Gambling Code of Conduct

The holder of the Commercial Raffle Organiser’s Licence is Adflex Marketing Pty Ltd (Adflex). Adflex will comply with all rules and policies contained in this Code and will use its best endeavours to ensure that contractors or service providers also comply with these requirements.

1. Availability of the Responsible Gambling Code of Conduct

This code in written form is available on request to Antony Velona, Head of Clients on 1800 31 80 30, and may be seen at our raffle client's websites and at Adflex's website

This code is made available for all Adflex staff in Adflex's employee manual and is shared with all service providers via Adflex’s Policy Book.

2. Responsible Gambling Message

Adflex Marketing Pty Ltd (Adflex) is committed to responsible gambling in raffles and lotteries conducted in support of community and charitable organisations. Adflex and its charitable clients believe that raffles are effective for fundraising, but that support must be provided in a way which allows supporters to make informed choices when participating.

3. Responsible Gambling Information

Adflex and it’s not for profit clients want you to know, in order to gamble responsibly you can take the following steps:

  1. Understand the financial commitment you are making and whether you can afford that commitment.
  2. Read the invoice, receipt and or ticket voucher you receive from us.
  3. Consult the raffle rules which are available to you at the place and date of the draw and are available at our web site.

A supporter or potential supporter may contact Adflex via our website, via email to and telephone on 1800 31 80 30. Additional information and support about responsible gambling may be available from the following sources: or by phoning Gamblers Help on 1800 858 858.

If you believe that your commitment to gambling is unhealthy, you are free to contact Adflex at any time prior to the raffle draw date to change or cancel your commitment or to decline to take further calls.

Adflex’s Responsible Gambling Officer: 
Antony Velona, Head of Clients
1800 31 80 30

4. Gambling Product Information

The raffle terms and conditions are available on the website of each not-for-profit client for which we are selling entries subject to this code. The terms and conditions for the conduct of a raffle will be printed on the ticket and/or on the information material designed to promote the raffle.

The information made available to potential and new supporters will include how to enter and the odds of winning the stated prizes based on the total possible ticket sales.

5. Engagement with Customers

If a customer indicates that he or she has a gambling problem, or where a staff member becomes aware from the customer that they may be overextending themselves financially, staff will decline to accept major purchases. In addition, Adflex may instruct staff to:

  • suggest that the purchaser take a moment to reflect on whether they wish to purchase tickets/as many tickets (cooling off period)
  • suggest that the purchaser be offered an opportunity for us to call back to that person at a later time (cooling off period)
  • Provide a telephone number whereby credit card purchasers could amend or cancel their order (cooling off period)

Where a large purchase is detected a call back to the supporter will occur to ensure that the purchase is intended.

New ticket sellers are trained on the importance of responsible gambling and the availability of support services. All ticket sellers must know how to provide information about the code of conduct and responsible gambling and how to act upon requests arising from the code to act upon requests arising from the code.

6. Engagement with Staff

Staff are not permitted to purchase raffle tickets being sold by Adflex.

The Senior Client Account Manager will assist a staff member who requests it, with information about help with a gambling problem. This information will include referral details to a Gambler’s Help telephone service and/or information materials prepared by Gambler’s Help services.

This will be done away from the general work area and in such a way as to protect the staff member’s privacy.

Staff members who are displaying indicators of distress that may be related to problem gambling (not confined to raffle purchases) will be offered the above information and assistance.

7. Interaction with Problem Gambling Support Services

The Responsible Gambling Officer will contact and collect available resources for problem gambling twice a year from Gambler’s Help services.

This information will be communicated to staff, and made available for use with / distribution to customers, as soon as practicable after it is received.

8. Customer Complaints

If a customer wishes to lodge a complaint relating to Adflex’s gambling code of conduct, they may do so in writing, addressed to:

Complaints Officer, 
Adflex Marketing, 
Level 4, 459 Chruch Street Richmond

Or via email at:

Or alternatively via telephone at 1800 858 858.

The Complaints Officer will investigate the complaint as soon as possible and take the following steps to resolve the issue reported:

  • Receipt of the complaint will be acknowledged (and where possible resolved) within 24hours
  • Complaint will be assessed to see if it is relevant to the Gabling Code of Conduct and advise through written notification
  • Compile as much information as possible from all the relevant parties where further investigation is needed
  • While the issue is being investigated, updates on the resolution process will be provided
  • If a customer is not satisfied with the investigation or resolution of an issue, it will be escalated to a Senior Client Account Manager/ Director for review.
  • If Adflex remains unable to resolve the complaint to the customers satisfaction, the matter will be to an independent mediator.

All complaints received will be logged on a complaints register and complaints will be provided to the Victorian Commission for Gambling Regulation (VCGR) upon request.

9. Commitment to discourage gambling by minors

Adflex does not encourage early gambling habits in children. Adflex will not target a promotion or sales campaign at minors and will not knowingly sell raffle tickets to minors. Tickets are not sold to anyone under the age of 18.

Adflex will not supply a prize of a raffle which includes liquor (or any other product that cannot be legally purchased by a minor) to a minor.

10. The Gambling Environment

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

  • Set a limit on the quantum or value of tickets to be sold to an individual
  • Check data base of regular ticket purchasers to detect a pattern of excessive purchase
  • Not engage in hard/pressure sales techniques

11. Financial Transactions

Adflex will not 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 per cent of a travel prize.

12. Responsible Advertising Promotions

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

  • Comply with the advertising code of ethics adopted by the Australian Association of National Advertisers and the Fundraising Institute of Australia
  • 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
  • Not promote the consumption of alcohol while buying raffle tickets.

Adflex will incorporate the above standards into its advertising checklist and will assess all proposed advertising against these standards.

13. Processes and Structures to Support the Ongoing Implementation of the Code.

  1. Responsible Gambling matters will be a standing item for Board and staff meetings.
  2. A Responsible Gambling Officer will be identified from among senior staff to:
    1. Handle more difficult customer contacts
    2. Liaise with Gambler’s Help services to obtain relevant information, advice and training and make this available to staff and customers
    3. Induct new staff members to ensure they are informed about responsible gambling issues and the Code
    4. Handle responsible gambling issues raised by staff
    5. Identify staff worthy of reward and recognition for their responsible gambling efforts

14. Code Review Process

  1. A review of the operation and effectiveness of this code will occur in June each year.
  2. 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 VCGLR by 30 June each year.