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Submission on the Gambling Amendment Bill 2024

Posted September 19, 2024

The Salvation Army Te Ope Whakaora is grateful for the opportunity to comment on this legislation, although this is a brief response due to the limited time available to make comment.

About The Salvation Army

The mission of The Salvation Army is to care for people, transform lives and reform society through God’s love. The Salvation Army is a Christian church and social services organisation that has worked in New Zealand for one hundred and forty years. It provides a wide range of practical social, community and faith-based services around the country.

The Salvation Army employs almost 2,000 people in New Zealand, and the combined services support around 150,000 people annually. In the year to June 2023, these services included providing around 86,400 food parcels to families and individuals across 70 welfare centres, providing some 2,400 people with short-or long-term housing, over 2,900 families and individuals supported with social work or counselling, around 6,600 people supported to deal with alcohol, drug or gambling addictions, around 3,100 families and individuals helped with budgeting, and court and prison chaplains helped 5,000 people. 

This submission has been prepared by the Social Policy and Parliamentary Unit (SPPU) of The Salvation Army. The SPPU works towards the eradication of poverty by encouraging policies and practices that strengthen the social framework of New Zealand. These comments have been approved by Commissioner Mark Campbell, Territorial Commander of The Salvation Army’s New Zealand Fiji, Tonga, and Samoa Territory.

Key Points

  • The Salvation Army Te Ope Whakaora notes this Bill is being rushed through the select committee process and without prior consultation with stakeholders, including those working with people experiencing gambling harm.
  • This Bill amends the Gambling Act 2003, which has as a main purpose the minimization of gambling harm. The purpose of the prohibition on remote interactive gambling is a recognition of the much higher risk of harm and difficulty of regulating forms of remote gambling. By including this prohibition in the Gambling Act it was understood by that electronic transactions would be affected [1]. What was initially a specific exemption for three large charities in May 2020 has since been expanded to a general exemption for all Class 3 licenses until 31 October 2024, which this Bill now seeks to make permanent. We recommend a further temporary extension of the time limit while considering reviewing the strategy to prevent gambling harm and the regulation of all forms of online gambling.
  • This Bill is passing through Parliament at the same time as the Ministry of Health is consulting on the next three-year Strategy to Prevent and Minimize Gambling Harm. We ask how this Bill meaningfully contributes to achieving the goals of the current Strategy? It is likely that it makes little or no contribution and indeed carries the risk of increasing gambling harm.  
  • At the same that this Bill is in Parliament, work on regulating overseas online gambling is underway but no public consultation has taken place [2]. The Salvation Army supports the positions outlined in the Position Paper: Online Gambling prepared by the Problem Gambling Foundation and other agencies involved in harm reduction and treatment [3]. The Salvation Army generally opposes moves to expand access to online gambling, but if access is expanded then it needs strong harm protection and regulation [4]. The position paper recommends a range of strong and effective harm prevention and minimisation measures which should accompany any steps to regulate online gambling.
  • The supporting information for this Bill provides no evidence about the impact of the changes made since 2020 on the volume of gambling, amounts gambled, and estimates of harm caused by the increased ease of access to lottery gambling. The use of advertising and online promotion is known to increase the risk of harm. The assumption seems to be that there is no measurable harm from such gambling, yet the limited evidence available on lottery gambling in this country is that online gambling such as remote lotteries carries a higher risk of becoming harmful [5].
  • The rationale behind this Bill that increased access to remote gambling is only for charitable fundraising purposes further serves to emphasise the moral hazard created by a funding model that promotes a harmful activity to raise funds for purposes that are intended to benefit communities (i.e. fund charitable activities). The Salvation Army urges the Government to establish meaningful alternative sources of funding that uncouple gambling profits from funding services, sports and community groups. This would in turn enable a stronger focus on a harm prevention and minimisation approach to gambling with a focus on reducing a harmful activity in the gambling sector.
  • [1] See DIA website Gambling class 3 lottery license rule changes – dia.govt.nz
  • [2] Regulating online casinos approach | Beehive.govt.nz
  • [3] Online Gambling Position Paper • Problem Gambling Foundation (deploy.net.nz)
  • [4] Just a Click Away: Online Gambling in Aotearoa (2021), R. Tanielu, https://www.salvationarmy.org.nz/article/just-click-away-online-gambling-aotearoa 
  • [5] Lotto and Lotteries – What You Should… • Problem Gambling Foundation (deploy.net.nz)