MARGI offerings. RG Educational Events Educational events are an effective method to reach out to all customers about responsible gambling topics in an informative, personal and engaging manner. RGRC employees will organize, support and customize three existing RG educational events over the course of the year for the CGCs. These events may include, for example: Fact or Fiction: This plinko-based game educates customers around some the myths associated with gambling using a question and answer format. Modifications can be made to the questions cards to reflect the bingo game offering or environment. 83
86 Problem Gambling Prevention Week: RGRC employees drive the implementation of this province-wide public awareness campaign in gaming venues to increase awareness of problem gambling. This campaign is funded by the Ministry of Health through the RGC, the operators of the RGRCs. Spotlight on the Games: A dice game that invites customers to learn more about their favorite games in the context of the chances of winning and losing and safer gambling tips. Bingo-styled games can be easily added to the suite of games highlighted in this event. MONITORING AND EVALUATION RG Player Awareness Survey 2014 was the first year to that the RG Player Awareness Survey assessed awareness and effectiveness of RG Program elements among Charitable Gaming players. This year s sample will be the baseline for subsequent waves of research among charitable gaming players. Some highlights from the 2014 RG Player Awareness Survey among Charitable Gaming players include: 55 per cent considered themselves somewhat or very knowledgeable about how gambling works at Charitable Bingo and Gaming Centres 37 per cent do not believe in any Charitable Gaming myths 53 per cent recall seeing or reading information about responsible gambling at the CGCs 77 per cent have heard of the Ontario Problem Gambling Helpline 54 per cent have heard of brochures at CGCs that describe the warning signs for problem gambling and tips to gamble responsibly 86 per cent reported they have set a spending budget in the past 33 per cent felt unhappy after they finished playing games at CGCs 72 per cent somewhat or strongly agree that OLG is doing a good job making sure that Ontarians gamble responsibly at CGCs RGRC Quarterly and Year End Reports On a quarterly basis, RGRC will provide statistical data and progress updates regarding program developments at CGCs. Statistical data will include total visitors to each Centre (information visitor, interaction visitor, event participation) and MARGI visitors to each Centre, per month. An annual Program Report will also be provided. GAPS AND OPPORTUNITIES Evaluation and Measurement of RGRCs at Charitable Gaming Sites With the RGRC program still in its infancy at Charitable Gaming Centres, there have not been any performance reports provided to date. By the end of 2014, reporting and evaluation will have been completed for a full year, and OLG will have received quarterly statistic reports and a final annual program report from RGC. These reports will highlight total visitor and MARGI kiosk interaction numbers, and allow OLG to begin to assess and track the value of RGRCs at Charitable Gaming Centres. The program reports and future needs assessments will allow OLG to make informed decisions about various program elements, and help benchmark their success. AGCO Control Activities OLG is currently finalizing the design of its overall RG Program for cgaming sites, which is expected to be completed in April Upon finalization, OLG will create specific RG Program Directives to operationalize the design. These directives will ensure the cgaming sites meet the AGCO RG standards for RG Customer Education that stipulate that cgaming customers be provided with accurate and meaningful RG information in an available, accessible and visible manner. This RG information will pertain to gambling risks, spending limits, available help resources and game mechanics. The RG Customer Education initiatives being rolled out or planned for the cgaming Centres will be a central part of this assurance. Self-Exclusion POLICIES AND PROGRAMS OLG has made considerable improvements to its Self-Exclusion program since OLG rolled out an Off-Site Self-Exclusion registration option across the province and has implemented Facial Recognition technology in all OLG Slot and Casinos. A Self-Exclusion sensitivity training component has been added to the RG Training to assist employees who administer Self-Exclusion in dealing with potential sensitivities with program participants that may arise in program administration. A two-phase research project is underway to introduce an additional support to players at the time of their Self-Exclusion registration by providing them with a motivational video to seek treatment. Furthermore, following completion of the Self-Exclusion ban, players who wish to return to OLG gaming sites will be required to complete a mandatory Responsible Gambling tutorial as part of their reinstatement process. 84
87 Self-Exclusion has also expanded beyond the scope of land-based Slots and Casinos. PlayOLG.ca will launch in 2014 with a Self-Exclusion program which replicates the core program elements of land-based Self-Exclusion. OLG also undertook a feasibility study to determine if Self-Exclusion could be introduced into the Charitable Gaming and Bingo environment. The following statistics outline the number of enrollments in the Self-Exclusion for Gaming since 2010: Table Self-Exclusion Registrations 3,017 3,001 2,917 2,983 Self-Exclusion Reinstatements 1,743 1,880 1,886 1,838 Self-Exclusion Breaches 1,396 1,996 1,910 1,977 Off-Site Self-Exclusion An enforcement-to-assistance-registration process, which was in development at the time of the 2010 submission, has since been implemented across Ontario. The Off-Site Self-Exclusion registration option provides another means by which a person can enroll in the program without having to be at the Gaming site. Local problem gambling counsellors or credit counselling offices with whom we have established formal Memorandums of Understanding (MOUs) provide the majority of off-site offices. By having the off-site registration locations at community treatment facilities, OLG further strengthens the link between the Self-Exclusion program and treatment enrolment. Using Self-Exclusion as a means to encourage and assist problem gamblers to seek treatment was one of the main recommendations of a 2008 study by the Responsible Gambling Council on best practices in Self-Exclusion. There are currently 21 off-site offices across the province with plans to expand into additional communities. Since off-site registration has been available, OLG has conducted over 325 off-site registrations. Off-Site Self-Exclusion is also discussed in WLA Program Element 6: Treatment Referral. Facial Recognition Since 2011, OLG has implemented Facial Recognition (FR) at all OLG Slots and Casinos as well as Caesar s Windsor. Implementation at the remaining Resort Casinos (Casino Rama, Niagara Fallsview Casino Resort, Casino Niagara, and Great Blue Heron Casino) is being planned over the next three years. Since the FR pilot in 2010, OLG has nearly doubled its annual rate of Self-Exclusion detections. Table Self-Exclusion breaches 883 1,396 1,996 1,910 1,977 Table FR alerts Jackpot alerts Manual detection Not indicated 1,
88 Self-Exclusion Sensitivity Training The enhanced RG Training for Gaming employees that is being implemented in 2014 (see WLA Program Element 2: Employee Training) will include new content for all security and supervisor-and-above level employees. These employees generally respond to the more serious situations that may call for Self-Exclusion discussions or actually administer the program itself. This additional content is intended to address a gap in soft skills for those responsible for registering people in the Self-Exclusion. The mandatory training includes skills and techniques to help reduce stigma around problem gambling and Self-Exclusion, as well as promote understanding of cultural differences. Reinstatement Tutorial In 2011 OLG consulted with OLG Security, gaming operators and independent problem gambling clinicians to determine plans for additional support for individuals returning to gambling after Self-Exclusion. Individuals applying for reinstatement currently receive a Responsible Gambling information package following the completion of their reinstatement meeting. A 30-minute online tutorial prior to reinstatement is currently in development. The tutorial will be mandatory for persons seeking to return to OLG s land-based or Internet gaming sites, and is expected to launch in fall The objectives of the tutorial are: 1. provide key information about gambling, game odds, safe gambling tips, and player control tools to players returning after Self-Exclusion 2. simplify the process of reinstatement, and standardize procedures with igaming 3. collect anonymized data that can be used to improve the Self-Exclusion program The tutorial is being developed in conjunction with CAMH and will equip individuals returning to gambling with practical information to support them in managing their play. OLG has also contracted CAMH to study the effectiveness of the tutorial by measuring changes in player behaviour following their reinstatement. (For more information on the evaluation project, please see Self-Exclusion Reinstatement Tutorial Evaluation in WLA Program Element 1: Research.) ITrak Enhancements OLG is currently enhancing the Self-Exclusion database, itrak, by upgrading to the latest version of itrak software. The upgrade will provide additional and more advanced functionality and address issues with the current itrak version, including an initial data cleanse. The update will remove any data errors and fields that are no longer considered mandatory or required, and subsequent routine data cleansing will maintain data integrity. Additional enhancements include: the development of new reports, including breach reports and Facial Recognition conduct and manage reports enhancements to the integration of the itrak system and our Player Information Repository (PIR) system a new training environment that will allow for better itrak training MONITORING AND EVALUATION Facial Recognition (FR) Technology The implementation of Facial Recognition (FR) technology has become a significant component of the Self-Exclusion program s detection capacity. FR has helped nearly double the rate of detection since first implemented as described above. However, given that it is a new program technology and is sensitive to various environmental factors (lighting, positioning/angles etc.), OLG began conducting a Quality Assurance program in 2013 to help ensure FR is operating optimally. This program monitors the performance of the FR system by registering designated employees into the FR database and, for a given period each quarter, logs the number of positive hits. Reports are then sent to OLG Corporate Security for analysis of detection effectiveness and opportunities for continuous performance improvement. OLG has also conducted audits of the FR system. In 2011, Deloitte was contracted to audit the system over two phases to meet privacy requirements and detection effectiveness. Responsible Gambling Council Beginning in 2009, OLG commissioned the Responsible Gambling Council (RGC) to conduct a two-year study to evaluate the use of Resource Gambling Resource Centre (RGRC) employees to offer information and support during Self-Exclusion program registration, renewal and reinstatement. While the study initially began with a randomized, longitudinal, between-groups and within- 86
89 groups experimental design involving five locations, the research design and recruitment methodology continually changed in response to the study s great difficulty with recruiting participants. In the end, despite being reduced to a one-sample, within-groups design with two followup surveys, the study was unable to generate a large enough sample size to produce any reliable results. After 18 months of recruitment at five sites, only 15 self-excluders consented to participating in the study, with dramatic drop-off at each subsequent survey period. The study s report provided lessons learned for OLG in recruiting participants for Self-Exclusion research. Off-Site Self-Exclusion Survey Finally, to assess the Off-Site Self-Exclusion registration option, OLG surveyed its Off-Site Self-Exclusion partners in 2012 about their experience with the off-site process. Over 75 per cent of respondents had at least a good or very good experience with the Off-Site Self-Exclusion process. Table 7.10 How would you rate your overall experience with Off-Site Self-Exclusion? Responses Response % Has been very good Has been good Has been satisfactory Has been negative 0 0 Table 7.11 Have you experienced any problems (by you or your client) in Self-Exclusion registration? Responses Response % Technical issues Problems booking appointments with OLG staff Logistical issues (room availability, Wi-Fi) Human resources Issues None
