Agent Recruitment and Performance Management Policy

1. Policy

High Gate (High Gate) has a firm recruitment, monitoring and termination practices in place for Education Agents that recruit students for High Gate. High Gate takes all reasonable measures to only use Education Agents that have appropriate knowledge and understanding of the Australian Education Industry and does not use education agents who are dishonest or lack integrity.

This policy covers the recruitment, management and termination of Education Agents and their compliance with High Gate obligations under the ESOS Framework.

2. Related Documents

Education Agent Application Form
Education Feedback Form
Education Reference Check
Education Agent Agreement

3. Relevant Legislation

National Code (2018), Standard 7
The Migration Act 1958

4. Policy and Procedure

Education Agent Appointments

High Gate enters into a formal written agreement that governs the appointment of Education Agents engaged to represent High Gate.
High Gate does not accept students from an Education Agent if it reasonably suspects that the Education Agent, their employee or sub-contractor:
Engaged in, or previously involved in dishonest practices, including the deliberate attempt to recruit a student, where it conflicts with National Code Standard 7.
Facilitated the enrolment of a student who the Education Agent believes will not comply with the student visa conditions.
Provided immigration advice where it is not authorised under the Migration Act.

Education Agent Recruitment Procedure

Agent Application

Provided immigration advice where it is not authorised under the Migration Act.
The Education Agent completes the Application to become an Agent and sends it to the Director of Marketing , along with:
Business details including
Business name
Name of the contact person
Postal, email, website and telephone
Primary countries of operation
Membership of Professional Associations
Other (Refer to Agent application form:

Assessment for suitability

  1. The Director of Marketing assesses the application based on:
  2. The quality of the documentation provided by the agent
  3. The applicant’s business references
  1. The Director of Marketing ensures that the education agent declares and takes all reasonable steps to avoid conflicts of interest with its duties as an education agent of High Gate. Examples of conflicts of interest include, but are not limited to:
  2. When the agent charges services fees to both overseas students and registered providers for the same service;
  3. Where an education agent has a financial interest in a private education provider; or
  4. Where an employee of an education agent has a personal relationship with an employee of the education provider.
  1. If the application from Education Agent is successful it is signed off by the Director of Marketing or CEO. The Director of Marketing provides the Education Agent with a High Gate Education Agent Agreement and access to all relevant High Gate current marketing and promotional documents etc including the High Gate Student Handbook, the course flyers/brochures, High Gate course intake dates and fees and charges and other marketing material that may assist the agent to represent High Gate .
  2. An Agent Profile is created by the Director of Marketing on the High Gate , and ensures PRISMS and ASQAnet are updated.

If the application is incomplete, the Director of Marketing advises the Education Agent that the application will not be processed until all required information is provided. The agent is reminded of the same through email reminder, the application is not processed until all the documentation are submitted.

Where applicants are not successful, the Director of Marketing advises the applicant accordingly.

Education Agent Approval

  1. Successful applicants are provided with an Education Agent Agreement, which must be read, understood, signed and sent back to High Gate before the Education Agent is approved.
  2. The duties and responsibilities of High Gate and the Education Agent are listed in the High Gate Education Agent Agreement.
  3. Upon receipt of the signed Education Agent Agreement, High Gate sends a formal and written letter advising of the decision.
  4. Approved agents is provided with High Gate promotional materials and is given an induction.
  5. All approved agents are provided with a High Gate Agent confirmation notice.
  6. All approved agents are placed on High Gate Education Agent Register on the PRISMS, ASQAnet, and the High Gate website.
  7. ASQAnet is updated via ASQAnet no more than 30 days after the agent has been approved.
  8. All approved Education Agents have an Education Agent file which holds the Education Agent Agreement and any other relevant documentation between High Gate and the Education Agent. The files are stored by the Director of Marketing.
  9. The Director of Marketing ensures that all marketing, promotional and relevant High Gate policies and procedures are updated and that the information is passed immediately to its approved Education Agents to ensure prospective students are provided only with accurate and current information.
  • Education Agent Agreements are approved according to the agent agreement, which are renewed dependent upon performance and student feedback.

