Key Results


SKYCITY casinos performed well. They either met expectations or partial expectations in all but one instance.

The results for Christchurch and Dunedin casinos were slightly lower, but both casinos have displayed a good standard of host responsibility and culture in response to the mystery shopper exercise.

Class 4 sector

In the class 4 sector a low number of venues met expectations (eight per cent), but many more met the partial expectations (33 per cent). Fifty nine per cent of venues did not meet expectations.

There were pockets of good practice which largely came when strong signs of gambling harm were presented to staff.

The exercise has shown some positive efforts by gambling operators but the results show there is a need for improvement.

Follow up action

The Department will use the results of this mystery shopper exercise as a key piece of information to target high risk venues.

Inspections of high risk venues will lead to sanction action if outstanding issues are not rectified within a certain timeframe.

We expect the sector to use the results to continue to improve gamble host responsibility. The Department will continue to work with the sector to improve performance and will use the results to identify where more education and extra regulatory focus is needed.

The results will be used by us as a baseline to assess future improvements.


In late 2016, the Department of Internal Affairs (the Department) conducted a mystery shopper exercise to assess current host responsibility practice in class 4 venues (clubs and non-clubs[1]) and casinos in relation to electronic gaming machines, or “pokies”.[2] The exercise is part of a range of activities being undertaken by the Department, in conjunction  with the gambling sector, aimed at improving harm prevention and minimisation practice and promoting a ‘culture of care’ in venues.

The purpose of the exercise was to provide a snapshot of how well venue staff identified and responded to signs of harmful gambling. It also highlights opportunities where further support can be provided by industry operators and the Department to better protect gamblers and build stronger communities.  

Scenarios were developed to assess how frontline staff responded to a variety of gambling harm behaviours. They were developed using a range of information that included input from gambling operators about how they expected their staff to perform.[3] The scenarios varied in duration and exhibited a range of strong and general signs of gambling harm. Each selected establishment was visited by a mystery shopper who acted out a specific scenario.

The Department assessed the country’s six casinos and a random selection of 120 of the 1221 class 4 venues.

What we found in 2016/17

Since 2014 gaming machine societies and casinos have put considerable effort into harm minimisation practice. The Department has noted a significant change in attitude towards the issue of gamble host responsibility in this time. 


The four SKYCITY casinos have made significant improvements. They have made positive changes, not only to systems and processes but also to culture and staff attitude towards helping those who display signs of harmful gambling.

Christchurch and Dunedin casinos have also made progress, but the results indicate more can be done to lift their performance.

Class 4 sector

For the class 4 sector the scenarios in this exercise were based on our clear expectations and best practice guidelines outlined in the Gamble Host Pack.[4] These resources were distributed in December 2015 and presented our expectations in a new way, designed specifically for use by venues.

The standards we assessed against were high, and to meet the expectations venues had to achieve all criteria. Given this, the number of venues meeting all the expectations was low. Many more venues partially met the expectations. This suggests progress can be made by the sector to further improve harm prevention and minimisation in venues.

The results from class 4 reveal some areas where a high percentage of venues did not meet our expectations. As an example, we note the low response to EFTPOS declines. We will work with the sector to understand the reason for this. For example, it could be a training gap, the busy environments of venues, or limitations on how the scenarios were played out.

In general, class 4 venues were better at identifying and responding to strong signs of gambling harm than they were at recognising a combination of general signs. For example, when a family member raised concerns that a relative was a problem gambler.

The results indicate more work is required in venues to lift their performance and understand what obstructions there may be to achieving this.

Looking forward, we expect the joint approach by the Department and the sector to improve harm prevention and minimisation practice will result in more venues meeting expectations.


The Department has shared the results with each of the operators involved in the mystery shopper exercise. We have met face-to-face with each of the three casino businesses involved and all but one of the non-club gaming machine societies.

