Responsible Gambling Code of Conduct

1. Availability of the Responsible Gambling Code of Conduct

The Code is available on our website at www.unity4.com (Website) or by request to Daniel Turner, CEO on 1300 886 489. The Code is made available to all our staff and workplace participants in our employee manual.

2. Responsible Gambling Message

The holder of the Commercial Raffle Organiser Licence is Unity4 Contact Centre Outsourcing Pty Ltd (we/us/our). We are a service provider contracted by community or charitable organisations to assist with the conduct of raffle programs. In providing our services, we are committed to responsible gambling and to selling raffle tickets responsibly to support community and charitable organisations. We are also committed to providing an environment where customers can make an informed decision about their ticket purchases.

This Responsible Gambling Code of Conduct (Code) forms part of that commitment and will be available on our Website and we will refer to this Code where possible on material developed by us for the promotion and conduct of raffles on behalf of community and charitable organisations. We acknowledge our responsibility in the shared nature of responsible gambling.

This responsible gambling message will be displayed on the Website and at all places where raffle tickets are sold. We believe in the importance of generating awareness of the risks associated with gambling and creating and promoting environments that prevent or reduce the potential harm of gambling. We will comply with all the rules and policies contained in the Code and will use our best endeavours to ensure that contractors also comply with these rules and policies.

We are committed to providing a safe and responsible gambling environment for our patrons. This policy outlines our commitment to minimising harm associated with gambling and promoting responsible gambling practices in accordance with the Victorian Responsible Gambling Code of Conduct.

3. Responsible Gambling Information

Available on our Website and by request, are the following tips that support safe gambling practices when participating in charitable raffles and campaigns:

• Understand your financial commitment: Review your financial situation to ensure you can comfortably afford the amount you commit to spending on raffle tickets. Responsible gambling includes staying within your means;
• Set personal spending caps: Determine a spending limit for raffle ticket purchases ahead of time and stick to it. Only gamble with funds you're comfortable parting with;
• Reflect on motivations: Periodically assess why you choose to gamble. Gambling for excitement, social reasons, or entertainment is very different from gambling with financial expectations. Being aware of your motivations can help keep gambling in perspective;
• Monitor time spent: Stay aware of how much time you're engaging in gambling activities. Establish a time limit for purchasing tickets and commit to it;
• Maintain a balanced lifestyle: Ensure that gambling doesn't become your primary activity. Engage in a variety of interests, hobbies, and social activities for a well-rounded life;
• Identify and address triggers: Recognise any emotional or environmental factors, like stress or social pressure that may increase gambling urges, and find healthy ways to cope;
• Review your purchase details: Always read through your invoice, receipt, or ticket voucher to confirm purchase details and avoid misunderstandings;
• Consult the raffle rules: Familiarise yourself with the raffle rules, which are available at the point of sale, on the physical ticket, and on our charitable client's websites. Understanding the rules ensures you're fully informed and can participate responsibly;
• Educate yourself on odds and risks: Learn about the odds of winning and the potential risks associated with gambling. Having a clear understanding of how gambling works can encourage informed and responsible choices;
• Self-Exclusion options: We offer a self-exclusion program for those wishing to limit their access to raffle services. Information on how to initiate, modify, or end self-exclusion can be found on our website and is available upon request;
• Resist the urge to recoup losses: If you experience a loss, avoid the temptation to keep buying tickets to "win back" money. Remember, gambling is a form of entertainment, not a way to generate income;
• Restrictions that apply to the payment of winnings: Details of restrictions that apply to the payment of winnings are outlined in section 12 of our Code and available online on the Website;
• Access support resources: If you sense that gambling might be becoming problematic, reach out promptly to any of our staff members for support via our website, via email to info@unity4.com, and telephone on 1300 886 489.

Additional information and support about responsible gambling may be available from the following sources:

• Lifeline Australia — Phone: 13 11 14 (24/7 helpline). Website: lifeline.org.au. Services: Provides immediate crisis support, including assistance for gambling related distress, and helps with suicide prevention.
• Financial Counselling Australia — Phone: 1800 007 007 (Free financial counselling service). Website: financialcounsellingaustralia.org.au. Services: Offers free financial counselling, budgeting advice, and assistance with managing debt, especially for individuals affected by gambling.
• Gambler's Help — Phone: 1800 858 858 (Free, 24/7 helpline). Website: gamblershelp.com.au. Services: Provides confidential support for gambling issues, including self-exclusion programs, financial advice, and counselling services.

