These policies and procedures aim to provide direction on the appointment, certification, management, and termination of external third-party agencies and to establish a framework for the ethical, efficient, and consistent recruitment of international students by approved recruiting agencies on behalf of Keiser University (hereinafter as KU).

These policies and procedures apply to all international student recruiting agencies engaged by KU.

• Agency Agreement refers to the contract between KU and an international student recruitment agency that outlines the terms and conditions under which the services of the agency are provided.
• Agency Code of Conduct (ACC) outlines the principles and standards that all agencies accept and observe when acting on behalf of KU.
• Certification refers to the proof that an agency is certified as a KU partner based on their compliance with the standards, responsibilities and practices set forth in KU’s Policies & Procedures, the ACC and Agency Agreement.
• International Student Recruitment Agency (Agency) is a commercial, external third-party that is authorized to recruit students for KU through a formal agency agreement. The agency is paid a one-time commission for each successful student enrollment. Agencies can be self-incorporated individuals, privately-owned partnerships, publicly traded corporations, or agent aggregators. Agencies can also include education portals, professional associations, education institutions or other entities that are monetarily compensated for their recruitment of students on behalf of KU.

Only agencies that have signed Agency Agreement with and are certified by KU are authorized to represent and recruit students on KU’s behalf. If there is any conflict or inconsistency between the terms and provisions of this policy and the Agency Agreement, the provisions of the Agency Agreement shall prevail.

• KU is responsible for having contractual oversight of the Agency, including its selection, certification, training, management, renewal, and termination.
• KU shall manage Agency’s compliance with all relevant KU policies, particularly those related to agency training, support, and performance review.
• KU shall train the Agency during its onboarding and throughout the term of its engagement.
• KU shall manage and mitigate all reputational and other risks associated with the Agency.
• KU shall collaborate with stakeholders on Agency and relationship management.
• KU-certified Agency is responsible for acting professionally and ethically in accordance with KU’s Policies & Procedures, the Agency Code of Conduct (ACC), the conditions of the Agency Agreement and other KU’s operational policies.

KU shall establish clear criteria for selecting recruiting agencies, considering factors like reputation, expertise, compliance with laws and regulations, ethical standards, and previous performance. KU will conduct and document due diligence when assessing the suitability of prospective Agency against appropriate criteria that includes the following of the Agency:

• Student recruitment experience and application success rates
• Business location and online presence
• Business conduct, annual plans, and marketing samples
• Knowledge of KU and the American higher education system
• Demonstration of the ability to comply with the ACC
• Clearance from international sanctions
• Reference check and feedback

• It is preferred that the Agency holds valid certifications through the American International Recruitment Council (AIRC) and/or International Consultants for Education & Fairs (ICEF).
• The Agency shall operate in accordance with the industry standards and ethical principles, such as NAFSA Statement of Ethical Principles, and/or AIRC Quality Standards
• The Agency shall have a reputation and a market scope to effectively promote KU and its programs.

• Agency interested in recruiting for KU must submit an application for approval. A vetting process will be conducted to evaluate its eligibility. KU will collect and record sufficient information to screen the Agency.
• Approved Agency will enter into a formal agreement with KU outlining their roles, responsibilities, and compensation terms. KU shall draft and sign an Agency Agreement with the Agency that meets the criteria listed in section III-a of this KU International Student Recruitment Agency Policies & Procedures (Policies & Procedures) and demonstrates a commitment to comply with the ACC.

• KU shall certify that the Agency has fulfilled all the conditions in the Agency Agreement and has received onboarding training. Only certified Agency can recruit students on KU’s behalf.

• KU shall document and maintain records of Agency Agreement, due diligence undertaken and certification.

• A provisional Agency Agreement may be issued under exceptional circumstances, such as when conditions dictate an accelerated response.

• KU shall conduct initial training session(s) for all newly appointed agencies.
• KU shall maintain regular contact with the Agency and advise it via written communication, telephone, virtual meetings and/or in-person visits to provide updates to training or to refresh marketing materials including updated academic program, school, and admission information; revisions to procedures and application processes; information regarding relevant policies and/or changes to legal or regulatory conditions; branding guidelines including the use and placement of KU’s name, logos & symbols, and other promotional materials.
• Agency is expected to undertake at least one training session with KU, which will be made available by KU to the Agency via in-person or virtual session(s).
• Agency is responsible for familiarizing itself with academic program changes, policies, admissions, marketing materials, application processes, visa regulations and other applicable information

• Non-Discrimination: Agency must adhere to non-discrimination principles and actively promote diversity in the student body.
• Accuracy and Truthfulness: Agency is required to provide accurate and truthful information to prospective students about KU, its programs, fees, and other relevant details.
• Conflicts of Interest: Agency must disclose any potential conflicts of interest that may compromise the integrity of the recruitment process.

