NZORD’s submission on the Gambling Harm Reduction Bill

Changes are needed to achieve the good intent of this Bill – September 2012

This month NZORD presented to the Commerce select committee of Parliament about the Gambling Harm Reduction Bill. While supporting the intent of this Bill to reduce gambling harm in the community, NZORD called for changes to avoid contradictions in some of its provisions. We also suggested changes to correct anomalies that already exist regarding funding for regional and national organisations, and which could be made worse by a blind emphasis on local community. Here is our submission: (Word version available here)

Submission to the Commerce Select Committee on the Gambling Harm Reduction Amendment Bill

This submission is from John Forman, 228 Tinakori Rd, Thorndon, executive director of NZORD, the New Zealand Organisation for Rare Disorders.


NZORD supports the general intention of the bill to reduce harm from gambling, provide for controls on the proliferation of gambling machines, and to bring greater transparency and accountability to the distribution of proceeds from the machines to the community.

However we are concerned that the bill as worded will not achieve those aims. We agree with many commentators that the bill is badly drafted and places contradictory processes in place, such as the conflict of council roles in potentially restricting the number of machines while also depending on them for availability of funds for sport, recreation and not-for-profit groups in their community. We also believe the emphasis on local community leaves regional or national groups vulnerable to scarcity of funds, and there are insufficient controls in place to ensure principled and rational distribution of funds, free of political pressures.

But instead of calling for the complete rejection of this bill, NZORD instead proposes that the bill should be carefully amended to achieve its good intentions without introducing the inefficiencies and complications inherent in it, as drafted.

Our organisation

NZORD is a charitable trust, set up as an umbrella group to provide information, support and advocacy for patients and families affected by rare disorders, and to assist with the development of support groups for them.  Rare diseases affect about 8% of the entire population.

Our network includes over 150 rare disease support groups, and we work with these groups to assist them to operate more effectively in the support they provide to affected families, and to ensure their voice is heard in decisions on health care and disability support services.

We also work closely with more than 60 support groups for common disorders on a range of health and disability sector improvement initiatives and we build collaborative relationships with health professionals, health planners and researchers to improve knowledge about rare diseases, improve clinical care, and develop treatments and cures for rare diseases.

We declare a financial interest in the receipt of approximately $60,000 in total from “pokie trusts” over the past 10 years, and an increasing reliance on applications to these trusts as our traditional “non-pokie” charitable funders have less money to distribute.


NZORD believes there is sufficient evidence available in a variety of reports on the topic, to identify major problems with the existing arrangements to manage machines and venues, and in the distribution of funds from gambling machines. We believe legislative action is required to clean up the industry and we think the best way to achieve this is to totally separate the operation of machines and venues from the distribution of funds.

Many charitable organisations are torn about their need to approach these trusts for funds for their survival, and many would feel very relieved and most comfortable with the idea that strict and effective measures were put in place to avoid the many questionable or illegal practices that seem to permeate the gambling machine industry.

The fact that not all of the industry is corrupt is little comfort when it is difficult to know which trusts are the responsible ones – able to be approached with reduced apprehension about the source of the funds they are seeking – and thus not receiving tainted money.

We are aware that many not-for-profits have responded to the industry’s call for strong opposition to this bill, and some have done that while quietly informing us that they have felt under considerable pressure from the industry to do so. That should be of considerable concern to this committee as there have been clear implications about possible loss of funds to those organisations if they do not oppose the bill. NZORD itself perhaps risks having a much higher proportion of its future applications rejected even for saying this.

One matter of great frustration among many charitable organisations, especially small ones but some larger one too, is the current emphasis many trusts put on returning funds “locally”. This is a confused notion and the bill compounds that problem, by thinking of community only in geographical terms. Many not-for-profits provide important information, advice and support to their community but do that across the country, wherever their dispersed target group is. For some disabilities and health conditions, that can be anywhere in the country even though their national or regional office is a great distance away, and the field officer who works with them perhaps living in another city or town altogether.

Some contradictions inherent in an emphasis on “local community” are highlighted by these examples:

  • Should a group providing support to a family living in one location and dealing with a rare neurological condition, be denied funding because their registered office is in another location, and their field officer is based in another?
  • Should a group providing self-esteem and adventure learning to siblings of disabled children be denied funding because they are not “local” groups, even though they may be providing places for children from the local community of the trust applied to?
  • Should a group that provides a web or telephone based information and counselling service and chat-forum to families affected by a particular condition, be denied funding because it is not possible to identify the “local” aspect of their operations, and they do not hold face to face meetings as a group?

Perhaps a significant amount of opposition to the bill actually stems from the additional complications the bill appears to present for groups that operate on a regional or national basis. Current practice does not well enough recognise that communities can be widely dispersed and “virtual” in modern times and the bill would in fact make this problem worse.


NZORD recommends to the committee that is pursues changes to the bill that would:

  • Provide strict controls over the operation of gaming machine venues and distribution of licenses for those venues
  • Strictly separate the collection of the revenue from the distribution of funds
  • Provide for the establishment of appropriate proportions of the distributed funds that would be dealt with locally, regionally and nationally – perhaps in a way similar to the split of Lottery funds into local, regional and national distribution pots
  • Provide for distribution committees to be composed of a mixture of community representatives nominated by local councils or community trusts, plus nominees from the minister, with a minority of committee members to be representative of the pokie trusts.

Yours sincerely,

John Forman
Executive Director