Our Responsible Gambling Officer: Daniel Turner, CEO — Dan.turner@unity4.com — 1300 886 489.

4. Gambling Product Information

The terms and conditions for the conduct of a raffle will be included on the electronic ticket/receipt and referred to on any material designed to promote the raffle, as well as in detail on the Website or by request to our customer support via email at info@unity4.com, or via telephone at 1300 886 489. This information will include how to enter and the odds of winning the stated prizes based on the total possible ticket sales.

5. Customer Loyalty Scheme Information

We will not be offering any 'customer loyalty scheme', as defined in the Ministerial Direction.

6. Interaction with Customers

To identify and assist customers with gambling concerns we actively monitor customer interactions and purchasing behaviour through feedback consultations with our staff and via access to our raffle sales data, specifically observing any significant or repeated ticket purchases. Additionally, all our staff are trained on the following processes when engaging with customers:

• Encouraging Thoughtful Decision-Making at the Point of Sale: In both online and in-person promotions, our staff encourage potential buyers to take a moment to consider their decision to purchase tickets and the quantity they wish to buy. This brief "cooling-off" period helps promote thoughtful, intentional decision-making and discourages impulse purchases;
• Direct Support and Self-Exclusion Options: If a customer displays any behaviours pertaining to problem gambling, we will discreetly reach out to provide assessment and support. Depending on the outcome of the assessment we will offer options such as setting personal spending limits or utilising our self-exclusion program, which allows customers to restrict or temporarily block their access to our services if they choose to take a break from gambling;
• Respectful, Private, and Supportive Interactions: All customer interactions are handled with the utmost respect for privacy. Our staff are trained to be compassionate, nonjudgmental, and supportive, ensuring that customers feel respected and understood. Where appropriate, we follow up with customers who have shown gambling concerns, providing them with ongoing support and resources; and
• Ongoing Monitoring and Comprehensive Staff Training: We are committed to continuously monitoring gambling patterns and updating our staff training regularly. Our team is equipped with the skills and knowledge necessary to identify potential gambling concerns and intervene effectively, ensuring a safe, responsible, and supportive environment for all customers.

7. Interaction with Staff

To ensure a fair and responsible environment staff members are not permitted to purchase tickets in our raffles.

• Encouraging Proactive Support: We are committed to providing proactive support for staff members who experience challenges related to gambling in a prompt, sensitive manner. Any staff member showing signs of distress potentially linked to problem gambling, regardless of whether it relates to lottery purchases, will be discretely encouraged to seek assistance from our Responsible Gambling Officer. This will be done away from the general work area and in such a way as to protect the staff member's privacy; and
• Providing educational materials that raise awareness and understanding of gambling-related issues, helping the staff member recognise any signs of problem gambling and the available support options (outlined in section 3 of this code) to staff members who request it.

8. Interaction with Problem Gambling Support Services

The Responsible Gambling Officer will establish a protocol to reach out to Gambler's Help services twice a year. This will include obtaining updated publications, changes to contact details, and information about available services. Once this information is received, it will be communicated to all staff members and made available for customers as soon as practicable. This ensures that both staff and customers are informed about the available support services for problem gambling.

9. Customer Complaints

If a customer wishes to lodge a complaint relating to our Code, they may do so in writing, addressed to: Complaints Officer, Unity4 Contact Centre Outsourcing Pty Ltd, PO Box 725, West Ryde NSW 1685. Or via email at info@unity4.com. Or alternatively via telephone at 1300 886 489.

In making a complaint, the customer should include:

• Complainant's contact details;
• Date and time of the incident;
• Description of the incident and supporting evidence (if any);
• Specific details of the issue (e.g., names of staff involved, specific breaches of the Code); and
• Desired outcome (if any).

The Complaints Officer will investigate the complaint as soon as reasonably possible and in any event within 21 days, and will take the following steps to resolve the complaint:

• Acknowledge receipt of the complaint and attempt to resolve within 24 hours;
• Assess to see if it is relevant to the Gambling Code and advise through written notification;
• Compile as much information as possible from all the relevant parties where further investigation is needed;
• Provide regular updates on the resolution process while the issue is being investigated;
• If a customer is not satisfied with the investigation or resolution of an issue, it will be escalated to a Director for review.