• Compensation Structure: The compensation structure for the Agency will be clearly defined in the agreement. KU shall maintain transparency in commission rates and payments.
• Timely Payments: KU shall ensure timely and accurate commission payments to the Agency in accordance with the Agency Agreement.
• Commission payments and any other funds or remittances payable to the Agency shall only be transferred to the contractual Agency.
• KU reserves the right to withhold payments to the Agency who is in violation of these Policies & Procedures and/or the conditions outlined in the Agency Agreement.

• Admission Standards: Agency shall be informed about KU’s admission standards and processes, ensuring its promotion to qualified candidates.
• Application Assistance: Agency shall guide applicants through the application process, helping with documentation and providing support where needed.
• Visa Guidance: Agency shall offer additional guidance and assistance to students with visa applications, ensuring compliance with immigration laws.

• Performance Metrics: KU shall define key performance indicators (KPIs) to measure the effectiveness and ethics of the Agency.
• Regular Reporting: Agency must submit regular reports on its activities, including student applications, admissions, and other relevant data.
• Monitoring and Evaluation: KU shall conduct periodic evaluations of the Agency to ensure compliance with these Policies and Procedures. KU shall monitor contracted Agency’s website and other media (e.g., social) on a regular basis to ensure accurate and current representation of KU-related information, including adherence to the terms and conditions for applications and admission. KU may randomly inspect the Agency virtually or during on-site visits across any of the elements listed in the Review and Renewal section.
• Agency who misrepresents KU is subject to the corrective action outlined in the Corrective Action section.
• KU shall collect information and maintain records of the outcomes of all Agency’s monitoring and inspection activities whenever possible. KU shall investigate and track any complaints about an agency that are raised by another agency, student, applicant or industry stakeholder. When KU finds complaints against an agency are warranted, the Agency will be subject to the corrective action outlined in the Corrective Action section.
• KU may conduct an audit of an Agency’s compliance with the Agency Agreement, the ACC and these Policies & Procedures at any time.

• KU shall carry out a formal evaluation of the Agency annually or on a regular basis as deemed necessary. KU shall collect the information required to conduct qualitative and quantitative reviews of the Agency’s performance, which can include, but not limited to, enrollment reports, interviews with the Agency and its employees, observations of events and interactions with students, prospective students, and feedback from internal and external stakeholders.
• KU shall perform a full review of the Agency’s performance prior to the renewal of the Agency Agreement. Based on the results of the review, ongoing monitoring, and other factors, KU may or may not re-approve the Agency and/or invite the Agency to renew its Agency Agreement at the end of the current agreement term.
• Re-approval shall require updated training/certification to be completed prior to such motion.

• KU shall issue a written warning to the Agency who is in breach of the Policies & Procedures, the Agency Agreement or the ACC. The warning will specify the infraction, corrective action, and timeframe to complete the corrective action.
• The Agency is required to submit a written response either acknowledging or appealing the warning within ten (10) business days of the warning issuance date. Should the Agency not respond to KU’s warning within this time frame, KU shall move forward with corrective action. KU will review and provide a written response to the Agency’s appeals within fifteen (15) business days of receipt of the appeal. Unless an alternate timeframe is mutually agreed upon by the Agency and KU, the Agency with failed appeals will be given ten (10) additional business days from the time KU communicates its decision to remedy the infraction.
• The Agency identified with unremedied infractions may be subject to some or all of the following actions:
  • Additional training as mandated by KU
  • Restriction of recruitment activities on behalf of KU
  • Lowering of application and/or commissionable-student quotas as applicable
  • Temporary suspension of the Agency’s representation of KU

• The Agency Agreement may be terminated for any reason by either party by sending written notice of termination, which shall be at least thirty (30) days after the date on which the notice is received by the receiving party unless otherwise expressly so indicated in writing by both parties. In the event of a termination, all students’ admissions/recruitment transactions undertaken and completed will be honored.
• The Agency Agreement may not be changed or amended in any fashion without the authorization by KU’s Office of the Chancellor. Any modification, addition, or deletion to the Agency Agreement must be in writing and signed by both parties.
• Where possible, KU will support terminations with available corroborating evidence secured from documented investigative and/or corrective efforts. KU will provide written notification of the termination to the Agency including the grounds for the decision.
• Transitional Period: In case of termination, KU may allow for a transitional period to ensure minimal disruption to students and ongoing applications.

• ​Principle 1: Agents and consultants practice responsible business ethics.
• Principle 2: Agents and consultants provide current, accurate, and honest information in an ethical manner.​
• Principle 3: Agents and consultants develop transparent business relationships with students and providers using written agreements​.
• Principle 4: Agents and consultants protect the interest of minors.​
• Principle 5: Agents and consultants provide current and up-to-date information that enables international students to make informed choices when selecting which agent or consultant to employ.​
• Principle 6: Agents and consultants act professionally.​
• Principle 7: Agents and consultants work with destination countries and providers to raise ethical standards and best practice.​