(1) This Policy sets out the University policy in relation to the recruitment, management and termination of International Education Agents. (2) On behalf of the University of Wollongong (UOW) and UOW College Australia (UOWCA), UOW Global Enterprises (UOWGE) is responsible for appointing and managing international student recruitment Agents. This arrangement is underpinned via the International Student Recruitment Services Agreement. (3) In carrying out this responsibility, UOWGE is committed to working with only those Agents who demonstrate: (4) The UOWGE framework for appointing, monitoring and terminating education Agents on behalf of UOW and UOWCA, is designed to ensure compliance with all relevant legislative and regulatory requirements established under the: (5) This Policy applies to: (6) All UOWGE Global Student Recruitment staff and UOWGE in-country consultants who contribute to the following for UOW/UOWCA: (7) UOWGE, on behalf of UOW and UOWCA, will: (8) Individual persons or organisations, onshore or offshore, may be engaged by the UOW and/or UOWCA as an International Education Agent to assist UOW and UOWCA in recruiting international students pursuant to the terms of individual Agency Agreements. (9) International Education Agents are representatives only within the terms of individual Agency Agreements. (10) As an Agent of UOW and UOWCA, all International Education Agents must abide by the principles of the National Code and the terms of their signed individual agency agreement. (11) The principles of the National Code of Practice for Providers of Education and Training to Overseas Students 2018, as they relate to the conduct of International Education Agents, are derived from Standard 3 of the National Code. An International Education Agent must not: (12) UOW and UOWCA have a number of approved education Agents to represent their interests in defined territories. UOWGE may approach prospective Agents to apply to be authorised Agents of UOW and UOWCA. UOWGE will also be open to receiving applications from education Agents who are seeking appointment as an authorised Agent. (13) Only Agents with a minimum of two years of experience directly representing universities that are ranked within the Top 20 in Australia, will be encouraged to apply. (14) Agents will be appointed in accordance with the following contractual conditions: (15) Agents will be appointed via the following process: (16) Global Student Recruitment Managers will ensure that: (17) Agents must submit a completed UOW Expression of Interest form or a UOW/UOWCA Authorised Agent Application form and submit either of them to international-Agents@uow.edu.au. The forms should be completed accurately and include the contact details of at least two referees from Australian Universities. Required supporting documentation includes business registration; certification such as Professional International Education Resources (PIER) – Education Agents Training Course (EATC), where applicable; photographs of the head office premise, and a business plan for promoting UOW/UOWCA. (18) The Global Student Recruitment Manager from the relevant region will evaluate the application and complete a UOW/UOWCA recommendation report, making a provisional assessment of the applicant’s suitability for appointment. (19) The two nominated referees will then be contacted by the Global Student Recruitment Manager and the responses provided will be submitted to the UOWGE Global Agent Liaison Officer along with the Agent application. UOWGE reserves the right to request the applicant to provide additional referees if deemed necessary. (20) The Director Global Student Recruitment Partnerships or nominated delegate will review the application and make a final assessment as to the Agent’s suitability for appointment. Reasons will be provided for the recommended appointment or non-appointment. The outcome and reasons for the outcome will be recorded by the Global Student Agent Liaison Officer in the Agent profile. (21) If an applicant has been assessed as suitable for appointment, the Global Agent Liaison Officer will complete the UOW/UOWCA Agent Agreement, including all schedules. The terms and conditions of the Agent Agreement include the Agent accepting responsibility and liability for the actions of any Agents acting in the capacity of the Agent’s sub-Agent. (22) A PDF copy of the Agreement will be sent to UOW and UOWCA for signature, then to the Agent’s University Liaison Officer, via international-Agents@uow.edu.au. (23) If the Agent accepts the terms of the Agreement, the Agent will sign and return the Agreement to the Global Agent Liaison Officer at international-Agents@uow.edu.au. (24) The Global Agent Liaison Officer will update the new Agent details in accordance with Clause 3.1 of Standard 4 of the National Code, in PRISMS within 24 hours. (25) The Global Agent Liaison Officer will then update the UOW website and relevant student systems with the new Agent details within 48 hours. (26) The Global Agent Liaison Officer will provide the Agent with a Certificate of Representation and with the relevant username and password for submitting student applications through the UOW/UOWCA Agent porta (27) The Agent will be able to access all relevant UOW/UOWCA course and marketing materials via the UOW website. (28) The relevant Global Student Recruitment Manager will provide training to the Agent within 30 days of the confirmed appointment. Training will address the following: (29) At