90 This survey is also discussed in WLA Program Element 8: Treatment Referral GAPS AND OPPORTUNITIES Prize Disentitlement Section 3.2(2) of the Registrar s Standards for Gaming (November 2013) prohibits a gaming site to pay out prizes to an individual who is registered in the OLG s Self-Exclusion program. To comply with this AGCO Standard, OLG will need to implement a prize disentitlement provision for OLG Gaming Centres, including OLG Slots and Casinos, Charitable Gaming Centres and Internet Gaming. OLG had developed the policy and a project implementation plan in 2010 to re-direct jackpots won by Self-Excluders but the program required changes to government regulations to move forward. With the AGCO Standards released in November 2013, OLG now has the legal mandate to proceed. Currently, OLG is developing a strategy and internal policies and procedures to implement this prize disentitlement provision at its existing Slots and Casinos and mitigate potential risks that could be associated with its introduction. Key issues and mitigation actions related to the introduction of this change include potential legal actions, notice to players and redirection of funds. Prize disentitlement will also be incorporated into the Self-Exclusion programs currently in development for Charitable Gaming Centres and Internet Gaming. Facial Recognition (FR) Technology To complete full implementation of Facial Recognition in the OLG Self-Exclusion program, and help ensure consistent detection rates across Gaming sites, FR technology needs to be installed at four OLG resort casinos. Currently, all OLG Slots and Casinos and Caesar s Windsor have FR technology. OLG has begun planning for implementation at Niagara Fallsview Casino Resort, Casino Niagara, Casino Rama, and Great Blue Heron Casino. After FR technology has been implemented at all OLG and Resort Casinos, OLG will undertake a thorough review of the technology to evaluate overall performance and identify ways to increase detection rates. This review will also assess the effectiveness of the quality assurance program that monitors FR technology performance and effectiveness. Optional Exit Survey To determine if the Self-Exclusion program is helping to meet the needs of program participants, the mandatory reinstatement tutorial that OLG is developing will include an optional exit survey. This survey will enable OLG to obtain feedback on the effectiveness of the video but also on the Self-Exclusion program overall. OLG plans to include questions in the survey from academic researchers hoping to study the Self-Exclusion program. To date, research on Self-Exclusion has been difficult to execute for a variety of reasons, including limitations of contact with self-excluders and reluctance of self-excluders to sign up for independent research. The anonymized exit survey will provide valuable opportunity for OLG to gather feedback on the effectiveness of Self-Exclusion and on participant satisfaction with the program. The findings are also expected to facilitate research for continuous program improvements. Standardized Breach Procedure Although Gaming sites have always provided RG information to self-excluders who are caught breaching, this process has not been standardized or documented and therefore subject to inconsistency across sites and breach incidents. OLG is working towards developing a formal procedure to clearly guide gaming site employees for meeting with a person who is caught breaching their Self-Exclusion. Breach meetings are an opportunity to review the Self-Exclusion program and terms with individuals, provide treatment provider information, update photos for the purposes of detection and log any meeting documentation within the itrak database. This procedure will help self-excluders understand the consequences of their breaching and obtain further support services information from the Gaming site, as well as allow OLG to audit the content of the breach meeting. New Methods of Detection OLG continuously monitors research and best practices for opportunities to evolve and improve Self-Exclusion. One area of potential opportunity is detection. OLG plans to examine the feasibility of introducing new methods of detection (in addition to manual detection, loyalty card alerts and FR). OLG may examine the applicability and feasibility of prize disentitlement, license plate recognition technology and identification verification technologies, and how they can be best structured to support detection within specific gaming contexts. 88
91 Inter-Operability between Gaming Sectors Lastly, AGCO RG Standards require that, in the longterm, OLG must have a Self-Exclusion program that has inter-operability between gaming sectors. This means that players must have the option to self-exclude from more than one gaming sector when self-excluding (e.g., have the option to self-exclude from Charitable Gaming Centres when self-excluding from Gaming sites). Currently, OLG has Self-Exclusion programs for its Gaming and igaming sites only. We are currently designing a feasible program for our cgaming site network and considering possibilities for our Lottery retail network. The concept of inter-operability will be an essential and integral part of these examinations and discussions, and ultimately will be a part of the establishment of any Self- Exclusion program for these other lines of business. 89
92 WLA PROGRAM ELEMENT 8: TREATMENT REFERRAL PROGRAM STATUS: 2010 SUBMISSION As outlined in OLG s 2010 submission, our treatment referral services are extensive. A comprehensive strategy to provide and promote support tools to players is integrated into multiple lines of business and relies on multiple internal and external relationships. Relationships with Gaming site employees, the Responsible Gambling Council, local treatment providers, the Ontario Problem Gambling Helpline, and lottery retailers were all described in the 2010 submission. In order to reach players at various points of contact and with different risk profiles, these relationships were, and continue to be, supported by formal MOUs between OLG and stakeholders, employee training, and RG information and communication efforts (e.g., knowyourlimit.ca). OLG s Self-Exclusion program is a key element in Treatment Referral and, at the time of the 2010 submission, OLG was launching an Off-Site Self-Exclusion program at local problem gambling treatment offices. Information and data from other OLG RG Program elements such as the Responsible Gaming Resource Centres, the annual Public Awareness Survey, OLG website analytics, and OLG s Customer Service Database were all used to help identify gaps and inform future direction. The gaps and opportunities identified in OLG s 2010 submission are summarized in Table 8.0 and are detailed in the update below: Table 8.0 Gaps and Opportunities in 2010 Submission Expand referral and support relationships with treatment providers Build relationship with Credit Canada Pursue partnerships and collaborations to better connect gamblers to local treatment services Current Status Update In place/continuous: Treatment services have been promoted through new channels as described below including: stakeholder engagement, Off-Site Self-Exclusion, treatment motivation for self-excluders and expanded treatment communication channels. In place/continuous: established a formal website linking agreement with Credit Canada. Credit Canada services are also promoted through a number of OLG channels including on digital displays at OLG Gaming Sites. RG training for OLG employees includes information on general credit counselling and referrals to local credit counsellors including Credit Canada. In place/continuous: Off-Site Self-Exclusion is currently offered in 21 off-site offices. 90
93 PROGRAM STATUS: 2011 TO PRESENT POLICIES AND PROGRAMS As outlined in the 2010 WLA submission, OLG continues to promote treatment services through a diverse range of channels, build strong relationships with treatment providers, and use content on knowyourlimit.ca and brochures to promote available resources and local treatment options. In 2013, OLG was required through its regulator to make essential RG information available, visible and accessible to its Gaming, cgaming and igaming customers. This information includes information about obtaining help, including Ontario s Problem Gambling Helpline and, for persons showing signs of potential problem gambling, easily accessible contact information of at least one organization dedicated to treating and assisting problem gamblers (see AGCO RG Standards 2.3 and 2.5). RG Program Directives for Gaming instills policies, procedures, tools and resources to ensure that such information is available to Gaming Site customers. (For further details, see WLA Program Element 7 Player Education: Gaming and Lottery). These Directives will be also implemented into all of OLG s other lines of business. Since 2010, OLG has worked to integrate feedback from various stakeholders into its formal referral strategy. A major part of that strategy is to expand existing programming and build stronger relationships with support services in local communities, including problem gambling counsellors and credit counsellors. By opening channels of communication, OLG has been able to disseminate key information about our games and our RG program, while learning how to best meet the needs of local support services and encouraging collaboration where appropriate. In addition to continuing to promote treatment services and raise awareness of support services through the methods described in 2010, OLG has advanced the program in four specific areas: 1) Stakeholder engagement, 2) Off-Site Self-Exclusion option, 3) treatment motivation for self-excluders, and 4) expanded treatment communication channels. Stakeholder Engagement Since 2013, OLG has conducted over 60 presentations to a variety of stakeholders including problem gambling counsellors, credit counsellors, local services, and community groups. Presentations included information on: Charitable Gaming and Bingo Internet Gaming Self-Exclusion Player Education Initiatives The presentations to treatment providers not only allowed OLG to disseminate key information, but also provided an opportunity to gather feedback about OLG programming and discuss future collaborative opportunities to further promote support service information. Credit Canada OLG has also capitalized on a key opportunity identified in the 2010 WLA submission, which is to build a formal relationship with Credit Canada. Credit Canada is a key stakeholder to help expand the reach of problem gambling information into the credit counselling arena. OLG and Credit Canada have a formal website linking agreement and work collaboratively on communications to promote Credit Canada services on digital displays at OLG Gaming sites. As well, OLG delivers presentations on new OLG products and channels to Credit Canada s counsellors while RG training for OLG employees includes information on general credit counselling and referrals to local credit counsellors. As detailed in WLA Program Element 7: Player Education, OLG has promoted Credit Canada services through a number of referral channels including: OLG s RG website, knowyourlimit.ca OLG s It Pays to Know brochures RGRC referrals OLG gaming employee referrals digital signage at OLG gaming sites support service materials provided to individuals registering for Self-Exclusion 91
94 Off-Site Self-Exclusion Registration Option An Off-Site Self-Exclusion registration process, which was in development at the time of the 2010 submission, has since been implemented across Ontario. There are currently 21 off-site offices across the province with plans to expand into additional communities. Local problem gambling counsellors or credit counselling offices with whom we have a formal MOU provide all off-site offices. Since off-site registration has been available, OLG has conducted over 325 off-site registrations. To support the promotion of the Off-Site Self-Exclusion registration option, OLG conducted a province-wide media campaign in a co-branded advertisement with local off-site offices. The development of the off-site registration option was a direct result of listening to stakeholders and monitoring best practices to ensure a wide range of opportunities are available for players to self-exclude in non-gaming environments. Off-site registration also provides selfexcluders with direct exposure to treatment services or information about problem gambling services directly from counsellors that they may not have otherwise had. Treatment Motivation for Self-Excluders The ILC is currently partnering with the Ontario Problem Gambling Research Centre on the development of a short video to motivate people registering for Self-Exclusion to seek treatment. OLG is the ILC lead for this project being conducted by a research team consisting of three academics with clinical experience. The intention is to create a video based on focus group feedback and then field-test the video at the gaming sites of the participating ILC jurisdictions. The test will measure the video s impact on self-excluder treatment-seeking behavior using a random experimental design. It is expected that OLG and the rest of the ILC members will deploy the video for their Self-Exclusion programs if there is empirical evidence of its effectiveness in motivating self-excluders to seek treatment. Expanded Treatment Communication Channels OLG expanded its communication channels to deliver treatment services information to Ontarians. As a local entertainment venue, Charitable Gaming Centres (CGCs) reach a different player base and represent a new opportunity to increase treatment awareness. CGCs now disseminate local support service information. In the past, only OLG s general treatment provider brochure, When You Are