THE NATIONAL CODE
OF ETHICAL PRACTICEFOR UK EDUCATIONAGENTS 2021

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INTRODUCTIONPurpose
The National Code of Ethical Practice for UK Education Agents (referred to as ‘the National Code’) sets out
the standards and best practice that education agents and agent aggregators, brokers and marketplaces(Digital Agent Networks), representing UK educational institutions are expected to adhere to.
Born out of the London Statement (2012) and the British Council Good Practice Guide for Education Agents(2013), it is endorsed by many of the UK’s education peak and promotional organisations. Education Agents
have contributed to the National Code’s development and UK educational institutions have committed toimbedding the National Code into their education agent contracts and quality management practices.
It is not in of itself a legal document.

Definitions
Education Agent
A person or organisation that deals directly with prospective international students on behalf of educationalinstitutions. They are contracted directly or indirectly to deliver a range of services to potential students andthe educational institutions. To a student, these services would ordinarily include education counselling, suchas course and institution matching, and assistance with academic and visa applications.
To an educational institution, services usually include marketing and promotion services and support inidentifying qualified students.

Digital Agent Networks
Contracted directly by educational institutions, a digital agent network (agent aggregators, brokers andmarketplaces) (sometimes referred to as a B2B Agent, Master Agent or an Outsourced Agent ManagementService) facilitates the delivery of education agent services to students via a network of education agents(service delivery partners) and providing a one-to-many relationship between an educational institution
and education agents. This is achieved through a technology platform and/or a sub-contracting-typearrangement. Digital agent networks assume responsibility for their service delivery partners’
compliance with this National Code.

Qualified Student
A student who intends to enter the country (UK) for academic purposes at the selected educational
institution or package of institutions e.g., foundation college to university, as described in their application
for study, and meets the requirements stipulated by the Home Office to legitimately study in the UK on theterms set out in their visa. Where a student intends to study a UK course offshore e.g., via a partner / online
delivery / institution’s offshore campus, they would be considered qualified based on their academic meritalone.

Student Client
A prospective student who agrees (signed agreement) to engage the services of an education agent in supportof their academic and visa applications and any ancillary services as per their agreement.

Educational Institution
A recognised UK education provider of a course or courses of study that international students may enrol in,
not limited to schools, colleges, English schools, foundation providers, universities and institutes.

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Ethical Framework
The National Code is based on the underlying ethical framework of the London Statement that requires
education and aggregator agents to operate with:•Integrity: being straightforward and honest in all professional and business dealings;•Objectivity: not allowing professional judgment to be compromised by bias or conflict of interest;• rofessional competence and due care: maintaining professional knowledge and professionalP
service, and acting diligently;•

Transparency: declaring conflicts of interest to all clients, especially when service fees are charged toboth the education provider and the prospective student;• onfidentiality: respecting and preserving the confidentiality of personal information, and not releasing
Csuch information to third parties without proper authority in-line with UK data protection legislation;•

Professional behaviour: acting in accordance with relevant laws and regulations and dealing withclients competently, diligently and fairly; and•	Professionalism and purpose: acting in a manner that will serve the best interests of clients and thewider society even at the expense of self-interest; recognising that dedication to these principles is themeans by which the profession can earn the trust and confidence of stakeholder groups (individual clients,the public, business and government).

The National Code Standards
The National Code of Ethical Practice for UK Education Agents is made up of five Standards.
Each of these Standards contains a range of expected/desirable practices and suggested evidence points.

Organisational
Behaviours

Organisational
Competence

Ethical BusinessPracticeTHE
STANDARDS

Student-CentredPractice

Objective Adviceand Guidance

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1. ORGANISATIONAL BEHAVIOUR
Education agents and digital agent networks commit to professional business governance and practices.
You conduct yourselves with due regard to the regulatory conditions in the market(s) in which you operate
as well as complying with all applicable national laws, regulations and official policies. Furthermore, you act
with integrity and in a manner that reflects positively on the image of the profession, of your educational
institution partners and of the UK education sector as a reliable and trustworthy provider of high-quality
education and training.

