Ϲ Monitor Articles about Codes of Conduct /category/industry-standards/codes-of-conduct/ Ϲ Monitor is a business development and market intelligence resource providing international education industry news and research. Tue, 03 Mar 2026 10:05:04 +0000 en-GB hourly 1 https://wordpress.org/?v=6.5.3 /wp-content/uploads/2022/07/cropped-LOGO_2022_FLAVICON-2-32x32.png Ϲ Monitor Articles about Codes of Conduct /category/industry-standards/codes-of-conduct/ 32 32 The next era of international education: Trust, transparency, and a focus on quality /2025/10/the-next-era-of-international-education-trust-transparency-and-a-focus-on-quality/ Thu, 30 Oct 2025 04:00:17 +0000 /?p=46296 Since 1995, Ϲ Berlin has served as a catalyst for connecting the world through education. With our 30th anniversary approaching, our sector is facing a new challenge: the need to build better systems and standards for ensuring transparency, compliance, and student wellbeing. In all four of the world’s leading study destinations – Australia, Canada, the…

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Since 1995, Ϲ Berlin has served as a catalyst for connecting the world through education. With our 30th anniversary approaching, our sector is facing a new challenge: the need to build better systems and standards for ensuring transparency, compliance, and student wellbeing.

In all four of the world’s leading study destinations – Australia, Canada, the UK, and the US – governments are taking a closer look at how students are recruited. From tightening visa policies and integrity audits to mandatory declarations of agent use, the message is clear: compliance and accountability are now as critical as marketing and conversion. The challenge now is to reshape how institutions, agents, and governments interact in this new context.

The next thirty years will belong to those who not only recruit globally, but who also act responsibly.

How it all began

In the 1990s, international education was still a limited, even experimental, activity. Apart from short-term language study holidays within Europe, students from a small number of countries travelled mainly to the UK and the US for tertiary studies or exchanges. Yet the soft power, innovation, revenue, and intercultural understanding generated by student mobility soon drew in many more students, institutions, and destinations. What began as a trickle of cross-border enrolments became a pillar of globalisation.

Three decades of expansion

In 2002, there were roughly 2.5 million international students worldwide, of whom more than a third came from China. By 2023, that number reached nearly 7 million, a 176% increase.

These numbers reflect a focus on growth. The expansion in outbound mobility did not only benefit schools and universities, but it also boosted governments and entire economies. In 2021/22, international student spending contributed US$52.2 billion to the UK economy and US$26.5 billion to Canada’s. In 2023/24, it accounted for US$32.7 billion in Australia and US$43.8 billion in the United States.

The benefits are not just fiscal. Nearly 60% of international doctoral students in the OECD study science or engineering. They drive research and innovation and lead major start-ups. Their collaborations consistently produce high-impact papers and cutting-edge research. In short, the mobility pipeline feeds the innovation pipeline. The lab bench does not care about passports, and the citation record proves it.

The cultural dividend of international student mobility is impossible to measure. International students bring the world closer together, forming friendships, business partnerships, and academic networks that last a lifetime. They return home as ambassadors for their host countries, carrying new languages, values, and professional skills that shape diplomacy and multilateral trade. In a world increasingly divided by politics, international education remains one of the few systems that consistently builds bridges rather than borders.

Thirty years of connection and change

Over the past three decades, Ϲ Berlin has grown alongside the industry itself, from a small gathering in 1995 to the world’s leading forum for international education partnerships. As always, the focus of the event evolves in response to changing circumstances, regulatory environments, and sectoral trends. Providing systems and structures that support greater transparency, trust, and accountability is not a new priority for Ϲ – it is a pillar of our operations. What’s more, we now offer agents and institutions more programmes and services supporting greater integrity and quality control than ever before. 

The human infrastructure behind it all

When thinking of what has driven the success of the industry so far, it would be wrong to underestimate the role of education agents. For decades, agents have helped families to navigate complex systems, translated opaque policies into clear expectations, and made international study accessible far beyond elite circles. Agents function as counsellors, logistics experts, and cross-cultural guides.

In fact, education agents have become one of the most quietly powerful forces in international education. They perform a unique dual role by guiding families through complex admissions systems and helping universities to reach more students in a diverse range of markets.

Yet as new regulatory frameworks emerge, such as the UK’s Agent Quality Framework and Canada’s pending federal registry for education agents, we risk forgetting just how much value these intermediaries create.

