CASA Code of Conduct

The Casino Association of South Africa (CASA) was founded in 2003 with the aim of creating a better understanding of casino entertainment by bringing the facts about the industry to the general public, the media, public representatives, regulators, and policy and other decision makers through education and advocacy.

CASA represents the vast majority of South Africa’s licensed casino industry which has been responsible for substantial new infrastructural and tourism investment in all nine provinces. It has added considerably to the South African GDP in terms of economic multipliers. As far as the financial structure of the industry is concerned it provides significant tax revenue to the fiscus – in fact government is an almost 40% shareholder in the casino industry – and is the second largest provider of “own” income to the provinces. In the construction phase of the various casinos the industry created almost 100 000 direct and indirect jobs and in the current operational phase of its business CASA members sustain approximately 53 000 employees, for many of whom it was their first job.

CASA’s members are employers, property owners and taxpayers and place the highest priority on the obligations of corporate citizenship and social responsibility.

Consumer Protection

Preamble

CASA members acknowledge that the Consumer Protection Act, No. 68 of 2008 (‘the CPA”) has come into effect and, acknowledge that it is necessary to establish national norms and standards relating to consumer protection; to prohibit certain marketing and business practices; to promote responsible consumer behaviour; protect the interests of consumers; to promote and provide for consumer education; to improve access to, and the quality of information available to members of the public so that consumers are able to make informed choices; to protect consumers from hazards to their well-being and safety; and to give effect to internationally recognised consumer rights.

The members of CASA therefore:

• undertake to respect and uphold consumers’ rights as provided for in the CPA, including the consumers’ right to equality; right to privacy; right to choose; right to disclosure and information; right to fair and responsible marketing; right to fair and honest dealing; right to fair, just and reasonable terms and conditions; and right to fair value, good quality and safety;
• undertake to comply with all South African consumer protection legislation and to implement strategies and procedures that will assist in achieving the objective of protecting consumer interests in general, as well as each of the specific consumer rights provided for in the CPA;
• in particular, undertake not to discriminate unfairly in any way against a person or class of persons in conducting their business activities;
• undertake to uphold the consumer’s right to disclosure and information in terms of the CPA, in particular, the right to information in plain and understandable language;
• undertake to market casino and related activities fairly and responsibly and particularly not to market gaming and related activities in any manner that is misleading, fraudulent or deceptive;
• undertake to conduct any loyalty programmes and promotional competitions in accordance with the relevant provisions in the CPA;
• undertake to uphold the consumer’s right to quality service, including the timely performance and completion of those services, as well as the performance of those services in a manner and quality that a person is generally entitled to expect; and
• undertake to uphold the consumer’s right to be heard and obtain redress in respect of consumer rights which are alleged to have been contravened, including the use of alternative dispute resolution for the resolution of disputes.

Preamble

The members of CASA acknowledge that corruption is a hindrance to sustainable development and economic growth, with a disproportionate impact on poor and disadvantaged communities. It distorts free-market activity and represents serious legal and reputational risks. We recognize that we share a responsibility to society and with government to obtain and to maintain an ethical industry, free of corrupt activities. As such, CASA members subscribe to the following code of ethics:

Code of Ethics

Corruption of business associates and of public officials in all its forms including extortion, bribery and blackmail is unacceptable. We recognize that we have a duty to conduct ourselves both ethically and with integrity in all our business dealings. As such, we are fully committed to playing our part in the fight against corruption and we hereby adopt a zero tolerance approach towards all corrupt activities. We will not offer and nor will we accept or solicit any bribes, unlawful inducements or unlawful facilitations of any kind within the private sector nor to or from public officials and public institutions, that are intended to improperly influence or secure any decision or business. We will in good faith consider, for implementation, appropriate anti-corruption initiatives, strategies and practices that may be developed through consensus with various industry bodies in other sectors of the economy. We will comply with all laws and regulations intended to combat corruption and we will co-operate in a responsible way with any anti-corruption investigations that may be conducted into our activities.

Money-Laundering and terrorist financing

The members of CASA recognise that money-laundering and terrorist financing are a serious and growing manifestation of international criminal conduct and represents an ever-increasing threat to the integrity and proper functioning of business and to corporate and professional reputations.

The members of CASA therefore:

• undertake strictly to comply with all South African anti-money-laundering and antiterrorist financing legislation and to implement strategies and procedures that will assist in achieving the objective of erasing these dangerous practices;
• subscribe to the principle of “knowing your customer” in order to detect suspicious money laundering and terrorist financing transactions;
• to cooperate fully with the FIC and various law enforcement and supervisory agencies;
• to communicate the individual company anti-money-laundering and anti-terrorist financing programmes through policies, procedures and staff training; and,
• to conduct continuous and sustainable money-laundering and anti-terrorist financing risk assessment across their businesses.

CASA and its members are committed to making responsible gambling an integral part of our daily operations at all our casinos throughout South Africa. To advance this goal, CASA members have agreed on a code of conduct which details how we fulfil this pledge.

