*See Information classification policy

This document sets out Strategix International College’s (SIC) policy in relation to the recruitment, management and termination of International Education Agents. This policy aims to ensure that Strategix forms working relationships with reputable International Education Agents in order to promote its products and services to overseas students whilst ensuring that the actions taken by appointed International Education Agents are ethical and comply with SIC’s obligations under the:

• ESOS Act 2000;

• The National Code of Practice for Registration authorities and Providers of Education and Training to Overseas Students 2018 (National Code 2018)

• Migration Act and Regulations.

This Policy applies to all staff of SIC and International Education Agents engaged on behalf of SIC, both onshore and offshore.

Strategic International College will:

Select only reputable International Education Agents and ensure those agents act honestly and with integrity;

• Manage their International Education Agents in a professional and responsible manner;

• Enter into a written agreement with each International Education Agent approved to represent it in accordance with the agent assessment process as described under Appointment of International Education Agents below;

• Maintain an accurate list of approved International Education Agents, which will be published on their respective websites;

• Ensure all relevant SIC business units have access to the accurate list of authorised International Education Agents;

• Include the name of the International Education Agent on the Confirmation of Enrolment (CoE) where applicable;

• Require their International Education Agents to have appropriate knowledge and understanding of the Australian international education industry, including the Australian International Education and Training Agent Code of Ethics;

• Provide adequate training and information for International Education Agents, including their obligations under this policy, the individual Agency Agreement and Australian migration laws; and,

• Ensure that International Education Agents have access to accurate and up-to-date marketing information.

International Education Agent Functions

Individual persons or organisations, onshore or offshore, may be engaged by SIC as an International Education Agent to assist SIC in recruiting international students pursuant to the terms of individual Agency Agreements.

• International Education Agents are representatives of SIC only within the terms of individual Agency Agreements.

• As an agent of SIC, all International Education Agents must abide by the principles of the National Code 2018 and the terms of their signed individual agency agreement.

• The principles of the National Code, as they relate to the conduct of International Education Agents, are derived from Standard 4. An International Education Agent must not:

  • Be engaged in, or have previously been engaged in, dishonest practices, including the deliberate attempt to recruit a student where this clearly conflicts with the obligations of registered providers under Standard 7 (Transfer between registered providers);

  • Be currently facilitating, or have previously facilitated, the enrolment of a student who the International Education Agent believes will not comply with the conditions of their student visa;

  • Use the Provider Registration and International Students Management System (PRISMS) to create Confirmations of Enrolment for other than a bona fide student; or

  • Provide immigration advice where not authorised under the Migration Act 1958 to do so.

Appointment of International Education Agents

An International Education Agent is appointed by signing a formal written Agency Agreement with SIC. International Education Agent Agreements are underpinned by the ESOS Act 2000, the National Code 2018, the 7 principles for the Ethical Recruitment of International Students by Education Agents and Consultants (the London Statement) and the Australian International Education and Training Agent Code of Ethics.

Prior to engaging a new International Education Agent, SIC will request the completion of an International Education Agent Application Form which incorporates the requirement for a declaration of interests on the part of the applicant.

SIC will undertake an assessment to satisfy itself that the potential agents will represent the College appropriately and will not pose risks to SIC, staff, students or prospective students. This may include:

• Assessing that the agent is registered to operate in their local jurisdiction.

• Assessing the agent’s history and track record in recruiting students for the Australian market.

• Checking references provide by the International Education Agent

• Assessing the agent's knowledge of the Australian international education industry, understanding of the principles of the National Code 2018, the Australian International Education and Training Agent Code of Ethics and other requirements relating to the provision of their services.

• Inspecting the agent’s premises to ensure that they are appropriate and present a professional image.

• Interviewing counsellors to assess their performance in advising students.

• Obtaining information on the display of SIC promotional materials.

The individual International Education Agent Agreement is signed by the Authorised Delegate for SIC and the International Education Agent Principal.

A database of approved International Education Agents and respective International Education Agent Agreements is maintained by SIC.

Review of International Education Agents

SIC will monitor the International Education Agent’s performance and activities on a continuous basis throughout the term of the agreement through meetings, visits and surveys of students.

SIC will conduct formal reviews of the Agent’s performance every year, or prior to each contract renewal period, whichever is sooner. The review may include (but is not limited to):

• Recruitment volume;

• Application conversion rates;

• Visa success rates;

• Quality and completeness of applicant documentation;

• Compliance with the individual International Education Agent Agreement;

• Student performance post enrolment;

• Quality of advice and information provided to students; and

• Student feedback.

Renewal of an International Education Agent Agreement will only be approved if the performance of the International Education Agent is found to be satisfactory.

