International Student Education Agent Management Procedure
1. Preamble
These procedures outline the process for governing the appointment, management, and termination of the relationships between International Education Agents (Education Agents) and the Australian National University (ANU).
This procedure is compliant with requirements under the Education Services for Overseas Students (ESOS) Framework, the Higher Education Standards Framework together with the Australian International Education and Training Agent Code of Ethics (ACE).
2. Procedures
2.1. Agent appointment
2.1.1. Agents may apply to the Institute to become a representative by emailing directly to the student services team.
2.1.2. The Institute may strategically approach agents directly and invite them to become an agent for the Institute.
2.1.3. An application made to the Institute by a prospective agent must be accompanied by the following information: Business Registration, Company Profile, Reference contact details from a minimum of three Australian education institutions, and migration agent certifications. Where the agent has not worked with an Australian provider, references are sourced from reputable international institutions.
2.1.4. Agents must declare in writing any potential conflict of interest in relation to their work for the Institute and must take reasonable steps to avoid any conflict of interest at any point in their engagement with the Institute.
2.1.5. The Institute's Student Services Team are responsible for reviewing agent's applications and providing recommendation to General Manager for approving the engagement of education agents.
2.1.6. In the event of an agent's application being successful, an agent agreement shall be prepared for execution and exchange. Agents have eight weeks to return signed agreements to the Institute and will be considered formally engaged on receipt of the agreement by the Institute.
2.1.7. Agent details are recorded on the Federal Government’s PRISMS database and Institute’s agent register.
2.1.7.1. In the event of an agent's application being rejected, notification will be forwarded to the agent and the decision will be recorded on the Institute’s agent management register.
2.2. Training and working with authorised Agents
2.2.1. Agents engaged by the Institute will receive comprehensive training and induction, including information relating to international education in Australia (ESOS and National Code requirements), Agent responsibilities, Australian requirements for and conditions of student visas, the Institute’s programs and courses, administrative procedures and forms, and other compliance requirements at the point of engagement. Formal training to supplement initial recruitment information will be provided no later than three months of agents signing an agreement.
2.2.2. Each training program is evaluated for quality assurance and continuing improvement purposes.
2.2.3. The Institute's Student Services is responsible for communication with agents regarding contracts, issues relating to admissions, key operational updates, policy changes, enrolment details, training of agents, and ongoing monitoring.
2.3. Ongoing monitoring and breaches
2.3.1. The relevant member of the student services team will use thorough, open and transparent evaluative methodologies to actively monitor the performance of its agents on an ongoing basis.
2.3.2. The relevant member of the student services team will undertake regular agent monitoring using data from internal databases, Australian Government agencies and their reporting systems and student feedback.
2.3.3. The General Manager, in conjunction with Student Services Team is responsible for monitoring and review of agents at the Institute and will report on outcomes to the Chief Executive Officer and Provost.
2.3.4. Formal monitoring of agents occurs on a Semester and annual basis.
2.3.4.1. Semester review pre- and post-intake.
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- Review the performance of agents with the aim of escalating immediate issues for action. The monitoring will be through:
- Feedback from students and other stakeholders.
- Analysis of the volume and quality of applications submitted by the agent, their conversion rates for applications and reasons for students not proceeding with their enrolment.
- Checking of agents’ websites, events and student communications for the accuracy and currency of the information they are providing.
- Analysis of student visa approval, refusal, and cancellation data.
- Academic outcomes of their students.
- Review the performance of agents with the aim of escalating immediate issues for action. The monitoring will be through:
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2.3.4.2. Annual Review
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- In addition to ongoing monitoring, the Institute’s agents are evaluated annually to determine if they are meeting the requirements of their agreement, their compliance with relevant legislation, and whether they meet agreed recruitment targets and other performance indicators.
- The General Manager approves the outcome of the annual review which may be either:
- The performance of the agent is found to be satisfactory,
- The performance and/or compliance of the agent is found to be unsatisfactory and further action is required.
- If further action is required the agent must respond within 10 working days from the date of the notification being sent, or up to any further period as may have been granted by the Institute.
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2.4. Agent Suspension/Termination
2.4.1. In the case of complaints made by students in relation to agents, the General Manager, will undertake an investigation of the complaint, document the complaint received and, if required, escalate the complaint to the Chief Executive Officer and Provost.
2.4.2. The Institute will take immediate corrective action where it becomes aware, or has reason to believe, that an agent (or an employee or subcontractor of that agent) has not complied with their responsibilities under the agent agreement, National Code 2018 or ESOS Act.
2.4.3. In the event of a successful annual review, or if the concerns in the review are addressed satisfactorily, the Institute may:
2.4.4. re-appoint the agent for a further period,
2.4.5. re-appoint the agent for a further period subject to certain conditions,
2.4.6. require the agent to do additional training and further professional development as specified by the University before reappointing them.
2.4.7. The Institute will immediately suspend or terminate its relationship with an agent where it becomes aware, or has reason to believe, that the agent (or employee or subcontractor of that agent) has engaged in false or misleading recruitment practices. Decisions on suspending or terminating agent agreements are made by the General Manager, and the agent is notified in writing.
2.4.8. The Institute may terminate an agent’s agreement if the agent does not rectify concerns raised by the Institute.
2.4.9. The Institute may determine not to terminate an agent where an individual employee or subcontractor of the agent was responsible for the conduct outlined immediately above and the agent has terminated the relationship with the individual employee or subcontractor.
2.4.10. Any party to the agreement may also terminate the agency agreement at any time and for any reason by giving 60 days’ notice in writing to the other party.
2.4.11. If the agreement is terminated by either party, the agent must:
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- Submit to the Institute all application and program fees from prospective students received up to the date of termination,
- Cease immediately any actions representing the Institute,
- Submit any outstanding invoices to the Institute within 30 days after the termination.
2.4.12. The agent may appeal a decision by the Institute to terminate the agreement, to the Chief Executive Officer and Provost, on the grounds that the review process has not been fairly undertaken.