Should a complaint not be resolved through the above process, then the customer will be entitled to participate in an independent mediation with the cost to be shared equally between both parties. The customer will be invited to resolve the issue and entitled to have the complaint heard by an independent authoritative body, such as the Institute of Arbitrators & Mediators Australia (IAMA). The IAMA can be contacted by calling 1800 651 650 or email: infoaus@resolution.institute.

The Victorian Gambling and Casino Control Commission (VGCCC) is entitled to monitor compliance with our complaints process. Complaints may also be reported to the VGCCC by calling 1800 182 457 or using the online complaint portal maintained by the VGCCC. The portal can be accessed here: https://www.vgccc.vic.gov.au/i-want/complaints.

Records of complaints and decisions of any review process made in relation to the Code of Conduct will be held for a period of seven years and will be made available for inspection by the Minister or the VGCCC on request.

10. Commitment to discourage gambling by minors

We do not promote gambling to minors and will not direct any promotions or sales campaigns toward minors. We also will not knowingly sell raffle tickets to individuals under 18 years of age.

• As we mostly sell raffle tickets to customers in shopping centres, our staff are instructed to confirm proof of age of anyone who appears to be under 18 and will not sell tickets to customers who cannot provide proof they are 18 years or older. In circumstances where raffle tickets are sold online, a date of birth verification check will be in place to ensure the purchaser is 18 years or older.
• We will not supply a prize of a raffle, which might include liquor (or any other product that cannot be legally purchased by a minor), to a minor.
• We display clear signage indicating that gambling is restricted to individuals over 18 years old. This approach upholds our responsibility to prevent underage gambling and protect minors from potential harm.

11. The Gambling Environment

We discourage repeatedly excessive purchase of tickets by customers. To achieve this we will:

• Set a limit on the quantum or value of tickets to be sold to an individual in a given raffle and refuse to sell further tickets once the limit on the quantum or value of tickets has been reached;
• Check customer database of regular ticket purchasers to detect a pattern of excessive purchase and suggest that the purchaser take a moment to reflect on whether they wish to purchase tickets/as many tickets;
• Not engage in hard/pressure sales techniques;
• Review customers' purchase history on a monthly basis to take all reasonable steps to prevent excessive purchase of tickets; and
• Provide an invoice or statement to the customer that shows the time and date tickets were purchased and when the draw will be held.

12. Financial Transactions

We will not cash customer's cheques or extend credit to customers to purchase raffle tickets. Customers will be advised of this at the time if they request such a service. Prizes of cash are not permitted in Victoria by law except that cash may form up to 10 percent of a travel prize. For all other prizes, we provide clear details on the prize type, how it will be delivered or collected, and any steps winners must take to claim their prize. This information is available on the raffle tickets, our Website or charity client's website, and in promotional materials.

13. Responsible Advertising Promotions

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

• Comply with the advertising code of ethics adopted by the Australian Association of National Advertisers;
• Not be false or 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; and
• Not promote the consumption of alcohol while buying raffle tickets.

The Responsible Gambling Officer will ensure the above standards are complied with by:

• Offering regular staff training: Our marketing and advertising teams undergo regular training to stay informed about the latest regulations and ethical standards, ensuring our content is always compliant;
• Review of client raffle pages: Before activating any client raffle pages, we conduct a detailed review to confirm that they meet our responsible advertising principles. This includes checking for accuracy, ethical messaging, and compliance with our standards;
• Promotion content guidelines: We ensure that our promotions do not suggest that gambling is a viable financial strategy or associate gambling with alcohol consumption. Additionally, we obtain consent from all identified winners before featuring them in promotional content, ensuring all advertisements are respectful and appropriate;
• Continuous monitoring and evaluation: We regularly assess the effectiveness of our advertising campaigns through audits and evaluations to ensure they align with our commitment to responsible advertising practices; and
• Transparency and accessibility: Our advertising policies and standards are publicly accessible on our website, promoting transparency and allowing for public accountability.

14. Processes and Structures to Support the Implementation of 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; and
• Identify staff worthy of reward and recognition for their responsible gambling efforts.

15. Code Review Process

This Code will be reviewed each year on the anniversary of its commencement. Input will be obtained from management and staff and a sample of patrons about the operation and effectiveness of the Code. A report of the review will be provided to the VGCCC by 30 June each year.