Over Your Limit, could be found at these sites. With the implementation of the RGRCs at CGCs, one can also find local support service brochures stacked in the RGRC brochure stand (for more information, see WLA Program Element 7: Player Education). New cgaming product offerings have also created an opportunity for OLG to raise awareness of treatment-related services such as the Ontario Problem Gambling Helpline. CGCs have the Ontario Problem Gambling Helpline posted on electronic bingo machine help screens and on ticket in/ticket out vouchers. The development of the new igaming site has also created new opportunities to build players awareness of resources and to bridge them to third-party support when necessary. The igaming website provides links to various RG resources and organizations throughout the site in both logged-in and logged-out states, as well as during the Self-Exclusion registration process. igaming customer service employees are also available to deliver treatment referral information to players 24 hours a day, seven days a week through telephone, online chat and channels. (See WLA Program Element 5: Remote Gaming Channels.) MONITORING AND EVALUATION As explained above, ongoing relationships with treatment providers are a key tool to monitor the effectiveness of OLG s treatment referral program and to identify areas for program improvements. In addition to outgoing monitoring with the stakeholders described above, OLG surveyed Off-Site Self-Exclusion partners and other problem gambling counsellors across Ontario in The goal of the survey was to monitor stakeholder satisfaction with OLG s RG programming and help evaluate the effectiveness of our communication channels. It was found that most treatment providers preferred to receive RG Program updates by . As such, OLG plans to develop periodic communication pieces to the stakeholder network to improve the dissemination of information. Stakeholder presentations will still be used to foster dialogue and collaboration with stakeholders. Since 2012, OLG has formalized its stakeholder engagement process and will re-evaluate stakeholder satisfaction in OLG also continues to measure the awareness levels of treatment services in an annual RG Player Awareness Survey (See Program Element: Research). 92
95 GAPS AND OPPORTUNITIES Expansion of Off-Site Self-Exclusion OLG plans to expand its current lineup of Off-Site Self-Exclusion registration locations. The success of the initial rollout has led to demand for more offices in additional communities. This will allow OLG to build stronger relationships in new communities where communication in the past was limited. Formalized Engagement Strategy with Treatment Providers OLG has formalized its engagement strategy with local support services but requires a more formalized process by which to collect and disseminate feedback. A formalized process could help local support services bring new ideas or initiatives to the table and would help OLG identify any information gaps. OLG will survey treatment providers to assess satisfaction with OLG s communication initiatives and collect feedback. Strengthen Support of Credit Counsellors Lastly, building on its current expansion of support for credit counselling and local support services, OLG will also be looking to further expand and strengthen its support of credit counsellors across Ontario. Sharing key RG information and promoting local services in Gaming Sites and Charitable Gaming Centres will help continue building these relationships. OLG has plans to support the development of RG training for Credit Counsellors in RG Coordinator for cgaming In addition, there is an opportunity to introduce the role of the RG Champion, which has been very successful for Gaming Sites, into the cgaming environment. As described in the Introduction and in WLA Program Element 2: Training, OLG is developing the RG Program Design for cgaming which will be the basis of the cgaming RG Program Directives. An RG Coordinator is one of the elements that is being planned to increase RG engagement and build RG culture in the cgaming environment. As in the Gaming environment, this role could help develop grassroots RG initiatives and relationships with treatment providers and credit counsellors. The future RG Program design and implementation phases for cgaming sites will assess the initial conditions and determine if such a role could be established as the product line is economically revived. 93
96 WLA PROGRAM ELEMENT 9: STAKEHOLDER ENGAGEMENT PROGRAM STATUS: 2010 SUBMISSION OLG s 2010 submission for the WLA Program Element of Stakeholder Engagement provided details to support its collaborative and integrated approach to stakeholder engagement. The submission outlined OLG s formal MOUs with CAMH, Ontario Problem Gambling Research Centre (OPGRC) and Responsible Gambling Council (RGC). It also described OLG s involvement with the ILC s Responsible Gaming sub-committee and the Canadian Partnership on Responsible Gaming (CPRG), as well as participation in various industry initiatives. Lastly, a list of OLG s stakeholders and several examples of stakeholder collaboration efforts was provided. A status update on the gaps and opportunities identified in OLG s 2010 submission is provided in Table 9.0. Table 9.0 Gaps and Opportunities in 2010 Submission Build relationship with Credit Canada Current Status Update Complete/continuous: OLG has built a formal relationship with Credit Canada, which includes a formal website linking agreement, Credit Canada services promotions at OLG Gaming Sites, OLG promotion of National Credit Education Week, presentations on new OLG products and channels to Credit Canada s counsellors, and inclusion of information on general and local credit counselling services in RG training for OLG employees. OLG is also in early stages of a three-way collaborative project in which CAMH will train credit counselors to intervene with problem gambling clients. For details see: WLA Program Element 8: Treat Referral and WLA Program Element 7: Player Education Continue relationship with RGC on development of RG Check standards Complete/continuous: On March 31 st, 2014, OLG achieved RG Check accreditation for its 19 OLG-operated gaming sites. OLG provided feedback on multiple iterations of RGC s new RG Standards for Internet Gambling. RGC will review PlayOLG.ca prior to launch against available RG standards for Internet gambling, including a draft version of its own RG Standards for Internet Gambling. After PlayOLG s commercial launch in 2014 and the finalization of the RGC Internet gambling standards and accreditation program, OLG will pursue accreditation of PlayOLG. For details see: WLA Program Element 10: Measurement and Reporting 94
97 PROGRAM STATUS: 2011 TO PRESENT Over the past three years, OLG has maintained and cultivated the relationships with external stakeholders described in the 2010 WLA submission, as well as relationships with the diverse groups of internal stakeholders across all lines of business. The development of an organizational CSR Strategy and Reporting Framework also provided a key opportunity to identify, map and prioritize issues relevant to RG programs in addition to other social and environmental issues. OLG recognizes the importance and value that stakeholder engagement can create for all parties involved. Accountability and respect are OLG Corporate Values (see Introduction) that set OLG s responsibility to deliver a high standard of service and value to customers, business partners, employees and the people of Ontario. Listening openly and honestly to these stakeholders enables OLG to respond strategically and deliver on its commitments. Fulfillment of the RG Program Strategy (see Introduction) and the ability to deliver effective RG programming rely on OLG s ability to build meaningful relationships with stakeholders. Throughout this submission we demonstrate the intention and practice of achieving better outcomes when all stakeholders are engaged. POLICIES AND PROGRAMS CSR Strategy and Report: Stakeholder Engagement and Materiality Analysis Stakeholder Engagement OLG contracted a third-party CSR organization (Canadian Business for Social Responsibility - CBSR) to assist in identifying a reporting structure and strategic CSR opportunities. The process involved several steps to identify and prioritize CSR issues including a literature review, sector scan and benchmarking. Stakeholder consultations were an essential step and involved stakeholder identification and internal and external stakeholder interviews which were used to conduct a materiality analysis. While OLG did not formally implement the AA1000 Stakeholder Engagement Standard that is recommended by the WLA, the stakeholder consultation process was informed by the Standard s principles of inclusivity, materiality and responsiveness. The objective of the exercise was to identify priorities, gaps, opportunities, issues and relevant metrics, as well as to further understand expectations and external perceptions across a variety of CSR issues, including RG. OLG worked with CBSR to ensure a balanced and comprehensive approach to determining relevant and significant issues for both OLG and its stakeholders. CBSR conducted in-person and phone interviews with 12 stakeholders representing treatment providers, NGO partners, RG experts, government agencies and local municipalities. External stakeholders were consulted on a wide range of social and environmental issues, with RG being identified by stakeholders as an area of particular importance and significance. The feedback received indicated that RG was core to OLG s business, and efforts should continue to include collaboration with external partners, appropriate employee training and facilitation of access to support services for players in need. General RG concerns of some of the 12 stakeholders included: interest in learning about how OLG enforces policies that relate to marketing practices, as well as game and venue design consistency in RG programming at sites across Ontario need to demonstrate positive performance during and post Modernization need to provide guidelines to players on setting limits effectively customizing RG messaging to players at risk and raising awareness among players on risk mitigation ongoing integration of RG messaging to align corporate communications and product marketing additional opportunities identified included: introduce lifetime voluntary Self-Exclusion, create protocols for investigating family concerns, and introduce further modifications to the slot machines to remove features that appeal to vulnerable players Materiality Analysis The external stakeholder consultation was combined with internal stakeholder input to highlight the key issues for an overall CSR strategy. As illustrated in Table 9.1, with respect to RG, customer education and awareness, employee training, customer assistance, engagement of retailers and operators in RG, protecting minors and transparency were regarded as significant areas. In addition to RG, other CSR pillars investigated included: value chain, community building, human resources and environmental management. 95
98 Table 9.1 CSR Pillar Area Potential Metrics Responsible Gambling Value Chain (supply chain, retail and procurement) Communitybuilding Human Resources Environmental Management (Bet on Green) change in player behavior employee training on RG protecting minors customer education/awareness assisting patrons game and venue design engagement of retailers and operators in CSR advertising and promotions (ethics) transparency and disclosure stakeholder collaboration ethics and integrity CSR standards and criteria in operator selection and performance requirements engagement of retailers and operators in CSR transparency contributions to province contributions to host cities (hosting fees) proceeds to charities community engagement/presence in the community support to employees during Modernization employee engagement learning and development employee engagement in sustainability/environmental initiatives relevant partnerships energy and paper consumption procurement and purchasing decisions % employee knowledge/confidence in RG knowledge % player awareness of RG programs/vse #s RGRC visits #s referrals to external support services #s employee interactions with players qualitative overview of application/ enforcement of policies and codes and quantitative breaches (e.g., if certain codes are not complied with) qualitative overview of policies, codes, criteria and enforcement of CSR in agreements total financial proceeds to each qualitative overview of OLG engagement activity in the community % perception of OLG as a community partner total jobs/economic contribution qualitative overview of policies, support to employees and outcomes of programs % employee engagement scores RG training rates total energy reductions total fuel reductions paper reductions employee participation in initiatives (#s) The key RG recommendations from CBSR based on this process were: build on current RG communications and emphasize RG concepts in product marketing and broader communications simplify performance metrics to communicate impacts to the public Continuous Stakeholder Engagements OLG has a number of key RG stakeholders with which it maintains ongoing engagements that drive and influence RG programming. Key RG stakeholders are: general public players across all lines of business employees across all lines of business and corporate government agencies (MOF, AGCO, MoH) business partners (lottery retail, charitable halls, associations, Resorts) RG specialist groups independent agencies (RGC, CAMH, OPGRC) RG academics/research industry peers support services treatment providers credit counselling local communities and municipalities 96