Expected Practice

Suggested Evidence

1.1. Act professionally, honestly and responsibly• Staff handbook•	Staff/education agency certification –British Council Education Agent Training
Programme

1.2	Avoid or declare conflicts of interest and comply with relevantlaws and regulations
1.3.	Observe appropriate levels of confidentiality and transparency
including declaring any relevant partnerships and affiliations(including with sub-agents/managed agents) to partners andstudent clients and providing clear protocols for managing
these relationships•	Archives of client records and agreementsfor previous 2 years•	Protocol/policy documents for managing
third parties with demonstrable auditing
trail to show they are being used

1.4.	Be transparent about which organisations the company
formally represent (under contract) and those that they do not•	Education agent websites and promotional
materials

1.5.	Clearly display the company registration/identifiers on
websites and advertising materials
1.6.	Use approved marketing communications or gain approval todevelop marketing communications on behalf of an educational
institution, to promote educational institutions with whom thecompany has an agreement
1.7. Provide a safe environment for their workers
1.8.	Provide a professional physical/online space for counselling
student clients•	Jurisdiction appropriate health and safety,bullying and harassment, and equality anddiversity policies or evidence of appropriate
processes in place•	Photographs of the office and promotional
stands - virtual/physicalDesirable PracticeMake efforts to minimise the environmental impact of their business
operations• Environmental kite marks• Environmental policies

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2. ETHICAL BUSINESS PRACTICE
Education agents and digital agent networks maintain the highest standards of ethical business practices.
You promote yourselves and your educational institution partners fairly and without recourse tounfavourable or negative comparisons with other educational institutions. You do not employ unfair orunprofessional practice to damage the interests of other agents or educational institutions. You are honest incommunicating information about yourselves, your educational institution partners and your student clientsin published, oral or in any other form.

Expected Practice

Suggested Evidence

2.1	Ensure all staff have read and understand the National Codeof Ethical Practice for UK Education Agents and the associatedbusiness practices of your organisation including being open
about commercial relationships (not financial detail) withstudent clients• Staff handbook•	Staff/education agency certification –British Council Education Agent Training
Programme

2.2	Be transparent about which education agent services fallunder ‘educational institution pays’ (under commission
arrangements)1 and/or ‘student pays’•	Signed written/digital agreements between
education agents and student clients that
include information about fees, information
about themselves and complaints processes•	Documented systems and protocols forhandling complaints

2.3	Disclose the use of marketing incentives to contracting
educational institutions and refrain from practices designed tolure prospective students away from competitor organisations
2.4	Provide clear avenues for handling complaints and resolving
disputes including UK educational institutions’ complaints
processes
2.5	Maintain signed agreements between your education agent
company and your student clients
2.6	Provide accurate information about yourselves that supports
comparison of registration, accreditations, professional
associations, qualifications and experience without knowingly
providing misleading information•	Examples of action taken based on studentclient and partner educational institution
feedback• Documented systems and protocols

2.7	Monitor student client and educational institution feedback
and act where necessary
2.8	Have in place systems and protocols (including relevantly
trained staff) to identify and avoid the submission offraudulent or misleading student documents to UK educational
institutions and visa authorities• Documented systems and protocols

2.9	Do not seek to or facilitate students moving between
institutions to courses of the same or lower QAA level (providerhopping), to gain additional commission*• Documented systems and protocols* Where a student has sound reasons for moving, you should inform theexisting and future educational institution and where appropriate work withthem to find an agreeable solution

Desirable Practice
Be members of professional associations and networks that promoteand support best practice in the recruitment of internationalstudents

1• Link to membership list / kite markNote it is not expected that the amount of commission is disclosed; this is commercially sensitive.

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3. OBJECTIVE ADVICE AND GUIDANCE
Education agents and digital agent networks provide accurate advice and guidance tailored to the studentclients’ needs, wants and capabilities. You shall not knowingly or by a failure of professional standards
provide or disseminate false, incomplete or misleading information.

