Clever Contacts Pty Ltd ATF The Kidd Family Trust (ACN 612 853 728)

The Code is available on the Clever Contacts website at clevercontacts.com.au or by request to Vicki Love, Compliance Officer, on 1800 589 519.

Availability of the Code

This message will be displayed on the Clever Contacts website and on material developed by Clever Contacts for the promotion and conduct of raffles on behalf of community and charitable organisations.

Responsible gambling information

A responsible gambling message is available to any customers placed on hold prior to or during a telephone contact. Information about the following is available on the Clever Contacts website or by request to Vicki Love, Compliance Officer:

how to gamble responsibly, for example deciding before you buy how much you want to spend
the availability of gambling support services
restrictions that apply to the provision of credit or the lending of money by Clever Contacts for the purposes of purchasing raffle tickets

The terms and conditions for the conduct of a raffle will be printed on the ticket and/or information material designed to promote the raffle, and on the Clever Contacts website. This information will include how to enter and the odds of winning the stated prizes based on the total possible ticket sales.

Interaction with staff

Staff are permitted to purchase raffle tickets being sold by Clever Contacts.

A nominated manager or supervisor of Clever Contacts will assist a staff member who requests it with information about help with a gambling problem. This information will include referral details to a Gambler’s Help telephone service and/or information materials prepared by Gambler’s Help services. This will be done away from the general work area and in such a way as to protect the staff member’s privacy.

Staff members who are displaying indicators of distress that may be related to problem gambling (not confined to raffle purchases) will be offered the above information and assistance.

Interaction with problem gambling support services

The Manager or a senior staff member of Clever Contacts will contact Gambler’s Help services twice a year to obtain updated publications and any changes to contact details or available services. This information will be communicated to staff, and made available for use with customers, as soon as practicable after it is received.

Clever Contacts telephone staff will assist customers who request it with information about help with a gambling problem. In addition, for customers who have indicated that they have a gambling problem, or where a canvasser forms the view that a caller may be overextending themselves financially:

Telephone canvassers will offer to end the call or call back later if the customer wishes to continue with their ticket purchase (cooling-off period)
We provide a telephone number whereby credit card purchasers can amend or cancel their order (cooling-off period)
Where tickets are sold by mail, an upper limit of books will be issued to a customer to purchase or sell at any one time

Customer complaints

If a customer wishes to lodge a complaint relating to the Clever Contacts Responsible Gambling Code of Conduct, they should do so in writing, addressed to: Clever Contacts, Attention: CEO, 25/27 South Pine Road, BRENDALE QLD 4500.

The CEO will investigate the complaint as soon as possible, and will take the following steps to resolve it:

Acknowledge the complaint within 24 hours of receipt
Assess whether the complaint is relevant to the Gambling Code of Conduct and advise through written notification
Where further investigation is needed, gather information and feedback from all relevant parties
Assess whether all parties have been treated fairly and reasonably in accordance with the Code
Ensure parties are notified on the progression of the complaint and informed of the outcome through written notification, detailing the action taken and how the complaint has been resolved
Complaints will be provided to the Victorian Commission for Gambling Regulation (VCGR) upon request

Calls are recorded for quality assurance at Clever Contacts: all agents across all campaigns are included. In the instance Clever Contacts could not resolve a customer complaint, we would liaise with the charity partner for clarification and resolution.

Commitment to discourage gambling by minors

Clever Contacts does not encourage early gambling habits in children. Clever Contacts will not target a promotion or sales campaign at minors and will not knowingly sell raffle tickets to minors. Tickets are not sold to persons under the age of 18. All persons buying tickets over the phone are asked if they are over the age of 18. The charity partners of Clever Contacts do not offer prizes that include alcohol.

Clever Contacts Pty Ltd ATF The Kidd Family Trust will not supply a prize of a raffle which includes liquor, or any other product that cannot be legally purchased by a minor, to a minor.

The gambling environment

Clever Contacts will discourage repeatedly excessive purchase of tickets by customers. To achieve this Clever Contacts will:

Set a limit on the quantum or value of tickets to be sold to an individual
Check the database of regular ticket purchasers to detect a pattern of excessive purchase
Not engage in hard or pressure sales techniques

Ticket sales are capped at $200 value or 10 books.

Financial transactions

Clever Contacts will not be processing customer payments. Clever Contacts is a partner of the charity for whom the raffle raises funds. All transaction information is passed through to the charity for processing.

Prizes of cash are not permitted in Victoria by law, except that cash may form up to 10 per cent of a travel prize.

Responsible advertising and promotions

Any advertising and promotions undertaken by Clever Contacts in relation to a raffle will:

Comply with the advertising code of ethics adopted by the Australian Association of National Advertisers
Not be false, misleading or deceptive about odds, prizes or the chances of winning
Have the consent of any person identified as winning a prize prior to publication
Not be offensive or indecent in nature
Not create an impression that entering a raffle is a reasonable strategy for financial betterment
Not promote the consumption of alcohol while buying raffle tickets

Clever Contacts will incorporate the above standards into its advertising checklist and will assess all proposed advertising against these standards.

Processes and structures supporting the Code

Responsible gambling matters will be a standing item for Board and staff meetings.
A Responsible Gambling Officer will be identified from among senior staff to:
- handle more difficult customer contacts
- liaise with Gambler’s Help services to obtain relevant information, advice and training, and make this available to staff and customers
- induct new staff members to ensure they are informed about responsible gambling issues and the Code
- handle responsible gambling issues raised by staff
- identify staff worthy of reward and recognition for their responsible gambling efforts

Code review process

The Clever Contacts Code will be reviewed each year on the anniversary of its commencement.

Responsible Gambling Code of Conduct