99 Table 9.2 lists the stakeholder groups engaged by OLG and summarizes the key RG issues, types of engagement and examples of OLG s response to feedback from engagement: Table 9.2 RG Stakeholder Group Key RG Issues Type of Engagement Example of OLG Response to Feedback General Public transparency and disclosure ethics and integrity survey public disclosures/ reports The general public expects OLG to operate lotteries, casinos and slots facilities in a responsible manner. OLG seeks to meet that obligation and report transparently to the public through various public disclosures including the CSR Report. Players RG Education RG Assistance Employees RG Training RG Culture-building Annual RG Player Survey focus groups customer education initiatives/player education tools RG interaction incidents CEO/Executive Advisory Panel annual survey training evaluation RG Champion RG Site Team See WLA Program Element 10: Measurement and Reporting Data from the RG Interaction Database informs RG training, employee communications and training reinforcement tools. See WLA Program Element 7: Player Education Training participant evaluations inform training enhancements and reinforcements. See WLA Program Element 2: Employee Training Government Agencies (i.e., MOF, AGCO, MoH) general RG policy transparency and disclosure ethics and integrity briefing updates regular meetings RG Policy Roundtable (AGCO) workshops presentations Feedback from collaborations with the AGCO have resulted in improvements to the development of OLG RG control activities. Business Partners (i.e., lottery retailers, charitable halls associations, Resorts) RG Culture-building RG Program Execution presentations consultations RG Training RG Education resources surveys trade shows conferences Responsible Gaming Resource Centres are being set up in Charitable Gaming Centres in response to the feedback for more robust RG Player education offerings. See WLA Program Element 7: Player Education and WLA Program Element 8: Treatment Referral 97
100 RG Stakeholder Group Key RG Issues Type of Engagement Example of OLG Response to Feedback RG specialist groups: independent agencies/ academics/ research RG Customer Education Self-Exclusion RG Standards RG Game Design presentations/briefings consultations/reviews commissioned/ collaborative research project collaboration regular meetings Consultations with CAMH, RGC, and OPRGC informed the RG program development to the igaming platform, PlayOLG.ca; See WLA Program Element 5: Remote Gaming Channels See WLA Program Element 1: Research See WLA Program Element 10: Measurement and Reporting Industry peers RG Customer Education Self-Exclusion RG Standards RG Game Design working groups joint research and projects Feedback on best practices through the work of the ILC-RGSB on a RG National Standards Framework has helped establish benchmarks for OLG s RG Training program. Support services: Treatment Providers RG Customer Assistance Self-Exclusion surveys presentations/briefings consultations Off-Site Self-Exclusion was implemented as a result of feedback from treatment and support service providers. See WLA Program Element 8: Treatment Referral Local communities and municipalities Transparency and disclosure Ethics and integrity presentations consultations townhalls interviews For Modernization, new communities may decide not to be considered as a host of a new Gaming Site based on community consultations. General Public The citizens of Ontario are the sole shareholder of OLG and therefore are a significant stakeholder in its affairs. OLG is accountable to Ontarians through its parent ministry, the Ministry of Finance, as well as operating mandates to provide Gaming in a particular way. OLG remains accountable to the public through the various relationships described below and through the public disclosure reports described in WLA Program Element 10: Measurement and Reporting. Players Players are a primary stakeholder of OLG because its long-term business viability is dependent on having a sustainable customer base that receives maximum positive value and minimum negative value from the gaming experience. RG is seen as an integral part of customer service. OLG engages its players in many ways including providing accessible and meaningful RG information in various educative, entertaining and interactive formats; conducting surveys and focus groups that gather the opinions and feedback on OLG and RG programming; and assisting and interacting with players who may have gambling problems (see WLA Program Element 7: Player Education; WLA Program Element 2; Employee Training). These types of player engagement have informed or led to many developments in RG programming. For example, the interactions that gaming employees have with customers when responding to Red Flag Behaviours are logged into the RG Interaction Reporting Database. RG Interaction Reports generated from this database, such as the most commonly reported types and responses to Red Flag Behaviours, are extremely valuable for identifying opportunities to enhance or tailor RG training to specific operational realities and issues. RG Interaction Reports are tracked and monitored on an ongoing basis by various individuals and departments within OLG. (See WLA Program Element 10: Measurement.) 98
101 In 2012, OLG created the CEO Player Advisory Panel, a regular focus group discussion in which problem gamblers provide feedback through an independently facilitated session directly to OLG s CEO and senior personnel. Three sessions have occurred including: slots and casino gamblers, facilitated by gambling addiction counselor Steve Chaisson, Lakeridge Addictions Services (December 2012); Internet gamblers, facilitated by psychologist Dr. Richard Wood (August 2013); and gamblers from an ethnic Chinese background, facilitated by Mary Fong of Chinese Family Services (December 2013). (For more information please also see WLA Program Element 1: Research.) Employees OLG employees are critical to executing RG programming, particularly ensuring RG customer education and RG customer assistance occurs at its Gaming Sites. OLG enables Gaming Site employees to perform their RG-related duties effectively by building and supporting an RG employee culture and providing job-specific RG training. A primary driver of RG culture at the Gaming Sites is the RG Champion and RG Site Team, which is set up to promote RG culture and awareness at a grass-roots level, as well as regular RG reinforcement communications on topical RG issues and important RG training concepts. Furthermore, OLG obtains extensive feedback on these areas through its annual employee survey and training evaluations, which are essential for assessing the effectiveness of RG training, the progress of culture-building activities, and identifying opportunities for improvement (see WLA Program Element 2: Employee Training). Government Agencies As the government agency responsible for provincial gaming operations, OLG maintains relationships with several government bodies. OLG is accountable to the Ministry of Finance (MOF), its parent ministry, and provides regular updates and reports on RG policies and programming, as well as consults MOF on significant initiatives. OLG is also accountable to its regulator, the Alcohol and Gaming Commission of Ontario (AGCO). In addition to the regulatory relationship between these two organizations, they have worked collaboratively to further each other s agenda. In the past two years, OLG and AGCO have been undergoing organizational transformations that have implications for each other. As a result, they have worked together to educate and consult with each other on their respective program operations and expectations to ensure that each organization s perspective is wellconsidered in the transitions. Both organizations have held presentations, workshops, discussion meetings, and review/feedback opportunities for the development of their own initiatives, such as the AGCO Standards and OLG RG program elements and control activities. Furthermore, OLG helped to initiate and also participates in the RG Policy Roundtable organized by the AGCO, which includes half-day discussion meetings between various senior-level employees from government and nongovernment stakeholder organizations in Ontario on RG policy issues (e.g., CAMH, RGC, AGCO, OPGRC). Since its inception in December 2012, there were three meetings that covered such topics as the AGCO RG Standards and RG research collaboration opportunities under the OLG Modernization plan. Lastly, as a partner in Ontario s overall strategy for problem and responsible gambling, OLG works with the Ministry of Health and Long-Term Care (MOHLTC), which is responsible for the treatment, prevention and research of problem gambling. OLG contributes $40 million annually to MOHLTC to spend in these areas. MOHLTC engagements consist of regular updates, reports, discussion meetings, briefings and consultations on RG strategy and issues. Business Partners OLG partners with third-party agencies to operate its lottery retail, cgaming sites and Resort Casinos. It is important that OLG attempts to build an RG culture within these environments and provide appropriate training that will facilitate the execution of OLG RG programming for these lines of business. OLG gives periodic presentations and briefings on special initiatives, as well as consults on RG programming relevant to the business of these third-party partners. For example, since 2011 the OLG It Pays to Know communications platform has been expanded to Charitable Gaming Sites with the introduction of a targeted brochure, website information and posters including information on the availability of the Ontario Problem Gaming Hotline (OPGH). OLG also provides RG training to assist these operators to execute RG programming content. (See WLA Program Element 2: Employee Training; WLA Program Element 3: Retailer Program and WLA Program Element 7: Player Education.) 99
102 RG Specialist Groups Independent Agencies OLG has maintained its relationships with the three independent agencies outlined in the 2010 submission: the Centre for Addiction and Mental Health (CAMH), Ontario Problem Gambling Research Centre (OPGRC) and the Responsible Gambling Council (RGC). OLG has current MOUs with all three organizations and engaged in various collaborations that have impacted RG programming and are described in the relevant WLA Program Elements throughout the report. Since the 2010 submission, OLG has conducted numerous engagements with these organizations. Centre for Addiction and Mental Health (CAMH) CAMH is Canada s leading addiction and mental health teaching hospital. It provides clinical, research, program and policy development expertise to OLG in various areas. OLG has been working with CAMH to collaboratively design and deliver RG employee training for all lines of business (see WLA Program Element 2: Employee Training). CAMH has also provided third-party consultation on various RG proposals and initiatives, including providing formal recommendations on RG player tools and OLG s Internet Gaming platform, PlayOLG. Currently, CAMH is engaged in developing the Self-Exclusion Reinstatement Tutorial, which will be a requirement for self-excluders to complete if they wish to be reinstated and permitted to re-enter Gaming sites. CAMH s clinical experience and expertise will inform the tutorial s content to prepare self-excluders to return to gambling at OLG Gaming sites. Its research expertise will be instrumental for assessing and understanding how the tutorial impacts player behaviour. Lastly, OLG facilitates access to gaming facilities and OLG employees in order for CAMH to conduct primary field research. For example, in 2013 CAMH gathered and analyzed the perceptions and opinions of 130 OLG gaming employees in a research study to understand and identify problem gamblers in gambling venues in Ontario. (See WLA Program Element 1: Research.) Responsible Gambling Council (RGC) The RGC is a non-profit organization that seeks to create research, information and awareness programs that contribute to problem gambling prevention. OLG continues to contract the RGC to operate the Responsible Gaming Resource Centres (RGRCs) at all Gaming Sites and works collaboratively to evolve and improve Centre operations. Over the past three years, changes have been made to RGRC staffing hours to improve service efficiency and delivery. Recently, the scope of RGRC services has increased to cover multiple lines of business with RGRCs being planned for 37 cgaming centres. OLG has also engaged the RGC Centre for the Advancement of Best Practices to conduct evaluations of the RGRC program. (See WLA Program Element 7: Player Education) RGC operates RG Check, an independent third-party RG accreditation program for land-based Gaming Sites. OLG is on track to achieve RG Check accreditation for its 19 OLG-operated Gaming sites by April RGC is also close to finalizing RG standards for Internet gaming, which will be the basis for a new RG accreditation program for Internet gaming platforms. OLG, along with its ILC-RGSC members, reviewed and provided feedback on various iterations of these standards during their development phase. (See WLA Program Element 10: Measurement.) RGC recently won a tendered bid to review PlayOLG, prior to launch, against various RG standards for Internet gaming, including the most recent iteration of the RGC Standards. This work follows earlier feedback, beginning in 2011, that was received from RGC where OLG sought substantial and meaningful feedback and input from independent organizations and experts in the intelligence gathering, planning, development and testing phases on the igaming platform and its RG features. After PlayOLG s commercial launch and the finalization of the RGC Standards for Internet gambling and accreditation program, OLG will pursue accreditation for its Internet site. (See WLA Program Element 10: Measurement.) Ontario Problem Gambling Research Centre (OPGRC) Up until 2013, the OPGRC was mandated to enhance the collective understanding of the nature and causes of problem gambling, and improve the scope and effectiveness of related treatment and prevention responses. Under this mandate, OPGRC has contributed to developing impartial, well-designed research to inform the development of RG policy and programming. For OLG specifically, OPGRC have been instrumental in providing a research perspective or research element to OLG RG programming design, development and implementation. 100