Commitment to Our Employees

• CASA members will educate new employees on responsible gambling.
• CASA members will train employees in respect of responsible gambling and provide periodic refresher training.
• CASA members will implement communications programmes for employees to improve their understanding of responsible gambling and related policies and procedures.
• CASA members will make available to new employees brochures regarding responsible gambling and where to find assistance.
• CASA members will post responsible gambling awareness signage bearing a tollfree helpline number at various locations where employees congregate

Commitment to Our Customers

Responsible Gambling

• CASA members will make available brochures regarding responsible gambling and where to find assistance. These will be available and clearly visible in gaming areas.
• CASA members will make available on their web sites clearly visible information regarding responsible gambling and where to find professional help.
• CASA members will display in gaming areas and on every gaming machine signage bearing a toll-free helpline number, as well as displaying statements advocating responsible gambling.
• CASA members will provide training for their employees that interact directly with gambling patrons in relation to information on responsible gambling, self-exclusion and where to get help.
• CASA members will provide opportunities for customers to request in writing that they not be sent promotional mailings and for revocation of their privileges for specific casino services such as loyalty card promotions. In addition, each CASA member shall make reasonable efforts to honour a written request from any person that it not knowingly grant that person access to gaming activities at one or more of its properties.
• CASA members reserve the right to exclude a patron from gaming, without a request from the patron.

Underage Gambling and Unattended Children at Casinos

• CASA members will make diligent efforts to prevent children from loitering in the gaming area of a casino.
• CASA members will communicate the legal age to gamble through appropriate signage and/or brochures.
• • Employees working in relevant areas will receive training in appropriate procedures for dealing with unattended children, underage gambling, and the purchase and consumption of alcohol and tobacco by underage persons.
• Where, in the opinion of management, an unaccompanied child on the complex appears to be at risk, appropriate personnel will be contacted and remain with the child while reasonable steps are taken to locate the parent or responsible adult on the property or by telephone. If efforts are unsuccessful, the unaccompanied child will be released to the care of an appropriate authority.

Alcohol

• CASA members will observe a responsible beverage service policy including the following elements:
  • Casinos will not knowingly serve alcoholic beverages to an underage person.
  • Casinos will endeavor not to knowingly serve alcoholic beverages to a visibly intoxicated patron.

Responsible Advertising

This code applies to the advertising and marketing of casino gaming by CASA member companies. It does not pertain to advertising and marketing that is primarily of hotels, restaurants and entertainment that are often associated with or operated by casinos.
For the purposes of this code, and as reflected in the national regulations, advertising and marketing include radio and television ads broadcast off the premises, print, brochures, direct mail, billboard and internet promotions.

• All casino advertising and marketing will:
  • Be consistent with principles of dignity and integrity and subject to the jurisdictions in which it operates.
  • Contain the National Responsible Gambling Programme’s (NRGP) responsible gambling message and the NRGP’s toll-free helpline number and contain a statement advocating responsible gambling.
  • Reflect generally accepted contemporary standards of good taste.
  • Make no false or misleading claims.
• Casino advertising and marketing materials will not:
  • Advertise or promote any gambling activity in a manner which is false, fraudulent, misleading or deceptive in any way.
  • Degrade the image or status of persons of any ethnic or religious group or affiliation.
  • Feature anyone who is or appears to be below the legal age participating in gaming. Contain claims or representations that gaming will guarantee an individual’s social, financial or personal success.
  • Exhort gaming as a means of covering past financial losses or imply that gaming is an alternative to employment or is a form of investment or that winning is a probable outcome or that gaming involves any level of skill or that the longer a consumer gambles, the greater the consumer’s chances of winning.
  • Be placed in the media where most of the audience is expected to be below the legal age to participate in gaming.
  • Imply or suggest any illegal activity of any kind.
  • Be placed in media specifically oriented to children.
  • Be placed at any venue where most of the audience is normally expected to be below the legal age to participate in gaming.

Commitment to the Public

Money Lending

• CASA recognises that some money lending practices could be harmful.
• CASA will strive to deter the practice of illegal money lending (“money lending”) at casino properties.
• Casinos will take reasonable measures to discourage money lending which will include the following:
  • Placing appropriate warning notices in the casino
  • Investigating any complaints or incidents of suspected money lending
  • Co-operating fully with any investigation regarding money lending by any relevant authority
• Should there be factual proof supporting a suspicion of a money lending transaction, the casino will take the appropriate action, taking into account all the circumstances surrounding the incident.
• Casinos will forward appropriate details of the evidence and any action against an alleged moneylender to all other CASA affiliated casinos.

Funding the NRGP

• In terms of agreements reached at the South African Responsible Gambling Foundation (SARGF), CASA members will continue to provide funding for the (NRGP)
• CASA members will use research by the NRGP to identify the best practices for casinos to follow to promote responsible gambling.

Non-compliance with the Code

Where the failure by any member to comply with the Code of Conduct is brought to the attention of CASA, the matter will be investigated and dealt with appropriately.

All aspects of CASA’s Code of Conduct are subject to provincial and national regulations and statutes.

Enacted on 6 December 2012 by the CASA Board of Directors