Guardrails but not roadblocks

No one disputes the need for higher professional standards, transparent data, and accountability. The scandals and negative headlines we have all seen in recent years show what happens when those are absent. But as it stands, policy makers have often blurred the distinction between unethical operators and legitimate, responsible businesses.

Without that distinction, the danger is that the blunt compliance mechanisms, however well intentioned, could consolidate market power among a handful of large agencies. This would leave local experts behind, and it would limit student choice. What is needed is not less oversight, but smarter oversight built on shared data, sound codes of practice, and technologies that make it easier to scale quality controls.

In this environment, voluntary accreditation frameworks such as  are helping to raise standards globally. With more than 2,300 accredited agencies in over 130 countries and nearly 700 institutional supporters across 50 countries, IAS has become the world’s largest quality-assurance framework for education agencies. It recognises businesses that meet rigorous ethical and operational criteria, providing governments and educators with a trusted benchmark of professional integrity. IAS demonstrates that accountability can be collaborative when well considered and structured.

Collaboration and systematised quality controls are essential for sustainable growth in the new era of international education. , for example, brings transparency to both sides of the recruitment relationship.

For institutions, it offers AI-powered analytics and real-time data for comprehensive due diligence checks on agent partners, flagging potential risks early by monitoring regulatory sanctions, legal filings, and social media activity.

For agents, it provides tools to protect their reputation and gain clearer visibility into their sub-agent networks, helping them demonstrate integrity and meet rising government expectations for accountability.

These innovations are supported by a broader commitment to professional development through , which today counts more than 144,000 registered learners and over 21,000 graduates across 130 countries. Ϲ Academy provides structured learning pathways for education counsellors, institutional staff, and sector professionals, making training and certification measurable and accessible worldwide.

ճ platform gives educators a practical way to ensure their recruitment partners are both effective and compliant. It enables structured, multilingual training for agent networks so that every counsellor understands an institution’s background and academic offer, admissions process, ethical standards, and regulatory requirements. It also allows institutions to monitor counsellor progress and training outcomes, giving them clear visibility and measurable oversight of network-wide compliance. The platform is equally valuable for master agents, who can use it to train and inform their sub-agents.

Beyond professional development, Train Your Agents helps educators to demonstrate compliance, protect institutional reputation, and support agents with credible, up-to-date knowledge. In an era demanding transparency, it provides clear proof of responsible recruitment across the global network.

These tools are not about policing; they are about empowering international educators and promoting quality assurance. Together, IAS, Due Diligent, and Train Your Agents create a framework where integrity becomes operational, where compliance strengthens opportunity rather than constraining it.

The next thirty years

If the past three decades were about expansion, the next will be about trust. Collaboration between governments, educators, and quality agencies will be essential to achieve this.

International education remains one of the most positive forms of global exchange ever created. The small agency owner in Nairobi, Lahore, or Ho Chi Minh City, the one who knows every student’s family by name, is as vital to that ecosystem as the vice-chancellor or the minister.

At its core, international education has always been about students. We should welcome and design frameworks and partnership models that protect their dreams and ambitions while empowering responsible agents and institutions to support them safely. The future belongs to those who evolve, embrace transparency, and continue to earn the trust of the students we serve.

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Who decides about quality? Education agents and the question of increased regulation /2024/06/who-decides-about-quality-education-agents-and-the-question-of-increased-regulation/ Thu, 27 Jun 2024 16:39:36 +0000 /?p=43492 There has been a surge in international student mobility since the pandemic, and that rapid growth has tested many of the quality assurance measures in place across the international education sector. Student services have struggled to keep pace, the global stock of student housing has been overstretched, and several models for recruiting and teaching international…

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There has been a surge in international student mobility since the pandemic, and that rapid growth has tested many of the quality assurance measures in place across the international education sector. Student services have struggled to keep pace, the global stock of student housing has been overstretched, and several models for recruiting and teaching international students have come under greater scrutiny.

Viewing all of that through a student lens, we have to acknowledge as a sector that in tandem with the recent surge in international student mobility, there has been an increase in reports of students having had a negative experience of study abroad. Those reports are grounded in a variety of issues, including shortages of affordable student housing, mental health concerns, poor integration into local communities, difficulty accessing support services, poor programme delivery, and sub-par graduation and career outcomes for some students.

