Agent Code of Conduct November 2022

Recruitment and Management

1. Scope Agent representatives are expected to conduct themselves honestly and morally at all times. The Nurture Education Group and any education agents that the Nurture Education Group works with are subject to this policy. Agents who have contracts to work with Nurture Education Group are subject to this policy. Agents who have contracts to work for any Nurture Education Group are not covered by this policy.
2. Purpose

2.1 This Policy and Procedures sets out how Nurture Education Group engages international education agents (“agents”).

2.2 This Policy and Procedures is in place to ensure that Nurture Education Group has structured processes of:

a) Application and approval in the recruitment and selection of education agents; and

b) Monitoring and management of its agents.

• Policy Principles

3.1 Every agent working for Nurture Education Group must sign a written agency agreement with the company.

3.2 In our databases, Nurture Education Group keeps current information about agents with whom it has an agreement in place.

3.3 The Chief Operating Officer or a delegate will update the list of agents at least twice a year. It is also available on the website of Nurture Education Group.

3.4 If the contract with the agent is terminated, Nurture Education Group will remove the agent record from its website.

3.5 When recruiting students, all agents of Nurture Education Group are expected to act truthfully, in good faith, and without using misleading or deceptive tactics.

3.6 All representatives of Nurture Education Group certify that they are knowledgeable about and comprehend the British, Irish, and international educational systems.

3.7 To keep an eye on its education agents, Nurture Education Group has established procedures. Agents who represent Nurture Education Group or its courses in a dishonest, unethical, or improper manner will be subject to an investigation, suspension, and/or termination by Nurture Education Group.

Application and Approval

4.1 Nurture Education Group typically sources agents based on markets chosen by management.

4.2 Additional sources for new agents include: a) currently approved Nurture Education Group agents; b) Nurture Education Group entities in Australia or abroad.

4.3 An agent may also contact Nurture Education Group directly by phone or email, visit a Nurture Education Group location, or get in touch with a Nurture Education Group company domestically or abroad to enquire about becoming an approved agent.

4.4 Nurture Education Group’ Country/ Region Manager(s) are generally the first point of call for an agent application enquiry.

4.5 Before approving an application to become an agent, due diligence checks must be made on the enquiring agent’s company profile. These checks must be made on the following items, among others: a) The names of the agency authorised representative(s) who will sign the agreement; b) Business Registration; c) Reference contact information from at least two educational institutions; and d) Professional or industry membership.

4.6 The Country/Regional Manager or delegate will notify the agent in writing if their application is denied after a thorough investigation.

4.7 Nurture Education Group will check the agent’s references if they decide to move forwards with their agent application.

4.8 If the results of all background checks are acceptable to Nurture Education Group, the organisation may approve an agent’s application if the hiring of the agent meets the organization’s business requirements. In these circumstances, a draught Agent Agreement will be made and forwarded to the agent to sign.

4.9 The Agent Agreement details the obligations of Nurture Education Group and the agents.

4.10 The agreement must be signed and returned to Nurture Education Group within three (3) months of the agent receiving it.

4.11 After receiving the signed contract, Nurture Education Group will:

a) set up a new agent account in Nurture Education Group SMS;

b) add the agent to its website’s agent list when it conducts its twice-yearly review of its agent list;

4.12 The Chief Operating Officer or a delegate of his or her updates the list of Agents on the Nurture Education Group website at least every two years.

Training and Development

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• •  The “Country/Regional Manager” system is used by Nurture Education Group to oversee its international marketing.
  •  Country Managers will regularly review data from internal databases, reports from governmental organisations, and student feedback to keep tabs on the Agent’s activities.
  •  Nurture Education Group will give all authorised Agents the tools and materials they need to make sure that prospective students always receive accurate and up-to-date information and to ensure compliance with all applicable laws, rules, standards, and codes.
  • Failure to abide by the above obligations will result in a review process which may result in the warning and termination of the Agent Agreement.
  • All new agents will also receive initial training that is appropriate on the programmes and resources offered by Nurture Education Group, as well as an explanation of their duties and responsibilities. This instruction will be given in person, over the phone, via Skype, a webinar, or by email.
  • The training will cover Nurture Education Group’s requirements for determining the eligibility of all prospective students as students in order to manage any potential visa risks associated with the reasons a student might want to study abroad.
  • Ongoing training is additionally offered via various:

a) Visits to acquaint agents with the market;

b) Market-based agent training and workshop days.

• Nurture Education Group will use a variety of communication channels, such as update emails and newsletters, training webinars, regular agent meetings, and agent visits, to make sure that approved Agents are given current and accurate promotional material as well as informed of any changes to courses or campuses and/or any legislative or regulatory requirements (where applicable).
  • The Director of Marketing and Business Development at Nurture Education Group must receive all requests for the use of the appropriate Nurture Education Group logo via email.
  • Prior to publication, Nurture Education Group must give its approval for any advertising or use of the organization’s logo.
  • The Nurture Education Group Agent Agreement is followed when paying out commissions. Agents might also be qualified for bonuses. These could occasionally be individually agreed upon with Agents. Keeping an eye on and evaluating agent performance
  • Country Managers must perform the following duties in order to manage and support their agents effectively:

a) Visit each active agent at least once a year.

b) Deliver thorough reports to senior management on a quarterly basis.

• In addition to conducting a formal annual review, Nurture Education Group continuously evaluates the work of its approved agents.
  • The review information may be provided through Country Managers, government agencies and their reporting systems, local government agency reports around the world, as well as from student feedback. Annual Agent Performance Reports
  • The business will review agent performance at the end of every year.
  • Non-Performing Agents who are in the Nurture Education Group management system may be suspended, and no new enrolments will be permitted unless their status is changed to “Performing.” Please see the “Warning and Termination” section below.
  • A few incentives, such as bonuses but not only them, may be given to effective agents.
  • The following actions may be taken against agents who have not conducted themselves in a professional manner or in compliance with all legal requirements:

a) A letter or email of caution

b) Termination of Agent Contract (no enrolments allowed until performance improves) Revocation of the Agent Agreement

c) (criminal activities and serious non-compliances) Termination and warning

• A warning letter may be sent to an agent where they are deemed in Nurture Education Group’ reasonable perspective to be non-performing. Where a warning is issued, it is entirely the Chief Operating Officer’s (or delegate’s) discretion as to what the recommendation for action will be.
  • In the first instance and in cases where non-performance issue is deemed minor, a letter or email of warning will be sent.
  • When an agent has been deemed to be in severe breach of an item stipulated in the Nurture Education Group Agent Agreement then a letter informing the agent of termination is sent and the agent is given the right of reply to Nurture Education Group .
  • Nurture Education Group is in favour of an agent’s right to challenge any decisions the company makes in relation to their Agent Agreement. Agents must respond to the appeal in writing and include any supplementary materials. The appeal will be examined by the Chief Operating Officer (or a delegate) who will decide whether the agent qualifies for a probationary extension of the Agent Agreement. The Chief Operating Officer (or delegate) will decide whether the agent’s response is appropriate in the given circumstance.
  • The agent will be removed from the SMS by Nurture Education Group within 30 days of the termination taking effect.

After the biannual agent list review, the fired agent will no longer be listed on the Nurture Education Group website.