Pooling Bingo Halls: Advertising & Marketing Guidelines

Introduction

This guide is intended to assist stakeholders in developing Hall Marketing Plans that are in compliance with the Terms and Conditions of licences, the Registrar’s standards, directives and policies, the Gaming Control Act, 1992 and Regulations.

Licensees and Bingo Hall Owners or Operators are responsible for ensuring that all advertising materials are in compliance with these Advertising Guidelines, Terms and Conditions of the licence, standards and directives and with any other legal requirements for advertising. Licensees are not required to submit their advertising for prior approval, but the development of projected materials should be included in the Hall Marketing Plan. The Hall Marketing Plan is to be submitted to the AGCO and licensing authority annually, accompanying an application for licence for review and information purposes to ensure that it meets the required elements of the Marketing Plan.

Updates and interpretations of these Guidelines may be published from time to time.

Definitions

Advertising means any public notice, representation or activity, including any promotional and marketing activity that is intended to attract attention to charitable gaming, the Licensees who are managing and conducting Charitable Gaming Events or the name of the premises where Charitable Gaming Events may be held. “Advertise” and “advertisement” have corresponding meanings.

Public Service Advertising means any advertising carrying a strong message against irresponsible participation in gaming events where the message promoting responsible gaming does not contain any direct or indirect endorsement of gaming, of participating in gaming events as a player, the name under which the holder of the licence conducts its charitable works or the name of the bingo hall.

Bingo Paper means a printed device of numbers or symbols on disposable paper, cards or books or reusable hardboard, table board, shutterboard or plastic cards.

Charitable Gaming Event means an event at a bingo hall for which a Licensee is licensed to conduct and manage one or more lotteries, including bingo, break open tickets and raffles.

Complimentary or “Comp” means goods or services given or offered without charge by Bingo Hall Owners or Operators or Licensees to bingo hall patrons in recognition of participation in a gaming activity.

Hall Charities Association (HCA) means an association formed by all the licensees conducting bingo and other lotteries within a bingo hall.

Licence means a licence issued to an eligible organization under the Criminal Code (Canada) by or under the authority of the Lieutenant Governor in Council, to conduct and manage a lottery scheme approved by the Registrar.

Lottery means a scheme for which a licence is available pursuant to s.207(1)(b) of the Criminal Code (Canada).

Operator means a person who operates a gaming site.

Pooling Bingo Hall means a bingo hall where proceeds are pooled among all Licensees conducting Charitable Gaming Events within the hall.

Person means an individual, corporation, organization, association or partnership.

Registrar means the Registrar of Alcohol and Gaming.

Win means gross proceeds from the licensed Charitable Gaming Event after deducting the value of prizes awarded and the amount prescribed by the Registrar as a provincial fee.

Hall Marketing Plan

The Hall Marketing Plan shall be developed jointly by the HCA and the Bingo Hall Owner or Operator forming a Hall Marketing Committee. The Hall Marketing Plan shall be reviewed and revised annually by the Hall Marketing Committee with an emphasis on realistically identifying projected revenues and marketing expenditures as market circumstances change. Hall Marketing Plans must be filed annually with the appropriate licensing authority and the Registrar for the purposes of information and review.

Proposed Hall Marketing Plans will not be subject to an approval process by the Registrar. The Registrar’s review will ensure the plan contains the required elements and is consistent with all applicable Terms and Conditions, Registrar’s Standards, adherence to these Advertising Guidelines and the policies set out in the Lottery Licensing Policy Manual (LLPM). Licensing authorities cannot specifically restrict marketing and Advertising activities for the licensed Charitable Gaming Events that are permitted under these Guidelines.

In the event that a portion of the Hall Marketing Fund is not spent, the HCA and Bingo Hall Owner or Operator must apply for approval to have the remaining money redirected to the revenue split. The application for approval must provide an explanation to the Registrar outlining why spending these monies would not be beneficial (for example due to the closing of a hall). The Registrar will evaluate how to proceed on a case-by-case basis.

Hall Marketing Plan: Required Elements

The following elements are minimum requirements to be included in all Hall Marketing Plans. Hall Marketing Plans will vary based on different markets, hall performance, desired objectives, etc.