Those reports have led to growing calls for better regulation of the sector, and they have prompted a wave of new policy settings brought forth by several national governments. New settings include enrolment caps in a number of countries – notably the Netherlands, Canada, and Australia – and a variety of new restrictions and requirements for visiting students.

Parallel to that pattern of tightened rules around international students has been a call for increased regulation of education agents. It is well established that agents play a critical role in student recruitment, and in providing invaluable support for students, parents, and institutional partners. But the education agent space is largely unregulated, operates at a considerable scale (with an estimated 22,000+ agencies worldwide), and offers few barriers for new entrants, especially in an era of aggregated agent networks and remote work.

Partly because the agent space is so large, varied, and lacking serious barriers to entry or to the expansion of agent networks, it has also been highly resistant to regulation. In practical terms, a given national government has little influence over an agency abroad that can quickly rebrand or restructure, or just as quickly shift its recruiting activity from one sector to another or from one country to another.

For all those reasons, there is a broad consensus that self-regulation – that is, measures that come from the industry itself – represents the best path forward for creating and implementing effective quality assurance measures for education agents.

The building blocks

Resistant to regulation as the agent space may be, there has, in fact, been a lot of great work done to strengthen standards of practice for education agents, and to advance the professional qualifications of agency-based student counsellors.

This work has largely occurred in three key areas: codes of conduct, agent training, and agency accreditation. There are a swirl of terms in this space, including “certification,” “accreditation,” and more. Codes of conduct, agent training, and agency training are sometimes conflated with one another, but it’s important to specify exactly what is being referred to. Each of these three components is quite distinct from – but highly complementary to – the others, and an effective self-regulation regime will combine all three.

Standards of practice

A number of codes of conduct and best practice guidelines are in place today, both pertaining to agent conduct and to the professional practices of institutions engaged with agents. Examples include the London Statement (formally, The Statement of Principles for the Ethical Recruitment of International Students by Education Agents and Consultants); the National Association for College Admission Counselling’s (NACAC) Guide to International Student Recruitment Agencies; the British Universities’ International Liaison Association’s (BUILA) National Code of Ethical Practice for UK Education Agents; the Australian Agent Code of Ethics (ACE); the Association of International Enrollment Management’s (AIRC) Best Practice Guidelines for Institutional Members; the Association of Language Travel Organisations’ (ALTO) Best Practice Guidelines for Education Providers and Agents; and the Ϲ Code of Conduct for the Ethical Recruitment of International Students.

Some codes of conduct are more oriented to one or more education sectors or to a given destination. If we were to put them side by side, however, we would find that they almost universally advance a common set of core principles, including transparency, accountability, integrity, fair dealing, and a commitment to high standards of student service on the part of education agents and also their institutional partners.

Any effort to strengthen quality standards for education agents – that is, any serious effort of self-regulation – rests in part on a clearly framed code of conduct, the standard of practice that it reflects, and a global mechanism for enforcing those standards.

An expanding field of training options

Put yourself in the shoes of a student counsellor working in an education agency. She may have studied abroad herself, or, through fam tours or other visits, have gained a firsthand experience of one or more destination countries. Alongside her knowledge of a study destination, its student visa programmes, and other relevant regulations, she also has to be an expert in any number of institutions and schools, their respective policies, and the many programmes and services they provide.

By any reckoning, that is a tremendous base of knowledge for any counsellor to establish and maintain, especially given that those programme offerings, policies, and other key points of information are changing all the time.

That explains the high demand for training among agency-based counsellors, both on best practices in recruitment and student services as well as training on advising students to study in one country or another, and of course ongoing training on individual institutions or schools.

It explains as well why many institutions invest heavily in counsellor training in support of their agent-partners, and why there is an expanding emphasis on agent training across the international education sector.

Agent training, for example, is embedded in the UK’s (AQF), a package of measures that includes specialised training courses for agency-based counsellors advising on study in the United Kingdom. And there are other specialised platforms, including , which provides a hosted solution that institutions and schools can use to deliver training for agent counsellors, and , which provides a growing portfolio of destination-focused courses along with other professional development options and qualifications for counsellors.