The overwhelming response has been that the mystery shopper results will be used to improve harm prevention and minimisation practice.[5]


Class 4 venues: non-club results

  • A total of 97 non-club venues were included in the exercise.[6] Of these, 42 venues received a pre-visit and a mystery shopper visit,[7] providing the Department a total of 139 venue responses to assess.[8]
  • Nineteen venue responses could not be assessed. This created usable data for a total of 120 responses.[9]
  • 12 out of 120 venue responses, (10 per cent) met the expectations.
  • 39 out of 120 venue responses (33 per cent) partially met expectations.
  • 69 out of 120 venue responses (57 per cent) did not meet expectations.

Areas of good practice

  • Those venues which met expectations displayed a high standard of gambling host responsibility with staff showing considerable care for their gambling patrons.
  • At venues which partially met expectations, there was also evidence of good practice, which we commend. 
  • The use of log books to record observations, share information with colleagues and note further monitoring or action required has shown considerable improvement.
  • Ninety two (92) per cent of venues met our full or partial expectations regarding responding to the concern of a family member to a potential problem gambler.
  • Thirty-six (36) per cent of venues met our full or partial expectations regarding responding to a gambler playing for an extended time.
  • Most venues engaged well with customers.
  • The mystery shoppers noted a good level of staff presence in most of the gaming rooms visited.

Next steps identified by societies

Themes have emerged from the responses received from gaming machine societies about how they will use the mystery shopper results to improve harm minimisation practice at venues. These include:

  • policies and procedures will be reviewed;
  • results will be used to provide more help and guidance to venues;
  • results will be incorporated into training;
  • refresher training is being provided where necessary;
  • there will be more emphasis on making sure patrons are provided with help-seeking information, when appropriate; and
  • processes will be reviewed about the response staff should make following an individual receiving two EFTPOS declines.

Areas for improvement

The results have provided the Department with important information about how harm minimisation can be improved.

We recommend:

  • gaming machine societies review their harm minimisation policies to ensure they align with the Department’s expectations;
  • societies review and keep current their harm minimisation training to ensure best practice guidelines are taught. We also suggest societies review how their training is conducted. The new Gamble Host training package is designed to support societies in this;
  • societies review harm minimisation training for staff to ensure it meets the needs of diverse ethnic groups;
  • societies ensure staff know how they’re expected to respond to declined EFTPOS transactions;
  • venue staff  provide more help-seeking information to people showing a variety of signs of gambling harm;
  • societies ensure that log books are used effectively in venues to capture, monitor and follow up any identified signs of gambling harm. Log books will help staff transfer information, follow up, and intervene appropriately with patrons;
  • societies consider a new log book format that makes it easier for staff to capture their observations and action. This will help confirm expectations about what should be recorded and standardise entries. Some societies are developing this already;
  • the sector understands fully the Department’s expectations about harm minimisation practice. This can be done most easily by using the Gamble Host Pack, the Gamble Host Harm Minimisation Policy template and the Gamble Host training package; and
  • societies consider introducing their own assessments to provide information about the effectiveness of venue harm minimisation practice.

 Class 4 venues: club results

  • A total of 23 clubs were included in the exercise. Of these, nine clubs received a pre-visit and a mystery shopper visit, providing a total of 32 club responses.[10]
  • Ten club responses could not be assessed, creating usable data for a total of 22 club responses.[11]
  • 0 out of 22 club responses, (0 per cent) met expectations.
  • 8 out of 22 club responses, (36 per cent) partially met expectations.
  • 14 out of 22 club responses, (64 per cent) did not meet expectations.

The best practice guidance and the clear expectations provided in the Gamble Host resources are relatively new. We are keen for these resources to be used more consistently and become familiar to venue staff so that, in future mystery shopper exercises, more clubs meet our expectations.

This is the first time we have included a sample of clubs in a mystery shopper exercise and we will be reviewing the way some scenarios were able to be played out in practice. At some visits the mystery shopper was either prevented from entering because they did not have membership, or could not enact the scenario as intended. This reduced the sample size and makes it difficult to draw any robust conclusions about harm minimisation practice in clubs.

We acknowledge that, in theory, club membership rules make it more likely that club staff know their patrons, and this provides them with a better opportunity to recognise when a patron is exhibiting signs of gambling harm when compared to non-club venues. However, the results of this mystery shopper exercise indicates this assumption may not be accurate and needs to be further examined.

