No. According to the definition given in the Lotteries Act, the three key elements of a lottery are: charge for participation, winning based on chance and a prize of monetary value. In other words, the Lotteries Act only applies to prize draws for which there is a charge. As a rule, you will need a licence for these kinds of prize draws (with the exception of small lotteries).
So, if there is no charge for your non-money lottery, you will not need a licence. However, the lack of charge must be genuine. In other words, you may not charge the participants indirectly either. For example, a lottery is not free of charge if participants must first pay an admission fee to the event where the prize draw takes place.