Within the AQF, the was developed and is administered by the British Council, and it is also delivered in partnership with Ϲ Academy. To date, 23,000 counsellors have registered for the course and nearly 10,000 have completed it and also endorsed the AQF’s code of conduct. “Until recently, the AQF was a voluntary framework where UK universities pledged to meet the standards set to evidence their good conduct,” says Jacqui Jenkins, the Global Lead for International Student Mobility at the British Council. “To the best of my knowledge almost all UK providers pledged to the AQF by the time the government made it mandatory [in spring 2024]. Independently, agents have also made public statements about their support of the AQF. Since the pledge was launched the number of agents registered for the [UK course] has increased from 8,000 in December 2023 to more than 26,000 in June 2024.”

Agent training is similarly embedded in the quality assurance standards in Australia, where agent-counsellors referring students to Australian institutions can complete the (EATC) in order to earn a Qualified Education Agent Counsellor (QEAC) designation. The EATC is a long-established course, now delivered by Ϲ Academy, with more than 13,000 graduates. “The EATC is a perfect example of how training can become part of an industry standard,” says Ϲ Academy Director Stacey Crosskill. “It provides counsellors with a strong foundation for effective student advising, and it allows individual institutions and schools to concentrate their own training efforts on their respective programmes and services.”

Alongside the British Council course for the UK and the EATC for Australia, Ϲ Academy provides specialised courses for counsellors advising students on study in Canada, the United States, France, Ireland, and, as of this week, New Zealand. All told, those courses have registered more than 127,000 learners and conferred professional qualifications to more than 19,000 agents in 130 countries who have successfully completed the course requirements.

Aside from the huge demand for training on the part of agency-based counsellors, perhaps the biggest takeaway from this review is that training courses can form an important part of a larger quality assurance mechanism, especially where they are explicitly incorporated into national or international models for quality assurance.

Validating and vetting the agency

If codes of conduct set a threshold of professional standards for both agencies and individual counsellors, and training advances the qualifications and professional development of agency-based counsellors, the last piece of the self-regulatory puzzle would appear to be verifying the bona fides, good practices, and compliance of the agency itself. This is where agency accreditation comes in.

There are lots of different mechanisms in the marketplace to screen or check agency qualifications. These especially include the requirements of the 14 national agency associations that comprise the supranational agent body (Federation of Education and Language Consultant Associations). They also include the vetting that occurs within the agent networks maintained by pathway providers, such as or . Similarly, event organisers, such as or , pre-screen agents that join their networking events. And of course many institutions or schools will conduct their own vetting of agent partners.

Against that varied backdrop, there are only two fully articulated agency accreditation programmes globally. One is administered by the (AIRC), and the other is the (IAS) programme. (Please note that in the United States, where AIRC is based, the term “certification” is more commonly used than is “accreditation.”)

AIRC has been certifying agencies since 2009. Its process is extensive, encompassing five broad areas of agency operation and a combined that agent-applicants must satisfy in order to earn the AIRC Certification seal. To date, 163 agencies have been certified and 107 are active-certified members. The process typically takes nine months, sometimes more or less. Agencies are initially accredited for a five-year term and, pending a successful reassessment in year five, may be renewed for subsequent ten-year terms.

Reflecting on the role of such accreditations, AIRC’s Director of Operations and Certification Jennifer Wright says, “They are designed to provide a full vetting of the agency company and recruiting operations and can be wholly accepted as a qualification for institutions to partner with an agency, or they may complement an individual institution’s agency vetting efforts. I’ve had institutions send staff to our reviewer training at AIRC with no intention of working on agency reviews for us. But they are going to use those skills in their own due diligence work in evaluating new agencies or agency performance, and the AIRC certification gives them a running start on their own engagement with the agency.”

Meanwhile, the IAS, says Tony Lee, Ϲ’s Chief Vision Officer, has become the de facto global standard for agency quality assurance and represents the “the highest common denominator of good agency practice in all of the major study destinations.”

The programme reached an important milestone earlier this year with the accreditation of its 2,200th agency across 127 countries. Another 1,000 agencies are currently in the midst of a comprehensive vetting process that includes reference checks, operational audits, and extensive document verification.

Agencies are reassessed annually, and agent compliance with accreditation requirements, including the Ϲ Code of Conduct, is overseen by Ϲ’s global agent team, which currently numbers more than 30 staff across 16 countries.