We therefore encourage clubs to review their harm minimisation policy and training to ensure staff are meeting the Department’s expectations regarding gamble host responsibility.

Areas of good practice

  • 100 per cent of clubs met partial expectations when responding to concerns about a family member’s gambling.
  • Two clubs refused the mystery shopper entry due
    to them having no club membership.

Next steps identified by clubs

Whilst the feedback from clubs has been minimal to date, feedback indicates a willingness to adopt the Department’s recommendations. The Department will meet with Clubs New Zealand to assist them with any training and development initiatives to support harm minimisation practices in clubs.

Areas for improvement

The small sample size may affect the validity of recommendations made below, but the results suggest that:

  • clubs need to ensure staff can identify and respond appropriately to the strong and general signs of harmful gambling;
  • clubs need to ensure staff engage and talk with gamblers about their gambling and provide help-seeking advice or information when signs of gambling harm are displayed;
  • log books are used more actively to record observations, share information with colleagues and note further monitoring or action required regarding signs of potential gambling harm. This will help staff identify and monitor patrons for whose behaviour may indicate that gambling is becoming harmful;
  • clubs consider a new log book format that makes it easier for staff to capture their observations and action. This will help confirm expectations about what should be recorded and standardise entries. Some clubs are doing this already;
  • clubs ensure they have adequate systems in place to identify or monitor a gambler who is the subject of a family member’s concerns;
  • all clubs review how they manage access to the gaming area by non-club members; and,  
  • clubs understand fully the Department’s expectations about harm minimisation practice. This can be done most easily by using the Gamble Host Packs, the Gamble Host Harm Minimisation Policy template and the Gamble Host training package.


Each of New Zealand’s six casinos were included in the exercise. There were three visits each to SKYCITY Auckland, SKYCITY Hamilton, Christchurch Casino and Dunedin Casino, and two visits each for the two smaller SKYCITY casinos in Queenstown.

We undertook a total of 16 scenarios across all casinos. One of the 16 scenarios could not be assessed. This was because the mystery shopper could not carry it out due to SKYCITY Wharf casino successfully encouraging them to self-exclude.

  • 8 out of 15 assessed responses (53 per cent) met expectations.
  • 4 out of 15 assessed responses (27 per cent) partially met expectations.
  • 3 out of 15 assessed responses (20 per cent) did not meet expectations.

The three casino businesses in New Zealand (SKYCITY, Christchurch and Dunedin) have put considerable focus on harm minimisation practice since 2014, and we have noted a significant change in culture with a stronger focus on preventing and minimising harmful gambling. Similarities in gambling harm behaviours played out in the scenarios used in 2014 and 2016 mean comparisons can be made. The results show an overall improvement across the casino sector. SKYCITY’s results stand out as showing a high standard of gamble host responsibility.[12]

In casinos:

  • fifty seven per cent (57) of the mystery shoppers were provided with help-seeking information by casino staff about problem gambling services compared to seven per cent receiving any intervention in 2014;
  • in three of the five casino visits assessed, mystery shoppers received a response to verbal and non-verbal behavioural cues in 2016 compared to no behavioural cues being responded to in 2014;
  • one of the planned visits to SKYCITY Queenstown was unable to be carried out due to the mystery shopper being identified as a potential problem gambler at a previous visit to Queenstown Wharf. The shopper was encouraged to self-exclude as their observed gambling behaviours over a period of time indicated a pattern of gambling that displayed signs of harmful gambling;
  • SKYCITY’s response to six of the mystery shopper visits met expectations, and two visits met partial expectations;
  • of the three mystery shopper visits to Christchurch Casino, the response to one visit met the Department’s expectations;
  • the Christchurch Casino response to two of the scenarios did not meet expectations. In one of these we acknowledge that the mystery shopper performed a gambling harm cue at a lower level of intensity than intended. Despite this she was at a machine for six hours and there was no staff interaction recorded. Therefore the assessment of not met expectations remains; and
  • Dunedin Casino’s response to one of the scenarios met expectations. The two other responses met partial expectations.