the completion of training, the Global Student Recruitment Manager will identify and communicate to the Agent any demonstrated areas of strength and concern and areas for further Agent training and development. A subsequent, targeted Agent Training Checklist will be forwarded to the Global Agent Liaison Officer for recording. (30) The Global Student Recruitment Manager will engage with the Agent at least three times a year (in person or virtually), to review performance and identify requirements for further training, particularly in areas that include, but are not limited to, student visa requirements, knowledge on UOW/UOWCA programs and to provide access to current marketing and promotional materials. At the completion of each engagement, the Global Student Recruitment Manager will identify and communicate any areas of concern to the Agent and will advise of further Agent training and development required. The Manager will update the Agent Training Checklist and will report this to the Global Agent Liaison Officer for recording. (31) Regular communication will be forwarded to Agents via an Agent newsletter that will be scheduled for release every two months. This will be the responsibility of the UOWGE Global Student Recruitment Digital Engagement Specialist and the Global Agent Liaison Officer. (32) In addition, to enable Agents to perform compliantly, timely updates will be provided addressing legislative, regulatory, and/or administrative changes in laws, regulations, policies and procedures pertaining to international students for UOW and UOWCA. (33) The Director Global Student Recruitment Partnerships or the nominated delegate will work with UOW and UOWCA on post census international student surveys to understand the experience of the student coming through a particular Agent. Surveys will be conducted the week after census for Session 1 and Session 2. Any feedback, trends and concerns analysed through the surveys will be addressed in the training delivered to the Agents. Any specific feedback for each Agent will form part of the Agent review process. (34) UOWGE will actively monitor the performance of all approved Agents to ensure professional behaviour and positive recruitment outcomes, measured by the number of student referrals and the conversion rate to active enrolments at census. Agent performance will be monitored via the following processes: (35) Analysis of PRISMS based data entries for each Agent made available under Subsections 175 (3) and (4) of Education Legislation Amendment (Provider Integrity and Other Measures) Act 2017, namely information on: (36) The relevant Global Student Recruitment Manager will evaluate the Agents’ performance against agreed performance criteria, which includes: (37) At the end of each year the performance of every agent will be comprehensively reviewed, drawing on evidence gained from the above three sources. The review schedule and review outcomes will be provided in the form of a UOWGE Agent audit report to key stakeholders including UOW Academic Quality and Standards Division, the UOWCA General Manager, the University Internalisation Committee (UIC) and the University Education Committee (UEC), at the first scheduled committee meetings of the following year. (38) The Global Student Recruitment Managers will make a recommendation relating to the renewal of each Agent Agreement, and the Director Global Student Recruitment Partnerships will decide whether to: (39) If, after successful completion of the current Agent Agreement, UOWGE is satisfied that the Agent has operated ethically, has represented UOW/UOWCA in a professional manner, and has enrolled high quality students to UOW/UOWCA programs, with satisfactory conversion and success ratios, a renewal of the Authorised Agent Agreement may be offered to the Agent in accordance with clause 1.3 above. The renewal process is as follows: (40) Without limiting UOW/UOWCA rights under clause 12.5 of the Agent Agreement, UOWGE may at its sole discretion suspend an Agent Agreement immediately if it has reasonable grounds to believe that the Agent (or where applicable the sub-Agent of the Agent): (41) UOWGE will notify UOW/UOWCA of its decision. (42) UOWGE will lift the suspension when the Agent (or where applicable a sub-Agent) has satisfied that the reason for suspension has been adequately resolved. UOWGE will notify UOW/UOWCA of its decision. (43) UOWGE on behalf of UOW/UOWCA may terminate an Agent Agreement at its discretion by giving the Agent 30 days’ written notice. Termination of an Agent’s Agreement will be automatic if UOWGE knows, or based on reasonable grounds, concludes that the Agent has engaged in criminal conduct, and that the Agent’s known or suspected actions will be reported to the relevant authorities. (44) If the Agent identifies the cause of a recognised breach as being one of their employees or sub-Agents; provides valid evidence to support this and takes immediate action to dismiss the responsible employee and/or terminate the sub-Agent’s Agreement, then UOWGE on behalf of UOW/UOWCA may decide to retain the Agent, on the basis that the Agent undertakes additional training deemed necessary and as specified by UOWGE. (45) Termination or non-renewal of an Agent Agreement will occur in cases of demonstrable or highly suspected: (46) When UOWGE decides not to renew or terminate an Agent agreement the decision and reasons will be conveyed to the Agent in question, using the Authorised Agent Termination email, and