“In order to be a true standard for the industry, any accreditation scheme needs to be credible, accessible by a wide variety of agencies, and administered by a market-neutral organisation with global reach and expertise,” adds Tony Lee. “These are the core ingredients of IAS, and it’s why we are seeing such rapid adoption of this accreditation model by agents and industry stakeholders alike.”

For additional background, please see:

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Ϲ announces new agent code of conduct /2023/11/icef-announces-new-agent-code-of-conduct/ Wed, 01 Nov 2023 13:55:41 +0000 /?p=40233 The following article is adapted from the upcoming edition of Ϲ Insights magazine. The print edition will be available at Ϲ Berlin with the digital edition freely available to download as of 2 November 2023. The article also departs somewhat from our normal coverage on Ϲ Monitor, in that it is explicitly concerned with a…

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The following article is adapted from the upcoming edition of Ϲ Insights magazine. The print edition will be available at Ϲ Berlin with the digital edition freely available to .

The article also departs somewhat from our normal coverage on Ϲ Monitor, in that it is explicitly concerned with a new initiative from Ϲ. We don’t normally highlight Ϲ’s programmes and services in our ongoing coverage but we’re making an exception in this case as we believe the subject is especially relevant and important for our readers.

The international education marketplace is more complex than ever. A greater number
of destinations – and education institutions – are competing for students’ attention. The range of available study programmes has expanded and now includes online and hybrid modalities. Students consider not only course content, but also scholarships, internships, and post-study work and permanent residency opportunities.

As a result, both students and educators are increasingly turning to agents for support. Students rely on agents to help them to plan study abroad, compare options, and apply to institutions. Institutions appreciate the local expertise and connections of agents when diversifying their markets, promoting a wider variety of programmes, and communicating across languages, religions, and cultures.

Greater use of agents has underscored the need for improved quality standards for institution-agency collaborations. Several best practice guidelines now exist, some developed by governments and peak bodies and some created by other stakeholders.

Despite having been developed at different times and in different contexts, the resources listed below all aim to codify best practices for educators and agents alike. Persistent themes include honesty, accountability, and transparency in agency-educator partnerships and in communications and transactions with students.

  • The London Statement framework (formally, The Statement of Principles for the Ethical Recruitment of International Students by Education Agents and Consultants)
  • The Guide to International Student Recruitment Agencies from the National Association for College Admission Counseling (NACAC)
  • The National Code of Ethical Practice for UK Education Agents from British
  • Universities’ International Liaison Association (BUILA)
  • The Australian Agent Code of Ethics (ACE)
  • Best Practice Guidelines for Institutional Members from the Association of International Enrollment Management (AIRC)
  • Best Practice Guidelines for Education Providers and Agents from The Association of Language Travel Organisations (ALTO)

A new code of conduct governing Ϲ-approved agencies

For the past year, Ϲ has been engaged in a process of deep reflection on these important themes, leading to the development of our own Code of Conduct. This is a code of practice that agencies are now required to endorse and comply with in order to establish or maintain their Ϲ Agency Status and their eligibility to attend Ϲ events.

“The increasing use of education agents in international recruitment also underscores the need for improved quality standards,” says Ϲ CEO Markus Badde. “The number of active agents continues to grow quickly yet the sector still remains largely unregulated. For decades we have consistently worked to advance professional standards in international student recruitment by screening, training and accrediting education agencies. Given current circumstances we feel there is now a need to do more. Over a year ago, we introduced block chain technology enabling students, parents, and educators to easily and instantly verify an agency’s IAS accreditation. Now we have gone even further with the implementation of a more in-depth vetting process for participating agencies, with increased agent monitoring and quality assurance measures carried out by Ϲ’s globally distributed Agents Relations team.”

There are currently over 1,500 education agencies in 115 countries who have been
accredited and have Ϲ Agency Status – a designation that is valid for one year and for which the vetting and review process is refreshed annually. This fast-growing base of IAS agencies already represents the largest network of accredited agencies in the industry, and, as such, represents a new global standard for agency recognition and quality assurance.

“Having a trusted source of accredited agencies around the world is imperative, particularly at a time when lower barriers to entry have created a proliferation of new agency players” says Ϲ’s Executive Director for Agent Relations Tiffany Egler. “With the Ϲ Code of Conduct in place, and with the steps we have taken to expand the IAS programme, schools, colleges, and universities can now be better assured that they are working with professional organisations to ensure the best possible outcomes for their international students.”