Where, on review, the performance of an International Education Agent is found to be unsatisfactory, action may be taken as specified in their individual International Education Agent Agreement.

Each year, a review report will be produced which summarises the performance of International Education Agents. This report will be forwarded to the Colleges Executive Management Team.

Termination of International Education Agents

In the event that an International Education Agent has been found to breach the terms and/or conditions of the individual International Education Agent Agreement, SIC may terminate their International Education Agent Agreement in accordance with the terms of the individual International Education Agent Agreement.

In the event that an International Education Agent has been found to have acted dishonestly, the College will terminate the individual International Education Agent Agreement immediately in accordance with the terms of the individual International Education Agent Agreement.

SIC may terminate an International Education Agent Agreement with an International Education Agent who does not comply with requirements as set out in the terms of the individual International Education Agent Agreement, and in accordance with this policy.

International Education Agent Remuneration

SIC remunerates International Education Agents through the payment of commissions based on enrolments attributable to the individual International Education Agent.

The amounts payable, and terms of payment are determined by the individual International Education Agent Agreement.

Any other conditions will be specified in the individual International Education Agent Agreement.

Communication with International Education Agents

SIC will ensure there is timely and relevant communication with its International Education Agents.

An International Education Agent newsletter will be distributed to all active International Education Agents on a regular basis and when updates occur.

Copies of communications relating to updates, commission payment and individual International Education Agent Agreements are retained on the International Education Agents profile on SIC’s contact management system.

Promotional Material and Events

International Education Agents are notified of availability of new promotional materials and College events through International Education Agent updates.

International Education Agents who request materials or request a representative of SIC at events are referred to the International Business Development Manager.

Roles and Responsibilities

International Education Agents are responsible for:

• Promoting SIC and the programs and courses offered to prospective students.

• Attending to prospective student enquiries by providing accurate information about the courses available through SIC and any relevant entry requirements for those courses.

• Recruiting genuine students to SIC

• Assisting students to apply for the courses offered through SIC’s enrolment procedures

• Assisting students to apply for their student visa once their CoE has been received

• Assisting the process between the prospective student and SIC and ensuring a line of communication is opened and maintained.

• Informing prospective students honestly and ethically of their responsibilities under their student visa – particularly regarding course attendance and progression, health cover, and working allowances.

• Ensuring all students are aware of SIC’s policies and procedures regarding student progress, fees, cost of living in Australia and any cultural and social expectations

• To inform SIC immediately of any issues surrounding the student that the International Education Agent has been made aware of and to work alongside SIC in solving the issues and problems the student may be facing

• Assist students to undertake an IELTS test if necessary to identify their level of English prior to applying for any course at SIC

• Forward all fees and charges collected within seven working days of receipt by international bank transfer to the relevant SIC bank accounts

• Refund any commission previously paid should the student receive a full refund on their course fees.

• Complying with the terms and condition of their individual agency agreement; and

• Maintaining understanding and compliance with this policy, the ESOS Act 2000, The National Code 2018 and the Australian International Education and Training Agent Code of Ethics.

SIC is responsible for:

• Entering into a written agreement with each International Education Agent that it works with and the agreement shall detail the responsibilities of each party and through this signed agreement the International Education Agent is authorised to recruit students for SIC in the territory agreed. SIC will provide the International Education Agent with a certificate to this effect.

• Managing the agent selection, monitoring, and review process as outlined in this policy;

• Providing staff training prior to the International Education Agent commencing recruitment for SIC, as well as on-going staff training both electronically and face-to-face in Australia and in the territory in which the International Education Agent operates.

• Distributing up to date, accurate and sufficient marketing and course materials for the International Education Agent to carry out their role under the International Education Agent Agreement

• Taking immediate corrective action should the International Education Agent be found to be operating in an unethical, dishonest, careless, negligent or incompetent manner or should they be found to be engaging in any misleading, false or unethical advertising and recruitment practices that could harm the integrity of the Australian Education sector.

• Payment of commissions to International Education Agents based on enrolments attributable to the individual International Education Agent. The amounts payable, and terms of payment are determined by the individual International Education Agent Agreement. Any other conditions will be specified in the individual International Education Agent Agreement.

• Terminating the International Education Agent Agreement if the International Education Agent, a staff member of the agent or any sub-contractor appointed by the agent is believed to be or have been operating in a dishonest, unethical or any manner which contravenes Standard 4.3 of the National Code or which contravenes the International Education Agent Agreement signed between the International Education Agent and SIC or contravenes the Australian International Education and Training Agent Code of Ethics.

• Maintaining the International Educations Agents details in PRISMS

• Maintaining and publishing a list of all International Education Agents it has agreements with and the territories in which they operate, on its website http://www.strategix.edu.au