Please initially allow me to submit some background information on the Ballarat Football League Social Club Inc.

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1 BALLARAT FOOTBALL LEAGUE SOCIAL CLUB INC. SUBMISSION - GAMING MACHINE ARRANGEMENTS REVIEW 2016 The Ballarat Football League Social Club Inc (trading as the Ballarat Leagues Club) wishes to submit the following submission for your consideration in response to the Gaming Machine Arrangements Review currently being undertaken. BACKGROUND INFORMATION ON BALLARAT FOOTBALL LEAGUE SOCIAL CLUB INC. Please initially allow me to submit some background information on the Ballarat Football League Social Club Inc. The Venue Operator of the venue known as the Ballarat Leagues Club is the Ballarat Football League Social Club Inc. The venue trading name is the Ballarat Leagues Club. The Ballarat Football League Social Club has a current Venue Operators License to operate 54 EGM s at the approved venue premises of 52 Humffray St Nth, Ballarat. The Ballarat Football League Social Club appoints a Committee of Management, which is elected by its members at an Annual General Meeting held annually. The Committee of Management is made up of volunteers, and these people are generally people who hold, or have held distinguished positions throughout Ballarat. In particular, it should be noted that several members of the Committee are involved in other community groups throughout Ballarat. The Committee of the Ballarat Football League Social Club has a full time and experienced Venue Manager, Chef, Gaming Manager and Administration Manager who form the basis of the Management team at the Ballarat Leagues Club. The venue currently employs 29 staff in total. The Management Team at the Ballarat Leagues Club meet on a weekly basis (or more if required) and the Committee of Management meet on a monthly basis.

2 BALLARAT FOOTBALL LEAGUE SOCIAL CLUB INC. STATEMENT OF PURPOSE The objects of the Club shall be:- 1. To promote, advance, foster and cultivate the game of Australian Football in the Ballarat region, with a particular emphasis in the Ballarat Football League. 2. To establish maintain and carry on Club premises for the convenience and enjoyment of Members of the Club and guests of Members and generally to afford all such persons the usual privileges advantages conveniences and means of enjoyment as are usually provided for Members of a Social Football Club. 3. To make Application pursuant to the appropriate legislation from time to time enacted and currently in force or any re-enactment or amendment thereof to:- a) Victorian Commission of Gambling & Liquor Regulation for a Club Liquor Licence or any other Licence Permit Authority capable of being granted to an incorporated body; and b) Victorian Commission of Gambling & Liquor Regulation for a Gaming Operators Licence and/or a Venue Operators Licence or any other appropriate Licence Permit or Authority; and c) To hold transfer renew vary remove or surrender any such Licence Permit or Authority if and when it is appropriate or opportune to do so and to do and perform all such acts or things which may be necessary to obtain and protect any such Licence Permit or Authority. 4. To raise funds by lawful means for the improvement of the facilities and amenities provided by the Club, the Ballarat Football League and its member clubs, and the remuneration of its staff, and to distribute such funds if and when in a manner approved from time to time by the executive committee of the Club by way of donation to the Ballarat Football League and its member clubs, and to other community groups for charitable sporting or benevolent purposes as permitted by law. 5. To engage in such other activities whether of a like nature or not as may from time to time are permitted by law and determined by the executive committee of the Club.