The complete code appears below, and we hope it will be helpful both for educators
working with agents and for agents who aim to distinguish themselves in an increasingly competitive marketplace.

Ϲ Code of Conduct for the Ethical Recruitment of International Students

Agency owners and executives are straightforward, transparent, and accountable at all times and in all dealings with staff, institutions, students, parents, and other stakeholders. This includes ensuring that they and their staff are:

  1. Acting fairly and in the best interests of both students and institutional partners.
  2. Providing current, accurate, and honest information.
  3. Providing realistic and appropriate information that is tailored to the individual student, particularly in relation to language ability, financial capacity, and intended study programme.
  4. Ensuring that visa and admissions applications are free of any fraudulent or misleading documents or representations.
  5. Being transparent in all business dealings and advisory services, including avoiding any conflicts of interest or misrepresentation.
  6. Prioritising the use of signed agreements or contracts between the agency and the institution and being transparent with both students and receiving institutions in cases where a student may be referred outside of any such formal agreement.
  7. Disclosing to partner institutions whether any contracted subagents may play a role in recruitment and ensuring appropriate oversight or quality assurance measures to monitor subagent compliance with this code of conduct.
  8. Preserving the confidentiality of all personal and business information.
  9. Ensuring that minor students have adequate representation and support from a parent, guardian, and/or legal counsel.
  10. Representing accurately the rights and responsibilities of the student in their intended destination country.
  11. Complying with all relevant laws and regulations in both the agent’s home country and the student’s intended destination.
  12. Promoting a government or industry endorsement – including the use of any official brand marks – only with the approval of the endorsing body.
  13. Using an institution’s officially approved material, including branding or any official marks, only in cases where a written agreement with that institution provides for such use.
  14. Ensuring that all advertising and marketing materials are free of misrepresentation and comply with both local advertising standards and the brand guidelines of partner institutions.
  15. Ensuring the quality of the student experience through effective mechanisms to gather feedback and otherwise monitor a student’s progress in their study abroad destination.
  16. Establishing clear processes for handling complaints and resolving disputes.
  17. Participating in appropriate industry training programmes where possible and appropriate, as well as training and site visits specific to individual institutions.
  18. Maintaining membership in appropriate professional associations and other standards-based bodies, where possible and appropriate.
  19. Working with stakeholders and colleagues to advance industry standards and best practices.
  20. Maintaining all required business licences and/or registrations.

For additional background on the Ϲ Agency Status programme, please see .

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NACAC changes code of conduct to allow international agents; releases agent guide for US institutions /2014/09/nacac-changes-code-conduct-releases-agent-guide/ Thu, 25 Sep 2014 15:16:28 +0000 /?p=13752 “In 1951, NACAC introduced a prohibition on incentive-based recruitment of students for all NACAC members,” explains Eddie West, director of international initiatives at the National Association for College Admission Counselling (NACAC). Earlier this month, Mr West opened a special panel discussion – “International student recruitment strategy: assessing the use of commission-based agents” – at the…

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“In 1951, NACAC introduced a prohibition on incentive-based recruitment of students for all NACAC members,” explains Eddie West, director of international initiatives at the National Association for College Admission Counselling (). Earlier this month, Mr West opened a special panel discussion – “International student recruitment strategy: assessing the use of commission-based agents” – at the annual NACAC conference in Indianapolis (18-20 September).

The prohibition on education agents that Mr West refers to was originally enshrined in NACAC’s Code of Ethics, now known as the Statement of Principles of Good Practice (SPGP), a document that effectively codifies the ethics and standards of conduct for the association.

The past decade has seen an expansion of active international recruitment efforts on the part of a wider field of US institutions, and a corresponding increase in the use of education agents by some universities and colleges. This triggered a growing debate within NACAC about the standing prohibition in the SPGP and the extent to which it could or should apply to international recruitment.

That debate was increasingly a subject of global interest in recent years as well. It culminated with the establishment of a Commission on International Student Recruitment within NACAC, which subsequently recommended to the NACAC Board that the association modify its official position on the use of international agents. In September 2013, the NACAC Assembly voted to modify the SPGP to permit the use of international agents, so long as institutions maintained transparency, accountability, and integrity in their dealings with commissioned representatives overseas.