  1. Issues/Situation Analysis - An analysis of the market environment and issues to be managed for the specific hall
  2. Joint Planning - Evidence of joint planning and co-operation between the representatives of the Bingo Hall Owner or Operator and the HCA
  3. Strategic Goals and Objectives - Defining and development of Strategic Goals and Objectives to be achieved for the period covered by the plan
  4. Methodology - Defining and development of the parameters to achieve the stated goals and objectives.
  5. Specific Marketing Activities - Identification of specific marketing activities to be implemented that intend to achieve the stated goals and objectives and are more specific than the parameters
  6. Cost Analysis - Cost analysis outlining projected revenues and marketing expenditures for the period covered by the plan
  7. Controls - Identify the elements intended to be measured to support the assessment of outcomes
  8. Evaluation of results and impact - Applying the measurements and assessing the outcome to determine if the intended goals and objectives have been achieved
  9. Expectation - The results sought as a result of the implementation of specific marketing activities
  10. Next Steps - identifying the points for assessment and options considered for necessary changes/revisions to the Hall Marketing Plan

Hall Marketing Plan: Process Requirements

  1. Joint development between HCA and Hall Operator of the Plan through the Hall Marketing Committee with joint sign-off by both the HCA executive and Bingo Hall Owner or Operator
  2. Revision and review of the plan by the Hall Marketing Committee occurring at least once a year
  3. Filing of the Plan annually with the Registrar and licensing authority for information and review for consistency with all applicable Terms and Conditions, Registrar’s Standards and adherence to these Advertising Guidelines and the LLPM
  4. Filing of any cross-marketing initiatives that may involve more than one bingo hall within a municipality or First Nations territory, which may also occur across municipal and First Nations boundaries with the Registrar and licensing authority for review.

Charitable Gaming Advertising Guidelines For Pooling Bingo Halls

These Guidelines apply to all stakeholders involved in Advertising and marketing activities for Pooling Bingo Halls, except where otherwise indicated. This includes Hall Charities Associations, charities involved in the conduct and management of lotteries at these halls, Bingo Hall Owners or Operators, manufacturers and suppliers to the bingo halls, and any organizations or associations representing these parties.

While the content guidelines are specific to the elements contained in the Advertisement or components of marketing and promotions, the principles also apply to the placement of Advertisements. For instance, where the content of an Advertisement cannot appeal directly or indirectly to persons under the age of 18, they also must not be placed in any medium that would target persons under the age of 18.

Content Guidelines

All Advertising should be considered on the basis of any expressed or implied message which may be conveyed. The guidelines apply to all aspects of the Advertisement such as the more obvious copy, graphics, lyrics, script and video, as well as the less obvious but influential aspects such as background music and vocal inflection.

All content, including graphics, used to Advertise and promote licensed Charitable Gaming Events must comply with the following guidelines:

  1. The content must depict charitable gaming in accordance with the principles of honesty and integrity.
  2. The content must comply with all applicable Terms and Conditions, Registrar’s Standards and adherence to these Advertising Guidelines and LLPM.
  3. The content must not suggest any illegal gaming or depict illegal gaming.
  4. The content must not imply that participating in gaming activity promotes or is necessary for:
    • financial success;
    • social acceptance;
    • professional achievement;
    • personal success;
    • sexuality or sexual opportunity;
    • the fulfillment of any goal; or
    • the resolution of financial, social, physical or personal problems.
  5. With the exception of Public Service Advertising content must not appeal, either directly or indirectly to persons under the age of 18 or be placed in media targeted specifically at persons under the age of 18.
  6. Celebrity endorsements must not state or imply that playing games of chance has contributed to the celebrity’s success.
  7. The content should be created in a manner that is in keeping with the standards of responsible gaming.

General Policies For The Redemption Of Promotional Products

Bingo Licensees and Bingo Hall Owners or Operators may offer giveaways or complimentary products as promotional items. These may include or be redeemable for cash, gaming and non gaming-related products.

Bingo Hall Owners or Operators and Licensees that wish to offer promotional products (such as Comps, customer loyalty programs and gift certificates) must identify these elements in the Hall Marketing Plan. How this may be achieved must be set out in the Hall Marketing Plan.

Use of Promotional Products in Exchange for Liquor Prohibited

The sale and service of liquor must be consistent with the Liquor Licence and Control Act , 2019 and Regulations. For example, alcoholic beverages may not be given to a patron in a bingo hall free of charge or in exchange for customer loyalty points or gift certificates.

Customer Loyalty Programs

Bingo Hall Owners or Operators and Licensees may operate customer loyalty programs without pre-approval from the Registrar. Third party sponsors can donate items that may be given away to patrons who have accumulated customer loyalty points. Customer loyalty programs must be addressed in the Hall Marketing Plan and their cost must be covered through the Hall Marketing Fund. How Hall Operators and Licensees plan to cover the expenses related to the ongoing existence of the customer loyalty program must be outlined in the Hall Marketing Plan.

Gift Certificates

Licensees and Bingo Hall Owners or Operators may sell gift certificates or gift cards as promotional items in accordance with a Hall Marketing Plan. These may be used to purchase any item or be redeemed for cash at any Charitable Gaming Event held in their hall. Any sale of gift certificates is considered revenue and is to be split accordingly. It is not necessary to submit gift certificates to licensing authorities prior to offering them for sale; however, they must be available for review upon request. In the event of hall closures or revenue constraints the onus is on Licensees and Hall Operators to cover the value of promotional products upon redemption by bingo patrons through the Hall Marketing Fund.

