Insight Institute of Further Studies (IIFS) must:
• have a written agreement with each education agent they engage with;
• enter and maintain education agent details in Provider Registration and International Student Management System (PRISMS);
• ensure education agents have appropriate knowledge and understanding of the Australian International Education and Training Agent Code of Ethics;
• ensure education agents act honestly and in good faith;
• take immediate corrective action, or terminate a relationship if an agent (or an employee or subcontractor) is not complying with the National Code; and
• not accept overseas students from an education agent if it knows or suspects that the education agent is engaging in unethical recruitment processes.

The written agreement must outline:
• IIFS’s responsibilities, including for compliance with the Education Services for Overseas
Students Act 2000 (ESOS Act) and National Code 2018;
• the requirements of the agent in representing Insight Institute of Further Studies (IIFS);
• Insight Institute of Further Studies (IIFS)’s processes for monitoring the education agent’s activities and ensuring the education agent gives overseas students accurate and up-to-date information;
• the corrective actions that may be taken and the grounds for termination of the written agreement with the education agent; and
• the circumstances which information about Insight Institute of Further Studies (IIFS)may be shared by the registered provider and Commonwealth or state and territory agencies.

Education Agents
Insight Institute of Further Studies (IIFS)must ensure the education agents they engage with act ethically, honestly and in the best interest of overseas students. This means that IIFS must ensure its education agents declare and take all reasonable steps to avoid conflicts of interest with its duties as an education agent of IIFS. This provision is to ensure transparency in the education agent’s activities.

Examples of conflicts of interest include, but are not limited to:
• when the agent charges services fees to both overseas students and IIFS for the same service;
• where an education agent has a financial interest in a private education provider; or
• where an employee of an education agent has a personal relationship with an employee of IIFS.

IIFS must also ensure education agents observe appropriate levels of confidentiality
and transparency in dealings with overseas students while acting honestly and in good faith.

Education agents must also have appropriate knowledge and understanding of the overseas education system in Australia, including the Australian International Education and Training Agent Code of Ethics.

IIFS should ensure any education agents they engage with, including offshore agents, have up-to- date and accurate marketing information.

The Australian International Education and Training Agent Code of Ethics is based on the
London Statement. These requirements ensure education agents adhere to and practice responsible business ethics, and that education agents understand their obligations to provide current, accurate and honest information to overseas students to help them make informed decisions about study in Australia.

Immediate corrective actions
• IIFS must take immediate corrective action if they are aware that or believe the education
agent or its employee or subcontractor, have not complied with the education agent’s responsibilities under Standard 4. Corrective actions may include providing education agents with additional information or targeted training on expectations of the agent.
• If IIFS becomes aware, or has reason to believe that an education agent is engaging in false or misleading recruitment practices, they must immediately terminate their relationship with the agent.
• If the false or misleading recruitment practices were engaged in by an employee or subcontractor of the education agent, IIFS must require the education agent to terminate its relationship with those individuals.
• IIFS must not accept students from education agents if they believe the education
agent is engaging in unethical recruitment practices. This includes education agents that provide migration advice to overseas students when they are not authorised to do so under the Migration Act 1958.
• IIFS must not accept overseas students from education agents that engage in, or have previously engaged in, dishonest recruitment practices. This includes education agents

knowingly recruiting an overseas student in conflict with the registered providers’
obligations under Standard 7 (Overseas Student Transfers).
• IIFS must not accept overseas students from education agents if they believe the education agent is creating Confirmation of Enrolments (CoEs) in PRISMS for non bona fide overseas students or facilitating the enrolment of overseas students while knowing that the overseas student will not comply with the conditions of their visa.