103 For example, after formal consultations with OPGRC regarding Internet gaming in Ontario in 2011, OLG created business requirements for the Request for Proposal for vendor selection based on OPGRC s recommendations. OPGRC-facilitated research on informed choice and player education, as well as OPGR-managed projects such as the animated education video The Slot Machine: What Every Player Needs to Know, have been integrated into OLG s RG player education initiatives, including being featured on OLG s RG website, knowyourlimit.ca. Academic Researchers OLG and OPGRC regularly collaborate on joint research projects that are initiated by, or are extremely pertinent to, OLG, yet are facilitated and managed by OPGRC. For example, both organizations are funding the development of a motivational video to encourage self-excluders during Self-Exclusion registration to seek treatment. This project is in its third-year, with OPGRC having managed the procurement process and researcher contract and OLG, along with the rest of the ILC members, providing feedback and gaming site access for the researchers to conduct the experimental evaluation component of the project. The desired outcome of this project is to enhance Self-Exclusion programs across Canada with a video that has demonstrated effectiveness to motivate self-excluders to seek treatment. This purpose follows on the heels of a 2010 RGC study on Self-Exclusion that concluded Self-Exclusion should be used as a gateway to treatment. Other research that OLG, OPGRC, and academic researchers are currently engaged in are projects to validate the effectiveness of a player tool that will allow players to compare real and perceived records of wins/ losses and to examine the effectiveness and usefulness to players of an electronic gaming machine classification system that is based on the structural characteristics of the machines and is communicated to players. In 2013, OPGRC received government direction to focus on the Knowledge, Translation and Exchange (KTE) of problem and responsible gambling research. OLG is currently updating its MOU with OPGRC to reflect these changes and define responsibilities as they relate to problem gambling research and KTE. OLG will continue to provide access to OLG sites to researchers funded by OPGRC to conduct research. (Please See WLA Program Element 1: Research for more details.) Interest Groups General The development, implementation and monitoring of many OLG player education initiatives involve working with interests groups focused on a particular issue or population segment. Meetings, briefings, ad hoc focus groups and advisory panel sessions all facilitate any exchange of information. OLG regularly shares research findings and seeks collaborative ways to implement relevant RG programming. For example, discussions with Chinese problem gamblers facilitated by Chinese Family Services of Ontario gave OLG the opportunity to share OLG research findings on the drivers, receptiveness and perceptions of RG and PG among Chinese players. (See WLA Program Element 1: Research and WLA Program Element 7: Player Education.) Industry Peers Interprovincial Lottery Corporation Responsible Gambling Sub-committee (ILC-RGSC) The ILC-RGSC was established to advance the level, effectiveness and operational integration of RG programming within the Canadian gaming industry, and to establish Canada in a leadership role in this regard. The ILC-RGSC meets monthly for a teleconference and twice a year for a two-day face-to-face meeting. Since 2010, the ILC-RGSC has been engaged in the following collaborative projects, some of which are described in more detail elsewhere in this document. Projects that are led specifically by OLG are noted: empirically-tested nine- and three-minute slot/vlt animation tutorial video explaining how these machines work is currently being used across jurisdictions (OLG) GamTalk sponsorship sponsorship of online peer-to-peer support service completed national inventories of program elements for Self-Exclusion and RG Training RG Check Standards Advisory role (OLG) provided feedback on RGC s RG Check Accreditation Program and drafts of RG Standards for Internet gaming treatment motivation SE video (OLG) production of video nearing completion and fieldtesting should begin in summer 2014 communication standards for electronic gaming machine statistical information (i.e., odds of winning and return to player) focus group testing a draft of communication standard to ensure player understanding 101
104 RG National Standards Framework (OLG) Defining set of risks, standards and common control activities for Self-Exclusion and RG Training RG Information Centres Evaluation Framework aims to provide nationally comparable operational standards and data to identify gaps and opportunities for improving RGIC operations framework is currently being implemented across jurisdictions common RG Training Curriculum developing content curriculum as a resource for jurisdictions to deploy training curriculum, lesson overviews and key messages have been developed in four areas (e.g., Overview, Casino Games Information, RG and PG resources, Responses and Responsibilities) The collaborative engagement of OLG with its industry counterparts across the country is intended to lead to better RG program design and effectiveness; greater program options resulting from cost-sharing, tools and research; leveraged expertise across organizations and accumulation of a Canadian body of RG expertise. Support Services Treatment Providers OLG s treatment referral strategy and programs have relied on strong relationships with support services in local communities, including problem gambling and credit counsellors. As described in WLA Program Element 8: Treatment Referral, OLG regularly presents information on RG Program areas to problem gambling counsellors, credit counsellors, local services and community groups. In 2012, OLG began strategically engaging treatment providers across Ontario, which included one-on-one consultations as well as community presentations on RG. In fiscal , OLG conducted 32 consultations and presentations and expects to increase this number to 41 in fiscal By opening channels of communication, OLG has been able to disseminate key information about our games and our RG program, while learning how to best meet the needs of local support services and encouraging collaboration where appropriate. Credit Counsellors For the past three years, OLG has built a formal relationship with Credit Canada to help expand the circulation of problem gambling information into the credit counselling arena. As described in WLA Program Element 8: Treat Referral, OLG and Credit Canada have a formal website linking agreement and work collaboratively on communications to promote Credit Canada services on digital displays at OLG Gaming sites. As well, OLG delivers presentations on new OLG products and channels to Credit Canada s counsellors. RG training for OLG employees includes information on general credit counselling and referrals to local credit counsellors. As detailed in WLA Program Element 7: Player Education, OLG has promoted Credit Canada services through a number of referral channels including: OLG s RG website, knowyourlimit.ca OLG s It Pays to Know brochures RGRC referrals OLG gaming employee referrals digital signage at OLG Gaming Sites support service materials provided to individuals registering for Self-Exclusion Local Communities and Municipalities OLG s relationships with local communities and municipalities represent a key way of meeting OLG s obligation to the public of Ontario and meeting the expectation that OLG operates lotteries, casinos and slots facilities in a responsible manner. OLG maintains Municipality Contribution Agreements (MCAs) with its host communities that define the amount of revenue the host receives for having a Gaming Site in their community. For the Modernization plan, where new communities had the opportunity to decide on being considered as a host of new Gaming Site, OLG offered information sessions and workshops, presentations to City Council in order to inform them on details of the Modernization plans and RG programming specifically. OLG also works jointly with municipalities to implement a Community Recognition Program (CRP) which involves publicly displaying and communicating how hosting fees are being utilized at the local level. Information on OLG s RG programming is provided at community townhalls and consultations which are part of the implementation of the MCA and CRP programs. Representatives from host municipalities were also interviewed in the stakeholder consultations for the CSR report. 102
105 MONITORING AND EVALUATION OLG s stakeholder relationships are essential in identifying and managing continuous improvement in other RG Program Areas as described above and throughout this submission. The surveys, briefings, working groups, focus groups, formal consultations and other engagement tactics described are frequently used as monitoring and evaluation tools to assess program effectiveness and stakeholder satisfaction. For example, the OLG Responsible Gambling Innovations described in WLA Program Element 1: Research involves an assessment of existing and potential collaborative relationships that OLG can leverage to provide industry leadership and ensure that OLG RG programs remain innovative and effective. In 2013, the OLG CSR reporting process described above offered the opportunity to identify and map all stakeholders and view RG as part of a broader social responsibility program. The consultation process provided insight into priorities, expectations, perceptions of OLG s gaps and weaknesses, and preferred approaches to communication. Some of the findings shed light on the quality of current stakeholder engagements, as well as on challenges and opportunities for engaging stakeholders. For example, while stakeholders acknowledged the efforts and positive intentions of the Social Responsibility Team at OLG, they also believed that overarching business goals and bottom line priorities often counter CSR values. This may call into question stakeholder perceptions of the genuine intent of OLG and perhaps the need for further integration of communications and education in this area. The consultations also revealed stakeholder priorities with respect to RG specifically. Many stakeholders expressed interest in learning further about OLG s RG programming and developments in regard to producing RG-appropriate marketing and game and venue design, and transitioning operations, including RG programming execution, to the private sector under the Modernization plan. GAPS AND OPPORTUNITIES OLG is committed to strengthening relationships and finding innovative ways to listen and engage with its key stakeholders. broader communications as well as simplify RG metrics to communicate impacts to the public. The numerous RG metrics currently disclosed through the various publicly available reports may lack context and be challenging or overwhelming for the average player or individual. OLG will seek clear and straightforward ways to communicate progress and impacts on various CSR issues including RG program areas as it continues to develop its CSR reporting framework. Data Governance Strategy OLG s strategy to conduct further research and analysis on players risk profiles and player behavior presents new opportunities to engage players and ways to expand research throughout the field. In particular, OLG s new Internet gaming platform, PlayOLG.ca, will provide OLG a new level of information on play behavior. OLG will be able to track all play behavior exhibited by a customer on the platform and therefore better understand its players and the impact of RG program initiatives. In addition to strengthening OLG s ability to reach players, OLG relationships with RG interest groups and academic researchers will also be enhanced, since providing access to the data will further the public interest by contributing to a better understanding of RG-related behaviour and gambling activity overall. OLG is currently exploring possible models to share data with credible independent academic researchers. (See WLA Program Element 1: Research, WLA Program Element 4: Game Design and WLA Program Element 5: Remote Gaming Channels.) CSR Reporting Process The process of mapping material issues with internal and external stakeholders as part of the CSR Reporting process is an opportunity to monitor ongoing stakeholder relations as OLG continues and evolves its CSR reporting methodology. Adoption of the GRI-G4 reporting framework with its increased emphasis on materiality analysis will ensure that stakeholder engagement remains a key priority. Communicating Performance Metrics The key RG recommendations from CBSR based on the stakeholder consultation process for the CSR Report were to emphasize RG concepts in product marketing and 103