Areas of good practice

SKYCITY casinos

  • Overall SKYCITY casinos have shown a considerable improvement in identifying verbal and non-verbal cues of gambling harm and long hours of play. 
  • At both SKYCITY Auckland and Hamilton, staff interrupted and stopped the mystery shopper from playing for an extended period.
  • SKYCITY casino systems for the identification and logging of data captured the scenarios in all but one instance.
  • In May 2014, SKYCITY Auckland introduced customer service ambassadors with the sole function of floor monitoring (with a focus on un-carded patron play) and interacting with gambling patrons.[13]  
  • In January 2016, SKYCITY implemented harm minimisation messages on ATMs at the Auckland casino.
  • SKYCITY Auckland also undertakes independent mystery shops which are used by management to focus training and support improvements in harm prevention and minimisation practices.
  • Other SKYCITY casinos have also been strengthening their focus around harm minimisation, for example, giving staff additional access to iTrak to record patron observations and behaviours.[14]
  • Log books and monitoring were used effectively by SKYCITY casinos to capture and share information about the shopper’s gambling harm. This allowed staff on the gambling floor to take appropriate and timely action with the shopper. SKYCITY Queenstown and Wharf Casino are commended for their effective use of log books and monitoring between both casinos.

Christchurch casino

  • Christchurch Casino met the Department’s expectations relating to EFTPOS declines at the cashier desk, and displayed sound practices and procedures.
  • Christchurch Casino has invested in new technology, Servizio, to manage un-carded play.[15]
  • Christchurch casino has seen an increase in the number of harm minimisation observations reported by casino staff.[16]

Dunedin casino

  • Dunedin Casino has provided extra resource to its host responsibility team by establishing responsible gambling host roles, increased staff training and greater supervision by staff of patrons on the gaming floor.
  • Staff have been given additional access to host responsibility logs to record their observations of patron behaviour. This has resulted in the number of harm minimisation observations increasing significantly.[17]
  • Casino staff formally check-in annually with regular carded players to discuss their gambling patterns.

Next steps identified by casinos


  • SKYCITY management has said it will maintain its focus on harm minimisation to ensure that standards don’t slip.
  • SKYCITY has noted that, in Hamilton, staff need to be reminded about identifying and responding to verbal and non-verbal cues of potential harmful gambling.


  • Christchurch Casino has provided extra resource to its host responsibility team.
  • Following the mystery shopper exercise and, in particular, the scenario involving long hours of play, Christchurch Casino, in partnership with Bally Casino Management Systems, identified an issue with the configuration of the Servizio software. A new patch has been installed to address it.[18]
  • Servizio has been updated to include a new “time on site rule”, which will help record how long a player has been in the casino.
  • Additional investment in technology is being considered to develop a potential “live floor view” to display to staff additional player information to improve harm minimisation.
  • The on-going review of technology to develop and implement an algorithm to help detect potential problems amongst carded players.[19]


  • Dunedin casino has increased its gambling harm team with the addition of a Responsible Gambling Host role. This role will be an additional resource on the gaming floor.
  • The casino will review its policy regarding how cashiers respond to a declined EFTPOS transaction because of a lack of funds.
  • The casino will review when staff should provide help seeking advice and information.
  • The casino will consider restarting its own mystery shopper activity with refreshed scenarios.

Areas for improvement


The results from this exercise show there are only a very small number of issues that SKYCITY needs to focus on. We recommend:

  • SKYCITY refreshes staff understanding of when to interact and intervene with patrons showing signs of potential harmful gambling.


  • Christchurch Casino management reviews how the Servizio logging and tracking tool is functioning, and how the information it provides is being used to identify areas of improvement.
  • Christchurch Casino reviews the monitoring and capture of un-carded gamblers that spend excessive time at gaming machines and reviews how records of long hours of play are used by staff to interact with gamblers to determine if an intervention is appropriate.[20]
  • Christchurch Casino reviews how staff identify, respond to, record and monitor verbal and non-verbal cues of potential gambling harm.