3 VENUE S PRIMARY MARKETING POSITION The Ballarat Leagues Club markets itself as a one stop family entertainment venue, amongst our members, to visitors of Ballarat, and predominately to member clubs of the Ballarat Football Netball League and their club members. The Ballarat Football League Social Club Inc. trades as the Ballarat Leagues Club, and it is through our close association with the Ballarat Football Netball League that we are able to attract the majority of our trade. By operating a high class bistro that seats approximately 140 patrons, and which incorporates a Kids Korner that includes 4 x-box s, computer games, tv/video and soft area for the children our bistro attracts many families to its facilities. We promote our bistro to the community as BLC- Food and Fun for the whole family, while Supporting the Local Community. Our members bar provides a comfortable sports bar atmosphere, offering designated casual dining, pay tv, live sports and TAB facilities. Finally, our gaming room currently has 54 EGM s and offers a welcoming environment for our patrons to enjoy the facilities. The Ballarat Leagues Club primarily markets to the following Members: 4400 social members on our Ballarat Leagues Club loyalty database through a variety of different membership categories. And importantly, via the BFNL Member Clubs (and their Members of the Ballarat Football League). These are summarised below: Note: The Ballarat Football Netball League is made up of not just the Ballarat Football League senior and junior competitions, but also the BFNL Youth Girls senior and junior competitions and obviously senior and junior Netball teams. This represents approximately 4455 registered footballers and netballers in central Victoria. Based on AFL Victoria averages for the total annual average revenue for Major League Club (Senior + Junior) the total amount of money generated by the Clubs under our auspices is approx $7 million. When the generally accepted economic multiplier effect of 4 is applied then BFNL footy & netball is the catalyst for circulating $28 million in the greater Ballarat region. The Ballarat Leagues Club plays an essential role in providing vital & critical funding to allow the clubs under the Ballarat Football Netball League "umbrella" to continue to operate.

4 Ballarat Football & Netball League Inc. Ballarat FNL Netball 11 Senior Clubs, 44 sides Competition 9 Junior Clubs, 45 sides Ballarat FNL Youth Girls Football Competition Ballarat FNL Junior Football Competition Ballarat FNL Senior Football Competition 890 Participants 14 clubs Approx 1,200 members 325 Participants 9 Junior Clubs 8 Age Groups, 72 sides Approx. 2,200 members 2,250 Participants 11 Clubs 33 sides (Seniors, Reserves, Under 18's) 2,750 Club Members 990 Participants Affiliated Clubs: Ararat Storm (Youth Girls), Bacchus Marsh, Creswick (YG), Darley, East Point, Golden Point (YG), Gisborne (YG), Lake Wendouree, MCDFNL Lions (YG), Melton, Melton Centrals (YG), Melton South, Mt Clear, North Ballarat Juniors, North Ballarat City, Redan, Riddell s Creek (YG), Sebastopol, Sunbury

5 VENUE S CONTRIBUTION TO COMMUNITY The Ballarat Leagues Club annually contributes significantly to the greater Ballarat region. This is best summarised by an overview of the BLC s cash contribution and also further its in kind contribution for the most recent audited financial year of 2014/2015. In terms of cash contribution, the BLC pays the entirety of the Ballarat Football Netball League Finance Officer wages, with her hours equally split between the Ballarat Football Netball League & the Ballarat Leagues Club. As such, with the full wage being paid by the Ballarat Leagues Club, 50% of this wage is regarded as a donation to the Ballarat Football League. This totals over $35,000 In addition, the Ballarat Leagues Club made the following cash donation to the Ballarat Football Netball League in the 2014/15 financial year $62,500 + GST The Ballarat Leagues Club made cash donations to Ballarat Football Netball League Clubs in the 2014/2015 financial year- $45,455 + GST The Ballarat Leagues Club made various other cash donations to a number of other community clubs and organisations (including the Ballarat Football Umpires Association) in the 2014/2015 financial year- $ GST In terms of In Kind donations, in 2014/15 the BLC donated over $42,000 + GST worth of venue bistro vouchers and discounts to various clubs, seniors groups, schools, community organisations and our members. In addition to the above direct cash and voucher donations, the Ballarat Leagues Club has also provided discounted use of our venue the Ballarat Leagues Club as an in kind contribution to various organisations and community groups to a total value exceeding $5000. TOTAL VALUE OF CASH, VOUCHERS & IN KIND: in excess of $197,000 * Note: * This does not include all further additional items approved as community benefits and submitted annually in our CBS.