106 WLA PROGRAM ELEMENT 10: REPORTING, MEASUREMENT AND CERTIFICATION PROGRAM STATUS: 2010 SUBMISSION OLG s 2010 WLA submission described a comprehensive list of public disclosures including Annual Reports, Quarterly Performance Updates, an independent report by Deloitte on OLG operations, Annual RG Progress Report, RG Program and Policy Report and Community Reports. All reports were publicly available on OLG.ca or knowyourlimit.ca. OLG s RG Scorecard and Measurement Report, which includes 26 measures and 130 indicators across all areas of OLG s RG Program, were also explained as key measurement and evaluation tools. In regard to external assessment, the success of GAM-GaRD Assessment of POKER LOTTO, RGC s best practice report on Self-Exclusion (2007) and RG Check were described. A status update on the gaps and opportunities identified in OLG s 2010 WLA submission is provided in Table Table 10.0 Gaps and Opportunities in 2010 Submission Implement new OLG CSR Framework Current Status Update In place/continuous: OLG used the CSR framework referenced in the 2010 Submission to develop its first CSR Report in December Also available at: disclosure.jsp and as printed document. Engage with RGC to pursue RG Check accreditation In place/continuous: OLG is participating in the RG Check accreditation program and is working to have all 19 OLG-operated Gaming Sites accredited by April
107 PROGRAM STATUS: 2011 TO PRESENT Internal and External RG Reporting Program POLICIES AND PROGRAMS OLG s commitment to continuous improvement, as set out in the RG Program Strategy (see Introduction), is achieved through routine disclosure of information. The measurement, evaluation and reporting of outputs and outcomes of the RG Program supports transparent analysis by all stakeholders. OLG reports to a diverse range of stakeholders on its commitments, programs and performance. Information is disseminated in a variety of ways that promotes inclusivity and awareness. Table 10.1 summarizes external and internal RG reporting initiatives at OLG including specific key audiences and dissemination methods. Key audiences for all external reports include the general public, players, media, RG stakeholders and government. Many of the reports are referenced throughout the submission and are used to monitor and evaluate relevant program elements and communicate with stakeholders. Table 10.1 Reporting Initiatives Area Potential Metrics Annual Report Contains information on operation of Responsible Gaming Resource Centres, player education, employee awareness and training, Self-Exclusion program, and stakeholder engagement activities Internal and external, oversight agencies (AGCO, MOF) and Ontario Legislature online (downloadable) printed copy printed copies delivered to government and other stakeholders and available upon request Available at: groups/corporate/documents/general/ olg_nd_ pdf CSR Report The report includes OLG s corporate profile; an overview of where the money goes; responsible gambling accomplishments (including the WLA certification and the RG Check accreditation); accomplishments in enhancing player trust (including the use of Data Analysis and Retrieval Technology in helping detect and prevent potential fraud); and employees giving back to communities and accomplishments in reducing environmental impacts Unclaimed Lottery Tickets Reports Contain information about prizes in excess of $5,000 that have gone unclaimed for eight weeks or more Internal and external, including Retailers, Partners (e.g., OPGRC, RGC, Academics, WWF), ILC members, Host Municipalities Internal and external, including customers online, hard copies first produced December 2013 e-copies ed to the key audiences printed copies mailed or handed over. Available at: public_disclosure/disclosure.jsp online (downloadable) updated regularly Available at: public_disclosure/tickets_unclaimed.jsp) 105
108 Reporting Initiatives Area Potential Metrics Where Winning Tickets Were Sold compilation of retailers in Ontario that have sold winning tickets of $10,000 or more report was developed in response to 2008 Deloitte Report recommendation Where the Money Goes an overview of where OLG revenues are spent report was developed in response to 2008 Deloitte Report recommendation replaces the Community Report that was available in 2010 along with Community Benefit Summaries Quarterly Performance Updates information regarding the quantitative performance of Gaming Sites in terms of revenues, number of patrons, revenues to municipalities and payroll amounts these reports are prepared and reviewed internally by OLG s Corporate Accounting and Reporting department for accuracy and consistency Internal and External, including customers and retailers Internal and External, including host municipalities and the public Internal and External, including gaming site management online (downloadable) updated regularly Available at: aspx?p=wtt online (downloadable) posters Available at: economic_benefits/index.jsp online (downloadable) prepared quarterly provided to Gaming Site management RG Scorecard and Measurement Reports detailed scorecard that reports 26 measures and 130 indicators across all areas of OLG s RG Program draws from various sources including the Annual Player RG Awareness Survey, web metrics, Independent Quantitative Research, itrak, RG Interaction Database, RGRC Statistics, Annual Employee RG Survey, Mystery Shop Program and Treatment Provider surveys Internal and External The information is used internally to inform and enhance the implementation and effectiveness of RG policies and programs online (downloadable) prepared annually also available in a summary version Responsible Gambling Report Summarizes the progress in delivering Responsible Gambling initiatives including RG Training, RG Culture Building, Self-Exclusion, Game Design, Stakeholder Relations and Research Internal and External Internally, this report allows the policy and program managers to be more accountable online (downloadable) prepared annually 106
109 Reporting Initiatives Area Potential Metrics Vital Signs Designed to provide OLG with a clear, continuous understanding of what Ontarians think of the organization and how we are performing. A random sample of 400 Ontario adults who are aware of OLG is collected each month using a telephone data collection method Internal, including the Executive Leadership Team, Leadership Council, and MCSR monthly RG Check Reports Internal, including MCSR and participating Gaming Sites every three years Responsible Gambling Interaction Reports Internal quarterly Knowyourlimit.ca Quarterly Reports Used by MCSR to monitor RG programs and communicate ad hoc with external stakeholders (e.g., CAMH, treatment providers, etc.) Internal quarterly Self-Exclusion Registrations and Self-Exclusion Reinstatement Reports Used by MCSR to monitor RG programs and communicate ad hoc with external stakeholders (e.g., CAMH, treatment providers, etc.) Internal Used by MCSR to monitor RG programs and communicate ad hoc with external stakeholders (e.g., CAMH, treatment providers, etc.) quarterly 107
110 Reporting Initiatives Area Potential Metrics Responsible Gambling Resource Centre Report OLG Board and Management RG Program Updates and Communications Internal Used by MCSR to monitor RG programs and communicate ad hoc with external stakeholders (e.g., CAMH, treatment providers, etc.). Internal OLG Board of Directors and Executive Leadership Team quarterly MCSR Social Responsibility, the departmental RG Program Lead, frequently provides RG Program updates to the Board and specifically its Social Responsibility Committee. MCSR Social Responsibility, as well as the Vice President of Gaming, also provide weekly updates to the OLG Executive Leadership Team. In addition to the reports above, report structures for the following reports have been designed and will be implemented as the RG Program Directives are put into place and PlayOLG.ca is launched. OLG Quarterly RG Reports for Gaming OLG Gaming Sites and related OLG departments (i.e., Corporate Learning, Gaming Marketing, Security Services and Compliance) will be required to produce quarterly reporting and performance measures in some of the eight program areas that constitute the RG Program for Gaming. These measures will be collected and summarized by MCSR Social Responsibility in an OLG Quarterly RG Report. Analysis of these RG Reports and measures will allow OLG to assess the effectiveness of a particular program area or specific feature, as well as assist in addressing or identifying issues around program compliance. The RG Program areas that collect specific quarterly reporting and performance measures are RG Customer Education, RG Marketing, RG Customer Access to Money, RG Customer Assistance, Self-Exclusion, and RG Employee Engagement and Training. OLG is currently implementing these policies which are expected to begin execution in Fall The specific KPIs are detailed in the RG Program Directives for OLG-Operated Gaming Sites. igaming Key Performance Indicators OLG has developed Key Performance Indicators (KPIs) that collectively measure the performance of OLG s Social Responsibility program for igaming. They are described in WLA Program Element 5: Remote Gaming Channels as well as in the igaming RG Playbook. These KPIs will evolve over time once the igaming platform launches in MONITORING AND EVALUATION How OLG uses the reports described above to monitor and evaluate OLG s RG program is detailed within each Program Element of the submission. The items described below are two initiatives that OLG uses to evaluate specific elements of its actual reporting program. Annual Reports OLG Annual Reports contain the financial performance of the company as well as information on the operation of Responsible Gaming Resource Centres, RG player education, RG employee awareness and training, Self- Exclusion Program, and stakeholder engagement activities. The financial components of the Annual Reports are audited for accuracy and compliance to International Financial Reporting Standards and the other components are checked by the auditors for consistency with financial disclosures. The reports are also tabled in the provincial legislature for review. The audit and the legislative review provide a mechanism for feedback and ensure that the contents of the reports are accurate and each component is consistent with the other components. 108
111 CSR Reporting Framework and Strategy Alignment Our first CSR Report for fiscal was reviewed by Canadian Business for Social Responsibility (CBSR), a Canadian non-profit that supports Canadian companies in advancing their social, environmental and financial performance. It was also reviewed by the Ontario Ministry of Finance, the Ontario Government s ministry that has oversight function over OLG. CBSR has since been engaged to help OLG develop an improved CSR reporting framework including report structure, content and metrics as well as to identify ways to improve alignment across CSR areas. The recommended reporting framework for the fiscal report will be based on GRI-G4 in order to provide a structured approach to disclosure on non-financial performance. GAPS AND OPPORTUNITIES CSR Report OLG s fiscal CSR Report is not anchored on any specific reporting framework. However, OLG plans to adopt the GRI-G4 framework in its subsequent CSR reports. As part of this process, a materiality analysis has been undertaken to determine the material aspects of OLG s operations from the perspective of internal and external stakeholders. The analysis has also provided insight into which indicators to focus on in future CSR reports. Additional learning from the first CSR Report indicated the need for a better CSR governance structure which will facilitate the ability of all lines of business to contribute during the preparation of the CSR report. OLG Quarterly RG Reports for Gaming: Implementation While the measures and KPIs have been determined and approved for the Quarterly RG Reports from OLG-operated Gaming Sites and related OLG departments, a system to collect and share the information has not yet been put into place. A systemic and automated process to transfer and deliver this information will also be needed for Service Providers under Modernization. OLG Quarterly RG Reports for Lottery and cgaming: Development Once the RG Programs for Lottery and cgaming are fully developed, they will require means for program monitoring and evaluation similar to the Quarterly Reports and KPIs described above for Gaming and igaming. The RG Program Descriptions for cgaming and Lottery include requirements on Service Providers to provide, on a quarterly basis, program reporting and performance measures. These measures will support OLG s overall management of the OLG RG Program and its accountability to ensure the ongoing relevance and effectiveness of the RG Program. External Independent Assessment Program CURRENT PROGRAM STATUS AND KEY LEARNINGS Over the past three years, OLG has undergone several assessments from third-party agencies to evaluate various aspects of its RG Programs. RG Check Accreditation RG Check is an independent third-party RG accreditation program operated by RGC that applies to land-based Gaming Sites over a three-year period. The accreditation process includes a detailed review of the venue s RG policies and procedures, physical observation of the site, interviews with employee and key stakeholders, employee and customer surveys, and an independent third-party (i.e., Accreditation Board) review and final determination of accreditation. RG Check prepares a comprehensive formal report of the audit results for each site with scores in RG Check s eight RG program areas. A venue with an overall score of over 70 per cent and no sub-cores less than 50 per cent for each program area is eligible for accreditation. OLG began pursuing the RG Check accreditation for its 19 OLG-operated Gaming Sites in Sixteen sites have been accredited as of February 2014, with the last three expected to be accredited by April In addition, Caesar Windsor Casino was the first resort casino property in the world to achieve this accreditation. OLG is also assisting its other resort properties in Ontario to obtain 109