  • Review harm prevention and minimisation training to ensure staff know when and how to intervene with gambling patrons by way of providing help seeking material.
  • Dunedin Casino reviews its policy around EFTPOS declines at the cashier’s desk and use this as an opportunity to check in with patrons and offer help seeking information or advice if appropriate.

Our response to the results

The current mystery shopper exercise used different standards to the 2014 exercise. This was done deliberately by the Department to encourage the sector to aim for best practice. It’s planned that the results from the current exercise will be used as a new baseline for future mystery shopper activity.

We will use the mystery shopper results:

  • to work with the sector to continue to improve harm minimisation culture and practice;
  • to inform and develop initiatives currently underway;
  • to inform the decisions about the prioritisation of resources;
  • to provide valuable information for the Department’s responsive risk-based regulatory activity and on-going mystery shopper exercises;
  • to provide an opportunity for the sector to identify areas for improvement; and
  • as a basis for future mystery shopper activity.

In line with good regulatory practice, the Department will provide assistance through education and working with the operators who show a genuine willingness to improve.  More serious compliance action will be taken against operators who show no willingness to improve and who do not meet minimum compliance requirements.


Most research is subject to certain limitations, and this project is no exception. Some of the limitations specific to this exercise include:

  • the ability of the mystery shoppers to perform the scenarios in full due to factors out of the control of the exercise; and
  • the inability of the mystery shopper to capture every element of their experience at the venue i.e. some information was not captured in the raw data and was not available to the Department.[21]

We acknowledge that the snapshot of harm minimisation practice provided by the mystery shopper exercise may not identify additional improvements that are taking place at venues.


[1] Non-clubs are venues such as taverns, hotels and restaurants.

[2] Mystery shopping is the use of trained researchers to act as a ‘customer’. In this case in order to monitor the quality of service delivery of harm prevention & minimisation in venues.

[3] See ’Methodology’ section on page 18 of this report for more details.

[4] A package of material to support staff and gamblers:

[5] A summary of written feedback from class 4 gaming machine societies can be found in Appendix F.

[6] The gaming machines are owned by gaming machine societies. Twenty non-club societies were involved in this mystery shopper exercise. A full list of them can be found in Appendix G.

[7] The pre-visit was by a family member concerned about a relative’s gambling. At the follow-up visit, a second mystery shopper enacted being the gambler 

[8] Venue responses are the responses provided by venue staff to the signs of gambling harm displayed in the four scenarios that were used. The fourth scenario had two parts to it, each assessed separately. The scenarios were: 1) displays of verbal and non-verbal signs of gambling harm; 2) multiple cash withdrawals including declines; 3) long hours of play; 4a) concern from a family member about a relative’s gambling; and, 4b) the relative visiting the venue to gamble.

[9] Some scenarios could not be enacted as intended due to factors outside the control of this exercise. For example, the mystery shopper could not act out the scenario in full. In such cases the scenario was not assessed.

[10] Refer to footnote 8.

[11] Refer to footnote 9.

[12] SKYCITY Ltd operates SKYCITY Auckland, SKYCITY Hamilton, SKYCITY Queenstown and Queenstown Wharf.

[13] Un-carded play is casino gambling without the use of a casino loyalty card, whereas carded play requires the use of a loyalty card.

[14] iTrak Incident Reporting & Risk Management System used by SKYCITY Casino.

[15] Servizio is a new incident management logging and tracking system used at Christchurch Casino

[16] Christchurch Casino provided data shows there has been a significant increase (569 per cent) in the number of staff recordings made about customers who are showing signs of potential gambling harm. The number has increased from 481 in 2014 to 3217 in 2017.

[17] Dunedin casino provided data shows the number of observed gambling harm indicators reported to the host responsibility team has increased from 14 in 2014 to 352 in 2016.

[18] Christchurch Casino says the Servizio tool was not picking up gamblers playing at a low rate, even if they had been gambling for a long time. This has been addressed with the patch.

[19] Carded players are those who use a casino loyalty card. Their play can be monitored more easily compared to uncarded players.

[20] Refer to footnote 13.

[21] Further limitations are outlined in Appendix D on pages 4 and 5.