Review of the Registered Clubs Industry in NSW - Clubs NSW

9 Improving corporate governance
Recommendation
50 That ClubsNSW introduce best practice recommendations into its Best Practice
Guidelines, and revise its Code of Practice to require a club which does not follow a best
practice recommendation to disclose its reasons in its annual report.
9.3.6 Enhancing ClubsNSW’s role in assisting smaller clubs with their compliance
obligations
Several stakeholders commented on the difficulties faced by smaller clubs in
complying with the Registered Clubs Act. While larger clubs were able to afford
compliance officers to manage their compliance obligations, this was not an option
for smaller clubs due to the costs involved.
IPART notes that OLGR has provided useful compliance tools for clubs, including a
self-audit checklist and a standards and systems audit. 175 However, there is scope for
further assistance in this area for smaller clubs. It considers that ClubsNSW should
employ a pool of compliance officers for smaller clubs to use as needed, on terms
similar to those set out below:
A club requests ClubsNSW to allocate a compliance officer to it for a fixed period
of time.
The compliance officer provides the club with services such as:
– auditing the club’s current level of compliance with the Registered Clubs Act
requirements
– reviewing the systems the club has in place to manage compliance.
ClubsNSW charges the club for the compliance officer’s services on a cost
recovery basis. That is, ClubsNSW charges the club a fee equal to the cost
incurred by ClubsNSW for salary, insurance etc, to provide this compliance
service per year, pro rata for the number of days the club uses the compliance
officer over that year.
The compliance officer is subject to confidentiality arrangements with the various
clubs s/he assists.
Only clubs with gaming machine revenue of $1 million or less a year should be
able to access the service.
175 The self audit checklist is the same list OLGR officers use when auditing clubs. The standards and
systems audit helps clubs identify their compliance risks and strategies for reducing these risks, and
compile a folder outlining their compliance program. (See
www.olgr.nsw.gov.au/gaming_info_compliance_tools.asp)
Review of the Registered Clubs Industry in NSW IPART 161