International Education Agent Remuneration

  1. International Education Agents are remunerated by High Gate in form of a marketing contribution for particular services or events, or payment of commissions based on enrolments attributable to the agent.
  2. The amounts payable, and terms of payment are an agreement between the individual Agency and High Gate.
  3. Any other conditions are specified in the Education Agency Agreement.

Communication with International Education Agents

  1. Management of the activities of the agent network is primarily the responsibility of the marketing department, High Gate ensures there is timely and relevant communication with its International Education Agents by maintaining:
    1. Contact via emails, phone calls, other electronic media.
    2. Copies of communications relating to updates, commission payment and individual Agency Agreements are retained by the Director of Marketing.

Promotional Material, Events, Training and Meetings

The Director of Marketing is responsible for the development of promotional materials.

  1. International Education Agents are notified of the availability of new material through communication by the Director of Marketing .
  2. International Education Agents who request materials are referred to the Director of Marketing.
  3. Where International Education Agent visits are arranged, Director of Marketing undertakes the following activities based on the agent’s needs:
  4. Training and update of the High Gate courses, prices and other information
  5. Workshops for promotion and marketing
  6. Updates about courses and changes to agreement or standards.
  7. Meetings held via audiovisual connection (Skype, WhatsUP, WeChat) are documented by the Director of Marketing
  8. The Director of Marketing is responsible for such communication and takes every opportunity both in Australia and overseas, to ensure that there is regular and ongoing communication with agents

Monitoring and Review

The Director of Marketing reviews each agent’s performance and activities every annually. This review helps ensure Highgate International College has good understanding of its agents’ performance over time and that training can be targeted.

The review may include:

  • Analysis of quality and quantity of applications on behalf of prospective students
  • Analysis of conversion rates from applications lodged to actual enrolments at High Gate
  • Analysis of visa grants and refusals for High Gate 
  • Adherence to High Gate admissions processes
  • Progress and conduct of students
  • Analysis of recorded instances where a student claims to have been misinformed by the agent about his or her studies at High Gate; and/or
  • The number of recorded instances where the agent has shown a lack of knowledge of student visa requirements or other matters relating to a student’s stay in Australia.

Where monitoring processes indicate a deficiency or non-compliance with legislation or the National Code, training and/or the provision of additional information in relation to the expectations of High Gate will be provided specific during visits to an Education Agent’s office or online.

Agents found to be in breach of the Education Agreement and or the Standards, or where complaints have been received by a student, are contacted by the Director of Marketing . The Director of Marketing may terminate an agent’s agreement if deemed necessary.

Where any practices by an Education Agent are identified as being negligent, careless or incompetent or being engaged in false, misleading or unethical advertising and recruitment practices, or engaged in practices that could harm the integrity of the High Gate or Australian education and training, the Director of Marketing takes immediate corrective and preventative action.

Education Agent Termination

Where High Gate becomes aware of, or reasonably suspects that an Education Agent, their employee or sub-contractor has breached High Gate Education Agent Agreement, the ESOS Act 2000, or the National Code 2018, High Gate terminates the agreement. This includes, but is not limited to the Education Agent, their employee or subcontractor:

  1. Being engaged in, or being previously engaged in dishonest practices, including the deliberate attempt to recruit a student where this clearly conflicts with the obligations of the registered provider under the National Code 2018.
  2. Facilitating the enrolment of a student who the education agent believes will not comply with the conditions of his or her student visa.
  3. Providing immigration advice where not authorised under the Migration Act 1958 to do so.

The Director of Marketing may terminate and Education Agreement at any time, or may decide not to renew the agreement. Reasons for both must be recorded in the Agent Profile.

Terminated agreements or agreements that are not renewed are marked as inactive in the High Gate system, ASQAnet and PRISMS, and will be updated on ASQAnet accordingly.

Education Agents may appeal any decision made by High Gate , in line with High Gate Complaints and Appeals Policy.

Link to Agent List

Education agents are an important part of the international education sector in Australia. High Gate ensures that our education agents act ethically, honestly and in the best interest of overseas students and uphold the reputation of Australia’s international education sector.

Find a reputable Education Agent from our list of Registered Education Agents or suggest a new Agent to us.

Agency List