the termination will take place when the Agent has formally served a 30 day notice period. If the termination is based on criminal conduct, The Department of Education (DET) and DHA will be notified of the termination. (47) The Global Agent Liaison Officer will update the Agent Audit Matrix and ensure all University systems including PRISMS are updated. (48) The Agent’s students will be notified of the termination/non-renewal, and invited to submit an UOW/UOWCA Change of Agent form. (49) UOWGE will ensure that no further applications are received from the Agent. (50) Upon termination of an Authorised Agent Agreement, the Agent must: (51) All Agent commission invoices will be processed and paid after the study period census date. (52) All commission invoices are to be sent to Agent-invoices@uow.edu.au and will be processed by the UOWGE Global Recruitment Administrator. (53) Before a commission payment can be made, the following information must be provided on the Agent invoice: (54) Commission payments are only payable on the fully paid tuition fees. (55) In cases where the students enrol for only a part of the program the commission will be paid based on the number of units/subjects enrolled by the student. (56) The Agent Liaison Officer will inform all approved Agents of any change in the physical address, telephone number, facsimile number or electronic mail address of UOW or UOWCA, within five working days of such change. (57) UOWGE does not accept referral students or encourages referral commissions from prospective Agents. (58) Any complaint made by a student of UOW and UOWCA, received via the UOW Grievance Policy and Procedure for Investigating Grievances will be investigated thoroughly. Likewise, any matter that becomes known and that relates to a suspected serious breach regarding the behaviour and practices of an authorised Agent will be investigated thoroughly. In either case the following steps will be implemented: (59) The outcome of the formal investigation will be recorded in the UOWGE Agent profile and in relevant UOW systems; and will be reported to the UOW Academic Quality Division, by the Global Agent Liaison Officer. (60) International Education Agents are responsible for: (61) UOWGE is responsible for: (62) UOW Admissions and Compliance are responsible for: (63) Strategic Marketing and Communications Division is responsible for:International Education Agent Policy
Section 1 - Purpose of Policy
Top of PageSection 2 - Application and Scope - Exclusions or Special Conditions
Top of PageSection 3 - Policy Principles
Top of PageSection 4 - International Education Agent Functions
Top of PageSection 5 - Appointment of International Education Agents
Section 6 - Training of International Education Agents
Section 7 - Monitoring International Education Agent Performance
Top of PageSection 8 - Renewal of International Education Agent Agreements
Top of PageSection 9 - Suspension of International Education Agent Agreements
Section 10 - Termination of International Education Agents
Top of PageSection 11 - International Education Agent Remuneration
Section 12 - Complaints Handling
Section 13 - Roles and Responsibilities
Top of PageSection 14 - Definitions
Word/Term
Definition (with examples if required)
Addendum
A contract addendum is an agreed-upon addition signed by all parties to the original contract. It details the specific terms, clauses, sections, and definitions to be changed in the original contract but otherwise leaves it in full force and effect.
Agent
A person or organisation approved by UOW/UOWCA with authority to promote its programs and services to students or prospective students within agreed terms.
Agent Agreement
Agreement between UOW/UOWCA and the Agent, including the Schedules.
Confirmation of Enrolment (CoE)
A document that confirms the enrolment status of a student.
CRICOS
Commonwealth Register of Institutions and Courses for Overseas Students.
ESOS Act
Education Services for Overseas Students Act 2000 of the Commonwealth of Australia.
ESOS Regulations
Regulations made according to the Education Services for Overseas Students Act 2000 of the Commonwealth of Australia.
International Student
A person who holds an Australian Student Visa and is an 'Overseas Student' as defined by the ESOS Act
Non Genuine Student
A student visa holder may be considered a non genuine student by the Australian Government Department of Home Affairs (DHA) if it appears that their primary intention is not, or not likely to be, to undertake study.
The National Code
National Code of Practice for Providers of Education and Training to Overseas Students 2018
PRISMS
Provider Registration and International Student Management System. Provides Australian education providers with the Confirmation of Enrolment (COE) facilities required for compliance with the ESOS Act.
Prospective Student
A person who intends to become, or who has taken any steps towards becoming, an 'overseas student' or 'intending overseas student' as defined by the ESOS Act.
Student systems
UOW’s student Customer Relationship Management system (CRM) and website.
Territory
The geographical location in which the Agent operates. An Agent’s Territory is identified in the Agent Agreement Representative Schedule.
University of Wollongong Global Enterprises (UOWGE)
UOWGE is a subsidiary group of the University of Wollongong. UOWGE manages global student recruitment and its related functions for UOW and UOWCA.
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