Expected Practice

Suggested Evidence

3.1	Introduce a range of possible educational institutions to thestudent client aligned to their profile•	Examples of student client and family
feedback

3.2	Refrain from claiming a direct government endorsement or
privileged relationship with a public official or member ofthe government where one does not exist, e.g., the misuse ofnational brand logos•	Examples of marketing communicationmaterials (including web)•	Photographs of promotional stands andoffice promotional areas•	Evidence of staff having completed a range ofnational and institutional training sessions•	Examples of feedback from educational
institution partners about the quality of thecounselled students/applicants• Documented protocols• Staff handbook

3.3	Refrain from claiming or implying a contractual relationshipwith a UK educational institution, or similar endorsement,
where one does not exist, e.g., the misuse of educational
institution brand logos, images and other marketing collateral
3.4	Implement considered and targeted marketing practices andensure honest and accurate communication resources are inplace
3.5	Be transparent about your company fees (student pays) andcharges and have in place a documented refund policy• Refund policy

Desirable Practice
Publish a company charter on how they will counsel and support
student clients• Company Charter

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4. STUDENT-CENTRED PRACTICE
Education agents and digital agent networks advocate for qualified students in their desire to gain admission
to recognised, accredited and contracted educational institutions. You act in the best interests of studentclients as well as the partner institutions and offer advice, counselling and information to students, andwhere appropriate their parents, in a manner consistent with the National Code.

Expected Practice

Suggested Evidence

4.1	Provide realistic and appropriate information that is tailoredto the individual student client’s circumstances, particularly inrelation to language skills, capacity to pay and level of study•	Examples of student client and family
feedback•	Spot check audit documents of counsellinginteractions• Staff handbook•	Company equality and diversity policy (forstaff and students) or equivalent document

4.2	Support student clients’ enrolment journey without prejudice
or discrimination, including in relation to their nationality,race, gender, sexual orientation, religion, disability, age,marital or maternity status
4.3 Act in the best interests of a qualified student
4.4	Proactively and accurately advise student clients of nongenuine educational institutions and areas of sector concern tohelp them make informed decisions
4.5	Provide pastoral care and student wellbeing support in linewith the education agent’s duty of care – for all student clients,
but in particular for those under 18 years of age
4.6	Specify the rights and responsibilities of the student clientin the destination country including complaints and appeals
processes and visa stipulations such as part time work rules•	Signed written/digital agreements between
education agents and student clients that
include information about fees, information
about themselves and complaints processes•	Documented systems and protocols forhandling complaints

4.7	Ensure strict confidentiality of personal information and that
this information is not shared with a third party unless consent
is given, in line with UK data protection legislation•	Appropriate governance and document
management in place and process/policy
regarding document management andsecurity

Desirable Practice
Publish a company charter on how they will counsel and support
student clients• Company Charter

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5. ORGANISATIONAL COMPETENCE
Education agents and digital agent networks maintain their staff and service delivery partners knowledge of
the UK and of educational institution partners, and the skills associated with delivering professional practicewith a high degree of competence.

Expected Practice

Suggested Evidence

5.1	All UK focussed staff understand relevant legislation andregulations relating to recruiting students to UK educationalinstitutions•	Staff/education agency certification –British Council Education Agent Training
Programme•	Record of staff having completed advanced
professional development units from theBritish Council Education Agent Training
suite•	Education agent’s/digital agent network’s
in-house training records demonstratingthat their staff and service delivery
partners regularly participate in continuing
professional development activities thatmaintain their up-to-date knowledge

5.2	All UK focused education agent counselling staff havecompleted UK education agent training
5.3	At least one UK focused education agent counselling staff peroffice to have completed the British Council Education AgentTraining Programme
5.4	All UK focussed staff participate in regular training from UK
educational institution partners
5.5	Keep records of staff’s UK education focused training(including dates and type)Desirable Practice•	Multiple UK focused education agent counselling staff per office
to have completed the British Council Education Agent Training
Programme•	All senior counselling staff have completed the British Council
Education Agent Training Programme•	Staff/education agency certification –British Council Education Agent Training
Programme

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