EduQuantica Ltd – Sub-Agent Onboarding Policy

Purpose and scope

No sub-agent may recruit, counsel or refer students for EduQuantica Ltd until they have passed due diligence, signed our agreement and completed training. This policy makes sure sub-agents meet the National Code of Ethical Practice for UK Education Agents, the UK Agent Quality Framework, and our contractual duties to partner universities, which hold us responsible for every agent in our network.

It applies to every individual or business that refers, counsels or submits applications for students through EduQuantica, in any country, whether paid by commission, fee or any other benefit.

Eligibility

A sub-agent must:

• be a legally registered business, or a self-employed individual where local law allows;
• hold any licence required to recruit students in their country;
• have at least one counsellor holding the British Council UK agent and counsellor certificate, with all counsellors certified within 3 months of approval;
• not be under investigation for, or have a record of, fraud, bribery, money laundering or immigration offences;
• not appear on any UK, UN, EU or US sanctions list;
• not already be terminated or blacklisted by any UK provider for compliance reasons.

Due diligence checks

We rate each applicant Low, Medium or High risk. High-risk applicants, such as those in high-refusal markets, with incomplete ownership details or adverse media, need a director's approval and enhanced checks, including a video interview and site visit.

Onboarding steps

1. Application. The sub-agent submits the application form and evidence above.
2. Due diligence. The Compliance Officer completes checks and risk rating within 10 working days.
3. Interview. A video or in-person interview with the business owner and lead counsellor.
4. Approval. The Compliance Officer approves (or a director, for High risk). Reasons for refusal are recorded.
5. Agreement. Both parties sign the Sub-Agent Agreement, the Code of Ethical Practice, and the Anti-Bribery, AML and Data Protection undertakings.
6. Training. The sub-agent completes EduQuantica induction covering our partner providers, UKVI rules, document checks, safeguarding and data protection.
7. Activation. We issue a sub-agent CRM access. The sub-agent is added to our sub-agent register and declared to partner providers where the provider's contract requires it.
8. Probation. The first 6 months are a probation period with closer monitoring, including review of every application before submission.

Sub-agent obligations

Every sub-agent must:

• follow the national code and EduQuantica's Code of Ethical Practice;
• tell students they are working with EduQuantica, and that EduQuantica is the contracted agent;
• use only EduQuantica-approved marketing and never use provider logos without approval;
• never charge students undisclosed fees, hold student money or take tuition payments;
• never submit, alter or advise on false documents;
• protect student data under our Data Protection Policy and report any breach within 24 hours;
• report complaints from students to us within 5 working days;
• complete refresher training every year and keep counsellor certifications current;

Monitoring and annual review

We monitor each sub-agent monthly and review them formally every year, in line with the September–December review cycle our partner providers use.

Results are rated Red, Amber or Green. Amber leads to a written improvement plan with a 3-month deadline. Red, or a second Amber, leads to suspension pending review.

Suspension and offboarding

We may suspend or end a sub-agent agreement immediately for fraud, bribery, money laundering, misuse of student money or data, or a serious breach of the national code. We may also end it on notice for repeated poor performance.

On termination we:

1. remove system access the same day;
2. take over or reassign all active students, so no student is left without support;
3. recover all student records and confirm deletion of any copies held by the sub-agent;
4. inform affected partner providers where required;
5. withhold commission linked to any breach, as the agreement allows;
6. record the reason in the sub-agent register.

Records and review

We keep due-diligence files, agreements and monitoring records for 6 years after the relationship ends. The Compliance Officer owns this policy and the board reviews it every year.