The sale and issue of gift certificates and gift cards must be consistent with the Ontario Consumer Protection Act, 2002 and Regulations. For example, gift certificates and gift cards may not have an expiry date and no fees may be attached to the card with the exception of fees to customize a card or replace a lost card. If a hall is closing it must provide at least 60 days notice posted within the hall which will allow opportunities for patrons to redeem these products.

Donations of Product by Third Party Sponsors

A third party may donate merchandise to be given away as part of a Bingo Hall Owner or Operator or Licensee-run promotional contest in exchange for promotional consideration. Bingo Hall Owners or Operators and Licensees must include this activity in the Hall Marketing Plan. If financial consideration is received as a result of this activity it is considered revenue and must be remitted to pooled funds for redistribution.

Complimentary Products in Bingo Halls (Nominal Value)

Bingo Hall Owners or Operators and Licensees may offer Complimentary (Comp) items of nominal value to new and existing patrons. The offering of Comps must be included in the Hall Marketing Plan. Nominal value is considered to be 20% of average bingo spend with a maximum of $5 per player per Charitable Gaming Event.

Branding of Gaming Products

Licensees may provide Advertising on their gaming products in accordance with these Guidelines. The product must be seen and perceived as a charitable gaming product and must not be misleading in its portrayal as a charitable gaming product. Charity involvement must be clearly and prominently identified on the gaming product. Any financial benefit received through the branding of gaming products is considered revenue and is to be split accordingly.

Design of Ads

Licensees and Bingo Hall Owners or Operators may work together on the design and placement of Advertising. It must be noted in the Hall Marketing Plan. The design of the Advertising must fall within the Advertising Guidelines.

Licensees must comply with all of the applicable advertising Terms and Conditions for electronic raffles.

Pooling of Funds for Advertising Purposes

Funds may be pooled across more than one bingo hall through a joint sign-off by the Hall Marketing Committees of the halls. This form of pooling may take place in halls with the same operators, halls owned by different operators as well as halls within the same municipality or across geographic regions.

Bingo Hall Owners or Operators and Licensees wishing to pool Advertising funds must include this activity in the Hall Marketing Plan. Pooling between halls will require approval by the Hall Marketing Committees from all participating halls with these agreements forwarded to the AGCO and relevant licensing authorities for information and review.

Transportation of Patrons to Bingo Halls

Licensees and/or Bingo Hall Owners or Operators may offer transportation services to their patrons. Transportation services must be part of the Hall Marketing Plan and be subject to review and written approval by the licensing authority where the destination bingo hall is located. If this service is provided through the Hall Marketing Plan it may be paid for through the Hall Marketing Fund.

Direct and Unaddressed Advertising

Licensees and Bingo Hall Owners or Operators may use direct mail Advertising to communicate with existing customers. Licensees and Bingo Hall Owners or Operators may send direct mail to reach new or lapsed patrons. This can be in any form provided that the Advertising is consistent with the Advertising Guidelines and all applicable privacy legislation.

Licensees and Bingo Hall Owners or Operators may also participate in other forms of unaddressed Advertising such as television or radio spots. Any mass media Advertising must also be consistent with the Advertising Guidelines and the Ontario Consumer Protection Act, 2002 and Regulations.

Paid Celebrity Endorsements

Celebrities may be paid for their endorsement of Charitable Gaming Events through a Hall Marketing Plan. Endorsements must fall within the Charitable Gaming Content Guidelines. For example, a celebrity may not express or imply that participating in Charitable Gaming Events has resulted in their personal or financial success.

No well-known personality may be used in any material advertising charitable gaming that may reasonably be expected to appeal, either directly or indirectly, to persons under the age of 18 if the Advertisement contains any direct or indirect endorsement of participation in Charitable Gaming Events. These may include historical, political, religious and cultural figures as well as celebrities and sports figures.

Celebrities may appear in Public Service Advertisements that appeal to all ages provided there is no direct or indirect endorsement of charitable gaming by the well-known personality.

Additional Use of Hall Marketing Funds

The Hall Marketing Fund may be used to retain the services of a marketing firm for the development and execution of Advertising and promotions materials. The fund may also be used to retain the services of a firm to conduct market and consumer research.

Marketing and research companies are not required to be registered under the Gaming Control Act, 1992. However, if marketing and research companies provide goods or services that go beyond marketing and research (services directly affecting the conduct and management of the lottery), the Registrar may require registration based on an evaluation of the services being provided.

Advertising of Raffle Odds

Licensees holding raffles in Pooling Bingo Halls may Advertise the odds of winning. However, they are responsible for dealing with complaints that may arise due to an inaccurate portrayal of odds.

Responsible Gaming Information Requirements

Information promoting the Ontario Problem Gambling Helpline must be prominently displayed in the Bingo Hall.

A responsible gaming message must be included in all Advertising in any medium including print, radio, television and all online Advertising.