112 RG Check accreditation, with Casino Rama and Great Blue Heron either currently undergoing the accreditation process or scheduled to undergo the process in Under Modernization and as a part of the goal to deliver a gold standard for RG programming, all OLG Gaming Sites will be required to have RG Check certification. This means that new private Service Providers who operate a new or existing Gaming Site will have to recertify or obtain new accreditation. Third-party Review of RG Program In 2012, OLG commissioned Ernst and Young to conduct a review of the existing RG activities across OLG s three lines of business Gaming, cgaming, and Lottery using a draft version of the AGCO standards that were being developed. The review consisted of visits to eight casinos and slots at racetrack facilities, one bingo site, and interviews with key corporate employees. Ernst and Young concluded that the RG Program was quite robust and generally in line with the proposed AGCO standards at that time. The limitations, however, centred on the lack of standardization and formal documentation of certain program processes. These findings drove in part the creation of the policies, procedures and documentation tools that can be found in the OLG-Operated Gaming Sites RG Program Directives and which will be leveraged in other lines of business to achieve as much RG Program standardization as possible across the four lines of business. The development of this process is further described in the Introduction. In developing the OLG-operated Gaming Sites RG Program Directives in 2013, OLG Audit Services was a regular part of the review and feedback process on draft content for the Program Directives. The role of Audit Services for this project was to review and provide guidance and advice on control activity development and raise potential areas for improvement in light of future formal audit assessments that may take place when the Directives are fully operational. Audit Service s feedback informed the design of the RG Program and its control elements but do not reflect a final opinion of OLG Audit Services on the state of the OLG RG Program. ILC RG National Standards Framework The Interprovincial Lottery Corporation s Responsible Gambling Sub-Committee (ILC-RGSC) is engaged in a long-term project to develop an RG national standards framework for Canada that will help continuously evolve and increase RG standards across different types of gaming. The first step in developing the framework has involved developing inventory and benchmarking program elements of different RG program areas across the country. The results of these activities enabled OLG to assess its program elements in relation to what its provincial counterparts were doing and identify gaps and future opportunities for program improvement. Thus far, the framework has been applied to two RG Program areas: Employee Training and Self-Exclusion. The impact of this work on OLG s RG Programs thus far is discussed in WLA Program Element 2: Employee Training and WLA Program Element 7: Player Education. OLG Audit Services Review OLG Audit Services primary responsibility is to provide information to the OLG Board of Directors, and it therefore operates independently of OLG management. It does not monitor or report on program effectiveness to OLG management. As a part of its services to OLG, OLG Audit Services reviewed Ernst and Young s Responsible Gaming Program Review report (2012) described above. The review led to recommendations for improving certain areas of the RG Program. It does not, however, represent Audit Services final opinion on the overall state of the RG program since it was not directly testing or relying on Ernst and Young s assessment in place of our formal audit. Gaming Site RG Training Needs Assessment In March 2013, CAMH completed a Training Needs Assessment for RG Training for OLG Gaming Sites. The analysis summarized the findings of multiple responsible gambling program evaluation tools from various data sources including research evidence, Ontario-wide clinician focus groups, adult education/ training literature on workplace learning and anecdotal evidence based on training experience and clinical feedback of treatment-seeking gamblers. Key findings, recommendations and the impact of the report on OLG programs are detailed in WLA Program Element 2: Employee Training. 110
113 igaming The development of the igaming platform involved extensive consultation with external stakeholders, as well as three specific third-party assessments to determine the effectiveness of its RG program, which are detailed in WLA Program Element 5: Remote Gaming Channels. The assessments included: 1. A heuristic assessment that informed ways in which the design and presentation of RG features could be enhanced to improve our players experience 2. A series of usability tests to guide future refinements of RG-related features such as limit-setting, communication of RG content and Self-Exclusion registration 3. A third-party assessment conducted by the Responsible Gambling Council (RGC) on OLG s RG approach to igaming in order to identify gaps and opportunities that will inform planning following the commercial launch of igaming s website. A new set of RG Internet gaming standards being developed by RGC will be used in this assessment. Self- Exclusion Program Review At the time of the 2010 submission, OLG had conducted a review of its Self- Exclusion (SE) Program with two external organizations: 1) the Responsible Gambling Council (RGC) and 2) KPMG. Improvements in the SE Program were made based on the recommendations of both the RGC and KMPG reviews, including use of Facial Recognition technology, more customer focused training and using data analytics to inform SE policies and programs. (Further details can be found in WLA Program Element 7: Player Education.) GAPS AND OPPORTUNITIES CSR Report As part of continuous improvement on CSR reporting, OLG will pursue third-party verification of the CSR Reports in future years. officials to obtain a deeper perspective from them on areas for improvement and to provide them with feedback on OLG s experience undertaking the accreditation. ILC RG National Standards Framework OLG will be working under the ILC-RGSC to advance the RG National Standards Framework. Similar to the work done on Self-Exclusion and RG Training, the committee plans to work through the process of identifying common RG-related risks, standards, and control activities that reflect best practices for five more RG Program areas: Employee Engagement, Player/Public Education, Research, Marketing and Communications, and Stakeholder Relations. RG Program Area Reviews The eight RG Program areas that make up the RG Program for Gaming will be reviewed every three years. Besides fulfilling an AGCO regulatory requirement, the purpose of these reviews is to ensure that the RG Program remains up to date with new OLG policies and procedures, current research and industry knowledge and best practice. The review may involve third-party expert organizations to conducts the review or to validate some of the review results. RG Standards for Internet Gambling The Responsible Gambling Council (RGC), which created the RG Check program for venue-based gaming described above, is nearing the completion of RG Standards for Internet Gambling. These standards will be the basis of an accreditation program for Internet gaming operators. After PlayOLG s commercial launch and the finalization of the Standards, OLG will pursue accreditation from RGC for its Internet gaming platform. As described above and in WLA Program Element 5, PlayOLG is currently undergoing an assessment against a draft version of the Standards. RG Standards for Gaming OLG expects to have all its 19 Gaming Sites accredited by April Once completed, OLG will conduct a multi-step process to identify and assess opportunities for improving the RG Program for Gaming based on the RG Check audit reports. This will include identifying key priority areas for improvement, assessed against policy and program developments that are currently being planned or underway. OLG will also debrief with RG Check 111
114 APPENDIX A: INDEPENDENT ASSESSMENT PANEL (IAP) Program Element 1: Research Panel s evaluation of completeness Very strong Level 4. Panel s observations and recommendations The IAP wishes to commend OLG for its wide-ranging and multi-layered research program. The program is clearly well-integrated with OLG s management and decision-making processes, informing effectiveness tracking and continuous improvement of key RG program elements. The research agenda goes well beyond legislative requirements, is well-funded and supports a range of in-house and independent research initiatives. Many research initiatives are conducted in a collaborative and stakeholder inclusive manner, seeking both industry and wider stakeholder inputs. A range of quantitative and qualitative methodologies are being used. Gaps, opportunities and future actions have been identified and several research projects have been completed, are in progress or planned. Solid evidence of effectiveness measurement is presented. OLG S 2013 RESPONSE OLG s Responsible Gambling (RG) Program continues to search for ways to incorporate and respond to current research findings. OLG is proud of the research undertaken over the past three years and how it has been used to monitor, evaluate and drive continuous improvement in key program areas including Player Education, Employee Training and Self-Exclusion. OLG s approach to research is strongly linked to its Stakeholder Engagement program as research is used to gain understanding into the various needs and viewpoints of players, employees, treatment providers and other key stakeholder groups. Research is also a key area in which OLG can fulfil its mandate to work cooperatively with other jurisdictions and academic researchers to advance and promote responsible gambling across the sector. 112
115 Program Element 2: Employee Training Panel s evaluation of completeness Best practice at Level 4. Panel s observations and recommendations Again, the IAP wishes to commend OLG on its achievements. The Employee Training program is clearly extensive, covering all employees. Content is tailored to different target groups, with strong monitoring and effectiveness measures being in place. Gaps, opportunities and future plans have been identified clearly. OLG s commitment to develop this program further offers strong evidence of its responsiveness to research findings (as discussed on pages 9-10 of the submission). Further, the program goes beyond a series of training interventions, aiming to have a deep cultural impact and acknowledging the leadership role of employees in taking RG forward in practice. RG and HR are clearly partnering to progress the objectives of the program, again providing strong evidence of deep integration of RG into day-to-day management. OLG s plan to integrate formal RG components with employees performance objectives and plans is to be applauded. This aligns with leading edge practices internationally in the context of corporate responsibility management. The proposed Training Reinforcement Strategy provides an example of OLG s commitment to innovation. The IAP looks forward to seeing the evaluation results relating to this in the future. The IAP would like to recommend this program element to be included in WLA s RGF best practice database (see covering note). OLG S 2013 RESPONSE OLG has continued to embed RG into the culture of the organization by measuring, monitoring and responding to the needs of employees and customers. Our relationship with the Centre for Addiction and Mental Health (CAMH) is a key component to the RG Training program s success, as are the insights gained from third-party research and employee and customer feedback. OLG continues to seek ways to leverage past successes in RG Training and integrate RG into the organizational culture across all lines of business and with all service providers. 113