6 Response to the Gaming Machine Arrangements Review The Ballarat Football League Social Club Inc. wishes to provide the following points in relation to the GMAR, and would ask you to consider the following: Community Clubs of Victoria Response The Ballarat Football League Social Club Inc. endorses the position of our industry association, Community Clubs Victoria, which has been developed with the overall welfare of Victoria s not for profit clubs in mind. Gaming Operator beyond 2022 GMAR General Statement Put simply, if our club were unable to operate gaming from 2022, we would not be able to continue to provide the services we currently do. The Ballarat Football League Social Club inc. relies heavily on the revenues from gaming. Although gaming is only one part of the overall offer at the Ballarat Leagues Club, the BFL Social Club would not be able to operate the Ballarat Leagues Club without gaming. We would not be able to pay the costs such as rent associated with running a venue of our size, or provide the facilities we presently offer. The Ballarat Leagues Club currently allows the BFL Social Club to financially support the Ballarat Football Netball League and its member clubs. It allows us to provide vouchers and support to many community groups and sporting clubs in the region. It allows us to provide a welcoming, comfortable and safe environment for our members. It allows us to employ the current 29 staff in a wide range of occupations. If we were unable to operate gaming the staff number would be zero, as there would be no possibility of continuing BLC in its current form. Our club, as listed above has over 4400 social members, but more importantly we provide support to over 6000 members associated with BFNL clubs, and the 4455 participants. If the Ballarat Leagues Club no longer operated gaming machines, the BFNL and its member clubs would suffer dramatically.

7 Ballarat Leagues Club position on Key Issues. Current Venue Operator Model We would like to note that Clubs machines generate less than half the revenue per EGM that Hotels currently achieve, yet the cost of Gaming Machine entitlements between clubs and hotels are not dissimilar. We believe the pricing and taxation for entitlements should acknowledge the disparity between the revenue earned from Hotel entitlements and that earned from Club entitlements. Distribution of Gaming Machines We concur with the thoughts reflected in the CCV submission. We believe the current measures in place including the 50/50 split between clubs and hotels along with the 80/20 regional caps should be maintained. Ownership Restrictions We do support CCV s view that the restriction of club operation of entitlements should be reviewed. The same restrictions that apply to hotels, should also apply to clubs. A club or club group should be permitted to operate up to 35% of available club entitlements, the same as a hotel owner. Tax The tax differential between hotels and clubs, whereby club enjoy an 8.33% tax advantage by comparison, should be maintained in recognition of clubs not for profit status. We would like to note that our clubs operations, forward planning and ability to provide financially to our primary purpose (the Ballarat Football League) was dealt a massive blow when the taxation increase occurred in 2014/2015. There was no warning or consultation, as the increased tax was announced and enacted within 4 months, and within the same financial year. The increase in tax meant our club experienced a loss from the bottom line of close to $100,000 annually, and we were forced to reduce committed financial support to the Ballarat Football Netball League. We ask that the tax structure and more importantly tax rate are set for an extended time, and that any changes are scheduled or are communicated well in advance to allow clubs to budget for any reduction in gaming revenue.

8 Entitlement Term The current 10 year term has offered clubs very little security. We have experienced issues with our lending arrangements during the term, with banks very nervous and hesitant to support our club during the payment of entitlement term. Luckily, we were able to secure lending, but the 10 year term and payment over 4 and a half years has been a challenge on cash flow and our day to day operations thus far. Our club would like to see the entitlement term operate similar to that of a liquor license, permanent in effect, and not vulnerable to loss or withdrawal by the state unless financial default occurs or there are serious breaches in operating standards. Allocation- access to Entitlements We again support Community Club Victoria s views that the process must be an offer to existing entitlement holders to extend their terms. This would see an orderly transition to any new Entitlements regime. Price and Settlement We certainly believe that the price for Entitlements be related to the revenue potential based on a long view of gaming at the site. Our club believes settlement of Entitlement payments be paid with or alongside taxation payments. This would assist with cash-flow and provide the state with continued revenue stream. We believe that the formula or calculation assumptions that underpin the price be reviewed at regular intervals over the Entitlement term. Transfer Market We again concur fully with the views expressed in the CCV submission. We believe the State should have full control over Entitlement distribution. 24/02/2016 Roger Howlett Secretary On behalf of the Ballarat Football League Social Club Incorportated.