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1.   Governing policy

These procedures relate to the International Representative Policy (“policy”).

They describe how a decision is made to terminate an international representative’s (“representative”) agreement.

2.   Scope

These procedures apply to staff involved in the process of terminating an International Representative Agreement (“agreement”).

3.   Procedures

These procedures set out the three key processes involved in the termination of a representative’s agreement as per Table 1 below:

1. Proof of evidence

A record of evidence that the representative has breached its obligations under the agreement.

2. Warning/termination of agreement

If a representative performs poorly or breaches their obligations, the Institution may issue a formal warning to the representative or terminate the agreement in writing. 

3. Recording the decision

All decisions to terminate an agreement are recorded on the Institution’s database and any future requests to form an agreement with that representative may be declined.

Table 1.

Process Responsibilities
1. Proof of evidence
The Country Manager submits evidence (or a reasonable suspicion) to the Senior Vice President (SVP) Domestic and International Development (SVPDID) to demonstrate a representative’s poor performance or breach of obligations. This may include but is not limited to:

a. poor performance;

b. participating in false or misleading recruitment practices;

b. deliberately attempting to recruit a student in conflict with the Institution’s obligations under the National Code Standard 7;

c. providing migration advice to international students in breach of migration legislation; or

d. acting in any other manner deemed unacceptable by the Institution.

2. The SVPDID, after discussion with Country Manager, makes a recommendation to the President and Managing Director (President) as follows:

a. a formal warning including corrective action and timelines where appropriate; or

b. terminate the agreement immediately if:

  • the representative is participating in false or misleading recruitment practices OR if it involves an employee or subcontractor, the representative must terminate its relationship with the employee or subcontractor  (as determined by the Institution); or
  • for other reasons as stipulated in the Representative Agreement.
Country Manager

Senior Vice President (Domestic and International Development)

 

2.  Warning/ termination of agreement
1. The Associate Vice President (International Operations) (AVPIO) drafts the warning or termination letter and submits it to the President for approval.

2. The President approves and signs the warning letter or termination letter.

3. The AVPIO sends the warning or termination letter to the representative.

Associate Vice President (International Operations)

President

3.   Recording the decision
1. The AVPIO records all termination outcomes in the Institution’s database.

2. The AVPIO removes the representative’s details from the Institution’s website and Provider Registration and International Student Management System (PRISMs).

3. The AVPIO notifies internal stakeholders of the termination of the representative agreement.

Associate Vice President (International Operations)

4.   Roles and responsibilities

4.1 The Senior Vice President (Domestic and International Development) oversees representative termination practices and makes recommendations to the President on warnings or terminations.

4.2 Country Managers report representative misconduct and provide reasonable proof.

4.3 The President approves representative warnings and terminations.

5.   Compliance and monitoring

These procedures are written in accordance with Standard 4 of the National Code of Practice for Providers of Education and Training to Overseas Students 2018 and Higher Education Standards Framework 2021.

6.   Records management

As detailed in Table 1 above, the termination of a representative’s agreement are recorded in the Institution’s database.

7.   Related documents

International Representative Policy

Monitoring Representatives and Agreement Renewal Procedures

Representative Engagement and Appointment Procedures

Training of Representative Procedures

Approved by the EMG on 20 February 2025