116 Program Element 3: Retail Program Panel s evaluation of completeness Solid Level 4 with innovative measures. Panel s observations and recommendations A comprehensive program with strong implementation and continuous improvement plans. Multi-layered approach to ensure retailer compliance with policy directives as well as to enhance level of RG awareness amongst vendors. Strong definition of vendors duties and responsibilities as business partners which are rigorously enforced e.g. via an innovative I.D.25 program. Clear identification of different target groups and tailored responses to ensure appropriate integration of RG into different types of sales channels and contractual relationships. Strong effectiveness measures in place. Gaps in target audiences acknowledged and improvement plans established. The section demonstrates OLG s commendable attitude to transparency and determination to respond to incidents with strong corrective measures. OLG S 2013 RESPONSE OLG continues to search for ways to engage and respond to the needs and requirements of the various retailer relationships that support its business. Under OLG s modernization, these relationships will be increasingly important. The development of Program Directives clearly outlines expectations and will standardize RG programming across gaming sites and sectors. OLG will continue to find ways to support retailers with RG Training and RG Player Education tools and resources. Program Element 4: Game Design Panel s evaluation of completeness Program under development. Not aligned with Level 4 expectations at this stage; strong Level 3 submission. Panel s observations and recommendations At this stage, the Game Design element appears to be work in progress. The submission provides a solid implementation plan for future action. This is aligned with Level 3 expectations but not yet sufficient at Level 4. OLG may wish to study other Level 4 programs to inform its future program development. OLG S 2013 RESPONSE Over the past three years, OLG has worked to develop its approach and demonstrate its commitment to game design through the development of the Program Directives for OLG-operated Gaming Sites, the expanded use of GAM-GaRD and innovative approaches in the development of the PlayOLG.ca, OLG s Internet-based gaming channel. Future progress will be heavily affected by the modernization of OLG. The RG Program Directives in development for game design in Lottery and Charitable Gaming will have multiple resources and tools to ensure RG-appropriate games are deployed. Future research and use of data analytics will help OLG support a strong approach to RG. 114
117 Program Element 5: Remote Gaming Channels Panel s evaluation of completeness Not applicable at this stage, but identified as an import aspect of future plans. Panel s observations and recommendations OLG does not currently offer remote gaming products. However, plans for introducing these products are in place and OLG is clearly approaching this with a proactive and enthusiastic RG attitude, seeing the opportunity to make RG a solid part of the business proposition for expansion into Internet gaming. OLG has set itself an objective to demonstrate leadership in this area at the international stage and the IAP looks forward to seeing how this work progresses. OLG S 2013 RESPONSE OLG has been determined in its approach to incorporate RG and stakeholder feedback into the development of PlayOLG.ca. The channel s launch later in 2014 will be the culmination of an extensive consultation process to ensure state-of-the-art RG programming for Internet gaming is embedded throughout the channel to provide a safe remote gaming option. Program Element 6: Advertising Marketing Communications Panel s evaluation of completeness Sufficient for Level 4. Panel s observations and recommendations Approach and programs described together with evaluation tactics, gaps and opportunities. Going forward the IAP would be delighted to see OLG apply the same attitude, energy and drive for innovation as it has demonstrated especially with regard to program elements 1, 2 and 3. In the dynamically changing on-line communications environment (e.g. use of social media platforms, etc.) and considering OLG s plan for remote gaming, the IAP recommends that OLG proactively considers these channels from the RG perspective. OLG S 2013 RESPONSE In addition to the Player Education information described in WLA Program Element 7, OLG vets marketing initiatives from the lines of business as well as Corporate Marketing. As set out in the Program Directives, OLG is embedding RG consideration into the marketing development and approval process by empowering the marketing employees with direct RG accountabilities, and supporting resources and tools. As a Crown Corporation of the Province of Ontario, OLG has been restricted by legislation from using social media. As these regulations evolve, OLG will ensure the same standards for RG information apply to all information channels. 115
118 Program Element 7: Player Education Panel s evaluation of completeness Solid Level 4. Panel s observations and recommendations Very comprehensive and tailored program with clear identification of different target audiences and gaming channels. Multiple communications and outreach channels used, backed up by strong evaluation processes and measures, including independent elements. Strong focus on continuous improvement of benchmarking and target setting processes. Gaps and opportunities for improvement identified together with clear action plans. Negative trend data clearly acknowledged and corrective actions identified. Number of future Player Education initiatives identified. The IAP would like to draw attention to its previous comment regarding on-line/social media communications channels. OLG S 2013 RESPONSE Over the past three years, OLG has implemented an extensive range of education initiatives aimed to reach several different target markets in a constant effort to make RG information accessible, relevant and responsive. Dialogue with related stakeholders, quantitative evaluation results and qualitative market research help ensure the programming remains fresh and innovative. OLG has not fully capitalized on social media communication channels due to government restrictions in Ontario, but as new channels become accessible, OLG will continue to apply its relevant, responsive and accessible approach. Self-Exclusion is a key resource for players and is included in this section. OLG is proud of the progress that has been made in providing Off-Site Self-Exclusion, the introduction of facial recognition technology at Gaming Sites and additional support for both employees and self-excluders. Program Element 8: Treatment Referral Panel s evaluation of completeness Strong Level 4 with some innovative measures. Panel s observations and recommendations Comprehensive and collaborative program. Well integrated with other relevant program elements. OLG supports and engages proactively with a wider range of relevant stakeholders and demonstrates its commitment to innovation by, for instance, reaching out to other support and counselling services working on issues potentially linked to problem gambling. OLG s work with Credit Canada is an example of innovative cross-sector engagement. OLG s SE program utilises a range of strong measures and as the program matures, this could evolve into a best practice example. Again, this section provides evidence of the level of RG integration across the business and the IAP commends the way treatment referral is one core part of OLG s wider stakeholder engagement plan. OLG S 2013 RESPONSE OLG s relationships with support services, including treatment providers and credit counsellors, are valued and constructive. These relationships inform other RG program elements; Player Education and Employee Training in particular. OLG is proud of how these relationships have evolved over the past three years and will continue to look for ways to expand and strengthen our relationships. 116
119 Program Element 9: Stakeholder Engagement Panel s evaluation of completeness Sufficient for Level 4. Panel s observations and recommendations OLG s stakeholder inclusive approach to RG management is evident throughout the submission with clear links to key program elements. This section provides further evidence of a well-structured and governed approach to working with and via key stakeholder groups. Engagement is driven by overall strategy with clearly identified and formalised relationships (e.g. via MOUs). Engagement objectives have been defined for most stakeholder groups together with specified success measures. The program demonstrates a genuine two-way collaborative approach to engagement and its strong link to OLG s decision-making and continuous improvement processes (e.g. policy and program design). Clear evidence of OLG s commitment to sector advocacy work - e.g. involvement in RG standardisation work with sector peers. Going forward, OLG may wish to study the approaches taken by other Level 4 organisations (often discussed in their public reports). The IAP has so far identified one best practice case study relating to stakeholder engagement. Although some of its elements may not be relevant or appropriate for OLG, this program by Camelot provides one example as to how an organisation may wish to describe its overall organisational level engagement program and how it relates to their aspiration to promote responsible gaming. The case study is available on WLA web-site under the RGF best practice case studies. OLG may also wish to refer to key international standards in this area. One such reference point is AA1000 Stakeholder Engagement Standard ( standards/aa1000ses.html) which offers principle level guidance on how to frame organisational engagement programs that are aligned with international best practice yet are regionally appropriate and aligned with overall organisational strategies. Following this standard is not a formal RGF requirement, merely guidance towards best practice that OLG may find informative. OLG S 2013 RESPONSE OLG is reliant on strong stakeholder relationships to deliver effective and valuable RG programs and recognizes its dependence on stakeholders to fulfill its mandate to the people of Ontario. OLG seeks ways to strengthen relationships through meaningful dialogue and incorporates feedback throughout its RG Program. In particular, OLG will continue to strengthen and enhance its relationships with researchers to continue its evidence-informed programming and facilitate knowledge and understanding in RG more generally. The accountability principles of inclusivity, materiality and responsiveness which the AA1000 Stakeholder Engagement Standard upholds are essential to OLG s approach, although the organization has not formally adopted the Standard. OLG s development of a Corporate Social Responsibility (CSR) report has provided the opportunity to define RG stakeholders as part of a broader CSR approach. The reporting process will continue to help formalize engagement including definition of objectives and success measures. 117
120 Program Element 10: Reporting, Measurement and Certification Panel s evaluation of completeness Sufficient for Level 4. Panel s observations and recommendations A comprehensive reporting program that uses multiple communications vehicles and channels with tailored messaging to different audiences. Innovative and internationally best practice aligned RG scorecard developed. Wider CSR reporting program planed with clear focus on RG themes as OLG s most material issue. Beyond 3rd party assessment of RG submission by KPMG, numerous other independent assurance mechanisms have been discussed. Continuous improvement commitments include consideration of an independent RG Check to introduce third-party standardisation across all OLG gaming sites. To facilitate networking and learning amongst WLA members, the WLA office is currently compiling a list of members who produce public CSR/sustainability/RG reports. This list will be made available on the WLA web-site under the RGF case studies section. The WLA office will contact you to ensure that your non-financial reporting activities are included in this list. Going forward, OLG may also wish to study reporting related standards and guidance. The leading internationally recognised non-financial reporting standard is the Global Reporting Initiative. Following this standard is not a formal RGF requirement, merely guidance towards best practice that OLG may find informative. The GRI s G3 Reporting Guideline together with various guidance and learning resources can be found here OLG S 2013 RESPONSE OLG s Reporting and Measurement efforts provide key opportunities for stakeholder communication as well as tools for monitoring various program areas. External verification is used as an important way to evaluate different RG program areas such as RG Training and Self-Exclusion. Over the past three past years, OLG has worked to implement the RG Check accreditation program at all OLG-operated Gaming Sites. The development of a CSR report also represents a significant development in OLG s outreach on all CSR issues including RG. The GRI s G4 reporting framework will guide the OLG reporting process going forward. 118
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