The official amendment

Following that vote, the NACAC Admission Practices Committee was charged with the responsibility of “fleshing out” those key principles of transparency, accountability, and integrity and determining how they could best be reflected within the SPGP.

Todd Rinehart, director of admissions at the University of Denver and chair of the NACAC Admission Practices Committee introduced the committee’s proposed amendments in Indianapolis.

As Mr Rinehart explained, the committee’s deliberations resulted in a reframing of the proposed 2013 amendment to create a new Section I.A.4 within the SPGP. It reads in full:

“I.A.4. All members agree they will not employ agents who are compensated on a per capita basis when recruiting students outside the United States, unless ensuring they and their agents conduct themselves with accountability, transparency and integrity;

Members will:

a. ensure institutional accountability by monitoring the actions of those commission-based agents acting on the institution’s behalf;

b. ensure transparency with a conspicuous statement on their website that indicates their institution uses agents who are compensated on a per capita basis;

c. ensure integrity by dealing ethically and impartially with applicants and other stakeholders, honoring commitments and acting in a manner that respects the trust and confidence placed in the institutions and the individuals representing them;

d. adhere to US recruitment and remuneration laws (US Higher Education Act) for US citizens, where applicable;

e. not contract with secondary school personnel for remunerations for referred students.”

“Per capita compensation” indicates that agents are compensated, normally on commission, based on each student recruited. Mr Rinehart also noted that NACAC will place a moratorium on enforcement of the amendments until September 2015, in order to give US institutions the opportunity to put policies and processes in place for compliance.

The amendments were voted and approved by the NACAC Assembly on September 20, 2014.

Some observers, including Inside Higher Ed, have pointed out that the amendment quoted above than did the wording approved by the NACAC Assembly in 2013. “While the language approved by the NACAC Assembly last year reads that ‘Members who choose to use incentive-based agents when recruiting students outside the US will ensure accountability, transparency and integrity,’ [the now-approved amendment states] that members will ‘not employ agents who are compensated on a per capita basis when recruiting students outside the United States, unless ensuring they and their agents conduct themselves with accountability, transparency, and integrity.’”

A new guide for universities and colleges

The process of framing and reframing the SPGP amendment is a result of the varying perspectives within NACAC that the association must balance as it works to reflect emerging practices, including appropriate and effective engagement with education agents, within its code of conduct.

In a further illustration of this careful balance, the NACAC International Advisory Committee also released a new guide for the association’s 13,000+ members – ”International student recruitment agencies: a guide for schools, colleges and universities” – on the eve of this year’s conference.

The guide is meant to expand and illustrate the key principles of accountability, transparency, and integrity in the SPGP amendment, and it unpacks each of these core concepts in some detail.

The introduction of the guide sets out that, “Should an institution decide to work with international student recruitment agencies, the following steps should be taken to ensure accountability, transparency and integrity:

  • Consult with critical campus constituents to address campus impacts.
  • Develop a unified or coordinated institutional policy concerning international student recruitment agencies.
  • Communicate the institution’s agency policy to international students and their families, via the institution’s website.
  • Develop a contract, involving campus legal counsel, risk management and affiliated departments.
  • Identify and vet prospective agency contractors.
  • Commit to delivering regular trainings and other elements of rigorous, continual quality assurance.
  • Provide international student support services commensurate with the expected growth and diversification in enrolments.”

The NACAC guide is otherwise designed to help US universities engage effectively with international agents and includes considerable background on recruitment agencies, identifying and vetting prospective agents, contracts and other legal considerations, training and supporting agents, and other best practices.

Mr West says of the new guide, “NACAC felt it was important to produce a resource that would promote best practices among institutions working with international student recruitment agencies, and one that included tangible steps schools could take to safeguard students’ interests, as well as their own. Absent a strong regulatory framework in the US – home to the majority of NACAC members – we believe individual institutions bear special responsibility to ensure they’re doing all they can in this regard. Ultimately we hope the guide and our future efforts contribute to an ongoing and global conversation about quality assurance in international student recruitment, admissions, and support.”

He notes as well that NACAC has a number of related initiatives upcoming in the months ahead.

  • In November or December of this year, the association will offer a webinar for US institutions on working with agents, with a particular focus on related legal issues.
  • Also later this fall, it will begin to circulate samples of agent contracts and other relevant documents among its members.
  • In early 2015, NACAC will also publish a resource guide for international students and parents to educate them about working with education agents.

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